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WILLIAMS; Your names, please.
SIMONS; ! Stuart M. Riche1 and Dr. Edward L. Simons
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WILLIAMS: As I understand it. Dr. Simons, you are here today not to talk power
but to discuss PCBs.
SIMONS: That is correct.
WILLIAMS: Let me have a little about your background. Regarding these PCBs,
what position do you hold?
SIMONS: I'm the manager of the Environmental Protection Operation.
WILLIAMS: What degree do you have?
SIMONS: Doctor in chemistry.
WILLIAMS: As manager of the Environmental Protection Operation I wonder what you
think about the allegation that PCB discharges from the m i x GE may cause irreparabl
damages to the Hudson River.
SIMONS: The extent of damage to the Hudson is
from the analyses that
have been made by EPA and by DEC of the sediments of the water and of the fish.
I am not in a position to judge as to whether these are irreparable or reversible. -)T!0 'f'l
I can only point out that the discharges that are now emminotin g from our plant,
the losses of PCBs have been drastically reduced by us in the last few years. At
the present time, they are down to well under 5 pounds per day^and we had agreed
in the discussions we have had here in the past few weeks that the Department of
Environmental Conservation that we would get these discharges down to about a pound
by mid *76. I would like to put this in perspective, use several thousand gallon
of PCBs a day at these plants at Hudson Falls. The amount that is lost in small
bits thru various steps of the manufacturing operation, is^when we reach our level ,
of one pound per day^is less than 12 ounces, that is it is less than a soda pop
bottle of material - so
,
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WILLIAMS: Are PCBs in liquid form? SIMONS; Well they are liquid but the losses do not occur by a direct loss of
gallons pure PCBs. What happens is that in addition to the several thousand psands of PCBs that we use each dayt we also.use a million and half of water per day for various operations in the plant and small amounts of these PCBs get into the water that 1s discharged from the plant. So it is this 1 -and-a-half- million gallons of water that carries these small amounts of PCBs into the river. It is not a dumping, in the sense that we have a barrel which we throw out scrap PCBs. WILLIAMS: A lot of people don't realize that. SIMONS: From the way in which this word dumping has been used even in the Sports Illustrated magazine, it is obvious that people either don't understand it or then they are using it for its wrong connotation. WILLIAMS: Yesterday, in the statement Commissioner Reed made it was azgg suggested that there may be some way to either ennumerate or outrightly get rid of PCBs in the river. Do you know of any way to neutralizing whatever PCBs may be in the Hudson? SIMONS: I do not. I saw the account. I was told that the account in the New
vNYO York Times, that appeared in thejjTate city edition did have a statement that to the effect that he was going to convene a meeting of scientists to discuss this problem. I do know that when the Vermont & New-York State were having their squabble over the sludge beds 1n Lake Champlane that was produced from years of operation of International Paper Company, the State of New York was arguing against the State of Vermont^which wanted these sludge beds cleaned out and the argument that the New York State authorities were using was that attempting to clean up these sludge beds would create and disperse the solution to a greater extent.
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WILLIAMS: Was that PCB pollution then? Or was that another form of pollution? - SIMONS: Yes, with this particular pollutant, the-Tri-County Journal News in Glen Falls.
RICHEL: The problem that Ed is going to speak about now and that he has analogized
to the International Paper problem Is our concern that interferring with the beds
as they may be, the sediment as it now is, may cause greater problems than what
now exists. And that problem of stirring up the sediment was discussed in this
paper that Ed just mentioned, in an earlier article and it was discussed by
one of EPA's chief enforcement officials in N.Y.C. and that was Dr. Ernest Regna.
Perhaps Ed could bring you up to date. That fellow's name was Regna.
WILLIAMS: Was that the same as the Lake Champlain situation? SIMONS:
XXEHEK: No sir. I gave the Lake Champlain situation as an example of where
New York State claimed itself that this would happen but nov^with respect to
the present problem in the Hudson River. Dr. Regna, who heads up the Permits
Branch of EPA's Regional Office in New Yorkjwhich has juristriction over all
plants in New York State - he gave an interview to ChaiTBlakeman of the Tri-County
News which appeared on August 11 and he said that the chemical has entered cjov Jo-
sediment on the River bottom and^continued to create problems even if no additional
amounts were discharged. He said dredging the river would not be feasible
because it would stir up the sediment and possibly increase the diffusion of PCB
into the water.
WILLIAMS: Do you agree with that analysis?
SIMONS: I have no basis for disagreeing with that - this has been a problem which
was also faced when there was the discovery of mercury contamination in many
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streams and lakes some years back*-- /hat although it is a potential reservoir for !
materials, there was no known technology for removing it which would not run the
risk of making the contamination more widespread.
