Document 7168bmDQ5Kkw6RbG6yjeZnZ1g

'Monsanto < uoNLorro iHCutTHui chiucjlli cm. ICO H. LlAdlr)n low<*rtf Jt. town. Ubomm 52123 ?*: 0141 B8A-ICCC la Re: PROPOSED TOXIC POLLUTANT EFTLUINT STANDARDS FOR ALDRINDIILDRIN, ET AL - FVPCA (307) DOCXZT NO. 1 / i/l?-'* B ! P-. WLf! Stste of Missouri ) County of Sc. Louis ) 85 V. B. Papageorge, being first duly sworn says: My name is V. 3. Papageorge and I am Kar.ager, Product Acceptability for the Functional Product Croups, Monsanto Industrial Chemicals Conpany, an operating unit of Mcr.sanco Conpany. I am a graduate of Washington University, St. Louis, Missouri vich a Bachelor of Science degree in Chemical Engineering and have received a Master of Science degree in Chemical Engineering iron the sane institute. I an i Registered Professional Engineer in the state of Missouri. I have been employed by Monsanto Conpany for approximately 22 years, during which period I have served as an engineer, maintenance superintendent, distribution superintendent, manufacturing superintendent, plant manager and manager of environmental protection. In my present position I am responsible for seeing that the quality of products produced by two business groups in Monsanto Company is properly maintained. One of the business groups within my area of responsibility is the Specialty Products Business Croup which manufactures and markets polychlorinated biphenyl (PC2) products for use as dielectric fluids in transformers and capacitors. I am a member, and have served as chairman, of a committee of the National Electrical Manufacturers Association which has reviewed the environmental effects of ?C3s and has reco--ended procedures to users of PC3s which should minimise the possibility of entry of PC2s into the environment. 173 .10039. HARTOLDMON0034725 -z- .ore'smoksajiTo com? position a.vd recojc'Z.vsATioas X* a aajor producer and supplier of polychlorinated biphenyls (?C2s) to the electrical industry for fire resiscar.c dielectric fluid applications, we have reviewed and evaluated the effluent standards for these caterials in proposed Part 129, Subpart I, Chapter I of Title 40, Code of Federal Regulations. Pursuant to this review, ue aubmit the following consents and recorooendacions: 1. The proposed effluent standards for PCZs are unwarranted and practically and econonically unattainable. 2. Actions by Hsnsanoo and its custoners, which have resulted in liniting the use of PC3s only to electrical applications in hemetitally sealed unit a, have dranacically reduced the quantities of the acre persistent ?C3s introduced directly into Che environment. ' 3. The definition of ?C3s in Section 129.09a, Subpart I should be changed to read: "Polychlorinated biphenyls (?C3s) near.s natarials containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaccumulate in the acuatic environment. These chlorinated biphenyls are identified as those compcoeots having ga3 chromatographic retention times greater than 60, relative to o,o-DOZ*ICO.- under the standard conditions reccnmended in the I?A PC3 test nethod." 4. The accuracy and reproducibility of results attainable between laboratories using currently available lanplir.g and analytical techniques are questionable and further studies are reccomier.ded. 5. The proposed PC3 effluent standard is based cn inadequate toxicity information, on non-typinal fish species ar.d on an . unusually high and artificial bioaccumulation factor. Fundamental scientifically-based data is lacking and no responsible standards can be developed at this time. Ve recommend chat studies.be conducted to obtain the relevant .data and that effluent standards be established which are appropriate for the unique conditions existing at each point source. 100G0 HARTOLDMON0034726 J < V.' 3- 6. Ve object to * limitation of 10,000 cubic feet per second being arbitrarily assigned as a maximum scream flcv, without a sound Cschnical basis demonstrating adverse affecca. 7. The presence of background levela of PCZa ac point aourcea ahould be conaidered when determining effluent levels. The folloving definition of "background" ahould be added under Section 129.01a: " 'Background' near.s amounts of tonic pollutant (1) presently found in the waterways of the United States (including the intake waters of a discharger), or (2) arising cut of operations subject to thia Part that occurred before the effective date of this Part, but were not discharged to the waterways of the United States before the effective date of thia Part.' 8 Technology for the attainnent of the proposed PC3 effluent standard has cot been den.onstraced and is not available to the industry. Ur.achievener.t of the strict