Document dYVpGEG5099D16YJjGEoNr4Jq

V -1- PCB8 - ALLOWABLE DISCHARGE PROM PRODOCIRQ/USINO PLANTS 4/28/72 MINUTES OP MEETING - 4/13/72 IM EPA OFFICES. WASHINGTON. D. C. A. Present For Monsanto K. Warren Easley - Washington Office W. B.Papageorge - Q.O. A. E.Leisy - WOK R. K. Blowers - WOK W. C.Engman - WOK E. Scott Tucker - NIC - Research S. 2nd. P. B. Hodges - 0.0. Por EPA John L. Buckley - Deputy Director - Ofc. of Research Alphonse F. Forzlatl-Chief, