Document MJNKq92jZ9x5B4JykoaXb38a

I * Monsanto . A*M 4NAMC A A AtC IM4C1 i, irtnttCi TO ' : E. E. Stewart, W. G. Krummrlch Plant CONFIDENTIAL October 26, 1972 POLYCHLORINATED BIPHENYLS WOK STRATEGY MINUTES OF MEETING - 10/20/72 " A. E. Lelsy W. B. Papageorge - B2NA O. L. Bratsch -W. C. Engman P. E, Helsler O. A. Hlppe P. B. Hodges J. R. Savage E. E, Stewart - E1SF B2SL The above met to review the status of the WOK strategy for dealing with the federal and state authorities with regard to "Polychlorinated Biphenyls and the Environment." Information presented for discussion and future actions to be taken are summarized below. I. An "in-hand" status report was presented for the Federal authorities on what we have done .are doing . and will do at WGK to control PCB's from the environment. DISPOSITION: Where necessary, sections will be altered to reflect that we have and can meet the expected EPA guideline. In the original version we stated we expected to be tenfold better than guideline. (The assumption has been made that guideline will be based on concen tration in the receiving water, i.e. Mississippi River). After corrections, all will receive document for review. II. Oraphs were presented showing current knowing losses to be about 0.001 ppb as a calculated concentration in the Mississippi River. Based on measured losses from the Aroclor and Incinerator areas of about 1 #/day. Losses at the Waste Treatment Plant Effluent of about 5 #/day are equivalent to a calculated concentration about 0.005 ppb In the Mississippi River. ' III, fish data were presented. DISPOSITION: River water samples will be obtained up stream and downstream. Will sample above and below plant outfall and upstream on the Mlsslslppi, Missouri and Illinois Rivers. Expect to be abl^ to measure down to 0.05 ppb concentration. m . ncv. /?* MQNS 029531 POLYCHLORINATED BIPHENYLS WOK STRATEGY ~ MINUTES OF MEETING - 10/20/72 Page 2 10/26/72 WOK IV. A Brief comparative review between WOK and governmental methodology was made. Hap Horner visited government labora tory at Cincinnati on 10/19/72. They start with larger sample and evaporate to smaller amount, use different organic solvent and employ different initial sample clean-up procedure. DISPOSITION: Hsp will issue a report and differences will be resolved. V. WOK - EPA CONTACT Initial contact will not be made until we know for certain that limits will be established on PCB. Strategy is then to have limits established that we can attain. A. 180 Day Notice - Outside chance that PCB may be mentioned at 12/6/72 hearing. Will attempt to find out at prehearing conference. Specific strategy to be developed after prehearing conference. Consider giving modified "in-hand" document mentioned in (I) above. ' ' ' '' B. Water Quality Bill - Chance that PCB's may be considered a toxic material with regard to water quality. Timing could follow this sequence following enactment on 10/18/72. 1) EPA to publish list of pollutants .that are toxic. 3 months 2) EPA to publish proposed effluent limits' tlons ' 6 mos after 1 3) EPA to promulgate standards (include 30 day hearing) 6 mos after 2 4) Standards to become effective 12 mos after 3 C. I recommend that we make contact with the Federal EPA in Washington accompanied by Region V EPA after PCB's are declared toxic and before standards are promulgated^ We should review our data as related to the "Polychlorinated Biphenyls and the Environment -- Interdepartmental Task Force on PCB's" report of May 1972. ' We should show two year trend data. . MONS 029532 POLYCHLORINATED BIPHENYLS _ WOK STRATEGY MINUTES OF MEETING - 10/20/72 10^26^72 WOK V. WOK - EPA Contact (Continued) We should push for limitations 1) Based on receiving water (Mississippi River) 2) Based on 246 and Incinerator area 3) Based on "knowing losses" of 1-2 #/day average 4) Based on acknowledgement and consideration of 5 #/day average background 5) State limits to be same as federal limits with same timing. Must keep state informed of conversation at Federal level. VI, ADDITIONS .> A. We should implement the existing WOK control - ;> <. program to get "knowing losses" down to essentially zero. B. Resolve any discrepancies in methodology between WOK and Government PCB laboratory analyses. C. If PCB is on toxic list we develop a fish-water coordination study. . , D. Review possible Aroclor customers in Illinois to be sure our actions within the state are evaluated in terns of potential customer problems. / vv - - f j r -*** v Edward E. Stewart Technical Services Department /tm- MONS 029533