Document dQQBOo5jrL4RavKEpdmyXyMxq

MINUTES OP MEETINO ON PROPOSED PCB EFFLUENT STANDARDS February 28, 1974 Monsanto Company St. Louis, Mo. HONS 029683 Chairman; Mr. W. B. Papageorge Manager, Product Acceptability Monsanto Industrial Chemicals Co Objective; The purpose of the meeting was to share Information, experiences and Impressions to help each of the participating companies In taking appropriate actions which are mutually supportive and effective In persuading the Administration of EPA to modify the proposed PCB Effluent Standard. MOWS 029684 PARTICIPANTS PCS STANDARDS MEETINO February 28. 1974 CERTIFIED BALLAST MANUFACTURERS Mr. N. R. Clark Universal Manufacturing Co. Mr. Arnold S. Doty Df. E. M. Moore MT. Rudy Carlson P. R. Mallory & Co., Inc. Electrical Utilities Co. Electrical Utilities Co. GENERAL ELECTRIC COMPANY Mr. James S. Nelson Mr. Stuart Rlchel DT. Edward L. Simons JARD COMPANY, INC. Mr. Richard Rollins NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION (NEMA) MT. A. M. Salazar WEST1NOHOUSE CORPORATION Mr. H. Sheppard MT. N. H. Smith HONS 029685 MONSANTO COMPANY P. 0. Benignus H. S. Bergen D. B. Hosmer R. H. Muneb W. B. Papageorge W. W. Withers C. Paton W. R. Richard J. R. Savage E. S. Tucker P. L. Wright 2- Market Manager Business Director Utilities and Environmental Protection Director Senior Science Fellow Manager, Product Acceptability Attorney Product Manager Manager, Research and Development Manager, Manufacturing Research Group Leader Manager, Toxicology HONS 029686 AGENDA PCB EFFLUENT STANDARDS MEETING February 28, 1974 9:00 AM .1 Welcome - H. S. Bergen 9:10 AM 2. Introductory Remarks - W. B. Papageorge a. Brief Review of Proposed Standard b. Critical Action Dates c. Objectives of Meeting 9:15 AM 9:45 AM 10:15 AM 10:30 AM 11:30 AM 12:00 Noon 12:30 PM 1:15 PM 2:00 PM 2:45 PM 3:00 PM 300 PM 4:00 PM 3. Discussion Topics a. PCB Characteristics - Realistic Definition chemical, physical, biodegradation b. Sampling and Analytical Methodology Break c Toxicity Acute Chronic d. Bloaccumulatlon - Blomagnlflcatlon e. Dilution - Stream Size Lunch r. Proposed Effluent Standard g. Control at Manufacturing and Use Sites Current losses Background Break h. Economic Considerations .1 Action Plans Adjourn HONS 029687 MINUTES OP PCB EFFLUENT STANDARDS MEETIMP 1. Mr. Howard S. Bergen, Jr., Director, Specialty Products Business Qroup of Monsanto Industrial Chemicals Company, welcomed the participants.. 2. Intpoductlon - W. B. Papageorge Mr. Papageorge summarized the timetable past and future on toxic pollutants: July 6, 1973 Toxic Pollutants list published September 7, 1973 Pinal toxic pollutants list pub lished Including PCBs and 8 other chemical classes (e.g. cyanide, mercury, DDT, cadmium, etc.) December 27, 1973 Proposed Effluent Standards published January 18, 1974 Filing date for status as participant at proposed EPA Hear ing on Standards January 25, 1974 (l) Prehearing Conference with EPA (ll) NEMA, Monsanto, Q.E. and Westlnghouae recognized as participants. (Ill) A total of 38 objectors ex pressed an Interest. They represented industry or trade associations with the exception of the Michigan Water Research Commission and two powerful environmental groups (Environmental Defense Fund and National Resources Defense Council). (lv) Presiding officer made It clear that hearings will be strictly for cross-examination of participants' Testimonies In affidavit form only. HONS 029680 -2- Maroh 15, 1974 April 8, 1974 Written testimony by 38 objectors to be submitted In affidavit fon7 Hearings open for cross-examination and rebuttal evidence. CN'/Cd/Hg first three. PCBs are 7th (third from last). Mld-tMay, 1974 Hearings completed. (Evenlngs/weekends may be used.) JUna 25, 1974 Pinal standards published - effective In one year, ' It should be noted that others who are affected by these standards can still comment by March 25 tol Dr. C. Hugh Thompson, Chairman-Hazardous and Toxic Substances