standard proposed would have the effect of a ban on the use of PCBs with serious economic and social consequences very thoroughly described in an inpact statener.t submitted to the Agency on January 15, 1974 , by Che General Electric Company. The chemical structure of polychlorinated biphenyls (PCBs) has been known for nearly 100 years. It was not until the late 1920s chat a use for PCBs was found -- as a dielectric fluid in transformers. The properties of ?C3 -- inertness, fire resistance and a non-conductor of electricity -- are perfectly suited to these electrical applicaticr.s where high-voltage arcing could occur; possibly resulting in serious fires or damage to the equipment. Commercial production of PCBs began in 1929. As the unique properties of Che material became known, me'-- uses were found. For example, their fire-res is cant nature made them excellent choices fer use in heat- transfer fluids. Their inertness gave long-lasting qualities to lubricants. Their use in surface coatings improved waterproofing . characteristics. Handling of the product at the manufacturing level has not presented problems as long as the normal industrial hygiene practices were followed and ?C3s have always been considered less hazardous than many ocher chemicals in everyday use. 177 -rr 100-3 < HARTOLDMON0034727 4- *i Therefore, it appeared that ?C3a vert a unique product which ret Important needs of industry. Vhea questions about Che effec: of ?C3s on the environment first surfaced, Monsanto Company reviewed its product line and the applications for these products. As more data vere developed concerning the effect of PC3s, Monsanto took steps to reduce the entry of ?C3 into the environment. The Company atopped the aale of ?C3s for use in various applications, except where no acceptable alternatives vere available. Today, ?C2s nar.ufactured by Monsanto Conpany are sold only to the electrital industry for use in closed systems as a dielectric fluid in transformers and capacitors -- applications for which there exist no acceptable aubstitutes. . ' Thus the situation today is drastically different from conditions which existed only three years ago. Today about 40 million pounds per year are being carefully used in the United States by less than 50 Monsanto cusconers in Che manufacture of sealed electrical equipner.r. Prior to 1971, close to 80 million pounds per year were used by thousands of customers. This lends perspective to the current debate over modest losses of PC3s to waterways. Our manufacturing and sales reduction program was a unilateral action taken by Monsanto and was based on our evaluation of developing environmental data. ` The Incsrdeparmer.cai Task Perce cn ?C3s in its report (1H concurs that the safety benefits derived justify the continued use in dielectric applications. Recommendation 5 under Findings, Conclusions and P.ecc-- er.darions reads as fellows: __ "6. The use of ?C2s should not be banned er.tirelv. Their cor.tinueo'use- for trahs-foffers ltd^capacitc-TS. in--trve..near.. _ future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which vculd result from a ban on PC2 use. Also, continued use of ?C2s in transformers and . capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic producer, has reported voluntarily eliminating its distribution of ?C3s to all except manufacturers cf electrical transformers and capacitors." Humbers in parentheses refer to reference list attached. 100 r"1 vJ r <. HART 6lDMON0034728 Recognizing :"fi nee- fc- proper controls in the handling and use of PC2s, representatives of the transformer and capacitor industries, utilities and governmental agencies under the initial auspices of the National Electrical Manufacturers Association formed American National Standards Institute Committee C-107. Proposed guidelines (30) for Che handling and disposal of dielectric fluids have been published. These guidelines reflect the industry's understanding of the need for ,i proper control and have contributed significantly tcvard achieving I' this objective. '' Proposals for the control of PC3s internationally vere considered by the member countries of the Organization for Economic Co-operation and Development (OECD) and in February, 1973, they adopted an agreement (31) vhich restricts the use of ?C2s to dielectric applications, non-food related heat transfer fluid applications and hydraulic fluid applications in mining equipment. This agreement is less restrictive than Monsanto's sales policy since it supports the continued use of PC3s in heat transfer and hydraulic fluids. . j I Ve have revieved vith considerable interest the effluent standards proposed for polychlorinated biphenyls in nev Part 129, Subpart I, Chapter I of Title 40, Code of Federal Regulations and have objections relating to the folloving: . '' 1. Definition of polychlorinated biphenyls. 