Neil Carman <neil_carman@greenbuilder.com> 
04/03/2008 03:11 AM	To
	<rcra-docket@epa.gov>rcra-docket@epa.gov
	cc
	
	bcc
	
	Subject
	EPA's recognition of Polychlorinated Biphenyls as Persistent, 
Bioaccumulative and Toxic Chemicals
	
	
Sierra Club
April 3, 2008
Stephen Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Resource Conservation and Recovery Act (RCRA) Docket Center
Via electronic submission at <rcra-docket@epa.gov>
Docket ID No.: EPA-HQ-RCRA-2008-0123
Re: EPA's recognition of Polychlorinated Biphenyls as Persistent, 
Bioaccumulative and Toxic Chemicals
Dear Administrator Johnson:
The Sierra Club is submitting additional public comments on the EPA's 
Proposed TSCA Import Exemption rule for Veolia to import up to 40 million 
pounds of PCBs for incineration including a copy of the EPA's web page on 
Polychlorinated Biphenyls from its Persistent, Bioaccumulative and Toxic 
(PBT) Chemical Program. The PCB-PBT information is being submitted to the 
Docket on Veolia's PCB import request because incineration of PCBs runs 
completely counter to the EPA's PBT Chemical Program to work to reduce 
PBTs including Polychlorinated Biphenyls in the nation. The EPA needs to 
do a much better job of disposing of PCBs since incineration is inadequate 
to destroy PCB liquid waste if several thousand pounds are being released 
by incinerators such as Veolia's Port Arthur TSCA permitted commercial 
hazardous waste incinerator.
4) Priority PBT Profiles: Find here the list of priority PBT chemicals for 
which the Agency is developing national action plans. As chemicals are 
added to this priority list, they can be found here. Each chemical also 
has a short chemical profile.
http://www.epa.gov/pbt/pubs/cheminfo.htm
Priority PBT Profiles
This is a listing of the priority PBTs currently being addressed under the 
PBT initiative. Under most chemicals there are chemical profile fact 
sheets and action plans. Action plans for all the chemicals will be added 
as they are developed. The initial page for each chemical has some basic 
background information about the chemical. Aldrin/dieldrin, Chlordane, 
DDT, Mirex, and Toxaphene's action plans all fall under the pesticide 
action plan. For mercury, the link provides access to the chemical profile 
found on the Agency's mercury website.
* aldrin/dieldrin
* mercury
* benzo(a)pyrene
* mirex
* chlordane
* octachlorostyrene
* DDT, DDD, DDE
* PCBs
* hexachlorobenzene    
* dioxins and furans
* alkyl-lead
* toxaphene
Polychlorinated Biphenyls (PCBs)
http://www.epa.gov/pbt/pubs/pcbs.htm
What are Polychlorinated biphenyls (PCBs)?
There are no known natural sources of PCBs in our environment. PCBs are 
either oily liquids or solids, are colorless to light yellow, and have no 
smell or taste. Because they do not easily burn and are good insulators, 
PCBs have been used widely as coolants and lubricants. PCBs are persisten, 
bioaccumulative and toxic (PBT) pollutants that have been targeted by EPA.
Why Are We Concerned About PCBs?
PCBs do not break down in our environment and can have severe health 
effects on humans. PCBs in the air eventually return to our land and water 
by settling or from runoff in snow and rain. In our water, PCBs build up 
in fish and can reach levels hundreds of thousand of times higher than the 
levels in water. Fish consumption advisories are in effect for PCBs in all 
five of the Great Lakes. PCBs are the leading chemical risk from fish 
consumption.
What harmful effects can PCBs have on us?
    * Probable human carcinogen
    * Damages the stomach
    * Skin irritation
    * Liver and Kidney damage
    * Thyroid gland injuries
How are we exposed to PCBs?
    * By eating contaminated fish and shellfish
    * Infants may be exposed through breast milk
    * Unborn children may exposed while in the womb
    * May be in milk, meat, and their by-products
    * Breathing indoor air in buildings where electrical equipment 
contains PCBs
Where can PCBs be found?
Manufacturing of PCBs stopping in the Unites States in 1977 because they 
were found to build up in our environment and cause harmful effects. 
However, we can still find them in our environment, especially in our 
lakes, rivers, and streams.
Current uses:
    * Municipal and industrial incinerators from the burning of organic 
wastes
Potential Sources to our Environment:
    * Poorly maintained hazardous waste sites containing PCBs
    * Illegal/improper dumping of PCB wastes such as transformer fluids
    * Leaks or releases from electrical transformers containing PCBs
    * Improper disposal of PCB-containing consumer products
    * Old microscope oil and hydraulic fluids
    * Old T.V.'s and refrigerators, lighting fixtures, electrical devices, 
or appliances containing PCB capacitators made before 1977.
    * Sediments in the bottom of lakes, river, or our ocean constantly 
release small amounts of PCBs into the environment.
***
Sincerely,
Neil J. Carman, Ph.D.
Clean air program director
Lone Star Chapter of Sierra Club
1202 San Antonio Street
Austin, Texas 78701
tel: 512-472-1767
fax: 512-477-8526
Neil_Carman@greenbuilder.com