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a-iRMeh-M WILLIAMS: For-pa3t-year3*;-the-GE-haa-been-diaeKarg4ng-50-ga**ens-er-mere
For past years, the GE has been discharing as much as 50 pounds or per day more of PCBs in the river. Conceivable, that could still be in the bottom of the river somewhere and if some one went in with a dredging operation you could clear it all out. SIMONS: That's right. Now I would like to point out with respect to these numbers that have been quoted about the discharges in previous years. We have been manufacturing capacitors up in there for at least 20 years but prior to 1969 there was no^Jiody in science, industry, or govemment^who knew that PCBs
were persistent and ubitiquous in the environment tor representedVfiaz^ard and
it was only in the beginning of the 1970s that enough evidence had accumulated to suggest that there was a problem and when we began a program to reduce these discharges from the levels that are being quoted of these 50 pounds per day - and as I say, in our efforts in the last few years, now have brought that down to well below 5 pounds and we are confident that by the middle of next year, it will be down to 1 pound or less. WILLIAMS: Was it your position then, I guess 1t would be or the GEs, at least at this time in the conceivable future that there would be no way to see the elimination of PCBs discharges? SIMONS: We have taken the position, two-fold, one 1s we have changed to a different grade of PCBs which are more readily degraded in the environment than the grade that was used before 1971. WILLIAMS: How much more readily is it? SIMONS: Its hard to put a specific number on this but I would say tan we're talking about a product which now contains about 99% of this more biodegradable material whereas the earlier substance may have contained less than 90S of the more biodegrad material.
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WILLIAMS: When you say a substance what you are using up there 1s not a pure PCB? SIMONS; PCBs are not a pure material, they consist of a mixture of materials of varying degrees of reactivity. . WILLIAMS: What Is 1t used for? SIMONS: It 1s used as an Insulating fluid 1n capacitors and 1n our transformers that we make 1n Pittsfield and Rome, Georgia. The principle advantage that we get from it Is because it is completely nonflamable. If there should be any failure of the equipment with electrical overloads or electrical-heating, there is no danger of a failure being followed by a fire and that 1s something that can be said of no other fluid that has been used 1n capacitors or has been proposed for use as a substitute for PCBs. WILLIAMS: Now these fluids are heat transmitters? SIMONS: Heat transfer and. electrical Insultatlng fluid. They serve both functions both electrical insulation and the removal of heat. WILLIAMS: Do they surround the capacitors? SIMONS: They surround the - they are inside the field metal case. A capacitor looks very much like a flashlight battery. _________ I think for your purBses it might be easier to say they are inside and this 1s a metal aluminum can and inside that are electrical equipment and everything else 1s filled with PCBs. DICKER: You mentioned that you are using a better grade of degradable PCBs, is there even still more a better grade of degradable available? SIMONS: No, the best that Is made by Monsanto which is the sole U.S. producer. DICKER:. Is It an expensive chemical? SIMONS: Yes, I don't know what the exact cost is now but 1t 1s probably, I've heard numbers. Its in the dollars per gallon, but I don't know the exact figure.
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RICHEL: Mr. Dicker I think at this point that It might be well to - it 1s
sufficiently expensive so there would be every economic Incentive for the
Company to use alternative substances. It 1s primarily, if not totally true,
that the substance 1s being used because of our concern that there be a non-
flanvnable substance used and our concerns In part, .1 might say, is that DEC'S
actions may compel the use of alternative substances 1n the long run, whose
environmental inadequacy 1s unknown and whose technical adequacy, in terms of
nonflalienability, will be either Inadequate or less satisfactory than PCBs.
DICKER: Do you think GE i9-the-en}y-ene-that knows how to do that 1f they are
forced into 1t?
RICHEL: When you say someone 1s forced 1t Implies that there aren't many options
and very definite. DICKER: Suppose they get a court order against -
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RICHEL: Well there 1s a proposed order that 1s now out and I think 1t 1s difficult
to say what we would do if that order 1s finally promulgated as 1t is now. I can
tell you very definitely that we will be participating 1n the Hearing and what
the results will be 1s unclear.
DICKER: Mr. Richel, are you with the Public Relations?
RICHEL: No, I'm an attorney who works with the Environmental Protection Operation
- my title 1s Environmental Protection - Attorney.
DICKER: I just wondered if GE had given any thought to the possibility of closing
this plant,. 1f 1t had a choice of coming up with an alternative or ceasing Its PCBs?
kinds
of
RICHEL: Those management decisions are not made by us 7
SIMONS: I think that the point that should be kept 1n mind 1s the fact that these
very expensive reductions that we have already made were made before the Dept, of
Environmental Conservation became at least publlclly aware that the problem existe
We had a program underway that we have 1n the weeks that we have been meeting with
the Department come to an agreement on all the Intermediate steps that are set
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forth in the Order as far as the levels may reach but we don't know wh how to reach the zero discharge. I might say something else with respect to that
employment problem. The Company has obviously been very concerned about that.
It was made quite clear by representatives of Hr. Reed that there should be ordering of a shutdown of the plant was under active consideration and we were
also informed that a shutdown would have dlsasterous implications for the economy
of that area of the state. Ue learned from the Department of Conrnerce, I might
add, that
TURNED THE TAPE
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SIMONS; complete elimination of PCBs down to zero. This is not the kind of
equipment of industrial problems in which there is industrial equipment on the
shelf, you order it, and use it the way the manufacturer prescribes and you get
a prescribed result.