2. Sampling and analytical methods. 3. Toxicity data. 4. Bioaccmnulxtion factors. . ~ 5. Safety factors. %~'r~ " rr- * ~y !".**- > ter ', 6. Stream flcv rates. 7. Background levels of polychlorinated biphenyls. 8. Economic considerations. D NITIOS OF POLTCHLORINATED BIPHENYLS Commercial polychlorinated biphenyl products, of vhich Aroclor' products are examples, are produced by direct chlorination of biphenyl; the degree of chlorination being chosen to provide desired properties. These products are in all cases multi-component mixtures and not single entities as implied by the commonly employed acronym '*?C3s". 100-30 HARTOLDMON0034729 . r6- - Vhile i- ia veil understood and accepted chat polychlorinated bipher.yl isomers have i unique sec of physical and chemical properties, ic is apparently c=c understood chac they bioaccumulace, dissipace and biodegrade it different races. This lack of ucderstending is reflected in che definition proposed la the E?A Toxic Pollutant Effluent Standards (Federal Register, Vol. 38, Ho. 247, page 35393, Section 129.09a)'and ve quote: . "As used in this Subpart. the tern: Polychlorinated biphenyls (?C3's) seats materials containing che . bipher.yl group vhich have been chlorinated to varying degrees. There are 210 possible different PC3 ccnpounds." Ve object to this definition because it irplies chat all polychlorinated biphenyl isomers are of equal environmental concern, i.e., that they ill persist and bioaccurulace in the sane nanner in our environment. It has been veil established by acadenic, government, and industrial researchers that this is sinply not true. Environmental ncnicoring prograns have clearly dencnstraced that, vich the exception of direct high-level controllable release near pcir.cs of nar.ufacture cr use, Che ?C3s found in our -'environment are the sere highly chlorinated ones, i.e., these containing predonin.antly five cr core chlorine atons per biphenyl molecule (2 thru 13). . This is true even though the lover polychlorinated biphenyls have constituted cere than 651 of all the PC3s nanufactured over the years. This is strong evidence that the lover polychlorinated biphenyls degrade rapidly. It further demonstrates that even under conditions of uniinited use, and vichouc special precautions to avoid release into our environser.c (vhich is not the case nov), that che lover polychlorir.at; biphenyls degrade rapidly enough to prevent bioaccunulacicn (4, 5, 6, 27, More recently, i: has also been 'demons traced in ''iaETdf a'trry' 6xpnrPdnrerrcsv--=that chlorinated biphenyl iscners, readily undergo bacterial degradation at rates dependent upon the number of chlorines per biphenyl molecule.(17, 13, 19, 20, 21 and 37). There are also good indications that ambier. environnental ?C3 levels are decreasing at races more rapidly chan predicted (14, 15, 16). The rapid metabolism of these chlorinated isomers and their lack of importance as contributors to the chlorinated bipher.yl tissue burdens ia evidenced in che results of numerous studies. Risebrough (2) reported chat che chlorine composition of the PC3s detected in Atlantic Ocean zooplankton vas approximately 542. He concluded "U.S. production of Aroclor 1254 in 1570 amounted to 12 million pounds -- only one quarte: ISO 10 0 c HARTOLDMON0034730 of the production of 45 million pounds of Arocior 1242. It might be expected therefore that biphenyls vith fever chlorine atoms would predominate in planktonic samples unless these compounds were selectively degraded." Sinilar findings in fresh water and aarine fishes were reported by Zitkc (3) and Jensen, et al. , (4) . The disappearance of the lower chlorinated hcnologs in extracts of tissues fron birds (5, 34) and mammals (6, 33) indicate rapid metabolism or excretion of Che lever chlorinated hcnologs. As a result of the metabolism and/or excretion of the chlorinated biphenyls containing less than, five chlorine atoms per molecule, their contribution to the effluent should not be used in measuring polychlorinated biphenyl effluent from a facility. On the basis of these data it is unrealistic to consider all poly chlorinated biphenyls equivalent in terns of persistence and bioaccunula- Cion as does the proposed regulation. Therefore, for environmental purposes, the definition of ?C2s should focus upon chose which are of concern and we recommend chat the following definition be substituted for that proposed in Section 129.09a, Subpart I, Title 40, Cade of