Document 6wMgDZV0wDDR1My6Gz3mRry23

August 11. 1983 Mr. D a v i d S. M c C r e a M c C r e a Z< M c C r c a 119 South Walnut Street P . 0. Bo:: 1310 Bloomington, Indiana 47403 Dear Mr. McCrea: T h i s l e t t e r is w r i t t e n in r e s p o n s e to t h e i t e m s a. t h r o u g h e. on p a g e 2 of y o ur l e t t e r of A u g u s t 3, 198B. S e v e ra l cf the items merited rather extensive responses which were p r e p a r e d in the form of separate d o cu me nt s whic h area re f e r e n c e d at the approp ri at e plac es in this letter and a t t a c h e d to it. I have a t t e m p t e d to r e s p o n d to your listed items in order below. a. R e a s o n s f o r testing: T h e a t t a c h e d d o c u m e n t " H i s t o r y of the Westinghouse PCB Survey" describes how the PCB testing came about and who was involved. The short a n s w e r is that so me of us in W e s t i n g h o u s e felt that eventually those companies who were releasing to the environment chemicals which had serious adverse effects would eventually be made responsible for their actions. The chief e x e c u t i v e officer (CEO) of W e s t i n g h o u s e wanted the company to be a "good citizen" and take this 'responsibility voluntarily (see the document cited ab ov e, p a g e 3, l i n e 20 to p a g e 4, li n e IS? a l s o see the at t a c h e d d o c u me nt "Date of Me et in g wi th W e s t i n g h o u s e CEO". So m e of t h e re st of us t h o u g h t it made good business sense: filing the problem when only t h e c o m p a n y k n e w ab ou t it, b e f o r e a h u e and cry was raised, was bound to be much cheaper than being forced to take remedial measures later under public scrutiny and court order-- essentially, fore-warned was fore armed. b. M e t h o d s for testing: A m o d e r a t e l y d e t a i l e d de sc ri pt io n of the me th od s for me as ur in g PC B' s in the collected samples is put forth in the attached document "Method U s e d Fo r M e a s u r i n g P C B 's In T h e S a m p l e s F r o m Th e Westinghouse PCB Surve/". c. D e c i s i o n -- m a k i n g p r o c e s s not t o m a k e t h e t e s t da ta p u b l i c : I h a v e d i s c u s s e d t h i s p o i n t at s o m e le ng th in the attached document "Who Knew About The PCB Survev D a t a A n d B v W h a t D e c l s i o n - M a k i ng P r o c e s s W a s It D e c i d e d No t To M a k e It Public"'". A s h o r t e n e d a n s w e r is that.I d o not t h i n k such a declsion-mal i ng p r o c e s s too* place. The survey started out as secret to give those concerned time to react appropriately before the puzlac became in-flamed. I do not think a corporate-wide, h i g h - l e v e l a s s e s s m e n t o-f th e r e s u l t s ever tool pierce. d. Description of your conference meeting with Westinghouse attorneys in New York, and e. Description of telephone conferences with attorneys and what they communicated to you with regard to your serving as a consultant for Mr. and Mrs. Conard: B o th o-f t h e s e it em s <d. and e. ) a r e d e a l t w i t h in t h e attached document "My C o n t a c t s With, the Law Fi r m R e p r e s e n t i n g W e s t i n g h o u s s ". I hope that you find these materials both responsive to your requests and useful. Also attached to this letter you will find c bill for my services to date. Sincerely yours T. 0. M u n s o n , Ph D 905656 1 HISTORY OF THE WESTINGHOUSE PCB SURVEY by T. O. Muns on , P h D (8 /6/1988) I joined the Westinghouse Electric Corporation's Ocean Research Laboratory ( W O R D then located in San Diego, CA in M a y of 1969, They didn't re al ly h a ve a project for me to wori.. on but f e lt that a P h D B i o c h e m i s t w o u l d a d d s o m e n e e d e d breadth to the staff, I was given the task of coming up with a project which would augment ongoing WORL programs and possibly lead to some outside contract research money. At th at time WO R L was c o n d u c t i n g an e c o l o g i c a l s t u d y of a p o r t i o n of the n e ar by ne ar s h o r e m a r i n e en vironment. The pr o j e c t I c a me up with wa s to m e a s u r e th e r e s i d u e s