Document 25wpdV9j60wkMZ9rxdOeDj3R

tEPAKMEHT CF NSTOiaL KESOOTCES Public Hearing to Review and Receive Public Cement Upon Preposed ASniniatrative Kales Relating to the bischarge of Fdlychlorinated Biphenyls (PCB's) Into the Waters of tte State ) ) ) ) ) Hearing Held August 28 t, 29, 1975 Pages 1 to 75, Inclusive WTM0053? NCR- FOX-0281394 WATER PCB-SD0000041032 appearances xjmxs casspciwnt oo. fcy Eugene Czeracbil, Dewelopuental Engineering Mg*?. 957 H. Ottawa Ave., Chicago, Illinois 0631 BERGSTROM PAHER OCKPANy . by Janes S. Haney, Public Affair* Director Bergstrom Road, Neenah 54956 . and by Richard W. Hand, Administrative Vice President 451 . Peekham St., Neenah 54956 BKW) OOtffiKK George 0.. Reihbaoher,. Director of Sifg. 228 E. Hamilton St., Eau Claire 54701 cm OF HUHAnKEE Sewerage Permission by ' Richard M. Manthe, Supervisee, Lab Services and Quality Control P.O. Bax 2079, Milwaukee 53201 CmimEE TO EXPOSE CAACDCGEN OOVEK-CP Affiliate of Center for Public Presentation by Edward P. Tilflon - 244 Lakelawn Place, Madison 53703 CCtSQUGDATED PARER, SC. *ar Groff Collett, General Manager, Paperboard Products Wisconsin Rapids 54494 ' and by Stratton Martin, Director, Envirormental Affairs - P.O. Bcoc 50, Wisconsin Rapids 54494 . DCW CHMEAL Cenpary by Doon tu Branacn 1702 Bldg., Midlard, Michigan 48640 and by . jofcnC. Safranski Jr., Research Manager 2020 Bldg,, Midland, Michigan 48640 BOH ocaaoto CaEECKU3CH fcy . Dennis C. Besseneckec, New Products Marketing Coordinator ' Midland, Michigan 48640 HSCJSOQC HUSKIES iSSCXSXECOtt Richard Rollins, Vice. President, Engineering Bowen Road, Bennington, Vermont 05201 KAKDEJlIJ PAPER CCHRWOf . Jy William Dryer, Director, Research and Development 200 First Ave. North, Park Palls 54S52 tCKE BOBUS PAPER CO. by Irvin B. Oaths, Attorney - 2U V. Wisconsin Ave., Milwaukee 53203 1 f VTH00538 NCR-FOX-0281395 WATER PCB-SD0000041033 appearances (cant.) GENERAL EIECERIC Cb. *y Stu Richel, Attorney, Environmental Protection One River Road, Schenectady, New York 12345 GNEKAL MOTORS ty . Henry Johnson, St^ervisar, Solid Waste Management Resource Recovery Gi kh Center, Warren, Michigan 48090 - institute cr rarer chemistey tar Dwight B. Pasty, Research Associate 2101 Clover lane, Appleton 54911 . XZAAX WALTCN LEASE CP AMERICA *y . A. X. Forster, State Urea. 3317 Harper Road, Madison 53704 ICEMAN UCN AND METAL CO. fcy Milton Laraan, President US Lorrnan St. Fort Atkinson , KENASHA CCSPCSATICN John Strange Paperboard Division . by ' ' Janes J. Schedgick, Sech Director . 2702 S. telulah Ave., Afpletcn 54911 and by W. Allen Schenck, Vice President Highway 41, Neenah 59546 . . ' MICHIGAN DEPAKMENT CP PUBLIC HEALTH by Harold Humphrey, East Lansing, Michigan MINNESOTA DEPARTMENT CP AGRICULTURAL SERVICES by David itacLean? Director 510 State Office Building, St. Paul, Minnesota 55155 . MINNESOTA DEPARTMENT CP NATURAL RESOURCES iy . award F. Krasch, Aquatic Biologist 390 Centennial Building, St. Paul, Minnesota 55155 MUMESCTA PCILOTICN CCNEROL AGENCY by Marvin E. Beta, Senior Biologist - 1935 W. Co. Id. B2, Roseville, Minnesota 55113 MONSANTO COMPANY ty William B. Papageorge, Manager, Product 800 North Lindbergh Blvd., St. Louis, Missouri 63166' and by Dr. Paul L. Wright, Manager, Toxicology 800 N. Lindbergh Blvd., St. Louis, Missouri 63166 THE NATIONAL ASSOCIATION OF RECYCUNS 31OTSTKEE5 by Howard Ness, technical Vice President 330 Madison Ave., New York City 10017 ' WTM0D539 i N C R-FOX-0281396 WATER PCB-SD0000041034 afperrmebs (Cent.) . NCKEHERN SCOBS POWER CXK>WET tv . Richard Etreetin, Environmental Biologist 100 N. Baratov, Eau Claire 54701 `' ' O'BRIEN GEES ENGINEERS, INC. tv ' Ralph Modurg 910 W. Wingra Drive, Madison 53505 * . . . SHHX IHWBl SSSTB, DC. . by R. A. Shade, President Box 730, Green Bay 54301 . ' gram raasijanyE council by . steyen Sehepler, Setma s Technology Intern . loan 147; North State Capitol, Madison SIKES OF WISCONSIN ' Division of Health of Separtaent of Health 4 Social Services ' by Gacege H. Handy, M.D. - 1 W. Wilson, Bck 309, Madison 53701 . . tKTVERSIT5f ce WISOCNSIN . by . * Linda Weimer, Assistant .Director, Sea Grant College Progxwa 1800 University Ave., Madison 53706 and by Z. P. Tilscn, Bigineer-in-iraining, Hater Resources Canter. 1975 Willow Drive, Madison 53706 . UNITED SCOBS HWIHCMEnL RRHDLT1CN AGEKX tv Karl E. Braner, St A Division 230 S, Dearborn, Chicago, Illinois 60604 . and by . Francis J. Early, Physical Scientist, NEIC, P.O. Bck 25227, Denver, Colorado 80225 and by Billy Fairless 1819 W. Pershing Road, Chicago 60609 and by Itra Kopp, office of Tcodc Substances . ' . Washington', D.C. 20460 .. and by Gilman Veith, Research Chemist, National Water Quality Laboratory 4102 ccoJce St., Duluth, Minnesota 55804 U. S. PISH t WTTnLTTB SHWiCES . by Ear. Maes B. Elder,. Wildlife Biologist pied. Gldg., Ft. Snelling, Twin Cities, Minnesota 55111 U. S. POCD AND DJDG AEKDCSISAnCtl by Henry P. Roberts, Deputy Regional Director 240 Hennepin Ave., Minneapolis, Minnesota 55401 VERSKR, INC. by 6621 Electronic Drive, Springfield, Virginia 22151 3' VTTM00540 NCR-FOX-0281397 WATER PCB-SD0000041035 APPEARANCES (Cent.) WISCONSIN EIZC3KCC POKER CCfrEANI ly . Francis B. Manning, Superintendent, Environmental Planning 231 W. Michigan, Milwaukee 53201 and by . John W. Troglia, Chief Station Engineer (also rep. Kiaocnsin Public Service Ctrp.) 231 W. Michigan Street, Milwaukee 53201 KISCCNSIN PAPER COUNCIL Donald L. Bach, Attorney 121 S. Pinckney St., Madison 53701 and ty 432l'w!*College Ave., Appleton 54911 ' WISCONSIN POWER i LICHT 00. fcy Michael D. Wish, Environmental Specialist 222 W. Washington Ave., Madison 53701 WISCTHSIN PUBtlC SERVICE CCKPCRflTXCN BERGSTROM PAPER COKPAIK fcy Allen W. Killians, Jr., Attorney 777 E. Wisconsin Ave., Milwaukee 53202 WISCONSIN TISSUE MILLS ' fcy Richard C. Peterson, Deink Si$>t. 632 Reed St., tleenah 54956 1 DR. AOTCN MUBINS . 111 4th St., W&unakee 53597 ' RODERICK S. SMITH 309 B Eagle Heights, Madison 53705 DAVID A. ST!TIBER Bahopok Ball, University of Winoonain, Madison 53706 . ' . 1 4 UTM00541 NCR-FOX-G281398 WATER PCB-SD0000041036 BEPPBV. USS CEPMSHQiS CF NATORAL RESOURCES Public Hearing to Review and Receive Public Consent Upon Proposed Adminis- trative Riles Relating to the Sischarge of Polychlorinated Biphenyls (PCB's) Into the Haters of the State )_ ) ) ) ) . Hearing Has held in 421 South of the Capitol Building, Madison, Wisconsin, on DiuradUy and Friday, August 28 and 29, 1975. * Presiding: EXAMINES JAMBS CHRISTOSCN '' Recorder: DAVID CROFT EXAMINER: Cb the record. Die Department of Natural Resources-of the State of Hiocorsin has set at this tine and place a public informational hearing to receive ccciuMila on and proposed rules re lating to the discharge of polychlorinated biphenyls, also known as PCB's into tie waters of tte State of Wisconsin. ' . .. Such owiurnLs and information received, regarding the presence and use of PCB's- . nay also constitute a basis for proposing, or reccnnending. state or federal legislation regulating the sale, use and distribution of PCB's by this Department. - The proposed rules under consideration today are created pursuant and proposed pursuant to subsections 144.025(1), 144.025(2) (d), 144.31(1), 147.01(1) and Section 227.014 of the Wisconsin Statutes. Die rules were proposed and reocmneaded by the Natural Resources Department--or excuse me, the Natural Resources Board'at their July, 1975. meeting. Die provisions of Chapter 227, wisixnsin Statutes, requires that the Department of Natural Resources hold a public bearing on this matter. The procedure of the bearing will be guided by that same chapter. : Let the neoand show, that notice of the bearing as required by Section 227.021, Wisconsin Statutes, was published in the proper manner in tbs notice section of the Wisconsin Administrative Register for the month of July, 1975.. Also, notice has been sent to various - interested persons the Department .determined were likely to have an interest in this matter. To date I believe there's been also three priaiic nswa releases regarding the. matter and the time and date of this hearing. Again, the purpose of the hearing today and tomorrow is to provide an opportunity to those agencies and persons interested in the proposed rules for oral owment. Die Department WlU also receive written carmenLa, which will be given the sar* weight as any oral statements made here today or tcmonxw. As far as the time, allotted or aUcmed for the written-cement . eutmissicn, that'll be determined later today dr early tarorrow. It is my understanding also that Ocmgressnan Alvin Baltes conducted a fiorun for public oaiment on PCB's in Pepin, Wisconsin on August 20, 1975 and that the record of that farua is available to the Deportment for review if we wish it. . ' Die procedure of this hearing, due to the.mnfeer of persons participating, will be as follows: First, there will be presentations by various parties requested to make those presentations by the Department, Again, this will be considered the Department presentation. Today, August 28th, the presentation by the Deportment will last acmewtere between 10:00 am. and 3:00 pus. He will then open the hearing to receive public eenneht. If wa have time between the hours of 10:00 amd 3:00, we will both allow questions and receive public ocnment. - Various copies of the agenda of the two-day tearing have barn passed around. Again, it's teen changed somewhat, but it gives you an idea of the.time sequence. 5 . TO100S42 NCR--FOX-0281399 WATER PCB-SD0000041037 r The hearing teccrrcw, set for this sane place, will cctmence at 8t30 aja. and go until 4:00 pja. Again, various agency representatives have been requested to make presentations on of the Department and I believe the majority are iron the Environmental Protection Agency, Without further statements, 1 will new call on Mr. Stanton Kleinert, chief of the Surveillance Section, Wisconsin CMS, to give a presentation, - MR. gTj.'Tm:OTi Thank you, Mr. Christenson. My name is Stanton Kleinert. X am chief of the Surveillance Section in the Bureau of Water Quality, Department of Natural Resources. X am responsible fear the Department's investigation of pcdychlgrinatBd biphenyls, or PCB's, in Wisconsin. My remarks will he confined to a discussion of the information conducted by the Department concerning the PCB's. PCB's are a family of chlorine-containing organic chemicals with varying properties. The oatitcn KB's encountered in Wisconsin include Areolae 1242, 1248 end 1254. The latter two digits iitiicate. the percent chlorine in the canpeund. Each Arcelor produced is actually not a pure oonpound but a nulti-caspcnent mixture containing lesser amounts of other Aroclors. In this report, all aroclors will simply be referred to as the PCB's. - Mere than .860 fish samples have been analyzed far PCB's by the Department of Natural Resources to date. The fish analysis program has shown that many fish baa Green Bay, take Michigan, the upper Mississippi River and the Fck River near Portage, exceed the Food and . Drug Administration Tolerance Level of 5 parts per mi 11 inn PCB's. The data to date is insufficient to indicate whetter or not PCS residues are increasing or decreasing in fish, with the exception that surveys conducted in the upper Mississippi River, including lake Papin, indicate a re duction in PCS concentrations in the fish between 1970 and 1975. ' ' The State Departments of Natural Resources, Health and Social Services and ~ Agriculture have' a working emmittee to review and act upon the monitoring data for PCB's in ' fish. We have also shared our information with neighboring states, the Environrental Protection Agency and the Food and Drug Administration. Xn addition to the fish monitoring program, the Deportment has searched for sources of PCB's. PCB's have been found above the .1 part per billion detection level used for screening purposes in core than half of the sewage treatment plant effluents we have tested. The higher concentrations are most common in sewage treatment plant effluents serving industrial areas such as Sheboygan, Neenah-Menasha and Milwaukee. In most cases, however, the discharge of PCB's is less than one part per billion end .01 of a pound per day. . Tracing sources of PCB's reaching a large municipal treatnent plant is a difficult and time consuming task. The Department is attempting to trace aouroes of PCB's reaching treat ment system: where the final effluent exceeds 1 part per billion. At the present time, we know of only two municipal wastewster treatment plants in Wisconsin which exceed one part per hillicn, the Shehqygan and Portage facilities. . The main source of PCB's. being discharged to the Portage treatment plant was found to be the NCR Appleton Papers Division Paper Capsule Plant in Portage. This facility had used PCB's in the manufacture of carbonless copy papers prior to the earner of 1971. After ceasing the use of PCB's and after repeated cleanings of the holding, tanks of the facility, the company substantially reduced the discharge. Residuals still remain, however,' in the sewer Systran and the sewer sludges, resulting in an effluent of several parts per billion at the municipal treatment plant. . . The Department of Natural Resources has tested the effluents of 16 pulp and psper mills far PCB's. The testing has revealed that nine of the mills had measurable discharges which ranged from .1 to more than 18 parts per billion. The higher concentrations and quantities were fourti in the effluents of two mills which deink and recycle waste papers. These axe the Bergstrom Paper CCcpafiy Mill and the port Howard Paper Company Mill. PCB's are found in many kinds of waste papers. Because their solubility in water is very low, we believe that most of the PCB's discharged frem waste paper mills are adsorbed on fibers and' other particulate matter. Mill waste treatment system which effectively remove particulate matter should also remove PCB's. The Department has checked effluents frm iron and steel foundries and aliminum foundries. The testing has shown that the cooling water effluents frm three of five alusimmi foundries sampled contained KB's ranging frm 11.5 to 335 parts per hillicn. Close investigation of one of the alminan foundries, Meta Mold of Grafton, revealed the source to be leaking hydraulic fluids containing PCB's, which were being used in the die cast machines. Meta Mold is replacing these hydraulic fluids and is disposing of the old fluids by recomaended disposal practices. Ke have found'PCB's in the cooling water effluent of only one of nine iron and steel foundries which have been cheeked to date and that at a cencentraticn of .9 parts per billion. 6 WTM00543 NCR-FOX-0281400 WATER_PCB-SD0000041038  The eleetaieal industry continues to uae PQ's as dielectric fhiids in son* capacitors and.transformers. Althcugh the PCB is sealed in .the capacitor and tamsfoemer units, ease may be lost as a result of accidents or as a result o the disposal practices for defective units. In March, 1375, the Department oarrespcnded with the inajcr electrical oenpaniea in Wieocnsin to determine current handling' practices far capacitor and- transformer fluids. Tha oerrespccdence was followed by visits to many facilities. The txnpanies contacted were aware of the PCB problan. But sone ware not aware of the recentnendad guidelines of the American National Standards institute for Handling and Disposal of Capacitor and Transformer Fluids containing the FCB's. He also found that seme electric ccnpanies were storing defective capacitors con taining FCB's until a pepper disposal method could be found. As a result of this survey, specific guidance was given to Wisconsin Electric Dilities far the proper handling and disposal of FCB's. ... snow samples were collected early in 1975.to determine if PCX's were deposited cn land and water as fallout fron the air. Analysis of the snow melt water fern Racine, Kenosha, Hadiscm and Milwaukee revealed ccncentxaticns fixm .17 to .24 ports per billion. It is suggested that a major source of FOB'S, in atmospheric fallout is the incineration of papers and other materials which contain FCB's. . " ' FCB's are present in the sediments in harbors and.streams near industrial sreas. The sediments act as a reservoir'wheie FCB's may be released slowly ever a long period of time. Sediment samples have tested three and a.half parts per million in the Milwaukee River,, hear Vhft rapifjil Brims Bridge, nine parts pan mill inn in Bupm-ierr Ksrfcer siid 73 par+Ltt pw-mitUnn in the Fck River below the outfall of the.Fcrtage Sewage.Treatment'Plant. .' Presently the Department has one. chemist and two laboratory technicians working full-time analyzing fish, effluents, sediments and other, saspies for FCB's. - . gn addition. Department district biologists and environmental engineers are upon to collect samples and asks surveys of industrial and municipal facilities and treatment eystaas. ' '' '. The Department is a working runiter of the lake Michigan Toxic Substances Committee with the State of Michigan, Indiana, minis and the fiwircrenehtal Protection Agency. The committee held meetings cn March 24 and May 22 to consider the FCB problem, has cespiled infanoa- ticn gathered by the various states and EPA and has released its report and raumnwdatinns for deeding with the problan in lake Michigan. '' The- Department is also working as pert of.a. task force group with the State of Minnesota, the Environmental Protection Agency.and the Food, and Drug AJministraticn, in respending to the problan in the upper Mississippi River, Node assignments have been made and task force - maters ere proceeding with their various tasks, which include the analysis of water, sediments and fish and- the investigation of suspected sources of pollution. Meetings pf this group vers held cn May 23, June 2, June 18 and August 6. The task force has issued' its first report bn PO levels in fish. Effluent samples obtained firm the major' dischargers to. the upper Mississippi River are being tested at this time. The task force will meet again cn Septintes 15 to review and act upon the reoent data. " *' . . In simony, although we have found saury source* of dieeharge of FCB's, most of thmare la tease mmmtB aC.-lesa than one part pgr billjm, Seme of the sources,' however,. such as -fallout fron the air and diacharqes frem waste paper recycling, account far larger amounts of FCB's. We knew very little about the accent of FCB's vhich may be released from past accanulaticns in sediments in rivers and harbors. We knew little about losses of PCX's which might occur as a result of leaching fraa.disposal sites where capacitors and transformer fluids and other material a were disponed in the past. .' He anticipate that PCB levels in the. envirenuent will progressively decline with declining uae. Me are searching for ways and means, to further reduce discharges to the environ ment and welcome your participation here today to consider the effluent limitation approach to the problem. We are mindful, however, of the fact that other regulatory mechaniane may be needed to limit dicharges to the envixement. ." . Thank you. ' EXAMINER: Thank you, Mr. Kleinert. Do you have a copy of that statsuent? We have a few minutes. Would anybody wish to ask a. clarifying question? TOZCEs Can espies of that be mads available--that statement, MR. HSEHSSi It's part ed the hearing raoetd. X could give copies, if naeMaary. 7 ' '- WJMO0544 NCR-FOX-0281401 WATER PCB-SD0000041039 EXAMINER: It is part of a hearing regard; it'll be available in tte transcript. Mr. William. MR. HULISKS: (Inaudible) . EXAMINER: Excuse me. Could you use the Bdxarpfccne here so it goes cn the reoozd. Please identify yourself. MR. VHUAMS: Allen Williams/ here for Bergstrm Paper Canpany. Ycu indicated initially that you are lucping all of the Aroclars together and you would speak about PCB's genetically, including 1242, 48 and 54. Can you, though, identify which of those Aroclores you were finding in these various fish that you were testing? MR. KLEINERT: We can--we can in sane cases. Like In the upper Mississippi River, the principal Arcelor that vre're finding in fish is 1254. In lower Green Bay, the principal Axoclcr we're finding is 1248. MR. WTO.TAMS: lharik you. EXAMINER: Does anybody else wish to ask a question of Mr. Kleinert? (No response) EXAMINER: Okay, in that case, then, we'll go on with the presentations by the Department of Natural Resources. For the benefit of those appearing on behalf and at cur request, I would request that they care up alongside Mr. Kleinert and speak into the microphone, at . way if anybody does have questions, they can apeak to them froa the other miexepbcne. And I believe that the first person cn the agenda is Mr. Bessy P. Roberts, deputy regional director of EDA in Minneapolis. - tad I also request that each person making a presentation please identify thaoselves and who they represent and if they are representing somebody, their title. Go ahead, sir. MR. RCBERSS: Ihank you, Mr. Christenson. ' Good morning. My name is Henry Roberts. X am the deputy regional director of the Minneapolis Office of the Federal Food and Drug Administration. She Department of Natural Resources for the. State of Wisconsin has asked me to testify cn the subject: the rationale far the five parts pies million tenpcrary tolerance for PCB's and the FDA enforcement action far carp in Lake Pepin. . As part of sy testimony, I as attaching tbs final estiar cn polychlorinated biphenyls dated July the 6th, 1973 (38 Federal Register, page 18096). This order and the accotpapying preamble explain in detail the overall problems of PCB's, the steps taken by PDA to control this problem, the tolerances established by FDA far FCS's in certain foods and the basis for these tolerances. PCB's are toxic industrial chemicals. Because of their past uncontrolled industrial applications and their chemical stability, PCB's are a persistent and widespread con taminant of the environment. As a result, certain feeds' including those of animal and serine origin, contain PCB's as an unavoidable environmental contaminants. In the case of fish, the transmission is through the water in which they live, \*ich is contaminated fay PCB's. Because PCB's are unavoidable, temporary tolerances under paragraph 406 of the Federal Food, Drug and Cosretio Act far residues of PCB's as unavoidable environnental contaminants were established. In establishing these tolerances, the ocmidsaicner of the Foods and Drugs took into account available toxicological data, which is simmarized in the attachment and the extent to which PCB's in these foods are unavoidable under current good manufacturing practices. - Cn the basis of these considerations, the cxiunlssioner established the following teaparary tolerances far PCB's: One, 2.5 parts per million in milk on the fat basis. Two, 2.5 parts per million in manufactured dairy products on a fat basis. Three, five parts per million in pounltry cn a fat basis. Four, 0.5 parts.per s&llich in eggs. Five, 0.2 parts per million in finished animal feed for food-producing animals, except the following finished animal feeds, feed concentrates, feed supplements and feed premixes. And six, two parts per million in animal feed eerapements of animal origin, including fishmeal and otherfy-produets e marine origin ami 8. WTM00545 NCR-FOX-0281402 WATER PCB-SD0000041040 in finished animal feed concentrates, supplements and premixea intended fca: focd-prodtcing enisals. Seven, five parts per million in fish and shellfish, edible .portion. Bse edible portion of fish excludes bead, scales, viscera and inedible bones. An3 eight, 0.2 parts per million in infant and junior foods. . Additionally, the FDA is enforcing ah action level of 10 parts per million for KB's in paper 'food-packaging material, pending the ccnpleticn of a public hearing to establish a formal tolerance under paragraph 406 of the. Federal Food, Drug and Cosmetic Act. I wish to wnphaslyn that the tolerances established in 1973 were based on the best todlogical data available at that time.. - He recognize, however, that additional scientific studies, such as those conducted by Sr. Allen, who will he speaking to you sanetime today, have been ccnpleted. And wo are currently reviewing these studies to determine whether revision of our tecpqrary tolerances is necessary. .. . ' As you know, IDA has jurisdiction over food only when it is offend for shipment or ia shipped in interstate, eeranerce. In the case of fish fedn lake. Pepin, we have found shiprents of carp that- exceeded the temporary tolerance of 5 parts per million of PCB'a. Carp - found to exceed this tolerance are subject to federal regulatory action. Such action might include seizure of the violated fish and the shippers of such fish, are also, in appropriate cases, liable to. criminal action or Can be enjoined from future' shipnehts. wish, to assure ' . you that EDA will continue to devote' its attention to the pcoblen of ccrmerical marketing of. all foods, including fish that contain FCB residues. . I also wish to assure you that the Minneapolis Office of the Food and Drug Afadnistraticn has been and will continue to work closely with the CNR of Wisconsin, the Wisconsin State Department of Agriculture and the fishermen to control this serious, peoblas.. . Hopefully our joint efforts will succeed in eliminating the problem in the lake. Lake Pepin, so that FCB's will be of interest only historically, I shall be happy to answer any ' questions that are appropriate to the hearing. .. . EXAMINER: lhank you, sir. Do you have a copy of your statement available for us? MR. RfflERIS: Yes. . . BCAMM: Anybody wishing to ask clarifying statements cr questions, please approach the mike. Would anybody wish to ask questions? microphone. Please step up, sir. Identify yourself .and who you,represent when yea get to the . . MR. FAPAGBOKS: I am William Papagoorge from Monsanto Ccnpuy.. My question to Mr.; Roberts, the prograu indicates that you were going to discuss the step-by-step rationale for the arrival at the five, part per million level in. edible fish. Mould you please do that for us. _ .. MR. RCBEFOS: I can do this by reading the Federal Register, which is part of ay attachment.- It's a rather long, lomg.dseHBenfc. . St's going 'to take"'" well, if were ready, you know, an hour cr two, if that's--- , . arunazy?. _ MR. EAEiAGECKS: Is there any manner In which you can mmmarlze it, sir? Just a brief ~' . : ; '. - . m. VCEERISi Rationale--and I'm net a scientist. I'll be perfectly, honest with you. I'm hot a chemist. Is based on the amount in these particular foods that one would in gest over a period of time. It's based on those kinds of things and this is explained in here and it is based on, of course, as you probably knew, the Japanese experience back in. the '70's. And that is--veil, maybe I can do it this way--I'll have to find--dietary sources, temporary tolerances, temah toxilogical data, would that be what wa're talking about, . . However, what I'm trying to do and I'm not trying to be la^ about this, but I . just-- don't wont to read an hour of the Federal Register. It's not that interesting reading. MR. FAFAGBOHZ: wall, sy intent, Mr. Roberts, is not,: to taka acre time than is necessary, but I hove been present in many discussions at which the setting of levels in food . had been discussed and. frankly, I'm still confused as to how they arrive fees animal toxicity data,, tha incident in japan, the type of diet that the American-is normally1 exposed to. and tha arrival at fiv parts per miUion when I also knpw cr have heard that .that five part par mlllim level existed long before it was ever publish in tha.Federal Register and action levels aid actions were fcaksi as early as 1369, as best I recall. ' N C R-FOX-0281403 WATER PCB-SD0000041041 So sanewhere in the Food and Drug Administration, there must be sanecne *4 taows where that five pert per million number came frm and Z have had difficulty finding how they have arrived at that nudber. I'm just trying to get seme information. MR. KjfcstklS: Yen mean four and a half parts per min-tm? MR. EBPAGECBGE: Yes, why isn't it three; why isn't it 15} why isn't it 50? There must be sate basis far the five part per million. IS. EGBERTS: day. let me read this to you. This is the dietary sources of PCB and this may help explain it. - The results of ISA's total diet studies far fiscal years '70 and '72 show that quantitatively, measurable residues of PCB's are equivalent to an intake of approximately 0.06 micrograms per kilogram body weight per day or 4.2 micrograms a day for a 70 kilogram man. Because of the sensitivity of the analytical methods used, PCB'a may be present in levels too low to be detected. Xf lewer levels could be measured, the dietary intake of PCB's fron the toted diet studies VJtuld probably show an increase. It should be recognized, however, that in rare instances seme people could have more systemic exposures to PCB's in foods than those expected by eating a moderately wall balanced diet, such as represented by the total diet sazrples. Bence, there is a need for minimizing potential hsznan exposure. The total diet studies indicate that PCB's most frequently occur in the food composite consisting of seat, fish and poultry. Experience has sham that most of the PCB residues in this oarposita are in the fish and, to a lesser extent, in the poultry. And in the food composite consisting of grain and cereal products, experience has shewn most of the PCB residues in this ccrrposite are derived fron the paper packaging materials. FDA's food surveillance activities have shewn that PCB's also occur In dairy products, eggs and packaged foods, in addition to packaged cereal products. . The temporary tolerances for PCB's, using the human toxicological data described . above and I can go back and explain that if that's what we're talking about, the HA concludes that for the short term, based on the lowest dose producing an effect an estimated biological half-life of PCB's, current levels of PCB's in the diet represent ns immediate hazard. It is also true for the average total dose causing an effect in the Japanese far long-term exposure-- for long-term exposure. However, based on the most sensitive Japanese patient, i.e., lowest total dose producing an effect, the possibility of potential long-term hazards necessitates reduction of levels of PCB's in food as soon as possible. In the interim, temporary tolerances are necessary to limit human exposure to those foods that may contain PCB's resulting from environmental contamination, which, as a practical matter, are presently unavoidable. Those foods for which taqaerary tolerances are established include milk and dairy products, poultry, eggs and fish-and infant and junior foods. Infants and younger children consume a greater amount of food per kilograms of body weight and thereby have a proportionately greater exposure than do adults. A separate teeporary tolerance for infant foods and junior ' foods therefore reflects the possibility that undesirable exposures could result if occbinations of certain PCB contaminated fdods catprise a major portion of this.age group's diet. In order to minimize the overall dietary intake of PCB's, individual sources of PCB contamination must also be appropriately minimized. PCS' s have been shown to occur in packaged food as a result of PCB contamination of the paper food-packaging material. limitations on levels of PCB and paper feed-packaging materials are therefore necessary to minimize the amount, of PCB's which migrate into the packaged food. Since PCB's can be transmitted to and concentrated in edible portions of food-producing animals ingesting PCB contaminated feed--animal feed, represents another source of PCB's in the food supply. . Limitations on levels of PCB's in animal feeds and animal feed empunents are necessary, there fore, to minimize frequency and magnitude of PCB residues in food of' animal origin. Vat, do you want me to go hack and read more? MR. PAPAGECKZ; Ho, thank you, sir. ' EXAKZHER: Ckay. Thank you, sir. Does anyone else have any questims? Step up and identify yourself and who you represent, please. .MR. STOIBERs I'm David Stuiber, University of WiaocnsiB Food Science Department. I'm a faculty member within that Department. Hy question pertains to a statsaaat that was just reed which states that the animal, beef, pack, fat--chicken, gg, ar the primary source of KB's as far as the diet is concerned? 10 WH400 547 NCR-FOX-0281404WATER PCB-SD0000041042 MR. JCEEfiSS: Yes. MR. STOISER: My -.reaticn is where the hell does the animal get it? I roan, if we're talking about grains, we .- talking about a thicken. QJjay have a very controlled diet. Now, I naan, they don't absorb iz frcra the air. Semeplace along the line they have to be picking it up. MR. 03335: Probably they're picking it up in the feed. MR. SlUlHtat: Yes, well we practically eat the same thing, then you talk about grain or cereal, all right, they get a little lesser quality, but as far as the grains and the feeds going into these particular animals, we consume the same thing, so I assure, then, for all practical purposes, that X contain the same amount. MR. RC8EKES: Mall, remember they were chickens, how. Particularly we've got prchlans with fish meal and that is a major diet in acme < at least sore areas of the country, Xt may not be in-- . . MR- STOIBER: Primarily it's only 50 percent. MR. HCBEKIS: Wisconsin. But it.is a part^--well, that's enough if it's high enough. And you know, this---we had this problem, remember whan the USDA had to <01 of the chickens dam in Arkansas and Missouri. MR. SIOTEERs Rig:-.. ' ' .' . MR. KEEinSs I > e done.....I am. not aware pf any data on beef or perk, but wa're talcing a very conservative apptrz.. because it can unavoidably be in tire rations that ftyi animals eat. We're going to inc.ude those under this thing. MR. STOXBER: Hell, I would'just like to say that if we're going to foed, we ought to damn well go bade.and look at everything that we're consuming. era ' MR. RQBE2Q5: Maybe ve will. MR. STOXBEK: Hall, X didn't think it should be maybe. X think we should. SfflMHOB: Okay. At this time, Mr. stuiber, just keep it to questions. You went to make a statorent later cn, I'll give you a chance. . . Anyera aUe? ' ' .' (No response) EXAMINER: Cfcay. Bank yw very ssrafa, sir. Bre statement*--can X have it? Please leave the statement to make it part of the record. - Ckay. Is Mr Kixsphbaua of tire Wisconsin Department of Agriculture lrere? MR. XXHSCBBftiM: iy TM Mnrm K-t-rrhfeni- T rm n* ffy nryl Standards Division of the Wisconsin State Department of Agriculture. I have been requested to. discuss cur department's.food testing programs and the enforcement action that we took against carp in the &een Bay area as it relate* to PCS'*. . Our Department bare the responsibility far. the administration and enforcement of Chapter 97 of the Wisconsin Statutes, which is the state food law, as well as a ranter of feed regulations pcanalgated under this law. Biis responsibility includes the licensing and inspection of various feed operations as set forth in Chapter 97. We also, inspect other feed production processing and distribution operations that may not be required to be licensed. An important part of the toted food,inspection program is the sanpling and laboratory analysis of the various raw and processed food products fer adulteration and cccposition. . . Brere are several section* in Chapter 97 which are pertinent to the administratim of this law and to sy statarent here this rooming. . Section 97.01 defines tire federal act as the federal food, drug and cosnetic act as amended. Section 97.02 defines an adulterated food. With out reading the entire subsections of Section 97.02, this section states that food is adulterated, one, if it bears or contains any. poisonous or deleterious substance which is unsafe within the meaning of the federal act and two, if It is or it bears or contains any food additive which is unsafe within the meaning of the federal act. X cite these-provisions since they are tire basis far our using the tolerances and temporary tolerances established by FDA' for pesticides, fungicides, herbicides and in this instance, RGB's. Fishy therefore, containing more than five parts per mliHrr> sea's are eensideced to be adulterated under chapter 97 of the Wisconsin Statutes. .. 11 VTM005A8 NCR-FOX-0281405 WATER PCB-SD0000041043 Tt> meet this problem, our division baa developed the following program: ' First, the objective, of course, is to permit only foods, including fish, to be sold caitnercially in Wisconsin marketplace that are below the temporary tolerances for KB's. This will be done with as little trauma as possible to the food industries involved. Including the fish industry. But the primary objective that we feel we have is to continue to assure the cexramers that foods censured are not adulterated. TWO, a sarpling program, for fish will be continued and, where necessary, increased to achieve the above objective. A specific sampling schedule for different species of fish has been developed. Our primary sampling points will be at wholesale and at fisheries; however, a few select retail samples will he taken. Four, our major emphasis will be sailing of fish originating in Wisconsin, hut we do intend to randomly sleet samples of fish originating outside of the state. Five, in fulfilling this responsibility of keeping cur food supply safe, the department will continue to work jointly with the Food and Drug Mministrati.cn and the Department of Natural. Resources in preventing duplication of effort and meeting fish industry problems in supplying a wholesome food to the public. In carrying cut this program, early this spring we did sample and have analyzed in our laboratory samples front two lots of carp in the Green Bay area. These samples were found to contain 8.9 and 33.4 parts per million of KB's. The two Jots amounting to 975 pounds of carp, were placed under holding order under authority of Chapter 97 and disposed of as being adulterated food. just recently we were requested and did obtain five samples of carp that were in a holding pend in the Green Bay area to be sold for food. All five of these samples were found to contain more than five parts per million of FCB's, varying from a low of 13.1 parts per million to a high of 57.5 parts per million. The fish in the pend, amounting to 12,500 pounds, had been placed under a holding order and are not to be sold ccnmercially as food. The owner is presently attainting to find a disposition for these fish. All of the carp involved in these two actions were obtained frtxa the Green Bay area. ' He have cooperated with the Department of Natural Resources in sampling and analyzing individual fish from lake Pepin and other areas of the state. This project has been in the form of a survey and information gathering effort. He have not taken any official action on fish as part of this survey. He axe hopeful that through the carbined efforts of the industries that use KS's, the fish industry and the regulatory agencies involved, both state and federal, that we can eventually eliminate the problaas concerning PCS'a in fish and in foods. . I shall be hippy to respond to any questioas that may be pertinent to the issue. EXAMINES: Do jou halve any copies of your statement, sir? MB. KXBSCBBKH: Fes. EXAMINER: Thank you. Does anyone wish to put questions to Mr. Kirschbeum? (No response) EXAMINER: In that case, thank you very much, sir. Is Mr.--Dr. George Bandy present? Kill you please step up, sir. '. Bit. HANDY: I'm Dr. George Bandy, state health officer, administrator of the Division of Health of the Department of Health and Social Services. My presentation is to establish the relationship of the Health Department to this particular problem. Our statutory authority domes from Statute 140.05(1), which says that the Depart ment of Health and Social Services shall have general supervision throughout the state of the health and life of citizens. It shall make sanitary investigations into the causes of disease, especially epidemics, the causes of mortality and their effect on the health of localities, sroloymeats, conditions, habits and circumstances. And further goes on to state that the department may espowar the state health officer to act for the department. 