Federal Regularises: '. "Polychlorinated biphenyls (?C3s) means materials containing the biphenyl group which is chlorir.aced and which have been shewn to persist and rapidly bicaccunulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than SO, relative to p,p-EDE - 100, under the standard conditions recommended in the E?A ?C3 test method." ANALYTICAL hZTHODOLOGT Ve have no reason to doubt chat the recommended E?A PC3 test meched is capable of detecting parts per trillion (ppc) levels of PC3s in waste waters. However, our experience with analyzing industrial waste waters for PC3a at the parts per billion (ppb) level prompts us to be - concerned about the following areas, some of which are not covered adequately in the test procedure. 1. Sampling Procedures 2. Correction for Laboratory and Reagent Background 3- Correction for Hor.-?C3 Sample Interferences 4. Absolute Verification 1S1 loo :.o HARTOLDMON0034731 t 3- 5. Physical State of PCPs (Adsorbed/Dixsolved) 6. Quantitation 7. Precision and Accuracy Our concern lies in the fact that icy method, especially one as complex as a PCS analytical method, which is Co be used for effluent control purposes oust be c.-.oroughlv evaluated and its accuracy and reproducibility proven. If this is not done, the effectiveness of any effluent linit, no aatter vhat the level, will prove to be difficult, if not inpossible to decemine. For example, we have found that if waste water screens are noc sanpled properly, the PCS levels found depend on the sampling procedure erployed and bear no relationship to the amount of PC3a discharged. For this reason, sanplir.g procedures used must be designed for Che discharge in question and clearly stated. To our knowledge, this has not been done. Ve also note that no provisions are recocroended for correcting the apparent ?C3 level found in a sanple for laboratory and reagent background. It is our experience that as one approaches the ppt level, 'this background can significantly affect the observed ?C3 level. Vith regard to correction for ncr.-?C3 sample inter:erences, we feel ' that, while the procedure notes momy of the possible interf erenons, it does not really address itself to those which are more likely to be in industrial waste water streams. For this reason, if the electron capture chromatogram dees not match the ?C3 being manufactured or used, complete absolute verification of all components counted as ?C3 oust be validated via an alternate technique such as gas chromatcgraphy/mass spectrometry. Ve slso note that the recommended E?A PC3 test method does nor specify a meins of differentiating ber.'een dissolved and adsorbed ?C3s. Ve believe this should be dome since there is s definite diff erence in the toxicity amd availability f or bicaccumulacicn of dissolved and adsorbed chlorinated hydrocarbons (2 Vhlle the scheme proposed for estimation (quantitation) of ?C3s is logical, ic suffers from the same shortcoming as do the multitude of oche procedures which have been proposed. Ic is an empirical estimate and only a reflection of the real PC3 level. Therefore, ic should be determined via an alternate, more-elaborate procedure hew closely the calculated ?C3 levels (for each of the cases) are to the real PCS levels so chat they may be corrected. 132 00 HARTOLDMON0034732 9- LajC, but noc least, the precision snd accuracy of any procedure propcs as a standard method should undergo a chorcugh inter-laboratory evaluac If this has noc already been done, it nust be carried out prior to the use of Che procedure for enforcement purposes. The accuracy and precision of the Monsanto PC3 procedure has been subjected to a pre liminary evaluation. Prior to this evaluation, ve probably vould have overestimated the precision and accuracy of our procedure. The exact details of Che evaluation are available. | . . Briefly, samples vere prepared by spiling distilled vater vith 500 neb PC3s. Individual preparations include blanks (no PC3s), Aroclor1-1242 Aroclor 1254 only, Aroclor 1260 only, all 50-50 evo-component mixture and a 1/3, 1/3, 1/3 preparation containing all three components. Six samples of etch mixture vere prepared and analyred by tvo experienced analytical laboratories. Bach result, expressed in ppb of the individual Aroclor, vas converted to percent of the total added. Analysis of variance vas run on all data taken together and on each laboratory independently. . The 951 confidence Units observed for individual results vere: Zither Lab 87.5 + 55.21 Lab A 81.3 + 46.4T Lab 3 . 