Document YjO4odBOB71Kgy03aRzZaKgnD

ENVIRONMENTAL PROTECTION AGENCY BEFORE THE ADMINISTRATION In re: Proposed Toxic Pollutant Effluent Standards for Aldrin/Dieldrin, et al. ) ) j ) ) ) FWPCA (307) Docket No.1 COMMENTS OF WESTINGHOUSE ELECTRIC CORPORATION GENP 005507 Presented by Dr. James H. Wright Di rector Environmental Systems Department March 15, 19 74 774158 County of Allegheny State of Pennsylvania ) AFFIDAVIT My name is James H. Wright. I am Director of the Environmental Systems Department of the Westinghouse Electric Corporation, and am authorized to execute this affidavit on behalf of the Corporation. I have reviewed the foregoing Cooents of Westinghouse Electric Corporation filed at FWPCA (307), Docket No. 1. The Comments were prepared under my super vision and direction. The material contained in the foregoing Comments is true and correct to the best of my information, knowledge and belief. Subscribed and sworn to before me this / 5 7 /j day of March, 1974. Notary Public MQNROIViLlf. UMMCII VY cnvMij^.u tJItP'ilnt::. fti"I'HYYii 15. t9/ Ki.ames H. Wright, Director Environmental Systems Denarem: rPkf\ - i M ' d O 774159 < C I.- INTRODUCTION These comments are filed on behalf of Westinghouse Electric Corporatic in connection with the hearings being conducted by the Environmental Protection Agency on Proposed Toxic Pollutant Effluent Standards for Aldrin/Dieldrin, et a (FWPCA (307), Docket No. 1). The comments have been prepared under the directi of Dr. James H. Wright, Director of the Environmental Systems Department of Westinghouse and are limited to consideration of standards for polychlorinated biphenyls (PCB's). A copy of Dr. Wright's qualifications are attached to these comments. The Westinghouse Transformer Divisions and the Westinahouse Distribu Apparatus Division are users of a substantial quantity of polychlorinated biphenyls in the production, for sale to their customers, of capacitors and transformers. The (W) R & D Center has done considerable precision work in the analyses of PCB's. The Environmental Systems Department is charged with the responsibility of assisting industry and government requlating agencies in quantifying environmental problems and assisting in devising solutions to thes problems, and in this connection it has reviewed and analysed the environment: aspects of the proposed regulations for PCB's. A review of the scientific information indicates the proDOsed regul are unreasonable, unworkable and impractical. These comments detail the rea.s for this conclusion. As set forth below, we believe that an environmentally acceptable regulation of PCB's can and should be adopted which will not hr c the costs associated with the proposed regulation. These comments are divided into six sections as follows: I. Introduction II. III. Westinghouse Position on Proposed Standards History of PCB Usage IV. Requirements of the NEPA of 1 % 0 and the FWPCA Ammendments of -1- 774160 UiNI- w V. Consequences of Proposed Standards VI. Summary and Recommendations II. -W-E-S-T-I-N-G-H-O-U-S-E---P-O-S-I-T-I-O-N--ON;--P-R-O-P-O-S-E-D--S-T-A-N-D-A-R-D-S A. The numerical derivations of the discharge limits are highly t(. questionable. 1. The concept of a single standard for PCB's does not seem valid. The PCB isomers used commercially, categorized according to the degree of chlorination, differ greatly in viscosity, water solubility, biodegradability, persistence and toxicity. Most of the environmental and toxicological data used in derivation of the proposed effluent standards refer to the higher chlorinated, more persistent PCB isomers while many and perhaps most of the effluents to be regulated contain primarily the lower chlorinated, less persist' isomers. The environmental impact of a PCB containing discharge depends upon factors such as the types of the PCB in the effluent; the sedimentation rate of the receiving water; the types of biological food chains present; and the existing loading of other toxic materials in the receiving water. The propose standards ignore these factors and consider only stream flow and amount of PCB material discharged. 2. The selection of a "factor" to account for the bioloqcal recor tration of the discharged material must be, by necessity, an educated guess, because the limited data available give a broad range of numbers due to the ::: of different test animals and different experimental conditions. Although the 30,000 factor selected for reconcentration of PCB's by fish ir, tb* :r.-rir; environment falls within the- range of available data, the 200,000 f.-uTor for freshwater fish appears to be indefensible v/ith the available dita. Per example, the data presented in Table 7, pg. 100 of the Interdepartmental T.r / Force on PCB's report dated May 1972 shows a rcconcentration factor range of 12,000 to 76,000. 