12 WMOOSM NCR-FOX-0281406 WATER PCB-SD0000041044 . In 1971, based on the federal department, car tie FEA statement of February, 1970, and b five-state meeting held in September of 1971,, we issued a warning on October 18, 1971, that the five pert per mill inn action level far PCS for market basket fish and that sports fishermen . be advised to refrain fron eating more than one meal per veek of such fish and that pregnant women and children be cautioned to limit their intake to. one average si2e serving of such fish per week, ibis was based on the available infoanation at that time. Mr. Donald Healton of FDA, in January 30th of 1974, updated the status.concerning PCB, which he read fron the Federal Register, fron. a--this was a presentation given at the Governor's Great Lakes Regional Interdisciplinary Festidde Council in Chicago cm January 30, 1974. Following that, Mr. Voigt of II called a interdepartmental meeting of Department of Agriculture, Department of Health and Social Services and DNR on May 16th and from that meeting, the public release of n of 10th of June, 1975 and our contribution was to reiterate, based cn lack of any additional informa tion, of the action level of five parts per. million. Ke feel that the Department has an obligation to publicise this situation, provide a warning to all citizens of the state and very closely work with these other, departments cn any changes of information. . The Department has an additional responsibility in terms of occupational health and that is the people that work far this material, to see if we can find cutany evidence of specific occupational illness in those erplcyees. o date, to my knowledge,- there has been ncns generated and we're watching as carefully as wa can. . shat, air, is ny contribution. KJffiMHERj . Shank you, sir. Do you have a copy of that? DR. HAMS: X don't, but I'll trite it and send it. . P20MINERs Shank you very nuch. ' . Would anybody like to ask questions of Dr. Sanity? . (Ho respcnee) EXMCNER: Ckay. if there's ih questions,, thank-yen very much, sir. Hew, we are heading---ate are ahead of schedule and for, that reason we can take statements fron the audience at this time. Is Mr, Forster here? .. Sir, would you please approach the mite and mate your statement. Please identify yourself and who ycu represent. ' MR. FORSTER: I am- Albert K. Forster, .State Treasurer of the Xzzak Walter League of America in Wisconsin. have been delegated on behalf of the state organization to present three exhibits. Number one is a current report by Francine Zeldman in August, 1975 issue of "Environnent Midwest" cn this problem of the PCS. And Mr. Kleihert wait ewer many of the basic things he outlined cn there, so I'm not going to waste too much time ch that. But this is fee the record. ,' ' . -. Exhibit 2 deals with a resolution on toxic substances, including PCS, that was adopted at the National Convention of Izzak Walton League in Dea Moines, Iowa cn July 9th and 13th of this year, taking a definite position cn use and application of these chemicals. 1 would like to read the substance of it. Every year, thousands of new chemical substances are introduced to the environrent through their manufacture and use and tte disposal of industrial vastea. Acusul&ting evidence of serious environmental and. health defects of such widely used substanoes as phenaxy herbicides, polychlorinated biphenyls, fluorocarbons, heavy metals,visyl chloride, has intensified concern that other, as yet unidentified ctemical substances may be exposing large segments of the public to grave health hazards.. . . De^dta the magnitude of the risk, no.caqpcehensive authority exists to require testing of substances before man and the environment are widely exposed to their effects. Existing regulatory mechanises which concentrate on reacting to a known hazards rather than preventing the ones, dome into play only after the envizmnental or health dotage has teen proven. Shis approach 'is clearly inadequate to protect the public fron latent, longterm effects of exotic substances, the delayed effects of which manymay not -teonme visible until years and even decades following exposure to them. In the meantime, the entire earth is being used as a laboratory. 13 WTM00550 NCR-FOX-0281407 WATER PCB-SD0000041045 Therefore, the Izaak Walton League of America, assembled at oonventicn at Dea Moires, urges a ccnprehenaive program be established to prevent damage to human, health or enviroment from hazardous chemicals by one, requiring that potentially hazardous substances be thoroughly tested for 'safety prior to their introduction into the environment. TWo, establishing the principle that manufacturers, users or dischargers of a substance suspected of being hazardous must bear the burden of proving the use of the substance as having low envircrmental or health effects--adverse effects. Providing for prohibition or stringent regulation of substanoes fcund likely to pose a significant ride to human health or environment. Then we present another resolution here fran our state meeting in Wisconsin con cerning herbicides and phenacy--all these chanicals that present a hazard, all related to base ccrcpcurds found to be very pertinent and do not break down in ecosysten. Wteraas damage frem compounds containing tetra-diesdn to animal life in producing birth mutations and other defects. Whereas, these sane coipounds are also strongly suspected to adversely affect humans as reported, but hot proved beyond doubt and. that tetrsdiadn and ere of the ingredients of herbicides is extremely poisonous and nay, under certain circumstances, produce additional tetradicDude in fires or when- exposed to heat, and, ' Vheroas, airborne, these phenacy herbicides affect all growth indiscriminately and when waterborne, is carried uncontrolled to other areas, or sinks to the beds of waters to affect that grewth and. Whereas, no studies have disproved any of the Shove statements, and. Whereas, control in application, erven with care and strict supervision cannot curtail the application within boundaries, so that it crosses all lines established as boundaries, local, state, national, international. Therefore, Wisopnsin. Division of the Izaak Kalten League in convention assembled in Stevens Point April 19th of this year, do resolve to oppose use. of ary of these chemicals and to encourage use of any other oenpounds and chemicals as are compatible with the envirement and with population and/cr trsran, until such a time as these pherexy herbicides and other chemicals are proved safe to use in eoosystem. We further resolve to work actively in support of legislation to control application of phenacy herbicides and other chemicals until sure proof of safety for ecosystem is produced. EXAMINER: is that your statement, air? . MR. FORSTER: Yes, X went to present that for ycur file. EXAMHER: Thank you very much. I appreciate that; Okay. Is Mr. Richard M. Month* present? . MR. MORSE: Yes. ' raMOHER: wtia you like to make a statement at this tins? MR. MURSE: (Inaudible) ' BaMffiER: duty. Do we have other appearance slips held that haven't been submitted yet as far as people v*o wish to mate statements at this time? Is Mr. R. A. Shade present? . So you wish to mate a statement at this tuna, sir, or would you wish to wait? MR. SHADE: (inaudible) BOUflUER: Okay. Please step to tie mike and identify yourself. MR. SHADE: My nan* is Robert Shade, president and chairman of Shade Information System, Incorporated. We are a Wisconsin corporation established in 1965 and enploying 250 people. We are a major eenverter and supplier of carbonless business forms, a major converter and supplier of office papers and business fonns made from recycled paper, a significant sillier of post-conmattes office waste paper to recycling mills in Wisconsin. 14 WTM00551 NCR-FOX-0281408 WATER PCB-SD0000041046 In connection with itsn three, the Shade Haste Hot Progran far redeeming high quality office waste paper was started cm July 15, 1973. The Waste Hot program was the first source separation systan Car recovering high quality office wastes establish'd in the United States. This unique program is being successfully carried cut in businesses of all types, state and local governments, federal agencies and educational institutions. The-EPA has consulted with us, as the leader in office waste recovery,' in' developing guidelines far.mandatory source separation in federal office buildings. Both H>Aand the State of Wisconsin have established workable office waste recycling efforts in their own offices as a result of our Waste Hot program. The success of Waste Hot has provided iapetus to the growth of office waste recovery and is contributing to the solution of the problem of solid waste disposal as well as resource aid energy conservation. ' '. A statement of cur corporate policy regarlng KB's may be in order at this time. First, we believe PCB's at certain levels are delximental to society or to the eoosystem. Secondly, we believe additional PCB's should not be introduced as an additive to siziy product or eystm, as of now, unless alternatives would be sore detrimental to society, and only then if nchpollutirg disposal could be guaranteed. - Three, we believe controls should be established to guarantee that PCB's are not unknowingly reported into this country. Those knowingly invested' should be subjected to the same sale and use prohibition we apply to the domestic producers. Tear, ve. believe that a great deal mere needs to be known about the various varieties of PCB's. their sources, measurement, safe level, removal and disposal before any meaningful action can be taken. Five, We believe that pre-existing PCB's should be reduced: to a safe level an a national basis as soon as it is technically p-mgihi to do so. . Six, we believe that it wuld be premature to rule that KLsoensin cities and industries meet unattainable levels of PCB's in their water discharge because: (A) He do not know how much . pre-existing PCS is already in the air, land and water of the state. (B) He do not kjw how, where csr by what means additional pre-existing. phS's--PCB's, are being introduced into the air, land and Water of the state. (C) We do not know how to officially remove arid dispose of pre-existing PCB's. (D) Ve do hot knew.hew to effectively and continually monitor the level of the pre-existing PCB's in a water stream at the levels proposed.- Xh effect, the proposed rule asks .Wisconsin cities and industries to solve a problem by unknown means to arrive at an iiiaxplete solution that the results of which will be measured by unkown ihstruaents. ' Seven, ** believe that ismediate funding by both the public anl private sector is necessary to determine the source, measurement, safe levels, removal and disposal of pre-existing PCB's so that effective controls may be instituted at the earliest possible date. Oir. concern: Ha are concerned that a premature ruling might cause Wisconsin paper mills that use waste paper aa part of their fiber supply to reject all ofice waste paper because of the possibilities that such waste might contain iER paper produced before April 21, 1971. It is then our understanding that PCB's were used in the NCR piper senufactured pricx to . April 21, 1971 and those PCB's have been identified as a source of contamination. He furtter understand that no PCS'* have been used in KB paper manufactured since that date. - it is-cur-contention that as of this writing very little MUR pager produced prior to April 21, 1971 is getting into.the office waste stream. It is further cur contention that such NCR paper will constitute a continual ly mailer part of future office waste. . He submit the following information without proof because no proof is available. These are the best estimates of individuals in our company and other , sources considered to be qualified in the art. First, we estimate that multiple copy business forms represented less than 50 peroemt of total office paper by weight. This means.that for 100 poinds of office papers, approximately 50 pounds would he multiple part business forms. Secondly, industry figures shew that for the years prior to 1972 carbonless paper represented less than 15 percent of the multiple part business forms market by weight.. This means that only seven and a half pounds of the 50 pounds of multiple part business forms woiild have been NCR paper. Three, ICR paper contains three types of paper. First ply. is always a coated beck sheet, called a CB. The last ply is a coated feemtsheet called a CF. Tim internal plies are coated front and hack and are called CFB's. Gnly the CB porfcim of the paper con tained PCB's. Industry figures show that the average nwltiple part business form is an original and two copies. Therefore, the average form made Cron IKK would contain one CB, one <5B and one CF. Shis means that of the seven and a half -pounds of ta paper, five pounds might contain PCB's. as FM0DSS.2 N G R-FOX-0281409 WATER PCB-SD0000041047 Frcm the above, it is apparent that in the years prior to 1371, ICR paper containing PCB's could not have accounted for mare than five percent of office papers. The question then becases hew such of the office papers used in the time when NCR paper was--still contained KB's is presently in office archival files, because such files are virtually the only source of NCR paper containing KB's. We estimate that all PCS containing NCR paper has been oarwert--rhad been converted to ferns and used by.the end user by the end of 1972, 20 months after NCR ceased using KB's, if wa assure that archival files for 1972 had 5 percent PCS containing NCR paper and files for 1973 and thereafter had no such paper, we must attenpt to determine when archival files for 1972 and before will be destroyed. File retention and destruction programs vary by industry and' by application, but let us assure that most files are destroyed in three yean. Oils means that 1972 files will be destroyed in 1976 and 1973 files will be destroyed in 1977, although sens files, for example real estate records, are supposed to be--are supposed to be retained in perpetuity. It should also be pointed cut that many regards are converted to magnetic computer tape aid microfilm and the source docurents are destroyed in the year used. We believe that such file destruction programs account for less than 10 percent of the total office waste stream. Therefore, if we assume that NCR paper represented five percent of the 1972 files which will be destroyed in 1976 and file destruction represents only 10 percent of the office waste stream, we will arrive at the estimation that one-half of ora percent of the office waste stream- in 1976 will be NCR paper containing PCB's. In 1977 and thereafter, the amount of old NCR paper being released to the environ ment will go daan dramatically because most archival files for 1972 and before will already have been destroyed. There is no questicn, however, that seme old NCR paper containing PCB's will be present in government and industry files for years to cone. We further estimate that only 10 percent of office waste is presently recycled. This means that in 1976, 90 percent of the office waste stream will go to solid wests disposal and it will contain one-half of one percent- ' one-half of one percent old NCR paper. And . 10 percent of the office waste stream will be recycled and it will contain one-half of one percent of old NCR.paper. In both instances, the KB's are being released to the environment. To identify and remove this old NCR paper is no easy task. Unfortunately, there is no practical means of distinguishing between old NCR paper which contained PCB's and new NCR paper, which does not. ' . Our experience in operating an office waste program suggests that even a massive educational program aimed at the elimination of PCB containing papers could not- absolutely guarantee the elimination of such papers froa our recycling stream. Even if such an educational program could succeed in Isolating this old NCR paper from our recycling stream, it would not solve the problem because such paper would either be recycled by mills in other states or dis posed of by solid waste disposal-systems which do not eliminate PCB's from the environment. In other words, we could cmly succeed- - we would only succeed in eliminating this old NCR paper from Wisconsin recycling mills and we would not have guaranteed that it would be disposed of properly.. That which is not recycled will indeed find its way into the environment via rain, air movement or water flow. We cannot and the recycling industry cannot, provide the total solution to tte overall problem of PCB's in Wisconsin environnent frem either, one, the continuing source of new PCB's which are not related to the paper industry ear two, froa the many, and diverse sources by which pre---pre-existing PCB's are entering our waterways. The real answer is to provide the means by which PCB's can be effectively isolated and removed frem the environment.' This fi&Bns Bfifc fptf cist* At best we can only begin to alter the existing impact to one identifiable segment of the problem--which means shifting that inject to other areas of the prcblem. It is only through irradiate public and private funding, we believe, and an ongoing dialogue between business and government that the information and technology can be developed to evaluate the overall prcbles and arrive at a meaningful solution. Thffrik you. BfflMHERi Thank you, Mr.---do you have a copy of that statement? MR. SUSIE: Xes, sir. BSKBJER: Thank you. . . Ctay. Now X do have a couple of gentlsnm scheduled tea ibis afternoon who contacted saa, but I believe they're here this morning and it's going to te up to them as to whether they wish to speak at this fete. '' 16 WTH00553 N C R-FOX-0281410 WATER PCB-SD0000041048 la Mr, Boward Ness present? . MR. NESS: Ye*. EfflKfflER: Wbuld you like to speak new, sir? Please step tip to the mierophoM and Identify yourself. MR. NESS: fy nsrae is Board Hess. X en representing the National Association of Recycling Industries, Zac., whose offices axe located at 330 Madison Avenue, New York, New York, By toy of introduction, X would like to describe cur association, NARX, and the industry it represents. NARI is new in its 63rd year. It is the leading and nost oenprehensive trade association in the recycling industry. It speaks for acre than 700- marber caipanie3 located throughout, the United States, all of which share one ccccson economic. purpose, the recycling of solid waste materials into new raw material and products. Our matters are the recyelers of all types of metals, paper, textiles, rubber, plastics and other waste materials. In.the paper- industry, far exzctple, NARI's mastership includes all segments of paper.recycling. Sane of cur matters Collect waste paper firm various sources. Others sort, grade and process waste paper into' new, raw materials for sale to paper manufacturers. Our membership includes those--these consumers of recycled materials, the paper mills, and the exporters of taste-paper. Similarly, in metals, our metrbera include :firms which collect scrap metals from solid waste, fins which recover, .process, refine and convert scrap metals into new raw materials and finally, manufactures who purchase these recycled metals for utilization in products for domestic ccnsunption and expert. Bte recycling industry now pcccesses over three million tens of nenferrous metals, 13 million tons of taste paper and millions, of pounds of textiles and other materials annually. Kith the chairman's permission, we would like to include as part -of pur presentation for the . * record, the contents of a panphlet entitled' "Recycling Resources: A Guide to Effective Solid Waste utilization". Most of the material contained on this booklet cn recycling is the result of considerable research by cur association in recent years, including data oempiled as a research project authorized, conducted far, and approved by the United States .Environmental Protection Agency. In addition, we would like to include; for the record the:following pacrphlets that show the importance of recycling: "Energy in. Solid Wastes: A Citizen Guide to Saving", published by Citizens'. Advisory Committee on Emdronrental Quality. Second Book "What You Can Do To Recycle More Paper", publication number SW-143 and "Khat You As A Consumer Can Do Tb KelpEnoourage the Recycling of Waste Material% publication.narber SW-117-1, She latter two are published by the United States Environmental Protection Agency. . We believe, and every authcritive agency of the Federal Government concurs, that expanding---that expanded recycling is the most constructive step that can be taken to assure our nation the raw material supplies required for future eoonmic growth. In the face of the rapidly depleted natural resources and at significantly lower energy requirements that are needed when raw materials are used-^-when virgin raw materials are used. . The 13 miHicri tons of taste paper currently recycled each year represents 20- percent of toe nation's total raw materials need for paper fiber. It also represents the conservation of 200 million trees'each year that can either be left in place or used for other purposes. The EPA's "Report to Congress cn Resource Recovery", dated February, 1973, indicates that the use of waste paper in the paper making processes replaces limited wood pulp supplies i and represents energy savings of 60 to 70 percent. - Currently, only about 13 million tons cut of an annual paper production of aver 60 million tons are recycled. But 35 million tons .of additional waste paper are recovered for raw material use. The doubling of our current recycling volume from 13 million tons to 26. million tons a year, a rate close to our world War XI paper recycling level, would result in industrial energy savings of 55 hilltop kilowatt hours of energy or 32.5 million barrels of oil a year. Further, since paper emprises almost half of the nation's collected solid waste, it represents another important energy source' after recyclable materials have been extracted for new raw material uses. ERA states that about 80 percent of this aqnrecydable residue is ecca- Jaistibla atol can be recovered in. the farm of energy. ' .' . Of course, recycling also decreases landfill, requirements. Each ton of material removed froa the mmicipal waste stream leaves such needed space far taaaxrtw's landfill needs. According to. a repent study by the National League of Cities .and the United States Conference of Mayers entitled Cities and the Nation's Disposal Crisis, and X am quoting ftem that publication: "Kith almost half of our cities running exit of current disposal capacity, in froa one to five years, .urban America faces an imiediate disposal crisis." We bsliive that effective increased recycling is truly in the bast interest of the nation and the citizens f Wisconsin. 17 WM0O554 NCR-FOX-0281411 WATER PCB-SD0000041049 It* recycling industry oalpetes on a day-to-day basis with virgin raw material industries and, therefore, even the slightest suggestion that recycling paper is inferior to virgin product has a devastating effect on recycling. This is particularly important new that tte re cycling industty is being urged by the federal government and the Ancrican public to expand solid waste utilization both in traditional and new product areas. ' . Three years ago, when it was first, determined that seme recycled paper board contained.KB's, it vas traced to the presence of PCB's in the manufacture of carbonless carton paper produced by the national Cash Register Canpany, NCR. At that point in time, regulations were passed by the SEA to limit the KB levels. unfortunately, the KB regulations were misinterpreted hy many as conclusive findings that recycled paper was harmful to health and was therefore inferior to virgin paper. The evidence of the devastating effect of these regula tions were as follows: When the proposed regulations were issued, many consumers of recycled paper immediately cancelled their orders after seeing scare headlines in newspapers which in sane cases real "recycled paper bills". Shortly after the regulations were issued, legislation was introduced in the New Jersey General Assembly which would provide criminal penalties of up to $50,000 for the manufacture, sale or distribution of any food packaging material made frem ' recycled paper. Clearly, toe Food and Drug Administration did not mean or seek to focus only on recycled paper. It indicated that even sane virgin paper products pertained KB's and that there were many other sources of KB's, such as heat transfer fluids, hydraulic oils, lubricants, transformers and capacitors. Nor did the FDA mean or seek to produce such fear amongst the consumer of recycled materials, nor frustrate the purposes of the resource recovery act. In all fairness to this industry, which contains seme 4,000 mill workers and nany thousand more employees at the sipplier and consider level, we. simply cust set the record straight and prevent such damage frem spreading in the future. According to the FDA and industry data, we understand further that PCS levels in ` paper are continuing to drop as the production of NCR carbonless paper has been discontinued. Indeed, we have been infexmed that most paperboard new contains less than three parts per million, well within the FDA regulation of 10 parts per million. Die recycling industry is making every effort to seek out the contaminants, the NCR carbonless carbon paper made with KB's and not use them where they would be detrimental to the health of the public. During toe last two years, the recycling paper industry has seen the KB level in recycled paper drop to less than five percent of its initial estimate and the industry is still diligently working to lower this level. - We strongly urge your agency to use your full authority to eliminate KB's at the source. Ideally, it would be best if your agency had the statutory authority to direct a cenpary, corporation or government agency to withheld all existing stocks of KB and PCS containing material. But at the very least, we urge you to seek, on a voluntary basis, the removal of all existing stocks of such products wherever they may be found. KB's are not reslily discernable. They may km buried on the shelves of many of your cun offices or in the many of the hundreds of manufacturers' warehouses in the font of electrical equipment and miscellaneous fluids. Surely, these industries and agencies should cooperate in such a national peeblera, especially when such cooperation is toe nest effective and perhaps the only way to rapidly reduce kb levels in all products.' Finally, existing stocks of KB's and carbonless carton paper must be withheld fran use and, if feasible, destroyed. We hope that your agency will initats immediate discussions with those corporation and gwemneat agencies who stock such material, toward that end. The recycling industry will do its share in cooperating to remove the KB's frem the envixeanent. But to saddle the recycling industry with the full burden of raneval, when it is not even the cause of toe problem is completely unfair and discriminatory and not responsive to the total KB problem, most of which is caused by industrial companies outside the recycling industry. ' ' The recycling industry strongly supports toe Department cf Natural Resources in its effort to eliminate the KB's frm the environment. However, the imposition of the zero discharge rate at this time is unrealistic, unnecessary to achieve the objective and will have a devastating effect. . . - The proposed regulations will destroy toe present recycling programs for office waste paper. This program has taken years to stimulate and pufcin motion It is a meaningful progress since it effectively recycles the high-grade paper that is always in short supply. Wisconsin has made excellent progress in all of its recycling programs. It its one of the leading recycling states of cur nation, having demonstrated this by its excellent reeyeling legislation that was recently passed. Tb now pass new regulations that will, in effect, stifle existing recycling programs, would be a mistake. 18 WTM00555 NCR-FOX-0281412 WATER PCB-SD0000041050 It will erroneously inply a danger and inferiority relating to recycled paper products. Compcehensive federal and private testing programs over many year's period have fully and unquestionably proven the quality and reliability of recycled paper products and thair nonharnrdfd relationship to cne>a health. . Other witnesses will tell you of the other detrimental effects of this proposal, including the loss of jobs, loss of industry expansion in Wisconsin and the loss of taxes to. the state and the loss of costs of products. . He strongly urge this agency hot to reoansend passage of the proposed effluent rates, but to one, reexamine and reevaluate the whole PCS problem as it concerns Wisconsin and two, to propose a realistic plan for achieving the objective without imposing a regulation crippling Wisconsin industry and seriously damaging its ongoing efforts to maximise energy savings and solid waste utilisation through recycling. ' '. me recycling industry stands, ready to cooperate with the Department of Natural Resources and to support any reasonable legislation that will control the affluents and reduce the discharge of all contaminants into the state waterways. - Such realistic legislation must do more--nnst do more to eliminate the sources of PCB's, thereby practicing preventive medicine, rather than inadequately treat the sjoptem of the problem after the damaging PCS'a have already infiltrated the entire economic system. Eliminate the entry of the PCB's in Wisconsin and you eliminate the source of the problem. Thank you. EXAMINER: Thank you, sir. And ycu have a copy of that? KR. HESS: Yes, I do. , .. EXAMINER: Plus the panphletS? . MR. HESS: Yes, right here. EXAMINER: Thank ycu. How, ladies ,and gentlemen, since we are somewhat ahead of schedule and also sinoe Z want to get started.at 1:00 this afternoon with our next presentation, we will recess for the noon lunch recess. It may take you somewhat of a time to find a place to eat. please, if you- have not submitted appearance slips and . plan to be here this aftemocn, submit the appearance slip to me before leaving= ' .... - Off the recced. (Noon recess) EXMQNER: Back on the'record. ladies and gentlemen, we're resuming the hearing which started this morning regarding preposed rules pertaining to effluent limitations of polychlorinated biphenyls to the waters of . the State of Kisoensin, My name is Jim Christensen. I'm an attorney with the Department of Natural Resources and em the hearing examiner far today and Unorrow. The first part of the. program this afternoon will be presentations by various indi viduals at tbe'xequest and cn behalf of the Wisconsin Department of Natural Resources. is Dr. Harold. Humphrey here please? Would you pitying step to the frent, air. DR. ELHPHREJf: Ace you ready? BOHDER: Yes, just please identify yourself end who you represent. DR. HIMHREY: I'm Harold Hmphrey. I'm enyjrcwnantal epidemiologist with the Michigan Department of Public Health in Lansing, Michigan. X was invited to ocme here today to describe a study which I'm directing in which tha Department of Public Health is conducting and the federal----tha Food and Dn^ Administration is supporting. And the study is an investigation of peraens in Michigan who consume fish. IS ' wm0.0556' NCR-FOX-0281413 WATER PCB-SD0000041051 The presence of PCB's in lake Michigan fish actually came to light during tte 1968 hearings an EOT contamination of ccnmercially marketable fish. Guideline levels, as has been mentioned today, have been set at five parts per million fear PCB in fish. The continued presence of excessive levels in Great lakes fish has failed to show improvement, indicating a continuation of the overall problem. Htmercus animal studies, have dsronstrated a dose-related affect for PCS ocrpomxis. They are fat soluble', stored in adipose tissue. They are persistent and toxic effects appear to be related to the degree of chlorine content in the caspcurds. PCB ingestion, either directly or through contaminated food has been shewn to cause, in animals again, liver damage, skin changes, disturbances in reproduction, pneutost^pression and abnormal type dispiaistic cellular growth patterns suggestive of possible neoplastic transformations. EXMEHER; Excuse me, sir. could you speak tp. They're not getting it out there. MR. HUMPHREY: The PCB contaminated fish species of the Great lakes represent a desirable spurt fishery and although the general population receives a degree of protection through IDA. regulations, seizures and etc., sport fishing, which represents a population who, by choice, census* millions of pounds of Great lake fish. Sport fishermen do. not receive this kind of protection. Thus the question does arise, what risk does consutptlcn of sport fish represent to the health of this particular population group. Knowledge of the toxic effects of PCB's cm humans canes principally from an episode in Japan in 1968 and this is the new familiar Yushcw(phcnetic) disease, in which case--where over a period of time about a thousand people were exposed to daily---to rice oil, an oil used in their daily cocking and a variety of maladies were recorded in hunans, including things such as increased pigmentation of skin and nails, swelling of the upper eyelids, impairment to vision dueto eye discharge, nurtaess, edema of the limbs, persistent headaches, weight loss, fatigue, gastro-intestinal synptans, including ahdtiwna.1. pain and disturbances in liver function. I merely mention these because when I describe the study later, We were, asking people whether or not they had had such signs and synptons. This Xushar incident ahaed that the effect in this Japanese occurrence was a lingering one and that was suggestive of the possibility that in hunans, there's a long biological half-life. Now, admittedly, consurption of Great lakes fish does not represent a magnitude of exposure, as shown in the Japanese Xushcw incident. However, the suggestion of a long biological half-life for PCB's in man, allows the assinpticn that if PCB's are ingested and if such ingestion continues, the. ccnpound could acetnulate in tissues for a long period of time by this long-term, low level exposure or through internal recirculation of the chemical as it remains in the body. Thus the habitual consumption of contaminated fish from the Great Lakes represents a hypothetical means for accumulated, perhaps a clinically significant dose of PCB's. TO date, data concerning prolonged human exposure to low levels of PCS as represented by fish consumption in the United States has not been available. Likewise,- the relationship between the quantity of contaminated fish construed and the accumulation of .PCB's in hunans is unknown. Such infanraticn is necessary in order to assess the huran health significance of the present situation in Lake. Michigan. The study, entitled, "Evaluation of Changes of the level of Polychlorinated Biphenyls in Huran Tissue" vras begun in 1973 by the Michigan Department of Public Health with FDA. support. And this is'the study I want to describe to you today. The field work phase was just completed this past sparing and the analytical data is new being generated in our laboratory. I cannot give yen what will eventually pane cut of the study, that is, the hard and fast analytical data, but X will be able to tell you how we've approached this problem and what the study--protocol is. The investigation represents an atteept to study the effect of exposure to PCB's from consuming fish, primarily sport caught fish froa the Great lakes. And again, the absence of of a decline in the levels of these materials in the lakes demonstrates the problem which was being addressed in 1973 does, indeed, still exist today as fax as fish contamination is concerned. The PCB study has catprised two major efforts over the past two years. One is an epidemiological field survey and the other an analytical laboratory program. The primary objectives far the study have been--and I've got five of them here. Ntnfcer one, to identify exposing control populations in selected geographic locations where PCB levels are known to be excessive in the fish. To select participants for the study and collect suitable blood specimens,, using acceptable epidemiologic techniques. Three, to record the intake of the PCB levels in the fish meals actually being consumed by participants. Four, to develop a sensitive laboratory method for detecting PCB's--PCB concentrations in human blood. And fifth, to determine by laboratory analysis, the concentration of PCB's in participant blood specimens in order to evaluate the ingestion of PCB via fish meals, the PCB levels in bleed f banana who do and vto do not eonstsoe .these fish, the variattaia of PCB levels in blood due to 20 WTM00557 NGR-FOX-0281414 WATER PCB-SD0000041052 the seasonal oonsurptim habits and lastly, to estimate ths metabolic half-life of PCB'g in the blood a hunans. The work for the study was done in four Michigan camiunltles. I'm assuming everybody tare is familiar with the State of Michigan. If not, look at the back of your left lend and the ccrumnities rare Traverse City, Manistee, laddingtm end South Haven. These are ail camunitles that border on the lake Michigan shoreline of Michigan. In addition, from the previous study that we had done on mercury, we had available control- wmplcs frua Algenite xrA also from South Haven far testing for FCB's. . The residents of the oamunities were selected for'the study on the basis of sport caught lake Michigan fish consuspticn habits and were categorised as. either exposed fish eaters or noneater control people. In order to qualify as a."fish eater", the participant had to have consumed at least 26 pounds of fish per year and again, this would befreshly caught lake Michigan fish. This is the equivalent of a half a poundfish meal per week.- TO be a control person, preferably they censured no fish at all, but no mere than six pounds per year was allowed to have a person qualify as a Control. The study involves approximately 200 persons, so when X mention oenmunities, I'm not suggesting that we surveyed entire communities in. the state,' but rather these would he statistically selected portions of the populations of -the calamities. Persons were selected far participation on the basis of responses .to a personal, interview. The control group was selected by a randonly-picking names'fran the Folk City Directories for these ctirnunitiei and then visiting the households. so selected and the---upon visitation the decision was made as to whether ti person could qualify as a control. So the controls in the study were randomly selected. The exposed people were either picked up through the random selection, which is a very minor portion of the study group, but more principally, the exposed group were identified by wood of mouth Or referral. . 1 t . ,. - Sport fishing in the Croat lakes is a fairly visible hobby and it was quickly evident that various officials, friends, neighbors, family, could quickly identify people who were sport fishermen. These people were approached, identified and if they agreed they represented the exposed portion of the study. Of course, they had to consume at least 2$ pounds of apart caught fish per year in order to qualify as an exposed 'participant. A questionnaire was developed for use in the study and basically it dealt with trying to gain information from the people with regard to their*--to the members in their fnily, the amount and--a -special focus on the fish oonsurptirm that participant had, including a location of where they caught their fish, the species they ate, the frequent of sating these fish, the quantity of fish eaten-and the gradation of their preference-for species. Other information, such as occupation, major medical events and the occurrence of specific medical conditions was esked of ttese people also. Die specific medical conditions that were asked of the participants included a fairly long list end many of .the kinds of sighs of symptoms that are typical of those reported fran Japan fcr Yushow. ' . Over the duration of the study, which la. . has been a tao-year study,, contact has been maintained with the participants to retain-their.interest in the study end to collect blood specimens. Mow, a person who. participated in the study, if they ware a control person they'd have been.randonly selected; they were interviewed onoa. It was confirmed that, indeed, they qualified to be a control. A 20 cc blood sample was obtained and. that was primarily the ryf theix :. The fid) eaters ware located as I described, by ward of mouth, tracking people down, talking to pecpleia ccmrunity groups or neighborhoods or what not, potential fish eaters ware located, identified, interviewed. A good deal of questioning went an to confirm, indeed, that tlrey qualified as fish eaters and these people were folly interviewed and asked to participate in a study for a prolonged period of time, which would, include multiple samplings of their- blood fear testing. - '. In addition, exposed fish eaters were asked to maintain a dietary log and zeooed when and what kind of fish they ate. Again; the emphasis always being cn--not on oatanercially purchased or restaurant bought fish, but Lake Michigan caught fish. And also they ware asked -bo save portions of their fish meals so that we eventually, fran fish eater participants, would have a dietary log of their fish consumption habits and a awpling of tha meals they had censured over the period of time that, wa were taking blood levels. Obviously, what we're attempting to do here is see if there's a dose relationship;going on. Tha first year of the study 168 participants were identified, selected and intarvimed in tha suarer and early fall of 1973.. Of these, 33 ware randomly selected.eonhrel paeple and 135 were initially categorized as fish eaters. I won't go.into the breakdown, but they ware distrilxrted ever the sr cities, with people fism Traverse City cocposing ths bulk of the 168 and appreoeimately 20 to 30 foa Manistee and luddingten. 