93.7 + 19.21 . The repeatability for Che individual labs, based on repeat tests of sanples having identical prepared ccnposicions vas: Lab A + 42.0Z Lab 3 11.62 . Ve feel that these results denenstrate the importance of evaluating the precision of any ?C3 procedure. Koce that the test did noc include sampling problems, used disciiled vater free of incerferences, and vas carried out at a relatively high PC3 level (500 ppb; 500,000 ppc) by tvo experienced laboratories. It is expected chat, if sampling, problen vere involved, ar.d the level of PC3 present vas extremely lov, the accuracy and precision of any PC3 method-vould decrease considerably. 1S 3 100701 HARTOLDMON0034733 -10- sacxcrcund tor propcsit z?a effluent stanuaro, /-'- In Che establishmer-Z of the proposed effluent standard the primary basis for toxicological consideration cane from the Water Quality Criteria. October. 1973. (Federal Register, Vol. 38, pages 29646 et seq., Friday, October 26, 1973). These criteria were, in turn, based on Water QuallsCriteria. 1972 , by the National Academy of Sciences and the Nacior_al Academy of Engineering. The Water Quality Criteria. October, 1973, have not undergone the normal review, crisicisn, ccottens and revision before final adoption. We object to the use of challengeable portions of a proposed publication in the developnent of critical effluent atandards. Ve note in Water Quality Criteria. 1972, in those sections pertaining to polychlorinated biphenyls, the frequent use of unpublished data and the disturbing use of qualifying phrases such as "...nay adversely affect...", "...apparently related...", or "...the work...suggest.. In our opinion, none of the discussions present adequate data to support establishment of responsible effluent standards for PCBs. On page 5 of Water Quality Criteria. 1972, the Committee emphasised the importance in ur.ders tar.ding that there is a distinction berveer. criteria and standards and that the vords were not interchangeable nor or they synonyms for words such as objectives or goals. The report further states that it is necessary to establish scientifically-based recocner.daci for each assignable vater use, inplying availability of practical methods of detecting and measuring vhich can be applied to monitoring. Once these fundamentals are available, political, social and economical factors enter into the decision-making process to establish standards. In our opinion, these procedural ste?3 vere net followed in arriving at the proposed effluent standards for ?C3s. The maximum acceptable concentration in fresh vater that would be permitted by the proposed standard ia 0.002 cg/1. The rationale described 'in the Statement of Basis sr.d Purpose, Toxic Pollutant Effluent Standards ia based on results of a preliminary study which have suggested (not-yet proven) a threshold PC3 level for salmon egg mortality. We camr.ot accept the selection of sxlmom as representing organisms vhich are usual or may potentially be present in vater systems near facilities described ia Section 129.09, Code of Federal Regulations. The cumulative sales of PCBs ia the United States since 1930 has been estimated to be about 500,000 tons and that `total world production was probably 1,000,000 tons (1). About one-half of the PCBs were used ir. applications where containment was difficult and losses into the environment were common. With this amount of material discharged into the environment, it is of considerable imporrance to cote that extensive harm predicted by some theories has not been found amd documented. IS HARTOLDMON0034734 -11- Xhii lack of evidence indicates clue ill of Che ?C2s do aoc persist in the environment as i result of ftccors such is Che biedegration ve hive discussed previously. Also, the PC3s tha,. do persist nay not be eviilible because of irae ficcors not clearly understood at present. One characteristic which undoubtedly is of aiguificant importance is the ability of ?C2s to adsorb tenaciously to particulate natter. Under these conditions, can PC3* be rightfully considered to be environmental!;active and, if so, to what degree7 There exists at present a critical need for data relating to partition coefficients between water and sediments and diffusion coefficients in sediment (1, 22, 39, 60). Although many reports have been published on the subject of poly chlorinated biphenyls and living organisms, the majority of these describe the presence of ?C3s in the environment. Presence should not be assumed to imply adverse effect. To our knowledge, no published report exists which conclusively relates the mortality of any wildlife apecies to the presence of PC23. The only reported nortalities are those achieved in laboratory itudie*. Not enough is known about the fate ar.d effect of PC3s in the natural and diverse