774161 II 3. Use of the 0.5 ppm level as the limit in fish is unduly c ative because this limit proposed by FDA applied to feed stock levels only. Navigable waters are seldom used as controlled feed stock sources for any husbandry activity. Such action would normally be prohibited by state laws protecting aquatic species. The ,PCB standard should be concerned with the 5.0 ppm level allowed for human consumption except in such cases and water syst which are used as a source of feedstock. Other federal agencies routinely incorporate a consideration of the actual food chain consideration on a case-by-case basis in establishing and enforcing regulation's. * B. A review of techniques for removal of materials such as PCB's from the water has revealed that no commercial operation is now in effect. Furthf ( more, there is no proven technology on which such a technique might be based Two techniques for removal of PCB's from water have been suggested which after considerable research effort over an extended period of time may * > < <( be shown to be effective. The first of these is carbon adsorption. While ! we have no data nor have performed any experiments along this line, a practica system might be developed sometime in the future. The other technique which could find some usage here would be rever osmosis. While no experimentation has been performed to date that we are awa of, the reverse osmosis contacts have advised us that there is a possibility of using this technique. However, again capital costs are.expected to be extremely high and operating costs probably would exceed that of the activate carbon system. In addition, in using the R.O. system and the adsorption sy*..'v , disposal of the concentrate would be a problem. The EPA explicitly states that "the attached standards ,ir> not :m s upon___ the availability of treatment technology1', (see page of F.K., -3- II. < No. 247 dated December 27, 1973}from which we derived that the EPA also acknowledges that no suitable treatment method exists. C. The proposed standards are unworkable from an analytical point of view because the known methods for monitoring effluents are not sensitive enough to determine PCB's at the required compliance levels. To show complianc with the minimum allowable daily discharges at the Westinghouse facilities would require detection of PCB's at effluent concentrations less than 0.1 microgram per liter, while standard methods, under the best conditions, allow estimation of PCB's only at levels greater than 1.0 micrograms per liter. Ever at these higher levels, the data obtained are at best semi-quantitative and "subject to uncertainties on the order of plus/minus 100 percent. D. In the definition of PCB's as 210 possible different PCB compounds, Section 129.09a does not recognize the differences in the individual PCB's which have been found by the government research surnnaries. Because the environmental contamination and toxic effects attributed to PCB's appear to be related to the homologs containing more than 4 chlorine atoms per molecule, and because available evidence indicates that the PCB homologs with 4 chlorinn atoms or less per molecule are biodegradable, the lesser chlorinated PCB's should be considered separately under less restrictive standards than the greater chlorinated PCB's. A definition providing for these differences soul, substantially reduce the adverse economic and social impacts of the proe-..'' standards without lessening the effective protection of the envircnm*T.t. 774163 -4 t III. HISTORY OF PCB USAGE Polychlorinated biphenyls consisting of many different chemical com pounds have been manufactured by Monsanto Company since 1929 and sold under the trade name Aroclor. Since that time the various isomers have been distributed throughout industry for all types of applications including plasticizers for plastics, paints and paper coatings as well as for heat transfer liquids and liquid dielectrics used in capacitors and transformers. The Aroclor PCS's were compounded by the consumers into various compositions and, in the electrical industry, were resold as liquid dielectrics under various trade names. The Westinghouse trade name is Inerteen. After a number of years, an industry name Askarel came into use as the generic term for polychlorinated biphenyls used in capacitors and transformers'; The growth in the use of Aroclors-continued and reached a peak in; 197i of approximately 80 x 10 lbs. It was determined in the few years prior to 19 that PCB's had a deleterious effect on the environment so that effective Augus 30, 1970 Monsanto voluntarily discontinued the sale of Aroclors for all modifi and plasticizer applications. (Exhibit I). Later, effective December 15, 197 Monsanto discontinued the sale of PCB's for heat transfer applications, there after, offering the sale of PCB Aroclors only for use by the electrical indus (Exhibit II). In 1970, about 50% of the usage of Aroclors was by the electri industry -- 40 x 10^ lbs. This usage divided approximately two-thirds in capacitors -- 26.67 x 10^ lbs. -- and one-third in transformers -- 13.33 x 1C lbs. At the same time Monsanto discontinued the sale of Aroclors for non electrical applications, the electrical industry was cautioned by Mcir.irr'; the PCB environmental problem. Westinghouse took strong measures to fwrrh*'' limit the amount of PCB's entering the environment as the result of menu fact ing operations (Exhibit III). Drains in'manufacturing ar^as, w h o m P C , wor used were sealed. All waste matter was collected in specially marked coritai -5- 774164 III. in the factory. This material was subsequently sent to incinerating plants we understood were designed to consume th PCB's at temperatures that would destroy them. When accidental spills