Document B5p6bDKM3D3vOZGJeBMXY1xQ8

A ar-i? at2i i i aai at* a n 1 S lo ir s ^ c r J iis a iJ 2 aas 151ra i 7ST5 NORTH FORT MYER DRIVE ARLINGTON, VIRGIN IA 22209 TELEPHONE 703-524-8800 TELEX 89-2357 March 27, 1974 Dr. C. Hugh Thompson, Chairman Hazardous and Toxic Substance Regulation Task Force Office of Water Program Operations Environmental Protection Agency Washington, D. C. 20460 SUBJECT: 40 GFR Part 129; Proposed Toxic " txutant Effluent Standards Dear Dr. Thompson: The proposed effluent standards for polychlorinated biphenyl (PCB) materials announced in the Federal Register of December 27, 1973, would effectively prohibit the manufac ture and use of these compounds and of products containing them. The impact of pro- . raulgating and implementing the effluent standards as proposed would be economically serious upon the members of the Air-Conditioning and Refrigeration Institute, whose members manufacture heating, air-conditioning, and refrigeration equipment and the "components which go into the manufacture of such equipment. (The products of ARI memoember companies represent more than 90 percent of the refrigerating and air-condi tioning equipment manufactured and sold in the United States.) ' he proposed rules would also affect adversely the many thousands of air-conditioning and refrigeration contractors and their employees who purchase and install the pro ducts manufactured by ARI member companies. Furthermore, the proposed rules would have a significantly adverse effect upon current efforts and programs to conserve elec trical energy in that they would decrease the supply of motor and power capacitors* Subpart 1 "Effluent Standards for Polychlorinated Biphenyls (PCB's)", is stated to apply' specifically to any "capacitor manufacturing facility." PCB materials are now used as the dielectric in most capacitors, for these compounds have properties of high dielectric strength and nonflammability which make them uniquely desirable in this application. Capacitors containing PCB dielectric compounds are used in refrige rant motor-compressors which are major components of air-conditioning and refrigeration equipment and where the motor size is approximately five horse-power or less. It has been estimated that some 17 to 18 million refrigerant motor-compressor units containing such capacitors are manufactured each year. Capacitors arc also used in the motors which drive many fans or blowers in heating anc. air-conditioning applications. The motors are of a type described as peraanentsp]ic capacitor motors (PSC), and implementing the proposed effluent standards for PCD compounds would have, the'effect of cutting off most of the supply of capacitors for uao in this type of motor. Prior to the development of the PCB compounds, the dielectric used in capacitors was mineral oil. If the use of PCB materials in capacitors is effectively prohibited, capacitor manufacturers would be forced to return to the use of mineral oil or other restitute materials. The dielectric properties of mineral oil are not as good as uht*. dielectric properties of PCB. In order to obtain equal capacitance, a mineral- COMnoxZD AIR TO } MfATlNC-- C O O lIN O CONTROLLED HUM IDITf CLEAN AIR 782192 NEL 000346 - 2- V. :il capacitor would have to be at least twice, and possibly three times, as large as a P C S --dielectric capacitor. Hence, to manufacture capacitors using other then PCB di electrics, it would be necessary to use from two to three times as much of the other materials that go into capacitors. These materials are, we understand, already in short supply. Increasing demand by a factor of two or three would result in very, very severe shortages of capacitors. If the supply of capacitors became inadequate, motor manufacturers would, of necessity, begin using induction motors for such applications as refrigerant motor-compressor units and for the motors used in air-circulating fans and blowers. These motors re quire more copper in their windings and-'more steel in the frames. Both of these materials are already in short supply, with cooner being in particularly short supply. It would be most unfortunate if the demand for these materials were forced to increase solely because capacitors were not available. The use of induction motors in place of PSC motors would have another unfortunate effect. The PSC motor is more efficient in its use of electricity than is the induction motor. Furthermore, the PSC motor operates with a power factor very closely approaching 1.0. One of the major concerns of electric utility companies is that their system power factor be as close to 1.0 as possible, for this permits them to utilize their generating capacity and distribution facilities more effectively and efficiently than if the system power factor were, let us say, 0.8 or less. As a matter of fact, most utility companies usk large capacitors or banks of capacitors to correct the power factor when inductive loads are present. This is not an insignificant consideration. In its recent document, "Design and Evaluation Criteria for Energy Conservations in New Buildings" (NSBIR 74-452), prepared for the National Conference of States on Building Codes and Standards, the National Bureau of Standards includes the following provision: 8.0.1 POWER FACTOR -- In each building having one or more electric services aggregating 600 amperes or more, a graphic (recording) power factor meter shall be provided during the first year of operation and the power factor shall be continuously monitored. I f `the power factor falls below 0.9 lagging for periods accumulating one-half hour in any 24-hour period, power factor corrective devices shall be installed to raise the power factor to 0.9 or higher. If, after the initial power factor correction, additional reactive loading is introduced in the building, the power factor shall be continuosly monitored again for a period of one year, and additonal correction performed to meet the above criterion. The document then goes on to comment that low power factor causes greater losses in transmission and distribution of electricity. Where the loads of the building are such that they create a power factor at the building service of less than 0.9 lagging, capa citance corrective -devices can be placed at those loads or at the feeders to those loads. Power factor correction at the generating plant does not prevent losses associ ated with transmission of the reactive power components through the distributive netvo rk. We understand that the PCB materials are the only known nonflammable liquid dielectric compounds. Mineral oil certainly is flammable. We understand that at least one com pany has developed an experimental compound which has dielectric properties nearly as NEL 000347 782193 - 3- od as the PCB materials, but it is flammable. There is same question concerning the uesirability of having capacitors containing flammable dielectric compounds located in the. circulating air stream of heating and air-conditioning systems. We do not assert that any hazard thus introduced would be serious or even significant, but it should be considered. It is understood that the purpose of the proposed regulation is to reduce, to the maxi mum extent feasible, the concentration of persistent PCB materials in navigable waters*. Vie also understand, however, that some PCB compounds are significantly more persistent than are others, and that the level of persistence is apparently related to the amount of chlorination in the compound. It has-been reported that the PCB materials having low chlorination have not been found in nature, whereas those with high chlorination have been found in nature. We understand further that it is the low-chlorination PCB material which is used in capacitors. We urge strongly that the biodegradable charac teristics of certain of the PCB materials be considered in promulgating the effluent regulations. The proposed effluent regulations would have severe and adverse impact on the airccnuitioning and refrigeration industry, including the manufacturers of refrigeration and air-conditioning equipment, their employees, and the contractors who install and service refrigeration and air-conditioning equipment and systems. The proposed re gulations, if implemented, would Increase the demand for scarce and critical materials which are already in short supply. The proposed regulation, if implemented, would re quire the redesign of much equipment and the use of electric motors which operate at lower efficiency and lower power-factor than do motors utilizing capacitors made with :B materials The Air-Conditoning and Refrigeration Institute therefore urges t^iat the Environmental Protection Agency either not issue the regulation in the form proposed, or modify it so that`its impact upon the production of capacitors will be substantially reduced, if not eliminated entirely. Sincerely, HTG/lp Consumer Affairs NEL 000348 782194 Yp PRODUCT QUALITY STAFF GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY, H. Y. 12345 SUBJECT MONTHLY ACTIVITIES REPORT James S. Nelson__________ CO PIES: F. S. Rothe April 4, 1974 33 Mr. J. F. McAllister NEW YORK IV - PRODUCT ENVIRONMENTAL COMPATIBILITY 1. Activities in March revolved around strengthening the Company's position vis-a-vis the hearings on toxic pollutant effluent standards for PCBs. Formal testimony was filed in affidavit form on March 15. The testimony, written by Dr. Ed Simons and the undersigned with the counsel of Stuart Richel, Attorney, and with the aid of operating components, was signed in part by Mr. George Farnsworth and in part by Dr. Simons. Supplemental testimony was provided by Dr. Gerald J. Lauer, an aquatic biologist engaged as a consultant for this purpose. In addition, aid was provided to NEMA in the preparation of a letter of consnent to the EPA, mailed March 25; and assistance was provided to IEEE in the preparation of a "white paper" for eventual distribution to legislators and other influential people on the Washington scene. The cognizant operating Divisions have been invited to call upon this office, EPO, and the Washington Office (Mr. Foley), should they desire our assistance in briefing legislators on the background and issues involved in the EPA hearings. Both Mr. Richel and the undersigned will attend the opening day of Che hearings (April 8) to get in a better position to advise the designated GE testifiers, in the event they are called upon to submit to cross examination as the hearings proceed. V e ry t r u ly y o u rs, J 3 N :e v J. is 5. Nelson NEL 000349 ' 782195 GENERAL LCIfC GENERAL ELECTRIC COMPANY. 