aquatic and marine environments to properly design laboratory studies. Results from such studies are not extrapolatable to the natural situations and any conclusions derived from such studies must still be considered speculative. Fundamental scientifically-based data is lacking and, in its absence, the establishment of effluent standards for polychlorinated biphenyls cannot be made intelligently and responsibly. In the establishment of the PC3 effluent standard for freshwater systems a bioaccumulation factor of 200,000 was selected. This factor has no extrapolitable relationship to either the residues of PC3 in salmon eggs or to PC3 residues of fresh water forage fish. The only published report (27) of an accumulation factor of the magnitude selecte: was that for the hepatopancreas of the pink shrimp, Penaeus durarum. Even though an accumulation of 206,000. in the hepatopancreas has occurrec a nearly complete elimination of PC3 fron that tissue was achieved when the shrimp were placed in water free of added PC3. The equilibrium whole body accumulation plateau indicated an approximate accumulation factor of 22,000. These results are in agreement with those reported by Stallings and Kayer (29), and with the studies of Ryther (28) , Creichus at al (24) and Crump-Veisner, et al (22) ahowing equilibrium bicmagnific: tion factors between water and fish ranging between 1,000 and 75,000 depending on the presence and absence of sediment and the specific PC3 mixture present. These data would support the selection of a factor considerably lover than the factors which yere applied. 1S5 100703 HARTOLDMON0034735 Arbitrary safe:y factors were applied to the tolerable chronic limit to establish Che so-called "critical chronic limit'' which was then used to conpute the raTj-:ro allowable effluent. These safety factors were ' proposed to account for a aulcitude of variables, including non-point sources, crulriple discharges and industrial grcvrh. The safety factors proposed were identical for 7 of the 9 naterials for which effluent standards were prepared. These safety factors, resulting in approximate! tvo-fcld reductions, are so snail as to be of no beneficial toxicological consequence. Ve recoaaend that no safety factor be applied. In establishing the effluent standards, an actenpt was aade to distinguish between types of receiving waters by classifying them as streans, lakes and inpoundnencs, estuaries and coastal waters. Ve do not believe this attenpt to distinguish water bodies is by any neasure adequate. Vater bodies are universally known to be complex. systens with no two systems alike. With a conplex material auch as poly chlorinated biphenyls, the deteminaticn of possible adverse effects in each vater body becoces exceedingly difficult. The uniqueness of each water systen at each point source nust be considered. A key paraneter used to further describe the water body is Che flow rate which was limited to Che probable lew rate of stream flow occurring during a seven-consecutive-day period ence in ten years. Ve do not agree that this is realistic or appropriate. In cur opinion, appropriate control is achieved using average screen flow rctes. Further, the naximum flew rate that can be used in .calculating the daily discharge permitted has been arbitrarily set at 10,000 cubic feet per second. This linit is based on a nondegradaticr. philosophy which tolerates United diffusion and on a desire to discourage industry fron locating facilities on large main inland vaters and coastlines. This limitation deprives our society of the.Judicious use of an important gre: natural resource. Discharge limitations should be based on the effects a naterial will have on a water systen, giving consideration to its sire and flow rate. For PC3s, proper control will not occur by imposing naximum flow rate conditions, but by applying results fren scientific studies which properly define hew each water system responds to the presence of PC3s. RESIDUAL POLYCHLORIKATID BIPHZhTLS Because of their chemical and physical properties, ?C3s can be found in soils and waters at point sources leng after a discharge.has occurred. This source of PC3s to Che environment will diminish with Cine but its presence will distort and nask results fron current control activities. To maincain control of losses, emphasis should be directed toward discharges resulting fron current and future uses of PC3s. IS 6 007 'j HARTOLDMON0034736 -13- Since this problem of background levels occurs with ill materials in varying degrees, ve propose Che follcvtng revisions: Frra Section 129.01c(b), delece che vords "in intake waters for a discharger". Add an additional