of the p e s t i c i d e DDT in the t i s s u e s of th e a n i m a l s in t h e s t ud y area. A few scattered bits of data s u g g e s t e d that the l e v e l s of DDT in the s o u t h e r n C a l i f o r n i a m a r i n e e n v i r o n m e n t w e r e higher than one m i gh t e::pect s i m p l y f r o m the input of urban waste. In the last half of 1969 an d t h e f i r s t half of 1970, with funds supplied by the Westinghouse Research and D e v e l o p m e n t L a b o r a t o r y in P i t t s b u r g h P A (of w h i c h W O R L w a s a part). I set up the necessary equipment to analyse for "hard"(or persistent) chlorinated pesticides and learned how t o do the analysis. In the p r o c e s s of d o i n g t h e n e c e s s a r y literature reading, I learned about polychlorinated bi ph en yl s (PCB's) at this time. Scientists around the world had been measuring the a c c u m u l a t i o n of "hard" c h l o r i n a t e d p e s t i c i d e s (especisllv D D T and its me ta bo l i te s) in wild animal t i s s u e s since the 905657 i l a t e 1 9 5 0 ' s. In c e r t a i n a r e a s of t h e world, u n k n o w n c h l o r i n a t e d su b s t a n c e s o c c u r r e d in the animal ti s s u e s at high enough levels to inter-fere with the chlorinated p e s t i c i d e analyses. In the m i d d l e 1960's t h e s e su bs ta nc es were identified as PCB's by scientists in Sweden. I got a set of P C S s t a n d a r d s f r o m M o n s a n t o an d b e g a n m e a s u r i n g PC'B le vels in the mari ne organisms, as well as the DDT residues. Sometime during the summer of 1970, I read an a r t i d e on PCB's which listed their many and varied uses, and I l e a r n e d to my s u r p r i s e that by far the la rg es t use was in the electrical industry as an electrical insulating fluid in transformers and capacitors. After making some inquiries, I learned that the electrical insulating fluid used by Westinghouse was called Inerteen. specially formulated by M o n s a n t o and ha v i n g as its main c o m p o n e n t A r o c l o r 1242, the. PCB mixture containing 42 weight percent chlorine. At a b o u t t h i s t i m e a v e r y s i g n i f i c a n t e v e n t tool: p l a c e at WQftL-- t h e m a n a g e r . Dr, R o y C. Gaul left to t a k e a p o s i t i o n in the O f f i c e of Naval R e s e a r c h in Washington, D.C., and he was replaced by a career Westinghouse e x e c u t i v e . Dr. J. C. R. Ke ll y, Jr. By v i r t u e of his m o r e than 20 years of service with W e st in gh ou se and his elevated p o s i t i o n (he was a Director, one step down from a Vice President), Dr. Kel l y knew e v e r y t h i n g and ev er y b o d y in the W e s t i n g h o u s e E l e c t r i c C o r p o r a t i o n . It wa s e v i d e n t later why such a high-level person had been chosen as our new leader: the decision had been made to te rminate WORL in San Diego, and it was up to him to decide whether to move a remnant to t h e E a s t C o a s t t o c o n t i n u e t h e o p e r a t i o n cr t o t e r m i n a t e it c o m p l e t e l y . T h e d e c i s i o n to m o v e W O R L (and as man v o-f the 905658 senior staff member 3 a s wished to go) to the We st in g h o u s e site at the Bfv Bridge near An napolis MD, was announced N o v e m b e r 1. 1970. T h e m o v e was t o b e a c c o m p l i s h e d by t h e end of January, 1971. In S e p t e m b e r or O c t o be r of 1970, I e x p r e s s e d my c o nc er n to Dr. Kelly that the W e st in gh ou se Electric Co rp or at io n might have a pote nt ia ll y very serious environmental problem r e l a t e d to t h e use o-f P C B ?s. S w e d e n h a d a l r e a d y b e g u n r e g u l a t i n g t h e u s e o-f PC B' s, an d t h e U. S. scienti-fic c o m m u n i t y was b e g i n n i n g t o p r e s s u r e t h e U. S. g o v e r n m e n t to do so also. I had been unable to determine whether anyone w i t h i n W e s t i n g h o u s e knew that t h i s wa s tailing p l a c e or whether there were any environmental concerns associated w i t h t h e u s e o-f P C B 's. Dr. K e l l y w a s a b l e t o a s c e r t a i n v e r y quickly