1 RIVER ROAD. SCHENECTADY. NEW YORK 12345 Phono 1513) 374-2211 PRODUCT QUALITY STAFF Blind Copies: EL Simons) SM Riehel)w/att. JF McAllister April 5, 1974 Mr. Richard L. Rollins Vice-President, Engineering Jard Company, Inc. Bennington, Vermont 05201 Dear Dick: .... - Thanki you, for sending .us a copy of the fine letter you have written to Pea- flalier.-et al. It -should have the effect of enlistingadditional--support: in the struggle for rational disposition of the matter of the proposed PCB standards. However, I should point out that the statement you have attributed to me (or, through an understandable confusion, to one "J. Simon") is not correct. In my letter to Dr. Sager and also in the attachment thereto, we made a careful distinction between kilovolt-amperes and kilowatts. This distinction was lost in your paraphrasing, so that we appear to be claiming too much. Dr.' Galler, at least, has seen a copy of'bur original letter to Sager. In any event, the point you are making remains valid, that the energy saving associated with capacitors is significant. Very truly yours, JSN: Enclosure James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000350 782196 JARD Company Inc. Bennington, Verm ont 05201 3 April 1974 (802) 442-3173 L' 1 M r . Janes S . Nelson, Consultant Product Environmental Compatibility'-" GENERAL ELECTRIC COMPANY 1 River Road Schenectady, New York 12345. ... Dear Jim: ... Attached is a copy of a letter that has been sent to Dr. Sidney Galler at the U.S. Dept, of Commerce, .Representative Staggers, Chairman of the House of Representatives, Committee on Interstate and Foreign Commerce, and to Mr. Fred Malek, Deputy Director Office of Management and Budget. It attempts to summarize our Industry's position, recommends a maximum PCB effluent level of 5 pounds per day per plant, and requests their assistance in obtaining'relief frbm'EPA's present stand. Also, included are statements from representatives of a paper company and an aluminum foil company which'might be helpful to indicate the reality of material shortages *today1,' and the problem of supplying the capacitor material needs if mineral oil were substituted for aro d o r . Finally, an impact statement from Fedders Corporation is Included which raises the question of the Product Safety Commissions stand on a flammable material used in home appliances. Thank you for allowing us to quote your letter. Very truly yours, JARD COMPANY, INCORPORATED RLR:m Richard L. Rollins Vice-President Engineering NEL 000351 782197 JARD Company !nc. Bennington, Verm ont 05201 29 March 1974 (802) 442-3173 Dr. Sidney R. Caller Deputy Assistant::Secretary for Environmental Affairs Office of the Assistent:-,., Secretary of Commerce U.S. Department of Commerce Main Commerce Building 14th Street & Constitution Ave., N.W. Washington, D.C. 20230 Dear Dr. Galler: JARD is a small electrical components manufacturer that has been in business since February 1970.' The company is totally, dependent upon the manufacture of oil-impregnated alternating current capacitors used as efficiency- improving devices'in-the fluorescent and mercury vapor lighting industries and the air conditioning industry. -Cff - _ The capacitor which contains a polychlorinated biphenyl oil has characteristics of (1) nonflammability (2) small physical size, and (3) high reliability with failure rates much less than 0.2Z per year. Unfortunately, the oil, which imparts the above characteristics to these capacitors, has, after 40 years of use, recently been listed as a toxic pollutant by the environmental protection agency with suggested maximum effluent levels so restrictive as a cause for a ban. Polychlorinated biphenyls (PCB's), first synthesized in the late 1800vs and first commercially used in the mid-1930's, contain a percentage (varying percentage of 0.4Z to 60X depending upon the grade) of material which is persistant in nature. This persistance and past uses, in pesticides and carriers for pesticides, paints and coatings, provided widespread distribution into the environment causing-the material to be considered ubiquitous. In 1966, the PCB's were identified to be a potential food contaminant.^ As more evidence became available regarding its widespread existence In the environment, the sole domestic supplier, Monsanto^, voluntarily restricted sales to only the essential electrical applications in sealed containers. Approximately 97% of the users, and point sources of FCE effluents, were eliminated as a result of the change in sales policy, and a large percentage of the 40 million pounds eliminated as a result of the change had been used where purposely exposed to 1. Jensen, Soren 1966 - Report of a New Chemical Hazard, New Scientists 32:612 2. Monsanto Industrial Chemicals Co., 800 N. Lindbergh Blvd., St. Louis, Mo. !fii* 782198 NEL 000352 Dr. Sidney R- Gailer - 2 - 29 March 1974 che environment, eg. in pesticides. Also, the electrical industries users of PCB's, (the transformers and capacitor manufacturers) established-guidelines in the Spring of 1972 for handling and disposing of this material. Committee C-107 of American Standards Institute published and the National Electrical ilanufacturers Association adopted these guidelines as a Standard CP-P1-1973/TS-P6-1973. Most manufacturers have since imposed self-control in adherence to the standard which include proper plant housekeeping, proper disposal of solid and liquid wastes which contain.PCB*s and methods for minimizing effluent stream contamination. In addition,^Monsanto supplied, to the capacitor industry in September 1971, a FCB compouhr which reduced the percentage of persistant material from 7Z to 0.4%, and by Dedfember 1971, all capacitor manufacturers had changed. The above changes appear'to'have been successful in reducing contamination for in the previous three years of 1969, 1970 and 1971 several indidents involving PC5 contamination were found but, the Food and Drug Administration has said no PC3 residues "that .could,be quantitated1' have been in the FDA's last 10 Market Basket Surveys (Food. Chemical News, July 9, 1973 - page 11). Others have reported a significant reduction in PCB input to the environment. However, rhe E P A ^ u n d ^ 1Section 307 of the Federal Hater Pollution Control Act Amendments of 1972 (Public Law 92-500) published a list on September 7, 1973 that included PCB's as a toxic pollutant. It is very difficult to Understand the reason for listing when reviewing the total picture on PCB's, as mentioned above, with the Administrators Mandate, (See Federal Register, Vol. 30 No. 129 Friday, July 1973) which, for inclusion of a material on the list, was to focus on those water pollutants which pose the most serious hazards and to pose the most immediate problems. Also, in the United States, medical records show during the 40 years of unrestricted use, the only adverse health effects experienced by workers exposed to PCB's have been infrequent cases of non-chronic chloracne or other temporary skin irritations. On December 27, 1973 and as required by public law 92-500, the EPA published a proposed effluent standard for toxic pollutants. The discharge levels suggested for PCB's (.0648 pounds per day maximum) are so restrictive that the effect would be an outright ban. For alternating current capacitors, a ban on the use of PCB's would force the re-introduction of a-mineral oil capacitor 40 years after having been phased out. The result of this substitution would be to (1) replace a non-flammable product with a flammable product (2) replace a given capacitor with one that is twice the size (3) double the cost of the capacitor function (4) reduce by approximately one half the numbers of available capacitors which are an allocated commodity today because of the material, (paper and aluminum foil) shortages and (5) not contribute significantly to the elimination of present environmental levels of PCB's. 3 SEMA CF-P1-1973 782199 NEL 000353 Dr. Sidney Caller -3- 29 March 1974 -- 1 1 , t ! , . . . . . . ' 31 -"U L . -- A f l a ^ a b l e product u s e d 'in appliances could certainly create an additional hazard in the hone and it is doubtful that its use would~be permitted (see attached copy-of letter from' Mr* `R* H. Heyerhans of Fedders Corporation to Dr. Hugh Thompson of the EP). Further, because the available substitute would require nearly twice the material for the same capacitor, the demands on the material suppliers would double. As is pointed out by the letters from Mr. T. Steinert of Schweitzer Paper Division of Kimberly-Clark Corporation and Hr. J. Douglas of Republic.Foil Division of National Steel Corporation, thera are basic raw material shortages which will.not permit, the growth required even if additional processing^ equipment were made avh ilable. - The result of less capacitors would be to substantially Increase the demand on electrical energy to provide the.sane amount of lighting, cooling, etc. One industry source-* has -estimated the .loss equivalent to one-half of the nations -- annual growth requirement.