Document 99JdR26y0xR5zbNKM4dov4R26

r* 1 MONSANTO-INDUSTRIAL CHEMICALS CO. 6 0 0 N. Lindbergh Boulovard S t. Louis- M is ro u n 63166 Phone: (3141 6 6 4 -1 0 0 0 March 24, 1976 SPECIALTY ChCUICM-S C-.'WJ C-V Mr. C, M. Timm, Director Surveillance & Analysis Div. U. S. Environmental Protection Agency, Region V 230 South Dearborn St. Chicago, IL 60604 \ g Dear Mr. Timm: Confirming my conversation with Mr. Marcyn, I will appear on your panel to discuss PCBs. I plan to arrive on the morning of May 19th and leatfe after lunch. If there is any information you need, please let me know. Sincerely yours, J. Coleman Weber Manager, Product Acceptability mh unitolMonsanto Comcanv ACM CC65CS UNITED STA TES en v ir o n m e n t a l pro tectio n a g en c y REGION V 230 SO UTH DEARBO RN ST. CHICAGO. IL L IN O IS 60604 MAR 1 9 1973 Mr. J. C. Weber Monsanto Company 800 North Lindbergh Blvd. St. Louis, M0 63166 Dear Mr. Weber: A few days ago, Chester A. Marcyn of our Environmental Emergency Section discussed with you in a phone conversation the possibi1ity that your company might provide the services of a panelist for one of our sessions at the coming Hazardous Materials Pollution Control Symposium. Any treatment of the subject of polychlorinated biphen yls would be incomplete today without opinions expressed by a representative of the Monsanto Company and we would be pleased to see such representation. Featured In the sessions will be the elements of field response techniques including neutralization, cleanup, and disposal of various materials. As you know, the symposium to be held in Chicago on May 18, 19, and 20, 1976 Is co-sponsored by the U.S. Coast Guard and the U.S. Environmental Protection Agency. These presentations have been well received in the past and we expect a good turnout of Federal, State, and local agency people as well as industry representatives. The program has essentially been established according to the enclosed draft agenda. Program scheduling and other arrangements can be discussed with Mr. Marcyn by writing or calling 312-353-5813- It is hoped that you will soon name your choice for panelist for our symposium. We are looking forward to working with you on this essential environmental task. Sincerely yours, / C hristopher M. Timm, D ire ctor Surveillance G Analysis Division ACM CCbSIC c > '* V " ) * - . .v>. - 'r.-fK;''- -* ? \.V ' -r ' :'' - V , - : / ' V il-. (DRAFT COPY) HAZARDOUS MATERIALS POLLUTION CONTROL . SYMPOSIUM FIELD RESPONSE MAY 18, 19, 20, 1976 . SHERATON-O'HARE NORTH MOTOR HOTEL CHICAGO, IL (ROSEKONT) co-sponsored by U.S. ENVIRONMENTAL PROTECTION AGENCY REGION V U.S. COAST GUARD DISTRICTS TWO AND NINE Tuesday Morning, May IB 8:30 - 9:00 Registration $ 9:00 - 9:20 introduction and Welcome George R. Alexander, Regional Administrator,' U.S. Environmental Protection Agency, Region V, Chicago, IL RADM J. S. Gracey, Commandant, U.S. Coast Guard District Nine, Cleveland, OH HAZARDOUS SUBSTANCES AND REGULATIONS Moderator: Chester A. Marcyn, Environmental Emergency Section, U.S. EPA Region V, Chicago, IL. 9:20 - 9:45 Hazardous Substances Pollution - The National Scene Kenneth E. Biglane, Director, Oil and Special Materials Division, U.S. EPA, Washington, DC 9:45 - 10:25 Status of the Federal Hazardous Substances Regulations Henry D. VanCleave, Oil and Special Materials Division, U.S. EPA, Washington, DC 10:25 - 10:45 BREAK 10:45 - 11:15 The U.S. Coast Guard and Hazardous Cargo Transport Cmdr. Robert E. Ettle, U.S. Coast Guard District Nine, Cleveland, OH 11:15 - 11:45 State Regulations on Hazardous Materials Delbert D. Haschemeyer, Office of Legal^ Affairs, Illinois Environmental Protection Agency, Srpingfield, IL .,^11:45 - 1:15 L UK C H ACM OC8511 .Tuesday Afternoon May 18 ' Panel: HAZARDOUS MATERIALS IN RAILROAD ACCIDENTS 'Moderator: Aifred- C. Smith, Michigan-Ohio District Office, U.S. ERA Region V, Cleveland, OH 1:15 - 1:55 Handling of Railroad Cars in Derailments Art Proefrock, Hulcher Emergency Service, Inc. Virden, IL 1:55 - 2:25 2:25 - 2:45 Panelists Gene Schlaf, Illinois Central Gulf Railroad, Chicago, IL Ed Pritchard, Federal Railroad Administration, Chicago, IL C. D. Bossard, Bureau of Explosives, Chicago, IL it Discussion 2:45 - 3:05 BREAK Panel: PESTICIDE AND MIXED CHEMICAL FIRES Moderator: Dr. Mitchell Wrich, Air and Hazardous Materials Division, U.S. EPA Region V, Chicago, IL 3:05 - 3:35 Some Recent Plant Fires in Ohio Alfred C. Smith, Michigan-Ohio District Office, U.S. EPA Rgion V, Cleveland, OH 3:35 - 4:05 Panelists: Dr. John Jordan, Air and Hazardous Materials Division, U.S. EPA Region V, Chicago, IL Joseph Palatini, Pennwalt Corp., Delaware, OH Dr. Donald P. Morgan, Iowa University College of Medicine, Iowa City, IA Curtis Golden, Air and Hazardous Materials Division, U.S. EPA Region V, Chicago, IL 4:05 - 4:30 Discussion v\ . ACM 'CC fc5 12 Wednesday Morning, May 19 Panel: ACRYLONITRILE AND VINYL CHLORIDE Moderator: Anthony Rutter, Indiana District Office, U.S, EPA Region V, Evansville, IN 8:30 - 9:00 Experiences with Acrylonitrile Spills George Moein, U.S. EPA Region IV, Atlanta, GA 9:00 - 9:30 ' Panelists Donald-Goodwin, National A1r Pollution Center, Research Triangle Park Gene Schlaf, Illinois Central Gulf Railroad, Chicago, IL Byron Denenberg, MDA Scientific, Inc. Park Ridge, IL p 3 0 - 10:00 .10:00 10:20 ** Discussion BREAK Panel: POLYCHLORINATED BIPHENYLS Moderator: Dr. Billy Fairless, Central Regional Laboratory, U.S. EPA Region V, Chicago, IL 10:20 - 10:50 1 PCB Perspectives Karl E. Bremer, Surveillance and Analysis Division, U.S. EPA Region V, Chicago, IL 10:50 - 11:20 11:20 - 11:45 Panelists George Moein, U.S. EPA Region IV, Atlanta, GA Donald Heal ton, Food and Drug Administration, Region V, Chicago, IL (To be named), Monsanto Company, St. Louis, MO U> ***. Discussion 11:45 - 1:15 LUNCH Wednesday Afternoon. Hay T9 A .Panel: PHENOL - CRESOL - CRESOTE Moderator: Samuel Mason, Michigan-Ohio District Office, U.S. EPA Region V, Cleveland, OH > * *> CCfi 5 i3 Wednesday Afternoon, May T9 (Cont.) 1:15 - 1:45 Phenol: Its Treatment and Removal William M. Throcp, Environmental. Sciences Division,Envirex Co., Milwaukee, WI 1:45 - 2:15 Panelists Richard Kramkowski, National Institute of Occupational Safety and Health, DHEW, Region V, Chicago, IL Charles J. Rogers, NERC, U.S. EPA, Cincinnati, OH (To be named), Koppers Co., Pittsburgh, PA 2:15 - 2:45 Discussion 2:45 - 3:05 BREAK 9 Panel: LIQUEFIED GASES: AMMONIA, CHLORINE Moderator: Russell Diefenbach, Environmental Emergency Section, U.'S. EPA Region V, Chicago, IL 3:05 - 3:35 Experiences with Chlorine Fritz Zorn, Chlorep Committee^ Chlorine Institute, Inc. and BASF Wyandotte Corp., Wyandotte, MI 3:35 - 4:05 * Panelists George W. Feldmann, E.I. DuPont Co., Wilmington, DE (To be named), Illinois Fertilizer & Chemical Association, Inc., St. Anne, IL Byron Denenberg, MDA Scientific, Inc., Park Ridge, IL Jack Coblenz, Illinois Environmental Protection Agency, Springfield, IL r; v\ ACM CC6514 Thrusday Horning, Hay 20 DATA SOURCES - PROTECTION - COUNTERMEASURES Moderator: Clarence Oster, Minnesota-Wisconsin District Office, U.S. EPA Region V, Minneapolis, MN 8:30 - 8:50 Protective Suits for Handling Hazardous Materials LTJG Keith R. Nicholson, U.S. Coast Guard, Washington, DC 8:50 - 9:10 Field Response Experiences (To be named). Tech Escort Center, Aberdeen Proving Grounds, MD 1:10 - 10:00 0:00 - 10:20 flO:20 - 10:50 I. The CHRIS Data System in Spill Situations LT Richard Harding, U.S. Coast Guard, Washington, DC $ BREAK *# EPA - sponsored Development of Containment Devices. Dr. Joseph Lafornara, EPA Industrial Environmental Research Laboratory, Edison, NJ 10:50 - 11:25 Response to Spills on Large Water Bodies or Busy River Systems Stanley W. Whitebloom, Metropolitan Sanitary District of Greater Chicago, Chicago, ll\ 11:25 - 11:45 Predicting the Hazards of Organics at the Air-Water Interface W. Brock Neely, Dow Chemical U.S.A., I Midland, MI i i 11:45 - 1:15 LUNCH Thursday Afternoon, May 20 ' 1:15 - 1:40 Transfer and Disposal of Hazardous Materials Robert Meier, Waste Management, Inc., Oakbrook, IL 1:40 - 2:05 The Role of the Contractor in Spill Response David Usher, President, Oil Spill Control Association of America, Southfield, MI 2:05 - 4:30 Presentation of Available Equipment and Supplies: An Open Forum i ACM C08515 c f - TV 'K-.V -6-* ' *K, i.fi- - - v +. `\ : - , -... . v:- v* "'i- ." . \.V V- i. ~i J . february 21, 1974 Sr. Sidney X. 0*11er Deputy Assistant Secretary for Environmental Affairs Office of the Aseletant Secretary of Commerce , 0. 8. Department of Commerce Hain Coaneree Building 14th Street A Constitution Avenue, M.V. Washington, D.C. 20230 Dear Dr. Oalleri Tour letter to Hr. Warren Easley dated January 15, 1974 as forwarded.to me to respond with eonments relatif .to the proposed effluent standard for polychlorinated .biphenyls (KBs), With regard to the five points listed, we have the fol lowing Information to offers 1. Can the proposed standards be met by existing tech no logyt Mo. There is evidence to Indicate that poly chlorinated biphenyls can be removed from water by absolution or adsorption by particulate matter such as clays and soils. In fact, ourrently-used analytical methodology utilises this characteristic, further studies will be required to determine the best method for disposal of the contaminated solid waste which would result. A detailed manufacturing process, engineering design, capital oost and manufacturing coat have not been com pleted or determined. The cost would be substantial. There Is no "turn key" tech nology available to industry. Dr. Sidney R. Oaller February 2l# 197^ Page 2. 2. If the technology to meet standards applicable to your operatlon(s) exista, please describe any poten tial problems you foresee in applying the technology within the proposed time period. Assuming the technology discussed in (l) above could be made available, we estimate 24 to 30 months may be required for the design, procurement, installation and demon stration of the facilities. The situation, as it relates to Monsanto1a polychlorinated biphenyl-producing unit, is further compli cated because of the yet-unknown requirements which will be imposed for the local and re gional waste treatment systems which are now being planned. We do not know specifically the situation as it would pertain to the users of chlorinated biphenyls and we suggest, they be contacted for their views. 3. Describe the manner and extent to which meeting the standards would impact upon your energy requirements. If the adsorption technology proves effec tive, large quantities of solid material containing polychlorinated biphenyls will be generated. Disposal of this waste will require incineration which will consume a considerable amount of fuel. Ihe quantity cannot be determined until pilot studies are completed, 4. If the standards are to be met, describe the antici pated economic and social Impact as reflected in the following: a. Plant closings. b. Employee layoffs. c. Projected Increase in capital and operating costs as reflected in finished product coat. d. Termination lz^.manufacture or consumption of products. ACW C 0 6 5 1 7 Dr. Sidney R. daller February 21, 1974 Page 2- If practical technology remains unavailable, the low effluent standard proposed cannot be met. This could lead to forced termina tion of the manufacture and use of polychlori nated biphenyls. Monsanto's PCB operations directly utilize 25 employees with an addi tional 30 In supporting service functions. In addition, the unit which supplies the Inter mediate raw material Involves 47 employees who would also be laid off If no alternative use of the material can be developed. The current users of polychlorinated biphenyls, electrical capacitor and transformer manu facturers and their customers, will also be affected and we believe the extent of the economic and social Impact would be considerable. Representatives of the capa citor and transformer manufacturers and the power distribution industry can provide more specific Information and should be con tacted. Sincerely, WBF/b t cc: Mr. K. V. Easley Washington, D.C. V. B. Papageorge Manager, Product Acceptability Functional Product Oroups \ ACM C06 5 18 . f J a n u a r y 15, 1974 n c s i r c n e t u c A.s ? ! 