that my concerns were not unfounded-- Westinghouse did indeed have an "exposed flank" in this area. He wrote a m e m o s u m m a r i z i n g our c o n c e r n s and t r a n s m i t t e d it to Dr. W i l l i a m E. Sh ou pp , t h e W e s t i n g h o u s e V i c e - P r e s i d e n t w h o w a s t h e h e a d of t h e W e s t i n g h o u s e RS<D L a b o r a t o r y . T h e s u b s e q u e n t e v en ts were ra th er b r e a t h - t a k i n g for me. W i t h i n a f e w m o n t h s of r a is in g my "red flag" down near the b o t t o m of the co rp or at e ladder, the C h a i rm an of the Board of the Westinghouse Electric Corporation (Donald Burnham) was standing in front of my equipment while I briefed him on the p o t e n t i a l e n v i r o n m e n t a l p r o b l e m s c o n c e r n i n g th e us e of PCB' s -- b 1 o c o n c e n t r a t io n , b io m a g n i f icat 1 o n . an d pe r si stencc? in aquatic ecosystems. I do not remember very much sp ecifically that Mr. Burnham said except that he assured me th a t if a n y W e s t i n g h o u s e p l a n t w e r e d o i n g a n y t h i n g that might be deleterious to the environment, he wanted to know 905659 about it and wa nt ed it stopped. He said then and had said elsewhere that the Westinghouse Electric Corporation would be a "good citizen" with respect to the environment. I did not feel that this was Just rhetoric-- he struck me as a very sincere individual. I think at that time he was serving on some Presidential Advisory Panel for the Environment or somethina like that. All of this made an impression on me at the time because I was young and idealistic, and was a bit shaken to think that I might be w o r k i n g for on e of the "black hat" corp or at io ns who where ra pi ng the environment in p u r s u i t of th e a l m i g h t y buck. In t h e a b s e n c e of documentation, I am unable to fix the time of this meeting closer than the period November, 1970 to September, 1971 (see associated document, "Date of Meeting With Westinghouse CEO"). That p o r t i o n of the s e ni or staff of W O R L wh o ch o s e to move East moved themselves and their families during the m o nt h of January, 1971, and for th e f o l l o w i n g mo n t h s cond uc te d business out of rented room s in a motel near the Bay Bridge site until the new office/1aboratory spaces were completed in late March or April (1971). During this period of disruption, I made use of the time by completing the fi r s t trips to the W e s t i n g h o u s e si t e s at South Boston VA, S h a r o n PA, a n d B l o o m i n g t o n IN. Dr. S h o u p p p r o v i d e d s u p p o r t f o r th e p r oj ec t out of his d i s c r e t i o n a r y fu n d s until the new project funding cycle in September. At each of these meet in gs I met wi th th e plant manager and members of his staff to explain the prog ra m and gather i n f o r m a t i o n for p l a n n i n g t h e s u b s e q u e n t s a m p l i n g p h a s e of t h e survev. The p u r p o s e of th is s u r v e y as s t a t e d to them 905660 w<?= to d e t e r m i n e w h e t h e r t h e s e manuf actur 1 ng sites w h i c h incorporated PCB'S into products were lealing significant levels of P C B ?s into the e n v i r o n m e n t in the process. At each such meeting I emphasized the fact that we had the opportunity tc locate problem areas and tale remedial action before such problems became public knowledge and a panic situation might occur. At no location was the management in favor of co nd u c t i n g such a survey. The feeling seemed to b e that there would not be a problem unless and until I uncovered one. The field sampling portion of the survey was conducted du ri ng the Summer and Fall of 1971 to the best of mv recollection. We drove to each site with the appropriate sampling gear, collected samples and carried them tack to the laboratory for analysis. The samples were analyzed either di rectly by me. or by a chemist under my supervision. I di.d all of t h e d a t a w o r k - u p and r e p o r t p r e p a r a t i o n . If I am remembering correctly, the reports were distributed bv mail and then I met with the ma na gement at each site to discuss their report in person. The original concept of the survey had been tc extend it to several other sites and the many repair facilities, but after this original effort, it sort of faded away. The funding for internally funded research programs at the Westinghouse R&D Laboratory was done on a competitive basis using priorities set up by the operating divisions within t h e co m p a n y . If t h e o p e r a t i n g d i v i s i o n s di d no t wa nt a p r oj ec t, o n l y s t r o n g s u p p o r t f r o m t h e top level of the co rp o r a t i o n w o ul d get it funded. This p r oj ec t ap parently did not have such s u p p o r t a f t e r the fi r s t s u r v e .. ]f I am 905661 r e m e m b e r i n g c o r r e c t 1 y t h e p r o j e c t w a s -funded -for t h e Sept em be r 19 7 1 -Sep te mb er 1972 p e r i o d at the level of about 4 m a n - y e a r s of effort, and then h a r d l y -funded at all after that . 905662 Date of M e e t i n g with W e s t i n g h o u s e CE O By T. 0. Mu n s o n . P h D <8/9/88) U p o n initial c o n s i d e r a t i o n of t h i s ma tt er , I fi*:ed the date Gf this meeting to the time period (November-December of 1970) by the fo ll ow in g th ou g h t process, in spite of the a b s e n c e of do cu me nt at i o n . I s p e c i f i c a l l y r e m e m b e r the speed at which the events unfolded from my first mentioning the p r o b l e m to Dr. K e ll y to th e m e e t i n g with the CEO of West in gh ou se-- a matter of a few weeks or months. Giving a o n e - o n - o n e p r e s e n t a t i o n to the CEO of one of the country's major corporations makes a lasting impression when one is 29 ye ars old as I was at that time. The Fe b r u a r y 24, 1971 memo f r o m R. D. M c C l a i n of B l o o m i n g t o n t o D. M. Sa u t e r , M a n a g e r of the D i st ri bu ti on A p p a r a t u s D i vi si on (which you supplied me), makes it clear that the Westinghouse PCB survey was u n d e r w a y by that date. My s p ec if ic m e mo ry of the p r e s en ta ti on to Mr. B u r n h a m was that it was in my lab, and my lab was packed in boxes from January, 1971 until after the spring thaw in Annapolis when the foundations could be poured for the new laboratory s p a c e -- sometime in March or April of 1971. I was re membering that the project definitely did not begin until after the meeting with^Mr. Burnham. Also along these same lines was the fact that when I f i r s t v i s i t e d S h a r o n F`A ( b e f o r e F e b r u a r y 2 4 , 1 9 7 1 a c c o r d i n g to the above mentioned memo), I was sent packing by the p l a n t m a n a g e r w h e n I e x p l a i n e d w h e t I w a n t e d to do. Hi s o p i n i o n wa s t h a t t h e y w o u l d no t h a v e a p r o b l e m if I did not 905663 sample the river. He knew that PCB's had been spilled into the river,.but felt that no harm could have been done because Sharon Steel a short way further down river had totally wiped out the river. After I returned to Annapolis. Dr. K e ll y r e p o r t e d to Dr. Shoupp, and Dr. Sh o u p p talked to the Vice-President of that particular manufacturing division. Subsequently, I was invited to return to Sharon by the plant manager (probably John Rissinger), and he took me to the country club for lunch where we planned the scope of the survey at Sharon. I'm.do not think Dr. Shoupp could have turned that situation around without the involvement of higher management-- Westinghouse was run very strictly by chai n-of-command. But on the other hand, upon reflection, a fairly clear i m a g e has fo rmed in my mi nd of m y s t a n d i n g in front of th e equipment in my la boratory showing a ch ro ma to gr ap hic trace of a PCB f o r m u l a t i o n to Hr. Burnham. The p r o b l e m is that I did not acquire that particular equipment until we got into t h e n e w lab s p a c e in A n n a p o l i s . If t h a t p i c t u r e is c o r r e c t , th e meeting could not have taken place in late 1970 in San Diego. It also seems unlikely to me that the meeting was in San Diego for another reason. Westinghouse had very little manufacturing activity of any ma gn it ud e going on West of the Mississippi in 1970. Mr Burnham would have been unlikely to h a ve flown 6 h o u r s just to get a 10 m i n u t e br iefing from me. It is m u c h m o r e l i k e l y t h a t h e w a s s c h e d u l e d t o vi s i t t h e Oceanic Division facility at the Bay Bridge site near Annapolis (just across the parking lot from W O R D . and they sc he d u l e d a brief stop for him to get a f i rs t- ha nd look at 905664 where the PCS survey was going on. S o I w o u l d h a v e to s a y t h at I 'm not s u r e w h e n th e m e e t i n g to ok place, but I am d e a d c e r t a i n t h a t it dijd t a k e place. The most likely time was in the period November, 1 9 7 0 - S ep te mb er, 1971. i i 905665 1 M e t h o d Used For M e a s u r i n g P C B ' S In The S a m p l e s F r o m T h e W e s t i n g h o u s e P C B S u r v e y by T. 0. Muns on , P h D <8/10/88) T h e an al ys is of thes e sa mp le s was perf or me d be fo re methods for PCB analysis were promulgated by the U.S. Environmental Protection Agency, but the method finally put forth by the USEPA reflects pretty closely the methods which had been used earlier, and which were used in this study T h e p r o c e d u r e c o n s i s t s of a s e r i e s of steps, ea ch of wh ich will be discussed in some detail below. EXTRACTION: The first step in the procedure was to extract the P C B 's from the sample matrix. Exactly how that was done d e p e n d e d upon what type of s a mp le was being dealt with. Soil and sediment samples were first dried at room temperature, ground to a powder with a mortar and pestle, sieved to remove particles larger than 1 millimeter, and a weighed portion extracted about 8 hours in a Soxhlet extractor with an organic solvent m i x t u r e <2:1 h e x a n e - a c e t o n e ) . Fish <and other tissue) samples were kept frozen until the beginning of the extraction step. They were then sawed into chunks w i th a f r o z e n - f o o d kn if e and r e d u c e d to a p a s t e in a blender. A weighed portion of the paste was ground to a dry powder with 4 to 6 times its weight sodium sulfate (anhydrous). This dry powder was then extracted exactly like the dried soil or sediment samples. CLEANUP: The extracts containing the PCB's also contained 905666 m a ny other extracted materials which needed to be removed prior to the gas c h r o m a t o g r a p h y step later on. Removal of the unwanted material was done at this cleanup step. Because P C B 's are very stable chemicals, a single, very rigorous step can be used which will remove all but the most stable chemicals. Simply stated, the extracts were treated with a mixture of fuming sulfuric acid and concentrated sulfuric acid to oxidire and remove the unwanted materials. T h e t r e a t e d e x t r a c t s w e r e t h e n r e d u c e d to small v o l u m e s (a few milliliters) using a Kudurna-Danish evaporative concentrator. IDENTIFICATION: The P C B 's were identified using a gas c h r o m a t o g r a p h (GC) e q u i p p e d w i t h an e l e c t r o n - c a p t u r e detector. Th e e l e c t r o n - c a p t u r e d e te ct or was used because it gives very strong responses to halogen-carbon bonds such as the chiorine-carbon bonds in polychlorinated biphenyls < P CB?s). A GC is an in st ru me nt w h ic h s e pa ra te s mixtures of organic chemicals based upon their volatilities. A particular PCB formulation, such as Aroclor 1242, will give a particular pattern of peaks on the strip chart recorder output from the BC. The location of each peak on the chart and the relative heights of the peaks are the identifying features which are used to determine whether a sample c o n t a i n e d P C B 's. If t h e s a m p l e c o n t a i n e d P C B ' s t h e ch a r t would e x a c t l y match that of a PC B standard or mixture of standards run under exactly the same GC conditions. QUANTIFICATION: Determining which PCB was present, and how much, w a s d o n e b y c o m p a r i n g t h e s a m p l e c h a r t s w i t h the F'Cr 905667 s t a n d a r d charts. Which P C B or c o m b i n a t i o n of PC B ' s was i present was determined by the positions and relative peak h e i g h t s of the p e ak s on the charts. How much PCB was ; p r e s e n t w a s d e t e r m i n e d b y c o m p a r i n g t h e p e a k h e i g h t s on %ihe sample chart to the peak heights on the PCB standard charts. Using the known concentrations of the standards, the c o n c e n t r a t i o n of t h e P C B ' s in t h e s a m p l e e x t r a c t s c o u l d be calculated and then the co nc en tr tions in the original samples. CONFIRMATIONS !i The id e ntification of the PCB's was confirmed by running the extracts and standards on a GC with a different separation column which would give a different pattern to the peaks and these charts used to verify the initial identifications. i QUALITY CONTROL: To make sure that the procedure was w o r k i n g -- finding no PCB's in samples which did not contain PCB's, and finding the right amounts of PCB's in samples which did contain PCB's, quality control samples wererjun. S o m e s a m p l e s w e r e run t w i c e to see that the s a m e result; was obtained each time. A blank sample containing no PCB's was run with each group of samples to make sure that the i analytical procedure was not adding PCB's to the samples (for t i s s u e sa mp le s a sa mp le of beef liver was run, and for sediment samples a sample of clean sand). Known amounts of PCB's were added to some samples to see that it was not lost during the analytical process. 905668 3 Who Knew About The PCB Survey Data And By What DecisionM a k i n g P r o c e s s WA s It D e c i d e d Not To M a k e It P u b l i c ? B y T. 0. Mu nson, P h D <8/11/68) ( At the outset there was no question that the in-formation which would be generated by this survey would be h i g h l y s e n s i t i v e and p o t e n t i a l l y d a m a g i n g if r e l e a s e d p r e m a t u r e l y be-fore r e m e d i a l a c t i o n s c o u l d b e taken. S o m e o-f these sites had used PCB's long before any environmental c o n c e r n s w e r e a t t a c h e d to i t -- it h a d b e e n t r e a t e d like m o t o r oil. O n e c o u l d e x p e c t t r o u b l e -for p o u r i n g it i n t o s t r e a m s in l a r g e q u a n t i t y but it wa s -fine -for s e t t l i n g t h e d u st on r o ad s. I w a s i n s t r u c t e d by Dr. K e l l y (m an ag er o-f th e W e s t i n g h o u s e Ocean R e s e a r c h L a b o r a t o r y ) that all of the r e p o r t s would be stamped "Company Proprietary. Class 1 " in red ink, and they were. This designation meant that the reports were to be distributed inside the company only on a need -t o- kn ow basis, and not at all outside of the company. I w a s not t o s h o w t h e r e s u l t s -from o n e s i t e t o t h e p e r s o n n e l -from a n o t h e r site. A s y o u c a n se e -from t h e d i s t r i b u t i o n l i s t on t h e -front o-f t h e B l o o m i n g t o n re p o r t , t h e r e p o r t w a s -fairly w i d e l y d i s t r i b u t e d w i t h i n t h e c o m p a n y : -four c o p i e s t o B l o o m i n g t o n ( B r i t t a i n , M c C l a i n , Shoaf-f and S a w / e r ) , o n e t o t h e R`?*D Lab (Shoupp), one to my boss (Kelly), one to the Environmental Systems Department (Terrill), and two to headquarters (Kerns and Boquist). Including my copy, there were then only ten original copies made, each with its big red stamp on the fr o n t . T h e r e d ink did net ?.ero:: well and is not v i s i b l e on 905669 the copy you sent me. At the ti me these r e po rt s w e re generated, it seemed right and proper that this in-formation be held closely within the company so that appropriate actions could be taken in the same way that the developmental data on a new product would not be discussed or published outside of the co mp an y. W h y t h e d a t a w e r e not r e l e a s e d later, if not to the public, at least to the Environmental Protection Agency, I do not know. Clearly, Mr. Wills, the at to rn ey for Westinghouse who responded to the EPA interrogatory concerning the Westinghouse Electric Corporation's use of PCB's did not even allude to the existence of the PCB survey V. data. Since responding untruthfully to such an interrogatory from EPA was a rather serious offence, I would like to assume that Mr. Wills eith er did not know about the PCB survey or had forgotten about it in the ensuing years. I believe I have met Mr. Wills, but I cannot remember the context. As a ma tt er of fact, some of the data w e re ma de public, and various pe op le in EPA knew of the e x is te nc e of the PCB survey conducted by me. Consider: -- In 1972 s o me ti me (I can't fi nd t h e r e f e r e n c e right now), EPA proposed some effluent standards for PCB's and held a h e a r i n g (in Washington, D.C., I think) at which time various interested parties testified. At that hearing, on behalf of the company, I testified that Westinghouse had done a PCB survey around some of their plants and mentioned some of the data. --About 1973, the We stinghouse plant in South Boston VA was 905670 contacted by State of VA officials because high levels of P C B 's had been found in fish in the John Kerr Reservoir which received water from the Dan River near the plant. They showed the officials my report which showed the levels of P C B 's in the Dan River sediments were Just as high upstream from their plant as they were downstream, indicating a source upstream from the Westinghouse plant. The officials went on their way an d f o u n d t h e s o u r c e u p s t r e a m (a f u r n i t u r e manufacturer, I think). On A u g u s t 18, 1976, I p r o v i d e d Mr. R i d g w a y M. Hall, Jr., then Special Assistant to the General Counsel of the USERA (by whom I was then employed), a sworn affidavit c o n c e r n i n g t h e d e te ct io n limit for P C B 's in water. As part of the de sc ription of my experience, the following information was included in that document: "From that time until I left Westinghouse in 1976, my principal research interest was chlorinated hydrocarbons in the envi r o nm en t-- parti c u l arly polychlorinated biphenyls (PCBs). This work involved primarily four general areas: ... 4). a s t ud y to d e t e r m i n e the leakage to the e n v i r o n m e n t of P C ET s fr o m We s t i n g h o u s e Electric Co. transformer and capacitor manufacturing facilities. (All of t h e r e s u l t s of t h i s p r o g r a m ar e of a p r op ri et ar y nature. Prior to the preparation of this affidavit I mentioned the proprietary nature of this study t o the ERA attorney, Mr. Ridgway Hall, and we agreed that I should not disclose the substance of it to an yo ne at EP A or anyone else, or di sc us s it in this t e s t i m o n y w i t h o u t t h e e x p r e s s p e r m i s s i o n of Westinghouse).M 905671 At my level in the c o r p o r a t i o n , I was not a part of a n y decision-making process concerning anything other than my small group of people. The ma nagement pr oc es s was done 5 strictly by chain-o-f-command, very much top-down management. The ability to keep in-formation to yoursel-f and not discuss higher-- level in-formation with lower-- level p e o p l e with whom you worked was one of the personal at tr ib ut es considered for being promoted up the management ladder. 10 It seems likely to me, based upon my e x p e r i e n c e with management in private industry and with the government, that a decision was never made not to make this information public. I think the specific responses to the reports at the sites where the samples were taken were left to the 5 m a n a g e r of th e pa rt i c ul ar plant to decide. In my opinion, some of the responses were appropriate and some were not. I spent some late-night hours agonising over whether I should make some of the information public but decided not to. E v e n if I w e r e not sent to jail for v i o l a t i n g t h e Industrial 2 0 S e c r e t s Act <if s u c h a t h i n g e x i s t e d ) , at t h e v e r y least, I would have lost my job. Obviously, those inside EPA who knew about the existence of the PCB survey data did not convey the information to the appropriate persons, or the EPA 2 5 i n t e r r o g a t o r y wo u l d h a v e s p e c i f i c a l l y r e q u e s t e d it. Apparently, the reports were not shown to the appropriate pe op le inside Westinghouse or hr. Wills would have given them to EPA, and Mr. Westlake, the new plant manager at Bloomington would have known about them. 905672 W h a t s t a r t e d as a n o b l e m i s s i o n w i t h th e s a n c t i o n o-f the Westinghouse CEO did not have the beneficial effects that it could have had for all concerned. It's an imperfect world! 