21 . W3M0Q558 NCR-FOX-02814 WATER PCB-SD0000041053 The proparticn of fish eaters to controls that were included in the study was intentional. We had fewer controls than we did fish eaters. This figure was arrived at on the advice of statisticians during the planning stage and as X mentioned earlier, we had control people from an enrlinr study of mercury in Michigan to draw cm for additional control sanples. At the end of the fishing season in 1973, blood samples were drawn for all participants and it was intended that this sampling would provide a measure of PCB levels in these people--in the blood of these people at the end of a fish-eating season and would also provide data for future ccnparisons for the next year. The following spring, spring of '74, a subset of the Traverse City group of fish eaters were sampled prior to the resorption of the fishing, season in order to evaluate changes in PCB levels in these people during the winter layoff, again remembering where folks--folks go cut and get fish from the Great lakes and there is a definite time when you can and can't take a boat cut, at least without risk of life and linto. '- Another subset of participants was sanpled at--two times during case day to provide a fasting and a nonfasting blood specimen. The point of this was to determine if, depending cn the lipid mobilization of the body during fasting, if this also mobilized PCB levels in tie holy from their stores in the adipose, thereby changing the blood levels. And the secondary purpose of this was also to determine which kind of blood ssnple should be taken an a routine basis, whether it he fasting or nemfasting. During the second year of the study, again the principal cities were Traverse CLty, Manistee and Inddington were revisited and approximately 100 people included in the second phase. Sane of the fish eaters were from the previous year and sane new people with an emphasis cn higher fish ccnsmpticn habits, were recruited.' Hat, these people, at this time, were followed in very great detail from the beginning of the fishing season to the end and when X say in detail, this--I'm thinking of multiple sauries of blood during the summer, dose maintenance of their . dietary logs and records, encouragement to keep these up, reminder to save portions of their fish meal. Essentially what we were trying to do is make sure that the fish consumers were keeping as close track as possible of their actual oanstmpticn of lake Michigan fish. And as X said earlier, this was--we were trying to--we will eventually attempt to see if there's a dose relationship here that we can establish. Blood specimens were collected during the simmer to represent--several times during the simmer to represent an increase--to represent changes in PCB level which might he occurring during the intake of fish. Then at the oonclusicn of the fishing season, the fish eater participants were asked to refrain from eating any further fish. In other words, abstain. And once their fish eensutpticn ceased, that was the zero time, then samples were taken at IS days, 30, 90, 120 and 180 days after they ceased eating fish. The atteapt here was to see if we could evaluate a change in the PCB level in the humans---in the blood of the limans over this time and establish a half-life fcr PCB in bleed. That fairly well describes the protocol of the study and alludes to the kinds of things that we are trying to find. X might just add here that the analytical testing of the blood, the conpored blood samples is done at the Michigan Department of Public Health . laboratory. A geed deal of time and effort went into developing a suitable analytical technique, the carpiicatiig factor being the presence of COT in the blood of most people and that causes interference in the identification of PCB and secondly, the affiliation of ary PCB's in the with the lipid oorponenta to the bleed requiring extraction--an extraction step. The third procedure that was finally agreed on is a fairly direct one using gas chromatography, but a number of different techniques to improve the sensitivity of detection of PCB in blood were tried and eventually rejected fcr the final technique that is in use. The sensitivity of this procedure is five parts per billion concentration in hinerl ard this is primarily being the peaks for Aroclor 1254 and 1260 are the standards that are used to verify the PCB's that are being measured. And the recovery of PCB from spiked sanples is running between 94 and 100 percent, so that the technique appears to be fairly accurate. Now, I would like to conclude with a couple of things that we have came up with just in the last couple of days with regard to seme things that we're seeing out of the study. Again, cn the of testa on the blood sanples, Z can't make any statements yet regarding that because of the fact they're not available. Bowever, we have taken a lock at the response to the questionnaire portion -the portion ef the questionnaire regarding the health symptoms. Basically, as X b-m a matent ago, this was a list, sort of a laundry list of symptoms asked in the way, in the sense of I'm going to list some health conditions. Tell me the ones you've experienced, when the condition began and if you saw a doctor for it. And then you run through a list of about 18 different things. These items included things such as numbing--numbness and tingling of the Hubs, discharge and swelling of the eyelids, skin eruptions and problems with akin . 22 WTM00559 N C R-FOX-0281416 WATER PCB-SD0000041054 pigmentation and tha like. This is a mean type of list. And basically what has been seen as--so far as that is concerned, there's no difference, between the fish eaters and the central people in their responses. No statistically significant difference. BfflMINER: Does that ocnplete your statement, sir? MR. ECMEEKEY: I have one mare ccraoent to make. DCAMINERi Ckay. . MR. HMPHREY: Cue other piece of information which is beginning to evolve is a ---the characterization of the fish oonsuqsticn of people.. The people classified as fish eaters or the exposed people, ws found oh the basis of looking at 75 of these, the range of fish exsnsuqption, poundage, was from 25 pounds to 260 pounds a year is what tiny recorded they ate. She bulk of the people, 56 cut of 75, ate fish- in the 26 to 60 pound range. Thirty-five people ate fish at the rate of 26 to 35 pounds. . Basically what I'm saying here is that it appears that fish eaten; we're talking about--about a meal a week so far aa ccnannpticn rate. There were only ten people vho ate greater than 84 pounds of fish, per year and.of these, only three ware above 206 pounds of fish a year. How, at 200 pounds of fish per year, that's approximately 20 fish poo month. So again, this is not fully completed yet, but it appears that even then you seek heavy fish eaters, by world standards, these are not vast ccnsurpticn quantities. And the--the other thing that characterized the fish eaters is they--although they catch the fish, they tend to distribute their catch among a family cr friends, viiich leads to. a member of people laving an occasional fish, irieail at least and the amount of fish that they consume is not consistent from year to year. Tiny might catch 50 pounds in one year, and depending cn the waves, the weather arc the ability to actually catch fish. They may only eat 20 pounds the .second year. . In conclusion, we're optimistic that this investigation will, for the first time, provide information about ECB's in haaans from the Great lakes situation. And we're optimistic that it will provide data on the amount of fish oensurptien by people in the Great lakes area. The PCB dose received from Great lakes fish, the body levels of PCB's of both control aM exposed persons, annual changes in PCB level- and half-life changes in PCS levels in fish. Thank you. ' dene. DOWUERi Dr. Buaphrey, I just have you will provide a Copy of that when you're HR. HUMPHREY* Yes. - \ EXAMINER! I just have a couple of real quick questions myself. Do I understaml that the sapling, itself, the blood saspling is completed? MR. ELKFHHEIj Yes, that's correct. EXAMINER: And when do you expect the results of the sampling to be published? MR. HUMPHREY: We're obligated by contractual arrangement with EDA to have this data ready by the first of the year or during January. EXAMINER: And would it be possible to provide the Department of Natural Resources with a copy of that study and the results? MR. HUMPHREY: I eaqaeest it could be; yes. . EXAMINER: Cfcay. Thank you very much. Kw, does anyone else have any questions of Dr. Bmphrey? Wbuld you please step up here to the mike, sir. It is being recorded and that way we can get your statement. Please identity yourself. . MR. TTTflfM: My name is Bd Tilacn. I'm trying to find how long the study is going to he eontinued. X might have missed that. '' MR. HUMPHREY! The study has been going ax fee two years. It started in 1973. It was--the field, pertiesi was ocapleted -this past summer. It----the support---tha financial support for the study has been a esntractual arxahgmnent with tha EDA so so & as that phase of it is bemoerned, it is finished. Obviously the. interest in the problem remains and it--at this anravt there is hs> definite plan to go forward, but as generally the case with these kinds of things, I'm s maiy intriguing questions will be raised by the results. ' 23 . WM00560 NC R-FOX-0281417 WATER PCB-SD0000041055 EXAMHGR: Ckay. Any further questions? CNo response) SSSMDERj Ckay. Thank you very such/ Dr. amphrey. Is Dr. J. R. Allen present? Okay. Vfculd you please identify yourself and make your presentation sir? . DR. AT.TCTi: I'm Professor j. R. Allen of the Department of Pathology at the University of 'Wisconsin. I've been doing research on the polychlorinated biphenyls for a matter of years. In 1967/ even before the Japanese outbreak of polychlorinated biphenyl intoxication, we were doing research on the particular effect of the polychlorinated biphenyls on the liver, particularly on the liver enzymes. Following news of this outbreak, we modified some of our experiments to include same of the biological effects that might be experienced frtatt exposure to the PCB's. Our first procedures were to try to establish the most suitable experimental animal model. And within a relatively short period, we found that the nsnhuman primate developed the syaptems and the ' lesions E/milar to those that occurred in the Japanese outbreak of 1968. In our initial studies we were trying to determine really at what level these ocnpbunds were toxic. Early studies had 300 parts per million in the diet, produced extreme morbidity and mortality within a period of two to three months. As was the case with the Japanese, these nenhaaan primates; they were rhesus monkeys, developed a loss of hair, swelling of the face, accumulation of fluid underneath the skin, a loss of the eyelashes and a decided acne. Case that died, and all of them did eventually die, they had a severe gastritis, marked thickening of the walls cf. the stomach and ulcerations of the wells of the stomach. In our subsequent, experiments we fed another group of rhesus monkeys 100 parts " per million in their diet. - It was in a period of three weeks they began to develop the signa and the lesions that 1 had mentioned that occurred in the 300 parts per million groigp. And here again, within a period of approximately two to three months, all of the animals had expired. In our next experiments, we decreased the level of intake of these animals to approximately 25 parts per million of the polychlorinated biphenyl and I must mention here that this is the PCS Aroclore 1248 that was used in all of the experiments unless I mention another ecupound. In the 25 parts per million group, we fed animals for a period of two months, and at 25 parts per million they developed the loss of hair; they developed the loss of the eyelashes, subcutaneous edema and a decided acne within a period of approximately three weeks. By two months, it was obvious that these animals were.... they were ill and unless they were removed from the experimental diet they would have expired. He took them off of the experimental diet and one of the six experimental animals expired two months after having been removed from the diet, here again with the classical signs and lesions of PCB intoxication. He have followed these six1....the remaining five animals for a period of new approximately two years. After two years, they're still showing signs of PC3. intoxication. These animals have been bred. He have had at least six infants freet the five surviving animals. They are extremely snail and average weight of a rhesus monkey at birth is about 475 grams. These animals invariably weighed in tbe neighborhood of 350 grams. They had detectable levels of PCS's in their tissues at tbe time of birth, thus indicating a transplacental movement of this material from the mother through the placenta into the infant. As we left these infants on their mother and they nursed, there was an increasing level of PCB's in their tissues, thus indicating and substantiating the Japanese work as well as otters that there was an acarmilation of the polychlorinated biphenyl in the mother's milk aid could be given to the infant at the time of nursing. so in these experiments after, two years, we have definitely shewn that there is a rprffjet-orxT. of PCB's in the mothers and there is a continued elimination of this material via the placenta to the infants. NOW, probably the one of the more interesting experiments that we have done and this has just recently been oaqoleted, is we fed levels that were similar to and cne-half that permitted in certain foods destined far human ccnsunpticn. We fed levels of 2.5 and 5 parts per million. And you know, in certain fish products that they are allowed five parte per million, others, why--other food products certainly it may be less than this. However, to as surprise, these animals at levels of 2.5 aid 5 parts per million in their diet and they were consisting this on a continuous basis and hot as man would as he eats fish or whatever it stight.be. They're consisting this diet containing 2.5 and S parte %r 24 . HIM00561 NCR-FOX-0281418 WATER PCB-SD0000041056 millim within a period of apprcodmataly two months, these animals began to lose their hair; they began to lose their eyelashes. They began to develop chloroacne. Within approximately four mouths, they began to show irregular menstrual cycles. They had atteine---particularly the five parts per millim group had attained a relatively steady state of the PCB's in their tissues at six months. We attainted to breed these animals to control males. . we----in the 2.5 parts per million we were able , to get---well, all of the animals conceived. And this we determined by tnaiinc (phonetic) assays. All of the animals conceived and within a relatively short period of time, they--the five of them were able to carry their infants to term. The three remaining animals either aborted or resorbed their fetuses. These are the 2.5 parts per .million. Six of the eight experimental animals cm the five parts per million ccmoeived; however, cmly one of the animals was able to. carry their infant to term. The remaining animals either aborted their infants or they were resorbed. These data indicated to us..that really there would /appear to be no marked effect upon the ability of these animals to conceive, yet there appeared to be a decided effect upon their ability to cany tvte infants to term. We have carried these animals bn this diet for over a year. They have still persist in showing signs of PCB intoxication. We axe presently in the process of evaluating the biological effects of the PCB'a on the infaints, particularly as it relates to their physical status and to any ^behavioral eat learning .Ahncrmwl ities that may arise in these infants. We are nine initiating studies that are underway at the present time to mare closely simulate the intake that man secy have as.he eats the fich or other foods that are exposed to the ECB's. And hopefully within the next year we will have seme data as to whether these levels will be trade. However, at the present time wa have.ret established a level of PCB when iwniinHi on a continuous basis..thaf is ncntcedc to the nonhuaan primate. . Hopefully the levels that we will---we are feeding at te present time will be rentesde. This is one aspect of our studies. He have also done extensive metabolic studies con cerned with the absorption, this tissue distribution and metabolic fate of the polychlorinated biphenyls. This to us is.quite interesting in that in these studies we have'determined, that there is, particularly with the lower.Chlorine Isaners and I'm sure that it's already been men tioned that the cannercial PCB's are imposed of many isaners, that.tbere is an entirely different metabolic fate of the PCB's in the nonhureah primate and in the laboratory rat. The laboratory rat is able to hydxoxylate these ccmpcunds and excrete then quite readily. The :nonhjnan primate does not do this nearly as readily. It has to go through an intermediate metabolite known as the arena oxide interatediate. This particular arene oxide is capable of oarbining with tissue micro- ' molecules su=h as ENA, ESA and protein and may give rise to extreme deletrioua effects. These . studies are.being pursued in detail in cur laboratory at the present time. He do not know and. it is our concern what the lew level exposure, particularly in the nanhuman primate, of these- conpcmds will be--maybe not today,, hut in .five years ot ten years and thin is our concern at the presort time and these studies, are being carried out in laboratory animals and also in quote,, ''the test tube", in vitro o$eriments. . \. EXAMINER.: Thank you, air. Only one question for nyself. Knot's the. Iciest level of PC53 foods that are being fed to the monkeys at the present time ; the rhesus mmkeys? DR. AIIEN: The lowest level--the lowest level that is being fed to these monkeys at the present time that we have ary data at all on is 2.5 parts per million in the diet. SXAKDSR: Gkay. Thank you very much. Does anyone else have questions of Dr. Allen? question. Sir, would you please step up to the microphone, identify yourself, state your . DR. HMEHHEI: I'm Harold Humphrey. I'd like to know, have you bad the Arcelor that you've been feeding, confirmed as to its purity? Are thera.any contaminants in it? - DR. ADEEM: This we have done and this is a point of 1 think all of our concern, There are two that I'm aware of that may be there in these Aroclors and certain there's a recent report in nature indicating that seme of the Aroclors are raitaminated with the dioxins, which are very potent teratogens in sane of the--and the lb 50 on these and sons of eaqpesiitental imimata is quite low. The other are the dihemal teens (phonetic), which- are aim rather tox-is, So yes we have and it is, as far as I'm concerned, free of these particular contaminants. There are others, X don't know. These are the two that wa have concerned ourselves with. . 25 . WTM00562 NCR- FOX-0281419 WATER_PCB-SD0000041057 EXAMINER: Thank you. Or. Kisrphrey. Anybody else have questions of Dr. Allen? (No response) us? ' EXAMINER: Dr. Allen, do you have a synopsis or a report that you could fils with DR. ALUM: I'll find it. EXAMINER: Thank you very much. I appreciate ycur appearance. Okay. The next person appearing on behalf of ana at the request of the Department of Natural Resources is Mr. w. B. Papagecege. Kill you step up here please, sir? Ycu can just please identify yourself and rake your presentation. MR. EARAGECRGE: I am--can everybody hear me? I am William Papagecrge. I am William Papagecrge, manager of product acceptability with Msnsanto Company, located in St. Louis, Missouri. I've been associated in varying degrees with polychlorinated hiptenyls for a little ewer 20 years. I have been intimately associated with than practically full-time for the past five and a half years. And during that period of time I'd just like to take this opportunity far a few moments to express three areas of Concern 1 have which in my opinion prevent us from really identifying our problem and, of course, cnoe we've Identified it, take appropriate action to cope with it. The one that cones to mind immediately is this tendency on maty of us to use the acronym PCS to describe really ewer 200 different cteudcals, many of which have different properties, both chemical and physical. Samples of that would be the rate at which these materials would , degrade if exposed to similar conditions. There is a demonstrated difference.' it's ny ' considered opinion that if we could just turn the clock back and only use let's say 1221, a 1232 and even a 1242 and no others, we. probably wouldn't be sitting in this zoom today. I just don't think a problem would have developed. ' Another area that we might want to consider briefly, tte presence of PCB's has been reported and they are described as being ubiquitous. They are found in places that have challenged us to try to explain just why and how would they, get there. There are, of course, as you 5mcw, ' many reports in the scientific literature relating to PCB's. The last rather I'd heard quoted were there were at least 1,500 known. Most of the reports' that X personally have seen address themselves to reporting presence of PCB's in the environment. And invariably, those of you that follow the literature will note these are described as being equivalent to Axoelor 1254 cat 1260. Now, sate of the earlier work--this goes back to 1970, 1971, there were a few investigators that identified say an Aroclor 1248 occasionally or a 1242 and there was even a few that had a 1232 identified. But as time goes on and the present time', more and mom of these reports reflect what appears to be an Aroclcr 1254. This ought to be telling us something. . The effect* on the envirorment--we still need en awful lot of information to bell us a lot mere about the fate and effect of these PCB's on the environment. There have been seme speculated reports that' try to tie in the presence of PCB's to ease observed effect. Mary of these early reports have been discounted since then. X have, in mind, for example, the reference to the demise of the brown pelican off southern California because the egg shells just couldn't sqppcrt the weight of the hen and the eggs weren't hatching. That was disproved by the laboratory located in Laurel, Maryland, by Dr. Robert Eeath. There was a report in 1970 regarding the sea birds and seals in the north, sea. That was discounted later by the ministry in the United Kingdom. There was no relationship established because they found that apparently healthy animals of the same species had higher levels of FCB in them than those that had met their demise. . Hell, the only reason X mention those is to point out that we still lack a lot of information. Evidence that animals are affected cr creatures are affected by levels of PCB's have generally, have to ay knowledge--to ny knowledge have cane, fran laboratory studies. And in those instances the levels used appear to me to be higher than those found in the true, natural environments and then X personally find it very difficult to translate the pristine conditions X have personally observed in a a laboratory With such situations as you might find out in the real world. And with co^lsc materials like PCB's X personally wonder about this jtaping into conclusions that we find ourselves doing. Another area, and X think this is most important, is our ability to sample and analyze and get reproducible results within a laboratory and fsm laboratory to laboratory. We 26 WTM005S3 NGR-FOX-0281420 WATER PCB-SD0000041058 have found within our own canary between two laboratories, we find as much as piTM or mirnw 50 percent variation. There is sane dispute about ability of laboratories to cane up with the sane answer, far the sane sample. Under the auspices of the ASTK, there's a study raw uiderway, a round robin, in which 12 laboratories representing industry, government, both Raradiim aid U.S. and gjiniercial laboratories and academic laboratories , to participate in a rourd robin and we are looking forward to see diat the results will tell us. So mud) for that. 1 was asked really to talk about past.tues, current uses aid amounts produced aid.sold in the United States. The past uses, as most of you peehebly know . by new, were many aid varied. They seem to really be a function of the economy, aid its growth and a function of advancing technology. The initial uses were primarily, of course, the dilectrie uses in transformers aid capacitors. During world War II there was such developiental work going cn so shortly after World War II these materials found themselves, in uses such as special paints, inks, sealants, caulking materials, plasticizer for thei then new synthetic rubbers, An attenpfc was made to use sate of them in floor tiles to make then fire resistant. These kinds of uses. They go cn aid on. Virtually anything you can imagine, at one time or other, someone tried FCB's in them. ' . ' . ' The big inputs came through about three specific areas. Following a serious fire in one of the automobile txanasissien plants in Michigan. The change, ftan mineral oils to fire resistant hydraulic fluids took place, kid KB's played a big role in that, industrial hydraulic fluids. MOt your automobile hydraulic fluid, not the .airline hydraulic fluid, but industrial types. Generally where there's hot molten metal and high pressure hoses and they do leak and the intent is to keep fires to a minimum. Another big use that developed was the need for fluids that could withstand high temperatures to be used in heat transfer systems. As our technology evolved, the need far higher aid higher temperatures came about and this offered an opportunity to, use high temperatures and not have to resort to high pressures, which in many areas require licensed operators and safety devices of all sorts. . A third big use that came about in the early '60's was the application of the carbonless copy paper that we all know about. So each of these represent* a sharp rise in use aid as sort of a gradual increase following the growth of our eocnsny. In 1970--early 1970, Monsanto.decided to withdraw fraa these uses which in our opinion represented almost a total aid quick release into the environment. So we withdrew from all of these sealants, caulkings, paints, varnishes, lacquers, plasticizer for synthetic rubbers, matings for fabrics, all of the uses that'as X said earlier, in essence amounted to full and easy release into the environment, either through poor incineration or disposal in sewage systans or open garbage dorps aid the like. This occurred--then this went into effect in August of 1970. The next material1 that we removed' from use car the next application was its application in the carbonless copy paper and this started to phase out in late 1970 and tlwi last.truckload was delivered as 1 recall about April, 1971. And during that period it was a decreasing amount into that prooess. ... .... - . . Finally, in.1972 we withdrew fin the heat transfer application because we had learned from experience that although these could he sealed tight systems, it turns out that we couldn't rely, cn this, and so we withdrew from the marketplace, forcing our ecc-customers to : geek alternative fluids aid I'm told to this -day they have not found any. Me have not found ' any that are fire resistant. So they had to redesign their systems, introduce fire walls, sprinkler systems, fire detection devices aid pay increased insurance premiums. So today aid as of 1972 wa sell only to the dielectric applications, such as the transforners and capacitors we've all.htord of. Aid this is dene under certain legal require ments from our customers. They don't like this aid X can appreciate why, but they're asked to sign a docupent in which they assize full possession and ownership of the material as soon as ' it leaves our plant gate and they maintain, control cn it from then on Cuto In conjunction with this withdrawal fran the marketplace, we also found that we had to build exarsalves an incinerator to dispose of the liquid wastes because we kept telling our customer? don't dispose of it improperly and they always cams bade, well, if we can't do it the old way, what;do we do with it? . So we designed a liquid incinerating unit and we offer that service to a custaner for a fee. There are, of course, since then cannercial units also available operatod fcy people in the business Of disposal. .- The production aid sales data; I have here, a chart that I'll leave with the examiner aid there are a few copies for those of you are interested. This Inforaation is the best we could put together froa our existing records. It takes us back to 1957, gives us the full year for 1974 aid a the last page is the first quarter of this year. The peak year was 1970, when we produced 85 million pounds and there's a breakdown there by use category aid at the bottom of the page fcy taoelore type .that you might tSnd interesting. ' 27 UTM00564 NCR-FOX-Q281421 WATER PCB-SD0000041059 Currently we ere producing at about the 40 million pound per year rate. We have shut down one unit that used to be located in Alabama and disposed of that unit. The production is oomentrated in Illinois, across the river frm St. Iouis. Bsose 40 million pounds go into these dielectric uses. I'm told that this year in particular, it's about---half of it goes for transformers and the ether half goes to capacitors. The ratio -varies with eccmnic conditions and the needs of the marketplace. I'd like to point out sane interesting pieces of information in this. Keep in mind the 40 million pounds used today go into sealed systsns which we believe can be controlled to a satisfactory degree, This would indicate then that the additional 40 million, in essence, got out into the envirenneat within the year. Once you reach seme sort of equilibrium, amount put in equals amount that's escaped. So 40 million pounds per year are no longer entering the environment in this country. I am not trying to speak for the rest of the world. I like to think that something ccnparable is happening in Europe and in Japan, of oourse. Another interesting bit of information, through the years *b have tried, knowing that the higher the chlorine level, the more persistent the material, to shift downward in the chlorine scale and trying not to sacrifice dielectric properties or fire resistance. So we've eliminated the use of, for example, Aroclcr 1260 in transferrers. And our customers agreed to go with the use of 1254. We have gotten away froa the use of Aroclcr 1242 and introduced a distilled version of Aroclcr 1242, which ve refer to Arcelor 1016. This Aroclcr 1016 contains one percent or less of the five chlorine and higher isomers. The old 1242 used to oentain about ten percent. Now, we're not sitting here saying that this is the panacea or the curea.ll. All we're saying is that we believe that this is a step in the right direction. Should any of this material, get away from us, and it can happen, the chances of it being handled by the environment are that much better than they would have been with the higher chlorine iscmers present. We have been criticised in a, way when people look at these numbers to say that the rationale follows this logic. Aroclcr 1254 is the tjpe found in the environment. Monsanto says that they have reduced the open uses and yet their report stows they make as such Aroclor 1254 as they used to in the past, therefore the pebblm continues. The fallacy in that type of thinking is that they do not take into account that 1254 used today is in a steel box into which --you can only get into it with a tool, a wrench, for example, to open up a pipe plug or what have you. In the past much of that 1254 ended 19 in adhesives and inks and caulking materials, varnishes, traffic paints and so an. So there is a decided difference in the type of application and its exposure to the envirccsrent. Another change, of. course, is the 1254 that is now substituted for the old 1260. So the amount of 1254 remains somewhat the same, but it's certainly in a different application. I do not have a prepared statsrent, Mr. Examiner, but I do have the table and I also have a statement that describes cur marketing polity which is available--anybody which I have paraphrased as 1 spoke. very natch. EJOMMEH: Ckay. Fine. I'd like a copy of each if X could, please. Thank you - Is that the end of your statanent today? MR. EAPAGEEBGEt Yes, sir. EXAMINER: Ckay. Does anycne have questions of Mr. Papageorge? Please Identify yourself. MS. VE3MER: I'm Linda Weimar with the University Sea Grant Program. X wonder, can you tell me, are any foreign catpany selling PCB's in this country and if so, about tow much of the PCB's construed are ocming from that source? HR. PAPAGECKGEs I can tell you what I've been told by the Office of TtecLc Substances at ERA. Now, there are representatives of that grot?) in the audience. BffJSNHU They're oaring tomorrow. 1. HffAGBCSGEs They'll be here tanarrow? I can only give you second-hand informa tion. AH 1 know is there's setae coming in and that's been reported by B?A. And if they can't halp you, I'd be happy to--whatever the examiner desires. Nhafc is appropriate. 28 WTM00565 N C R-FOX-0281422 WATER PCB-SD0000041060 SXHOXSR: If you wish to give a paraphrase of what year understanding is, fine. We can verify that tomorrow with HA. ' ' MR. PAPAGECPGS: All right. I am told that in 1974, I'll try to recall: tl* lumbers as best Z can, about 40,000 pounds of a material that has 42 percent chlorine was recorded as entering this county and about 350,000 pounds of a.chlorinated turf fennel (phonetic), this is . a three benzine ring group, which, has. about 60 percent' chlorine was recorded as having entered this country. And if that turf fennel is anything like the material Monsanto produced when we were making it--we no longer make- it, Z would suspect--I would not be surprised that it contains up to about 10 percent of biphenyl in it and which would, get chlorinated. . Does that help? EXAMINER! Would you please step- up the mioephene. ' MR. T3XSCN: My name la Tiinon. Bd Tilsen here. Z was in the--Z was speaking with somebody in the electrical industry and he said that the name under which your product is marketed is Paraaol; is that true? MR. PAPAGSQftGE: Pyzanel is a trademark of the General Electric Corporation and we blend a material and package it for the General Electric Company. . MR. THSCN: Well, given that--what I'm trying to bring out here is that that might scundbetter, for instance, to make a reference to.a paraffin carpcund, which this is not, as opposed to a benzine derivative, a dibenzine derivative which it is, which might alert people . to the tcodcify of it. However, ny question here isvhcw do you avoid troubles with trademark--tradonark restrictions given that Pyranol is apparently a registered trademark of Abbott laboratories far pararemincghendl. MR. PAPAGECRGSs Sir, Z'm'not aware that that's true.. All Z know is Pyranol, P-y-r-a-n-o-1 is aregistarad trademark of the General Electric Company. ' MR. TZLSCH: Ckay. That explains it because this is P-a-r-*-n-o-l. It's p-a instead of p-y. . MR. PAPAfflQRQBs Z'm sorry. That's right. P-y is the GE txadaoark. . EXAMINER! Any other questions? Step up to the microphone please and identify yourself. MR. HREMERs. Z'm brl Bremer, U. s. EPA, Chicago. X have a couple questions. Mow, you indicated that you have an incinerator system u&ere customers say send beck liquid wastes; is that right? MR. PAPAGECBGE: That is correct. MR. BRSMBfe What do they do with their rags and their solids and so forth, this type of thing? I've encountered this on a couple of inspections where we have customers that, will ---they'll have.liquid waste end they say "(fell, yes. We can send that back to Monsanto." But during our rebuilding process and so forth, we have rags and other things that; are contaminated with the product. VSiat do we do with that? And we tell them, well, we'll ask you. that do they do with it? ' ' . '. MR.. PA2AGECRCE: All right. Tint's a good question, a difficult question to answer because facilities far the proper incineration of solid material, are not to ny knowledge available today on a eanoercial basis. There are a few snail units where you can take a drum of material, sort of a muffle furnace and seal the door and let it evaporate or vaporize, for a 24-hour period and destroy them in that fashion. But there is, to ay knowledge, no commercial incinerator that will handle solid material that requires high temperature incineration. Therefore, lacking that resource, we.have to reluctantly suggest, because, we don't have a better answer, that they find a wen operated, properly operated dry landfill and dispose of the material in that fashion. And that's the best we can do today. MR. SHEMERi Would you clarify something for me on your Areolar 1016 and 1254. 1 saw ^publication that ms, oh, X guess in press or in progress and I notice some graphs and so forth in there and it indicated that you do have soma degradation of 1254. And on looking at that data it seemed that 1016 ms somewhat the sans; is that true 'in terms of degradation? . 