Regulation Task Force Office of Water Protection Agency, Environmental Protection Agency Washington D. C. 20460 Industry representatives still wishing to comment and who need more background Information can contact any of the Industry participants (see attached list) or Nr. W. B. Papageorge of Monsanto! (314-694-4051). Mr. Rlch|sl (O.E.): (l) Madia a plea for greater Industry participation. Comments can; still be made up to March 25 with sound excuse for tardiness. (11) EPA > at January 25 prehearing Conference were reluctant to expose themselves to cross-examination. Dr. Hugh Thompson to be available for cross-examination at Hearings. (ill) Many objectors had common Interest (e.g. environmentalists). EPA suggested a common counsel for this group. (lv) On each of first 3 pollutants, EPA would offer 2 witnesses. Mr. DotyifP.R. Mallory) asked about bearing of economic factors on standards. Mr. Rlchel (O.E.) stated: (l) Law 1 Is clear-economic factors are not relevant In establishing standards. (ll) EPA Is somewhat of a split personality on this. The HONS 029689 -3- Preslding Officer at the Prehearing Conference ruled that economics are relevant. NHDC (National Resourcea Defence Council) objected and waa over-ruled. (ill) Industry can and should therefore Introduce relevant economic data. EPA would be wise not to expressly refer to such data In the published standard otherwise NRDC could go to court and EPA over-ruled. Department of Commerce It was pointed out that Sidney R. Oalller, Deputy Assistant Secretary for Environmental Affairs at the Department of Commerce wrote Monsanto on January 15 asking their views on the proposed effluent standards. Copies of Dr. Oalller's letter and Monsanto's response were circulated at the meeting. Industry should Contact the Dept, of Commerce. Their legal counsel (Mr. Holland) has been active on the side of Industry in other environmental hearings. Mr. Salazar (NBMA) pointed out that the PCB Task Force had recommended a standard for PCBs of 0.01 ppb in the main body of water. (EPA was a member of that task force). ANSf C-119 proposes to use this Task Force recommendation and print this as a standard of 0.01 ppb In main body of water. Mr. Sheppard (Westlnghouse) queried If plant effluent standards could be set to meet 0.01 ppb. Dr. Simons (O.E.) said this Implied an acceptance of ANSI C-119 by Industry. There seemed to be some doubt on this. PCB Characteristics Dr. Tucker (Monsanto) presented hand-outs on: (a) Monsanto's proposed definition of PCBs (b) Comments on EPA's proposed analytical methodology (c) Monsanto's pre-publlcatlon paper on biodegradation of PCBs. (a) Definition of PCBb 1-4 chloroblphenyls do not have long residence time. PCBs up to tetrachloroblphenyl are not of concern on environmental persistence or blomagnlflcation. Dr. Tucker proposed the following definition: HONS 029690 -4- "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which Is chlorinated and which have been shown to persist and rapidly bloaccumulate In the aquatic environment. These chlorinated biphenyls are Identified as those components having gas chromatographic retention times greater than 54, relative to p, p-DDE = 100, under the standard con ditions recommended In the EPA PCB teBt method." Mr. Sheppard (Westlnghouse) said Monsanto's proposed definition was relevant to persistence but was It relevant for standards directed toward toxic materials? Are persistent materials non toxic? Mr. Wright (Monsanto) stated the proposed effluent standard had two partB: (l) acute limits directed to toxicity of materials and specifically limits PCB concentrations on that basis. (ll) dally load in effluent - based solely on blomagnlflcatlon (relevant to persistence). Dr. Simons (O.E.) pointed out that section 307-A of the proposed standard! refers to persistence as being a critical factor to be considered. Dr. Tucker (Monsanto) stated we were badly hurt if all PCBs are regarded! as persistent and If blomagnlflcatlon factors of 200,000 are used. Researchers other than Monsanto have found bacterial degradation of PCBs and that PCBs have been found to undergo metabolism in both avlarlan and mammalian animals. Mr, Nelson (O.E.) asked if proposed PCB definition would exclude Arocior 1016. Dr, TuckSr (Monsanto) Arocior 1016 would be excluded for the most part (9tJl9p Is lower than pentachloroblphenyl). Arocior 1242 would be Excluded to 6554 or better. Arocior 1254 however would not be excluded. Mr, Papageoree (Monsanto) pointed out that of the factors listed as beingTorltlcal In determining which pollutants made the EPA list of 9/7/73 only blomagnlflcatlon appeared relevant to PCBs. Dr. Simons (O.E.) agreed. HONS 029691 -5' Mr. Wright (Monsanto) stated that an acute toxicological level Is defined in the EPA Basis & Purpose document as 10 ppm (96 hour LC-50). He also believes that differences in toxicity among PqBa are minor until chlorinated as high as Aroclor 1260. Mr. Nelson (O.E.) stated that words should be used In a dlacourse o|n definition to properly screen us on acute toxicity. In reference to a comment that Aroclor 1254 would not be excluded|, by the proposed definition. Dr. Tucker (Monoanto) offered ithe opinion that transformer fluids were easier to recover th|an capacitors. (b) Analytical Methodology Dr, Tucker (Monsanto) stated the EPA's proposed method for PCB analysis' was being submitted to ASTM. He thought the method was well! written and capable of detection to ppt (parts per trillion!) but it was untried and the quantitative accuracy la in question. The method was not submitted for round-robin testing pefore EPA adopted it. Monsanto has found that by spiking distilled water with 500,000 ppt or 500 ppb of PCBs we get values for PCB that vary by i 555*. The EPA, however, claims a capability of detecting absolute values at 50 ppt. The EPA method Ignores Interfering substances. Mr. Clark (Universal Manufacturing) said that with a proposed upper limit for PCB discharge of O.0648 lb./day the sensitivity of the ahalytlcal method would vary "all over the lot" depending on the size of the water "reservoir" into which the PCBs dis charge . Mr. Sheppard (Westlnghouae) commented that If the analytical techniques on determining PCB levels are so difficult, how valid are the determination of toxic values for PCBs. Mr. Clark (Universal Manufacturing) asked if analytical techniques dlfferen';iate between different chlorine levels. Dr. Tucker (Monsanto) said It would depend on the PCB mixture1 Aroclor 1242 could probably be Identified quantitatively in a mixture with Aroclor 1260 but addition of Aroclor 1254 to the mixture would prevent Identification because Aroclor 1254 contains PCB homologs that overlap both Aroclor 1242 and 1260. Dr. Munch (Monsanto)said that the proposed EPA method does not use high I resolution and hence handicaps identification of Individual peaks. Dr. Slmods (O.E.) mentioned that after EPA set automotive emission standards (NIOX) the analytical methodology was found faulty and the standards were delayed. In this case, EPA is not setting the effluent standard on analytical methodology but MOMS 029692 -6- on factors Buch as toxicity and persistence. The methodology Is relevant In enforcement and monitoring. This then leads to the possible argument that the effluent standard Is correct and Justified on the basis of toxicology et al, but Is not enforceable due to lack of an accurate method for absolute value deter mination of PCB discharge. Mr. Rlchpl (O.E.) pointed out that EPA won't buy an answer to that argument which seeks to raise the effluent standard to a level thpt can be accurately measured. Mr. Savage (Monsanto) felt strongly, however, that this dilemma needed to be in the record. Others agreed. Dr, Tucklsr (Monsanto) said ASTM would hold a round-robin on the jSpa metnpd and that Monsanto would participate. He will send the name of the ASTM contact to the participants