Document LKXmQKYQKwxkjK9YjqNNyvK27
Monsanto
FROM (NAME --LOCATION --PHONE)
J. H, Craddock-^--63WD - 4-4764
: July 16, 1985
: E. F. Hohlfeld Achievement Recognition
REFERENCE
R. B. Phillips CS7N
W. J. McCarville - G3WD
I want to take this opportunity to recognize the support and achievement
that Gene Hohlfeld has made to the PCB Issues Management Program over
the past year and to suggest his nomination for an achievement award
for his significant accomplishments.
r
Gene was instrumental, this past year, in reviewing several sets of proposed PCB-Transformer Regulations being discussed and proposed by EPA under the Toxic Substances Control Act. His line by line analysis of these complicated proposed new rules and his comments on suggestions for workable alternatives were used in large part by the Chemical Manufacturers Association PCB Program Group for the chemical industry response and rebuttal to EPA.
EPA issued the new Transformer Fire PCB regulation July 1, 1985. In many
provisions Gene's analysis and suggestions were fully taken into account
and are implemented as the new PCB transformer regulations. In essence,
Gene's analysis and suggestions resulted in exclusion of the chemical
manufacturing industry sites (as well as that of other industries) from
the 5 year mandatory transformer phaseout, as well as other onerous and
costly provisions.
Adoption by U.S. EPA will result in a Monsanto cost savings in excess of $15 million over the next 5 years plus cost of business interruptions.
Gene is still in the process of contributing to this program and is, in fact, reviewing the new PCB rules for technical content to insure that no errors have crept into the actual regulations.
I applaud Gene Hohlfeld's efforts and significant contributions to the PCB Issues Management Program and certainly support recognition of his accomplishments via an Achievement Award or other appropriate recognition.
ve
IN - JO (REV. 8/7 7 )
PCB-ARCH-EXT0378136