DICKER: What have you been doing so far to get it down to 50 pounds and then in a ye*
down to 1 pound? SIMONS: The biggest single steps have been to review the imminent details of each
of the steps in our manufacturing operation to find all the places from which
small amounts of PCBs can be lost to the environment and once the major reductions
by major changes in our manufacturing procedures and our long-range program would
involve further treatment programs after that but the biggest reductions that have
been obtained so far have been thru changes in the manufacturing 'and processes
operations. DICKER: Why do you take a million and half gallons of water 1n a day.? Is that
A c c c n n rTNJtro
used for cooling purposes? SIMONS: For cooling purposes, we have lots of ovens and
and so forth
and they just need cooling. DICKER: And I guess the potential is always there for a big PCB loss, From pipes
that rupture or --
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SIMONS: Yes. we have all of our storage areas are now being diked. The piping is put above grounds so the steps that are necessary to prevent the massive spills are currently 1n place or being updated.
Our problem is not really the containment of spills, we haven't had
any major spills of that nature. Our problem is the drainage of these major eachof
losses and a little bit from these various manufacturing stages.
DICKER: I think what you said to me that PCBs accumulated in a fish's body.
That's the implication of all of this.
SIMONS: Yes
DICKER: Something like the chlorinated hydrocarbons?
SIMONS: Something like DDT - yes. DICKER: Do you know 1f it have to be a gas accumulation or an adsorption of
the skin or ---
whose
SIMONS: There is a difference of opinion among the biological authors ef papers
I've written and there is no clear indications of whether one - either of both
mechanisms are in operation. DICKER: I wonder how individuals at your plants handle PCB affairs - somehow
carefully protected against them - with special
the
SIMONS: The employees have 1n the decade they have been used only health effects
that have been observed that were attributable to PCBs were occasionaly cases of
skin irritation or
acne and these cleared up when the affected employee
was transferred to other non PCB operations. DICKER: Has the Health Department moved recently to check any of your employees? SIMONS: I really don't know. I know they have checked the drinking water up there,
whether they have done any examinations of employees medical records, I just don1,
know.
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DICKER: Apparently they have conferred that the drinking water is safe?
SIMONS: Yes. I have that report this afternoon.
DICKER: ONE LAST THING - I wonder if
Is there anything I haven't asked you about that you wanted printed in
the story on it?
SIMONS: Just the statement that I made earlier that there is a continuing effort
since the environmental espersion of RGBs became known several years ago for the
Company to reduce these to the i u z t lowest feasible level. These steps were
undertaken before DEC got into the act, and they would have continued 1f DEC
had not banned this order.
DICKER: Have you been served with any papers?
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SIMONS: They were served on our plant at Hudson Falls this morning and I expect
to see a copy of that tomorrow.
DICKER: Mr. Richel, just let me ask you something. When was it suggested that DEC REEK might attempt to close your plant down ?
RICHEL: On several occasions.
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RICHEL: SIMONS: Ue had a visit by - let me put it this way - I want to make the language
clear so as not to misrepresent . the language
has been quite expressely this
- that the shut-down of our plants was one option under active consideration and
it was said to us by the General Counsel, Mr. Hallman on at least one or two occasioi
I can recall, I didn't record the dates but Ed 1f you'can fill me in--
SIMONS: 1 can give you the dates - the first meeting at which this was mentioned wa
Otilar w
a meeting held on August 14 at Hudson Falls and the ranking Department official
there 1s Dr. Theodore HulTer, Deputy Conmissioner for Planning & Research and he
indicated at that meeting that this was one of the options that the Department
had open to it. That no decision had been made but that was one of the options
under consideration. The following day, which was Friday, August 15, we met at *
the Department Offices and Dr. Huller was joined at that meeting by Mr. Robert Halim
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who 1s the Deputy Convnlssioner and General *Counsel and he too Indicated that this,
was a possible option open to the Department.
DICKER: You haven't heard anything about that since?
SIMONS: That has not been mentioned as a specific option since those times.
RICHEL: I would Infer that they are not considering that option now but are
instead considering measures which may have the same open impact.
DICKER: What do you base that on?
RICHEL: If indeed the order that results from the Hearing and subsequent
decision making is something in an order with which the Company can not comply
then some consideration will have to be made on our part to ppxx options at
our own - and one of those options would by definition be what do we do if we
can't comply?
DICKER: Do you know if there are states in this area or around the country
that are permitting discharges at a higer level than what 1s going into the
Hudson?
RICHEL: There are numerous states - The Federal government under the Water
Pollution Control Act has been issuing permits to many plants for many company's
involved in the manufacture of transformers and capacitors. There is no condition
within any of those permitsto my knowledge which presently requires a complete
elimination of the discharge of PCBs. The conditions being placed into these
other permitsat least in part recognize one - the continuing need for the uee
of PCBs and two the technical limitations on the control of discharge of PCBs.
What this proposed order does is to say eliminate it although we don't know how
you are going to do it.
DICKER: I would like to thank you both for your time and perhaps if I do have
any further questions, I can get back to you?
RICHEL & SIMONS: Sure
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