Document 3QBb8KmgRX0Lq70nND2JkNjXJ

G E N E R A L ELECTRIC GENERAL ELECTRIC COMPANY. ONE RIVER ROAO. SCHENECTADY, NEW YORK 12345 Phone (518) 374-2211 REAL ESTATE AND CONSTRUCTION OPERATION November 11, 1975 Mr. R, W, Lewis, Vice President Corporate Operating Services Fairfield, Conn. 06431 Dear Bob, Enclosed is the documentation relative to the assertion by Mr. Severo in this morning's New York Times that the testimony GE presented to New York State was in apparent contradiction to testimony given by me to EPA last year. 1) Page 6 from my written testimony submitted to EPA in March 1974. 2) My response to a medically related question during cross-examination by EPA on May 8, 1974. 3) The medical data submitted by GE to New York State on October 29,1975. Very truly yours, A ELS :1 (Att.) cc: EL Dobbins MM Masterpool JS Nelson JF Repko ES Weaver E. L. Simons t SERVING PROGRESS 773919 c^r-in ^ C 5 - V ? y Even though the proposed standards are not based directly on the alleged "high order of toxicity to man", the use of this phrase In the promulgation of the list is inimical to objective evaluation of the criteria. Although this error was called to the attention of the EPA in November, 1 9 7 3 ^ , the statement has not been withdrawn nor the error acknowledged. We hold that the persistence of this error may have unduly alarmed the public and thus Impaired the climate for the present hearings. To the extent that EPA staff believes its own statement, the credibility of its evaluation of all related criteria must be called into question. In a document prepared by the General Electric C o m p a n y ^ at the request of the Office of Science and Technology, we reported: "In the United States, medical records show that over a nearly 40-year period, the only adverse health effects experienced by U.S. workers exposed to PCBs, either during the manufacture of these liquids or of electrical equipment containing these liquids, have been limited to occasional cases of non-chronic chloracne or other temporary skin lesions or irritations." It should not be surprising if an investigator, convinced -- against all evidence-- of the "high toxicity" of such a material were to propose a standard completely at variance with th public need. 2. Seriousness of environmental threat In promulgating its List of Toxic Pollutants (38 FR 24342), EPA set forth several criteria that were used in.choosing pollutants for inclusion on the list. In particular, let me quote criteria 2, 3, and 4, with under lining added: ( "2. The pollutant is discharged, or has the potential to be discharged, from point sources and constitutes a very serious environmental threat. 773920 GENP 005269 yVH * * ' " 'r -- * 'J / S '? ^, ' 2711 1 Ci Well, perh a p s w e c a n p a s s over that for the time 2 being. 3* Have you attempted to measure the PCB levels in 4 the sediments observed in the Hudson River? 5 JL T h e r e h a v e b e e n no m e a s u r e m e n t s m a d e by us of the 6 Hudson River. / 7 Cl Have the w o r k e r s t h emselves b e e n m o n i t o r e d ? For 8 example, have blood samples been taken and measured for PC3 9 content? . '' 10 "'A. Befo r e comi n g d o w n h ere I choc k e d w i t h the m e d i c a l 11 d i r e c t o r ' o f our P i t t s f i e l d plant, wh o is a w a r e of -- w h o c a n 12 speak .in terms of d i r e c t e x p e r i e n c e at P i t t s f i e l d and is 13 aware of the s i t u a t i o n at the other plants that u s e PCB'c, 14 b e c ause in our tes t i m o n y we had indicated that the o nly 15 m e d ical effects that had b e e n reported d u r i n g the four d e c a d e s 16 that we were in this b u s i n e s s h a v e been o c c a s i o n a l cases of 17 chloracne or o t h e r m i n o r skin i r r i t a t i o n s of a n o n - c h r o n i c ,1.8 n a ture w h i c h d i s a p p e a r e d u pon the tran s f e r of the e m p l o y e e 19 to some other o p eration. 20 . I asked the medical director if that statement is 21 still valid today; he a s s u r e s m e it is, a n d t h a t that is the 22 extent of the medical problems that we have encountered among 23 the employees e x p o s e d to PCB's. 24 Inc. ft Well, that d o e s n ' t q u i t e a n swer m y q u e stion. 25 I asked if their blood levels have been monitored A/-rrAA J M a A 773921 f . PiCtc< Vi y ^ y d./^U/ ' y/-7!~ < With respect to each instance so diagnosed, give the number of employees diagnosed and the date(s) thereof. B. St at e w h e t h e r any GE e m p l o y e e e m p l o y e d at e i t h e r of the !:manufacturing facilities was ordered or requested by a physician ?!to a v o i d c o n t a c t w i t h o r e x p o s u r e to PCB's. If so, state the nu mb er of e m p l oy ee s so or de re d or ji ::r e q u e s t e d , the d a t e the o r d e r or r e q u e s t was m a d e or s u b m i t t e d ! I.'GE and s u b m i t a c o p y of any w r i t t e n r e p o r t of su ch r e q u e s t o r tc [o rd er and a c o p y of a n y w r i t i n g p r e p a r e d by GE w i t h r e g a r d to- each such request or order. .. A N S W E R TO I N T E R R O G A T O R Y NO. 17 ( <-- ^ 7 17. A. R e s p o n d e n t o p e r a t e s an i n d u s t r i a l d i s p e n s a r y at b o t h manufacturing facilities. i Hudson Falls Plant. T h e m a i n d i s p e n s a r y is l o c a t e d at th* . D u ri ng the p a s t 15 years, 49 e m p l o y e e s h a ve r e p o r t e d ;i 'the dispensaries complaining of allergic dermatitis, diagnosed as having been caused by contact with PCBs. During this perioc i* 16 other employees have reported one or more of the following i w h i c h m a y h a v e b e e n c a u s e d b y or a g g r a v a t e d by e x p o s u r e to PCB:J 1. n a u s e a 2. d i z z i n e s s -30- 773922 i1 3. eye irritation 1 4 . nasal irritation 'l ' 5.- asthmatic bronchitis * I I t i; 6. fungus i1l: ;i 7. ' acne ii The following is a summary of r e p o r t e d cases b y ; ii !! * !; ii* Ii ;; ,1 !i . ' ;; Vear ' I960 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Total Dermatitis Cases . 0 0 0 0 0 3 4 3 6 13 3 2 3 3 8 1 49 Other Conditions 0 0 0 1 0 0 1 3 2 4 1 0 0 1 3 0 16 j,During these years, ap p r o x i m a t e ly 13 00 employees have w o rk e d in j| fiareas exposed to PCBs. j !i u4; ' B. The p l ant p h y s i c i a n r e c o m m e n d e d that each of the 65 t* ;employees referred to in p a r a g r a p h A be removed from e x p o s u r e to I !U,PCBs. Each reco m m e n d a t io n of the plant phy s i c i a n is c o n t a i n e d in ; la medical report w h ich is privileged. ii i; . . ' * GENP 005272 -31Iii; 773923