occurred in a manufacturing location, the material was absorbed with industrial absorbents and this material was sent to incineration plants. All possible precautions were taken to minimize the flow of PCB's from Westinghouse plants into nearby streams or sewage systems. Despite all of the precautions, there is an irreducible effluent limit below which manufacturing operations cannot be continued. Westinghouse also conducted extensive evaluation programs leading to the use of Inerteens (PCB's) having relatively lew persistence and high bio degradability in the environment. For many years, Westinghouse used Aroclor 1260 diluted with tri chlorobenzene and thereafter used Aroclor 1254 diluted with trichlorobenzene. After thorough testing, including field tests, it was determined that Aroclor 1242 would be suitable as an Inerteen, and in February 1968, the use of this material was initiated in all Westinghouse transformers. According to Monsanto, Aroclor 1242 contains about 91% of the lower isomers (containing four chlorines or less) that more readily biodegrade in the environ ment. This material has been used by Westinghouse since .that time with the understanding that over 90% of any small amounts that did enter the environment would have relatively la-/ persistence. At a later date Monsanto refined Aroclor 1242 to remove more of the higher chlorine containing isomers to produce a material designated as Aroclor 1016. By the first quarter of 1072, this material was introduced by v-csr i into the manufacture of all capacitors which up to that time had alway: t :-n filled with Aroclor 1242. The new material, Aroclor 1016, according to Mor.*-an* contains 99% of the more biodegradable isomers (four chi orine", or loss) so ::h.:* -6- 774165 ni. less than 1% of this material escaping into the environment would be highly resistant to biodegradation. Dating from the time of first manufacture of PCB's, it is estimated that the non-electrical uses accounted for 95 to 99* of the entrance of these materials into the environment. Since the non-electrical usage of PCB has beer discontinued, there are perhaps only about 50 locations in the United States where PCB's are still used in the manufacture of electrical apparatus. IV. REQUIREMENTS OF THE NEPA OP 1969 AND THE FWPCA AMENDMENTS OF 1972 A. Regui remsnts We urge you to establish guidance in your regulations for toxic substances on the basis of the principles of the National Environmental Policy Act of 1969. Your proposed standards should incorporate the added dimensions of economic and social as well as environmental impact. Section 101(a) of NEPA commits the federal government to "... to use all practicable means and measures .... in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which ma; and nature can exist in productive harmony and fulfill the social, economic c other requirements of present and future generations of Americans." Section 102 authorizes and directs to the fullest extent possible th the policies, regulations and public laws of the United States shall be inter preted and administered in accordance with the policies set forch in this Ac: Specifically, it calls for an impact statement relative to oacr. .led sion, regulation, or recommendation for legislation having <i signifies; d: on the environment. This impact statement must contain the followin'?: (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot h*.* ,:voi A. ! (iii) alternatives to the proposed action, 774166 (iv) the relationship between local short-term uses of man's -7- o rC C A O J M 3 D IV. environment and the maintenance and enhancement of long term productivity, and (v) any irreversible and irretrievable commitments of resource which would be involved in the proposed action should it be implemented. The interpretation of this law in the courts has added the requirement that a benefit-cost analysis of proposed actions be evaluated. But the basic principle of the law is to guide these important decisic processes so that both man and nature can live in productive harmony. The specific provisions require that the short and long-term effects of proposed and alternate actions be analyzed so that a balancing of benefits and costs ca be made. Thus, this innovative statute for protecting social values recognize the essential aspects of trade-offs. EPA, in promulgating effluent standards pursuant to the Federal V/atef Pollution Control Act Amendment of 1972 may not be required by NEPA to file ar environmental impact statement. However, can the EPA afford to be less thorc, in its considerations when establishing standards, especially when the law P: 92-500, administered by the EPA further requires consideration of the relatic of economic and social costs in establishing and enforcing effluent limitatic including economic or social dislocations in the affected community, to the s and economic benefits to be obtained (including attainment of the objectives the Act). B . Application to Proposed Toxic Pollutant Standards 774167 Have the principles set forth above been met in the Propor,-.; Pollutant Standards of December 27, 1973? The answer compelled by "ho cc of the proposed standard in the Federal Register is NO 1 On page 35339 of the Federal Register, it is explicit!'