(44 million kilowatts) of electric power. The additional financial burden for providing more electric generation facilities to compensate for,the less of the capacitors would eventually fall on the already overburdened consumer. - .....' - It is suggested, that (the'merits of. PCB's far outweigh its problem as a pollutant in light of-the-presenthindustry^self-controls* :. :. * -- : - - v u 1. ' ' ' The standards of effluent levels which should therefore.,be adopted would provide continued effective and realistic control of PCB discharges without shutting down the electrical industry users. Recalling that thei.number of plants presently using PCB1s Is less than 3Z of those in the past, and that sales have been eliminated where sigoifleant percentages of 40 million pounds of PCB'simper year were likely to be exposed to the environment, a limit of 5 pounds per day per plant for the approximate 46 plants would impose a tight control compared to the past practices and ensure that additional pollution is kept to an absolute minimum. Also, diligent and^Tespoasible members of industry could restrict their PCB effluents to this level. We believe that PCB's should not have been initially Included in the toxic pollutants list and oppose it remaining on the list." However, removal from the list nay be more difficult than altering the suggested standard. It is with this in mind that we request your support and assistance in obtaining relief from the unrealistic levels suggested by EPA for the polychlorinated biphenyls to the more realistic but meaningful maximum effluent level of 5 pounds per day. Very truly yours, JARD COMPANY, INCORPORATED RLR:m lx T . f r u . + t r i. ;-n , 9 Richard L. Rollins Vice-President Engine ring 782200 NEL 000354 &4R 2 51974 FEDDF.RS CORP0 RAT10 N ED!fON NiivV ..'ERSjSiV March 21, 1974 Dr. C. Hugh Thompson Chairman, Hazardous and Toxic Substances Regulation Task Force Office of Water Protection Agency Environmental Protection Agency Washington, p,..._.Cr .3.Q40 Subject: PROPOSED WATER EFFLUENT STANDARDS Dear Dr. Thompson: -- The Fedders Corporation is a major manufacturer of room air con ditioners and residential and commercial air conditioning equipment. Our major manufacturing facility is ir. Edison, Ne*.' Jersey with other plants lo cated in Herrin and. ELfinghnm, Illinois; Buffalo, New York; Frederick and Elkton, Maryland. Dtirlng the past calendar y*ar we manufactured over 1,000,000 products of tvarious,, types and sizes nil of vh ch used one or more impregnated capacitors. ' The. writer, its Corporate Director of Product Safety and Reliability and is a Reglcer`ed"Professlonal Engineer In he State of Mew York* T*yp /' The Fedders Corporation would like to go on record as being strongly opposed to the inclusion of Polychlorinated Biphenyls (PCB) in the water ef- fluent standards as proposed by the EPA and published in the December 27;, 1973 V :!;' Federal Register. This standard Is restrictive enough to provide an effective . ban on the manufacture and use of PCB which would therefore prohibit Its use in Impregnated capacitors. > The only presently available prectible substitutes for PCB as the imprgnant fluid In capacitors are mineral oil based materials and Phthalste Esters. The necessity for the substitution o f 'either of these materials in capacitors would be of great concern to us, over and above the economic effect which would be appreciable, for the following reasons. 1. Capacitors with substitute non-PCB fluids would be phy sically larger than those currently in use with PCB. This fact would create a serious problem for the consumer with regard to the replacement of capacitors which failed, since it would be impossible in many instances to install a non-PCB capacitor where a PCB capacitor was used as ori ginal ecuipTier.t. We normally maintain service peers inventory for at least two ye:*rs. Our capacitor inventory could not be replaced . for many years with non-?CTS ca^-icitors because of this serious inLrrchanpoafci 1itvjV*,>prro! Icn. 1 -j.t; - `2CC* 782201 NEL 000355 FCDDERS CORPORATION Dr. C. Hugh Thompson 2 March 19, 1974 2. Capacitors using the non-PCB fluids would tc flammable. It Is not certain as of this dace whether such capacitors could be used in.UL or AGA listed products because of this deficiency. Furthermore, with the increasing emphasis cn safety for conSumer products it is doubtful that the w o of capacitors with flaomable iopregnant fluids would be acceptable to the Consumer Product Safety Corliss ion for air conditicnera and other appliances which are used in the home. In line with the strong position the Commission is taking with the television industry in regard to._ the potential hazards from television fires, the use of such capacitors would certainly appear to be a ctcp in the wrong direction from the Comlssion's standpoint. Even if UL listed such capacitors and If the Conclusion was not opposed to their use, there v-.<uld still remain considerable re luctance on our part to use capacitors in our products which had an Increased fire hazard potertial without many years of careful surveillance-of controlled field test simples. The Fedders Corporation feels that the minimal risk of environmental contamination due to the use of PCB in capacitors would be more than offset by %7Sthe serious problems outlined above. We therefore urge you to remove PCB frea-thei-list of toxic pollutants included in the Proposed Effluent Standards. Very truly yours, RHK: jp R. H. Meyerhans Vice President * NEL 000356 782202 ARNN3as?Uituhinboni*nts'aJc.lfcASFtleuelamllinCuomrporation >nuMoic Titiir.dmiumt,conh oasis TiumoNi ub)ir^i-mi M a r c h 25, 1974 Mr. R i c h a r d L- F^ollins Vice President Engineering JARD COMPANY, INC. ?. 0. B o x 650. Bennington, Vt. 05201 SUBJECT: Proposed Toxic Pollutant Effluent Standards of the Environmental Protection Agency Dear Mr. Rollins: We understand that the water effluent standards for Poly chlorinated Biphenyls (PCB's) as proposed by EPA and published in the D e c e m b e r 27, 1973 F e deral R e g i s t e r are r e s t r i c t i v e enough to provide an effective ban on the manufacturing and use of this material. We, also, are aware that PCB's are the p r i n c i p a l i m p r e g n a n t u s e d .in lighting, ai r c o n d i tioning, m o t o r and power factor capacitors and that the one immediate fall back impregnant available, mineral oil, would require capacitor manufacturers to double the size of a capacitor to achieve the same electrical ratings which, in turn, requires twice as much aluminum light gauge capacitor foil. .' You have asked Republic Foil to answer questions as they pertain to Republic Foil and to our industry, the producers of light gauge aluminum capacitor foil. Any comments we make about our industry must be understood to be our current best estimate as to its position or condition. Before answering your questions, perhaps several comments should be made about our company. We have been supplying light gauge capacitor foil for more than 20 years and currently we are the single largest United States producer and supplier of this foil to domestic capacitor manufacturers, if we exclude General Electric Company who produce anc supply most of their captive needs. Approximately 70% of the light g a u g e capacitor foil vje s e l l goes into lighting, air conditioning, m o t o r a n d power factor capacitors. NEL 000357 782203 T o :" Hr. Richard'L. R o l l i n s JARD COMPANY, INC. March' 25/ 1974 4 _ * .; Page *2 Our best answers to your questions follows 1) D o light g a uge c a p a c i t o r foil p r o d u c e r s h a v e the capabilities to provide twice the aluminum foil now being supplied to lighting, .air con ditioning, motor and power factor capacitor manufacturers?' . *" ' , * W e m u s t .f i rst answer this f r o m o u r a b i lity t o d o anything. S i n c e J a n u a r y 1973 we h a v e b e e n p r o d u c i n g the m a x i m u m a m o u n t o f light gauge capacitor foil possible for us to roll at our Danbury Connecticut rolling mill. We are on a firm allocation to all our customers for the balance of 1974 and anticipate this condition continuing thr o u g h o u t 1975. As such, w e c a n n o t i n c r e a s e .our production of capacitor foil, much less double it. *;V . with respect to our domestic industry being able to supply substantial additional capacitor foil, w e can advise that it appears very unlikely during the balance of 1974 even though there is a small amount of additional capacity coming.on stream. The installed capacity will not even solve current shortage situations that exist. `r-..-* Foreign suppliers of capacitor foil to United States ca- . pacitor producers have been making a concerted effort"to get. ou t o f selling in the U n i t e d States for m o r e t h a n a y e a r ;now, and w h a t sales they h a v e left h e r e are: at premium, levels .to `V United States published capacitor foil prices. VV 2) W h a t are t he limitations of o u r industry;^?";' producing the needed foil quantities? .' > V ,' * -- * '*" **-ITr;.. *' ' .. Republic Foil limitations are primarily two-fold.- The ' first is rolling mill capacity and the second is basic, aluminum., availability. If w e h a d a ddi t i o n a l m i l l capacity, we- w o u l d h a v e an a l m o s t impossible t a s k g e t t i n g m o r e a l u m i n u m to- roll. -T h e ' - critical supply of aluminum has been well documented during the past twelve months. This shortage of aluminum applies.not only to us but to our industry. 3) W h a t is the p r o b a b i l i t y cf s i g n i f i c a n t l y . removing the limitations or alleviating the cause of the limitations in the near future? * 782204 Tos Mr. R i c h a r d L. .Rollins JARD COMPANY, INC. v :.* 'Vo;- * i;v " - .?-.*!> ;M a r c h 25, 1974 .Page 3 For Republic Foil it is not likely that capacity limitations will be changed in the near future. Lead times on new rolling mills - and related equipment are so extended that were expansion plans approved within say six months, it would then be two years before new production facilities would be on stream. Even with additional rolling capacity basic aluminum availability would still be a limit- ^- ing factor. We cannot comment.on what our industry is planning o t h e r than to say w e k n o w of m o d e s t capacity b e i n g a d d e d din t h e - next year, but we don't believe this would provide much, if any, relief for the quantities that might be required, due to the pro posed ban on PCB's. - 4) If capital expen d i t u r e s are n e e d t o p r o v i d e t he abov.e requirements, w h a t changes in t he . market (such as price) would b e essential? . *-- ' Certainly for any producer to supply more capacitor foil major capital expenditures would be required. We could not s u b s t a n t i a t e i n v e s t m e n t w i t h today 1s r e t u r n an d e v e n i f t he r e t u r n was satisfactory, basic aluminum availability again must be con sidered and assured. We cannot comment on our industry's position - in this area as e a c h c o m p a n y 's c a p ital r e q u i r e m e n t s a nd f o i l p r o ...