definition in Section 129.01a: " 'Background' means aoaunts of toxic pollutant (1) presently found in che waterways of che United ' . .States (including the incake waters of a discharger), . ` or (2) arising out of operations subject Co this Part that occurred before che effective date of this Part, . but were not discharged co che waterways of the United States before Che effective dace of this Part." ECONOMIC CONSIDERATIONS At our PC3 manufacturing facility, we developed and instituted an aggressive control''program which we described before the Effluent Standards and Vater Quality Information Advisory Cc--ittee, E?A (41) . Yet, in spite of all our efforts, we car.noc today meet the proposed effluent standard. " In response (42) to an inquiry froa che U.S. Department of Cctncerce, we eaphasiced chat technology has not been developed to the point chat facilities could be designed co meet a reasonable standard. However, .analytical techniques suggest a conceptual design using adsorption, fettling and filtration of aqueous waste, followed by incineration of the adsorbent, probably carbon. Ve estimate che capital cost of such a facility, sioed co handle our plant w:e it $600,000, not including a dedicated incinerator for Che disposal of che adsorbent material. Annual operating coat would approximate $150,000. The value of Monsanto's annual PC3 production is about $8 million, while Che value of che electrical devices made therefrom is an order of nagnicude larger. If Monsanto were to cease production of PC3s, the jobs of 55 employees would be eliminated directly, while those of an additional 47 employees in a supporting facility would be in Jeopardy. The total payroll involved is on Che order of $1.5 million. The impact of a PC3 ban on our customers can best be described by them. However, it is apparent that capacitors or'transformers made without PCSa will be less fire-resistant chan present products, thus leading to an undeterminable incidence of fires, higher insurance rates, and additional protection facilities. In the case of capacitors, Che replacements are likely to be larger and less efficient, thus consuming more of che resources required in their manufacture. A mere complete 137 1 DOT Or, HARTOLDMON0034737 analysis of the consequences of * PC3 ben ves developed by the General Electric Company end addressed to Dr. Kartha Sager, Chaimer., Effluent Standards and Veter Quality Advisory Committee, E?A (43). Ve concur vith the Ceneral Electric Company's conclusions. Our purpoae in commenting on the proposed standards is to aid the Agency in the development of realistic effluent standards vhich will achieve the intended objectives vithout serious technical, social and - economic disruptions. We recognize the aeriousness of thia endeavor and find a statenenc nade by Hr. John R. Quarles, Jr., Deputy Adninistracor Environmental Protection Agency, of considerable interest. At a recent conference, Hr. Quarles (26) anted: "Ve have found it virtually inpossible to devise intelligent standards vhich apecify an appropriate degree of control over toxic pollutants irrespective of the aources of those pollutants and factors affecting the feasibility and timing of their abatenent." . The difficulties vhich could be anticipated in establishing effluent standards vere recogr.iced by the National Academy of Science in its preparation of Vater Quality Criteria, 1972. In a reviev vhich appeared in the Environmental Reporter (3S) dated August 24 , 1973 , the following pertinent stacener.ts highlight some of the areas of concern: _ "Knowledge of local environmental conditions is essential prior to application of any vater quality recommendations for marine aquatic life and vildlife.. '`NAS said application of recomendations to a local situation is unique because it requires an ur.der' standing of the circulation of vater and the resultant nixing and dilution of pollutants, a knowledge of bio logical species and determination of the most sensitive species, and an evaluation of the transport of nateriila through the food veb." "XAS aiid it is not practical to cake recomendations for the relatively persistent organic pollutant based on vater concentration, especially vhen partition coefficients are unknown." 1S 3 lOOTCh HARTOLDMON0034738 7e cm apprsciata Hr. Quarles' cooeam, particularly as it applies Co ?C3a. Lacking good scientific inforaation on Che fata and affects of PC3a in ccrplex water syscens each having unique characteristics, vs urge extrene care ba taken Co avoid the prosulgaclon of effluent standards which ara unattainable and urvarrancad. Ky Cocnission expires \i. m s" \ is s HARTOLDMON0034739