/ stated t.hu: "the attached standards are not based upon economic considerations or upon i ability of treatment technology. However, the impact'of the standards upon 8- - V. CONSEQUENCES OF PROPOSED' REGULATIONS A. Economic Impact of Proposed Regulations Introduction A study of the economic impact of the proposed environmental water effluent standard is a study of the many alternatives that possibly meet the standard directly or indirectly. For each alternative, the economic impact has two parts: the impact on the manufacturer using PCB's in his product who is directly affected by the effluent standard and the impact on the consumer. Most assuredly, the laws of our economic environment imply that whatever the ir pact on the manufacturer the impact on the consumer will be at least equal, if * not greater. 1. Use & Significance of PCB's in Transformer Designs a. Existing Transformer Designs Although the basic materials of core and coil construction of all transformers are essentially the same, the environment within the transformer tank or enclosure can be different. Principally three environments are used: 1) Mineral Oil 2) PCB's 3) Dry (i.e. no liquid) b. Why PCB's in Transformers? Where failures resulting in fires and explosions may not repress! serious threat to life, mineral oil transformers are used. These designs rep! sent most of the power transformer applications. However, fire underwriter*; generally will not accept the use of flammable liquids for indoor transformers-and electrical codes will not permit flammable liquid filled ( transformers in congested areas or buildings. As a result, non-fl^mm-ibV ltAo PCB filled transformers are used whenever fire protection is importrifi-1: a::d laws demand. Most are installed in and on buildings or at close proximity - 10 - 774168 l c V. to buildings. Whenever fire and explosion are concerns, PCB filled trans formers meet the requirements without additional containment. Based on availability of non-flammable transformers, considerable construction has already begun or has been designed. Delaying these projects to incorporate a substitute for the PCB transformers would result in significant financial hardship in a market of around 1 billion dollars. 2. Alternatives a. Existing Plant, Existing Product, Refurbish Manufacturing Process Economically this is the most attractive alternative for manufacturer. utility and consumer. However, the controls on the manufacturing process and/or new manufacturing techniques are not available to meet the proposed standard. There exists a serious question whether it is technically feasible to develop such controls. This alternative could be economically attractive but proves to be an alternative more technically limited than economically linri b. Existing Plant, Substitutive Product There are two technically feasible alternatives to PCB filled trcns formers: (1) mineral oil filled and (2) dry. Each type has its own ad vantages and disadvantages. In itself, a mineral oil filled transformer is more economical tiiar a PCB filled transformer. Oil is substantially less expensive than PCB's. Overall, the PCB filled transformer is 25% - 35% more expensive than the oilfilled unit. As a result, in many applications, mineral oil transformers are preferred. However, a mineral oil transformer cannot directly subs ti **.! r'.*r a PCB transformer, where PCB transformers are presently being used. '!.;*!inability is the primary consideration. With mineral oil transformers, cc meet the laws, electrical codes, and fire underwriters requirements, significunt installation costs would be incurred by the user to make the mineral oil 11 774169 ft iCCfin ^TMTTrv V. transformers safe. These costs may result from the use of fireproof vaults in buildings, or, where land availability permits, outdoor substations. The effective cost of the transformer that must be paid by the utility customer would approach twice the cost of the PC8 transformer. The dry type transformer offers comparable nonflammability of a PC3 transformer. Lacking a flamnable oil, it could satisfy the legal requirements However, for the manufacturer it is a more expensive transformer to make, and for the utility, a more expensive transformer to buy. The dry type trans former is very likely to cost 30" to 60" more than a PCS transformer. They are somewhat larger and heavier. Also, dry type units are 5-10 db. noisier. To achieve a sound level equivalent to a PCB unit of the same rat ing, utilities must pay a premium in price of approximately 10% for a typical unit. Furthermore, dry type transformers do not have the overload capacity of a liquid (PCB'or oil) filled unit. Liquid filled units would easily sur vive overload conditions that would cause the failure of a dry type unit, c. Existing Plant, New Technology New technology would concentrate on the development of a new liquid to fill the transformer. Assuredly, adjustments (and strategic expense) woui occur to modify present transformer designs. The significant expense would occur in the discovery and development of the new liquid. Ideally, it would approach the desirable characteristics of PCB, particularly nonflammability while improving biodegradability. In all likelihood, development of an acc- ceptable substitute for PCB having good nonflammability charactertsr.