5 T /*r*it t F r o r T a r v / W . '5 n , "j : - n . O.C 2 2 Z 3 0 * " * " Dr. W arren Easley Monsanto Company 1101 16th S t r e e t , N. W. Room 604 W ashington, D, C. 20036 Dear Dr. Easley: $ Section 307 of the F e d e ra l W ater Pollution Control Act A m e n d m e n ts of 1972 (P ublic Law 92-500) r e q u ir e s the Environm ental Protection Agency (EPA) to publish a list of toxic pollutants and to propose effluent stan d ard s. for such pollutants.. In accordance with this req u irem en t, EPA published on S ep tem b er 7, 1973, a lis t which includes ald rin , d i e l ^ i n , *nrfTin; benzidine, cad m iu m , cvanide. DDT, DDE, DDD, m e rc u ry , polychlorinated biphenyls, and toxaphene. The law re q u ire s EPA to review and re v ise this list from tim e to tim e . On D ecem b er 27, 1973, E P A pro p o sed effluent standards for th ese toxic pollutants. A copy of the proposed standards is enclosed. EPA has established a 90-day period for comments. In addition to any co m m en ts w hich you m ay subm it to EPA , this Office is interested in obtaining your views on the proposed sta n d a rd s, p a rtic u la rly with re g a rd to the compounds listed which y o u r com p an y p ro d u c e s o r c o n su m e s. We a r e re q u e stin g your views so that they m ay be considered in form ulating com m ents which the D ep artm en t of C o m m erce plans to provide to EPA within the prescribed 90-day period. \ j ACM C06519 2 We would, in p a r tic u la r , like to have you a d d r e s s the five points listed below. P lease include the m axim um am ount of specific quantitative inform ation to s u p p o rty o u r view s. 1. C an th e p r o p o s e d s t a n d a r d s be m e t by e x is tin g te c h n o lo g y '1 2. If the technology to m eet standards applicable to your o p eratio n s) exists, please describe any potential p ro b le m s you fo re s e e in applying the technology within the proposed tim e period. 3. D escrib e the m a n n e r and extent to^which m eeting the standards would im pact upon your energy requirem ents, 4. If the standards a re to be m et, d escrib e the anticipated econom ic and social im pact as reflected in the following: a. Plant closings. b. i^mpioyee lay o ils. c. P ro je c te d in crease in capital and operating costs as refle cted in finished product cost. d. T erm in atio n in m anufacture or consum ption of products. 5. A re there any other points you wish to make regarding the inclusion of compounds on the list? P lea se support your . position with health effects or other relevant data. We recognize that developing this inform ation m ay take considerable tim e and effort; how ever, in o rd e r for us to effectively consider any in fo rm atio n you develop, we m u st rece iv e your re sp o n se by F e b ru a ry 18, 1974. \ ACK CC652C i V 3 9 t t > t 5 i ri i \ If you also file co m m en ts with EPA on the p ro p o sed s ta n d a rd s , we would appreciate receiving a copy of th le tte r. Sincerely, Deputy A ssistant S ecretary for Environm ental Affairs $ E n c lo s u re : E P A - N otice of P r o p o s e d Rule M aking (40 CFR P a r t 129) T oxic P o llu ta n t E fflu e n t S ta n d a rd s i | I J i ! Vl e \ t '[7 'i1I I *. J* L.N1T5D S T A T E S E N V I R O N M E N T A L P R C T E C T : C N A G E N C Y W A S H IN G T O N 0 Z 2C-160 Mr. W.R. Corey Director, T05CA Administration Monsanto Company 800 ii. Lindbergh Boulevard St. Louis, MO 63166 y Z ^ - ' C E O F ~ O a C S L 3 S " >i NOV 2 1 13 70 $ This letter is to acknowledge receipt of your petition for exemptions) from the Processing and Distribution in Commerce Bans on PCBs as provided in 40 CFR 761 (See 44 FR 31558, Kay 31, 1979). Acceptance of this petition does not mean the Environmental Protection Agency (EPA) has decided to grant your exemption request(s), nor does it mean that EPA is expressing any opinions on the merits of your petition. At this time we cannot respond to each petition individually as to its completeness due to the large number of petitions received. Processing of petitions that fail to respond to the questions identified in 44 FR 31560 will be delayed. Therefore, we refer you to the "Processing and Distribution in Commerce Exemption Procedural Rules," on page 31560 of the Federal Register of Hay 31, 1979, to verify that you have submitted a complete petition and that it conforms to the procedural requirements. While your petition is being evaluated you may continue the processing and/or distribution in commerce activity or activities for which you have petitioned for exemption. As stated in 44 FR at 31559, May 31, 1979: Any person who petitions EPA by July 1, 1979 to continue processing or distribution in commerce after July 1, 1979 may continue his activity until EPA rules on-his petition. v ACM C C & 5 Z Z 2Attached to this letter is a checklist indicating materials which the Agency has recieved from you as of this date. The Agency will contact you by separate letter if any additional information is required to assist us in our review, or if your petition contains questions directed at the Agency concerning factual or legal matters. If you have any questions about this letter, please contact Peg Velie at (202) 755*0920. \ \ AC* CC8523 Checklist Your correspondence regarding this exemption has been filed in the Official Rulemaking Record for Section (6) TSCA, OTS Docket No. 066002. _ y _ Petition for exemption, Dated A S ,f t Verification of continuing need for petition for exemption, Dated Additional data on original petition, Dated Correction to petition for exemption, D a t e d ____________________ ft Withdrawal of petition for exemption, Dated Confidential Information, Dated vv AD* C C t i t M t Monsanto M n sin to Cm pany 8 0 0 N. ltn trgn Boulevard St. Louis. M iia o u ri 63165 P h o n : C314) 6 6 4 - 1 0 0 0 June 28, 1979 Document Control Officer (TS-793) Office of Toxic Substances U. S. Environmental Protection Agency 401 M Street, S. W. Washington, D. C. 20450 St Attention: Docket Number CTS/C56002 (PC3/PDE) Re: Petition for Exemption from PC3 Processing' Prohibition Dear Sirs: Monsanto Company hereby petitions for exemption from the poly chlorinated biphenyl (PCS) processing prohibition under section 5(e)(3)(A)(ii) of the Toxic Substances Control Act (TCSCA). This request is made pursuant to section 750.31 of the Interim Procedural Rules for Processing and Distribution in Commerce Exemptions as published in the Federal Register, Volume 449 Number 106, dated May 31, 1979, beginning on page 31550. This petition specifically requests an exemption for a period of one year in order to continue using phthalocyanine pigments for the coloring of plastic materials in our plastics processing facilities at Springfield, Massachusetts; `Addyston, Ohio; Muscatine, Iowa; and Pensacola, Florida. Attached is a summary sheet providing the required information on cur Company, the location of sites needing exemption, and the estimated consumption of phthalocyanine pigments and amount of ?C3 contained therein at each site. - The plastic products in which phthalocyanine pigments are used `contain far less than 50 ppm PC3 because of the dilution that occurs when the pigment is mixed with the plastic materials being colored. It is our understanding that pigment producers have- efforts underway to develop alternative processes for man ufacturing phthalocyanine pigments without PCS contamination, and that changes are expected over a period of a year or two. We contend, therefore, that granting of this petition would net A CP CC 5 2 5 Doccent Control Officer (7S-793) June 28, 1979 Page Two. result In "an unreasonable risk of Injury to health or environ ment," and that-good faith efforts are being made "to develop a chemical substance which does not present an unreasonable risk of injury to health or environment" as stipulated, respectively, under sections 6(e)(3)(B)(i) and 6(e)(3)(3)(11) of TOSCA. In the meantime, we must continue to use the phthalocyanlne pigments now distributed in commerce, as substitute colorants are not available. The concentration of these pigments in our plastic materials ranges from the low parts per million (ppm) to about the two percent level. Our inability to use these pigments would affect approximately 200-300 million pounds of plastics production at our plants, and would result in either a curtailment of production or alternately severe economic di3-' location. We believe that the above fulfills the information requirements as described in section 750.31(d) of the Interim Procedural Rules, and Justifies granting this petition for exemption from the PCB ban. -- Sincerely yours, Attachment bcc: W. R. Corey N. B. Galluzzo R. H. Schlattman W. R. Corey Director TOSCA Administration \ ACM CC65* MONSANTO COMPANY ESTIMATED 1980 ?IGMNT/PCB VOLUME Monsanto location Monsanto Company Headquarters 800 N. Lindbergh Blvd. St. Louis, MO 63166 (314) 694-1000 Springfield Plant 730 Worchester Street Indian Orchard, MA 01151 Port Plastics Plant Addyston, OH 45001 Muscatine Plant P.O. Box 473 Muscatine, IO 52761 Pensacola Plant P.O. Box 12830 Pensacola, FL 32575 Pounds, Drv Basis Phthalocyanine ?C3 7,000 18,300 900 4,000 30,200 1.40 3.66 0.18 0.80 6.04 Notes: 1. Both phthalocyanine blues and greens are included. 2. The average PCB content of the phthalocyanine pigments is-assumed to be 200 ppm. 3. The pigments are introduced into a closed processing system for coloring the plastics materials. ACK CC8527  f if**"***, U N IT ED ST A T E S E N V IR O N M E N T A L PRO TEC TIO N A G EN C Y National Environmental Research Center Research-Triangle Park, North Carolina 27711 29 August 1975 Mr. Elmer P. Wheeler Manager, Environmental Health Medical Department Monsanto Company 300 N. Lindbergh Blvd. St. Louis, Missouri 63166 Dear Elmer: Enclosed are copies of recent papers concerning PCBs and DDT. I would appreciate your corranents particularly with regard to collective and analysis techniques and possible sources of PCBs. Is it plausible that the PCBs are formed from irradiation of DDT? Best regards. Sincerely yours t Enclosures James R. Smith Criteria and Special Studies Office \ r u U r . o i . ' s L ,;.~v: -rl ^ i**.'j i-- TM n L C w - t M W M i ^ r . s - V w 'v^i Annus! Reoort fcr the Year Ended 30 June 1975 CO iO Southern Caiifcrnls v_/\-. _. ----i :' Water;Research Frcjsc: 1500 East Imperial Hi El Secundo, California [1 \ J J 0:1 Jl" C _ w C* CC85i5 David R. Young and Theadore C. Heesen INPUTS OF DDT AND PCB With Che support of che U.S. Environmental Protection Agency, we have continued our investigation cr the input races of^ chlorinated hydrocarbons into che waters off southern California. The rain routes are municipal wastewaters, surface runoff, aerial fallout, direct industrial discharge, antifouling paint application, and ocean current advection. During the past year, we have concentrated our efforts on quantifying the inputs via the first four routes. One of che principal goals of this research has been to determine the concentrations and emissions of chlorinated hydrocarbon contaminants from the major municipal waste waters discharged to the Bight. During the 2 years of the study, we have analyzed a number of 1-week effluent com posites from each of southern California's six largest outfall systems, which account for approximately 95 percent of the submarine discharge of such wastewaters. Detailed intercalibration programs cn split samples have been con ducted with laboratories at che University of California and the University of 'Washington, and at the major sanita tion districts responsible for routine monitoring. One of our major conclusions from these intercalibrations is that che determinations of DDT compounds in Joint Water Pollution Control Plant (JKPC?) final effluent (once the dominant source of chlorinated hydrocarbons) made by che County Sanitation Districts of Los Angeles County have been in good agreement (20 percent) with those of the other laboratories since the beginning of chat monitoring effort in 1971. This is important in light of the fact that the JWPCP annual mass emission rate decreased from approximately 22.000 kg in 1971 (a mean effluent concentration of 42 fig/1) to 1,100 kg in 1974 ( a mean concentration of 3.0 ng/1): Because of the rapid changes, occasional surveys by outside laboratories such as ours could provide only a coarse evaluation of the effect\of control efforts in reducing coastal inputs that have teen dominated by this discharge. The agreement between the DDT determinations of the other major sanitation agencies and chose of outside 105 AC* CC653G laboratories was not as good, but the DDT levels in these effluents were generally quite lew (less than 0.3 ug/1, except for Hyperion's 7-mile sludge, which, was an order-of-nagnitude higher). The only other chlorinated hydrocarbon pesticide we have observed in local wastewaters is Dieldrin; typical concentrations now appear to be on the order of 0.1 p.g/1 or lever The situation for the polychlorinated biphenyls is less satisfactory. These industrial materials often are a com plex mixture of synthetic organic compounds that are diffi cult to identify and quantify by gas chromatography. For 1254 PC3, which has an average 54 percent chlorination, some degree of agreement on analytical data is new being reached between the outside laboratories and the monitoring agencies. However, major discrepancies still exist, and these must be resolved before confidence can be placed in this part of the effluent monitoringprograms. The most significant recent finding is that 1242 ?C3 appears to be the dominant known polychlorinated biphenyl in most of the local municipal wastewaters. Effluent levels of 1242 PC3 range from 0.1 to 3.0 ^ig/1, and Hyperion sludge contains 70 jig/1. In contrast to DDT compounds, PC3's are widely dis charged from submarine outfalls along the southern Cali fornia coast. A comparison of estimated 1974 mass emission races for total DDT and PC3 compounds in the major municipal wastewaters to the 3ight is given in Table 1. This com parison shows that approximately 90 percent of the DDT com pounds released with municipal wastewaters during 1974 came from the JVPCP discharge off Palos Verdes Peninsula, in spice of the fact chat control efforts instituted by the Los Angeles County Sanitation Districts in 1970 resulted in a 93 percent decrease in DDT waste emissions between 1971 Tabt* 1. Elhmatad 1974 annual m i tm<o>on rata of total ODT and total PCS diidtargad to tit* flig h t wia maior municipal .wattematari. Discharge R o w Total OOT Total PCE (mgd) fkg/yrl ik g jy rl Oxnard, Vantura Countv H yperon, Santa Monica Say 5-miia afftuanr 7-mila iludg* Total JWPCP, Paioi Varoat Pe*>niult Crangt County Sanitation Ontncts, Orange County Point Lorn*, San O'ago \ Total. Southern California Sight IQ 340 5 350 350 17Q 100 980 4 56 17 73 1,440 S4 14 1.600 una 5 160 790 950 2 .ICO 1,1 CO S.50Q JOS ACM CC6531 C ilc n n a c a Hydrccz, ns Tabta 2. Eitim atad 1372*73 annual m a n am ittion rataa of eh ion natad h y d r o a r b o n t carnad m to aoutharn C alifornia coattml w a ta n via n o rm Typ Volum ( 1 0 * cu m l Total D D T (kg/yr) Oiafdrin (kg/yr) PCB 1254 (kg/yr) Storm D ry Weather Tout D ry Weather 574" 127 701 18.I K 313 - 318 7.1 - 7.2 330 - 325 2.2X 61 6 4.9 66 5 7.4% 241 - 274 7.3 - 7.6 248 - 282 2 . 