29 ' WTM00566 NCR-FOX-0281423 WATER PCB-SD0000041061 HR. PAPA3BCRGE: No, there is a closer resemblance to 101$ to 1242. Z don't too/ which report you have in mind, but 1254 from the reports I'm familiar, does shew an observable difference. Thera is hot that much similarity. Do you have a bacteria study in mind or an animal residue study? MR. BREMER: No, it was just one of your in-house reports and maybe scracre coald clarify that for me later, but it seemed that when Z locked at the graphs in there, that the 1254 and 1016 were quite similar in terms of that degradation and this is why I expected that possibly in terms of persistence of 1254 in the errrixorment that because of your production figures and so forth, in terms of 1016 that we might expect scroewhat of the same problem or a similar problou with 1016. It's a concern of ours. MR. PAPAGBORGS: Z'd be very surprised--in fact, it isn't a rational conclusion, knowing what we knew about the isomers present in 1016 and the isoaers present in 1254. Z think the chemist will tell you that there is----that's an easy difference to detect on the gas chronatcgraph chart. There is a definite difference in the two. And the 1016 is more closely --more closely resembles the fingerprint of 1242 and not 1254, so in degradation natters you will more liketly find 1016 behaving men like 42. ' Z'd like to discuss that with you at your convenience. MR. BREMER: Yes. New, those experiments that we're talking about here and sane of the in-house studies you're done have been daae in the laboratory and you indicate there is that degradation. Khy don't we see this sort of thing in a sewage treatment plant? MR. PAPAGBCKSE: Well, I don't knew why you don't. We do. The village-----the village treatment plant, at Sauget, Illinois shows a definite distinct drop from the input that we put into it that the total stream that the village system gets, measures, Z forget, something, like say 10 parte per billion, just to pick a nunber of EC3's. The outfall is a definite ` reduction. So sanething is happening and of course we look at the sludge. Tte sludge plus outfall still is less then input. In as big a system as that, it's difficult to make a good material balance, but there's seme indication that acmething does take place. MR. BREMER: Well, what do we do with these oontoninated sludges then? Co you have airy recounendaticns far that? Contaminated sludges and' sediments and the old sediments that we have there that are contaminated. Do we send those to a landfill car--- MR. PAPAORGE: That's--as I said earlier, lacking anything better, a landfill. I personally would like to see the day someday when this country has a network of indrerstors that we can all use. But Z'm afraid that's in the distant future. MR. BHH4ER: Z have one other question on shipment. When your Aroclors are shipped, for exanple, to GE or another appropriate ccupony, are they shipped by tanker route or are they in barrels or hew do they receive them? MR. PAPA5EERCE:. There's two modes of shipment--Z'm scary, three modes. Most of the volume moves by tank car on railroads'. The second highest volute move is in steel drums of a special heavy duty steel because this material is, of course, heavier than normal oils that we run across in trade. The third mode is by tank truck. That is a very stall portion of the total. MR. BREMER: Co ycu have any idea on these modes of transparaticn? For example, by tank car or tank truck, how these are flushed or is the same tanker maintained for Aroclor? Is it ever used anywhere else? MR. PAPAGECBGE: These vehicles, whether they be rail or motor, are dedicated to that service. Cleanout is very seldcm required. If there is an accidental contamination, we clean them in cur own plant through cur own control system and it becomes part of our plant effluent, so we're very, very careful. MR. BREMER: So that they cannot flush those at any other point in route then? MR. PAPAGBCBGE: Well, they should not and they're told not to and I have no evidence to indicate that they have tried to clean then en route. MR. BREMER; ------ steel drums far transport are returned to you or------ MR. PAPAGBCHE: The only time we 80S the return dsisw is whan return scrap material earns back to us. MR. BR3ERs You do receive scrap material then? 30 WTM00567 NCR-FOX-02S1424 WATER PCB-SD0000041062 MR. FAPAGECRGE: . Ves. MR. BREMER; Hot just liquid. MR. PAPAGEGRCE: Wedi, I scant scrap liquid. MR. BTEME3?: Liquid? * MR. RAEAGBORGB; Right. Ho solid. I can't handle solid. ' MR. BREMER; That's about all I have. Thanlc you. EXAMINES: Thank you, sir. . . Are there any other questions at this time? Please identify yourself, sir. . MR. FORSTER: A. X. Forster, Madison, X2aak Kaltcn League. What amount of time and energy is devoted to medical research on tte part of Monsanto so that the iconsuaer will get relief when he eats fish that has over 5 join's of PCS and he doesn't have to limit himself to once a week or once a month? How can you overca* that? And has anything been done along medical lines--after all, we. eensvxners, we want to knew whether we could live after consuming fish or any food products that have an excessive amount of PCB. How can we overcome that? MR. RAPAGEORGE: X appreciate your concern. I'm a eemsuner also, really. And this is not to say that your remarks axe not appropriate'. Eitm the moment we' were led to believe that PCB1 s om1d be a pcoblot, this was bed; in the late 'SC's, we, through our medical department, which is responsible in Monsanto for toxicology studies and the like, visited the appropriate then-existing government agencies and remember at that tine EPA was ret in existence ard I'm that they were frustrated because they could get no guidance as to the types of studies that would lead us to better understand what these materials were doing to the envirorment aid to people. lacking any guidance, we came bade then and decided we would conduct the studies that-we have been conducting for years whenever we desire to register a chemical for feed use. Hot that we intended to. petition the material for food use, but we felt that this was the proper way to go. Therefore, we asked the Industrial Biotest laboratories, located in the outskirts of Chicago, . to conduct two-year feeding studies with dogs and rats. They conducted, X think it was 120-day leghorn chicken studies. Ttey conducted three gerwratim rpmrhv*-im etirij Wi mutogenic studies and sate aquatic studies,' fish studies; ;' . So we have done what we feel is a responsible bit of work in trying to define tte chemical as it. is normally done using animals and birds and fish. You ask what are we doing about health studies, we, of course, have always paid particular attention to cur atplcyees through the years, through the 40 years we manufactured these materials and I'm told by our medical people that there's nothing that shows up that is unique to that group of people. In the meantime,' we are new in the midst of a study in which we are going back and looking at people who have worked in that department for long periods of time. in our mult, individuals' do. move in and out of that department. The same.pecple aren't: there'year after year after year. Sane people seek different types of wark and others feel that that's the work they-wish, so they ask to work in it. So-we do have a turnover. So far that study is not ccsplete, hut there's nothing that shows in this study that is different froa the base population of people in the greater. St. Louis area. I don't knew hew else to describe our activities other than we feel this is unique fear an industrial chemical. He have dene mare than erver's been dene-far industrial ii to date. ' '. ' ' ' . MR. FOSTER: Nell, you're to be. ocemended for that. Further, what is the statistical recced of any death due to--due to overuse of PCB? MR. PAPAGECRGE: I'm not aware of any death; in spite of t*at I-- MR. FORSTER: Huaan death. MR. PARAGBQRGE:. Hasan deaths.' I'm not aware of any human deaths, in spite of the popular press articles, that have been attributed by tie knowledgeable people and this---my source .is primarily Food and Drug Administration toxicologists, that it's teen attributed--directly attribuad to FCB's. '. ' MR. FORSTER: Thank you. 31 WTM00568 NCR-FOX-0281425 WATER PCB-SD0000041063 EXAMINER: Thank year, sir. . The gentleman in bade. Please identify yourself, sir. MR. OCEHSCN: Henry Johnscn, General Motors. .The Chan Co facility in New York is listed by the Federal EPAaa a hazardous waste facility. Aren't they also licensed by tte State of Hew York to handle PCS contaminated combustibles? . MR. PAPAGEQRGE: Did everybody hear that question? Yes, they are, to ny knowledge. They are handling many PCB's; yes. DR. MITIiTOG; My name is Anton Milling and I'm just a--although I have dene sane studies with, in particular, prime dichloryl biphenyl, but I'm not presently involved in any chlorinated biphenol research. Well, you mentioned that your ecupany has dene studies cr> chlorinated biphenyls and the study was given to a biotest in Chicago; is that correct? MR. PAPAGECRGE: The studies I mentioned with Industrial Biotest were the typical animal feeding studies; is that what you had in mind in reference to? DR. MTTXiTTC: Yes, definite eynpteos and so forth; is this what they were doing? MR. PAPAGBOHE: Yes, that is right. DR. MHUN3: Okay. How does that study compare with Dr. Allen's findings, who just gave a report, I think, before ycu? Was it as severe? Were the findings as severe? MR. PAPAGEQRGE: I am Kit a toxicologist. I can report to you ny understanding of the studies at Monsanto--had conducted far it and I'll have to leave it to you to ocmpare with what you heard Dr. Allen mention. . * Our studies with the rats and dogs can be samarized in this fashion. She high levels---and the studies were conducted at 1, 10 and 100 parts per million in the daily diet of the animals for two years. And as you know, the two-year period is near the life span of the rat. Of course, a dog lives longer. In the cases where the higher chlorinated material, the Aroclar 1234, 1260, at the high level, 100 parts per million, these symptoms were noted along with ease rarer ones, but the obvious ones are the animals exposed did not gain weight as rapidly as the controls. They wee analler in their growth increase. Also, the livers of these animals were enlarged and seemed to be trying to cepe with the exposure. Now, with the chickens, it appears the reverse is true; with tte lower chlorinated, the Aroclcr 1242, seem to affect the ability of their egrg to hatch. Via noted that at one part per million the eggs were hatching. At ten parts per million, no hatching. So we reran the studies at 2, 4 and 8 parts per million. We found an effect at 4, no effect at 2, so we concluded Bcmewhera between 2 and. 4 parts per million in the diet of the white leghorn chicken, its egg batchability will be affected. Reproduction studies, as I recall, at again the mammals, at' the higher levels^--the higher chlorinated mixture, as I rstenber, the second generation, second litter sensed to ba affected in the reproduction. DR. MTTJ.TMl: day. Has there been ary work done with Aroclcr 1618? MR. PAPAGEQRGE: The work with Aroclcr 1016 has--which came about later, was confined to the 90-day study, which was identical to the 1242. So we concluded that the two-year would probably look like the 1242. DR. MULING: So--well, it seems to me, that, that 1016 is not ary less toxic; is that right? MR. PAPAGBCRGB: He have never that is right. We've never claimed it's less toxic. Ha said it's more degradable. DR. MmiBS: Ckay. Thank yax. SCAMntER: Further questions? Please identify yourself, sir. A. B3PPH2KAM: Mark Bepple&m, Hoofer Ecology Center. You said that Moaaato signs a con-tactual agreement with eiataaars, uhkh lets ' 32 WTM00569 NCR-FOX-0281426 WATER PCB-SD0000041064 Monsanto off tte hxk, I guess, if any accidents happen car something like that, bit my question is then therefore you could identify exactly where all yon: PC3 cuujxuixls are going; right? Is that correct? HR, PAPA3E0KS; We can tell you fron our shipping record the delivery point. Beyond that we do tot know whether it gees into a transformer, a parti radar capacitor or where that piece of equipment finally is used. .. MR. OBPIIXAM: But you do identify a shipping point aid a customer, right? MR. PAPAGBORGE: Xas, yes. MR.. BCPPIfiraM: Ckay. Is that---could that be made, public record car is that strictly confidential? Z mean, could you tell the State of Wisconsin these are our customers in Wisconsin or would you be willing to? ' MR. PAPAGEeRGE: It's against our corporate policy, which is not unique to Monsanto, not to talk about our customers specifically. I can tell you, however, that through legal means, federal EPA did get a list of pur custaners. MR. BCPKEM: Ckay. One other question. With the transformers and the steel tanks, I was just wondering, do' PCB's have a really stable, long life. I mean, has anyone compared the life of PCB's with these steel tanks? MR. PAPAGBORGE; Yes, there is quite.a bit of information. Again, keep in mind I am not in the tranformer business personally Mid I am going to try to pass on to yew my under standing. There are, fee example, I'm told, transformers that were filled 40 years ago still in service doing a job. Apparently: they're hot stressed to the. point where the fluid is damaged in any way. and they keep doing their job in, day out and cause no problm. . On the other hand, we have varying degrees-of .success of how long that fluid lasts. Depending on the service the unit is placed under, maybe its design and maybe an oversize or under sized unit is placed in service so it's'stretched more so it requires a little more attention than . normal, 90 we get varying degrees of failure of the fluid. I hope that answers your question. It's a varied pattern. MR. KXPZEKAM: ' 1 thank you. EXAMINER: Are there any further questions? MR. VBUH: My name is Gilman Veith. I'm with the 0. S. EPA in Duluth. I share your concern over, the inferences that people studying, the emrirennent sometimes make or feel forced to make. But in that same light, .1 have a great deal of concern over the inference, that PCB's, because they cannot be accounted for on a mass balance basis, are degradable in the environment. And you mentioned,- for example, you do see a decrease in- the Sauget, Illinois sewage treatment plant when you try to dp a mass balance of the effluent and the influent and the-sludge and I'm wondering if you could provide for the hearing record data to, you know, that would have---I've dene a few studies cn sewage treatment plants. 1 find it very difficult to try to do a mass balance to really conclude /anything and Ifa wondering- we have seen, of course, the decrease in the efluent:and whether or not it's absorption or stripping through the secondary-----through the aeration, or through degradation, I haven't been able to conclude myself and I think it's important for a ramfcer of reasons. Che is -there seems to be seme' concern that it is not possible to adequately treat PCB wastes to get them down, so that if there is a process to: treat it, whether it just simply be biological absorption onto a flock, I' think this trxild be quite useful. And the seoond thing is that when we look for degradation of camounds, if you want to test whether or not DDT dees, in fact, degrade, you can find DDD; ycu can DOE; you can find DMJ in the environment. If we want to get sane indication that ehloridane degrades, we can identify cxychloridane as a residue in the fish. let then we cane to PCB's, we do net see these metabolites, end I'm wondering if these compounds have been identified as degradation products in the sewage treatment plant and I guess the second part of that really is-has Monsanto checked the losses in such plants due to just simply stripping. As you knew, PCB's has a substantial vapor pressure and there seats to be graving information that aerial transport of PCB's as a source of contamination is becoming---maybe a significant zeute and a secondary--I mean an aerated sludge, process could, indeed, simply be stripping the KB's from the waters. MR. PAPAGSORGE: Very good. For the benefit of these who don't know what we've dens in on; laboratory, we have tried to siawlata in toe laboratory, toe situation that might occur in a murucipal treatment system. We went to one of the local, municipal plants, obtained 33 - WTM00570 NCR-FOX-0281427 WATER PCB-SD0000041065 tte sludge aa a culture and set up in the laboratory units in which we introduced the sludge with the proper nutrients and the ratio of water to sludge and bubbled air and the ratio that might be found in the--in the plant, a sewage treatment plant. We then add the material we wish to test. How, thi3 test was not designed by Monsanto far KB's. It's a test that was developed back in the days, you may remember, when we had the hard detergent, soft detergent problem. SO we just mimic that situation. I recognize that this problan of evaporation of the material, the KB's, the transport by the air stream running through the bath, or the deposit bn the sludge itself could account for the disappearance. So we set up studies in which v pass this air through a series of absorbent bubble trains and all and check to see if the PCB's were out there, I forget how many, six or so bubblers in a train. We assured ourselves after repeated trials that it wasn't there. We then looked on the sludge, itself, and satisfied ourselves that we could make this material balance and still there's, a disappearance of that fingerprint. We have not and we were hoping others would start these kinds of studies, but we've been disappointed thus far. Vfe have not identified the products of this degradation, which is your frustration and mine also. Vie don't knew what it becomes because we've been asked this question, could the material that results have prohlans, maybe worse than the original? He can't answer that because we do not knew. He have made sane studies on the amount of COj evolved and it shows us that there is an cocodaticn going an. That paper, incidentally has been published in the "Journal of Bwironnental Contamination and Technology"-- something like--I think that's the title. He've also had cur Monsanto researchers in Europe publish a like kind of study and I'm sure you've seen Dr. Metcalf's work out of the University of Illinois. Those are the only three papers I'm aware of that address themselves to degradation of PCB's by mieaxfees. EXAMINER: Thank you very nuch. Any further questions? '* . Please identify yourself, sir. DR. VAN DUSER: My name is Arthur Van Duser. I'm a physician with the Department of Health and Social, Services. And I apologize to the ccmnittee and to Dr. Papageorge if this question may have been asked before, but it relates to the problem, I think. Are you familiar and could you update me personally at least as to what's being done oh the national level to prohibit or to change the importation of these materials? I think most of us feed, that Monsanto is trying to do a good jab, but we worry about what's caning in through imparted sources or from manufacturers elsewhere. EXAMINER: I believe that was touched an before. Hell, maybe you can give the answer again. EPA wall be here temorrew with that same information, too, but go ahead if you'd like to repeat it. -' MR, PAPAGEC9GE: It's ny understanding, sir, that cur regulatory, agencies do not have the statutes it needs to prevent the importation of this material. DR. VAN KISER: Ycu are saying the gates--peripheral gates are certainly open as of the present time as far as you know. MR. PAPAGE0K3E: Yes, sir. You may have heard of the--the group of nations that call themselves the-----that under the auspices or banner of CECD, the Organization for Cooperation Economic Developement. These nations have an agreement regarding PCB's and the agreaient reals as follows: "The producing nations, those producing PCB's, 'will sell them only to txanfarmers, capacitors, nonfood heat transfer applications and as a functional fluid--hydraulic fluid in mining equipment." That's modeling into tte Monsanto practice. Even in Europe we don't follow ttat practice. As an aside, and not definitely written in the agreement is that each of these nations presumably are to respect the mariser nations' attitudes, if you will, towards PCB's. So if the U. S., for example, does not go along with the heat transfer and hydraulic fluid application, they're not supposed to ship material into this country for that application. There is evidence that that's not being followed. 1. T3ISCN: Bd TUscn here. I thought I'd like to read this off because thin is from Manual of General Tcsdcity---if the specific name is needed I can get it at a future time. It lists under chlorinated diphenyl oxide, which have a high likelihood of being a decatposition product of PCB's, says under disaster hazard, "dangerous vhen heated to deocrapositionj it emits highly tcocic faues." And then rate chlorinated diphenyls, it says rate toxicology--this is an 34 VTM00571 NCR-FOX-0281428 WATER PCB-SD0000041066 extract, "coddes of chlorinated diptenyls are more tcmdc than the unoddized materials." wob just try way of anment on the material that's already been presented. EXAMINER: Okay. Sank you, six. Are there ary further questiens? MR. BREMER: Karl Eretrer, D.S. EPA in Chicago. Fcxgot this one before. X just vent your general opinion. Bow necessary do you think MB's axe in electrical systems, particularly in transformers and is it because Of electrical code that we're fighting with right now or what? - MR. PAPAGBQRGE: She electrical code refers to .fire resistance. So it's really fire resistance that is the benefit thatrve ell enjoy, whether we reccgnize it arret. Without this characteristic, many, many of the units new installed in places that have high people concentrations or high property values like in factories and what have you, X think you can . see. the benefit of having a fluid that would not bum should the unit foil dramatically, with hxiis of fixe being scattered in all directions. . . MR. BREMER: Well, the reason X asked the question was X have had conversations with a rainier of electrical manufacturers and they indicate that ,technology is developed to a state where breakers and so forth, can be used, for exanpla in a building in the event that you have this arcing and so forth that occurs in a transformer system that particular types of breakers and so forth can prevent the--you know, the actual, arcing and. burning or explosion of a transformer and X was wardering if we might, you know, be able to use sane of this technology rather than kind of sticking with what we have. And the other thing is the advent of the dry transformer, which we realize, ycu know, is a thing that more space. It's a different size and therefore, well, people are, you knew, they're a little reluctant to use something a little.different because of the way it has been done and you know that it's like this in--oh, you kriow, just in the building industry itself and in manufacture. But I just wonder if maybe we could wa could think of using cur technology, up-to- date technology and use this type of, let's say a breaker system with another type of oil that; you know, would efficiently do the job rather than using something that we knew---we've determined is pretty toxic and yet we keep saying, well, it is in a closed, system, you know, and here we have something that. Okay, it's, in a closed system. Hell, you have the other thing where just simple maliciousness on the part of same people where they'll----okiy, they'll put a bullet hole in a. transformer or something of this type.' You have Idle fluid go cut an the ground arad/or you have a leaking of it just by, you know, defectiveness of the oempehent or whatever it is. And it just seems like a vicious kind of circle, but I -was just, you know, ay consideration is----well, X think, you knar, myself,. that electrical code can be changed. You knew, .that it doesi't halve to employ' these in-house transformers in large buildings. They ccuitd be put cutside. Technology could : use-the parti cular breaker systems that we have developed and we could use other substitute fluids which are available at this time. . It's just ay--X just thought that maybe you felt the electrical code, you know, may be holding us back, too. X don't know. ' ' MR. PAPAGECRGE: I am not perscr.Uly qualified to speak for the electrical-- I know really very little about the electrical codes and electrical engineering and the alterna tives available in design. I understand there nay be sane people speaking on that matter later. YOU my wish to reserve your question far them. . . MR. BREMER: Yes, fine. . MR. PAPAGBDHGE: I just am not qualified to speak toward tint. . \. MR. BREMER: Thank you. EXAMINER: Any further questiens? (No response) EXAMINER: okay. In that case, thank you very such, Mr. Papegecrga. I appreciate' it. At this time we'U take about a IS-minute recess and stretch our legs. It's pretty warn in here. (Recess) EXAMINER: Cteay. tfe're back on the record, ladies and gentlemen. Please he seated. ' . 35 WTM00572 NCR-FOX-0281429 WATER PCB-SD0000041067 Ke are entering into the public content partim of the hearing today. I'd first like to call Hr. Jerry Dimer for carment. MR. DUMER: Thank you, Mr. Christenson. I'm here on behalf of Lt. Governor Martin Schreiber who unfortunately couldn't be here, but he has a statement that he would like me to tread. I would like to direct my testimony to two points. The first is to ccemend the Board of natural Resources and the Department of Natural Resources for holding these hearings. For over a year, I have believed consideration of effluent standards for PCB's is a valid first step toward .eradicating the documented dangers of PCB contamination. And I find it most encouraging that Wisconsin is ones again taking the lead in protecting cur environment. The second point is that effluent standards are only the. beginning, because effluents are only one of nary ways PCB's are released into the environment. As a result, action to curtail PCB contamination will only be effective when PCS tise has been restricted to the greatest extent possible. Hopefully, these hearings will provide enough information for the appropriate standing conmittees in the Legislature to take this action. Currently only PCB's used in the.electrical industry in transformers and capacitors are considered irreplaceable. X believe it is necessary that all other uses he carefully examined and in all cases where less toxic substitutes exist, PCB use should he banned. In addition, the essential uses of PCB's in transformers and capacitors should be critically reviewed in order to determine the feasibility of developing replacement products. Further action by the Department of Natural Resources and the Legislature should be aimed at encouraging other states and the U. 5. Environmental Protection Agency to follow Wisconsin's-lead in considering effluent standards for PCB's and eventually terming all . replaceable uses of the chemical. Hopefully, also, these hearings will call attention to the myriad of PCS-oontaining products new being used far a variety of purposes. Althcugh Monsanto Chemical Corporation is tie only domestic producer. Great Britain, Trance-, Germany, The U.S.S.R, Japan, Spain, Italy and Czechoslovakia all manufacture PCB's. Insufficient.monitoring of imports makes it impossible to knew hew maty materials containing PCB's enter the United States, or how much is actually manufactured worldwide. I should note that the Envizoment&l Protection Agency has instituted a voluntary reporting program far imports containing PCB's. Unfortunately, the H>A has no statutory authority to mandate this information. However, toxic substances control legislation presently before Congress would provide the authority to gather necessary data. Why wsuld Z mention the toxic substances control legislation at this hearing? Because this hearing,, whether it considers effluent standards or an outright ban of ncnessential PCB uses, is still reacting to the problem of chgiucal pollution with hindsight, not foresight. The real solution lies in ensuring the harmful chemicals never reach the marketplace. Scientific evidence of the adverse effects of toxic materials mounts daily. Several hundred new chemicals appear in the marketplace every year. Hone of than are tested for possible harmful effects on health or emrirarment. Only after the adverse effects are fiualy decimated is action considered. This is the case with PCB's and it was the case with DDT and Dieldrin. Besides providing the EPA with the authority to demand data en toxic substances, a toxic substances control act would provide the mechanism for testing potentially harmful chemicals before they beocme an environmental or a health hazard. Testing of materials such as PCB's before they beccne a problem, before they are allowed to be placed cm the market, is the only prudent approach for the future. This hearing will collect information for effluent standards far PCB's. X would ask that each participant, and all those who will-use' the testimony delivered here, be mindful of the fact that these standards are only one step. The success of the fight against the hazards of PCB contaminaticn win be measured to the degree to which widespread intergovernmental action is achieved and the degree to which we realize that action based on hindsight will always be less than enough. Thank you. SMOBt; Thank you very much. Hr. Disasar. Is Mr; James Allen present? Mr. Allen? 36 TWTM00573 NCR-FOX-0281480 WATER PCB-SD0000041068 MR. MRDIOH: Fes. EXAMINER: Please identify yourself and who you represent. MR. MADISCN: For the record, my name is Allen Madison. . . SfflMINER; Excuse me. ' MR. FBDISCH: Base secretary, Congressman les Aspin. Mr. Secretary, markers of the board, the hearing examiner, Mr. Christensen, first of all, 1 would like to thank you for the. opportunity to submit testimony, for, these very important hearings. In view of the essential nature of this hearing and the lumbar of people wishing to testify, I shall try to be precise and brief. .- . He are here to discuss the subject of TCB's, polychlorinated biphenyls. To residents of Wisconsin and others of the Great Lakes states, this is not a new problem and it is one which we are all striving to solve. . The Secretary and the Board of the Dqartnamt of natural. Resources have presented . us with two choices in this natter: (A), a bah of the discharge of polychlorinated biphenyls, either in pure form or in substance, mixture, products or cccpounds into, state waters or (B), a limit of ho more than .005 milligrams per. liter of PCS as treasured in a 24-hour, composite sample, shall be discharged into state waters. X urge you to sqrporta complete ban of the discharge of polychlorinated biphenyls into Wisconsin's waters. After long deliberation, I feel that this is the most expedient way to attack this problem.. . Research into the harmful. effects of FCB ccnmrrpticn or assimilation has been intensified in resent years due to the increasing awareness of the potential dangers of this toxic group of substances. We in Wisconsin are fortunate to have the advice and assistance of Dr. Janes Allen, pathologist at the university of Wisconsin, whose research on the effect of KB's on rhesus monkeys has offered us an invaluable insight into the possible harmful 'effects these substances would have ' on huaarts. ' . , What recent research has offered to us is a further strengthening of the opinion of many federal, Wisconsin and other Great lakes states':agencies, that RGB's pose a potential long term hazard to humans. Cn the federal level, the U.S. Food and Drug Administration has instructed " that the maxims: allowable concentration be limited to five parts per million. Recent research done by Dr. Allen on animals has shown that a dosage of five parts per'million of the ECB's has produced toxic manifestations in a month's time. Lower dosages of FCB's have also been found to produce toxic manifestations. . . This, then, leads, us to ask what level of FCB concentration in the envirennerit can be viewed as safe for human consumption. The answer to this question is that we just do not know. We do have evidence as to what effects certain levels of contamination have cn animals, fish, birds, mirks, monkeys, etc., and we have documented evidence of what a large dosage of RCB's can do to humans. This example involved 1,000 Japanese, who in 1969 acirientally ate ' PCS contaminated rice. . . Because KB's are retained in body fat, the symptoms of the contamination lingered In many fee years. longterm effects of this are still undetermined. Sixteen huran deaths were attributed to this PCB poisoning. The babies of two pregnant wemeh were still born and the babies of nine wmea showed syupluus of chlariabiphenyl poisoning. FCB contamination has hit very hard in Wisconsin industry and has the potential to hit harder. Contamination of fish in Lake Michigan, Lake Fepin, in the Green Bay Hatchery and along the Mississippi has laid a further, blow to cotmercial fishing in Wisconsin. In addition to fishing, sport. anglers in certain areas'have been advised to limit their intake of : certain fish to one meal per wede. I aa sure that we are all aware of the federal and state . investment of many millions of dollars to restore the Great Lakes fisheries and its habitat. This dual effort was to detenoins methods to control lanpreys. This, involvement was largely suoceesful, but is being' undermined by the even greater pcoblem of FCB oontmrinaticn. The State of Wisconsin has the largest mink industry in the nation. The effect of KB's on mink living near Lake Michigan, has been documented. The National Waters Quality Laboratory has tested minks which had eaten fish with .6 parts per million Of PCB's. These mirks failed to reproduce and suffered a mortality rate of 71 percent. The- possible long term and even sheet-term effects this could have on Wisconsin mink industry: could be devastating. Wisconsin is also affected by FCB contamination of milk. There have been instances of milk oentoainafeioa from silage which was stored in concrete stave Silos. Tbs FCB source was 37 VTM00574 I NCR-FOX-0281431 WATER PCB-SD0000041069 traced to a sealant used cn the inside walls of these silos. PCB's were found to be efficiently transferred frtxx the silage to the cows' milk. Hie U.S. Department of Agriculture surveyed a nuaber of fanes around the country that were using contaminated silos. Levels of PCS residues in milk fat were approximately 10 parts per million. Hiere have teen instances in other individual farms of residue levels as high as 28 parts per million. It is interesting to note here that FDA guidelines for maximum PCB residue is equivalent to 2.5 parts per million in milk fat. Hie U.S. Department of Agriculture views this as a potential danger in farm families who drink milk fran their cwn cows fed on contaminated silage. Potentially, intakes ofPCB's for over 15 to 20 years could approximate the level of short-term intakes that caused the serious effects in Japan which X have mentioned. Hie Wisconsin Department of Agriculture, the Department of Matured Resources, and the Wisconsin Division of Health, have fully cooperated with the U.S. Food and Drug Administration, the U.S, Environmental Protection Agency and other Great Lakes states in intensifying research into the sources and harmful effects of PCB and in setting tolerance levels. Hieir combined efforts have been vitally instrumental to determining the possible obliteration of this envirormental and human toxic substance. . In 1972, the Monsanto Company sole producer of PCB's in the United States, voluntarily agreed to limit, the sale of PCB's to those industries with closed systems. Hiis agreement also limited the use of PCB's in the manufacture of electrical transfanners, insulators, capacitatars &nd Tat* itscus* It was hoped that this action and action taken by the Food and Drug Administration vould limit the level of PCB in the environaent. According to the U.S. Environmental Protection Agency estimates, PCB levels have risen in many areas and remain the same in others. Hiis is not encouraging, to say the least, and is, in ay. opinion, a dangerous indication. What I feel theTM what Z feel the implications of this are is that our past monitoring, testing and control of the use of PCB's has not been strong or effective enough. ' We are all aware of what the known PCB sources are and it has been my repression that many people would prefer the discovery of present unknown PCB sources before placing a ban cn the use of PCB's. I believe, Mr. Secretary, that this is not the best way to attack this pccblan* . A ban of this industrial oerpamd would necessitate an intense search into areas where levels of PCB's are either expected or thought to be located. It would greatly increase our knowledge of what PCB .sources actually are. It would greatly enhance our efforts towards a total obliteration of this hazardous chemical. . Such a course of action has been urged by the Minnesota Pollution Control Agency and its regional task force, the Upper Great Lakes Cccmittee of the Great TaVg Fishery Ccrraission, and by Nathaniel Reed, assistant secretary of tbs U.S. Department of the Interior. Mr. Secretary, I submit to the board today a three part, proposal which I feel oust be adopted to eliminate the PCB problem. - First, I ask the Department of Natural Resources to tan the discharge of PCB's into Wisconsin waters. .' Second, I plan to initiate action on the federal level for an imrediate ban cm the new production and importation of PCB's and products with a PCB content. In reference to existing supplies of PCB's, I feel that a five-year phase-out of these sigplies be enacted. Ihird, I feel that it is necessary that an intense study of long-term health implications of the consoiption of PCB's be made. Hiis study should include a complete analysis of the nature of the more than 250 different chemical canpounds of polychlorinated biphenyls. The elimination of all source points of PCB contamination, both in Wisconsin and in other parts of the nation is contingent cn the adoption of this proposal. I also think that this board would be interested in knowing of actions taken by other nations of the world regarding the PCB problem. Sweden requires a permit for the manufacture and use of these industrial chemicals. Hie. Canadian government is about to pass a toxic substances act, much stronger than the tadc Substances Control Act being considered by the U.S. Congress. Japan, qn industrial nation similar to the United States, has recently banned the production of PCB and has initiated a phase-out of existing supplies of KB's, similar to what I have proposed. . Hie action I call for----a ban on the.use, nanufmeture and isportatiem of poly chlorinated biphenyls--is not an unprecedented act. It will be, I firmly believe, to the benefit of the citizens of Wisconsin, and of tha United states. 38 WTM00575 NCR-FOX-0281432 WATER PCB-SD0000041070 . ny vtivs. Thank you, Us. Secretary and the board fear allowing me this opportunity to express . . EXAMINER: Do you have a copy of that statement, six? . Blank you. . Mr. Donald Bach. Axe you ready for your presentation, sir? MR. EACH: Z eon attorney Donald L. Bach of the law firm DeKitt, McAndrews and . Porter of Madiscn, Wisconsin.. Z appear today bn behalf cf the Wisconsin Paper Council, trade association fear the pulp and paper industry within Wisconsin. There are 49 pulp and pager nulls within Wisconsin operated by 34 major companies, with a. total of 14B other associated plants, including converters and distributers, which are additionally located in Wisconsin. The pulp and paper industry eiploys 46,000 pesple, who produce an excess of five million tons of pulp and paper products annually. The total payroll for these pet-sens is approximately $410 million on which personal income taxes of $6.5 millien are paid. Bie Wisconsin paper industry itself pays annual taxes to local,. state and federal govemnents of approximately $53 million. Wisconsin manufactures more than 11 percent of the total production of pulp and paper products in the United States and is the umber one paper-producing state in the country. Although , the paper industry is obviously OKtrsnely critical one to the state, it is not nonnal for the ley person or even many technical experts to know a great deal about its manufacturing processes,. A raitfcer of elements are essential -.c the paper industry, among them being high concentration of capital investment, skilled,labor sufficient amounts of self generated or purchased energy, water and, needless to say, cellulose in the form of either wood pulp or waste paper. Most paper is made from the fiber of trees harvested fran scientifically managed forests of which, within Wisconsin, mote than 1.4 million acres are owned by the paper * industry and managed under professional management plans. . TO date, more than 130 million trees have been reforested in the State of Wisconsin by the paper industry and on a current basis, an average of approximately two and a half million trees ate being-additionally planted every year. . . Wisconsin, however, is not only the leading state, in paper making, but also the ranter one state in paper recycling. At least 19 Wisconsin paper firms recycle fibers to seme extent and several:firms make a specialty of it, producing papers widely known for their adapta bility and strength. A fifth of Wisconsin's annual paper production, about 780,000 tons, is made from recycled, post-consumer wastes. Recycled paper distributed ftem Wisconsin throughout the nation includes such things as paperboard, corrugated boxes, cones, folding cartons, industrial wrappers, solid, fiber braes, napkins, tray covers, roll stock, toweling, tissues, test liner, container chip board and a wide range .'of fine writing, printing, business and office papers. . Sane Wisconsin paper makers have been producing recycled paper and paperboard since the turn of the century. As a result of such recycling, weed fiber, resources and the use of residue from the manufacture of other wood products such as lusher and plywood.are being extended each year. It is estimated that wood chips, Slabs, edging, sawdust and the like provide 25 percent of all the mod used to make pulp. . we face a paper and fiber, crisis in this country, although assuring that adequate forests are made available.for the harvesting of timber, there is no imtBdiate danger that the . nation will run short of trees. This begs the point,. however, that the nation is fast running out of solid waste disposal sites and continually avercGnssning its natural resources, although, fortunately our forests are unique in that they are renewable resources. . It thculd be noted that paper products axe at least 40 percent of the nation's solid waste, with garbage cmpoelng only 24 percent, metal' 10 percent, glass 12 percent and miscellaneous items 14 percent. Since paper is approaching half of the waste bulk, recycling obviously is a technique with great environmental as well as econcmic potential. New York City alcm spends $6 million annually to dispose outdated issues of the tiaf York Times. The unfortunate thing is that currently only ;22 percent of the nation's paper is being recycled as ocopared to 4& percent (hiring World War II in the United States and as ccnpared to 40 percent today in Japan and West Germany, the two highest recycling nations in the world. . . . Maw, should recycling be encouraged? The answer is obvious, it oust be encouraged. Beading firm Governor lucey's charge to the recycling task force appointed by him in July, 1971, Z quote as follows: The ever-increasing demands upon the supply of cur natural resources dansnstxates the necessity fob reuse of our waste materials. Wa cannot continue to s&tply dispose of society's wastes without jeopardizing our entire future. The present methods of solid waste disposal, such as landfill aM incineration, joes a threat not only to our supply of natural resources, but also to our air, land and water. The shortage of land around our urban centers . and the increasing levels of air pollutants leaves society no choice but to recycle our solid . 