\.y result in more expensive transformers, but it could easily be the tive technically. C - 12 - 774170 < < < I 1 V. Development efforts indicate a silicone-based fluid may be an al ternative to PCB. It has better non-flammability characteristics than mineral oil, but is not sufficient to meet all existing codes and decomposition pro ducts (gases) are highly combustible (explosive), d. New Plant, Existing Product If unable to meet proposed standards at the existing plant loca tion, an alternative is the construction of a new plant. This constitutes an unusual investment decision for any manufacturer. Very careful examina tion of market and potential profit is required before investment is permittee. Assuming that it is economically justified, the new plant also creates a social impact. Aside from the employees (and families) that undergo relo- - cation, a much larger quantity of fbrmer employees will be out of work. The effect will multiply throughout the community. It represents lost purchas ing power to the community and a social burden in supporting the unemployed. f\7CCf\(\ JTKTOrr^ 3. Significance & Use of Power Capacitors with PCB Capacitors are used in electric utility power systems to reduce the current carried by transmission and distribution circuits, thereby reducing the electrical losses, and to supply KVAC necessary to maintain system voltage. Transmission losses are significant to a utility. Even with the large quantity of capacitive compensation presently installed, transmission losios are approximately 10 of the energy transport. The lost energy could con ceivably double if capacitors were not available for transmission. illustrative example of the present transmission losses, the entire oi, of presently installed generation at Grand Coulee Dam is required to sens'y the losses of the Bonneville System. Unlike transformers where only a fraction of the units use alc-es* all capacitors use PCB's. Since its introduction into capacitors, more than - 13 - 774171 V. 30 years ago, it has resulted in significant improvements to capacitor re liability, reduction in size to make capacitors compatible with installation requirements, and enabled the manufacturing to lower the S/KVAC price of capacitors. The advantages of PCB's in capacitors clearly extends beyond its inflammability; it represents a significant economic and technical im provement over other designs. 4. Alternatives a. Existing Plant, Existing Product, Refurbish Manufacturing Process The same comments apply here as were stated under "Transformers", Section V,2,(a). b. Existing Plant, Substitutive Product It is technically feasible to go back to old, less efficient technolc mineral oil capacitors. However, designs of this type will be considerably more expensive. For technical reasons, alone, the expected cost to manu facture would be 3.5 to 4 times a PCB capacitor. In large part, this is due to the difference in dielectric constant of mineral oil (2.25) and PCE (5.35). The mineral oil capacitor precludes use of film/paper designs, forcing the manufacturer to physically large units for a given rating to maintain equiva lent reliability. The net result is an approximate doubling of capacitor size or, in the present capacity limited situation, a 50% reduction in quanti; of capacitance (KVAC) available to utilities. Investment by capacitor manu- j facturers to increase supply capabilities would not have an immediate signi ! ficant effect on the supply of capacitors. In addition is the ra.ct c < takes at least 1 to 2 years to build a new plant. The supply uf t capacitor grade paper is expected to continue at its present rate. To mo-jt * the demand of capacitor manufacturers (and utilities),' tin* p.ipor supply Id - 14 - 774172 V. have to double. A similar situation exists for mineral oil. The net result would be an additional price increase. With the yearly market for power capacitors presently estimated at $35 x 10^ and an industrial capacitor market about double that figure, the additional cost to utilities would be over $100 million dollars per year, if the same output could be maintained. Over the short term at least, the total cost to utilities would be even more. With only 50% of the capacitors available, 50% of the planned' transmission compensation could not occur. Ad ditional fuel would be spent to provide for the extra transmission losses. 0 Mineral oil capacitors are flammable.* Utilities would have to as sume protective measures such as locations in "safe areas" away from con gested areas or buildings, or locations in protective fireproof vaults. Fire insurance would be more expensive. As a result, the installation cost of capacitors would increase, increasing the cost to the customer even more, c. Existing Plant, New Technology New technology for capacitors concentrates on development of a new fluid. Aside from the common problem of flammability for alternatives sug gested in technical literature, possible replacement liquids (representing untried new technology) generally lack either a sufficiently high dielectric constant to keep capacitor size down or a sufficiently high dielectric strengt to maintain reliability of a PCB capacitor. In any case the state or thu art indicates that the solution to the problem of an insulating fluid would fall between the limits