6 - 3.1% and 1974. Emission of PC3 compounds via these sources was much core uniform off Lcs Angeles, Orange, and San Dieg$ Councies; the highest: mass emission rate estimate ^(2,100 kg/yr, off Newport 3each) was only about two tines the lowest (950 kg/yr, into Santa Monica Bay). PC3's now constitute the major chlorinated hydrocarbon contaminant found in municipal wastewaters discharged to the 3ight, amounting to approximately three and one-half times the input of DDT compounds (5,500 vs. 1,600 kg/yr, respec tively). Other chlorinated pesticide inputs via this route appear to be relatively minor; Dieldrin is the only other pesticide we have observed, and its estimated 1974 mass emission rate from municipal wastewaters appears to be less chan 100 kg/yr. Because pesticides are often widely dispersed follow ing application in the field, surface runoff is generally assumed to be cr.e of the dominant modes of chlorinated hydrocarbon transport to the sea. To determine the impor tance of such inputs in southern California during Water Year 1971-72, we conducted an intensive sampling of storm runoff in four major channels flowing into the 3ighc. During the following year, we limited our efforts to cr.e of the largest of these channels, sampling the Los Angeles River over four storm periods. We also conducted two seasonal samplings of dry weather flow from ten channels widely spaced throughout the 3ight. On the basis of very satisfactory agreement obtained between Los Angeles River storm runoff results for the 2 years, we have used the 1971-72 flow-weighted mean con centrations in storm runoff to obtain Bight-wide mass emission rates for 'Water Year 1972-73. The results for this year, which was not unusually wet or dry, are summarized in Table 2. These d^ta indicate chat, although dry weather flow from the coastal plain con stituted approximately 20 percent of the total surface runoff during 1972-73, it accounted for only about 3 per cent of the mass emissions of chlorinated hydrocarbons 107 via this route.. Thus, mcsc or the surface transport cf these synthetic organic contaminants to the sea takes place during the few stormy days cf the year that occur in southern California. In addition to surface runoff, aerial'fallout is a I? (1- potentially-ir.p or ran r -ode for transport of chlorinate hydrocarbons to coastal waters. A technique of collet ing dry fallout particlas on glass plates sprayed with a hexane/mir.eral oil mixture has been used to determine the account of aerial inputs to the Southern California Sltht. Details of this fallout survey are presented in the following article. Our studies of chlorinated hydrocarbon inputs to the Southern California Sight via six routes curing 1973-74 have produced the results summarized in Table 3. This summary indicates that submarine discharge of municipal wastewaters is still the largest known source of chlorinated hydrocarbons entering he marine ecosystem from the coastal plain. Although there has been a dra matic decrease in the DDT contribution of this wastewater during the last 3 years, it is still seen to be about one-half the total coastal input, excluding ocean cur rent advection. However, the data indicate that aerial fallout is also an important route of entry for DDT and that surface runoff appears to be of secondary importance. = Municipal wastewaters are also the dominant known source of polychlorinated biphenyls. Of the 5.5C0 kg estimated to have been discharged via these wastewaters during 1974, approximately 80 percent was characterized as 1242 PCS and 20 percent as 1254 PCS. All of the large municipal systems make a significant contribution to this total, and it is important that more reliable monitoring data for ?C3's be obtained in the future. Table 3. Estim ated annual m a il am ission rat as or chlorinated h yd rocarbons vie b x routes to the Southern California Bight. Route Year Total D O T 1kg/yr) itldrin lkg/yrl Total PCS* lkg/yrl M u m c m l Wastewater Oirect Industrial Discnarge ISan Pedro 5av) Antifouling Pamr Surface R ungH Aerial Faifout Ocean Currents 1974 1973 1973 1973 1973-7* 1973 "9 0 oereent Irom JA P C P . 1.254 P C S : COG kg/yr. *1 2 5 4 PC S'O niy. 1.600' 20. <1 3 tO 1.300 7.000 SO S.S50 5 50 <1 <1 70 < 3 C 0 *" - i.scof - 4.000* 08 CM CC6533 CiofinCi'id H, ir^csrzcrs Cnly 1254 PC3 was detected in the aerial fallout samples, and a preliminary estimateof this input is about 1,500 kg/yr. k*e do not yet have a corresponding value for the lighter polychlorinated biphenyls such as 1242 ?C3. However, it appears that surface run off contains more 1242 than 1254 ?C3; thus, the aerial fallout contribution of the lighter polychlorinated biphenvls may also be significant. Surface runoff carries almost the same amounts of total DDT and 1254 PC3 to the coastal waters (about 300 kg/yr, each). Thus, preliminary estimates for the aerial fallout inputs of these contaminants (1,300 and 1,500 kg/yr, respectively) are in good agreement with the relative amounts found in runoff. An investigation of the importance of vessel anti- ^ fouling paints as a potential source of chlorinated hydrocarbons (particularly ?C3's) has demonstrated that, by 1973, this was a completely insignificant nede of i nputalthough it may have been an important source in the past. Our survey of approximately 40 industrial effluents being discharged directly into San Pedro and San Diego Harbors has produced no evidence that such discharges presently constitute a significant source of chlori nated hydrocarbons to the local marine waters. In conclusion, it appears that inputs of PC3 com pounds to the Southern California Bight from the adjacent coastal plain are several times larger chan chose of DDT compounds. In contrast to DDT, the major PC3 inputs are broadly distributed along the coast; thus, it may be considerably more difficult to obtain significant reduc tions in the quantities of PC3 reaching the local marine ecosystem. ACM CCB53<t David R. Young and Deirdre J. McDermott 'AEORFIADLDFTALLOUT The comparison of chlorinated hydrocarbon inputs presented in the previous article indicates that, during ^ 1973 and 1974, aerial fallout contributed almost as much DDT and its residues to the coastal ecosystem as did munici pal wastewater, the largest single source of the pesticide. In light of the decreasing concentrations of DDT in the municipal effluents, it appears that aerial transport will be the dominant input route of the future. Thus, with the support of the U.S. Environmental Protection Agency, we have investigated the fallout rates of chlorinated hydro carbons onto the 3ight in considerable detail over the last 2 years. Utilizing a glass plate and mineral oil collection technique first developed by Dr. Vance McClure (National Marine Fisheries Service, Tiburon, California), approximately 1,000 samples were taken in replicate 1-week collections made during two 13-week periods at 14 coastal stations ar.d 6 island stations between Point Conception and the U.S./ Mexico border. These samples have yielded a large body of data on several DDT compounds in dry aerial fallout, at levels free of apparent chromatographic interferences or significant contributions from analytical blanks. The results for p,p,'-DDT, and p,p'-DDE (plus p,p'-DDD for the second survey) have been converted to estimated mean daily fluxes (10*^ g/sq n/day) for each sampling, applying a collection efficiency factor of 50 percent. The Wilcoxon signed-rank test was used to determine if there was any statistically significant difference between the two seasonal values of total DDT fallout onto the Bight. Mone was demonstrated at 95 percent confidence level; therefore, the weekly data for the individual components were averaged over the entire 26-week collection period. Figure 1 pre sents the resultant mean for total DDT. The average ratio of p,p'-DDT to o,p'-DDT observed \n the Bight was 2.5 to 1, and these two isomers constituted approximately 70 percent of the "total" measurable flux of DDT compounds onto the Bight. In contrast, p,p'-DDE is the principal component /// CQb35 AC* P Figura 1. Average flu x of total D D T (1 0" g/sq m ;dav) in d ry aerial fallout, 1973-1974. U#W#| ^If I< observed in JL'PCP wastewater and in the ocean bottom sedi ments around Che sice of chis major discharge: Approxi mately three-quarters of Che total DDT is made up of p,p'-DDE in the surface sediment samples. Northern 3aja California is ofeen used as a control zone in Project studies; thus, during the first seasonal collection, a few weekly samples also were taken by stuoent volunteers at the Institution for Oceanographic Investiga tions, Universidad Autonoma de Baja California, in Ensenada, Mexico. The results indicated that one of the highest coastal flux values for total. DDT observed in the Bight during summer 1973 occurred at Ensenada. This is an agri cultural region of the 3aja California peninsula, and these higher fallout values appear to reflect greater or more recent local usage of DDT than to the north. One of the most striking results of this 3ighc-wide survey was chat, with the exception the Ensenada results, the total DDT fallout values generally increased toward Los Angeles. This was surprising, as the major agricultural areas of the coastal plain lie to the north and south of this highly-urbanized region. Because the results of this research had indicated that dry aerial fallout was a relatively important source of DDT compounds to the Bight, the project conducted its' own fallout survey within the Los Angeles Basin to further investigate this finding. 112 ACf CCc^3e Between 26 April and 24 May 1974, we sampled 24 sca tions during 4 successive weeks. 3ecause of the past history of dramatic DDT pollution of the 3ighc, apparently as a result of waste discharges from'Montrose Chemical Company, four stations were established within a few blocks of this industrial plant in the city of 'Torrance. Four sices also were established around the sanitary landfill in Rolling Hills Estates on the Palos Verdes Peninsula, oper ated by the County Sanitation Districts of Los Angeies County. It is reported that this landfill received DDT wastes from the Montrose plant up until about 1972. In addition, four sites were established around a private sanitary landfill owned by Sen K. Kazarian and located near the city of West Covina where the Montrose wastes are now taken. In this survey, both the DDT constituents and 1254 PC3 were clearly identified at levels at least an order of mag nitude above those found in process blanks. The results showed two regions of relatively high DDT fallout, located in the vicinity of the Montrose plant and the Rolling Hills sanitary landfill. The highest of the values in each region generally occurred at the south or southeast stations. As the prevailing coastal winds are from the northwest, this suggests two separate sources. Wind data for the interior of the Basin are being analyzed to further investi gate this subject. In light of the large gradients in DDT fallout rates that were observed, and the implications regarding the sources, the survey was repeated during 2 weeks in September 1974; two additional stations were included in the pattern arcur.d the Montrose plant. The September DDT data were similar to those of the previous spring and indicate little seasonal effect. The occurrence of an occasional anomalous value can strongly bias a small-sample mean, so for this basin study, we assumed the median of the six weekly values to be most representative of the fallout flux at a given station. These values for total DDT and 1254 PC3 are illustrated in Figures 2 and 3, respectively. The data presented above indicate an apparent rela tionship between the DDT fallout distribution and the loca tion of a major manufacturing facility and one of its past waste disposal sites. However, the level of DDT in the dry aerial fallout around the present disposal site (the Kazarian landfill) is not any higher than levels at other Basin stations. As the two principal constituents of the pesticide itself are p,p'-DDT and o,p'-DDT, we examined these two products of the manufacturing process in greater detail. We round a considerably larger value for Che ratio of p.p'-DDT to o,p'-DDT around the two regions of highest fallout (10 sices) than in the rest of che Basin 113 A CH CC6527 t Figure 2. M e d ia n flux of total D D T (1 0 ' g/sq m /day) in d ry aerial fallout collected during 6 weeks of 1974. Cs s ::j i j?.' (15 sices); -adan, valas for che evo groups are 5.0 and 3.2, respectively. This ratio nay be an indication of the relative "freshness" of the DDT constituents collected on our fallout plates. Similarly, the para and ortho isomers together constitute the largest percentage of total measurable DDT at these 10 sites; median percentages for the two groups are 85 percent and 63 percent. This too Figure 3. M edian Mux of 1254 PC S (1 0_ g/sq m /day) in d ry aerial fallout collected during 6 weeks of 1974. 