so that they can decide If they want to Join the round-robin test. Mr. Sheppard (Westlnghouse) said he was not prepared to accept that ther proposed epS method for determining quantities and types of PCB lp samples and animals was accurate enough so that toxic limits cpuld be defined on the basis of PCB levels of question able accuracy. Toxicity Mr, Hoarser (Monsanto) stated that the original EPA publication on Water!Quality Criteria came from a publication by McKee and Wolfe for the State of California. The McKee/Wolfe volume was well done and EPA did not change much of It. There 1b now a new 2-volume EPA edition extracted from the work of 10 committees of the National Academy of Sciences. The toxlflty of FCBs Is related to salmon egg studies and Monsanto;doubts the validity of this. Monsanto has made their feelings known to Dr. Thompson of EPA but he thought the criteria i were sound. Since then Russell Tram has been sued by NRDC and other groups on the grounds that the toxic pollutants list Is not long enough and the proposed standards are too len ient . Mr. Wright (Monsanto) went through the rationale used by EPA in arriving!at a PCB discharge maximum of 0.0648 lb./day. He also showed hdw the standard could be changed and yet be consistent with published data on PCBa. Details follow. (a) FDA set arbrltary proposed tolerances: 5 ppm In fish for human consumption 5 ppm In components for animal feed 0.5 ppm In complete animal feed MONS 029693 7 (b) Monsanto would not disagree with these tolerances. (c) FDA has presented - acute toxicity limits (point sources) - chronic toxicity limits (dally load) Acufre toxicity limits: 96 hour LC-50 studies for PCBs show: <"200 ppb In fresh water (blueglll) ~10 ppb In coastal or seawater (pink shrimp/oysters) Published data based on materials leaving an outlet and going into a body of water. Acute limits have no direct relation to chronic flmlts. Chronic toxicity limits: The EPA equation Is: Chronic limit X water flow rate X safety factor gm/day discharge In Marine organisms the chronic limit Is set as -016? pp* In fresh 1 water the chronic limit has been determined by using 0.5 ppm $s toxic limit for salmon eggs and a 200,000 blomagnlflcfttlon factor. This gives a chronic limit of ggg-,000 = 2*fig5 PPb The blomSgnlflcatlon level of 200,000 is baBed on unpublished data froi# Stalling ft Meyer (Fish Pesticide Lab, U. S. Dept, of Interior: Colombia, Mo.). Dr, Simona said that In response to repeated!requests by O.E. to the Columbia Lab the only reference they have been given Is a Stalling ft Meyer paper presented In Carolina In 1971 and which contains no mention of a 200,000 factor. Mr. Wright (Monsanto) stated he has seen only one literature reference to an accumulation factor of--200,000 and that was in the hSpato pancreas of a pink shrimp. If the PCB level was calculated on the basis of the total shrimp then the accumulation factor Was only 22,dot). Other references give accumulation factors of 1000-75,000 for whole tissues of various freah water organisms. Accordingly, Mr. Wright proposes that a blomagnlfloatlon factor of 30.000 ana not goO.ooo be used. He also pro!oses that we retain the chronic limit of 0.5 ppm with out aeoa* lng the salmon egg lsaueT MONS 029694 -8- Thls would lead to a discharge level for PCBs: i5_ ;X 10,000 X 30.000 (flow rate) 0.5 X (safety factor) 5.4 (conversion Into lb./ day) * 0.459 lb./day This compares to the proposed standard of 0,0648 lb./day. The safety factor comes from the EPA's Basis and Purpose document supporting the proposed effluent standards. It Is supposed to take account of non-point sources of PCBs and Is the same as 6 of the 9, toxic pollutants proposed for EPA standards. Monsanto's Medical Department feelB this safety factor Is arbitrary and confers no real toxicological benefit. If deleted, the revised Wright PCB discharge level would be 0.918 lb./day. One of the most critical parts of the discharge equation Is the