39 WTH00576 NCR-FOX-0281433 WATER PCB-SD0000041071 tastes. If the present rate of increase and use of natural resources continues without regard for recycling, we may face a shortage of natural resources." The report of the Governor's Recycling Task Force on solid taste issues and jRfavi in 1972 in February, contained cn page 26, the following statement: "It is appropriate to the task force charge to strengthen the traditional role of the Wisconsin industry in pulp and paper manufacture. Therefore, it is suggested that a singular opportunity exists here and! row for expanding the base of paper manufacture by using essentially recycled fibers." She same report on page 15, notes that in fourteen counties, that we are prodioing 200 tons-----202 tons of waste newsprint per day, 101 tens of waste magazines daily, 101 tons of waste corrugated paper daily, over a thousand tons of mixed paper and other types of corrugated paper daily and 368 tens of wood daily. These are significant amounts. They are shameful amounts. There are volumes and amounts that America and Wisconsin recycling industries are dealing, with, and in case of same of Wisconsin's paper companies, they have been dealing with sinse the very beginning of the 20th century. What has Wisconsin as a state, in addition to its paper industry, done about it? Governor Xncey in June of 1974 signed Chapter 305, laws of 1973, creating the Wisconsin Solid Waste Recycling Authority. This was a law strongly supported by the Wisconsin Paper Council, even though it did not directly affect the econanic interests of its Berbers. In that law, the _. legislature clearly declared that the people of Wisconsin have a right to clean and vtoleseme envircraent and that prevailing solid waste disposal practices, i.e., landfilling, burning and the like throughout the state result in an unnecessary environmental damage, waste valuable land and other resources and constitute a continuing hazard to the health and welfare of Wisconsin citizens. . . Manufacturing any product is not a clean, tidy process. Generally it is noisy; usually it is dirty and normally Mark with large machinery is involved. It normally takes skilled labor of which Wisconsin is fortunate to have an anple and sufficient svgply. The point being, however, that in the manufacturing process, certain natural rsources are consumed and related byproducts are discharged or Blitted as part of the process themselves. . * Recognizing this inpact an the enviroixnent cn which it depends, the Wisconsin paper industry had expended prior to 1975 approximately $126 million cn water pollution .abatement equipment. It is the estimate of the industry that within the next five years an $153 million, at a minimum, will be expended far a total investment of approximately $280 million for water pollution abatement equipment alone, not one cent of which is attributable to production equipment. In 1953 an average of -218 pounds of BCD per ten escaped to Wisconsin rivers from the paper mills. In 1972, this figure had been reduced to 65 pounds per ton, with the ultimate figure expected to be reduced even further. This is doubly ranarkable when one considers that pulping can produce up to 700 pounds of BCD per ton of pulp produced and that the paper industry in 1953 was producing only 2.8 million tons of paper and paper products per year, wheceas in 1972 its production had increased' to almost 4 million tons annually. The renoval of suspenled solids from effluent also showed a marked decline between 1953 and 1972--fraa 92 pounds per ton to 39 pounds per ton, with, the ultimate amount to decline even further in the future. . as to air pollution, prior to 1975 the Wisconsin paper industry had invested approximately $34 million in air pollution abatement equipment and anticipates that between 1975 and 1980 it will invest at a minimua, an additional sum in excess of $60 million. In rcugh figures, therefore, the paper industry in Wisconsin alone will have spent by 1980 approximately $375 million for air ami water pollution abatement equipment, approximately $8,200 per otployee on What is very enviramentally necessary, but is unproductive by itself. Mow, on the issue of polychlorinated biphenyls, by this time in the testimony, I think I need spend a little time in identifying PCS's or their historical uses. I do wish to point cut, however, that for an extended period of'time, these substances have been used, particularly within the electrical industry. For exanple, for purposes that have been dwmed and are still deemed to be socially acceptable and beneficial in terms of their ability to reduce explosion and fire and to protect hanan life and' human welfare. One of the many varied uses of RGB's prior to 1971 had been in the cartonless copy paper, which has accumulated in the files of many businesses and romerous governmental agencies and have .stayed there for seme time, but from time to time, also gets sorted out and become part of the solid waste chain. It has been only relatively recently that attention has been drawn to KB's because of their widespread distribution in the envirorment. As a matter of fact, many eonmentators have referred to the fact that PCB'b have become ubiquitous and that even a total cessation of manufacturing and the use of KB's would not result in tha rapid disappearance of the material, i.e., ultimate disappearance frm the mvixcment will take many years 40 NCR-FOX-0281434 WATER PCB-SD0000041072 regardless of any total ban, even if a total ban were desirable, which it ia most emphatically rot desirable. At this point Z wish to sake very clear what should be obvious at this time. Waste xarm* collectors and recyclers do not manufacture PCB's, nor do they use then in their nanufacturing process. However, to the extent that certain transformers and capacitors cn their premises nay or may not have PCS fluids in than, such materials might be cn their premises. Further, to the extent that recycled waste paper does contain traces of PCB's, this contaminate is introduced into the industrial systsa and becomes part of the industrial waste discharge of the paper waste recycling facilities. ' At this point, several very' critical issues mist be noted by the Wisconsin Department of Natural Resources, namely: Cne, quoting from the Kay, 1972 report of the Inter departmental Task Force an PCB's entitled PCB's end the Enviraasent, Z quote, "...tare scientific information about PCB's is needed. Only general statements can be made about how PCB's reach the environment, how they reach target organisms and how much is. present." - Ke could not more fully concur with this analysis of . the scientific level of knowledge or lade thereof about PCB's, nor more fully offer our assistance as an industry to cooperate with the government to achieve an effective system for assessing and controlling PCB's. ' .' Two, you rust understand that a very email, portion of the total arcunt of PCB's ' manufactured domestically by Monsanto were used for carbonless papier, which is the chief assured source by which wastepaper contains the PCS contaminant, tooclor 1242 by weight containing relatively lower amounts of chlorine than other domestically produced and sold PCB's, was used in the production of carbonless paper. Between 1958 and 1971/ at which time the use of PCB's in the manufacture of carbonless paper was ceased. .Approximately 47/8 percent of Monsanto's PCB production was of aroclor 1242. However, of its entire dcmestically sold production during those years, a little over 21 percent was used for plasticizer applications. Plasticizer applications . include.not only use for, carbonless paper, bub also for adhesive, . textile and other surface coatings, inks, investment casting wax and sealants. Therefore,, we know that something considerably less than 10 percent of Monsanto's total PCB production between 1958 and 1971 was used in the manufacture of- carbonless paper, all of it being Arcelor 1242. - Three, to be emphasized repeatedly, since 1971 no'PCB's of any kind have been used to manufacture carbonless paper. Four, Arcelor 1242 used in: the manufacture of carbonless paper has significantly different structural constituent characteristics, whereby its stability and persistence axe less and its degradeahility appears to be significantly higher than its cccpazatively more highly chlorinated Aroclor relatives. ' . Five, based cn studies reviewed by us, it is hot Aroclor 1242, the carbonless paper Aroclor which has carmcrly been found in large concentrations in Ccramrcial fish. All of. the above can be restated concisely as follows: Only a snail portion of total PCB domestically produced were utilized far purposes of manufacturing carbonless paper and as to those particular Aroclocs, they see relatively less' stable and persistent, appear to be more degradeable and are less susceptible to accmulaticn in fish than are their related, mere highly chlorinated Aroclors. As a result, the impact of the waste pager recycling industry cm the issue of PCB's, when taken in this light, is substantially pud: into a mere proper and positive perspective. As to the proposed IKR regulations, many studies have been pub! ishfd and many articles written relating to the existerae of PGB'b in the aryiroranent. The presence.of PCB's in tte envixoment, however, should not be assumed-to imply a negative effect. In fact, including -----again quoting frcraPCB'a and the Environment, on page 17 it states. "At the levels in which they axe found, PCB's do not appear to present an iasdnent hazard." Again, based on studies reviewed by us, we have seen ho conclusive published report relating to the death of any wildlife species because of the presence of PCB's; The only reported mortalities have.been those achieved in laboratory experiments. Most of those laboratory studies related to the higher chlorinated, more persistent PCB's,. while most, if net all of the effluents proposed to be regulated, contained primarily the lower chlorinated; less persistent type. Mo one can deny that the proposed DNR regulations are aimed most directly at the waste paper recycling industry in Wisconsin. ' Based on appearance/ very little theught went into the drafting of these regulations and,, in fact, they would appear not to represent the approach recoBEgaded by the EKR staff which is, presumably, more qualified than; many- lay persons, whether on the Board of the Department of Natural. Resources or not, to make judgements of a technical nature. The adoption of either proposed regulation would be an economic catastrophe for toe paper industry in Wisconsin.. ' 41 WTM00578 NCR-FOX-0281435 WATER PCB-SD0000041073 Being concerned about the environment and attsnpting to do sanething about it are responsible goals and actions. As I have pointed out, the paper industry has been the leader in both areas in the past and will continue to do so in the future. However, I rust axnent that the suggestion of these so-called alternative regulations, with the full fcroe and effect of the' prestige of the Environmental Quality Caimittee of the Department of natural Resources Board can be classified as approaching the irresponsible. Quote, "current scientific knowledge gained from laboratory animal experiments if often inadequate to allow reliable interpretation of the data in tents of possible effects on man. -Che scientific basis for interpreting such tests must be improved. He situation regarding PCB's is not significantly different from the problems of other toxic substances which can=e concern when they cane in contact with man, his food and his environment. Certainly continued vigilance on the part of the governmental agencies, industry, universities and many other agencies, both within and outside the government will be necessary to achieve an effective system for assessing and controlling the hazards of toxic substances, including PCB's." Hat's also from the report entitled PCB's and the Environment. At this point we think there are several issues, that the DMA should answer in the very near future. Wat is the toxic level of concentration and tie degree of exposure necessary to achieve either mortality or an imminent hazard to health, to htscans or wildlife? what is the background level of PCB's in Wisconsin waters? What Azoclors constitute these background levels? In the fish being tested in lake Michigan, lake Superior and Lake Pepin and in various Wisconsin rivers, what Aroclors are being detected? What is the background level of Arcelor 1242 in the waters most suspected of contamination by the Department? * Is it not true that Arodor. 1242 is more degradeagls and less persistent in the ' environaent than its more highly chlorinated relatives? Of PCB's? Under what provisions of the Wisconsin Statutes do you propose to ban the discharge Do you propose, whether or not you are required to do so pursuant to Wisconsin Statutes 1.11, to issue an environmental and economic impact statement prior to your prcrmilgation. of any FCB ban? An ancillary problem that I'm sure the DNR staff has contenplated is the alternative methods of dealing with PCB's. Ctbviously burning contaminated waste paper is net the solution because unless such burning is done at extremely high, temperatures and is in excess of 2,000 degrees Fahrenheit and in extremely efficient incinerators, the PCB's will simply be emitted to the atmosphere, to once again fall on land or into the water. Likewise, is not the solution because of the quantities of wastepaper involved, thereby necessitating more landfills. Again using the material from the Interdepartmental Task Force Report on PCB's issued in Kay of 1972, it has been estimated that the total injection of PCB's into the American environment.between the years 1932 and 1972 was approximately 30,000 tons in the atmosphere, 60,000 tons in the water and 300,000 tons to the landfill. Out of this total, rsnainirsg residues in 1972 were calculated to he approximately 20,000 tons in the air, which would be ultimately redistributed on either land or in water, 30,000 tons in water and approximately 200,000 tons in dunps. The conclusion 1b obvious, that PCB's in water are degrading more quickly than those emitted into the air cr placed in the land. . I think it is time for us to recognize that we all know less than we would like to know about PCB's. Bnranwe of their persistence and because of uncertainties about their impact, the new production of this substance has all but been eliminated and is rxw used for only very specific and limited purposes. An inventory must be made of where PCB's axe caning from, the type of Aroclars that are being discharged, emitted and landfilled, the best methods of decreasing these discharges, missions and landfillings and to put seme proper perspective on the existence of this substance in our environment. In the last legislative session alone, Senate Bill 339 and Assembly Bill 463 were introduced and would have required the state to purchase paper with a certain specified amount of recycled fiber in it. In addition, if you will view the current letterhead stationery of the Wisconsin Department of natural Resources, you will note that it says on the bottom "This is 100 percent recycled paper". If you will look further at the notice for board meetings of the Wisconsin Department of Natural Resources, yew wdU likewise note the statement that "This is 100 percent recycled paper", ladies and gentlemen, you are promoting the use of recycling. And we thank you fear that. leu are also pso- mating the disposal of KB's. let us take a reasonable approach to this problem together. We appeal to you fear reason Let us admit together that we do rot taw enough 42 WTM00579 NCR-FOX-0281436 WATER PCB-SD0000041074 at least at this point to take a stand such as proposing these ill thought out proposals. The result be an economic catastrophe for a significant, portion of Wisconsin's paper industry. The cctrmittrent of this .industry is to Wisconsin .and its awiroriaantaliy pure future. It has invested and will invest over $300 ail lien dollars prior to 1SS0 to acqcnplish this goal. It further has a goal canton with Governor lucey to decrease landfill sites, and to recycle to the maxima solid wastes so as to preserve our natural resources and to beautify cur state. It is . indeed unfortunate that mere reasonable and more well thought out proposals for regulations have not beat brought forth so that sane hind of. an attespt could have been made even at this point of tte hearings to work out seme kind of meaningful regulations. We only hope, after the review of the entire hearing record, with written material to be submitted subsequent to the oral testiasny that realistic, reasonable, feasible and responsible regulations will be preposed by the Department of Natural Resources, which will holster its reputation as a defender of the envirorment, while at the same time, hot place it in a position of ridicule, because it has suggested regulations so badly researched that they have became negotiable prior to the time they are published far hearing. Thank you. EXAMINER: Thank you, sir. Co you have a copy of that? KR. BACH: Yes, I do. . EXAMINER: Bunk you. Mr. Geccge Reinbacher? . MR. KE2NBACHER: My name is George Reinbacher. I'm director of manufacturing for tte Absorbent Products Division of Brcwn Caipany and the manager of its operations at the mill in Eau-Claire, Wisconsin. * She mill at Eau Claire employs approximately 700 people , and has. an annual payroll in excess of $7 mil 1.1m. We pay over $100,000 annually in property taxes and are one of the major industrial employers in the Eau Claire area. During the past two years, we. have spent almost two million dollars.to reduce stream pollution and estimate that.a similar amount will be spent ' during the next two years to cccpleta the' secondary wastewater treatment plant. Our primary raw material, the secondary fiber or waste paper, which is shipped to us froa all over the country. Annually over 70,000 tons of this natesial is repulped, cleaned and manufactured into usable sanitary'products. Use Of waste paper permits us to compete . economically and also provides us with usable furnished when so-called virginpulp is not available. The problem of identifying and sorting waste paper is unique i. that generally speaking, 1,700 to 2,000 pounds of various types of paper that we use are generally.shredded and baled together in 72-inch bales. The material canes firatt printers, office buildings, department stores and recently, from municipal and private recycling centers. There is no practical way . of sorting and identifying random KB contaminated, paper. Ercwn Catpany does not deliberately buy cr use PGB in its productive, processes. Nevertheless, the. carpary- is concerned that the. proposed regulations will introduce an extremely serious problem in any paper mill using recycled pspear, ' ' - . Our industry is caught in a situation which is not of our making and over which we have little practical, control. The'whole concept 'of recycling waste paper .is at stake. Wa firmly believe that where recycled paper is involved, the regulations must recognize the taiparary nature, of the problem, the 1cm concentration of contaminants that is involved and the ^practicality of identification and segregation of raw materials. Otherwise the whole concept of paper reuse must be reconsidered and greatly curtailed, which could result in ecdhanic disaster to the Eau Claire mill, as well as others using waste paper furnaces. .. . Thank you. . . EXAMINER! Thank you very much, sis. Thank you. - Is Mr. Patrick Mantis present? .' . . Mr. Richard Rand? MR. WAND: ly name is Richard Wand and X am the adaiitistxative vice-president of Bargsbxm Paper Canpany. X am resper-sible for supervising and coordinate all staff activities of the company and 1 direct corporate efforts in the area of environmental management. ' ' 43 . . WTM00580 NCR-FOX-0281437 WATER_PCB-SD0000041075 2he Bergstrom Paper Ccnpany is a manufacturer of fine printing and writing papers and since our founding in 1904, we have been recycling waste paper to make our preducts. Ke cm no Hratwinrdu and rely cn waste paper fee approximately 65 percent of cur total fiber raw material requirements. Mary of our products are produced firm 100 percent recycled waste paper and we are the nation's leading rr^vw of printing and writing papers frem secondary fiber. He have manufacturing facilities in Neenah; where we enploy about 570 persona and until April of thin year we also operated our mill in West Carrollton, Ohio, where we employed approximately 575 people. Economic conditions, resulting in declining paper markets, forced us to close our chio operation this spring. All but ten of our Ohio personnel have been terminated or placed cn - layoff and three paper machines with a daily capacity in excess of 400 tons of paper have been idled for an indefinite period of time, pending improved market conditions. In 1974 and prior to closing our Ohio plant, Bergstzaa produced 225,000 tons of finished paper and recycled 141,000 tons of waste paper. This averages 18 truckloads and 8 rail cars of waste paper each day for 350 days a year. In Neenah we have an annual payroll of approximately $7.5 miUicn and we annually expend another almost $2 million for fringe benefits. In 1974 we paid Neenah real estate and personal property taxes in excess of $220,000. . . Since 1952, when we installed one of the first wastewater treatment systems in tte paper industry, our cenpany has spent in excess of $4.5 million on pollution abatement facilities. Plans for an additional $3.2 million secondary wastewater treatment system for our Keenah mill are currently being reviewed by the Department of Natural Resources. I give this background information by way of demonstrating our ccnpary's eccncxtdc Importance to the State of Wisconsin, to suggest our 70-year oenmitoent to toe cause of recycling, and to reiterate our concerns for protecting the environment. In spite of the fact that recycling has been practiced since before toe turn of toe century, an alarming fact remains that toe rate of recycling is actually declining in this nation. According to recent EPA figures, this country is recycling only about four percent of its textiles, 13 percent of its zinc, 13 percent of its aluminum and only 19 percent of its waste paper. Biis waste paper rate compares to a World War XX rate of 27 to 30 percent. ' Recently enviromentalists have been among toe strongest supporters of toe ooncept of resource recovery, that is, recycling because it makes good cu.inen sense to tap our massive solid waste stream to recover materials which can be utilized at their highest ecancmic value. Recycling saves tnsiendous amounts of energy. It greatly reduces toe need to bum or boxy solid waste, which now costs cur municipalities a national average of $26 far each ton. It promotes the conservation of our precious raw materials and it makes us less dependent, therefore, on foreign cartels and it results in substantially reduced air, water or solid waste pollution. And yet we now face a proposed rule to totally ben the discharge of polychlorinated biphenyls, PCB's, into the environment. That, very simply, will put virtually all paper recyclers out of toe recycling business and both the proposed zero discharge rule or the proposed rule to limit PCS discharges to .005 of a milligram per liter or five parts per billion, which, as a practical matter, constitutes a total ban, could well put toe Bergstrom paper catany cut of business. Allow me to elaborate on this. The Bergstrom Paper Company has never, to w knowledge, purchased PCB's tor use in our production processes from Monsanto or froa any other foreign or domestic supplier. PCB's are not and they newer have been an additive to Bergstrom paper products. ' a May of 1974, Bergstrom Paper Cenpany cooperated with toe Industrial Wastewater Section of the IS in a survey of all of our mill conditions and wastewater characteristics as they related to toe sonitoring aid reporting requixanents of our KPDES pennit. In analyzing a composite sample froa our main outfall for PCB's, the Department found a discharge level of .0185 parts per million. It was assumed that toe source of the PCB's was carbonless waste paper and our ccnpany assisted the Department by sending samples of such waste paper to the State lab for testing. . in March of 1975, we were advised that toe DNR bad conducted additional ssnpla tests cn our effluent in February of 1975. Hie Department then requested that we first analyze our general types of waste paper process to identify toe specific source of PCB's and to detsaaaine if it is practicable to significantly reduce fete discharge of PCS'a by eliminating certain kinds of wast^aper. Ami secondly to determine if leaking teat exchange fluids os hydraulic fluids eould be a soiree of PCB discharge. ' ' 44 WTM00581 NCR-FOX-0281438 WATER PCB-SD0000041076 At considerable expense to-the cenpany, ve ooiplind with, the Department request and conducted extensive tests on.14 wastepaper samples and en cur hydraulic fluid* Ho KB's were detected in the hydraulic fluids and the Department has been provided with the results of the paper sarnie tests. Die important fact is that all-14 wastepaper sattple tests shewed sene traces of either Arcelor 1242 or Arocler 1254, ranging from less then .1 of a part per nviHlcn to 3.6 ' parts per millicn. Die vast majority of the. KB's detected in the wastepaper were of .the Arocler 1242 variety, which was the only Arocler. known to be used, in the production of carbon less paper. We are advised that PCB's have not been used in the production of such carbonless papers since early 1971. We are also advised by the Institute of Paper Chemistry that in order to detect PCB's in wastepaper samples at less, than 500 parts per billion for Arcelor .1242 or 100 parts per billion far Aroclor 1254, which are the current limits Of detectability; we would have to test massive quantities of wastepaper in order to arrive at a concentration level in which the minute quantities of PCB's could be identified end counted. Indeed,. this lack of technical capability to accurately measure, much less continually iremtor the PCB's in both, the wsatepaper'we eensane and in our effluent, would suggest to us that there is no known way to enforce either proposed rule short of closing all recycling operations. . In order to identify and eliminate those grades of wastepaper which currently show PCB contamination at rxure detection levels, we would face both enormously expensive and physically impractical, if hot impossible, processes. Few laboratories are even equipped to take on such a saspling or monitorin; project on a regular basis; Die point we're trying to make is this. PCB's.did exist--do exist in the environ ment today. Through the voluntary efforts of the manufacturer, Monsanto, and those utilizing the product, .current ccnsimptim is'limited to closed systems which minimize the entay:6f more PCB's into the environrent. By placing a restriction on the discharge of PCB'.s, not necessarily ' by the manufacturer or by his custaners, but by those recycling 'caiganies who find themselves inadvertently obtaining PCB's in their wastepaper, will.result in catastrophic damage to cur business and to the cause of recycling. . . In the past few years, a number of programs have been inplanented to separate materials fron the solid waste stream. Dse proposed rules would be devastating to such efforts. For example., we recycle sorted office waste which cones to us as a result of a major office waste recycling program, which includes amccg .its participants governmental agmeies of the State of Wisconsin.. Fran time to time, old carbonless papers from office files find their way into this program. A ban an PCB's would very simply put an end to the program. Die Wisconsin Solid Haste Recycling Authority will face a similar problem in dealing with residual materials ' from a variety of establishments.' - '. . Representative Aspin has earlier suggested time approaches to the problan. We concur that additional health studies are necessary and we certainly concur with a ban on the impart of PCB's. But with respect to his suggestion of a total ban. on discharge of PCB's in effluent, which after all, is the subject of this hearing, v must point cut that this is cnly possible through the termination of recycling. Operations. ' .. . ?te. believe that tiiese is'no recycling mill in the .cewntry which could consistently meet a zero PCB discharge level, no matter how careful it might be in attainting to isolate bid carbonless papers, since PCB's are a pervasive background occpcnent in a variety of wastepaper grades. Die Bergstrom Paper Ctnpany, 50 percent of whose wastepaper exceeds the limits of POT detectability, would be forced cut of recycling were the Department to irposa either of the proposed rules. Since we have no guaranteed backup supply of virgin pulp, we sincerely fear that a halt .to our recycling would force us to go cut of .business altogether. Die additional . cost of purchasing virgin pulp would force such a major increase in the price of our products merely to cover this .added expense that we oculd no loiger carpets in the paper markets. . Our objections to the proposed rules can be summarized as follows: Regarding hath alternative rules, no. 1 and no. 2, your own Department staff at the JUne meeting of the board ffnivi(*3 to the finding of PCB's. in melting snow, which illustrates the problems'of achieving zero discharge. Bo the best of cur knowledge, there is no technological method for achieving a zero discharge of- this possible contaminant and we believe a five part per billion limitation' to ha tantamount to zero discharge in view of current treasuring technology and techniques. Furthermore, we roust respectfully suggest that there are a lumber of other issues which must be resolved before any PCB regulation should be considered.. First, there is no physically practical cr eocmcreically feasible method for continuously testing either wastepaper samples or effluent to insure either a limitation on any PCB contaminated wastepaper used in cur production or consistent compliance with the discharge limitations being proposed. 45 WTM00582 I NCR-FOX-0281439 WATER PCB-SD0000041077 Secondly, there is no evidence that restricting the discharge of FCB's will substantially reduce the number of PCB's currently in the enviroroent since solid wastes currently being recycled would have to be disposed of either through landfill or .incineration. In neither process is there a destruction of the chemical compound. Thirdly, there is no substantial body of scientific knowledge to. dancestrate that the ingestion of`minute quantities of FCB's is harmful to human life, to the best of our knowledge. Indeed, wa knew.a few laboratory experiments to assess toxicity in which Aroclar 1242, vhich is the one found in old, carbonless paper, has even been the test median. . Fourthly, there is no evidence known by us which would suggest that Arcelor 1242 found in our effluent is the same Arcelor found to acctnulate in the fatty tissues of fish, fowl or other wildlife. Indeed, though it has been docisnented that Arcelor 1242 was the most plentiful Arcelor produced by Mcnsanto, few traces of this variety are being found in the envirorment. ' It is apparent from the testimony gathered at these hearings that legitimate questions of concern have been raised about PCB's. it is also apparent, Z think, that wa have great gaps in bur knowledge about the effect, the degradability, and the econemics of eliminating PCB's. Ke believe that it would be unconscionable fear the Department to pratulgate these proposed rules without better documentation, to shew that the proposed discharge limita tions are necessary; that they are attainable and that they ore of sufficient benefit to merit halting recycling in the State of Wisconsin. ' Since being, alerted to the possible problem of FCB's, we at Bexgstraa have attempted to oooperate with the Department of Natural Resources to the fullest. In our independent research, we have discovered that the cnly thing everybody seems to agree on regarding FCB's is that nobody really knows that much about that. Authorities are split an questions of taicieity. Experts - dispagree on safe alternative products. Scientists have divergent views on questions of PCB stability arid degradability. If there is a prcblon, those of us in recycling will do cur share to find reasonable solutions to the problem. But a hasty,, ill-conceived decision to pramlgata either the proposed rules will raise ecorotic havoc with an entire recycling- industry, which, by its very nature, is one of the most environnentally considerate industries in the state. Ke strongly urge rejection of these proposals and the creation of an unbiased task farce to review and research the PCB situation and the adoption of reasonable regulations if it is shown that regulation is necessary to protect the people of Wisconsin. - Thank you. '. EXAMINER: Thank you, air. Can you provide me with a copy of that statement? MR. WA1C: Yes. ' EXAMINER: Thank you very much. Mr. William Dryer. MR. DRYER: My name is William Dryer and I am director of research-end development for the Flambeau Paper Company. The Flambeau Paper Company is a semi-integrated sulfite mill and paper mill located at Farit Fails in Price County. Flambeau employs 525 people and has an annual payroll of $5,800,000. We purchase about 90,000 cards of wood each year frbm our Wisconsin or local loggers at a cost of about $2,700,000. We pay $4,100,000 in federal taxes; $600,000 in state taxes and $136,000 or about 25 percent of the City of Park Falls taxes each year. We operate in a part of Wisconsin which is considered to be a depressed area. We produce pulp using the calcium base sulfite process. Our paper machines manufacture bonds, duplicators, mimeograph. Xerocopy, envelope; offset, manifold, register bend and many specialities. Since we are not able to produce all of the.fiber required by cur paper rtachires, we are krom as a semi-integrated null. We must purchase seme kraft pulp, which is produced by the sulfate process and is the most readily available source of virgin market fibers. We also buy wastepapers to keep cur paper machines operating. During normal times, cur purchased wastepaper consists of envelope dippings and other unprinted wastepaper. However, whan market pulp is scarce, wa will purchase other types of wastepaper and keep our paper machines running. One other item I would like to explain is "brete1*. This is the name given to spoiled paper in paper mills and finishing room. It is generated by any number of causes during the 46 WTM00583 NCR-FOX-0281440 WATER PCB-SD0000041078 1 processing and packaging operation. IE it la .not, contaminated, it .is .usually repulped and tie fibers returned to the papeaasaking process; ' The proposed administrative Codeprovisicns to prohibit or severely limit tie discharge of polychlorinated biphenyls, if adopted in their present form, will have devastating effects an. all paper corpanies in the State of Kisransin which' axe' not octupletely integrated. I would like to cite our cecpany as a case in point. Virile cur sulfite mill has the capacity to produce about 125;and a half tana of pulp each day, cur paper machines can use in access of 290 tons of fiber during the same period of time; During normal times the difference is made up hy. using purchased kraft, cur paper machine broke and our finishing rocm broke and. purchased wastepaper.. Early in 1974, at a meeting of the Swedish Pulp and Paper Mission held in Chicago, we were told that Europe would soon be in importing rather than exporting pulp. She same set of conditions exist in the United States. We are expanding our papermaking capacity such-- at a much faster rate than we are expanding our ability to produce pulp. During the simmer and fall of 1974 when the demand for paper was high, Flambeau was unable to purchase enough kraft to fill its requirements. Even by buying all the wastepaper we could cfetain, we still were unable to secure enough fiber to operate all of rrr paper, machines continuously so that we could fill all of the orders fer paper. ' On December 3, 1974, we took ccrr .ito. sairple* from cur outfalls and had them analyzed by a.consulting laboratory for 24 char, .is, including polychlorinated biphenyls. Vo my surprise, our effluent contained 2.3 .part: er billicn of PCB's. My feeling was that our consulting laboratory had erred in their testing. After learning mere about the nature of PCB's, I now feel that this test was correct even though we did not knowingly use any ' psre-1972 no carbon reproduction paper in cur furnish. - PCS's will tend to stay with the fibers or particulate matter, Camercially there is no way of telling which broke contains PCB's and which does not, unless you can trace the origin of the paper back to its furnish. If brokewas used in that furnish, then the . origin of that broke must be traced back. also. Probably sane of the wastepaper we used when kraft was in short supply, was madefroa furnish containing oane'pre-1972 no carton reproduction paper. How seme of the paper made by cur oanpany during the last three-quarters of 1974 contains PCS's. We Jmow that part of what was made on December 3rd did; If alternative 1 is adopted, I would have to advise our company to dispose of all our.purchased wastepaper and all of cur finishing room broke to paper mill--to paper mills in other states. V.'e could no longer use purchased, wastepaper in our furnish and we could use none of cur - finishing roam broke until we were certain that it was manufactured only iron virgin fibers. Our mill`Would never again sun at 100 percent capacity, far during the times of recession we would not have orders to run at full production and during the times when the demand for paper is high, we wtwld not be able to purchase enough virgin fiber to fill our needs. By having to use all virgin fiber, our furnish costs would raise, and we would rc longer be ccnpetitive with mills in other states. . If alternative 2 is adopted, we would try to operate as we did during the last three-quarters of 1974. He would not use office wastepaper, rc; would we use NCR no carbon reproduction paper. Our purchased wastepaper sorting costs vutid increase and since other mills would hove to use the same type of purchased broke as we are new using, we probably will have to f<r ourselves having to shut.our paper machines down at tines for lack of fiber. The paper industry does not knowingly add PCB's to its products. The PCS's added prior to 1972 will decorpose with time. Recycling of wastepaper will, not increase the amount of PCB's in tbs envirorment. PCB's are concentrated in pre-1972 no carbon reproduction paper. Both the federal and state governments are large users of- this type, of paper. At present, the Deportment of Natural Resources discharge monitoring report form is printed on no carbon reproduction paper, sconor ar later these completed forms will have to be disposed of. New is the time for government to find out which of their forms are rant-ami rated with PCB's and which are not. Contaminated farms ehTMid be segregated and disposed of in a sanitary, landfill. Forms free of PCB's should be as such and recycled, This would do mare for reducing PCB's in cur water and air than either alternative 1 or 2 and at the same time it will conserve air natural resources. Thank you, . SfflHBffilU Thank you, sir. Cmld X have a espy of that? Is Mr. losaan here? Mr. Milt Ionian? 