114 ACK CC 6536 L/usnnaca r.,Qrzcjr;om -ay be related to effects of "weathering." Finally, to determine if the relatively high DDT fallout values around the manufacturing plant and its past waste depository could be due merely to higher deposition of particulates, we have normalized the values against 1254 PCB, which is not manufactured by Montrose Checmical Co. Distinctively higher values for this ratio are observed around the plant and the Roiling Hills landfill (median: 6.0) than in the rest of the basin (median: 1.2). Thus, it appears that the gradients in DDT fallout values we have observed do indicate two regions that are potentially important sources of DDT compounds to the Los Angeles Basin and the adjacent Southern California Bight. Two methods were used to calculate the amount of total DDT falling onto the basin annually. The first involved a strict linear interpolation between data points. For thosi stations where there were two or more sampling sites, the median flux was used to represent the station. It should be*noted that in the case of the Rolling Hills landfill, one sice has a significantly higher flux chan the other three sites. As this value is the median of six weekly values, and this site had the highest weekly flux reported for the entire Basin study, it appears that the site repre sents a secondary source or DDT. However, the median flux of 1,400 x 10"^ g DDT/sq m/day is a more representative value for that station. Because the location of sampling sites and the high values at Montrose bias the fallout estimate of 2.2 metric tons/yr derived from our contours, we consider this to be an upper limit. The median flux for the entire 3asin, 930 :< 10"^ g/sq m/day, was used to estimate a lower limit. The fallout estimate calculated using this value is 0.5 metric tons/yr, resulting in an estimated range of 0.5 to 2.2 metric tons/yr. Cne of tne most important aspects of these findings is that there still may be a significant release of DDT wastes to the southern California environment from the manufacture of this pesticide in Lcs Angeles County, even though the discharge of liquid wastes to the County sewer system has been stepped. During 1974, the average level of total DDT in JW?CP final effluent was 3.0 >i/l, which alone exceeds the level allowed by the California State i'ater Resources Control Beard "Ocean Plan" (2 fig/1 on a 50 percent . occurrence basis) for total identifiable chlorinated hydro carbons in such wastewaters. The corresponding mass emis sion rate for total DDT was 1,400 kg/yr. Ve have estimated that a similar quantity (1,300 kg) of DDT compounds fell onto the coastal waters annually during 1973-/4. A signi ficant fraction of this material may have emanated from DDT wastes produced during manufacture of the pesticide in Los Angeles County, either directly from the plant or from its original land waste disposal site. -Thus, a unified con- 115 ACM C08539 I Croi piar, co reduce narir.e inpurs of rhis politicane va-11 require char accencion also be paid co Chase parer.rial sources of DDT co che acnosphere in Los Angelas 3asin. $ \ 116 c CCfcS^C AERIAL FALLOUT OF DDT IN SOUTHERN CALIFORNIA David R. Young Deirdre J. McDermott Theodore C. Heesen * Southern California Coastal Water Research Project 1500 East Imperial Highway El Segundo, CA 90245 Submitted to : Bulletin of Environmental Contamination and Toxicology \ L At> CCc 5 1 DDT and its metabolites are among the most serious ccntamir.ar*3' yet identified in the marine environment (Risebrough et al., 1957: DeLong et al., 1973; McDermott et al., 1974). in past years, verv large quantities of DDT wastes were released into* the JWPCP* sewer system of the County Sanitation Districts of Los Angeles County (MacGregor, 1974) . These wastes, apparently produced by Mor.trcsa Chemical Company (during the manufacture of this pesticide) were subsequently discharged via the JWPCP submarine outfalls off Pales Verdes Peninsula to the marine ecosystem of the Southern California Bight (Figure 1). During the last 3 years we have investigated the input rates of DDT and other chlorinated hydrocarbons to the Bight via a number of different routes (Young et al., 1974; Risebrough et al., 1974). Here we report the results for'one of the routes, dry aerial fallout. In view of the very low rainfall in southern California, approximately 30 cm/yr, dry aerial fallout dominates aerial inputs along this section of the Pacific Coast. Utilizing a glass plate and mineral oil collection technique first developed by Dr. Vance McClure (National Marine Fisheries Service, La Jolla, California), approximately 1,000 samples were taken in replicate 1-week collections made during two 13-week periods** at 14 coastal stations and -6 island stations between Point Conception and the U.S./Mexico border. These samples have * . Joint Water Pollution control Plant **July-September 1973 and March - June 1974 \ 1 a c k ccas^ti yielded a large body of data en several DD7 corr.pounds in dr fallout, at levels free of apparent chbonatcgraphic interfe or significant contributions from analytical blanks. MATERIALS AMD METHODS The collection device for sampling dry aerial fallout vwass a piece of cleaned'window glass (0.1 square meter) sprayed with a mixture of pharmaceutical mineral oil (Squibb brand) diluted by five parts pesticide-grade hexane. A pair of cleaned plates wrapped in aluminum foil were taken to the collection site, unwrap and placed on a horizontal surface above the Aground. Genera lly this was the roof of a one-story structure located on or near the beach but removed from obstructions with large profiles which might cause excessive turbulence. Every effort was made to isolat the sampling plates from nearby painted surfaces, especially if the paint was flaking. If this was impossible, samples of rhe potentially contaminated material were taken for analysis. Once the plates were unwrapped and in place, they were sprays with a very light coat of the diluted mineral oil using a TIC sprayer (Chromatosprayer brand). The criterion followed was to apply enough oil so that the plate would trap small particles but not larger objects such as insects and feathers. Usually, spraying from a distance of about 0.3 meter for a period of abcuu 5 seconds was sufficient. After the hexane evaporated, this left roughly 0.3 ml of oil on the plate. ACM C065*3 At the end of the one week sampling period, a cleaned niece of teflon, cut with a 'straight edge, was used to scrape the mineral oil and fallout particles from the plate. The oil was transferred frcm the edge o.f the teflon strip to the inner rim of a pointed, graduated pyrex centrifuge tube. After several minutes of scraping, the plate was re-sprayed with diluted mineral oil and rescraped; this procedure was repeated for a third scraping. (Tests have indicated that this three-step process recovers more than 95% of the fallout material.) Then, the sample tube was covered with aluminum foil under a screw cap and returned to the laboratory. Before leaving the site the scraped sampling plates were re-sprayed to begin the next sampling period. Aerial fallout samples were processed through a "clean-up column" before being analyzed by gas chromatography. The' clean up column was a disposable 5 ml pipet packed with specially pre pared and activated silica gel. MCE Silica Gel (SX-144-6) IGC-ZCO mesh was washed with a 1:1 solution of methanol/benzene. Three milliliters of solution were used per one gram of adsorbent. After rinsing, the silica gel was dried in a*Rotovapor and activat at 180 overnight and then stored under hexane. The column was packed by inserting a plug of silane treated glass wool, adding several mis of hexane and slurrying the silica gel with a pipet. Using the markings on the 5 ml pipet as a guide, adsorbent was added until the volume of the compacted bed was-1.7 ml - 0.1 ml. A vibrator was held against the column briefly to compact the adsorbent. \ 3 At* C C t S ^ The fallout, samples came into the laboratory ir. cantrifuze tubes containing up to 1 ml of mineral toil. The slices of the ' tube were washed down with enough hexane to bring the volume to 3 mis. The sample was then introduced into the column using a pipet to transfer it from the centrifuge tube. The initial eiutaan was with 1.7 ml of hexane to remove the mineral oil from the column; this fraction was discarded. The DDT compounds were then eluted with 5.7 ml of 2C?s benzene/hexane. Dilutions of this fraction were made to appropriate volumes for analysis by electron capture gas chromatography. 8 RESULTS A13 DISCUSSION The results for p,p'-DDT, o,p'-DDT, and p,p'-DDE (plus p,p1-DCD for the second survey) have been converted to estimated mean daily fluxes (10 g/sq m/day) for each sampling, applying respective collection efficiency factors of 60, 64, 36 and 63 percent. The Wilc'oxon signed-rank test was used to determine if there was any statistically significant difference between the two seasonal values of total DDT fallout onto the Bight. None was demonstrated at the 95 percent confidence level; therefore, the weekly data for the individual components were averaged over the entire 26-week collection period. Figure 1 presents the resultant mean for total DDT. The average ratio of p,p'-DDT to o,p'-DDT observed in the Bight was 2.5 to 1, and these two isomers constituted approximately 70 percent of the "total" measurable flux of DDT compounds onto the Bight. In contrast, we have observed that approximately 4 ALI* GC5 three-quarters of the total DDT in ocean bottom sediments around the site of the JV/PCP outfalls is made-up of p,p'-DDE and the principal components of the wastewaters discharged are p,?'-DDS and p,p'-DDD. During the first seasonal collections a few weekly samples also were taken in Ensenada, Mexico. The results indicated that one of the highes-t coastal flux values for total DDT observad in * the Bight during summer 1973 occurred at Ensenada. This is an agricultural region of the Baja California peninsula, and these higher fallout values appear to reflect greater or more recent local usage of DDT than to the north. # One of the most striking results of this Bight-wide survey was that, with the exception of the Ensenada results, the total DDT fallout values generally increased toward Los Angeles. This was surprising, as the major agricultural,areas of the coastal plain lie to the north and south of this highly-urbanized region. Because the results of our research had indicated that dry aerial fallout was a relatively important source of DDT compounds to the Bight, we conducted a fallout survey within the Los Angeles Basin to further investigate this finding. Between 26 April and 24 May 1974, we sampled 24 Basin stations during 4 successive weeks. Because of the past history of dramaoic DDT pollution of the Bight, apparently as a result of'waste dis charges from Montrose Chemical Company, four stations were astablis within a few blocks of this industrial plant located in a suburb t of Los Angeles. Four sites also were established around the sani- \ tary landfill in Rolling Hills Estates on the Palos Verdes Peninsuj. 5 AC* C C 854 fc operated by tbs County Sanitation Districts of Los Angelas Countv. 