*'yjj. duct mix are different. * 'W: -. , \ .t 1; * * *\ - r ''-"Vi ` *V**- In summary, we do not believe that if aluminum foil requirements ' w e r e d o u b l e d for lighting, air conditioning, m o t o r a n d p o w e r factor -- ' c a p a citors o u r i n d ustry could p r o d u c e a n y where .near e n o u g h f o i l t o `\ supply the capacitor industry's sudden increased requirements. .. Sincerely yours, /*j* ' 4,,. -<*t' ; UA'i- . REPUBLIC FOIL/ NATIONAL ALUMINUM . '^ JvTD :mvs yt-uj's J o h n w. Douglas', Jr, Sales Manager Electrical Products A 782205 Zwr ' o U) VO ` MA'R'l g 974 Peter J. S chweitzer Division KIM BERLY . CLARK CORPORATION its .M assachusetts ot23B*" 13-343-1000 :a biz: -schw*izicar' March 14, 1974 M r. Richard L. Rollins JARD Company, Inc. Bennington, Vermont 05201 Dear Rich: The ramifications of the proposed standaids on toxic pollutant effluent by the EPA are enough to boggle the mind. If P C B 's are effectively outlawed and the capacitor manufacturers have to resort to the use of mineral oil as an imprgnant, it will be necessary for the capacitor paper industry to virtually double its productive cap acity. This means about 18 new paper mochines would have to be built at a cost, at today's prices, of about $10-12 m illion each. The last machine we built was done so in record time -- .two years. With the .. problems of getting delivery o f parts these days, it would take considerably longer. ; Before any paper machines could be built, it would be necessary to increase the current selling price of capacitor paper by approximately 4 5 % . The manufacture of capacitor paper is not sufficiently profitable to attract the capital needed to build machines. M ew machines can be built, it is on ly a question of time and money. The real problem, however, is pulp. N a tio n a lly and internationally, there is a serious shortage of capacitor-grade pulp with no prospect of increased production; In fact, we are concerned with a decreasing supply. .1 v-i: The substitution of the mnercl ol imprgnant would be exactly opposite to our environ mental and conservation efforts. We would use twice as much energy to produce both the pulp and the paper and would deplete our wood and chemical resources by an e q u als amount. In contrast, our efforts have been continuously directed towards the reduction of the paper dielectric thickness, increasing ccpccitance, and so reducing the amount of paper required. The use of mineral oil as a substitute imprgnant is not a feasible solution for the TSIEL 000360 782206 ../... Peter j . ScHveitzer D iv is io n i*ct*w* c,:o p o <*tio \.tf - M r. Richard Rollins JA R P Company, Inc,_________________ - 2 - __________________M arch 14,1974- reasons given above end would also have a negative environmental impact. We think it would be better to delay the ban on the use of PCB until a high dielectric constant imprgnant could be developed. Sincerely yours, PETER J.SC H W EIT ZER D IV IS IO N N V ___/' / C cC fC tws abc Thor W . Steinert M arketing M anager, D ielectric Pcpera NEL 000361 * 782207 PRODUCT QUALITY STAFF G E N E R A L ELECTRIC 1 RIVER ROAD, SCHENECTADY. N. Y. 12345 SUBJECT MONTHLY ACTIVITIES REPORT Janes S. N e l s o n _________ CO PIES: F. S. Rothe April 29, 1974 Mr. J. F. McAllister NEN YORK Dear Jack: The following is my April activities report: 3Li 2. PCB Hearings Our impressions of the EPA hearings on Toxic Pollutant Effluent Standards have been covered in letters dated April 12 and April 17. The Department of Commerce has filed a letter of comment with EPA. In the section on PCB, the Department quotes extensively from the GE testimony relative to economic impact. Present information is that EPA wishes to hold PCB hearings on May S (to be confirmed). NEL 000362 782208 G E N E R A L iSm E L E C T R I C Mr. J. F. McAllister 2 REDACTED April 29, 1974 JSNrev Enclosure Very truly yours, James S. Nelson lfii- NEL 000363 782209 1.1 PRO DU CT Q U A LIT Y ST A FF H E R A L D ELECTRIC 1 RIVER ROAD. SCHENECTADY, N. Y. 12345 SUBJECT Cc (P :m 3*235-2261 C O PIES: SM Rich el' May 6p 1974 Mr. J. F.' McAllister NEW YORK Dear Jack: Supplementing our telephone conversation, here are some notes that strike the highlights of federal environmental legislation. I 'm giving a copy to Stu Riche1 so he can flag any errors that these notes could contain. v. Very truly yours, JSN:ev James S. Nelson !fi} j J U j L U & - J lO~lsJ NEL 000364 S. M. RICHEL 782210 HOTES ON FEDERAL ENVIRONMENTAL LAWS AIR POLLUTION The Clean Air Act - 42 U.S.C. 1857 et seq. With respect to air pollution, The Clean Air Act, as attended, is the primary statutory authority. Its principal features are: 1. Air Quality Control Regions (Section 107). States are divided into Air Quality Control Regions, with each region classified (I, II, or III) as to compliance with each of the ambient standards. There are over 200 regions covering the United States. r 2. National Ambient Air Quality Standards (40 CFR 50: FE 22384). Standards define the objective for implementation plans administered by the states. Primary standards are those intended to protect public health and secondary standards are those intended to protect public x*elfare. Pollutant Standards: Primary and secondary standards have been promulgated for six pollutants (40 CFR 50; FR 22384): Particulate matter Sulfur oxides Carbon monoxide Hydrocarbons Nitrogen oxides Photochemical oxidants A ?nsc Hazardous Pollutants (38 FR 8819): > (S' C* Standards have been issued for three "hazardous" pollutants: vr c\. ^ ^trurce Standards: Mercury Asbestos Beryllium 4. t 1 ,<r` . c New source standards have been promulgated in several different industrial categories (40 CFR 60; 36 FR 24876, and other). The most /~ recent example is Organic Chemicals Manufacturing Point Source Category \ (39 FR 14676, April 25, 1974). Kry Amendments Under Consideration. ooorwX OJ On U Several amendments, intended to help alleviate the energy crisis, are reportedl under consideration in the Congress: Conversion of oil-fired power plants to coal Elimination of the "non-deterioration" concept Permitting "intermittent" emission controls The first of these would free up oil for uses that cannot be served by coal; the second would be a legislative answer to the court determination that forbids states 782211 Notes on Environmental Laws 2 now enjoying air cleaner than federal standards to industrialize to the point where present air quality would deteriorate. The third would permit use of lessclean (more available) fuels when conditions favor good plume rise and dispersion. WATER POLLUTION Federal Water Pollution Control Act Amendments of 1972 - PL 92-500, 86 Stat. 816 33 USC 1251 et seq. The principal statute is the Federal Water Pollution Control Act, most recently . amended in 1972. The P.efuse Act of 1899 is regarded as of historical interest, because it was used to get the EPA started on a vigorous control program before the passage of the FWPC Act in its present form. The Water Quality Act of 1965 required all state and U.S. jurisdictions to develop water quality standards for interstate" waters, and to submit these to EPA for approval. The FWPC Act Amendments of 1970 based the then-current permit program on ambient water quality standards. This was found to be impractical, and the 1972 amendments rejected, this concept and required each polluter to place controls on his operation reflecting: BPT - best practical technology (by 1977), and BAT - best available technology by 1983. ' The significant difference in these two requirements is that best available technology is not limited to practices in the industry concerned, but may require technology transfer, and will frequently result in a zero discharge limitation. The goal of universal "zero discharge" in 1985 is just that, and not a fixed requirement' of the law. Enforcement is by means of a permit system termed the National'Pollutant Discharge Elimination System (NPDES). Federal authority pertains until assumed by the individual states under EPA approval. To date, about nine states have taken over =their o w r ..permit, system, and perhaps more will do so by year's end. ? In the case of an industrial plant discharging into a municipal system, pre treatment standards apply, involving BPT and BAT, as above* New Source Standards, covering new plants and major modifications to existing plants, will reflect best available technology. The law also provides fox construction grants (municipal facilities) and for fines in the case of spills of oil and hazardous susbstar.ces. In the latter connection, "hazardous substances" are not as yet defined. Toxic Pollutant Effluent Standards (now in the proposal stage) are to be superimposed on the permit system. Current proposals cover mercury, cadmium, cyanide, and ?C3 among other materials. The PCB standard is widely regarded as unattainable and is the subject of vigorous attack at the current EPA hearings (as are also the standards for the other materials named above). NEL 000366 782212 Notas on Environmental Laus 3 OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970 - PL 91-596 The declared purpose of the Occupational Safety and Health Act of 1970 is "to assure so far as possible every working nan and woman in the Nation safe and healthful working conditions". Administration is vested in the Secretary of Labor. Standards are promulgated in the Code of Federal Regulations, Title 29, Part 1910 (36 FR 10466 et seq, May 29, 1971). Thus far, the principal product impact has been in terms of OSHA noise regulations, and in terms of transforming the National Electrical Code from a set of voluntary or local standards to a matter of federal l a w -- and applying it to industrial apparatus where it has never been invoked before. NOISE Noise Control Act of 1972 - PL 92-574 The Noise Control Act of 1972 is distinguished from all other environmental laws in that it is the only piece of legislation, to date, aimed specifically at the control of the characteristics of products. The law required EPA to publish "scientific knowledge" relating to the effect of noise on public health or welfare, and to define maximum levels of noise consistent with sane. These steps have been accomplished (a few months later than the statutory ? date). On April 28, EPA was to have promulgated a list of those products or classes of products which are f>major sources of noise", publish proposed regulations for products on the list, and finalize same by October 28, 1974. The April 28 date has been missed, but we understand from Dr. Meyer that the list is decided upon, and will contain on initial publication only two items -- trucks and portable air compressors. Two products will be added in the next fiscal.year, one of these to be a consumer product. As matters now stand, standards now in the works (as mandated in the law) include railway equipment, and aircraft. Trucks and compressors are to folloxr. Additional products will be named one or two at a time, at intervals of several months, to allow EPA time to develop standards within the year-and-a half period allowed after a product is added to the list. SOLID WASTE Solid Waste Disposal Act - PL 89-272 (1965), as last amended by the Resource Recovery Act of 1970, PL 91-512. These laws are concerned with developing information, study grants, and the like, and have not had significant regulatory impact. At the present tine, a number of solid waste bills are under study by the Congress. Hatters to be covered probably include (among others) federal