47 WTM00584 NCR-FOX-0281441 WATER PCB-SD0000041079 Is there any other individuals representing the Wisconsin Paper Council present to give any kind of testimony? Hr. Richard. Beilins. Wtould you like to sake a statement sir? HR. ROLLINS: lank you, Mr. Christenson. My nans is Richard Rollins. I'm here on the behalf of the Electronic industries Association, the EIA. ' The EIA is a national association far the manufacture of electronic ompraenta and equipment. I speak on behalf of that body today and represent 14 companies that operate 16 plants for the manufacture of capacitors in this country. Hbhe of these plants is located in Wisconsin. I would bring a few statements--a few questions in regards to what are capacitors and transformers and where they're used and we begin with capacitors and transformers are devices to store, control and direct the flew of electrical power efficiently and econanically. PCB's are used as an insulating fluid in these devices. PCB filled capacitors are found, among' other places, in outdoor lighting, fluorescent lighting, air conditioning and television receivers. PCB filled transformers are found, toong other places, in railroad cars, apartment houses, large office buildings, industrial plants and utility substations. ^ primary reason for the use of PCB's in capacitors and transformers is their quality of nonflammability. While certain present alternatives do have other needed characteristics, no present alternative provides the nonflanmabllity daranded by our customers and by due regard for p,ih1 ic safety.. . Governmental agencies have recognised the need for the continued use of PCB's in restricted circumstances, namely sealed electrical applications. In 1972 the Food and Drug Administration exerpted the safe use of PCB's in electrical capaeitators and transformers from . the requirement that PCB's no longer be permitted in feed-related establishments. That's in the 38 Federal Register, 18096. In 1972, also, a Federal Interdepartmental Task Force found that continued use of PCB's in transformers and capacitors was necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB use. iat is under the Federal Report Ho. HF-PCB-72-1. While recognizing the need for continued use of PCB's in electrical applications, one nay not ignore the need for strict control over the discharge of PCB's. ms, our membership has implemented controls resulting in a total daily discharge of less than 11 pounds, that is less than two gallons, and that represents .014 percent of the 79,000 pounds used daily. Our handling and disposal practices are in accordance with the guidelines established by the American Rational Standards Institute, C107.1-1974. - tank ycu. EfflMIHBR: Thank you very such, sir. ' Mr. E. P. Tilscn. Would you have a statement? ' Please identify yourself aund who you represent. MR. TXLSCtfc My name is Edward LIson and I'm an engineer-in-fczaining, actually my PE license is pending review. I represent, today at least, the Water Resources Center at University of Wisconsin. And this is a letter that the center has sent to this--to the attendees of this public hearing cr. polychlorinated biphenyls. Dear Participants: This letter will hopefully serve to advise you that we at the center are also presently concerned with polychlorinated biphenyls, most especially as regards the Menenranee River Pilot Watershed Study being sponsored by the International Joint Ceemissien and the U.S. Environmental protection Agency, iis study, centered on the Mencmemee River watershed in the Milwaukee area, has PCB's as a selected water quality parameter within group C (organic) as determined on water and sediment sanple3. This class of ccqxunds will be a focus consistent with the stated objectives of the study. Che, to determine the types and quantities of potential pollutants moving in flew systems toward: Lake Michigan. TWO, to define sources and characteristics of potential pollution in terms of urban land use and three, to develop a model to facilitate extrapolation of findings to ether urban settings. It is, however, to be noted that identification is not so much directed toward individual point sources in tots study as toward diffusa origins, that is, the correlation of parameters to land use. 48 WTM0O585 N C R-FOX-0281442 WATER PCB-SD0000041080 In turn, manufacturing land use would be expanded to industry type according to standard Industrial classifications. Further iteration would allow quantifiestica of deviations fron the derived calibration-coefficient means by sub-basin. Hie finding, of PC3 levels above limits of detection within the study area is perhaps consistent with its heavy industrial character, featuring chemical producers, electrical equipment manufacturers, machinery fabricators and transformer switch yards. . - One of our staff is investigating the possibility of in-stream synthesis of KB's fron the waste products of industry present in the watershed. However, since this study is in its initial phase, I will not elaborate except to say that such a source has apparently not been hitherto considered. Certainly the ubiquitousness of this potential origin las ranch in camon with the ubiquitousness of PCB occurrence, most dramatically in snow-melt watera. Yet even should such a mechanism withstand further scrutiny, this could not be construed as likely to exonerate other potential sources. '' '. ' Hoping that our center's sendee is useful to you in the future--the signer is nest sincerely, John W. Goodricb-Mahoney, specialist, water resources, forth* Water Resources Center, University of Wisconsin in Madison. . I'd just sort of like to footnote to that that what could be said of this is that to the extent that seme industries are saying that there is a prcblea of ubiquitousness, it is not to say that this isn't being locked into.. And then the-second thing might be to say that I vets in a. program, a graduate program in engineering, economic planning and within that program there tended to he a stress, rather than on money and cash flews, ratter instead in terms of social resources.. And one of the social resources which is not.being properly applied today, the nuiiber of biologists and chemists such that when the applications cane into Water Resources. Center, tba credentials are such that people would like to hire two or three of than, but they only have the funds to hire one. _ Of KB'S. And this certainly is a resource which oculd be increasingly applied to this problem ' EXAMINER: Thato you vety auto, Mr. Tilaon, I appreciate your testimony. Is there ary other person present this afternoon too wishes to make an oral state ment at this time? - (No response) EXAMINER; In that case, Z only have--have tuo questions going to" 'a decision will be made by the Department with an anhcuncement toacirow. First of all, by a show of hands, tow many persons in the room feel that they may purchase a copy of the transcript or feel they should have a review of the transcript? Okay. Thank you very Such. Now, a related question, as Z stated earlier in the introductory rararks this morning. There Will be a written canrent period regarding the proposed rules and the subject matter of the hearing today. Kw, a question has-been raised and I believe it's been raised by, as one party, the Wisconsin paper council, as to the appropriateness of cannenting after the transcript's been available, so they could have a more detailed.review of what was said. I'd like to know if there's any other parties too have that--ehare that same feeling. If there are, also-could X have a stew of hands, of that? ' - - Okay. This will be considered and I will make an announcement temerrow regarding toe consent period and also availability of the transcript. Of course, toe transcript is always available fee purchase, but the decision is being made now as to whether we'll make it available to all matters of toe public, at least in limited areas. For your infeasnatiai, before I adjourn the hearing today, the hearing tomorrow will start at 8:30 in the morning and presently scheduled are four or five gentlemen representing the Envirwtemtal Protection Agency or the office of Toxic Substances. So perhaps maty of the questions you-have or information you're locking to can be given tchnrrew. Are there any questions before I adjourn the hearing today? (No response) EXAMINER: In that case, the hearing is adjourned 'til tanegrew 'til 8:30. Shank you very natch. (Bearing adjourned) 49 WTM00586 NCR-FOX-0281443 WATER_PCB-SD0000041081 BOMBER: Ladies and gentlemen, we're resuming the hearing regarding proposed effluent diesharge limitations rules by the Department of Natural resources. As in the presentations yesterday, the Department of Natural Resources have asked various people freta governmental agencies as well as industry to sake presentations on behalf and at the request of this Department. It appears that this morning presentations will be made by representatives of the Emdroraental Protection Agency and that the presentations will last the bulk of the naming's testimony. Hus afternoon will be three for public consent and questions may be asked to the 0. S. Environmental Protection Agency, although there will be no cross-examina tion. With that, I'd like to call Mr. Glenn Schweitzer, who's the director of the Office of Toscic Substances. . MR. SCHWEI12ER: A limited ranter of copies of my presentation will be available after I complete my remarks and particularly for the press. . I greatly appreciate the opportunity to present the views of the Enviromental Protection Agency concerning the environmental problems associated with the manufacture, use, distribution and disposal of polychlorinated biphenyls. Since its initial days, the agency has been concerned with practical steps that ceuld be taken to clarify and reduce the environmental risks attendant to canaercial applications ofPCB's. More recently, the agency has intensified its efforts to help insure that unnecessary hazards are effectively curtailed. Dais, we fully share ycur concerns and we will continue to work with state governments and other interested organizations in seeking feasible solutions to this problem. In view of the background papers that are available and the detailed statements being presented by specialists at these hearings, I will confine ay remarks to a brief review of tte history of the PCS problem, recent developments which have lead to increased concern and the spread of EPA activities directed to PCB's.'1 1 will then cement briefly on a few aspects that are of particular concern to the State of Wisconsin. In May, 1972, tte Interdepartmental Task Force concluded that PCB's were highly persistent, could be found in all parts of the environment, could bioaceumlate in fish by a factor of up to 75,000 and could have serious adverse effects cn human health. The task force urged discontinuance of all uses of PCB's except vises in closed electrical systems and called for early enactment of the toxic substances control act to provide a needed regulatory mechanisn to with PCB's and other problems of this type. . largely, as a result of the activities of the task force, the Monsanto Company, the sole U.-S. producer of PCB's at that time, voluntarily limited its sales tO'manufacturers of i-inccA electrical systsns. Also, EPA promptly announced that it would begin restricting the discharges of industrial effluents so that the levels of PCB's in rivers and lakes do not exceed 10 ppt. PDA took steps to establish PCS tolerances for several types of food, ranging from .2 ppm in baby food to 5 ppm in fish and to limit PCB contamination in food packaging and in food plants. . As further followup to the task force recaimendatlcns, the General Services Administration anendsd its procurement specifications to ban PCB's.in paper and the Department of Interior prohibited future use of PCB's in off-shore oil operations. The American National Standards institute issued guidelines fas in&tstxy on the use, disposal and labeling of PCB's. - Internationally, a decision of the Organization fear Eoowctnic Cooperation and Development, the CECD, provides that PCB's shall not be used ^ industrial or ocranercial purposes except in certain closed systens. However, even in respect to the accepted uses, the CECD council ffoaVdari that PCB's should be-----should only be used when adequate envirorcental controls are exercised and when benefits cutweight the risks and recarmended that countries work toward the elimination of PCB's in small capacitors.- This decision leaves it to the member governments to go beyond the council agreerents aid, in effect, invites governnents to phase cut PCB uses wherever possible. Japan, in the wake of PCB cantminatien of rice oil that adversely affected 1,000 people, banned future production or import of PCB's. More recently, the Canadians have begun to collect necessary data for restricting PCB's pursuant to a new Environmental Contaminants Act which should be enacted this year. Now, turning to recent developments. Recent research results have heightened concern over the toxicity of PCB's previously documented in the report of the Interdepartmental Bask Force. Concentrations as lew as 2.5 and 5 pfa have produced sericus adverse effects in monkeys. I believe you discussed- these effects yesterday. A still unpublished report indicates malignant liver ttsnors in rats exposed to cne grade of PCB at levels of 100 pp. Several reports of chloroacne encung workers exposed to PCB's have also been received. Also, ocncentratiens of 5 pjjfl isi fish eggs have resulted in xy mortality. SO VTM00587 NCR-FOX-0281444 WATER PCB-SD0000041082 In considering these effects, it is important to remember that there are eight ccomercial grades of KB's and their toxicity characteristics nay vary to sene degree. However, there is no basis far assming that ary one of the grades is hots. potential hazard. As a result of the FEA actions described above, the FCB levels in feeds have been steadily declining. At the Bam tine, however, the levels detected in fish and wildlife appear to have increased. Available monitoring data for PCS*s in the ambient air, .rater sediment, soil or human tissues do not provide a geed basis for estimating national environnental trends. For exanple, analyses of rater samples have. Bftldaa extended into the parts per trillien range and thus only rarely have KB's been detected. Limited adipose.tissue samples for fiscal year 1972 and 1973 indicate a slight downward trend with levels in' excess of 3 ppt being observed. Unusually high levels of KB's have been detected in recent months in the fish and Z needn't tell you this, in Lake Michigan, lake Pepin, the Hudson River and Southern California. PCB's have been detected in sludge firm sewage treatment plants as well as in the effluents. fieem these plants. PCB's have been identified in only two drinking water supplies during the past year. There have been at least five water spills involving KB leakage from.transformers during the past year and currently there are tens of thousands of capacitors, each containing several gallons of PCB's, awaiting disposal. .. 13d.le Monsanto is believed to be limiting its sales to manufacturers, of closed electrical systens, information has been received by EPA indicating that PCS reprocessors may be. selling PCB's for other uses. It is believed that'most of the PCS irperts,. which exceeded 375,000 pound in 1974, are not used in closed electrical systems. Among the PCB uses which are known to persist in the United States at present are. applications in investment casting processes, heat exchange fluid and hydraulic fluids. There-are a variety of other potential uses of PCB's, although firm evidenoe of such current use is not in hand. With regard to substitutes, J)ott Chemical has developed a product for use in large ' power capacitors, and Dow Coming has a product which can substitute for PCB's in certain transformer applications. At lease one of these substitutes is reportedly being introduced at the present time in Japan. Mow, turning to reoent regulatory actions, in 1973, rater quality criteria were preposed to limit PCB's' to 2 ppt- in ambient waters; Also a national effluent standard far KB's was proposed under Section 307(a) of the Federal' Water Pollution Control Act. PCB's were included in the advanced proposal of a hazardous substances list under Section 311 or the Federal Water Pollution Central Act in 1974. That section relates to spills of hazardous chemicals. Finally, METIS permits that limit the discharge of PCB's have been Issued fee- at least six. facilities, pxelisdnaxy reports indicate that, approximately 10 to 15 other discharge'pewits 'may contain effluent limitations for PCB's. in addition, the efffluent guidelines.prctailgated for the steam electric power generatihg eategery contain limitations requiring no discharge of PCB's. A sig nificant percentage of the permits issued for this'category to date contain these limitations. And as you knew, several states are currently considering imposing limitations cn PCB's. how, I'd like to identify for you the spread of EPA activities currently in progress directed to'PCB's. A rater quality criteria level of 1 ppt will soon undergo interagency review prior to final praadgaticn. The originally proposed level of 2 ppt has been reduced in view of the recent ecological effects data. Detailed dbementatibn necessary to support a national standard for rater effluent discharges under Section 307(a) of the Federal Rater Pollution Control Act, is being assenbled with issuance of a revised national standard scheduled in the near future. Proposal levels of harmful quantities of PCB's accidentally released into navigable raters and rates of penalties for such spills are currently being developed pursuant to Section 311 of the Federal Water Pollution Control Act. .' A laboratory demonstration program is underway to develop and test control technology, for treatment of PCS manufacturing wastes, including the aqueous effluent from PCB users and the discharge frrm leaks fraa transformers and capacitors. Tte scientific literature concerning the health and ecological effects of PCB's is being reviewed. Further, a continuing research program is .investigating the-metabolism and effects of KB's. As part of this program, several studies have examined the effects of PCB's in rats after long-term feeding regimes, especially effects on reproduction, liver function, carcinogenesis, and hemoglobin metabolism. . Collection and analysis of adipose tissues ere continuing. Several laboratories have hem conducting research on the ecological effects and environmental fate of PCB's. 51 WM0058S N C R-FOX-0281445 WATER_PCB-SD0000041083 m Studies of the behavior of PCB's in soil, particulary after spills aid tte likelihscd that the PCB's might reach the groundwater, are underway. . Analyses of the technological and the cost aspects of substitutes for PCB's in closed electrical systems have been initiated. Technical assistance is routinely provided on the storage and disposal of PCB-ccntaining wastes. In addition, test burns of capacitors- containing such' wastes in a high temperature incinerator are planned for 1976. During the last few weeks, a number of additional activities have been initiated in response to the recent concerns that have been raised over PCB's and I'd like to just itemize those dght now. , The National Academy of Sciences has been requested to give special attention to whether a drinking water standard for PCB is needed. Meanwhile, mcnitcring far PCB's in drinking water supplies is being expanded. -' Infcarnation concerning the best campling and analysis techniques far PCB's in different media is being assembled and rendered to provide guidance to the regions, to the states, to contractors and other interested organizations involved in monitoring. A limited number of anbient air, water, sediment, soil and fish samples are being collected and analyzed throughout the country. This data, together with existing data, will pro vide an up-to-date overview of the current levels of environmental contamination of PCB's. m response to local concerns, several regions will be measuring PCB levels in effluent Streams from industrial and municipal sources, receiving waters and associated fish pop ulate,cns to assist in relating specific discharges to environmental levels of particular concern. Infarmaticn concerning the use and distribution of PCB's and the level of PCB's in effluent discharges has been requested fern 84. earpanies, which are believed to handle PCB com pounds or mixtures in their operations. These .requests for information have been made pursuant ' to EPA'a authority under Section 308 of the Federal Hater Pollution Control Act and Section 114 of the Clean Air Act. . A special review of past and recent data to assess the carcinogenic potential of PCB's is underway. ' Test data on the chemical properties and potential bicactlvity of substitutes for PCB's have been requested from Dew Chemical and Dew Coming. nported PCB's and polychlorinated terphenyls are being analyzed to identify contaminants. In addition, the techniques for detecting PCB's, PCT's and polybranirated biphenyls are being to determine whether interference among the substances prevent reliable analysis for any one of them. General guidance for disposed of wastes containing PCB's will be developed. The Department of Defense, the General Services Administration, and other agencies are being requested to review ani to amend as appropriate their procurement specifications and those of their contractors concerning the purchase of PCB's and materials containing PCB's, Consultations with the Japanese Government are being Initiated concerning their experience in implementing a ban on the production and impart of PCB's. Consultations with the CECT> governments are continuing in an effect to determine the effectiveness of the 1973 decision in reducing the PCB problem on a worldwide basis and to encourage expeditious carrying out of the provisions of the 1973 agreement. And finally, consultations are being conducted with the Canadian Government to inform them of our information and activities concerning PCB users in Canada and to coordinate future actions. Now, the remainder of cy statement I would like to direct to those questions that were specifically identified by the State of Wisconsin of being special interest during these hearings. First, with regard to the aquatic enviroRnent, EPA considers a PCB concentration of 1 ppt in the anbient water environment represents an. appropriate goal for the natien. This conclusion is reflected in the water Quality. Criteria which are currently undergoing final review prior to prcsmilgation and will be elaborated further by another EPA representative later this morning. We would suggest that this goal serve as very broad guidance in developing strategies on a nationwide basis and locally to control discharge of PCB's- into our waterways. 52 WTM00589 NCR-FOX-0281446 WATER PCB-SD0000041084 However, we are not prepared at this time to provide more specific guidance on tte control strategies that should be adopted nationally or locally concerning the regulation of individual dischargers. We are developing a nationwide strategy with a significant oaqxnent of our approach to be reflected in a revised trade effluent standard for tea's scheduled for proposal early next year. At the same tire, we recognise that a nationwide standard might not be adequate in addressing local problems in seme areas and the Control strategies adopted locally may of necessity require an elaboration of the national approach. In any event, we believe that better information is reeded concerning the specific facilities discharging into the aquatic environment before reaching a final judgement on a national standard. Also,- it is important to clarify the portion of the PCB contamination problem which can be attributed to specific dischargers and the practical feasibility of reducing'the discharges. As a key step in this regard, on August 16 ve requested from 84 eatraiu.es detailed infonaatioh concerning their activities involving PCB's including details on their uses of PCB's and monitoring data in the effluent stream and in tte receiving waters. Kith this information in hand, we believe we will be in a much better position to develop meaningful regulatory approaches which take into account the realities of current industrial activities. Now, turning to. the Toxic Substances Control Act, as Z have indicated, EPA is currently utilizing or preparing to utilize authorities tinder the Federal water Pollution Control Act which address the problem of effluents and spills containing PCB's in an effort to reduce the envircnnental levels of PCB's. Additional authorities may also, be used if warranted by further information concerning levels of Pffi's in drinking water or even possibly in air. However, each of these available authorities has a limited focus and none provides the post, critically needed authority to limit selected uses and distribution of PCB's.. Indeed, even with the cooperation of Monsanto to limit production as well as the use of existing authorities, it seems clear that the PCS problem will continue to persist in sane form. . Under the pending Ttotic Substances Control Act, however, EPA would have the needed authority and could deal with the problem in a. far sore effective manner. In addition, authority --in addition to authority to restrict the production and use of PCB's, the legislation would, if necessary, enable ISA to require testing concerning the health and ecological effects of the proposed substitutes for PCB's. _ . . . With regard to the limitations that might be considered under this; legislation, the 1972 .Task Force Report concluded that there were appropriate substitutes, presumably at reasonable cost, for all nonelectrical uses of PCB's. Wa have, re "imfeoatire which would contra dict this conclusion. However, we currently are carefully analyzing each PCB use and the technological, environmental and cost aspects of possible substitutes to insure the soundness of that original conclusion. Also, 'we are carefully-reviewing the recent developments cehberning substitutes for -PCB's in closed electrical systems before reaching oiir final conclusions concerning the extent and character of limitations that would be . appropriate under the toxic substances control act. ' He are optimistic that we will have this new authority within a few months, but as you know, further aoygnent in this regard rests with the Congress. . Finally, cne key aspect of the Ttedc Substances Control Act should be emphasized, namely the authority to review rew chemicals before they are marketed and, if. appropriate, require testing or take steps to limit the production or use, if there is reason to believe a,hazard to hunan health or the enyirorcent might ensue. This preventive Or front-end approach to the control of chanical hazards wcdld provide a far mere reasonable and more cost-effective approach than current efforts to correct prcblms after the damage has been done. Not only would the public benefit front the esvizonnental point of view, but also the economic costs to industry would be minimized by taking actions prior to the time that major investments would have been made. It is clear that the past policies of allowing uncontrolled proliferation of chemicals such as PCB's into tbe envirenrent, chemicals which have proven to be both persistent end hazardous can re longer be tolerated. ' . .r . With regard to the experience in other countries, which is of interest to. you, we do have sane information frail Japan which I would like to report to you. The most relevant foreign experience in regulating PCB's has probably been the recent efforts in Japan where PCB's have been under government regulation since 1972. The Japanese Goverrmant has recently provided us with sane preliminary Insights as to their experience. The following consents are baaed on Initial reports we have received and we plan to obtain mere definitive information in the near future. According to infsanation just provided the Japanese Govemaent, there has been practically re production, import, or expert of PCB's in Japan since 1972. .The only two cotpaniea which had been producing PCB's in Japan stopped production and suspended sales in early 1972. . S3 . ' wmaosao NCR-FOX-0281447 WATER PCB-SD0000041085 Cne exception has been the production of PCB's fee railroad transformers which was discontinued is Septoifcer, 1373. Use of existing stocks of railroad transferrers and condensers, but no nor equipment using PCB's is pennittad. Even this limited use is subject to the restriction that to discharge of PCB's to the environment may occur.' Beginning in 1976, paper plants will be prohibited fran accepting PCB contaminated paper for recycling and such plants will be required' to build . treatment plants which will meet general discharge standards. Further, we understand that the impart of equipment using PCB's has also been virtually eliminated as of September 1972 and for these few products which have been permitted into the country, importers must cooperate with the ultimate users to insure that the components containing PCB's are recovered and properly disposed. Disposal is regulated by the Waste Disposal and Public Cleaning Control law which was amended in February, 1975 to include PCB's. Currently there are no regulations for labeling or handling PCB's. The present limitations on the use, import and export of PCB's are based cn Article 3 of the Chemical Substances Control Law which went into effect cn June 10, 1974. Ary manufacturer who wishes to produce PCB's in the future must apply to tte Ministry of International Trade and Industry, although approval of such a request is regarded as highly unlikely. Tta Japanese Government projects that a total ban on PCB's will' take effect in approximately six to ten years, when the current stock of equipment containing PCB's is exhausted. The Japanese has established PCB contamination limits for fish and shellfish of 3 ppm far near-share varieties and .5 ppm for ocean varieties. These limits are derived from a basic limitation for huran intake of 5 milligrams per kilogram of body weight per day. Guide lines first set in 1973 for water quality and bottom sediment were revised in February, 1975 to hot detectable, dftfimi as less than .5 ppb for ambient water and lb ppm far bottom sediment. These stardares are not necessarily permanent standards, since they were set with current monitor ing capabilities in mind. Under the water Quality Centred. Law, the authority used in setting these standards, penalties are imposed for exceeding authorized limits. Monitoring of the water quality and bottom sediment by each prefecture is Required by this lew. We have only very sketchy information concerning effluent limitations in Japan. According to the reports we have received, the Japanese Prime Minister's Office Ordinance based oh Article 3 of the water Quality Control Law sets the mwtiniffi permissible KB concentration in effluents at the point of discharge into rivers or lakes at 3 ppm. Coupled with this limitation is a provision authorizing a penalty for exceeding the effluent limit. The environmental levels of PCB's in Japan have subsided in the last two years and are expected to continue to diminish. In a 1974 survey of bottom sediment, including over 1,700 samples, 14 samples had PCB concentrations of over 50 ppm, 37 of 10 to 50 pprr. and 21 of 5 to 10 ppm. In the previous year, seme PCB levels had exceeded 10,000 ppm. Mo such peaks were found in 1974. Concentrations of PCB's in the milk of mothers were dcMV over the previous two years, although 25 percent of the samples were contaminated. The Japanese Association far the Disposal of PCB's is responsible, along with local Governments, for the collection and temporary storage of household electric appliance and other electrical equipment containing PCB's. The association will develop PCB treatment technology and treatment plants for disposal, although the latter effort has been delayed by public opposition to the. selection of proposed treatment plant sites. Substitutes for PCB's that are currently in use in Japan include far carbonless copy paper, alkyl napthalene and alkyl pbenyleihane for heat transfer, diphenyl, diphenylether, alkyl diphenyl, alkyl naptbalene, alkyl benzene and mineral oil and for transformers and capacitors, mineral oil and silicone oil. In conclusion, I would like to stress that EPA intends to continue to give high priority to the problems associated with PCB's. The recent data on toxicity and levels of environmental contamination have heightened our concerns and have stimulated considerable tv&r activity. Much is known about PCB's and much more will be known in a few months as cur current data collection efforts are brought to fruition. In recognition of the national interest in the PCB problem and particularly the interest in the Great lakes area, I am pleased to announce that in late fall, EPA, in cooperation with other federal agencies, will sponsor a national symposium in Chicago to further clarify selected aspects of the PCB problem. The State of Wisconsin herewith receives care first invitation to participate. I'll be pleased to try to respond to questions if that's in order. EXAMINER! Thank you. Do you have a copy of your report, sir? 54 WM0O591 NCR-FOX-0281448 WATER PCB-SD0000041086 *31. aaHEUZESl! Yea. r-'.MIffiR: Thank you very much. Doestbe Department have any questions of Mr. Scteit2er? MR. KLEEHEHT: Mr. Schweitzer, I'd like to address sene questions to the effects ctf the EPA to establish effluent standards for PCB's. Earlier EPA had .proposed an effluent standard far ICR's and I understand front your consents here this sensing that this general, standard concept isn't sonething that you're pursuing right now. . You're mere or- less looking at industries as groups is trying to reach limitations on discharge; is that .correct? MR. SCHHETTZER: I think what you're saying is correct, hut I'm. not sure the implication is correct. HO have not necessarily abandoned -the notion of a national---we are . planning to propose a national standard for PCB dischargers. Whether that, standard will he a series of numbers directed at specific types of discharge or whether it will be one number is undecided at. the present time. Is that responsive to yeur question? . MR. rrPTttEBT- i think so. What is the timetable or could you make an estimate when effluent standards would he established nationally? . . MR. SC8HEITZER; The timetable for proposing a.standard is late February. I cannot give you a acre specific--I can't give you a timetable on when this data would be prdsulgated final or when it would to into effect; .1 think the pranulgaticn date depends largely the reaction of the interested.parties and the public to the proposal and the length of time that the hearings would ta^e. The date at which the center would he effective would, depend on whether or not the finally promulgated standard is challenged-and if it is challenged the time that the court litigation takes. So I can't give you a date for when the standard-would be pranulgated final, nor when it would be effective, given the uncertainties involved in going a proposed standard to one that's in effect. , * MR. KEEHERT: I have another question on your contents cm the Japanese actions. I believe you indicated that the Japanese have established an effluent standard of three parts per million; is that cixrect? . MR. S39ErrZERs that is the report that we have' received fretn the Japanese govem>ment. We have--it is.a preliminary report; it has hot been confirmed and I really don't Jaw what it--Z raised ny eyebrows when I saw that muter eyaelf, hut I wanted to give you what we have and that's all we have and we have not.confirmed it. But we do have a report which soys that. Yes, sir. ' MR. XXE3NERS: Okay. Thank you.. EXAMINER:- Mr. Schweitzer, just one quick question before X open the rest of the pregram up to questions, you stated that there Will he a national symposiaa in Chicago in late fall. Bo you have ary tentative date---definite data for that synposim. MR. SCatELSZERs November. . EXAMINER; Ckay. Thank you. New, ladies and gentlemen. I'll open it up to questions, please try to confine your questions to. remarJca 'Mr. Schweitzer made. There will be technical people here from the--from EPA. - MR. SCEKECrgER: Mr. Chairman, may X make one--*-if there are any questions of a policy nature, I would prefer to take them at this time. There are--technical people will be happy to answer technical questions, but if they're policy questions, new ia the time to ask them. . ' .' . . EXHUMER: Ckay. Fine.. Would anybody like to ask him questions? . VOICE; Ace copies of your statement available? MR. SCSWSTTZER: We have a limited ranter. X think that we had saaething like 20. X just-- . EXAMINER: All right. The question was whether there was copias of the statanent and Mr. Schweitzer's response was approximately 20. . Airy further questions? {Ns response) SS WTM00592 NCR-FOX-0281449 WATER_PCB-SD0000041087 EfflMlNSU Cfcay. 3h that case, thank you very such, Mr. Seteeitzer. Is Mr. G. D. Veith present? Please identify yourself and who you represent. MS. VEHS: My name is Gilman Veith. I'm a research chemist with the Envixcnnental Protection Agency at the national Mater Quality lab in Duluth, Minnesota. My duties there involve the development of analytical methodology fdr isolating and identifying persistent organic chemicals in natural waters and aquatic organisns and research concerning the hiooanoentration of organic chemicals in aquatic organisms. . My testimony today will be taken firm ocnpletad and ongoing research and it will show that the PCB's are bioooncentxated in fish by factors greater than. ICO,000. Zt will enphasize that tte PCS residues resulting bioconentratlng from 10 parts per trillion of PCB's in the water have jeopardized the food resources of lake Michigan and tall discuss, in part, the rationale used for the cce part per trillion water quality criteria far PCB's. Shore are really three points I'd like to make today and our bioccneentr&ticn studies have shown these. The first is that bioaceumulaticn of PCB's in fish can be modeled by pharmaketics and appears to respond to a first order uptake model, The second is that the residues in the fish at steady state, being saaewhera in the order of 30 days, is directly related to tta water concentration that they are exposed to and that the decrease in the--of the fish residues cannot be expected without a decrease in the water concentrations. Third, once PCB's are accumulated by fish, c.HmiTv.Hnm of the FCB residues is immeasurably slew in elimination studies exceeding three months. Consequently P residue concentrations---I use the word concentration rather than total burden or a residue. The PCB concentration in fish from contaminated waters decrease only by dilution of body mass through growth. More Important than the direct toxicity of PCB's to aquatic organists in establishing effluent regulations for the protection of the environment are the extranely high fat solubility and persistence of these chemicals. Research during the past five years has shown that although PCB's exhibit acute and chronic toxic effects in fish at concentrations oesparable to those of other chlorinated chemicals, the high fat- solubility of the PCB's caused fish to accmtulate hazardous residues, that is, with respect , to consumers of the fish, from water concentrations far below the Concentrations that affect the fish directly. This tendency to form residues fran PCB's in water is measured by a concentration fat bioconcentration factor, which is a ratio of the concentration in the fish to the concentration in the water and the bioconcentration of PCB's in fish far the mare highly chlorinated ccnyounds, exceeds 100,000 times the concentration, in the water. - The second property of PCB's is the fact that these chemicals do not degrade in the aqueous envirorraent as rapidly like the bulk of the natural chemicals which a-.Trjxi.9a wastewaters. The resistance of these chemicals to' degradation causes than to persist in waters far belt** the dis charge and the accuculaticn of residues in waters such as the Great lakes may be, in fact, directly related cor the direct result of PCS usage many miles fron the lake. ' The terms "degradability", "mere degradable" and "nendegradable" have all been applied to PCB's. .And the data show that only the PCB's containing one and two chlorines have been degraded by adcrocarganists in natural water systems and that PCB's containing three and four chlorine atoms similar to those of Aroclor 1016 and. 1242 have shewn sane selective degradation, as well as caiplete resistance to degradation under wastewater treatment conditions far periods of time far exceeding those canaonly arployod in waste treatment facilities. Equally important, any reservoir water tends to accumulate PCB's in the biota and the sediments. They act more or less like any biological reservoir acts, like a fiord. Con sequently, low level discharges may lead to a growing aecanulation of PCB's in large water systems, such as the Great lakes. ' Regarding the bioconcentration studies that we've done, an understanding of the bhoaonoentxation of chemicals in prganiaas is essential to. understand the dynamics of these chemicals in tba environment. Considerable confusion exists regarding the relative significance of various update mechanisms, due in part to the absence of detailed definitions of the system's study. Much of the early literature assured that bioconcentration in the aquatic eewironnent was based on the trophic level car food chain, concepts. However, exposures of fish to water containing these hydrophobic chemicals dansnstrated that fish can bioconcentrate ehaticals directly from the water. Update can be approximated by a first order rate process and that process apppaared to be that of chemical partitioning firm the water to the lipids in the animal. Hus has led to proposals where food 56 WTM00593 NCR-FOX-0281450 WATER PCB-SD0000041088 chain biccorcentraticn----the food chain bioaxxsentration medal ia rejected in favor of a chemical partitioning model. As with Tseng kinetic medals in dynamic systems, multiple pathways are often observed and the relative significance of the various rate expressions is really dependent on the conditions imposed. Therefore, the selection of either a food chain model or a chemical partitioning model for the aquatic environments requires that the conditions of the ecosystan be considered and defined. The bioccncentratdcn of PCB's in laboratory studies where the mixtures are added directly to the water have been studied for numerous aquatic organisms and the observed bio . concentrations for PCB's varies with Organisms of different lipid content and different exposure conditions. ' I'm including two---ifippemdix I and H, which are studies by Nebeker and Defoe at the Duluth laboratory as well as a paper of ay owi that show that the bicccnentration for Aroclor 1254 in fathead minnows ranged from approximately 110,000 to 240,000 and that the hlcconcentraticn factors for predominant PCB mixtures in the fathead minnows, that is fish enerally less than ten percent.lipids, at 25 degrees, ranges fraa 30,000 to approximately 250,000, That is, what I'm describing here is the range that we've seen for the ctmrcnly encountered PCB isomers and as you get men highly chlorinated, the bibcoocentration factors are greater. '. . in. 1370, the annual report of the Pish Pesticide Research lab in Columbia, Missouri, shewed that the bioconcentration factor for Arcclor 1254 in. the scud was approximately 22,000. It was also 45,000 after 48 bouts in Daphnia macna and 13,000 in mosquito larvae after only 24 hours. What I'm trying to do. here is just desanie--there's a lot of organisns that have been studied and they all seen to be in sanawhat of the. same range of exceeding 10,000 and over 100,000. After 60 days in an -exposure to Aroclor 1242 and Aroclor 1248, the maxinua bioccncentration factor in Ganroarus was found to be appraxirately 30,000 and 50,000, respectively. Also, the bioccncentration factors ranged from 20,000 to 60,000 for blupgllls and catfish exposed to Aroclor 1248 and - Aroclor 1254. Sane evidence exists that the biooonentration factors measured in the laboratory are essentially the sate as those found in the river .enyiroiment. For example, appendix shews that the laboratory derived bioconcentration factor for Aroclor 1240 in fathead minnows range from 100,000 to 240,000. Appendices IH.end IV is.a.report on PCB's in the Milwaukee River system and the near-shore environment cf Lake Michigan, report that goldfish in the lower Milwaukee River accumulated Aroclor 1248 approximately 70,000 to 200,000 times the estimated PCS concentration in the water and that difference is dependent largely on the fat content of the fish. In May--in the May, 1573 report to the Lake Michigan Bade Substances Ccnmittee, the Michigan Hater Resources caanissibn presented evidence that the raaxiam-concentration of Aroclor 1254 in the Saginaw River shad was 165. micrograms per gram, whereas typical water concentrations were about one microgram per liter to a maxima of 2.9 micrograms per liter. This is equivalent to a bioccncentration factor of 60,000 up to perhaps 150,000, which seems to be in good agreement with the labcratcgy-derived conutatLraticn factors. ., Also presented in this report- is data to shew that the concentrations of PCB's in the intake waters in the mmicipalities alcng the Lake Michigan shore are, with cane exception, all below"tan- parts per trillion--ten ng per liter. This indicates that the maxima ccmcen--bioooncentxation factor for saelt in the lake where the main concentration is an the coder of 2.7 mlcEograms per liter, is approximately 300,000. Kid that the maxima bioocncentration factor for large trout may be as high as 150--or 15 times 103. SO that's 1,506,000. Appendix V presents data ccnoexnihg the mean ooneemtratiema of PCB's measured in Lake Michigan--or lake Superior fish captured in 1972 and 1973 from western lake Superior. The data indicate that the PCB concentrations in smaller, lew lipid fish, contain up to approximately 1.5 mierogfams per gram--parts per million, whereas a large trout' PCB's in large trout have been measured up to 5.6 micrograms per gram. . . Also presented are estimates of PCB's concentration in the western Lake Superior water intake and a bioassay control tank of the National Hater Quality Lab in Duluth. These estimates were made using a foam plug extraction technique in triplicate, perchlorinating the. attracts to fom dacachlorohiphenyl andrreacuring the deeachlorobiphenyl formed. The data indicate that approximately one to two ng or parts per trillion of PCB's, measured as Aroclor 1254 are present in the western Lake Superior near-ahere waters. ' The mean concentration of the smaller fish of the order of .9 adcrograas par gram, which would indicate an overall bioccncentration factor in Lake Superior fish of approximately 900,000 ear--that's right. 