9* It is reported that this landfill received DDT wastes from the Montrose plant up until about 1972. In addition, four sites .were established around a private sanitary landfill owned by Ben K. Kazarian and-located near the city of West Covina where the Montrose wastes are now taken. *, In this survey, the DDT constituents were clearly identified, at levels at least an order of magnitude above those found in process blanks. The results showed two regions of relatively high DDT fallout, located in the vicinity of the Montrose plant' Q and the Rolling Hills sanitary landfill. The highest of the values * in each region generally occurred at the south or southeast stations As the prevailing coastal winds are from the northwest, this sug gests two separate sources. In light of the large gradients in DDT fallout rates that' were observed, and the implications regarding the sources, th survey was repeated during 2 weeks in September 1974; two additional stations were included in the pattern around the Montrose plant. The September DDT data were similar to those-of the previous spring and indicate little seasonal effect. The occurrence of an occasional anomalous value can strongly bias a small-sample mean, so for this basin study, we assumed the median of the six weekly values to be most representative of the fallout flux at a given station. The values for total DDT are illustrated in Figure 2. V \ 6 ACM CCd5*7 The daca presented above indicate an apparent relations'-_o between the DDT fallout distribution and the location of a major manufacturing facility and oneof its past waste disposal sites. However, the level of DDT in the dry aerial fallout around the present disposal site (the Kazarian landfill) was not any higher than levels at other Basin stations. As the two principal con stituents of the pesticide itself are p,d '-DDT and o , p '-DDT, we examined these two products of the manufacturing process in greater detail. We found a considerably larger value for the ratio of p,p*-DDT to o,p'-DDT around the two Regions of highest fallout (10 sites) than in the rest of the 3asin (15 sites); median values for the two groups were 5.0 and 3.2, respectively.. This ratio may be an indication of the relative "freshness" of the DDT constituents collected on our fallout plates. Similarly, p,p'-DDT and o,p'-DDT together constituted the largest per centage of total measurable DDT at these 10 sites; median percentages for the two groups were 85 percent and 63 percent. This too may be related to effects of "weathering." Finally, to determine if the relatively high DDT fallout values around the manufacturing plant and its past waste depository could be due merely to higher deposition of particulates, we normalized the values against 1254 P23, which is not manufactured by Montrose Chemical Co. Distinctively higher values for this ratio were observed around the plant and the Rolling Hills landfill (median: 6.0) than in the rest of the basin (median: 1.2). Thus, it appears that the gradients in DDT fallout values we >have observed do indicate two regions \ that are potentially important sources of DDT compounds to the 7 AC* C C t r*t Two methods were used to calculate the amount of total DO? falling onto the basin annually. The first involved a strict linear interpolation between data points. For those stations where there were two or more sampling sites, the median flux was used to represent the station. It should be noted that in the case of the Rolling Hills landfill, one site had a significantly higher flux than the other three sites. As this value was the median of six weekly values, and this site had the single highest weekly flux reported for the entire Basin study, it appears that the site represents a secondary source of DDT. However, the median * flux for the four sites around the landfill (1,400 x 10-- 9 g DDT/sc m/day) is a more representative value for that region. Because the location of sampling sites and the high values at Montrose biased the fallout estimate of 2.2 metric tons/yr derived from our contours, we consider this to be an upper limit. The median flux for the entire Easin, 930 x 10--9 g/sq m/day, was used to estimate a lower limit. The fallout estimate calculated using this value is 0.5 metric tons/yr, resulting in an estimated range of 0.5 to 2.2 metric tons/yr. One of the most important aspects of these findings is that there still may be a significant release of DDT wastes to the southern California environment from the manufacture of this pesticide in Los Angeles County, even though the discharge of liquid wastes to the County sewer system has been stopped. During i 1974, the average level of total DDT in J7JPCP final effluent was 3.0 10 ^ g/1* which alone exceeded the level allowed by the State of 8 ACM CC654S California Water Quality Control Plan for Ocean '.raters of California (State Water Resources Control 3oard, 1972) for total: identifiable chlorinated hydrocarbons in such wastewaters (2 :< on a 50 percent occurrence basis). The corresponding nass emission rate for total DDT was 1.4 metric tons/yr. From the results of our two seasonal surveys, we estimate thata similar quantity (1.3 metric tons/yr) of DDT compounds fell onto the coastal waters annually during 1973-74. A significant fraction of this material nay have emanated from DDT wastes produced during nanu- facture of the pesticide in Los Angeles County, either directly from the plant or from its original land wast disposal site. Thus, a unified control plan to reduce marine inputs of this pollutant would require that attention also be paid to these potential sources of DDT to the atmosphere in Los Angeles Basin. ACKNOWLEDGEMENTS We thank Project members M. Westbrook, J. Johnson, M. Moore, and P. Smokier for participating in the field collections, E. 3erkih.j-sr and I. Szpila for assisting in the laboratory i analyses, and L. Schweizer and C. Moffatt for assisting in data reduction. We gratefully acknowledge the following individuals for their assistance in obtaining samples from the various islands off southern California: San. Miguel Island, Dr. R. de Long (National Marine Fisheries Service, Seattle); Santa Cruz Island, L. Laughlin (Channel Island Field Station, University of California, Santa Barbara) ; Anacapa Island, William and Mark Conr.ali (Island Packers, Co., Ventura) and Superintendent W. Ehorn 9 ACK CC655C San Nicolas Island, Chief R. Anderson (U.S. Navy, San Nicolas Island); Santa Catalina Island, Dr. R. Given (Santa Catalina Marine Laboratory, University of Southern California, Los Angel and San C-lem.ente Island, Lt. Commander Xay (U.S.'Navy, San Clem Island). We also thank G.C. Barragan (Universidad Autonona as Baja California, Ensendada) for collecting the Ensenada, Mexico samples. This research was conducted under a research grant (R801153) from the U.S. Environmental Protection Agency. Con tribution number 46 of the Southern California Coastal Water Research Project. $ REFERENCES De Long, R.L., W.G. Gilmartin, and J.G. Simpson: Science, 131, 1168 (1973). MacGregor, J.S.: Fish. Bull. N.M.F.S., 12_, 275 (1974). McDermott, D.J., T.C. Heesen, and D.R. Young: Rept. 217, So. Calif. Coastal Water Res. Proj., El Segundo (1974). Risebrougn, R.W., D.S. Menzel, D.J. Martin, Jun., and H.S. Olco Nature, 216, 589 (1967). Risebrough, R.W., D.R. Young, T. Munson, M. Goodwin, and R. Par Proceedings of the Marine Bioassav Evaluation Workshop, Montauk, Long Island, April 9-11, 1974. State water Resources Control 3oard, State of California: 'Mate Quality Control Plan (1972). Young, D.R., T.C. Heesen, D.J. McDermott, and P.E. Smokier: Rept. 212, So. Calif. Coastal Water Res. Proj., El Segundo (19 FIGURE CAPTIOUS --9 Figure 1. Average flux of total DDT -(10 g/sq m/day) via dry aerial fallout collected in the Southern California 3ight during 1973-74. Figure 2. Median flux of total DDT {10-- 9 g/sq m/day) via dry aerial fallout collected in the Los Angeles Basin during 6 weeks of 1974. \ AUP CCES5i ach 3 i 1 o o1 o VP VP ( i t I rl i t t f/ 120W U9W 1IBW 11JW * < r r p toward elirtincin^ the use of this substance and its associated threat to human health and the environment. 1 welcome this development and commend the Monsanto Company on its decision. A year ago EPA undertook a series of activities designed to examine and deal with the. PCB problem which had become one of national dimensions. In December I announced a PCB action plan to focus the efforts of government and.industry on solving this problem. I indicated tltfcn that although the government had no copprehensive regulatory authority to deal with the problem, our national goal should be to phase out all uses of PCBs as rapidly as possible. I am gratified by the cooperation of industry -- both manufacturer and user -- that has led to the Monsanto decision. Since last December, EPA has been working with Monsanto, the major manufacturers of transformers and capacitors, and other Federal agencies to ancou^asP the development of safe and environmentally acceptable alternatives. Environmental contamination will continue to be a problem due to the millions of pouods of PCEs already in landfills, soils, river and lake sediments, % in our air and water, and in wildlife and human tissue. This contamination will be there for years, moving into life systems, including humans. The problems still need to be addressed vigorously by government and industry. However, the Monsanto decision is a significant step in dealing with the total problem of PCB contemplation. AC* CG8555 April-24', 1972 MniCRAKDU'i TO: All Regions! Administrators FROM: Assistant Administrator `for Enforcement and General Counsel SUBJECT: Policy on FCB'c 9 Until further notice, the following policy should be followed by the r e m i t Program wiLh reapers to processing of permits for sources of Polychlorinated Biphenyl discharges. It is understood, of course, that by reason of the Eiscrice Court injunction in Kalur v, Resor, no permit may be actually issued at the present t' :. ^ It is the policy of the Enviror.m''".tal Protection .'.gcncy that all / disch-rgcs to the aquatic envirt `..lent involving Polychlorinated (PCB'i.) be restricted to the lowest possible level. The goal of the ' . policy is to achieve levels in the environment su/fici' itly low that fic'i . and other aquatic organisms wi'l not be damaged, that accumuJaticr- in edible Ci'di will not exceed the FDA guidelines of 5 parts per million ir tiic edible portion. To im.ile^cnt this policy, we will restrict hae-..-ir.-j | discharge:: to the lowcr.L ach. vable level by placing nil present dis chargers on an implementation schedule whii !i will seek to bring out no discharge from known sources of contamination as rapidly a:: p : z n i * - . It must be recognized that there arc reservoirs of PCB*s in sewer sy.-cc::-- -r a watqrways as a consequence of previous use. We should anticl; - a decline over tlic next several months of PC3 discharges frer: these soi.r-cs as the sources arc gradrally cleaned out. At the present tii.:;1., tlie Monsanto Co-.pany is the sol' U.S. - -...r * .and the manufacturers of capacitors and transformers nr: the or.';- u . % * * Monsar.Lo sells to no one else. We believe that there arc Iera thr.-i '| * individual plants involved in these uses. In addition to these so*:;-* there arc known rcsidu-w in paper t!iat is recycled, therefore, se e : , in waste from pulpriils can bw anticipated. These, too,`sht-ild dee^ ` 1 over the ne::t several mouths. PCB's were used in heat* transf -r syst.--, v' ACM CCfcSsfc - 2- reaching the cnvLronncnt from former u: errs should be greatly reduce.! or near zero. The drat red U n i t in vir.ter is 0.01 parts per billion. Our beat indicator of TCli contamination in various waters, however, will be renL v:.s in fish or in other aquatic orgaaisus. Excerpts fren t**o briefing memoranda prepared by the Off Lee of P^~ arc attached. The inter-.ge-.icy tasi; force report will be provided to ye-, as aocm as. it beccirea ava'table (it is now at the printers). Attiichrcnts ACt*. CCS 5 5 7 February 1972 A. f*: Rii-C!3 Briefing Iit::;ornr.*'.un -- PCB's (Prepared by the Office of Ro;* mrsh) 4 For tlio last vcral months Llicrc has been an interagency tusk form: on FCIJ's, It is new drawing together a document for publication. there era many gar*, in information about sources, occurrence, and effects of PCB's there is enough known that we probably should consider s. 'e actio in ETA at thin time. The salient facts follow: Amounts Manufactured Monsanto Is the sole manufacturer of PCB's in the United State". In 1970 its domestic sales were about 36,000 tons in a number of different' grades. That was approximately twice the amount manufactured in 1960. 1971 expected sale:*', wore down to about half the 1?70 figure. While former used an a dielectric fluid in transformers and capacitors, as a hydnul ic fluid and lubricavt where fire retardant characteristics are important, as a plasticizer, as an additive to paints, pesticides and numerous othcr product:-, and in enctpsulating for carbonless carbon paper most uses have now been eliminated by Monsanto. Continued use is expected only in come transformers and cap .- ;,-or3. Sources t.r the F.r.rir-.;'gvnt_ Air. There a*a no reliable data on PCE concentrations in air. Four mensuremenis have been made that suggest presence in three different citic There is also a reference to the presence of PC3's below quantiflab in lave in precipitation in Great Britain. In this country, the Geological r.-T-.-cy of Intoric. has looked for TCB's in precipitation samples in Floridj but they arc not: certain of their results. Certainly PCB's are not p"uscnt in levels as high as 0.1 of a part per billion (p?b). Through the Pvstic: Air Monioring Program soma samples will be combined and analyzed lot PC:;' and we will have come quantitative information within a month or so. The point for now is that PCB's in air are below levels that would cat: u.. ~:o need to regulate. Vie ,do need to learn about TCB's in air as a trau'pori mSchlrtlSHl.