product standards concerning use of recycled or recyclable material, equalization of freight rates to remove advantage of virgin materials, credits or other incentives for recycling, labeling systems, and the like. NEL 000367 782213 Notes on Environmental Laws 4 NATIONAL ENVIRONMENTAL POLICY ACT (N2PA) - PL 91-190 The National Environmental Policy Act was signed into law on January 1, 1970. The act established s national policy on the environment, placed new responsibilities on Federal Agencies to take environmental factors into consideration, and created a Council on Environmental Quality in the Executive Office of the President, responsibl* for coordinating Federal environmental programs- (EPA was established eleven months later). The NEPA is felt primarily through its requirement of "impact statements" for all major federal programs, and through the use made of this requirement, by activist groups to delay or modify programs they oppose. RADIATION The Radiation Control for Health and Safety Act of 1968, PL 90-602. Subpart 3, Electronic Product Radiation Control. The term "electronic product emissions" means any ionizing or non-ionizing electromagnetic or particulate radiation, or any sonic or infrasonic or ultrasonic wave which is emitted from an electronic product as the result o the operation of an electronic circuit. Essentially, the law provides for a radiation control program, a continuing research effort, performance standards for electronic products, import regulations, and enforcement procedures. ? J.S.N. 5-6-74 NEL 000368 782214 GENERAL Wm ELSSTH10 GENERAL ELECTRIC COMPANY, 1 RIVER ROAD, SCHENECTADY, NEW YORK 12345 Phone (518) 374-2211 PRODUCT QUALITY <J d O" STAFF Subject: GE TESTIMONY ON PCB May 10, 1974 Mr. Richard L. Rollins Vice-President - Engineering Jard Company, Inc. Bennington, Vermont 05201 Dear D ic k : In line with our conversation in Washington yesterday, I am enclosing a copy of General Electric's affidavits of testimony to the current EPA hearings on FCB's. I was disturbed not to see you on the Albany flight, and I hope your generosity in letting me take the only standby seat to Philadelphia didn't result in great inconvenience. Regards, p . i/ JSN :e v Enclosures bcc: JF McAllister A. Pozefsky SM Richel EL Simons James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000369 782215 GENERAL ELECTRIC GENERAL ELECTRIC COMPANY, 1 RIVER ROAD, SCHENECTADY. NEW YORK 12345 Phona (518) 374-2211 Polychlorinated Biphenyls PRODUCT QUALITY STAFF J May 10, 1974 Mr. Stephen F. Nagy Boot-Allen & Hamilton, Inc. Environmental Resources Group Hanover Road Florham Park, N. J. 07932 Dear Mr. Nagy: We understand that you have contracted to do some research for EPA in regard to the social and economic importance of polychlorinated biphenyls in various applications throughout the economy. We believe that you will find useful the following documents, copies of which are enclosed: 1. General Electric Testimony, FWPCA (307) Docket No. 1, particularly Section 1 - Social and Economic Impacts, presented by Mr. George B. Farnsworth. 2. Letter, J. S. Nelson, General Electric, to Dr. Martha Sager, Nov. 21, 1973, with attachment entitled The Impact of a llBan11 on the Use of PCB in Capacitors. 3. Letter, Bernard H. Falk, National Electrical Manufacturers Association, to Dr. C. Hugh Thompson, EPA, March 25, 1974. 4. Letter, John R. Vollmar, Louis T. Klauder and Associates, to Dr. G. H. Thompson, EPA, March 22, 1974. 5. Letter, JARD Company, Inc., to Consumer Products Safety Commission, May 2, 1974. 6. Letter, Air-Conditioning and Refrigeration Institute, to Dr. C. H. Thompson, EPA, March 27, 1974. 7. Letter, William C. Rountree, Assistant General Counsel for Legislation, U.S. Department of Commerce, to Dr. C. Hugh Thompson, EPA, 3-26-74. (See discussion of PCB beginning on fourth page of attachment) We assume that most of these documents are available to you through EPA channels, but we feel that it may be a convenience to have them collected in this manner. 782216 NEL 000370 G E N E R A L ^ ELECTRIC Hr. Stephen F. Nagy 2 May 10, 1974 If there is additional information which we can furnish that will be of help to you, please let .-us know. Very truly yours, JSN:ev Attachments bcc: EL Dobbins - PITTSFIELD JF McAllister - NEW YORK JF Repko - SYRACUSE SM Richel - SCHDY. EL Simons - SCHDY. James S. Nelson, ConsultantProduct Environmental Compatibility ? NEL 000371 782217 P PRODUCT QUALITY STAFF 1 RIVER ROAD. SCHENECTADY, N. Y. 12345 SUBJECT Status of PCB Hearings CO PIES: R I P arke s, J r / Hay 24, 1974 Mr. J. F. McAllister NEW YORK Pear Jack: Enclosed is a copy of a letter to Division counsels that Stu Richel has written to bring them up to date on the PCB hearings in Washington. I wish to take this occasion to comment, from direct observation, upon the very effective work Stu is doing at these hearings. In preparing GE witnesses for their cross-examination on Hay 8, and in preparing for cross-examination of hostile witnesses on May 20, he showed an understanding of the problems and a sensitivity to consequences far exceeding that of the attorneys for the other companies registered as PCB objectors. His success in getting certain EPA testimony disallowed could have significant impact on the outcome of a review by appellate court, should such eventuate. (To this latter point, see the story in Industry Week. May 6, also enclosed.) Very truly yours, JSNsev Enclosures James S. Nelson NEL 000372 782218 Q S n e ll Foster D. Snell. Inc. ^ ^ fu'~ ' General Laboratories/1^ y 9 j Hanover Road Florham Park New Jersey 0 7 9 3 2 (201)377-6700 M a y 21, 1974 Mr. James S. Nelson Consultant - Product Environmental Compatibility General Electric C o m p a n y 1 River Road Schenectady, N e w York 12345 Re: Polychlorinated Biphenyls Dear Mr. Nelson: O ur Environmental Resources Group study of P C B s for E F A is focusing upon . profiling the P C B using industries from a market, economic and technology standpoint . defining alternatives to P C B s (if these exist) in various end-uses and testing the economic impact of these in selected scenarios. The package of documents accompanying your M a y 10th letter is indeed useful, and w e are grateful for your thoughtfulness. - As we digest the considerable amount of raw information already compiled, w e would like to meet with you to . review preliminary data on the end-uses of askarel type transformers and capacitors . develop estimates of h o w many of these are currently in-service b y application category and service life . define market configuration (shares, product lines, etc.) among the askarel type transformer and capacitor m a n u facturers as well as among the principal purchasers of these 782219 A Subsidiary of 8 0 0 2 'ALLEN & HAMILTON Inc. NEL 000373 !Aj Mr. James S. Nelson General Electric Company M a y 21, 1974 Page Tw o . estimate imports/exports of P C B transformers and capacitors and products with these as components . discuss foreign technology as this might relate to alternatives to P C B s . solicit your views on the degree of technical and economic importance of each of the major end-uses, related to substitutability ~* explore scenarios of further improving environmental management of PCBs, particularly as these relate to discards from non-utility industry applications. f W e realize that these are broad topics, but might serve as a convenient check' list for discussions. I will phone to see if w e can arrange to visit you in Schenectad' at your convenience. Thank you for your cooperation., Very tally yours, Stephen F. N agy Project Manager Environmental Resources Group / w ? * -- -fv FOSTER D. SNELL. Inc. cc: T o m Kopp, E P A Project Officer rb NEL 000374 Foster D Snell, Inc. 782220 G E N E R A L ELECTRIC GENERAL ELECTRIC COMPANY, 1 RIVER ROAD, SCHENECTADY. NEW YORK 12345 Phone (518) 374-2211 PRODUCT QUALITY STAFF May 24, 1974 Mr. Stephen F. Nagy Project Manager Environmental Resources Group Foster D. Snell, Inc. General Laboratories Hanover Road Florham Park, New Jersey 07932 cc: JF McAllister SM Riche1 EL Simons RE: Your letter of May 21, 1974 Dear Mr. Nagy: With our letter of May 10, 1974, we sent to you relevant inform ation that is on the public record. Your present inquiry goes beyond that point to inquire into areas of information that bear upon our position in the industry, strength relative to competition, and proprietary techno logical development. While we are pleased that EFA has become interested (even though belatedly) in learning about the social and economic importance of this material they have undertaken to regulate, it is clearly beyond my competence as a staff man to prepare answers to questions pertaining to the operation of individual business components. I respectfully suggestthat you address further inquiries relative to the capacitor business to Hr. Repko, and further inquiries relative to the transformer business to Mr. Dobbins, at the addresses shown below. It will assist these gentlemen in determining their response if you will provide them with a copy of your agreement as contractor with EPA. Very truly yours, NEL 000375 JSN:ev cc: John F. Repko Division Counsel Electronic Components Business Division General'Electric Company Electronics Park Syracuse, N. Y. 13201 James S. Nelson, ConsultantProduct Environmental Compatibility Edward L. Dobbins Division Counsel Transformer & Distribution Equipment Business Division General Electric Company 100 Woodlawn Avenue Pittsfield, Mass. 01201 782221 PRODUCT Q U A LIT Y ST A FF GENERAL (*|p ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT MONTHLY ACTIVITIES REPORT James S. Nelson C O PIES: F. S. Rothe 9 6c May 30, 1974 Mr. J. F. McAllister NEW YORK Dear Jack: The following notes cover highlights of activities and developments for the month of May: mT IV - PRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB At the request of Mr. Win Pickett, Mr. Steve Larkin, an attorney for Whirlpool, was given a telephone briefing on the status of the PCB hearings and the issues involved (May 6 and again on May 30). EPA hearings were attended on May 8-9 and May 20. The testimony of 6E witnesses remained intact after their cross-examination at the earlier date, and attorney for GE was successful in getting disallowed the testimony of three of the four scheduled government witnesses on May 20. (For evaluation see Mr. Richel's memo of May 10 and my letter of May 24.) Foster D. Snell, Inc. (a division of Booz-Allen & Hamilton, Inc.) has a contract with EPA to develop a socio-economic profile on the use of PCBs, possibly looking toward eventual toxic substances regulations (beyond the present hearings). We have furnished them with pertinent information from the public record, and referred them to Division Counsels when their follow up questions began to touch on competitive matters and other sensitive information. Acting on information furnished by Mr. Farnsworth, Congressman .James M. Hanley (32nd District, N. Y.) has written the EPA regarding the stringent standards proposed. HJSDACT0 5 782222 GENERAL ELECTRIC Mr. J. F. McAllister 2 REDACTED May 30, 19 74 JSN:ev NEL 000377 782223 PRODUCT Q U A LITY ST A FF GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. H. Y. 12345 '" . 