905673 January 29* 1911 Mr, R. F, Casey Substation Operation & Maintenance Ehgineer Ohio Edison Company 47 North Main Street Akron, Ohio 44308 Dear Mr, Casey: Your letter dated January 20, 1971 addressed to Mr. D. A. Olson was forwarded to me for response since I have been closely involved with the polychlorinated biphenyl environ mental problem. Since February, 1970 when Mr. Olson wrote his letter inform ing our customers of a potential problem, there has been increasing evidence that PCB's of chlorine content less than 5h$ have been found in the environment generally near the source of contamination. There is also increasing evi dence that the PCB's being identified as Aroclor 1234 and Aroclor 1260 are probably the residues from lower chlori nated materials which had undergone degradation. Because of this limited information we have concluded that control of all PCB's is indicated. A large percentage of our production has had a chlorine content of less than 54$6. However since our Aroclor products are mixtures of many isomers, the higher chlorinated ver sions have been present in virtually every mixture in vary ing amounts. These higher chlorinated isomers are very resistant to degradation; therefore, will continue to build up in the environment unless controlled. Wo have an active program for evaluating new materials for use in Askarel applications. The most promising material developed to date is a modified PCB from which the per sistent higher chlorinated isomers have been virtually re moved resulting in a fluid which has attractive dielectric* properties but if it escapes into the environment is more biodegradable. Samples of this material, which we have designated as MCS 1016, are now being evaluated by many of NEV 012271 711523 Hr. R. P. Casey ,2 Jan . 29 1971 the capacitor manufacturers. If test results confirm that this material is an acceptable fluid we plan to produce it in commercial quantities by midyear 1971 An incinerator capable of destroying Askarels must operate at temperatures ranging from about 2000p to 3000F and must have facilities for scrubbing the stack gases to pre vent hydrogen chloride gases from escaping to the atmos phere. This type of unit can be relatively costly to in stall and operate but iC can be Justified if the volume of material to be destroyed is great enough. It may be econ omically practical for several units of this type to be located throughout the country providing a service to the utilities nearby. We plan to operate our unit to gain ex perience to help evaluate the practicality for installing more units. At present only one State, Pennsylvania, has objected to the disposal of Askarel contaminated solids in properly managed landfills, I recommend that landfills be used aB long as they are authorized. Certainly if the liquid is drained from failed equipment the potential for migrating into the environment, already very small, is reduced considerably. In the meantime vie are continuing our studies on the incin eration of these solids and hope to have a unit in operation fbefore the end of the year. I recognize the many problems that the PCB environmental contamination problem has createdj however, I am optimistic that Askarels with their many beneficial characteristics will continue to serve the industry if we all follow good house keeping and disposal practices. I recommend that you seriously consider participating in the NE4A-ANSI effort to coordinate the Askarel handling problem country-wide. I hope this information is useful to you. If I can be of further service, please let me know. Sincerely, V.TP sms V/. B. Papageorge Manager Environmental Control NEV 012272 t 711524