------- Sources in air probably include open burning at dumps nr: 1 pj-.r.:.hty tmburned particulates from incinerators. Vaporisation i:; k m t o :r from plastics. Complete incineration is not likely Lo result in PC.; r-iuld in a ir. \V AG* CC8556 a i t -V'"-;: RO-Lj-y:-:* ii'JiX' W'1-'51 cr.UT the aquiLlc environment fron both and fij-.i.-jip 1 nowcr outfalls, The usual treatment of municipal ni.:*-.a 0-'f' 'hi;*. 11 i.nd.nstrin1- i.!ii cipal) results in PCB's being pic-c:-.t in 1''' h sJu'ge nih) liquid ef-fjlic-nt. The total amount of municipal cfi"'*. iL " from lees than 1 ppb to a few tons of'ppb. Sore jneuci ouLf.i_l.lr. cjnL.ifr, hundred:, of ppb. The estimate of the total input to the fo u n t in env'r >n: .nit by Dr. SnroCin of Harvard is U ,O0i) L o n s per year. I thin'; that u m b e r way be high, particularly with the decreased use of l'CliV Furthermore, Dr f. Sirofira's estimate includes accidental discharges. Dump-:. TV. r.-.rofiia estimates the largest amount of PCU's ends up in dumps -- 20,0G'J tons in 1970. So long as the dumps are not burned, there prt'...-!)ly is relatively little transfer to other parts of the environ ment. Effects of VCB's 9 PCH'c h.'v;; been shown experimentally to kill shrimp and some fish at concentration.', an low as 1 ppb in water. The Pood and Drug Administration has establish- -1 a guideline of 5 ppm in fish. Japanese experience with the Yushu ilicit!?' suggests that a total intake of 1/2 gram was enough to cause overt synpi.n:c3 in man. Cone.nitr*.Mon Factors. Fish, shrimp, and crabs are known to concc::-ate c PCD'a frnu icv-alj in water by factors of up to 75,000 with exposure levels as low as O." ppb for fish and .06 for shrimp. Reco;.:-.-nd.itions ETA should establish guidelines for PCB's i:i water-of 0.01 ppb which will be sufficiently low that concentrations in fish should not exceed 5 ppn. 0.01 ppb is 1/500,000 of 5 ppm, and thus this concentrating should, not result in TCT1 levels in fish as high as the 5 ppm guideline of FDA. The 0.01 ppb level i:. sufficiently low that fish and other aquatic organisms should not be damaged. In operational terms, we should limit TCB discharges under Lhc 1S99 permit procedures. The allowable discharge should not be more than an amnia-t that will result in .01 ppb in the receiving water at mean annual flow, assuming uniform nixing. After Monsanto's sales restrictions become fully effective, there will be relatively few plants that discharge PC'l's in substantial quantity. These will principally be electrical manufacturin' * concerns that manufacture capacitors and transformers. Electrical utilities may also be sources if they refill their own transformers, (rcii's arc manufactured in oJ ~r countries. So far as we know, they are not iripcri'v!, except an components of plastics, electr:cal equipment, etc. With Knr.ant ;'s restrict Iona on salon in the U.S., there uny he a desire to import the . materials for uses that Mhnsanto does not provide for.) C ACh 00855*5 -3- KU-. Hnn::nnt\ s the soln U.5. mamif.-icturer, w M l be another cc:'"'.;::v requiring off -.'-nt pernittf. At lfcnst' for a uhiJa, some paper cn:r.;'::iLcs may have rcl. `w l y high ?C3 re'*.'dues from recycled paper, but thcau cone cnJMuti own :.Vmld diminish since FCB1s are no longer used in carbon less carbon pr the principal source in recycled paper. EPA should encourage reduction in use of PCB's wherever there arc acceptable si*' :,!L 'utes, When there are no acceptable substitutes, and when it is used in closed systems, we should entourage adequate induntria sanitation to it;*iini; c leakage to the environment. We should sample sewage sludges from time to tine now that PCD use /[is decreasing r.-'d should consider prohibiting dumping of such sludges at I sea if the PC1', levels do not drop. We should also prohibit1dumping of 1 PCB-containing .industrial vractes in the oceanB. <? v ACi* CCtiJeC- M.ii'ch 7.7, 1072 A; ro C; iContiiCivl.'irlrus on PC Policy (l pared by Tin1' O ffice of Research) mBmari*'-/_ro,'-'it-'* Polychlorinated Biphenyls (PCB's) arc chemical compounds that hove hr--a wi.de1y uor;l-- r.s flame-proof dielectric fluids in trnnsfnners and cop. -i.to *.-i; as plasticisers in plastics sealants, caulking compounds, iM i as p-.si.ie.it!<? extenders; as lubricants, heat transfer and hydraulic fluids; p-..i even as ingredients in heat shields on air to air missiles. Al"' 't l 1h'h0,000,0'!!0 pounds have been produced in the United States since 1'J-ptJ by Monsanto. There are no other producers of PCB's in the Unite.!' Si i* ,.but PC.:'s arc produced in a number of foreign countries including Grcv [ Britain, France, Germany and Japan. s Adcpiatu replacements for PCB's exist for all uses except for use in f.i-,1 p:u- f; capacitors and transformer fluids. Mon'.rnto has voluntarily withdrawn PCii's from the market except for the capacitors and transformer lines. Then user, are in closed systems, and good industrial practice can pre /out ''Gil's from these uses r- thing the environment. Worn out capacitors nr*i diaper ---l of .-.s solid wants, and presumably present only minimal threat to c Lhu env*.!* .nu because they ire sealed and little if `any is believe to lea* . l a f i l l c . There may be a possibility for using other disposal ire*hods with Icrge capacitors. There Is no existing legal authority for control of manufacture, impart, or i* of rcr.'n. Passage of the Toxic Substances Control Act would, of ctuu'.-e, nr he such regulation possible. It is possible that Monsanto's voluntary re."erections will result in import of PCB's, or of other cong.vuio" paiuifr.ct'irJrg PCB's in this country (patent protection has expired long since). The intent of the proposed EPA policy is to use the authorities that we do have to regulate the controllable sources of PCB's to the water env Lrcnr.cnt. It is impM*t:i..t. tJ note that we do not believe it is necessary to regul -te PCB's in air-- in fact, we don't have adequate methods for measuring tlu.m in air, even If we did want to regulate. We have already taken come actions to control PCB's; i.e., rermire! . pesticide r-g is .rants lo reformulate their products to eliminate PCB's, * either as inert or active ingredients; and included PCB's in our list of hazardous materials in the proposed regulation under section 12a of PL 660 now awaiting. OMB "cn irdinat Lon." * Other red era! Agencies are taking or l.^ve taken actions to contr;-'' r'./o. PDA hac establ1.'Ji-'.l interim guidelines of 5 jpin in foods, and there guidU n e s ard, monitored by FBA'and ULJA in the case of poull.'y produce.-; am! "i'l f . c Cfc CC8561 t\ i 2 RO Ft'* ii c* J" i n fr:i.l p * I'v'.'1u J ii 11 i: fr*M p ons p r d i M c l n n rc.i-cf*ncjj:i;np, ruryi.lcJ pulp t n*: \:v i t >* !.ili: , ;u k ! n temporary (nnu-yc-ar) toleram-n of u h ! . . g a "- H - e i'in lr ( FiJAhas prohibited Lite use of PCS1n pi.aits, f/***i' Ori /:C l.rt:*.'. 1. le i v.'Lll the proposed F.VA policy be announced? The In: orugeney Task Force report will bn released wiLli a news release Chet includes statar.-^nrs about Federal actions taken and proposed. /.I prer it includes statements consistent witii the. proposed EPA policy. In addition, when the EPA order is issued, an EVA news release eliee.Vi ! . A. r-'.i specifying in detail and explaining the EPA actions. 2. How will it be enforced? 9 Ter-its for the elect'-leal industry (and PCB manufacturers) will ."/ p/c -lb it discharge of PCB's (-technically possible to achieve th k ' * ' ;*f i.cntr-jl). The electrical industry is no the sole legitimte n: / of f' Monitoring data from fish, rhcllfinh, and water will be exemk-d \ n iv.- * r.-.^tions vith high PCB con: :nt. Thona areas can than be subject !r: fcl*. - w, studies to determine scu:vas, and enforcement actions under 11/ K*.1 1 A t initiated where wars*., ted. .As noted in the background paper I'wj/u u* .* continue to reach the environment (in decreasing amounts) free; iicccn'T y sources nu-h as recycled pulp, and f"oa undetected or unknown .Ir.-.kf! f m r n-;uIpr.tr.t *.n which PCB's arc used as heat transfer and hydrau'ia i. ;:h! u ill the*, change over to replace enus is completed. By the end cf i'i'..a should be drastic reductions in PCB's in us* in systems where ih , lid be expected to roach the environment (unless new supplies become ;r ..ll:f,*lr. If. rough i.i. art or new manufacturers). Are- s with known high levels of PCB discharge can be monitored r1". 'y to ar:.:,*' rapid decrease in PCB discharge levels-- Dayton, Ohio and h - A. gc' are camples of such areas. 3. L*!u.t arc the other options? The options considr! were: * * wot Id be Uaunrdou -- No action by El'A, assuming that the Monsanto res:., let ion ufficlcnt to achieve acceptable environmental levels of PCB. -- Including PCB's as a hazardous air pollutant and a mater ial nruh-.r PL GG0. V -- Enforcement! actions under the Refuse Act on the basis AC* CC65t>2 - 3- A IiM L 1 '7 ItO-CD-72- 3Q c fii; * no por no* JVh.'r w t 11 b\- vv-' .ion PCr.'c and hence no knowing discharges of i' -- lie*, !ring the' Slates to include TCB in the water (i! Mt.y ;;:*r.' .* - Lhey arc r-vised, and using the usual ccnfcrcncc r'*;.* iuru, :.ic. f- t: cnforccr.cnt. Thu revised "Green Book" is expected to It.-luV rcr(':;.; c:v!ations on allowable levels of PCli's consistent with the peop/- .d policy. -- Using the construction grant program to rcn-.lre Mun'elp to cn ict rogulat h*. ; that prohibit discharge of PCB's (; il Gth--* hvinr-Ious materials) to the newer system of which the grant p*.r.licL j '. a part. -- rrohibition of cli-rharge of PCB's by users of PC3's. The policy proposed vac based on the following facts: 1. PCIi use has b' (Id ml'' U.S. m-v. :f.:cturer), an:' *; l~1i" * *rs 2. The electrical ur\ ** <>r !v:-:'s. It is technologic, c CC j ':v * *.g the environment:. 3. PCB's are on the list of hazardous materials proposed unde:* the water pollution law.. A. Occurrence of PCB's in air is at very low levels, and Jr nc.:* I' 1 Vved to pose environmental problems. Furthermore, FCB uses Dirt c-;-.:. *v:ted PCli's to the air have been largely eliminated (pesticide use, uro in plastics, etc.). Some may reach the air from inadequate ir.cLncv.i of l`C3 -e Mi - l.ilng materials. 5. PCB's arc present in some plastics, paints, sealers, carbon-!r." carbon pape: and other manufactured products. As stocks of tl'-'s: matevi'-lr. are.used up and disposed of or recycled, some PCli's wi' read* Uie : cnt. Tie amounts should decrease r.ipidly, since FC.'i's arc no lougc sol.! for such uses. PCB's have been used in heat tr.i.irfur syr.tr*::; and as hydraulic fluids, lubr-cants, and cutting oils. Mwn-.-.rto linn noL only withdrawn PCB's f>.*r these uses, but has actively v.-or! with users to Ir.ve the nub stances replaced iir.,-.-rdi.itoly. Monsanto accepts thu used materials fo'* disposal by high temperature incineration. TIic rccommc;:ed policy was intendc' to prfvJdc iir.n^d iate hjlk r. t!ia t would "hack t*i" Il-.iu.v.nto's voluntary restrictions, and at the sa<.:c t>ic would rccogr.ir.e the iau\icablo. nature of some PCB residues. It would C ACM CC65C3 - t* - G il m Intuir') b':*-.Jn uses and secondary sources of centar.- iri"t,:'n. It indicate a co.it Cor nlln'wablc levels in waLnr. It v, '* ;roclude ruliiltionnl nclions later if these appear necearary ((r e:;;;;--..]',, d*uUir' with l'CD discharges to muncipal sys rests if TCD levels do uot declina as fast as we expect). C 44 . f. 9 i ADK CCfcSt^t ECONOMIC IMPACT OF TOXIC STANDARDS I. SUMMARY The main conclusions of the economic analysis are the following: 1. The proposed cyanide standards will have impact on more than four-fifths of the electroplating industry if they must be met within one year. If 2-3 years were allowed, the impact would still be about 800 small platers, affecting 4000 employees. e 2. Large, integrated steel mills can probably meet the cyanide standard within a year, but non-integrated mills may not be able to meet the standards in that time-frame. If 2-3 years are allowed, these nonintegrated mills can probably meet the proposed stan dards, although the industry continues to have difficulty attracting capital for pollution control. 