7,'.^, j --J - ->i^ TMM SUBJECT > MONTHLY ACTIVITIES REPORT James S. Nelson__________ 8*235-2261 1J t, CO PIES: ' FS Rothe June 27, 1974 Mr. J. F. McAllister NEW YORK U- REDACTED 4. PCB Although the PCB (Toxic Pollutant) hearings have been formally closed, legal maneuvering continues on the admissibility of certain EPA-sponsored testimony and other matters. Slippage of at least a month is anticipated in the promulgation of the rules (scheduled originally for July). V e ry t ru ly y o u rs, JSN:ev James S. Nelson 782224 NEL 000378 'M .S) 1 PRODUCT Q U A LIT Y ST A F F G E N E R A L ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT 4M 4 8*235-2261 | CO PIES: J. F. McAllister R. Muller D. T. Richardson F. S. Rothe July 15 1974 Mr. C. R. Thomas 14th Floor 570 Lexington Avenue NEW YORK, N. Y. Dear Curt: 1 am completely in sympathy with the objective of a unified system for cataloging our publications. The "PQS" decimal system looks like it would do the job; however, on reflection, X see no need for the additional complication of a "supplement number". The only bulletin now falling in that category, the one on PCBs, could just as readily have its own three-digit number, such as, for example, PQS 3.02 or PQS 3.03. We are faced with the necessity of reprinting covers for what we have been calling the Product Safety Manual. This now bears the number ENS-P-1, which means nothing to anyone. Have you any thoughts on how to handle manuals in your system? Very truly yours, JSN:ev NEL 000379 782225 L m r& eg o ix J S . V e/so , t PRODUCT QUALITY STAFF GENERAL ELECTRIC FAIRFIELD. CONNECTICUT 06431 SUBJECT MONTHLY ACTIVITIES REPORT (JULY) James S. Nelson__________ Mr. J.F. McAllister Office * COPIES: F.S. Roche August 13, 1974 REDACTED !fJ NEL 000380 A. PCBs Separate visits by a Monsanto representative and by Dr. Simons to EPA have indicated some disposition to compromise on the proposed toxic pollutant effluent standards for polychlorinated biphenyls, with partial 782227 GENERAL 'M>)a E L E C T R I C Mr. J.F. McAllister 2 August 13, 1974 adoption of G.E. recommendations now appearing likely. The relief in prospect may not be sufficient to permit continued operation of our PCB-using plants, however. Possibly helpful is the active interest being shown by the New England Caucus of Senators. JSN:cas James S. Nelson !fij NEL 000381 782228 October 18, 1974 Ur* W.F. Van Kart, Secretary Ad Hoc Coenittee on PCS National Electrical Manufacturers Association 155 East 44th Street New York, N*Y. 10017 Deer Bill: Your letter of August 27 to members of the Ad Hoc Gomalttee on PCS of the Capacitor Section and Transformer Section Invited response on the matter of EPA Proposed.Rules: Designation and Determination of Removability of Hazardous Substances from Water. This matter has also bean under study by a coomittea of the Manufacturing Chemists Association and I have secured clearance to pass along a memorandum covering that study and Including a draft of a letter of consent proposed for transmission to EPA* Very truly yours, 'Product Environmental Compatibility El-A JSH:cas Enclosure bcc: J.J. Castellanl - Schenectady J.F. McAllister - Fairfield A. Posefsky - Hudson Falls v/anel. 782229 000382 MANUFACTURING CHEMISTS ASSOCIATION 1825 CO N NECTICU T AVENUE. N.W. WASHINGTON, D. C. 20009 (202) 483-6126 October 4, 1974 TO Water Resources Committee Joint Subcommittee on Environmental Law Subject: Section 311 Regulations - Battelle Report on Hazardous Substances Gentlemen: Enclosed are copies of a record of the October 2 meeting of the special joint task group, a first draft response to the August 22 intent publication, and the tentative program for the October 21-23 Conference. If you have additions, corrections or additions for con sideration in the proposed designation response, these must be in our hands no later than THURSDAY, OCTOBER 10. Very truly yours HBB:er Enclosures Distribution cc: Special "A" Joint Task Group H, B . Brown, Secretary Water Resources Committee NEL 00383 782230 Manufacturing Chemists Association Water Resources Committee R e c o r d of October 2, 1974 Meeting of Special Joint Task Group on 311 Regulations Development The joint task group met to consider the August 22 FederalRegister notice of intent to designate hazardous substances; and the August 1974 Battelle NW_ draft final report entitled "Technical Do c u m e n t a t i o n For D e t e r mining Harmful Quantities and Rates of Penalty for Hazardous Substances." Present were: W. Bailey Barton W. C. Brittain John J. Castellani George A. Coffenberg J. T. Curtis George Dominguez Jack T. Garrett W. C. Gaskill G. J. Hanks, Jr. Samuel M. Lane Dennis M. M e a n y (for R. E. Austin) Brock Neely James S. Nelson Joseph F. Knott L. W. Roznoy Howard Schwartzman Jerome Wilkenfeld Howard B. Brown Borden Inc. Koppers Company Inc. *-- General Electric Company Stauffer Chemical Company U. S. Steel Corporation CIBA-GEIGY Corporation Monsanto Company E. I. du Pont de Nemours & Co. Union Carbide Corporation.., Mobil Chemical Company E. I. du Pont de Nemours & Co. Dow Chemical U.S.A. General Electric Company PPG Industries Inc. Olin Corporation The Procter & Gamble Company Hooker Chemicals & Plastics Corp. MCA Staff Task Group Members Absent M. M. Anderson E. H. Bellows J. J. D e l a n e y R. Gregg P . S . Park W. E. Winans Jack Woolley Union Carbide Corporation Olin Corporation Olin Corporation Dow Chemical U.S.A. Monsanto Company Stauffer Chemical Company PPG Industries Inc. Messrs. Hanks and Wilkenfeld were co-chairmen and chairman of the subsequently developed subgroups. Mr. Wilkenfeld outlined the agenda and tasks and W. M. Stover, MCA Director of Government Relations reviewed the legislative prospects of Section 311 and O. Or Oto- - oo ^ 782231 -3- The group felt that the types of water bodies needed better definition and possibly expansion to cover waters such as the inter-coastal canal. The report is lacking in consideration of mechanical details, e.g., dispersion in water bodies; does riot c l a rify the'duration of the discharge as related to spill definition; and lacks in clarity on required reporting and harmful quantity determination of spills on land. It was recommended that EPA after proposal publication conduct regional public hearings. The possibility of assigned costs for removal of a designated non-removal material was discussed. The tentative program schedule of the October 21-23 conference was discussed. The apparent lack of discussion input prior to the EPA announcement of their conclusions is disappointing. The PM sessions on October 21 and 22 were viewed as the more productive sessions and the best opportunity for the injection of industry views and concerns. It was felt important that industry representatives in formal and informal discussions present and reinforce the consensus views. The group requested that the MCA statement draft and meeting minutes b e distributed as soon as possible so that comparable position could be incorporated into individual company statements and be projected at the EPA conference. H B B :er October 4, 1974 H. B. Brown NEL 000385 782232 1st DRAFT - 10/3/74 October 15, 1974 EPA Information Center (A-107) Environmental Protection Agency Washington, D. C. 20460 Attention: Mr. Philip B. W i s m a n Subject: 40 CFR Part 116 - HAZARDOUS SUBSTANCES Designation of and Determination of Removability Gentlemen: W e are p l e ased to respond to the A u g u s t 22, 1974 FEDERAL REGISTER advance notice of intent, particularly on the tentative criteria for selection of hazardous substances and the appropriateness and levels of the selection criteria. Comments on specific substances under consideration and information on spills, spill prevention and countermeasures would be more properly supplied by individual basic chemical manufacturers. The Manuf a c t u r i n g Chemists A s s o c i a t i o n (MCA) is a nonprofit trade association of 180 United States company members representing more than 90% of the production capacity of basic industrial chemicals within this country. As manufacturers and handlers of chemicals which may be designated as hazardous, our members have direct and critical interest in the Agency's promulgation of a list of hazardous substances, subsequent establishment of harmful quantities and rates of p e n alty for such substances and the enforcement of provisions of law pertaining to onshore and offshore facilities. 782233 i NEL 000386 3a procedure will, in our opinion, correct a basic defect in the Act and avoid the probability of legal reporting being required before the basis for harmful quantity is known, it also will make available the elements the Administrator requires in his execution of discretionary determinations. Our specific comments on the notice of intent regulation address the general areas of I. Criteria Selection, II. Removability, III. Proposed D e s i g n a t i o n List*, IV. Spill Prevention, and Vi Impact on Transportation of Chemical Products. These are presented as an appendix to this covering letter. Sincerely, W. J. D r i v e r Attachments 782234 N eL 000387 DRAFT - HBB I. C R I T E R I A 1. F o r the following reasons, we r e c o mmend t h a t the aquatic animal T LM (96 hour) criteria b e reduced to 100 milligrams per liter or less. The IMCO/GESAMP guidelines for profiling hazardous materials, when considering damage to living resources, rate a T L M (96 hour) to aquatic life in the range of 100-1000 parts per million as "practically non-toxic" . (Battelle Report, Appendix>J3r2) .