57 WTM0-O504 NC R-FOX-0281451 WATER PCB-SD0000041089 In sanmary, the data from the Great Lakes demonstrate that tie PCB's are present in the waters of late Superior and late Michigan at concentrations below ten parts per trillion, but the concentrations of K3's in the fish are more than 100,000 times the measured concentration in the water and that the PCS residues which bioconcentrate in fish frxan water concentrations belcw 10 ng per liter have produced PCE residues in lake Michigan fish particularly that are significantly in excess of the PDA tolerance of five micrcgrats per liter and more importantly, the effect level of ocmsuners, such as minks and subhuman primates. ' . And I'd like, to introduce in the record at this time one correction that was made yesterday. I believe someone attributed the mink feeding studies that have gone on to the National Water Quality lab in JXlluth and this is an error. We haver--to my knowledge have not mink feeling studies, but the two major groups that are doing this are Bob Ringer at Michigan State University, working with the mink ranching and Platteneau at the University of Weltcn ' in Canada. Mow, concerning the ratimale far the water quality criteria farPCB's, it has been stressed that the rationale for water quality criteria for cumulative chsnicals, such as PCB's, consider the result of environmental monitoring programs in order that the ramifications of the criteria can be assessed. Data cn PCB's in the environment indicate that the large bioaceuaulatiom factors produce residues which are of primary importance. Far example, as has been discussed, Kebekcr has shcsai that .45 miexograms per liter of Aroclcr 1254 produced 50 percent reduction in midge reproduction; 1.3 micrograms per liter produced 50 percent reduction in Dephnia reproduction: 1.3 micrograms per liter produced 50 percent reduction in fathead minnows. DSFoe, in Appendix H that I'm including here has shewn that approximately 300 parts per trillion of Aroclor 1243 and Aroclcr 1260 were the highest concentrations not prcducting a discernible effect in the fathead minnows. And although the 300 ng or parts per trillion of PCB's is an approximate no effect level for these fish species studied, the residues acctnulated in these fish at that concentration Of the water was approximately 250 parto per million in the animal. Although the 300 parts per trillion did not produce a statistically significant chronic effect in the fish, the residues accumulating in this fish at this concentration would prohibit the use of this fish as a biological resource for humans due to the PDA action level of five mierograms per gram. Moreover, in this 14 and a half parts per million of body weight of Aroclcr 1254 in the diet of coho salmen have caused carplete mortality after--in 240-day feeding, studies, suggesting that the high residues in mall fish may endanger predator fish. Since FCB residues are an important--a more important consideration than direct effects on aquatic organisms, criteria are proposed by considering residues in relationship to the IDA tolerance level -of five mierograms per gram. In NWQL experiments, the residues in fathead minnows closed for 20 days at 300 parts per trillion were approximately 250 parts per million, to assure the five microgram per gram or parts per million residue is not surpassed, the concentration of PCB's in the water would have to be reduced 50 fold to approximately six parts per trillion in the water. That's case one. Case two, the mean concentration of PCB's in Lake Michigan coho salmon is approximately 15 parts per million and Ringer et al that I just alluded to, have shown that these residues cause carplete mortality in the mink. ."These data indicate that two mierograms----that these data indicate that two mierograms per gram of PCB's in coho salmon should be a maxisua concentration fed to mink. "She concentration of PCB's in the open late Michigan is estimated to be less than 10 parts per trillion and to obtain the residue tolerance proposed by the FDA for late Michigan fish, at least a three fold reduction, even if the levels are at ten parts per trillion, a three-fold reduction in the water to a mnximun of 3 ng per liter cr mere--3 ng per liter or more likely less than 3 ng per liter would be necessary for this reduction to the FDA limit. To attain an eight-fold reduction in the fish residues for mink feed, 1 ng per liter is likely to be the largest concentration possible if these fish are to be used far mink feed. Concentrations of PCB's in western late Superior has been estimated to be .8 of a ng per liter, with approximately 50 percent relative air. The mean concentration in Late Superior fish range cem below 1 microgram per liter to--in the smaller fish to 3 mierograms per liter. This is a mean concentration now in the larger trout, liwever, a larger trout presently contain --sana larger trout presently contain mace than five mierograms per liter. This suggests that increasing the water concentration to 2 or 3 ng per liter would therefore jeopardize the ccomereial marketability of the lake Michigan fish, if rot the entire ecosystem. Because of tisa mounting evidence, such as the above fwm bath field aid laboratory studies on bioconcentxatiens of PCB's and the adverse effects of PCB residues on the aquatic resource oonsucer, proposed water quality criteria for KB's is cm part per trillico. 58 NCR-FOX-0281452 WATER PCB-SD0000041090 SOMBER: Do you have a copy of that? MR. VETCH! Yes. EXAMINER: Cfcay, Does the Department have any questions? MR. KLEEERT: Dr. Veith, I'd like to ask a question about the fans of the KB's in the fish. The higher percentage chlorine Aroclcrs are carrtcnly found in the fish, the 1254 and the 1248. Yet we find in cur monitoring that a lot c the KB that we're identifying is 1242. Is there a selection in the retention in. the fish of the various kinds of PCB's? - . MR. VETCH: Hell, as I---there's probably two problems here that wa have to identify. One is that you have to be certain that ycu're analyzing the water that the fish spends most of his time in and then you can't be certain that the fish isn't going into harbors'. So that often times if Arcelor 1242, far example, is monitored in a river systan, you can't, you know, expect necessarily that you're going to find Arcelor 1242 as the predominant KB mixture in the receiving water, such as Green Bay cr lake Michigan dr the Great Lakes. . A seoend and more important consideration is there. la-- there does aeon to be a preferential or a higher hiiyiomwiilnticn of the more hirhly chlorinated .KB's and as.X indicated, the range for Arcelor 1242 up to Arcelor 1260 seems to La on the order of between 30,000--all of than fall in the range ci 30,000 to 250,000. And--so prat given equal quantities of these two etemicals in the water, you could expect to find twice as much Arcelor 1254 in. the fish as you could of the mare---the lower chlorinated compounds. And coupled with that is a canon practice of the cternist to dilure the extract in the fish analysis so that the major peaks are on scale . and what this does is it means that the smaller peaks, that maybe they're actually in greater quantities, are neglected, and the electronic capture response for a gas chromatograph increases very remarkably as you go up adding more, chlorines. It just makes it much mare sensitive so that. you can detect smaller quantities of Arcelor 1254 then yew can Arcelor 1242. And so that coupled with this--with the .Increased bioaccumulaticn and then the techniques of the chemist to scale to the biggest peak to quantitate, they essentially ignore peaks which are--look minor, but on a mass weight basis they definitely aren't. And it's, oarpletely inaccurate to say that the 2, 3 and 4 chlorine PCB's do not exist in lake Michigan. It's true that the predcaninant uuunuunds that are observed by gas Chromatography reeanbla Arcelor 1254, but we have presented evidence----GCMS analysis clearly shew that the di-, the tri- and the tetrachloro issuers axe there and so these conycwrids aren't mysteriously disappearing frm the environment. ' . ' . .. . . I naan that may be-an Incorrect statement. I can't really say that they are not disappearing, but at least they are present: they are not shewing vp in the larger lake systems. MR. KIBBQ29: Blank you. * SOMBER: can we obtain a copy of that? MR. VETCH: Yes, sir. ' ` EXAMINER: Okay. Blank you. Dees anyone else have questions of Mr. Veith? ' - Please approach the front and identify yourself. . MR. SCHRACCMAGEL: My name is Schraufnagel, Department of Natural Resources. X have a question----- .. EXAMINER: Speak into the mike, please. Shat way we can tvsar >*iat ycu're saying.. MR. SCHRABKnGEL: Hie question X have is X follow ycur reasoning on the one part per trillion, but is thebe any difference or variation for rare eutrephic waters, or waters that have mere sediment, for instance, the Mississippi River cr lake Winnebago. Do you think that would make ary difference on the magnification or the amount in the water that would accimulate in the fish? .. . MR. VETCH: Well, X guess X don't have my evidence to directly relate eutrcphic waters with the bioocmeentratien, but. there does seas to be, you know, 'wane evidence that the-- state -of eitrophicaticn of a body of water will effect, the KB concentration in the water. Xhat is, you'll have just a lot more organisms present to adsorb the material out of water. Bis bioaceumulatiai is in aU of the organises in the water. As to the availability and X guess the question to he raised would be the availability of adsorbed material or whether or not there's--"if you measure the total water sample, the ervaila- 59 . WHO05 96 L NCR-FOX-0281453 WATER PCB-SD0000041091 bility of all of the PCS'a present and I don't know that this Is a question to be considered, for sample In the lake Michigan, Lake Superior systems. However, in the river systems, as I nenticned, the Milwaukee River systm, and especially up above Estherbrcck Park has large masses of algae. In fact, they' usually get the algae hloaas in these reservoirs where these fish were taken &m and so I don't knew---I cannot say with any data that the presence of suspended material in the river does or does not affect the bioconcentraticn factors and this is a very hard thing to get a taring cn and I think it's the main reason for looking for field investigations that would help to verify the--help us to interpret the laboratory results that we're getting. MR. SCSMBENSGSLi Cue sere question and that is the range of reliability on your tests in water. How---with what results--accuracy of results can you get in tte one -tarillien ----one part per trillion range? . MR. VEHH: Hell, I think I indicated, certainly when you get down at that level, we have, I think, approximately a. SO percent relative air in the data. And the'waters, I think, can be routinely Treasured. This is----I'm speaking of lakes and same streams can be routinely measured---well, have been for five years, on---at approximately 10 part per trillion level, tut of course, well, Z believe I could perhaps defer that -question to a speaker later on who will dis cuss the analytical methods, but nty feeling would be that that is the option of a chemist, is to consider the sample that he's analyzing and do--use his discretion to came up with the--what he can say and what he can't say about the sample. mr. sasanFNRGELs shank ycu. BiSMIKER: Drank you, air. Does anyone else have questions? (Ho response) DffiMZKER: Okay. In that case we're going to take a five-minute recess so we can * arrange to copy of--the statement's that Mr. Schweitzer made. Dank you. (Recess) EXAMDSERs Okay. Cn the record. . He'll continue with the presentation by request and cn behalf of the Department of natural Resources and I'd like to request Mr. Fairless. Zs he present in the roan? Before this gentleman gives his presentation, we are getting copies of the state ment made by Mr. Schweitzer. If there aren't enough, we'll try to get acre and if that doesn't even work cut, we'll take the names and send copies of those who need them. Okay, sir. * MR. FAZRZESSt My naze is Billy Fairless. I'm deputy director of the Central Regional Laboratory, Region V, u.S. EPA, My statement will describe -the analytical procedures that the Central Regional laboratory Uses to perform routine monitoring analysis for BCB's and other pesticides. He collect one liter satrples in glass bottles with teflon lined screw caps. Die first portion of an extracting solvent is used to rinse cut the bottle and is ac&ed to a -two-liter separatory funnel with the bottles. Ore sanples are extracted twice with 100 milliliters of 15 percent volume by volute ethylether/hexane and once with hexane. Die extract is dried with sodium sulfate concentrated to shout five milliliters in a Kuderna-Danish evaporator. Die volume is then reduced to four milliliters using a stream of dry filtered air, H-nnt-nd to exactly four milliliters and split into two portions. Portion Z is spiked with phorate placed in a two mini liter vial, fitted with a screw cap and analyzed far phosphorus-containing pesticides. Die analysis is performed on a perkln-Elmer model 900 gas chromatograph using a flame-photometric detector in the phosphorus mode. Die instrunent is equipped with an automatic sanpler suggested for a 10 microliter injection and a Perkin-Elmer PIP 1 gas chromatographic data reduction system. He use a six foot by onefourth inch glass! column packed with 4 percent SE-30 and 6 percent OV-210 on 80 to 100 mesh gas chrcm Q fcr the original analysis and a foot by one-fourth inch glass oolizro pcVeri >iith 1.95 percent CV-17 and 1.5 percent OV-210 on gass chran Q 80 to 100 mesh far confirmation. Gas chromatograph conditions are as follows: the inlet temperature is 250 Centigrade, detector temperature is 240 degrees Centigrade. Die oven is programed fraa 200 degrees Centigrade to 265 degrees Centigrade at four degrees per msmte. Carrier gas is nitrogen at a flow rate of 60 milliliters a minute. Dsa seeemd peetim o the extract is placed cn a eolime of Florisil, with ana-half 60 WIMQ0597 NCR-SrOX-G281454 WATER PCB-SD0000041092 inch of oodium sulfate at the tap an! the bottom of the Florisil for drying purposes. 5X0 fractions are collected from the Flarisil. 5he first is with 200 milli liters of 6 percent ethyl ether in hexane and the second with 200 milliliters of 50 percent ethyl ether in hexane. Each of the fractions is concentrated to less than two milliliters in the same manner as used for the extract, diluted to exactly two milliliters with hexane, with Oieldrin, that's the 6 percent ether fraction, or Aldrin, that's the- 50 percent ether fraction and placed in a 2 milliliter vial with a septan cap for gas chromatographic analysis. . Each fraction frdn the Florisil colunn is analyzed using a Perkim-Ebrerncdel 3920 gas Chromatograph equipped with a two-colusn injector, splitter, automatic ampler with 10 micro liter syringe, two colusis leading to electron capture detectors. And the sane PEP-1 data reduction system is used. Colurhs are both 6 foot by a quarter inch.glass. One is packed with 4 percent SE-30 and 6 percent 07-210. 2he other with 1.95 percent 07-17 and 1.5 percent OT-210, both on 80 to 100 mesh gas chrcm Q. 5he oven terperatore is 205 degrees Centigrade; the carrier gas is 5 percent methane in argon for both coharns. .. A measured aliquot of each senile from the 6 percent.ether fraction which is thought to contain PCB's as based on the gas chromatogram we obtained from that fraction, is removed from the vial and placed onto a column of deactivated silicic acid. She first fraction is eluted with hexane, 45 milliliters and the second with 150 milliliters of 80 percent methylene chloride, 19 percent hexane, 1 percent acetonitrile. Each of these fractions is concentrated to less than two milliliters as previously described, diluted with hexane, spiked With Oieldrin ard placed in a vial for gas chromatographic analysis. The fractions are analyzed fear PCB's and pesticides on a Perkin-Elmer model 3920 dual-column electron capture detection system. A quality assurance program is maintained to measure the precision and accuracy of the results. 5he program includes scheduled calibration of all instruments used in the analysis to insure that they are working properly. 3t> monitor possible contamination of tte. samples while * they are being analyzed, reagent blanks axe run after each step of the analytical process, that's extraction, Florisil chraratography, solicic acid, chromatography and. gas chroratography. Seme sampl es are divided in half and. one fraction is. spiked with a known amount of the compound we're analyzing for. the recovery of the spike insures that there are no unusual chemicals in the sample that would interfere with the analysis. As a final check we analyze three standards with each grap of up to 35 sanples to insure that the total analysis achate is working properly. A procedure similar to this is being used by tee State of Wisconsin, the detection limit fee this procedure I've described is between .1 and .5 mierograms per liter of a specific PCS. Variable detection limit depends on the mount, of .other organic material in the sample. Mplicate analysis, of real sanples. run at different times in our laboratory, agree to within 10 or 15 percent at a concentration of 'approximately one microgram of PCB per liter of water sample. Xn a recent round-robin study in which sanples were sent to the six laboratories---state ' ' laboratories in Region V, that's Indiana, Illinois, Michigan, Minnesota, Wisconsin, the laboratories reported values between 0.82 and 2.2 micrograss per liter fear a sample that actually contained 1.5 miexograms per liter of Arochlor 1254. it's my opinion the chances of misidentifying a PCB using these procedures are negligible if the concentration is above 1 microgram per liter. As a final cchment, I Would note that we can include a chlorination step in the analytical procedure, which chemically charges all of the PCB's to decachlorobiphenyl, If this is done, we lose the. ability to identify the specific PCB's, such as Arodor 1254, 1251, or we can lower the detection limit to between 50 and 10 ng of PCB per liter sampled: Therefore, in summary, it appears that there is no particular problem with analyzing water samples for individual PCB's concentrations above .5 micrograms per liter, or for total PCB's at concentrations above .05 micro grams per liter. ' ' EXAMINER: shahk you, sir. Does the Department have any questions? . MR. lOEINEKr: Ho questions. EXAMINER: Do you have a copy of that presentation? Shank you. Are there any other questions. Shark you very much, six. . Mr. Francis Early. ' MR. EARLS': My nans is Francis Early. Z'a a physical scientist in tee Process Control Branch at the National Bhforwment Investigations Center of the .Environmental Protection Agency. I tm here today to address the prehlsa of reducing the discharge of polychlorinated bdphehyls to public waters. A problem of real concern at this time must be the relatively high discharge oanceateratioas shown certain and ap mills which ara dainking paper. ' 61 . 1OT005.98 NCR-FOX-0281455 WATER PCB-SD0000041093 VOICE: Speak up, please. HR. EARLY: Yes. from certain--a problem of real concern at this tine must be the relatively high discharge concentrations from certain pulp and paper mills which deink paper. For the record, let me briefly sketch the general process used for deinking paper. The deinking pulp producer buys wastepaper which is carefully selected for the end product which he intends to make from the deinked pulp. These papers are slurried in hot water with wetting agents or dispersants and art alkaline or acidic agent to adjust the pH. Other chemicals are used as required, toceslurried,. the paper, now undeinked pulp, is screened and cleaned to remove urdispersed materials, pieces of metal and grit. The actual delnteng usually takes place in a series of washers which are often operated in countercurrent process streams. The undeinked pulp enters the system of washers at one end while the clean water is introduced at the opposite end. The deinked pilp and the dirty water, in turn, are discharged at opposite ends. A primary objective of this process is to recover quality fiber, free fran ink, chemicals and pigments, as required by the needs of the end product paper, one or more stages of bleaching may also be used. ' ' Where do PCB's enter this process? In the wastepaper Which is the raw material for the process. They are discharged with the dirty water because they are essentially associated with and attached to the pigments and are rsmcved during the deinking process, having removed the un desired material, which includes KB's in this case, with water, the processor now is faced with a problem of removing the KB's frcm the water before discharge, or recycling the water to their process. These waters can be given primary and secondary treatment in order to meet the require ments of the NPEES permit program, which require dose control of biologic oxygen demetxi and suspemod solids, along with other requirements. We note here that ttere is extensive literature cn the presence of PCB's in water and their introduction into the food chain. However, few of these--little of this literature " addresses how the KB is present in the water. Dr. Peter Schccr of the Gulf Breeze Enviromental Research laboratory, in an article which will seen be published in September or October this year, in Higland in the international journal. Water Research, has demonstrated that Arcelor 1254 is soluble in water at concentrations of less than .1 part per billion. What this means is that ary of the material present in water in greater amounts than this must be either in the form of attach ments to suspended solids or in the form of an emulsion stabilized by a surface active agent. Since only a snail portion of the total amount of FOB material can be in true solution, the limiting--true solution states limiting the discharge of these materials can be enhanced by improved suspended solids removal and effective secondary treatment for the removal of cocygen^ocnstising materials. The effect of improved suspended material removal an PCS discharge is intuitively evident, since a significant portico of KB is undoubtedly attached to the suspended particles, because all PCB's are extremely lyophchic in water and therefore have a strong tendency to coalesce with other materials of like nature and to adhere to iycphofic sites cn suspended particles. The reduction of PCB's to he gained by secondary treatment needs a little mere explanation since colloidally dispersed KB tot renewed by an effective primary treatment probably is stabilized by a surfactant; it shculd be very sensitive to biologic treatment. Its expand, the dispersant cr surfactant which is sabilizing the PCB particle must be biodegradable, since natural surfactants are' biodegradable and by national policy, all ocncercial surfactants must be. Since the surfactant'"--once the surfactant has been degraded far enough to destroy its ability to emulsify and stabilize PCB particles, the KB removal problem or solution becomes the same as in the primary treatment except the suspended material that will carry tte PCB will be the biomass, which in the secondary clarifier or stilling basin will cany down the PCS. This fact is confirmed by recent data frcm California, which show PCB sludge magnification factors of up to 9--of about 9 to 1. Although PCB's may' have been ingested by the organism of the bionass, it is likely that it is just carried down as with the biemasa. In either case, it will be effectively removed from the water with the secondary sludge. In conclusion, I think we can say that although PCB discharges fran these deinking paper mills now tend to be rather high, we can leek forward to significant reductions in discharge concentrations as the programmed and projected treatment systems required by tie NPDES program become effectively operational. Thank you. EXAMINERS Thank you. So you haws a oepy of yoar report? m. S3MXt Yes, 1 do. 62 NC R- FOX-0281456 WATER PCB-SD0000041094 EXAMINER: Any questions? Co you have any questions? MR. KIEINSEE: Mr. Early, frcra your gjimants, it's your belief that the removal of suspended solids or the effective removal, of suspended solids will tad to effectively the JPCB'sj is that ooxrect? .. ' . '. MR. SARIS: Yes, remove a particn. I'm not sure howimah. . MR. XLeINKki's Hie other factor involved in addition to raxwing tte suspended solids is the second part of the--- MR. EARLY: That is correct. She biologic treatment system--an effective biologic treatment system. ' .. ' ' EXAMIKER: Those questions were put to Mr. Early by Stan KLednert, Departsont of Katural Resources. Coes anyone else wish to have questions of Mr. Early? (No response) EXAMINER: In that case, thank you very such, sir. . That's it far the ERA, isn't it? MR. KLEBERT: Yes. . BfflMINER: Okay. In that ease, the presentation by the Deportment of Natural Resources, with the aid of various other agencies and industries is concluded. Ws will now ocn- ' . tinua with public content by various parties who have attended this hearing fer that purpose. I'd like to first call on Mr. Dennis Bessenecker, Dow Corning Corporation. . - MR. EESSEHECKER: Yes,.sy nane is Dennis Bessenecker fran Dow Coming. I'd like to enter this statement for the record relative to the use of Pew. Coming 2-1090, dielectric liquid as a replacement for KB's in power tranfonaers. . Q2-1090, dielectric liquid is Dew Coming's version of a polyrtlmethlailoxane fluid qualified for use in electrical applications. The technical feasibility of using silicones in transformers has been shewn by over 20 years o:experience in military speciality transformers and several years of use an the Japanese National Railway and use in a lumber of .power transformers in the. Midland; Michigan, area. In addition to these actual applications, export for tie use of sili cones is contained in over 30 years of accumulated data on dielectric properties, and ccrrpatibility with materials of construction. Concern tor tire, explosion, health'and environmental hazards strengthens the rationale for using silicones. - Silicone liquids of the type advocated for this application are such less flammable than typical tranformer.mineral oils and. actually have a higher flash point than many PCB containing transformer liquids. And although these silicone liquids will bum, they have a relatively low heat of combustion, a high flash point and fixe points and have been, shewn to be self-extinguishing in static pan type bum tests. They appear to offer a level of fife safety greatly superior to min eral oils and oily less--slightly less than PCB based liquids. The sillcam liquid suggested for use in transfanners has been evaluated by Underwriter's laboratory and has received a flaunability classification lumber. . Simulated transformer explosions involving a PCB based liquid, a silicone i tgirtd and. a mineral oil showed that only the mineral oil. continued to bum after the explosion. There was no fire with either the PCB or the silicone. ... following a review of the extensive data, several insurance ccepanies have given their permission to pursue the use of silicone liquids in transformers used by their customers. Because no general policy has been established to date, insurers hove tivHr-m-n* that they will evaluate each application on an individual basis. '. " Silicones; often used in small concentrations in the preparation, of certain foods, have a very lew level of toxicity. The toxicity to mamnals and aquatic life and plants have been investigated and.continue; to do so. The esctranely low toxicity of silicones make it difficult to detect toxic reactions in the test subject; Studies directed towards determining the tendency for silicones to bioocncentrate have been: negative. It was hot possible to shew that faioaccuaulaticn was souring. 63 WTM00600 NCR-FOX-0281457 WATER PCB-SD0000041095 It has. often been stated that sillcones are persistent because they do not biodegrade. Although no evidence of biodegradabi 1 ity has been shown, silicones do degrade in the envixorecent. Contact with soils and water causes the liquid to rapidly depolymerize to volati-ve species. Once airborne, these materials are checucally degraded in the presence of ultraviolet light. Known chem istry also suggests the possibility of chemical degradation in water. Hie present listed price of silicone fluid is approximately twice the price of PCS ) igiilr3 and I'd like to make a comment on that after I conclude, however, the price differential would be expected to decrease as the volute of silicone fluid used increases. Hie cost of monitoring, controlling, spill cleanups, the potential--possible liabilities and disposal should be such less for silicones. Urns, in the long term, the total cost of using silicones would probably not be greatly different frcm the total cost of using PCB's. . And the eminent Z would like to make is the fact that we are on a' program right now of caimercializing the silicone fluids; it is available. Kith cur rebate program in our efforts to accumulate and extend our data bank or let's' say, service life data, we are offering a rebate system and with the rebate below the liBted price of Biiiocne fluids, we are very close to PCB's at the present time. EXAMINER: Do you have a copy of your statement, sir? MR. EESSEKECKER: I have a number of copies. EXAMINER: ckay. Just leave one for me. I think you can leave the rest there. Thank you very much. Is Groff Collett present? Please step up fee a statement. ' ' Ckay. Please identify yourself before you make your statement. MR. oaiJJTT: Yes. My name is Groff Collett. I'm general manager of Paperboard Products far Consolidated Papers of Wisconsin Rapids, Wisconsin. - This is the recycling area of our business, in which ws procure used or waste paper and recycle it to make paperboard. This recycled paperboard is ultimately converted into such items as folding cartons, paper ceres end cans, and various laminated paperboard products. He have one machine rnanufsennring paperboard and this machine supports the employment of approximately 340 people in central Wisconsin. Annually we consume or recycle about 33,000 tons of post consumer waste, keeping it frem the solid waste stream The payroll for this operation was $4.6 million in 1974 and federal, state and local hm amounted to about $1.3 million. -- . He share your concern with our cnrirciment and have rfade substantial effort to prevent any of our operations frtm having a deleterious effect vpon society in general. has invested more than $40 mi llion in environmental improvement programs; we anticipate capital and operating expenditures far environmental control will amount to $26 million for the three^near period, 1975 to 1977. We also feel strongly the responsibilities we have-to cur srployees far maintaining stability of employment, as well as providing a fair and reasonable return to cur shareholders. He believe the EOT. is serving its intended purpose when calling possible hazards to the attention of the public and to the attention of those who have control over the processes vhich are believed to be responsible for this potential problem. He very frankly do not knew at the Bccmnt the extent to which our operations are a source of ECB discharges to the state's waterways. Excuse ne. He are aware that certain types of waste fiber containing PCB's and essentially all the normal grides of reclaimed fiber which we use at Consolidated could possess extremely snail arownts of PCB's. Since we have rot been engaged in the production of paperboard for direct contact with food, we have rot been making routine analyses of the PCS input into our process. It is only within the last few months that we've been made aware of ary potential danger to the state's waterways as a result of our recycling operations. When this was first called to our attention, primarily through the press aid I'd like to digress from cur prepared etatanent far just a rament and say that this fact that we got our information originally primarily through the press, is a matter of same concern to me. I thought that we had established the long recced of a willingness---shewing a willingness to vjerk with the CNR on all problems related to our envircroent. As we have done, we've shewn a willingness to work with such government agencies as the state recycling authority. And our industry has worked with the FDA in establishing information on PCB's in foed board. Unfortunately, the first contact we had with the ENR on this whole matter is when we got notice that they were considering regulations that have the threat of putting us out of business, let me go back to ay prepared, statement. ' 64 ^r&ooeoi NCR-FOX-0281458 WATER PCB-SD0000041096 When this was first.called to our attention, primarily through tte press, we . ismediately attainted to make Erne deteminatlcns. Unfortunately, our hasty effort was largely fruitless since our saddling tpchnigups and new appear to have' been less' than representative of actual conditions. He truth is that we--we sent sarples to an outside agency' for analysis? they came back and they reported that it wasn't detectable at their level of one part per nriiHm and ws threw up cur hands and said that was inadequate. The state's talking about five parts per faillieo, not parts per million. And new we're starting all over again. f&ile our report states that cur effluent did not contain measurable quantities of PCB's, a review of our techniques has convinced me that they are inadequate. So we have now embarked on another testing program which we believe will be much, tore meaningful. Hiis program is going to cost us thousands and thousands of dollars and unfortunately, we are not at all sure of what the results will mean when they are cuipleted. I say this because vie are testing only the influent and effluent to cur paperboard machine, which is the only machine in pur company utilizing waste fiber,-which is the reported source of PCB's. If ue deteet the presence of PCB's, wa then have to determine the effect of cur 7.9 mill inn dollar treatment plant txw tinier cehstructicn m il have en this effluent. # , Given this situation, what are the alternative courses of action which .are available to cur oaipany. You understand we have very fw facts and Z really doubt that there is anyone in this country who can claim to have enough facts on this matter to. know the best coarse of action for a single company, state or the entire country. Hiere are only a few things we know with reason able certainty, cne of these is that the PCB's are present in snail quantities in most of the normal grades of wastepaper or reclaimed. fiber. In sane oases, the presence is probably so small as to he meaningless. They are reported to degrade very slowly. To the best of rry knowledge, there is.no practical way of ranoving them fraa our environment unless they can te collected art incinerated at very high teuperatures. second fact is that we have been in the recycling business in central Wisconsin since 1917 and had hoped to rerain in profitable operation for many years to cane. If we are banned frem discharging any PCB's at all with our present technology, we would have to back away from the use of wastepaper. Up until new, v have been encouraged under national .envirornental goals and yes, under Wisconsin goals as well, to support `reclamation programs for the recovery of these waste fibers and recycling than into paperboard. .' . 'If the EKR bens all discharge of PCT's, we have one of several alternatives. Ws could consider switching to virgin fiber. Ws firmly believe that the cost of this switch in central Wisconsin would be prohibitive and it is not an eecnemically supportable alternative. . Hie second alternative'is attempt to be mcsre selective in our reclaimed fiber procurement and I believe this could achieve sane reductions in the PCB's we take into cur process through the use of. wastepaper. Cur research personnel, tell us that the ocnplete elimination of PCB's by this method is inpossible and a substantial reduction would be an extreuely costly and probably unreliable procedure. '' Kith a zero discharge requirement, I quite frankly see absolutely no way ve aould continue to reclaim waste fibers. . Then kb ask what rate could ws achieve? Honestly, I do not know. At the nrant, the five parts per billion level sounds so dose to aero that I faelieve.it Would have tie seme impact. Hie whole subject matter is much too new to even have a meaningful opinicn on ths subject. Another alternative is to consider various treatment processes on the PCB's which might be present in cur effluent. We are willing and even anxious to do this and will start with ths carpi sHm of cur treatment facility previously mentioned. X realize that there can be many errors in' tee- thoughts I have set forth here. But I believe that they are henest and logical thoughts based on the iaformaticn presently available to me. lime will probably do a good jdb: of pointing out the errors and I guess that is the 1 cnly point. I can make with you today. Hasty action that leads to Unrealistic levels of PCB dis charges could have a very, adverse iapect on our recycling operations and on the eoenaty of central Wisconsin. It would undeubetdly faring ours to a halt and put 340 people out of work. This might be the result, even though the effect cm the presence of PCB's in our environaeht could be nil. I urge yoi,. therefore, to take the time and sake the effort to study ths serious impact of these preposed--these proposed regulations will have upon our eococay and the conservation of our natural resources. -- m waleeaa the input you make to cur technical understanding of the problem and m would be glad to cooperate in your studies and the evaluation of alternatives which are available to us in crier to protect out envircanent. ' .' 