of flammability, biodegradability. and cost dp": by PCB and mineral oil. Unless it approaches PCB in electrical char-.cage ist ics, the economic penalty would be high. GENP 005522 - 15 - j 774173 V. d. Substitutes for Capacitors 2 Without capacitors, I R losses on transmission and distribution systems rise. Fuel must be expended to supply the losses. As an illustrative example, assume that presently installed transmission and distribution (and associated capacitors) remain in service. Furthermore, assume that engineer ing plans for future transmission and distribution additions do not change, but, after actual construction, capacitive compensation is not included. Conservatively, this would result in additional losses equivalent to at least 5% of the load. By 1983, the electric generation equivalent of 1/2 million barrels of oil/day would be'required to supply system losses capacitors would otherwise compensate. In addition, the available power from transmis sion and distribution systems would be reduced, requiring more transmission and distribution lines. Extra generation capacity would of necessity be added to cover losses. Devices to regulate voltage would be added, too. The net effect would be considerable capital expense -- many multiples of the capital investment for power capacitors. This would be in addition to the direct exper of fuel and very significant maintenance costs associated with sophisticated equipment required to replace capacitors. e. Hew Plant, Existing Product The same comments apply that are given in Section V,2,d. rzeenn B. Environmental Consequences of Proposed Regulations 774174 The environmental impacts of PCB's would remain essentially un since as described previously in discussing the history of PCS usage. z are no longer available for uncontained uses. At the levels found by the Interdepartmental Task Force; (1972) 1) not to appear to present an imminent hazard (to humans) 2) be viewed as potential problems at present environmental levels - 16 - V. C. Social Consequences of Proposed Regulations The social costs impairing the national electrical distribution system would impact essential manufacturing, farming, food processing, lighting, heat ing and. shelter of all Americans are truly incalculable. In addition, life and death related systems such as medical care, safety and communications could also be affected by the lack of adequate power. As indicated elsewhere due to the high PCB backgrounds relative to cur rant controlled discharges, the standards might be met most easily by moving the plants to uncontaminated areas. * However, this would not accomplish a reduction in the PCB background and could result in a movemrnt of 2000-5000 workers. This in turn would affect totals of 8000-20,000 workers and their families. Since fgr every 100 jobs directly affected by an industry about 70 secondary jobs are affected, the total of workers and people affected would be projected as: Workers - 3400 - 8500 People - 13,600 - 34,000 Alternatively, the manufacturers of capacitors and transformers could moved out of the United States. This would be possible based on off-shore manu facturers of PCB's in Europe. The capacitors and transformers could then be lin ported with an unfavorable impact on balance of payments to the extent of $20,0 annually per employee or 68 to 170 million dollars annually and the loss of the number of jobs shown above. All of the social impacts of this move would occur without rT.v.r.ur -i:i changing the PCB's in the environment, or in turn, reducinn the environment.-:! ( impacts. L( - 17 - 774175 < 4 VI. SUMMARY AND RECOMMENDATIONS We fully recognize EPA's legislative requirement to propose effluent standards for toxic substances. While the toxicity of PCB's to humans has not been fully substantiated, we would agree with the judgment that PCB's should be treated as a toxic substance. We have opposed the effluent limit proposed on December 27, 1973 by EPj on the following basis: (1) There is no presently available technology or process for removing PCB's from plant effluents; therefore, the proposed limits violate the statement and intent of the Federal Water Vollution Control Act (1972). (2) The proposed effluent concentration limits are below detectable limits for routine analytical procedures.and, therefore, cannot be properly dealt with. (3) The technical basis for the proposed limitation incorporated two factors which are not technically justified: a) The 200,000 to 1 reconcentration factor for fresh water is well outside of the vast majority of results in the technical literature and is, therefore, unduly conservative. b) The use of 0.5 mg/kg as the maximum allowable tissue level for the derivation of the tolerable chronic limits appears to be more a case of back-fitting to a previously established limit of the FDA proposed tolerance for PCS residu-.:-: :n scm- plete animal feeds rather than an evaluation of exist.In-; /''T /'/' AA 1 k l r i 1~\ toxicity data. Better justification exists ror se !:::ire instead of the FDA proposed tolerance limit of 5.0 mu/kg fu PCB residues in fisn for human consumption. Ajgeneral des cription of many of the factors whi<;h have already been - IB - 774176 considered is given in the April 1972 issue of Environmental Health Perspectives. Differences