* It is reasonable to expect that in selection'of a criterian some consideration should be given to the magnitude of a spill that would make the criterion operative. We believe that the .. i!iiif^ size spill associated with reaching a 500 mg/1 concentration '.Mr ***-:*> in most waters is so large as to make the selection of this value unreasonably conservative. This was demonstrated in an evaluation made by a panel of experts of the IMCO/GESAMP Sub committee on Marine Pollution, of the discharge potential into various water systems. The purpose was to evaluate the range of concentrations to be reached by a material discharged in varying quantities into aquatic environments. Three typical, systems were identified -- coastal waters, estuaries, and rivers. On the basis of the calculations of these experts (summaries are appended *) the following table of concentrations NEL 000388 * Note that threre is an order of m a g n itude error in the IMCO cal culation of concentrations in the cause of a spill into a river. The corrected IMCO values are shown in the attachment. 782235 *!?.)nr: -3- substances w i t h L D ^ q values in excess of 50 m g / k g b o d y weight would, in spill situations, reach such concentrations that mammals could ingest in sufficient amount to produce a lethal dose. The use of a skin penetration criterion of 200 mg/kg body weight would be reasonably consistent with the 50 mg/kg ingestion value. The same is true with the vapor inhalation criterion of 200 ppm. However, it is questionable that m a m m a l i a n contact with water would produce the degree of skin absorption for the period of time to cause a lethal effect (24 h o u r s ) . EPA should reevaluate the use of vapor inhalation criteria as a decision-making mechanism to determine if materials are hazardous when spilled into navigable waters. If retained, the volatility of a substance be designation criterion. A suggested limit w o u l d b e a vapor pressure of 1.5 as u s e d b y EPA for designation of volatile organic substances for purposes of control of air emissions. II. REMOVABILITY In the advance notice of proposed rule making, it is stated that ..."In other words, if the spilled substance cannot normally be removed from a water body by physical, chemical or biological means, then it would not be 'actually removable' for purposes of the eventual hazardous substance designation." Removal by chemical or biological means has not been given X due consideration in the listing of candidate hazardous substances. For example] the relatively simple addition of alkaline substances oo OLO 00 782236 IV. SPILL PREVENTION -5- The members of the chemical industry have not ignored the importance of spill prevention measures. Incorporation of facilities and operating practices to reduce the likelihood of spillage, and the development of spill contingency plans, are practices followed by most members of the industry. We expect individual company comments to include reference to these programs. it NEL 000390 782237 . .* : ; ;* -J ;' * 1 X/ \ , '* u - p1i J o iX cs I I 1 N i*-3 :.t .-- CJ mJ u. ;. CT. - f V O * vrt p " * y -- >"< Z* taj i" ^ z - ~r jT,* n i ix i > r '<! - J -r -r v* r - -*j Ir! p l*-' LU H4 CZ CZZi >-- - '< CL U * -V- #" c. zs w , l/ -- i ~ H ri LT i* ;,; '/ ^ 1 ^*( fcfc" - " .*7-T -*r l_ -' ' ' 7 - .. -. .---'-*' * *'*** ' ; -*.--v ..M..........., .. *1? 1 iT U L'- <* 4-* il* w. i-t **- U **: /-- 'f'* :s i-- r f* * - t i Ti ^--. A: -M C c ^1 a u r. C E. a iS: mT* i- -C s'* i ir r> ' * i- .'. "i I < KJ C i - *t** ,z jC *k <, i : *l 7 ' * ->n c ` Ut*U 4 r" i "l T, z. ZI* rC l: "k f-- 1"? *,* %n_\ * Vj T : *R /I i' jlT *^ *a-- % -C C c V 1 u* CJ ir-- * o v< O u C r** u v* T&f O .,C**J1 n 5* 3 *Q ip ;V a Al a 4 ~ 4*> 4 4 E h^ -T> U* v i- s i C. CJ s ^ kn /j; a-' U- ll* M ir t: a> *r* jC +J O CI U X: iZ >* cr. c Cr. C i i V" V - i*. 'V , p* * j7- #5 kJ s*<i => -n O */ 1*>. *2* & V u c ? *A Ti VI CL rfii `Q TZ V. L_ C;/-* *4 3 /% u '4 a t* r% r: X ir ^Z' +J ,,-- M-- o L-C JZ* A a V-- iy w O u SI rw a" 1^ r,i 4 Oi c u V T^> z~ V a-. WO |J c *-- S I u ;, =1; * u -n a c O v^ '>- /* O V* T3 ? Cv 'i k* "* u 1**' p- c: h3 ).* 2 tJ " ir X' HT Cj d i-i ,,X" 1- i", V-" 4* f -- .** . `.* li' 1- V * p* < >** *2 - i~> .a ' *1vV. vi *^>1. i t ri r 44 **ACi* 4 r 4- * n *, cz uT l i i* w*t i-- Mc a; Si X 44 X u ,1', */" ,*%' *n :*t 1u b*; kr--- j. i_ 'c : r *r-- c a ----i u a: p r" r? c JJ o X". t UE cr rf-k ai CJ x : jC ra P a. V`Irf m *> c. 3 jC c 4 J +- / L. p |p* a i t * 'C -M *r- CU bA cr O a; jr c Li/*. p -JC cc s> 4^ ;rt c I-- * 4 SJ c * up 75 /" c L* s - Ol *r-- il 1" Ol .,-- o 1^U-- tn. tA X- LA tv' 1-- o -M E p a c. *v--ii jZ i/. r C >C- > ij */-- ..-- * 4 X. Cj r- -1 t- i-. -C '7 ,i .r' il. |.' Ti1 ir. ;* i-- i *p -- NEL 000391 782238 A J 1 *J T ' >, 1 iti H C * 1 _*" s v>* l/t ,s" .# .** ; j T - jC r (#l ; - u: - C* r~ -T 3 ' -f* .* - -7 *** r 1 L * i. c --i .f. .V * j,4i 7 ni c. CL 1C uV ,H 7 f L V ZjZ f-- *r* La b 'i ** ^p- i: V7 j -- a V* U j *jr V - .t: i" , ,C r-- u * - -C * c ; fc 4J r-- r** 'li t-- ! 4-* *T! J < * r* "* c -IT C* *p* *-*- V - 4j j Z sA <L 5- - - *-- n , o *?--' *-- j r " k*< il* V i* y p L VI Tl CU O * c c.> 'C it 4-* 4 / J ' 3 li VP T i TTi -; C I 4-- L . a j p V V i l* 4J <a C : ;j 4-1 D i a- 1* r** p-- -a ** -t-i -* 1C c w Ci e iC Si o ru irp 4- 7 C l -*T o ./- >j y c : U' w =U a i VP- V -a 7* o; i- /* 4 -* *t- cr> c . 1; oC u C i <l> A z* * ai i- w. *4- |W L a >> c : n r- a *-- * * -o `17 j ^7 V. c ai a> 01 L> %n 0 : V . 4X *<: p* t% R E u 5 V-* C Q> .'U *A L vi C i u >-t 4 J u*< Oiir u U o p" 4-t V C* y- - - V-- r Q . *Q M r* w rpj c w* C X I 4-4 ^1 -4-1 C a *-- p" > > <#* 4/ i / i . 4 C <1 A S 'i jC JQ 0> rti T" SX c 7--, 1"** 0> o 5* ***b* ++ vC 1 / w r; c - CR > /u o tu ai 1 C 75 Q> O '. *4 +-* V .t> w * p-- i* " Jj >p> u u a* !*. 4--* r-- U J5 Ci a >> r-- 0= 4 - r** ***" o CTU1 4-3 4 f- i o a> 44 i d u 1 -a pJ n i U^ r# cz C* -O rr - = i-- c p p r-- c 3^ 4-* t i-- y o -vi CM a c 4" r* i / t r-- ft i M r- -a 31 * (X ** 1/1 < v i tc CL r* 4 - O r" * * n w-- -- c. c LC o tr < _ IO r-- Cp LU a a" w ** C *t u X -* 1 . -C $ rp w < **- u O u J 4J U * /t i.*. Cp u: 3 S2 ** * .a a t su L i r* J t <1 a c Ci> c p i r* F * o o a. /j f i, s L- u-. 2 C 71 C -1 w * o 4 A Q: -13 4--< iLj P-" W C a u * Q Ci SU c . t .a u o **%'i o *-i " I >j S: t . l* i k> 5.' * V** s i w- o .L I Cl o +-^C r rt- ai L? L 7 ia . ." CJ p^. Ci 5 w -cr X " 'f Nt * -C*. s* 'S * * /l -J- ,, I cY. VJ CT IX* oM c V 2i ,7. *r, i.H j L' .* - *V a: * 4* V i *-*- ij- T*` rr. p1; i l I Vii S . ] * .'i. f-- r i >, y , T# 1- j**. f * r .T .11 72 'J CI J* i '; *4-* :3 <L* *./. ,cT -1 c> L- k*.. jj Y" o r-f si! zz'ir u,?js proq-j uts mivir,o by water have beer, spi 1)ed c u r;ng tn .* r-r *.oj Of T iP ? - and we b e lie v e t h e e *5 s i g n i f i c a n t C4irs?l re la tio n s, h ip fe rv e e r t h " . * f :_Ls i;i*a current in d u stry practice , bC-J with current S _ ' v C r r : f r e g u l a t i o n s ' . o :,-y.z o r . s u c h n ? v ? s . i nc U. 1'. -oast 6ujrdr `under Sts Snochapter "O'1 requi rc-"i:rM , i:t s ^ df.-.,1e- i'ullECi i*r.c r ic t ions r.r< the rw3nsni of hazardous products in the vaiurviv s y z ter. while !:'?- regulations were rost sp e c ific a lly designed to protect ru-an Tifp 7.3 z by5 1 v t pre 3er ty, t hey nonethe less have had a corollary e f hec t of t rotec i r n ti-<j_ e ,- i r-r.-r *-*:, so th i and and water. The passage of the Forts and Vate rv ay S ' et v A rt, a: : 7 as the Eridge-tO-5rfdCir Padio Telephone Act* hsvs cr.rtrit-Ced t-.Tward irpr*:v*L.: safely in ihc rwvcrfint of 11 products on the water*** vv-itc--. Thes* two L?ws* rt v s il as Sufcchapter t:0n irp le ^ n ta tio n , have occurred s i nr Public La.v fii-bT? w.-;i passed, and thus, we believe, should be take into- account as n W ir v ;-otes l-p; pro* ..Incted in rt^ victory fashion i f we are t r e a t in g to provide ar i r i^ n iv c for water quality ir-proversa t . Towing Vessel Operators Licensing Act bar ajzr- tec-sna law sin ce Public Law 9Z-5D0 was passed, and th is further stimulates safe T ra n sit of a ll products on the waterway s vsten*. Tr.? ~-- ~z rif the designated products is considered essen tial to the nenerul c . t y amps t a ll observers, and thus, the objective p.i/st regain to r-jve such grud^ U in the nust safe system of tran sit and to provide Incentive to co th is. Wr- h - lie 1 th at, properly structured. Section 3)1 regulations t?n contribute t:. [Ms e L jC itiv e , but that further appreciation of the decisions shippers nust aK* r.rc-:" t-> os understood fay those drafting the regulations. NEL 000392 782239 The requirements, both on land and water, Imposed by DOT, PfiA, and the Coast { Guard virtu a lly dictate high minimum standards fo r the vessel enntsining the i product, no matter what node. Land-based movements, fo r example, bv tank car } under close regulatory direction of the DUl/I KA would require stated periodic , inspections of not only the running gear on such v e h ic le s , hut also nn the ability j t j of the vessel to contain its contents, as w e ll as the op erability of safety j release devices attached to the vessel. In the ease o f tank cars, there is even a schedule by which old cars must be re tire d * no matter what their apparent ;* L f physical condition or what preventative maintenance procedures have been used^ j This schedule of retirement precludes a n cie n t c a rs from causing severe environmantai in su lt or physical injury by slip p in g through maintenance and testing pro- | t cedun?r.. The AAR has a very precise set of rules for interchange which co n cise ly a f f ix e s resp o n sib ility for inspection ! ! i of running gear to the receiving c a rrie r to fu r th e r ensure the safest transit | possible. From a highway point of view, Government re g u la tio n s cover medical exams and work* hour schedules for drivers. As in the case w ith r a i l c a rs , specific requirements I * ,1tir | t- J fo r design and inspection of the v e h ic le , aiming at both operational safety and containment of product, a* required, We believe that significant s p ill prevention p ra c tic e s at considerable associated [ i j* }i { | costs have been demonstrated to EPA in co n ju n ctio n with th e ir contract project with [ fiat t e lle Northwest, and that this should be taken into account in the promulgation | f Of fin a l regulations in this area. Punitive penalties, however, are what are l i k e l y to cause a serious economic dis ruption in this matter, and one need only review the recent activity related to the'. NEL 000393 782240 -vr-fi.:.