65 WTH0G602 NCR-FOX-0281459 WATER PCB-SD0000041097  Thank you. EXAKIKER: Go ycu have a ccpy of your statanent? Thank you. I appreciate your appearance. Mr. W. Allen Schenck. Present? Please Identify yourself and proceed. MR. SCBEN2K: My name is Allen Schenck. I'm vice president, technical and environmental, far Ker-asha Corporation, Neenah, Wisconsin. ` I'm speaking for the John Strange Paperboard Division of Menasha-Corporation. This paperboard. mill manufactures combination boxboard fran recycled paper and has done so for over 25 years. Two hundred and fifty people are employed at **< location. The annual payroll is $3 million. '- Up to January 1, 1975, John Strange had invested $400,000 in water and air inpruvanent. Che million, one hundred thousand dollars will he spent in 1975. Ttese expendi tures are a high percentage of the net worth of the mill. The plant is in with all environmental orders. Approximately 75,000 tens of paperboard are produced annually. The principal products are tube ana can stock, carton, stock, chipboard and cylingaar specialties. These products are, and historically have been made fran 100 percent recycled filer. The present grades of recycled fibers used are 50,000 tons of old corrugated, 25,000 tons of mixed paper, 8,000 tens of news. These products are purchased principally through recycled fiber dealers. ' MO PCB's are used in the manufacture of cartoinaticn box board. Ttere are no knewn- PCB's in electrical or hydraulic equipment in the mill. Of the total annual product at John Strange, about 20 percent is utilized in food packaging. Cenbinaticn boxboard for food packaging is made fran recycled fibers sleeted to minimize PCB's. Board which exceeds ten parts per million, the PCB is diverted to nonfood end uses. , Ten parts per million is the Interim level set by' the Food and Drug Administration far food packaging materials. Experience in the manufacture of these grades has demonstrate! that in the course of 24-heur run or. longer, peaks of PCB's above ten parts per million can occur. However, the frequency and intensity of these peaks has decreased dramatically since 1971, uten PCB's stepped entering the vastepaper use and reuse cycle. This trend is industrywide. Data collected fran the majority of canbinaticn boxboard mills in the United States shows the following: in 1971 87,percent of the board made met the FDA limit of ten parts peritallicn. In 1972, this had increased to 94 percent. In the last half of 1974, It was 98.5 percent. In the first half of 1975, it was 99. 5 percent. * The data far 1974 and 1975- each represent over 2,000 analyses. They were collected from 70 percent of the canbinaticn bexboard mills in the United States as part of a quality--co operative quality.assurance program with the Food and Drug Administration. The data is submitted to demtestrate that PCB levels are decreasing rapidly. It should again be pointed out the recycled fiber utilized in the manufacture of these boards was selected- to minimize the presence of PCB's. There is no practical method to select PCB free' paper in bale form. Tin. selection I speak of is based an the grade and the source of the wastepaper and cannot be foolproof. He have no definitive test data on the PCB ebnoentratien in our effluent. As a result, we do not knew the distribution of PCB between the outgoing paper and the outgoing effluent. If the conservative asswpticn is made that' the finished board has two parts per million of PCB, that 80 percent of the PCB in the raw materials stays in the paper, that 20 percent goes cut in the effluent and that the effluent amounts to 3,000 gallons per ton of paper. The concentration of PCB in the effluent would be. 40 parte per billion, it appears that a maxinun pemsissible level of five parts per billion could not be maintained with available recycled fibers. John Strange Paperboard could go to virgin fibers, but they most certainly would not stay corpetitive with combination boxboard mills in other states. If this operation was discontinued, it would mean the loss of the jobs end the loss of the payroll outlined at the start of ny statement. This would also mean that 85,000 tons of wastepaper would have to be disposed of by means such as landfill or incineration. There are undoubtedly other sources of PCB, but the current level of PCB's in re cycled paperboard result from actions securing prior to 1971. This source of P has been dis continued. The level of KB is expected to decline and. the broad base data presented supports this. He cannot excape the fact that PCB's are in the recycled paper system and they cannot be legislated away. They are, however, declining rapidly. 6 WTM00603 NCR-FOX-0281460 WATER PCB-SD0000041098 Xt is requested that the proposed, rulings cot he implemented, xt is reguested that the State of Wisconsin, through Department of Natural Resources, devise, a practical method of monitoring PCB's to be certain that the downward trend continues as expected. Blank you. EGWONER: Blank you very much. Could you provide a copy of that at your convenience. HR. SCHENCK: --I'll get it retyped. > ' E3KB3ER: Blank you very such, sir. Milton Teaman. . . '. MR. lOWfU: My name is Milton lonnan, president of loiman Iron and Metal Ccapany, established in 1913. Our business is a scrap processor of ferrous, nmfezrcus arid fiber scrap. In laymen's terms it's scrap iron, scrap metals, such as Popper, brass,, aluminum,-zinc, lead, and scrap newspaper, cardboard , ledger grades, sane of then called the sulfite grades. We plcy 65 to SO people. Our payroll is $622,379 per year. Our state and local taxes only last year were $53,294. Any material we process, particularly wastepaper, reduces the amount of land required for the inrrifni use. Bie statistics that Z have show that 60 percent, of the solid waste in the landfills is composed of paper fiber. . Bie conclusion X hope that you.draw is that we are today the largest conservationist, ecologist and/or environmentalists. . Because of the nature of this hearing, X will dwell on the wastepaper aspect. Besides our present plaint in Feet Atkinson, by means of industrial revenue bonds,: we are building a half a million dollar plant for the recycling of wastepaper in Janesville, Wisconsin, i Aside from this _ prepared text, it's frightening to knew that I'm going--a3 an entrepreneur, putting this much, money in an investment and it may not work. X mean, it could possibly be cut out. So X have--very apprehensive at this point. But this plant, as well as our present plant, purchases newspapers via paper drives, cardboard, tab cards, ledger grades, which is either old or hew, business forms of any kind, frtm qarcnercxal establishments, industrial plants, banks and printing oaqahiea. This material- is sorted by hand into specific grades of wastepaper to-be shipped to the paper mills. Bae following are grades of paper segregated and haled by the paper stock dealers to be shipped to paper mills. X've listed sate of these just to make you aware that it's just not wastepaper. There's specific grades. Bose's no. 2 mixed paper, no. 1 mixed paper, super mixed paper, boxboard cuttings, ho. 1 news, overissue newa----I'll skip saae. of' these i..oat into ..possibly the ones that would her well, in the mixed paper, it's very easy that somebody threw away a federal form that's got tte PCB in it. In the ledger grades it might be in sane industrial plant that has seme old'records. But to our--so I'm just trying to give you acme of tbe.grades fnt've have. . Bore's also 46 grades of wastepaper from our bade association and national association recycling industries. They're all listed here to give you an idea of what the grades of paper are aid tte specifications. The ones that--and other grades that would be affected here could be the-- what we ix no. 1 sorted colored ledger, manifold ledgers, and. *o forth. The effect of no PCB discharge to us, a. scrap processor, is related to what the paper milXa will purchase. In the area of the- high grade papers that cone from the banks, industrial plants, it is possible we will not be able to ship this paper to the mills if they, are curtailed in their purchases. That does that mean? As. you go down the line the alternative would be to take the to- the' landfill' and we would chaise these institutions. ' erne thing I would like to point out very emphatically, the scrap processor pays for everything when the economics are there. They pay people far it, which helps circulate money. At present, our customers are paid far what we pick up. Total restriction of PCB. would affect the economics of our easterners arid cur operations. . At present we have no means of identifying PCB type of carbonless paper frem other carbonless grades of paper. If there is a means of identifying the chemical, we do raise this ques tion, can we sort it out economically? Again, if we cannot, it will, go to the dump. Pardon me, the landfill. ' Xt appears to me if we cannot process the material, it ends tq? in the landfills, Biat PCB will still end up in. the water table or our enviroraneht. PCS was banned from the use in carbon less paper a few years. The amount in the wastepaper should be considerably reduced. I'm speak ing as a layman, not as a technical person and l found this in other, grades of sera? that we have ty.n,iiari throughout the years. Mien it's stepped at the scusce, it eventually just dwindles. My feme is that X have an ex&qple of a 100-ton -oould be atheusards of tens of paper. It could be because sewewhera there was 10 pounds dr 100 pounds Of carbonless paper, X don't know the ehaaistry of the specific PCB. I'm not mentioning pure PCB. But just think of it, maybe 50 pounds of carbonless paper- and say 100 dr 1,000 (sens of paper. Xf it's possibly there, we'd have to threw it in a landfill. 67 TTOi0O6O4 N C R-FOX-0281461 WATER PCB-SD0000041099 The paper recycling industry has had enouefc problems. This is the first we've had anything that really involves the environnent. Ke've hod unfair freight rates, unfair tar advantages ccnpared to paper mills who do not use wastepaper; if you'll pardon the expression now, harrasscent by the DNR in attenuating to license us. We're in court on this issue right how and sales tax discrimination resulting in a Supreme Court case. The confusion that I'm trying to shew you is that we are supposed to be the greatest ecologists and conservationists, we have the public backing. We have the legislative hacking. But we're constantly having problems with the---shall we say the bureaucrats in our state. . I'm aware of the danger of FCB's. In ny views, I express the effects on our industry. I feel the ansvrer is in the control by a realistic percentage than a total ban. At this point in history I feel the dye is cast. There cannot be a total ban. It will end up--that is, feint the wastepaper point of view, it will end up in our environment whether it goes through the paper mill or the landfill. -. EXAMINER: Do you have a copy of that presentation, sir? . MS. LCSMANs I just gave it to you. EXAMINER: Ch, Okay. Attorney Bach, as I understand, you went to make a motion and a swtmary? MR. BACH: My name is Attorney Donald L. Bach and I represent the Wisconsin Paper Council, the trade association for the pulp and paper industry in Wisconsin. Mr. Examiner, far the recced and because of the extreme complexity of the issue, we would like to formally move the tribunal to grant a 30-day period following the furnishing of transcripts in which written briefs and ccmrents could be made. EXAMINER: That motion will be taken into consideration and the determination made price to the closing this morning. MR. BACH: Thank you, Mr. Examiner. - Cn hehalf of the Wisconsin Paper Council, I'd like to sunmrize the key points in the testimony and positions offered by council members over the past two days. One, we recognize that there is a potential problem with the introduction of PCB'a into the environment. . Two, the peeper industry has not created this prcblcnw The paper industry does not use PCB's in its processes and the paper industry finds itself caught in tie middle of this controversy merely because of its recycling effects which would be halted by the adoption of the proposed rules. Three, the proposed regulations place an incredible burden on cur industry, requiring removal of KB's to levels one thousand times mailer than the Mood and Drug Administra tion's tenporary tolerances as applied to food board. Four, our industry has a history of cooperation with government agencies to reduce . PCS levels in our finished products. We will continue to cooperate with the Food and Drug Administration and with the CNR to find solutions to the FCB problem. Five, we strongly support strict controls on the manufacture, distribution and use of KS's and we favor a national, ban on the importation of PCB's. Thank you. . ' SMOKER: Thank you, sir. . Before we continue with further public oauaent, does anybody wish to eminent or speak to the motion made before this hearing today? Being the 3D-day comment period requested after availability of the transcript? (Mo response) EXAMINER: Ho. Richard Manfehe. would you wish to make a sfca-teaeBfc at thia time? MR. KMfHE: (Inaudible) 68 WTM00605 ' NCR-FOX-0281462 WATER PCB-SD0000041100 ESSONER: CAay. Thank you. Mr. Manthe will subaLt a varitten statement. I* Mr. Edward Titncn present? . Xs there anyone else present at this tire that wishes to sake an oral statement? VOICE: Z have a question on the transcript. Hew and when would they be made available and has that been decided? . . SSRMINER: Ckay. The question vent to the availability of the transcript. X think before going further we'll take between five and ten-minute recess to consult with the recorder. The hearing is closed for five minutest .. - . (Recess) . EXSMZNER: ladies and gentlemen, please be seated and we'll continue with the hearing. Okay, ladies and gentlemen, the action of the Wisconsin Paper Council regarding cements has been considered. The determination is that the eminent period, will be extended from today's date through 30 days after availability of the transcript, or November first, whichever is earlier. It appears at the present time the transcript may be available by the 20th of September. All parties filling out an appearance slip will be notified by letter as to availability of the transcript and the cost. There also--at least my recanrendation will be limited availability to the public of the transcript in at least tbe six district offices of the Department and the Madison office so that the public may view the transcript without cost. The district offices are located in Spccner, Wis consin, Bhirelander. Green Bay, ia Crosse, Eau Claire, Milwaukee. day. Mr. John Troglia. xs he present? MS. TROGLIA: My name is JohnW. Troglia and X am chief station engineer far the Wisconsin Electric Power Capary. X am a graduate of the University with a Bachelor of Science. Degree in Electrical Engineering. I'm a registered professional engineer in the State of Wisconsin. I've been employed by the Wisconsin Electric Power Company far approximately 15 years, during which period X have served as substation design engineer,, generation and trans mission planning engineer and'project engineer responsible for distribution of substation, design. In my present position, I'm responsible..for the' design of transmission stations, bulk power substations and power plant switchyards on the Wisconsin Electric Power Company System. I'm an alternate member of the National Electrical code committee Panel #13, which is responsible far those code articles dealing with.transformers, capacitors, resistors, reactors, transformer vaults and equipment and systems of over 600 volts ih general. I'm a member of the unit Substation Subcommittee of the A1E2 High Voltage Apparatus Committee and a marker of the HXE. ' My testimony today is in behalf of the Wisconsin Electric Power Cenpany and the Wisconsin Public Service Corporation. X would like to state at the outset that the- operations of the Wisconsin Electric Power cenpany and the Wisconsin public Service Corporation do not appear to be greatly affected by either of the two proposed rules regarding the discharge of fob's into the waters of the . State of Wisconsin. Our only use of PCS material is in capacitors and transformers which are cloned electrical systems. However,' other industries in Wisconsin are greatly affected and the above remarks should not be construed as diminishing their problems. Our presentation today is concerned with submitting information to the Department of Natural Resources regrading current uses of PCB's by the electric utility industry, Wisconsin Electrie Power Cenpany and Wisconsin Public Service Corporation. We understand that a Monsanto Corporation representative, among others, will present material concerning the technical,. . mcccfimic and scientific aspects of FCB manufacture and usages so wa will not address those areas. Tte best statement of the. history of FCB's in the electric industry, including benefits, risks and alternatives is contained in Chapter 2 of the American National Standard institute Guidelines for Handling and Disposal of Capacitor and Transformer Askarels Containing Polychlorinated Bipianyls, C107.1-1974, a portion of which X should like to read into the record at this time. Chapter 2.5 was Interdepartmental Task Fossa on PCB'a, An in depth study of PCB's las recently been ccnpleted by five executive branch departments of the federal government. Bis . 69 WTM00606 NCR-FOX-0281463 WATER_PCB-SD0000041101 Interdepartmental gunk Force on PCB's issued their report entitled Polychlorinated Biphenyls and the Environnent in May, 1372. The following cone)union is quoted fccm pegs 4 of this repeat. The use of PCB'a should not he banned entirely. Their corrtinved use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fixe and explosion and the disruption of electrical service which would result from a ban on PCS use. Also, continued.use of PCB's in transformers and capacitors presents a minimal risk of environmental contaminatim. The Monsanto Cenpany, the sole domestic producer, has reported voluntarily eliminating its distribution of PCB's to all except manufacturers of electrical trans formers and capacitors, unquote. He should also lika to subsit a copy of the entire ANSI Guidelines fear the record. The only use made of PCS material by Wisconsin Electric Power Ccnpany and Wisconsin Public Service Corporation is in closed, in other words, sealed electrical systems, such as transformers and capacitors. Handling procedures have been adopted by both catpanies that prTlil the ANSI Guidelines. However, pursuant to the July 9, 1975 letter from Mr. Brooks Becker, director of the Bureau of Mr Pollution Control and Solid Waste Management of the Wisconsin Depart ment of Natural Resources, to all Wisconsin electric utilities, Wisconsin Electric Power Cazpany Bade. Farce has been established to reevaluate KEPCO policies vis-a-vis the recanaendatiaw in that letter. Company policy is now being revised to insure that in the future scrapped transformers ard capacitors will be sent to approved disposal centers, which are all outside of Wisconsin. Wisconsin Public Service Corporation also initiated positive controls on the disposal of PCS cn June 22, 1972. Since that date, all scrap capacitors and transformers containing PCB have been collected and stored centrally, pending disposal in accordance with reocumended guidelines. It should be noted that the recommendations in Mr. Becker's letter were basically to follow the ANSI guidelines. In sunnary, it would seen apparent that the CNR is well aware of the voluntary efforts of iidustry to guard against the potential dangers of PCB materials. We have outlined in brief the history of PCB's including the benefits, risks and alternatives. There are compelling reasons, both technical and eooremic, for the continued use of these materials. EXAMINER: Thank you very such, six. . Is there anyone else at this time who wishes to make a public statement? Mr. Xilscn, are you ready to make a statement at this time? HR. TILSCN: (Inaudible) EXAMINER: Ckay. Let's recess for five minutes. ( (Recess) EXAMINER: Ckay ladies and gentlemen, back on the record and there'll be an oral presentation with slides by Mr. Tilson. -- statement. Mr. Tilson, please identify yourself, who you represent and present your MR. TILSCH: Ckay. Ckay. My name is Ed .Tilson and as I say, cty PE license is pealing review. I'm today I'm representing Gcmnittee to Expose Carcinogen Coverup and the there is with Center for Public Representation. This--I may not be too articulate because X really didn't quite have things together. I was taping over lurgh to put things in a more finished farm and I won't be reading frem anything. During the presentations we heard leading up to this, a lot of material was brought out in the record that I've more or less been researching and becanlrig aware of myself previously. And i've been very intrigued with the' work of Dr. Allen because you see there 1 think a major envircauental---well, it's actually a public health problem. This is one thing 1 want to say that thi is not, X don't think, an errvixomental problem so such as it is a public health problem and I think that the handling of this matter, polychlorinated biphenyls, points 19 that public hmith has actually been senewhat slighted as a process of the past few years, because there have been a lot of Departmental mergers cn the federal and state level in which public health has largely been thrown into environmental agencies and in that sense,' there has not been sufficient awareness of the problems that can develop into major public health problems--major public health--you'd almost call it catastopbe, although I've seen that word sort of misused during the hearing. 70 WTM00607 N C R~FOX-0281464 WATER PCB-SD0000041102 . As a result of ny cwn experiences In working in the environmental field as an engineer and seeing that most engineers gravitate toward administration, I've been kind of disappointed at the way in which engineers approach these kinds of situations and.I've been more positively impressed in the way biologists approach them. In other voids, I've' gotten the feeling that engineers working for biologists are a better team than biologists working for engineers. And I think the basic reason, for this is that engineers tend to think in terms of things, in terns of quantities, in terms of getting something done, producing results. And I think that that's not the kind of approach you're going to want when you're dealing with things that can lead to public health peohUms, . I think this is pretty well pointed 19 in 1st Corinthians, in which the quota is that "God hath chosen the foolish things of the world to confound the wise and God hath chosen the weak things of the world to confound the things which are mighty." And all life is really fcurded on a chain which evolves from very simple unicellular organists and the Various toxins which were put into the environment can effect then and can effect the entire life chain. And X think this is a thing which we're seeing with PGB's, because even though the quantities are very stall, around the limits of detection, this--this, is part of the problem that there's extensive bieeoncen- txaticn of these to levels wherein fish---they're approaching--they're approaching levels that could probably, in years to cote, induce liver cancer, stomach cancer, birth defects, reproductive malfunctions, and the concentrations are in the fatty tissues, which slows up in very high concentra tions in the liver and also in the brain. '' . Ifce brain is a very, carplesc thing, the---they- --esoteric neural pathways. I do think there, is a problem here no natter hew much certain industries tty to. play this down by presenting what they feel is eooncmie catastrophe fear them, when in actual fact, I don't think that's the I have sane maps iq> here in which I point up sene of the---the sources Of ICB's. . I don't know where Monsanto's plant is located, but, of course, they've presented themself previously. X tend to have a feeling on this that transformers tend to be a fairly conservative use of this material frem which it's reasonably difficult fcr.it to get into the environment. I think a very high priority should be placed on developing a substitute and there are reports that substitutes do exist. Obis was what people on the Natural resources Board have said. Item that standpoint, I'd like to see this replaced, even in transformers, but in the meantime, the critical thing probably becomes to limit inparta, given that many of these corporations are said to not be following Monsanto' s self-regulation. Nonetheless, transformers--they were a target, for instance, when I was at Standford during the radical unrest. The transformers were shot 19 a lot and, of course, whatever was in teem leaked out. So, I mean,, that's always something to be considered that even what you consider as conservative is not always conservative use of materials. ' Owe industry that I'm essentially concerned with is tee paper industry and this is not because I feel that the paper industry or the specific sector of it which deals with deinked paper and carbonless copy paper is not making an effort to dean up, but I think there's an inherited problem frem past years and I'll eeme back to this later, but people at DNR on the technical level, the lower level professionals, have tried to call attention to this. And yet what has cone out of there has hot really cnllhd attention to this and I'd like to return to that later. Hie--I----the sources which are a problem with this are Mud Paper Ccnpeny in Merrill and then there's National Cash Register subsidiary, which I understand is at Portage. Appleton Paper is a subsidiary of National Cash Register. I'll paint to these on the map over here. maps are? EffiMMERt Before you go any further, Me. Tiladn, would you please state what the MR. TIISCNs Okay. This is the---the erne on tee left is an aerial map. It's a pretty good asp far illustrating things, I think. And the one on the right is a regional planning mop put out by the Sea Grant Program. SSAMXMER: What area does the regional map cover? ' MR. SXLSCN: Of Green Bay. EXAMINER: duy. Also 1st me caution you, Jfc. Siiesn, we perhaps only, have tea minutes left of taps, so. ' 71 WTM00608 MCR-FOX-0281465 WATER PCB-SD0000041103 HR. TUSCNi I mean this is Merrill ard this is Portage down here. X don't think that these are major problems. Merrill, maybe, but any sediments from Merrill will be picked up and--like in Peterwell reservoir. (Inaudible) I'm not too familiar with that. But in any case, cartonless copy water, one of the higher concentrations is a relatively recent use of this. X understand PCB's given their peak stability have been used in premiums for about 40 years, which means you have a problem, of 40 years accumulation. - Now, in Green Bay, I'll try to go to my slides. The companies involved in this are Bergstrcn and Neenah, possibly American Can Company, because I understand PCX's are used to get the--to get like wax paperboard type products, like milk containers and things like that, ` papa: cups out of the molds. Combined Locks has Appleton Paper for Carbined locks. Again, National Cash Register is a subsidiary. U. S. Paper at DePere and X had difficulty finding it because it doesn't appear on this map. Xt seats to be very obscure. ' And then, of course, Fort Howard, which has & person on the. Natural Resources Beard, John Brogan, and then a third kind of problem exists in Green Bay, because that's where the sediments go to. I tried to do seme field sailing and I'll return to that in a second. X guess X need the lights off new. Okay, let's start. This is a statute of Bridges (phonetic), the ancient Baltic river goddess, mis is about 3,000 years old. What I'm trying to say by this is that 3,000 years ago our ancenstors didn't pollute the envirorment. Whether they would have if they could have is a question, but the thing is what will the envirorment and the public, health generally be like 3,000 years from new. _ Okay, mis is portage, mere was sort of an abortive trip out there locking for National Cash Register. While we were still in the air we couldn't find it too well. later on, X found roughly where it was before X got a sample. X thought that was it, but it turned out to be a hospital or a school or something. Xt has a cross on it in any case. Now, you can see sandbars on the river that caused us problems because we were using a sea plane and things are backwards, I can see. Xt will be a problem later on. We took this seaplane and we went out and came bade. Later on X used the land plane. This is very hard to see that there are cows here, and CNR is really down on cows because cows don't pay a lot of taxes and they don't employ a lot of people, so ecus are- and farmers are very much under attack. This is going to be very rough because this is backwards., X was given misinformation on hew this carousel worked. Could we step the tape and everything while wa change it, because it'll really be a problem. EXAMINER: Okay. (Off the record) ' EXAMINER: Back on the recced. MR. TUSCNi I'll try to go through these really fast. This is a--this is KimberlyClark. While sulfite process is not involved in this, there is a possibility that deink pulp from the deinking plants is used in kraft pulp, so at least one of these should be picked out to look at. . ' Hero's Bergstrcm outfall. This is algae. And I'm suspecting that algae anl weeds are bioconcentrators of this initially getting into the fish. This could be used to--that in a positive kind of way by--rather than using pesticides, just weed harvesting, weed and algae harvesting and then you're biocencentrating these residues in the past 40 years in tie algae. This is working downstream. It becomes a little obscure in here trjii one of these--I think.this may be Kimberly-Clark at Kimberly which since tl Neenah Plant doesn't lend itself to very good sampling because the sediments are roughly secured out. It's rock bottom there and this----wait a second, this one here--X think thta is the National Cash Register at Appleton--at Combined Lodes, Appleton Rape:, which has been involved in carbonless copy paper. Okay, mere it is again, mis.is Nicolet Paper, which X thought was U.S. Paper, since Q.S. Paper doesn't appear on the regional planning nap. Hit in any case, U.S. Paper is off to the right on the same bade as Nicolet Paper. 72 WM00609 N C R~ FOX-0281466 WATER PCB-SD0000041104 And Fort Howard, which is---and there you see the outfall with the plume extending downward. And this is caning up aver it. And an the right you see the treatment plants. X mean money is being spent, I think,, to' clean this-up presently and maybe a little bit of ah improvement is needed in that. But tte problem is an inherited one frcn the past 40 years and there I'm being left off at Neenah to face the hostile natives. Ibis is the most exotic piece of sampling equipment I had because I managed to get same of that nud later--they're excavating at Neenah for seme sort of outfall. Here we see sane of the' algae and sooe people fishing. I had a lot .of pictures of people fishing that didn't case . cut--one of which was Like people taking baskets of fish away.. So I mean it's no one fish a week. I mean, this is an area where there's very---sane people are involved in very heavy fish ccnstnption and there's a little boy even, you knew, a. little boy with his grandfather, I mean it Would have been a really gecd picture, X think, to shew this pcOblkn. ' '' . This is the Bergstrom Paper outfall. Here's an area, X think, where sediments have accumlated fron the breakdown of the fibers casing out of the plant and ttere's a lot of lily pads. Kell, what was interesting was that there was like an oily slime covering a lot of this plant material and the plants' cells were oily. X think that these plants are probably preferentially taking vp oily material; it' s part of their metabolids. And X think this might be a thing which could be explored. - This is a landfill which is being put down in that area and X think this migbr be tie best way to contain a lot of these sediments. If you put a clay layer, which is then run. ever by sheepsfoot rollers, to provide an infiltration barrier and you do groundwater studies to make sure that there's ho major groundwater flew through this area. But this would be a way of retaining any sediments that are found to contain' large amounts.of PCB. . this is Kimberly-Clark. This outfall was apparently plugged. It's a measure of the progress that is being made. . ' This is down near Menasha. This is, X think, this would be an outfall that would pick t^> material from American Can. Ccmpany, possibly Strange Paper Ccnpany, John Strange. That's American Can locking under the trestle. This is very largely rode button. That's what I usedup delicate professional hands are not used to the rigors of the norm. I'm really sore. This is American Can again. And this is John Strange... I'll try to get this a little bit better into focus, but it shows that they're using wastepaper also, so this is quite extensive, this problem. ' American Can--and this is returning. X'Jl. just show where the sediment areas were. This was the one fratrBergstran and Kimberly-Clark might be putting' out. American Can, John Strange, Menasha Corporation. I don't think is involved in this; Strange does use sane, waste- paper, probably not very much. American Can may use it as a release fron the malt. But anyway that second ..sludge bank is down here . We also have sludges all along this shore, the west shore of Little lake Buttes des Marts. A lot of sediments, - Kimberly--this is where Kimberly-Clark is--so that a spot check could be make on kraft paper industry. Contained locks where Appleton Paper is. X think at that time it was called Canbined Mills. I'll point to tJ.S. Paper and this is Port Howard over in here. ' And Fort Bcward is.this projection where there are shallows adjacent to it. See this is Pert Howard in here. . . And in Green.Bay, this is--I'll show Atkinson's Marsh, which was recently filled with sediments fron Green Bay. That has been since filled and Aany Corps of Engineers was allowed to fill that if they used sheet piling to keep the wastes fron getting back. . ' This is where most of the wastes have, accumulated actually, cut in Green Bay, where you would pttfaably find very good wnple--samples shewing high PCB content. . - The- interesting thing is that money exists to clean this vg>. There's $15 million in Section 115 which apparently a lot of people don't know about, because X think if ttey had known about it, they would have spent less---really less effort in trying to see that it didn't acme out. Instead they would have maybe admitted to' it.- But X don't know. Maybe that motfey is gene now. This is a clamshell dredge, X don't think that would he a good sort to use. There's a lot of resuspension fron that, and a dipper dredge the same thing. A cutter heal is for very hard material. This, 2 think, maybe would work pretty veil in the area of U.S. Paper in DaPere, 73 VTM00610 NCR-FOX-0281487 WATER PCB-SD0000041105 Fort Howard at Green Bay and actually out in the--in the eastern portion--western portion rather of lower Green Bay. Ibis ia a. suction device. And there is a source called jetting at laminar flow rates, jetting at ienthic deposits at laminar flow rates, which indicates that there ia--there's not nnch auspensi m--resuspension of pollutants observed when jetting, when the laminar flow rates are done. In other words, when it's done very slowly. And James Jones of the Any Corps of Engineers feels that very much could be done along this line if the proper techniques are followed. In other wands, the industry has not been too--it's been sloppy and he thinks there's a need to clean 151 there. Hiis is a floating dry dock. I thought maybe this would be a way of--not so much a floating dry dock, but an equivalent thing which has doors across. A landing ship dock could.be used to rstove these sediments, but now I don't think that's the best way. I think it would be best to put up, not so much sheet piling, but like a breakwater kind of effect, like retaining well and fill in the area behind that ever a period of time, using this technique for dewatering of dredged areas, mis is from civil engineering. And then what could happen would he it would be made into a landfill and a day layer far infiltration harrier could be put over that. EXAMINER: clay. Me have about two minutes. MR. TUSCN: Okay. m closing, I'd just like to sort of say that I don't--I really don't feel that the Department of Natural Resources, not withstanding this conference, has really been on top of this problem to the extent they should be, because there really has beat materandtms around on this since 1971 and in 1973 ETA almost had to 1 if you read the Great Lakes reports and such, the ETA was really the people that axe pushing CNR on this. And I'll read from a report, the Booz-Allen and Hamilton report for reorganization of EUR and one of tte things they say is that "long chains of ccrmand lend thanselves to delegation problons since it can become difficult to determine who in the chain is personally responsible * for specific results. They can also create -unnecessary organizational distance between professionals at a lower level win have detailed information and persons at the top of an organization who have a need for detailed information on a selective basis." My observations have basically been that the lower level people would like to see the environmental and public health problems addressed to. This is tbs people at a professional lower level and 1 know the Natural Resources Board, fran tty conversations with than. They want to see it dealt with. So the reason I think that there hasn't been mere action forthcoming on this is some where in between I question whether----as is often brought out, whether it's necessarily at the Secretary's level, and I think what will have to be done on this is that people will have to take less cognizance of how much taxes an industry pays, bar many people it employs and this kind of thing. And instead, the industries also have to sit down and be.willing to atploy technology which, as I say, 1 think does exist. There's biological treatment of chlorcphenolic wastes, which is a relative, a related compound. They've had luck with mildly acid reduction techniques far de gradation of polychlorinated biphenyls, mis can he done on a current basis, a restriction of the use of PCB's will cause---will be---cause the level of FCB's in waste-paper to drop over a period of time and then the sediments problan can be addressed. And I think that rather than industry saying that they really can't do it, but rather instead working to see what they can do. There's a lot of chemists; there's a lot of biologists, which are unemployed aid there's sort of almost a need to spend money, I think, to get the econemy goirg again and 1 think these are resources which sheuld be applied. I don't think problems should really be covered up. I think they should be dealt with and X think the people in the organization --I would specifically like to mention two people. think Stan Kleinert, here and Maurice Van Susteren I think are very dedicated professionals. And I think in seme way they should be singled out fox sane special oaimendation, may a Governor's ooanandation or something, for the extent to which they've pushed this, I think. I think with it, not necessarily being a thing which is endeared ttem with the administration of ENR. So anyway, 1 guess on that I'll close. EXAMINER: Ckay. Thank you very nuch, Mr. Wlson. I appreciate your appearance. Please provide us with copies of your slides and a manaranch.ni of what's referred to in the slides, identifying the slides and referencing material you used. It would be good for typing up the transcript. Thank you. Is there any other party who wished to make an oral coctment at this time? (No response) . - SCAMMER: Ckay. Kith that 1 win be bare for a start time this afternoon to sea 74 UTM0OS11 NCR-FOX-0281468 WATER PCB-SD0000041106  if anywe wishes to appear for consents in that we did issue news releases stating that we would be here, otherwise, I have no Information as to other parties ,>bo wish to appear. All of cur presentations axe cccplated. If those of you who are here do wish to leave at this tine, then we wiU adjourn for a toon lunch. But if .you aren' t going to be with us after lurch, again, there'll be no further hearings. ' . The concent period is extended to 30 days after availability of transcript or November 1, whichever is sooner, and you'll be--all those filling cut appearance slips will be informed. - ' On behalf of the Natural Resources Board, Secretary Voigt and the Department, I wish to thank you for your assistance and participation. We will new have a noon recess and. readjourn at 1:00. Hank you. . . - (Noon recess) . EXAMINER: Cn the record. The bearing into the proposed Administrative Cede rules limiting the effluent dis charge and pertaining to polychlorinated biphenyls which was recessed for the noon lunch period, is reconvened. ' It is presently 1:30. NO new persons'who wish to give oral statements have appeared in the hearing room. Therefore, at this time, the record is--excuse me. The hearing . is closed with the record to be held upon for receipt of contents pursuant to time limits stated in the before lunch recess address. . ' . Thank ycu. The hearing is closed. (Nearing closed) . 9-9-75 ds 75' WTM00612 N C R-FOX-0281469 WATER PCB-SD0000041107