water flow rate.' A significant number of dielectric PCB manufacturers have plants on rivers where the flow rate Is under 10p cfs or of the EPA cut-off flow of 10,000 cfs. Several plants discharge Into sewage plants which In turn have treated liquid flowing into rivers or streams with very low flow rates. For a river with 100 cfs flow the EPA maximum discharge would drop to 0.000648 lb./day or 0.1b2 lb. In a 250 work-day year. Even a revised standard of 0.91a lb./day at 10.000 cfs would only be 0.00918 lb./day at 100 cfs or ~2.3 lb. fer 250 Work-day year. Clearly this Is a Btaggerlng target to ave to meet. Mr. gotyi (Malloiy) pointed out that In the present language of the EPA Standards municipal sewage systems are not considered point soilrces. Mr. Rlchei (Q.E.) was of the opinion that where a plant dlacharged Into a sewage system without treatment and hence Into navigable waters the plant could have to comply with effluent standards on toxic pollutants. Mr. Papaaeorge(Monsanto) felt we should not be complacent and regard discharge to sewage plants b^lng the answer to problems. Mr. Hosmer (Monsanto) stated that 10,000 cfs represents the largest (low the EPA will consider1on the grounds that all Industry would move to the largest Hver. The opposite of that argument Is that It encourages small plants on every stream In the country. Mr. Sheppard (Westlnghouse) raised the Issue of sedimentation. Since ltl appears that all the experiments to establish toxic values wtre run without sediment effects being considered, the real-lift values were questioned. PCBs attach themselves to sediment * Furthermore the sediment moves down river and so PCB would be 1 dispersed from the point source. It was pointed out by Dr Richard (Monaanto) that Aroclor 1254 la soluble In water up to 50!ppb and that In time partitioning between sediment and MONS 029695 -9- water could take place. Mr. Wright (Monsanto) agreed that the discharge limits were extreme cases in the absence of sediment considerations and this was worth study and Incorporation into arguments against the proposed levels. Dr. Simons (O.E.) queried whether we were correct In concen trating pur attacks on the criterion of toxic effects of mammals eating filsh and Ignoring the possible argument that fish per se must be protected. Mr. Wright (Monsanto) said the proposed standard! says both. In salt water, standards are proposed that would protect the species that eat organisms containing PCB. In fresht water, if 0.5 ppm in salmon eggs correlates with *5 ppm In aalmoh then we are protecting salmon. He also said that the chronic [limits and blomagnlflcatlon limits he was proposing would protect the species themselves. We should, however, beware of arguing for higher levels In fish because we could draw EPA and PDA Into conflict. The PDA levels In food, fish etc., are temporary tolerances and any arguments against their validity could lead to a reduction in these tolerances. Mr. Savage (Monsanto) queried whether raising the level In organisms could cause possible danger to predators. Dr, Simons (CUE.) quoted from page 39 of the Basis & Purposes document which states that the body burdens of birds and mammals should npt Increase over present levels. Page 51 of the same document;cites a Nat. Acad. Scl. report which gives 2.0 ppm PCB as tolerable level In flesh of whole fish. 2.0 = 0.1 com PCB 260,006 la glvenias tolerable level In water divided by a safety factor of 5 to give a maximum PCB concentration In water of 0.002 ppm. Thus EPAlaccepted 2 ppm PCB level In fish but got to water concentration of 0.002 ppm by using a high level of 200,000 for blomagnlflcatlon and an arbitrary factor of 5. If we were to revise the proposed EPA standard by: (l) using 2.0 ppm as chronic limit in fresh water species Instead of 0.5 ppm; (ll) substituting 30,000 Instead of 200,000 for blomagnlflcatlon factor; and (111) Ignoring safety factor of 0.5 then the maximum permissible discharge