*; -SRit/lKT 4 i nf Florida's approach to water q u a lity assurance by imposing punitive Pencil tie s for sp ills to realize that economic d isru p tio n is certain to follow such actions. The state Of Florida's recent repeal of th e ir punitive penalties provider, excellent material for consideration as we proceed with urumiilgatlon of regulations under Section 311. The MCA continues to be most desirous of providing a ll technical and economic input available from its member cco an les to FPA in an e ffo rt to assist L*DA 1n drawing up meaningful and substantiate parameters ag ain st which the regulations can be derived. However, we w ill continue to seek le g is la t iv e r e lie f from those aspects of the Law which we feel are no longer necessary due to events which have transpired since passage of the Law.and s p e c i f i c a l l y covered In language on page 134 o f the Conference Report filed on this B U T . 782241 oor u> VO PRODUCT QUALITY STAFF G E N E R A L ELECTRIC FAIRFIELD. CONNECTICUT 06431 NEW SCHEDULE FOR PCS REGULATIONS yi-1 COPIES: John F. McAllister - Fairfield Edward L. Simons - Schenectady Stuart M. Richel - Schenectady November 1, 1974 Edward L. Dobbins George B. Farnsworth Lucas P. Hart, Jr. lee H. Hill, Jr* William F. McManus Charles J. Meloun Russell T. Morris William M. Nave Abbott Pozefsky Edward L. Raab John F. Repko James 0* Sweeny James H* Thayer - Pittsfield - Syracuse - Hudson Falls - Pittsfield - Washington - Pittsfield - Rome - Philadelphia - Hudson Falls - Pittsfield - Syracuse - Pittsfield -u Gentlemen; Dr* Kenneth Mackenthun, a limnologist of national reputation, has been named Acting Director, Technical Studies Division, EFA. He is now responsible for the program to implement Section 307 of the Federal Water Pollution Control Act* At a meeting in Washington yesterday of the Effluent Standards and Water Quality Information Advisory Committee, he announced the following plan for development and promulgation of Toxic Pollutant Effluent Standards for nine materials, including FCBs: Mid-December 1974: Advance Notice of Proposed Rule Making to be published in the Federal Register. (This will be a complete set of proposed regulations, and will allow public participation to begin without starting the ISO-day clock running toward the deadline for promulgation.) February and March 1975: Symposia on the advance notice to be conducted in about half of the ten regional EPA offices. May 15, 1975: (Approx.) Publication in the Federal Register of the Proposed Rule Making. MEL 000395 782242 GENERAL ELECTRIC November 1, 1974 June 15, 1975: Start of formal public hearing (similar to that conducted in April and May of 1974.) Late October 1975: Promulgation of Final Rules Present lav states that the rules shall go into effect upon the date specified in the promulgation order, but not later than one year from the date of promul gation. Under present lav, we would anticipate that, if the above schedule is followed, standards for PCBs would become effective in October of 1976. If the EPA gets the amendment to the Act it has requested, this date could be as late as October of 1978. EPA failed to impose the standards it proposed the first time around. However, its decision to re-propose should not be interpreted as evidence that the staff now subscribes to the arguments contained in industry testimony, or that the proposal to be disclosed in December will be capable of attainment. JSN:cas James S. Nelson, Consultant -Product Environmental Compatibility El-A NEL 00039 782243 / tOs o j . . -'-G'.-.U. Subject: PC.-- 3FILL ! *j .' ./hen: November IS, 197h f at : 3 0 FK. '` .here: Trion, Georgia (about 20 idles north of Hone, la.). How I.ueh: 270 gallons of Pyranol, approximately, and cGO gallons of 1 iZ transformer oil. There were six transformers involved, t..o of widen contained Pyranol and the otner four of wnich contained 100 oil. Type of Accident: A., accident involving a truck transporting six transformers. Terrain: The spilled fluid went into a roadside ditch and thence into a field. The nearest significant water body is believed to be tne Chattooga River, about l^g rales distant, which supplies drinking 4`jater. Siuorgency Measures and ll-tifinations: The Kedium Transformer Products Department, wnich nanufactured the transformers involved, has notified Georgia autnorities, tneir '.ivision attorney, D.L. Dobbins, and Dr. mi Simons, "like11 Dobbins instructed tiiem to notify tne _PA (even though m?A nas no jurisdiction unless ^ ?/ the spill reaches the water) . Mike notified Electric Mutual Insurance Co., wnich carries a ^25000-deductible spill insurance policy on Rome. He also ascertained that this office had been notified. Rome has dispatched Tom .Tichols (exp rienced i:i tne Kingston, Tennessee clean up) and Picard Lester, plant engineer, to the scene, .varth and hay-bale damming h a - been done. Digging and soil removal is to be done to the satisfaction of Georgia authorities, or at le .st to take care of visible effects as a first sten. The transformer^ a.ij trrek are to te wiped clean before returning them over the read. NEL 000397 octree of above i-.forf.atioi*: Two tele- none calls from Dr. fitons, in the foren. on of m-vember 19, 1>7U* -r* oir.cns ilans to write a ...c:.orandum and revise .s wit., a cun J.5. kelson, 11-19- I k 782244 L 3 - /// 8*229-2287 J.F. McAllister - Fairfield J.M. Phillips - Schenectady E.L. Raab - Pittsfield November 22# 1974 Mr. John Fagel Laboratory Capacitor Department Hudson Falls, New York 12859 Deer John: Of possible Interest is the enclosed from EPA's environmental monitoring series, "Estimation of Polychlorinated Biphenyls In the Presence of DDT-Typa Compounds." The paper discusses a loi temperature luminescence technique. Very truly yours JSNtcaa Enclosures James S. Nelson, Consultant Product Environmental Compatibility NEL 000398 782245 TECHNICAL REPORT DATA (Pleuse rc s d in siru c n u n s on m e rc v c n c b etre contpletin gt RT 3 . R E C IP IE N T 'S A C C E S S IO W -N O . EPA-670/4-74-004 1 T T l E AN D S U B T IT LE Estimation of Polychlorinated Biphenyls in the P r e s e n c e `of D D T - t y p e C o m p o u n d s s. r e p o r t d a t e J une 1974; Issuing Date (^P E R F O R M IN G O R G A N IZ A T IO N CODE 7. A L -T n O R iS ) J.T. Brownrigg and A.W. Hornig 9. P E R F O R M IN G ORC* \ N lZ A T I O N N A M E A N D A D D R E S S Baird-Atomic, Inc. 125 Middlesex Turnpike Bedford, Massachusetts 01730 8. P E R F O R M IN G O R G A N IZ A T IO N R EPO R T N O . 10. PROGRAM ELEM ENT NO. (16202GIY 1 B A 0 2 7 ;R O A P 0 9 A B Z ;T A S K 0 1 3 11. C O N T R A C T /G R A N T NO. 68-01-0082 12. SPO N SO R IN G A G E N C Y N A M E A N D A D D R E S S National Environmental Research Center Office of Research and Development U.S. Environmental Protection Agency Cincinnati, Ohio 45268 15. S U P P LE M E N T A R Y NOTES 13. TYPE OF R EPO R T A N D P E R IO D C O V E R E D F i n a l R p n o i-h . F e b r u a r y __ 1974 .. 14. S P O N S O R IN G A G E N C Y CODE 16. A B S T R A C T Earlier studies suggested that the low torperature luminescence properties of PCB's and DDT compounds could be used to identify these oenpounds singly or in mixtures. "he present investigation was undertaken to develop a relatively simple, rapid .etbod for estimating these oenpounds in water. The emphasis in this procedure has been on the inherent sensitivity and specificity of luminescence, avoiding chemical s^aration where possible. The present procedure involves collection of grab samples followed by extraction, drying, concentration, and redilution in a seaond solvent suitable for luminescence measurement at 77K. Studies include the determination of recoveries and detection sensitivities for some of the oenpounds of interest and also analyses of several environmental waters. Detection limits for p,p'-DDT and Aroclor 1254 doped in 1-liter samples of pure water were found to be approximately 0.5 and 0.03 ppb respectively. Sensitivities were reduced by an order of nagnitude or more in natural waters having high levels of dissolved organic material and particulates. This is due to a ccnbination of poorer recoveries and increased fluorescence background. Both of these rerain as probleareas deserving further study. Phthalic acid esters have spectral features resemb ling certain Aroclors and irav constitute an interference._____________________________ 17. K E Y W O R D S A N D D O C U M E N T A N A L Y S IS 1. D E S C R IP T O R S b .lD E N T IF IE R S /O P E N E N D E D T E R M S c. c o s a t i Field/Croup *DDT, *Fluorometers, Spectroscopy, *Aroclor, *Analytical techniques, *Water analysis, Aromatic compounds, *Pollutant analysis, Chemical analysis. Water pollution, Chlorinated hydro Chlorine aromatic compounds, carbon pesticides, Polyphenyl compounds, Luminescence *Polychlorinated biphenyls, *Low tem 1C 13B 19. D IS T R IB U T IO N S T A T E M E N T Release to public EPA Form 2220-1 (9-73) perature luminescence 19. S E C U R ITY CLASS (Tilts R ep o rt! 21. NO. OF PAGES 2 0 Un . SE clas C U R IT Y sifi CLASS e(Tdh is p a g e ) 100 2 2. PR IC E u n c l a s s i f i e d _________ 90 ft U6BI1W EIT w m e e t e t IW * -71 7 -S M /S U 4 782246 NEL 000399 8*229*2287 MONTHLY ACTIVITIES REPORT (NOVEMBER) J n i 8. ttolioa 7.8. Both* November 26, 1974 Mr. J.F, McAllister - Office 17 FKOPOCT PTgTgflBmmt COHPATTBILITT X Me Schedule for PCB Regulations d M r i l Electric cook a load rolo lo opposing tfao PCB ofeoadordo proposed by EPA almost a poor ago, and, on eho Company's motion filad by Stuart Riche1, tho testimony of several EPA exporta vos dlsalloued. As a rotule of chis offort, and similar suseossful opposition by companies involved with otbor nstorials on tbs list EPA is starting orar, on vhat ovoryons hopos ill bo a sounder basis, to develop standards for nina "toxic pollutant effluents." This action vill begin with an Advance Notice of Proposed Rulo Making in December, continuo vlth fonal proposal in May of 1975, and euIvinato with prooulgation of final rulos not oarllar than October of 1975. The affective date probably vill not bo earlier than October 1976 (and could be as late as October 1978, if EPA gets a requested amendment to the Act). Thus, at the least, additional time has been gained for development of control measure and/or alternative technology. The nev schedule, announced at last month's meeting of the Veter Quality Information Advisory Cornelttea, has been o f infsated to key personnel in the PCB-uslng components. 2. KB to rn A truck carrying O.E. manufactured transformers overturned 25 miles north of Rome on November 18, with spillage of soma 300 gallons of Fyranol. Although 6.E. played a role in notification of authorities and initial spill containment, it is now considered that responsibility rests with the customer and/or his carrier. REDACTED 782247 o J.F. MeAlllftar .v p r* 2 S o m b t r 26, 1974 JSHj c m O M r J.8. Xalioi 782248 N E L 000401