3. The proposed benzidine regulations may have some impact on the textile dyeing industry. Little is known about the amount of benzidine in discharges from the industry; some evidence indicates that levels may exceed the acute limit. On the other hand, there is evidence that in significant amounts of benzidine reach the dyers' effluents. We are presently continuing our efforts to collect addi tional data pertaining to this problem. The economic impact analysis of the iandards for the other toxic substances is hampered by a lack of information on the presence or absence of these substances in the wastewaters of each category. From the information available, the impact does not appear to be large. The difference between the HATS Standards and the Water Quality Standards is not substantial. Some other industrial segments may need more than one year for compliance, but the available information does not indicate which categories will require more time. 1 \ ACH CC85t5 -2- II. . ECONOMIC ANALYSIS OF SELECTED INDUSTRY CATEGORIES (MESCUSY. ' CADMIUM, AND CYANIDE) ' : "' The three pollutants - mercury, cyanide, and cadmium - generally affect the same industry categories. Assessing the economic imoact requires looking at each category rather than each pollutant because the total costs of the toxic standards are more economically relevant than each pollutant's cost component. Chlor-Alkali fMercurv Cell) All mercury discharges are less than 1.6 pounds per day and cadmium discharges are less than 10 pounds per day so that the Standards are currently being met. No economic impact is expected. Electroplating $ Only those electroplaters which currently meet the proposed cyanide standards could comply within one year. We have no data on the number of electroplaters affected, but we estimate that a sizable proportion (more than 80%) do not currently comply. Additional time allowed would enable many electroplaters to build the necessary treatment facilities. However, many small independent platers will still be affected by the standards. Our analysis indicates that more than 800 independent platers will close, affecting more than 4,000 employees. Some employment will be created in the large plating shops although not all displaced workers will regain employment. Lumber and Wood Products All mercury discharges are less than 1.6 pounds per day in dicating that the proposed Standards are already being met. No economic impact is expected. Non-Ferrous Metals (Bauxite) i All mercury and cadmium discharges will meet the standards by July 1, 1975 in compliance with the proposed Standards. No economic impact is expected. Petroleum Extraction Currently our data indicates that all mercury and cadmium discharges are less than the proposed Standards. No economic impact is expected. ' (' ACM CCtsSfct -3- Petroloum Refining Most/- if not all, refineries currently comply with the proposed Standards. Thus, no major economic impact is expected. Pulp and Paper Ninety percent of the pulp and paper mills reporting to the RAPP currently meet the 1.6 pound per day Standards for mercury. The remaining 10% are suspected to exceed 1.6 pounds only after inclusion of wastes from chlor-alkali plants that are run at the pulp and paper mills. These mills will not be impacted if the pulp and paper mills and the associated chlorine production are each regulated separately. If this is done, then no economic impact is expected to result from the implementation of these standards. . - Steel ? Although we can find no large, integrated steel mills which will have difficulty achieving the proposed cyanide standard, our data indicates that some non-integrated steel mills currently are not in compliance with these proposed regulations. Further, few if any of these facilities could meet this standards within a year, due to lead time requirements for constructing necessary treatment facilities. Additional time would make facility construction possible. Dilution of the waste stream is a possibility, but the costs have not been estimated. If treatment facilities are installed, the costs of treatment for toxics will be on a par with BPT costs for Best Practicable Technology (effluent guidelines). The industry's major problem, however, will be its ability to attract new capital for investment in pollution control, as well as new plant and equipment. Other Categories of Sources Some major industrial categories, such as coal and metal mining, could discharge significant amounts of mercury and cadmium. However, our feeling is that most sources currently meet the pro posed Standards. In general, treatment facilities cannot be constructed within one year, so that compliance vrould be difficult if significant treatment is required. \ ACM CCd567 -4- III ECONOMIC ANALYSIS OF OTHER TOXIC POLLUTANTS (PCS's'. BENZIDINE, AND THE PESTICIDES ^ PCBrS The discharge of PCB* s from the one PCB manufacturing location in the United States has been stopped. Discharges from electrical equipment manufacturers are suspected to be small and readily controllable. Utilities are considered to experience only non-point source discharges. In summary, the economic impact is ej e c t e d to be minor. Benz idine No measurements have been made of benzidine levels in the wastewaters of benzidine manufacturers, dye manufacturers, or dyers and finishers. Trace levels may be present in all of these wastes so that treatment may be required. Because the textile industry is very cost sensitive, serious economic problems could result if treatment is necessary. Little is known about the extent of the discharge problem or the feasibility of using benzidine substitutes. The Pesticides The primary source of pesticides in the environment comes from their application to crops. However, pesticide manufacturers and formulators discharge some relatively small amounts of these toxic pesticides. By and large, manufacturers can comply with the standards; but small pesticide formulators may meet the standards by discontinuing production of the toxic pesticides. Because most: of these facilities formulate many pesticides, the high costs of installing treatment facilities for only a few of their formulations would make continued sale of the toxic pesticides undesirable. Hence, usage of the toxic pesticides will shrink to only the most essential purposes. In general, the economic impact will fall on the pesti cide user, if good substitutes are unavailable. IV. CONCLUSIONS FROM THE ECONOMIC ANALYSIS Two issues have surfaced in the economic analysis: compliance time, and economic impact. Generally, for mercury, cadmium, and cyanide, the standards cannot be met within one year if treatment is necessary, due to construction lead times. Large scale dilution may in some cases require more than one year. ALM CCtbfcC -5More -is known about mercury, cadmium, and cyanide than the other toxic substances, even though large gaps exist in our ata. For example, verified data on concentration and daily load of mercury, cadmium, and cyanide exist for only a few of the ir.dustr categories. On the other hand, analysis of the economic impact o standards for the other toxic substances is hampered by a lack of data on waste characteristics. s \ ACH 006565 *11 i t : v; & : : ; /n ccrr, W'iUi J2ih A v-.-iuic .South N;i.s!.-ilJv,Tun.n-vrc V/204 November 10, 1973 Mr. i1.f.!;o Sav Econoim c Anal1;:. Envii-c i u e n t a ! Roc'f y/o 401 :'i. Street, : Washington, 0 . i Dear John: Enel : is or.' mere.u ?P/1 ry . shoui d n o t bi u the r . i v a l o r cor.pl .vos , < . ; * le f f c . : or. the ; In oi to vi*i disci';.?`!on of f b e he. if-y to c ! .ss further details with vou. Since r:;ly yo..:` AUAf*: , m e . ... ``^Johc I'.. Koon, Projot.t r'cinr.* ' OllliAv E n t;h i.* :' ACI* CC057O COST-EFFECTIVENESS RELATIONSHIPS FOR THE REMOVAL OF CADMIUM, MERCURY, AND CYANIDE FROM INDUSTRIAL WASTESTREAXS Preliminary Analysis For Economic Analysis Division $ Environmental Protection Agency Washington, D. C. I By John H. Koon, Project Manaqer Y. Argaman, Project Engineer Cheryl D. Magee, Project Engineer Carl E. Adams, Jr., Project Consultant ASSOCIATED WATER AND AIR RESOURCES ENGINEERS, INC. 2907 12th Avenue South \ Nashville, Tennessee 37204 November, 1973 COST-EFFECTIVENESS r e l a t i o n s h i p s f o r t h e r e m o v a l OF CADMIUM, MERCURY, AND CYANIDE FROM INDUSTRIAL WASTESTREAMS Scope of the Investigation The objective of this work was to estimate the cost of removing cyanide, mercury, and cadmium from industrial wastes and to obtain estimates of the residual concentrations which can bo obtained using A best available treatment. Because estimates were assembled from readily available literature data and from communication with researchers and equipment manufacturers, the values used in this report cannot be taken as the most accurate estimates available. Considerable more time in evaluating data from all sources would be required to arrive at final judgements. Treatment costs were obtained from industrial waste treat ment cost relationships, costs for municipal wastewater treatment processes, and from the best judgement of equipment manufacturers. In many cases it was necessary to use attainable effluent concentrations given by researchers and equipment manufacturers without having access to the detailed conditions under which the results were obtained. Several assumptions were made regarding the wastestream to be treated. These conditions may be enumerated as follows: 1. Waste flow = 3 mgd. 2. Influent concentrations of the species of concern * 2 mg/1. 3. Waste constituents to be removed can not be isolated in more \ concentrated streams. Therefore, it was assumed necessary to 1 ACM CCt572 treat the entire waste flow. 4. The wastestream would contain some suspended solids and organic constituents not removed in upstream treatment processes. 5. The effect of complexing agents could not be thoroughly con sidered due to lack of applicable information. Analytical Limits of Detection In order to add perspective to the residual concentrations of these toxic substances reported, the limits of detection for each constituent were reviewed. Briefly, the findings are as follows: 1. Mercury. The flameless atomic absorption procedure recommended by the EPA is capable of detecting mercury at the 0.01 ppb level; EPA, however, recommends that 0.2 ppb be set as the practical detection limit for mercury in natural waters. 2. Cadmium. The detection limit for cadmium in water when determined by flame atomic absorption at 228.8 nm is about 40 ppb, using the Bolin burner as recommended in Standard Methods (12th Ed). An adaptation known as the Delves cup method, which involves analysis of evaporated samples'; permits detection limits for blood samples (and presumably for v/astewater samples) of approximately 2 ppb. Methods based on atomic fluorescence and neutron activation are capable of detection limits several orders of magnitude lower, but their suitability for wastewater analysis has not been established. 3. Cyanide. The most sensitive practical methods for cyanide are color imetric. The procedure suggested by Standard Methods involves conversion 2 a d k CC6572 UJ of cyanide from a distilled sample to cyanogen chloride, which then reacts with a pyridine-pyrazolone reagent to form a blue dye. The. latter is determined spectrophotometrically at 620 nm. Standard Methods gives the effective range as 1 - 5 vg in the wastewater; this would correspond to 40 - 200 ppb, depending on how the sample was pre pared. A five-fold increase in sensitivity is said to be achieved by extracting the dye with butyl alcohol. , Treatment Processes 9 Treatment processes which were considered for the removal of each ion are discussed below. This discussion is limited to process para meters which have the greatest effect on treatment performance. A. Cadmium 1. Precipitation. Precipitation of Ca(OKj^ by lime treatment at pH 11 is expected to reduce the cadmium concentration from 2.0 mg/1 to about 0.2 mg/1. The lime dose, which depends on the waste alkalinity, was estimated at 400 mg/1. The effluent pH was readjusted to 7 - 8 by recarbonation. Sludge production was estimated at 500 mg/1. 2. Precipitation and Filtration. The precipitated and settled effluent was applied to a granular media filter where the cadmium concentration Is further reduced from 0.2 mg/1 to about 0.02 mg/1. This removal v;as based on data from the treatment of municipal wastes containing similar cadmium concentrations. No specific data for the treatment of industrial wastes was available. v 3 AC* 00657* 3. Ion Exchange. Cadmium can be removed to less than 10 ppb with ion exchange. A resin which is selective for cadmium or a mixed bed resin can be used. However, the mixed bed process is more practical. There are several types of resins which could be utilized including carboxylic acid resins and chelating resins. In this case, a chelating resin may be better because of the low salt splitting capacity. The degree of removal and the type of resin utilized is dependent on the complex being removed. 4. Reverse Osmosis. Generally, 97 to 99 percent rejection of cadmium can be obtained by reverse osmosis in a single-stage process. However, in this application, because of the low influent concentration assumed, i.e., 2 ppm, imperfections in the membrane, would result'in a lower percent rejection. Because of the higher surface area and wider opera tional pH range, hollow fiber membranes would be recommended. 5. Activated Carbon. Cadmium levels of <50 ppb are obtainable by the use of activated carbon. Although these low levels are achievable, the carbon loading is very low, i.e., 3 lb Cd/100 lb carbon. A residence time of 35 to 40 minutes is required for good removal. B. Mercury 1. Lime Precipitation. Precipitation of mercuric oxide by lime treat ment at pH 11 is expected to reduce the mercury concentration from 2 mg/1 to 0.4 mg/1. The lime dose was estimated at 400 mg/1 for waste with 200 mg/1 alkalinity as CaC03 . The effluent pH must be readjusted to 7 - 8 by recarbonation. Sjudge production was estimated at 500 mg/1. 