in lb. PCB per day would be: 2.0 v 10,000 x 5.4 36,6o6 A * ~ 3.6 lb. HONS 029696 -10- Por the plant situation on a river with a flow of only 100 efe the discharge would be O.036 lb/day or 9.0 lb. per 250 work-day year. These levels are still far below the 5 lb./day given In AflSI C-1D7. It Is therefore apparent that other aspects of PCBs must be highlighted In order to get away from PCB discharge levels as low as even our "revised'' proposals. Aspects to concentrate on are: (1) Definition of PCBs that excludes biodegradable homologs. This could exclude or better of Aroclor 1016 and 655* or better of Aroclor 1242. On that basis, discharge levels would be as follows: PCB Typej stream Discharge (ib.P<3B eoulvaient/dav) Plow (cfs) EPA Wright simons/wrlffht Any PCB Any PCB Aroclor :.01b Aroclor :.0l6 Aroclor 1242 Aroclor 1242 10,000 100 10,dO0 100 10,006 100 0.0648 0.000648 S7538 0.00648 0.l94 0.0019 O.918 0.00918 9.IH 0.0918 2.75 0.027 3.6 0.036 lb. 0 0.36 --------- iors--------- 0.10 (2) Try,to change stream flows from the present value of thejflow rate In cubic feet per second (cfs) expressed as the probable low rate occurring durlng~a7 consecutive day period once in 10 years at the effluent P^t. If the average flow rate over a period of time (to be agrSed on) was used, the lowest flow rate In the equation could conceivably be raised by a factor of 10 front 100 to 1000. In the Slmons/Wrlght version for a standard the Aroclor 1016 discharge could be raised to 3.6 ilb./day at 1000 cfs flow and Aroclor 1242 to 1.0 lb./ day 1st 1000 cfs flow. (3) Magnitude of PCB Point-Sources It lia possible that EPA and environmentalists are totally misinformed on the number of plants still using PCBs. In the U.S. today there are: HONS 029697 -11- 1 PCB manufacturing plant --18 capacitor planta using PCB -- 27 transformer manufacturing plants using PCB In the past there were probably 1500-2500* plants using PCBS. Only 2-3# of these plants continue to use PCB today. * (Sjubject to closer checking If necessary) In tfie past --97$ of plants using PCBs purchased--40 million pounds of PCB per year. Monsanto's PCB sales policy has therefore - reduced number of using plants to ~2-356 of previous total. - eliminated -- 4oH lbs. PCB sales per year. The fcPA standard would limit PCB discharge per plant to 0.0648 lb./day or ~3.2 lb./day across the U.S. (--50 plants). This equates to ~800 pounds In a 250 work-day year^ Since fish have survived throughout the 40+ years that! PCBs have been produced and widely used, the standard proposed by EPA seems far too drastic. Turning again to the Slmons/Wrlght proposal we can estimate the effect In terms of annual PCB discharge Into water across the U.S. at pOO cfs: Discharge As Discharge (lb./day)_ No. Plants US Total per 250 days (pounds) As Persistent PCBe Discharge ----- NoT^ US (lb./day) Planta Total Any PCB Aroclor ; 016 Aroclor : 242 Aroclor 254 3.6 3.6 1.08 O.36 *1 18 4 23____ 900 16200 1080 2070 1.2 0.36 0.36 ____ 36___ 1 18 4 23___ 300 1620 360 2070 , 20.250 ________________________ 4250 * Plant Is on river In excess of 10,000 cfs. Using this technique an argument can be made In favor of the ANSI C-107 proposal of 5.0 lb./day. MONS 024448 -12- Proposedl Effluent Standards Dr.Slmons (O.E.) summarized the points he felt had to be dealt with In trying to change the proposed standard: 1. ' Higher persistence of hl#ier PCBs versus alleged lower acute toxicity 2. Background levels of PCBs 3. Written testimony of participants and correlation Toxicity SPA Basis fr. Purpose document (page 50) states that 96 hour LC-50 to fish cannot adequately measure toxicity of PCB. Where Is time demarcation between acute and chronic. Chronic effects can be either lethal or non-lethal. Why are PCBs on the list on toxic grounds? LD-50 fop PCB Is such that It Is not considered toxic to humans. For protection of aquatic life the Nat. Aca. Scl. set a 96 hour LC-50 of 10 ppm or less. In proposing a definition