in concentrations between Aroclor types in the same media present a wide variation as ' shown in Table 1 pg. 160 of this document. (4) The aribitrary limitation of dilution effect to 10,000 cfs is un reasonable -- placing undue hardship on operations far in excess of any environmental benefits. (5) The broad classification of all PCB's under a single effluent limit is unreasonable and does not reflect credit to operations which have moved to lower chlorine content, biodegradable compounds. (6) The proposed effluent standards would require a total retention of PCB's from the entire industry of 99.9999% of all PCB's pro duced. Operations with such constraints are clearly impracticable. A cursory analysis of the environmental inventory of PCB's result ing from the last 30 years of operations using a 10-year environ mental half life of PCB's clearly indicates that environmental contamination from prior operations throughout the nation will far exceed the contamination from present operations until far into the next century. For the next 10 years, for example, prior contamination from all uses of PCB's will exceed that from current operations by a factor of more than 100 if current opera tion is held to a 1% leak rate. In the absence of an analysis by EPA detailing the social, and environmental effects of the proposed and alternate err. t strategies for PCB's and without the accompanying cost hone fit statement supporting the proposed effluent limit, EPA's pripn-.il is unjustified and should not be promulgated. h < < | 19 - 774177 VI. Recommendations: Consistent with paragraphs (1) and (2) of Section 302 of the Federal Water Pollution Control Act Amendments of 1972, we propose an interim effluent limit requiring producers and users to limit their releases to 1% of the quantity pro cessed and to examine, on a- case-by-case basis, the resultant environmental effe which would be limited for any situation to the 5.0 ppm content for human consurn tion and further restricted to 0.5 ppm in those cases where the top of the aquat food chain species were used as the principal feed stock in a husbandry program. Such a standard could probably-be implemented by improved processing and handling techniques without requiring special treatment facilities for which no process is presently available. It would also assure that the total environment burden of PCB's would be continually and rapidly reduced by holding ongoing oper tional effluents to a small.fraction of prior contamination. In the longer term, I would urge EPA to undertake such studies, investiga tions and development as necessary to provide a substantial technological basis for effluent limits of the various classes of PCB compounds and methods for trea ment and removal, all as provided for under P.L. 92-500. After development of adequate technical information, alternate control strategies could be considered along with the economic, environmental and social impacts associated with these various control strategies with final decision made on a cost benefit basis. /7rrnn jrkrrrrN - 20 - 774178 QUALIFICATIONS OF JAMES H. WRIGHT I am James H. Wright. I am Director of the Environmental Systems Department of the Westinghouse Electric Corporation. I hold a bachelor's' degree, a masters' degree, and a doctor of philosophy degree in chemical engineering. I have been working in the fields of pollution abatement and energy use for more than 20 years and have published more than 70 papers in the technical literature, and hold numerous patents for pollution abatement processes. My scope of work ha included design, research and development, construction, and operation of energy use processes including the abatement of pollution and environmental effects. I am a member of several professional societies including the America Institute of Chemical Engineers, the American Society of Engineering Education, the American Nuclear Society, and I am a registered engineer in the State of Pennsylvania. I am a consultant to various government agencies -- including President Nixon's National Water Commission. I am serving on the Commictee cn Power Plant Siting for the National Academy of Engineers. I am a dedicated conservationist, an ardent fisherman, an amateur mountaineer, and maintain active membership i.i the Sierra Club, Trout Unlimited and other environmental organizations. The Environmental Systems Department is charged with the responsibili of assisting industry and government regulatory agencies in quantifying environ mental problems and assisting in devising solutions to these problems. My staff consists of over 70 full-time professionals in the areas of marine biology, aquatic ecology, meteorology, radioecology, terrestrial ecology, landsacpe architecture, oceanography, public health and systems engineering. Our staff is supplemented by more than sixty part-time consultants. Our Department has conducted environmental studies for industry or government agencies in over half of the fifty states in the United States, the Commonwealth of Puerto Rico. Italy, France, Romania and Japan and are internationally recognized experts in the environmental impact of power systems operations. ..We conduct the Westinghous* International School for Environmental Management each year. 774179 GENP 005528