4 AC* CCd575 2. Sulftde Precipitation and Precoat Filtration. Precipitation of mercuric sulfide by adding a sulfide source such as sodium hydro sulfide followed by precoat filtration can reduce mercury concentrations from 2.0 mg/1 to'0.03 mg/1. This information was obtained from an existing nllot plant treating a chlor-alkali industrial waste. In the absence of other sulfide consuming compounds, the sulfide dose was estimated to be 10 mg/1 in excess of the stoichiometric requirement, i.e., about 16 mg/1 of IlaHS for 2 mg/1 mercury. The excess sulfide was then'precipitated as FeS by adding ferrus sulfate (about 75 mg/1). 3. Ion Exchange. Mercury can be removed to approximately 10 ppb by ion exchange. Again, as in the case of cadmium, the type of resin employed depends on the metal complex to be removed and the other constituents in the wastewater. 4. Reverse Osmosis. A 95 to 97 percent rejection of mercury can be obtained by a single-stage reverse osmosis system assuming the mercury is in the proper form. The complexed metal or free ion is rejected; however, organic mercury would not be rejected. Again, this percent rejection may be lower, due to membrane imperfections at these low levels. The hollow fiber membrane would also tend to give better results in this application because of the larger specific surface and wider pH range. 5. Activated Carbon. Mercury levels of 1 to 5 ppb have been reported from the treatment of chlor-alkali wastes. However, effluent levels of 34 ppb were obtained in a itudy with municipal wastes. Again, the 5 AGP CCtb7t carbon loading is lowv i.e., 3 lb Hg/100 lb carbon. The adsorbability of mercury varies significantly with pH with the best results obtained at pH 4 to 6. The adjustment of pH with HC1 enhances removals probably due to the precipitation of Hg C l T h e current facilities which utilize activated carbon for mercury removal do so.on a "throw-away" basis. When regenerating carbon with heat or hot gases, problems develop with mercury vapors. C. Cyanides $ 1. Alkaline Chlorination. Cyanides are completely oxidized to and carbonates in a two-stage process by adding caustic soda and chlorine. Excess chlorine is reduced by the addition of SOj. The process is carried out in a continuous flow system with the chemicals being fed automatically through pH and ORP control units. For a cyanide concen tration of 2 mg/1 the chemical doses are estimated as follows: Clj - 20 mg/1, NaQH - 25 mg/1, and SO2 - 5 mg/1. Effluent concentration of cyanide is reported as 0 with the analytical method used. For the pre sent calculations a conservative value of 0.2 mg/1 was assumend. (See section on analytical method for a more detailed discussion of dectable limits.) . Ion Exchange. Free cyanide can be removed to^lO ppb/by the use of a strong base anion exchanger. Again, various resins can be employed. Removals are affected by the presence of cyanide in complexed forms. 3. Activated Carbon. Cyanide can be removed to 50 ppb by the use1of activated carbon. The process involved is catalytic oxidation with 6 CM CO0577 CuSO^ and oxygen which converts the cyanide to CO2 and N,,. One disadvantage associated with this process is that copper appears in the effluent in concentrations up to 0.1 ppm. The copper is capable of displacing the majority of the heavy metals which are complexed with cyanide but copper is not capable of displacing the iron. There fore, any iron vriiich is in the wastewater must be removed prior to the carbon system. Removal of iron was not considered in this investi- $ gation. To prevent the formation of metal hydroxides and subsequent filter clogging, the pH of the influent stream must be between 6.5 and 8. While this process appears to be a feasible method for treating cyanide-bearing wastes, the technological success of the process has not been fully established. j 4. Ozonation. Cyanide can be removed to less than 10 ppb with ozone j alone if the cyanide is not complexed with iron. However, if the t [ cyanide is complexed, pH control and heat or ultraviolet light must be ! employed in combination with the ozone for adequate cyanide removal. L. Treatment Costs ATI cost estimates were adjusted to January 1972 levels (EPA Sewage Treatment Plant Index = 175). Allowances were made for engineer legal, and administrative fees and miscellaneous construction costs. Special conditions assumed for each process are discussed below. 1. Precipitation and Filtration. Costs were estimated for one-stage precipitation processes. Sludge handling was estimated using gravity thickening and vacuum filtration. The sulfide precipitation process 7 ACK CC 65 includedHaHS addition, filtration through a diatomaceous earth filter, Fe SO^ addition, flocculation, and sedimentation. 2. Oxidation Processes. Facilities for cyanide removal by alkaline chlorination and'ozonation included flocculation basins and chemical feed facilities. For chlorination the conventional two-step process . was used which employs pH and ORP controls; additional facilities were added for dechlorination using SOg. 3. Reverse Osmosis. Reverse osmosis was used forthe removal of cadmium and mercury. Cyanide may be removed if present as CN~ or cyanide complexes: however, it appears that any unionized HCN can pass through membranes. All capital and operating costs were obtained from manufacturers based on "best judgement" estimates of costs to achieve the given residual metals concentrations. Filtration costs were also added for pretreatment in all cases. Because cost data are not from independently reported sources, the adequacy of membrance cleaning and replacement costs cannot be determined. It is possible that higher costs might be obtained upon application of this process to specific wastestreams; however, no basis exists for increased costs 1n this investigation. 4. Ion Exchange. Ion exchange costs were estimated from manufacturer's data using the "0.6 rule" to make adjustments in plant capacities. Pretreatment included activated carbon and filtration, although this pretreatment might not be necessary for all wastes. Due to lack of ACM CQ6579 8 data and the complexity of selecting operating parameters, these costs are speculative. 5. Activated Carbon. Metal removal results and costs using activated carbon were estimated from one reported investigation as interpreted by two carbon manufacturers. Acid washing of spent carbon was included to restore the metals capacity of the carbon. An additional 10 percent was added to O&M costs to cover the purchase of acid. No costs were added for thermal regeneration to destroy organics which would adsorb 9 to the resin. However, it was assumed that carbon would be completely replaced twice per year. Costs for the catalytic destruction of cyanide were based on the process developed by Calgon Corporation. No facilities for iron removal prior to this process were assumed. When iron is present, this process might not be feasible. Although the treatment costs using activated carbon in all cases are attractive, it is felt that the technical feasibility of these prcoesses has not been proven and therefore, that costs are somewhat speculative. Attainable effluent levels for mercury which have been reported varied from 1 - 5 ppb to 54 ppb. This rancie is indicated in the cost-effectiveness relation ship. However, the lower residual values are subject to question. Cost effectiveness relationships are shown in Figure 1 - 3 . v 9 AOH CCBStJC y * n x o n cr. vn m FI TREATMENT COST (0/IOCO gal) 070 0.60 - Ion E x c h a n g e o u Oc; 0.E0 a - 0.40H o(O o H 0.30 <_ L-J H w o.zo;- r- l1 I ll R e v e r s e OcT.orlc SQ-uillff iidrfef P r o c e s s I I I 0.10> I A c ilv o ic d C a rL on 0 ... 0 i El* r-'LL'Ii!';' 3 Lu * Vi* I bm* t b* ^ I I V I m *a I1 *" f ACM CG8582 1 T 1 P r c ip ita tio n on d F iltra tio n * P re c ip ita tio n n .wVo CCI 'CE! TRATION (rr/i/l> '7t ^ r r p n r ' ^ r p i P - Y L i ' --I ^: rt\7i- vv. j fiii i v i i l.<ul Vw 'J i i i FM ?i J 4C0 T.\:ENT COST (C /IC O O nal) n o o CD Ul rr U-i J :C0 ISO 200 EFFLUXiIT C0 ' CZiJTRATI0 11 (m g/I) ii r -- -- * - T ./o i- i- j v U.% I I t .;.L.. 11, ,,*^ fc;,' c\?::;d i removal f I* ENVIRONMENTAL PROTECTION AGENCY SUPPORT' DOCUMENT/ DRAFT VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT for Polychlorinated Biphenyls (PCBs) Manufactur ing, Processing, Distribution in Commerce and Use * Ban Regulation (Section 6(e) of TSCA) Prepared by Office of Toxic Substances Approved by eJohh P. Dekany, D e p u t y Assistant Administrator for the Office of Chemical Control May 1978 \ c m ' CC85 ( . r i j t r , ! t'_r/"| V - w t- w u Cj3 u \j v ) U0i>.08;0Jd |clU8i.ULI0JIAU3 ;U8U18}2^DBdlU| 12;UGLU0JjA3 p j Q '.:2iun|OA/Wi8miopO $iddns-- 3!ny pesodo-y $Lb) L P Rp ---* \t * 3a m b * ^ . *! -w _. C5pr^-rr.a s n * ' . * + ' ' > * * * * ' * * * * * ? * * ^ -M m m m t W W W < * ,, < '* " * J '* :G 0 3 0 . y t J ff *P" ,^ -i r ;r>r n fi T * J d * r 'V 'A W - -4 m l W . V ! * VJ * I w *_ -- I ".- 'c J,:ll t 9 r ri J r '-Dibuiij** W L 'M u rr a t j *f. jj. m j v u i i i i; i`, , i i r i ' i X u 1<* '* ; '..ii 't* , * .i \m 9 \ S' i VOLUNTARY DRAFT ENVIRONMENTAL IMPACT STATEMENT SUMMARY SHEET (Check One) (X) Draft. ( ) Final Environmental Staieme/it. Environmental Protection Agency Office of Toxic Substances 1. Name of Action. (Check One) (X) Administrative Action. ( ) Legislative Action. 9 2. Description of Action. This proposed rule is designed to implement Section 6(e) of TSCA prohibiting the manufacturing, processing, distribution in commerce, and use of PCBs, and to provide several limited exceptions to these general prohibitions for activities which will not present an unreasonable risk of injury to health or environment. The use of PCBs has been extensive throughout the United States, and therefore, its impact is expected to be nationwide. 3. Summary of Environmental Impact and Adverse . Environmental Effects. PCBs are a significant environmental pollutant occurring throughout the biosphere, .They pose a significant risk to the health of man and numerous other living things. A number of adverse effects on living organisms has been demonstrated, including but not limited' to, bioaccumulation, biomagnification, and cancer in^Iaboratory_a.ru.JiiaTs> PCBs are extremely persistent in the environment circulating among the three environmental compartments (air, water, and land); additional release of PCBs in the environment will eventually result in widespread exposure and increased risks. \ AC. CC85C 11 4 Alternatives Considered. a. No Action. Section 6(e) of TSCA specifically bans the manufacturing, processing, distribution in commerce, and s- use of PCBs. EPA's discretion with respect to these "j S prohibitions is to establish and clarify certain , j definitions and to provide exceptions to the Lprohibitions. b. Action Through Other Statutes or Regulatory Bodies. This alternative was rejected because it was determined that using other statutes administered by EPA (i.e.. Clean Air Act, Federal Water Pol lut ion <?Contiro1 Act, Safe Drinking Water Act, or Resource Conservation and Recovery Act) was inappropriate because they could not provide the comprehensive coverage necessary to implement Section 6(e). This is also true of attempting to utilize statutes administered by other regulatory agencies or state governments. Furthermore, ithere is a strong case that EPA is required by TSCA to use Section 6(e) of TSCA to implement, and grant exceptions to, the explicit prohibitions mandated by Section 6(e). c. Action Under Section 6(e) of TSCA There are numerous alternatives considered within the authority of Section 6(e) of TSCA. Please refer to Chapters IV and VI for details. 5. Federal Agencies That Participated on EPA's PCB Work Group: Department of Commerce (DOC) ^Department of Defense (DOD) Department of Transportation (DOT) Department of Interior (DOI) . Federal Railroad Administration (FKA-DOT) General Services Administration (GSA) National Institute for Occupational Safety and Health (NIOSH) Tennessee Valley Authority (TVA) \ ADA C085S1 -1 1 iOn or about May 26, 1978 the draft statement was officially filed with the Director, Office of Federal Activities, EPA .and was made available to the public. Copies can be obtained from the Industry Assistance Office, Office of Toxic Substances (TS-793), Environmental Protection Agency, 401 M Street, S.W., Washington, D.C. 20460, (800) 424-9065, in Washington, D.C., 544-1404. The official record of rulemaking, including the draft EIS, is located in Room 520, East Tower, Environmental Protection Agency, 401 M Street, S.W., Washington, D.C. 20460, (202) 755-1188. It will be available for viewing and copying from 9 a.m. to 4 p.m., Monday through Friday excluding holidays. fi* ADM CC659* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY W A S H IN G T O N O C 20460 TO: PARTICIPANTS IN THE NOVEMBER 1975 NATIONAL CONFERENCE ON PCBs We w i l l be s e n d i n g you a copy o f t h e P r o c e e d i n g s o f t h e N a t i o n a l C o n f e r e n c e on PCBs as soon as t h e y a r e a v a i l a b l e , h o p e f u l l y w i t h i n one mont h. In t h e i n t e r i m , you may be i n t e r e s t e d i n Mr. T r a i n ' s r e c e n t C o n g r e s s i o n a l t e s t i m o n y c o n c e r n i n g t h e PCB p r o b l e m and t h e n e e d f o r t o x i c s u b s t a n c e s legislation. Sincerely 40 fD Enclosure Glenn E. S c h w e i t z e r , Di r Office of Toxic Substanc ACM CC65S3