for PCBs, Dr. Simons (O.E.) felt we should stress: (a) lack of persistence of homologs below tetrachloroblphenyl. (b) chronic toxicity does not arise for the lower homologs because they are non-persistent. (c) Ignore acute toxicity - no real differences between Aroclor 1016, 1242 and 1254. Participants need to consider: Do we have the best definition? In the tentative EPA analytical method we should take note that In the table on p.3-22, the percentage of PCs was not controlled. Mr. CarlSon (E.U.C.) pointed out that In Its present form the standard Icould saddle present PCB users with all other dis continued uses. Dr. Richard (Monsanto) pointed out that FDA and Boxboard Manufacturer's Association had agreed on a protocol that protected recycle paper users from Just such a situation. Mr, Bergen (Monsanto) asked that copies be circulated to participants. HONS 029699 -13- We need to word our definitions to exclude residuals. Participants should exchange proposed drafts on wording re garding residuals by March 7. 0. E, stated we should not approach the hearing on the basis that things can't be done. Rather take the proposed standard and poliit out what It means in real life, In G.E.'s case they use x 1? lb./year and yet can't lost 0.5 drops per day. Stream flow rates make the matter worse. This Is a point on which Dr. Thompson should be cross-examined. Of the participants present, 5 plants discharge Into sewers with outlets Into rivers (very small except in 2 cases). Three plants 4lcharge Into small rivers. Mo one at the meeting could cope with the EPA standard as It Is proposed, only Jard expressed an opinion on what level they could live with. (Jard stated 27 lb. Aroclor 1016 per day. This would be 2.7 lb. PCB by our proposed definition.) HONS 029700 -14- Part lclpatlon at EPA Hearing Definite participation; Monsanto Undecided: No participation: Electrical Utilities Jard NEMA Electronic Components Mallory Objectors of record could adopt non-responding company as witness. O.E.'s testimony will fall Into the following areas: - Explanation of why PCBs are used - Consequences of ban on customers - Inadequacy of EPA/Nat. Acad. Scl. statements - How standards would apply to O.E. - Inadequacies of the Standard definition methodology logic behind the standard Other contributory actions: - Involve Federal Energy Office (e.g. Aerovox letter on motor-run capacitor contribution to ease energy crlslB.) . - Involve P.E.O./other agencies along lines of petrochemical producers' PEG report. - Power Systems Group of IEEE will circulate a posi tion paper on PCBs (technical aspects) in the dielectric industry to Congress, EPA, FEO and Dept, of Commerce (target date: April). MQNS 049701 -15- Aetlon Plans 1. (W. B. Papageorge) Circulate to participants copies of FDA/Boxboard Manufacturers protocol on PCBs In recycle paper. 2. (Participants) Exchange drafts on testimony regarding PCB residuals/background levels with each other by March 7* (Monsanto contact should be W. B. Papageorge.) 3. (Participants) Submit to W. B. Papageorge their thoughts on proposed PCB definition (to exclude 1-4 chlorine homologs). 4. (Participants) Communicate with each other on how best to handle sedimentation phenomenon (as raised by Mr. Sheppard of Westlnghouse). 5. (E. S. Tucker) Send out name of ASTM contact for participation In round-robin on proposed EPA analytical method. 6. (Participants) Write to Dr. Sailer of Commerce Dept, opposing EPA standards. (See Sailer letter to Monsanto and Monsanto response.) 7. (Participants) Those who have not responded to EPA can still write Dr. Thompson by March 25. 8. (A. Salazar, NEMA) (a) Set feedback from Sangamo/McOraw Edison on the proposed standards. (b) Determine role NEMA will take on affidavits/testimony at EPA hearing. 9. (W. B. Papageorge) Obtain PEG report and send to Mr. Nelson (O.E.). 10. (Partlclpants) Involve F.E.O. In EPA Hearing along lines of Aerovox letter to Secretary Simon. MONS 029702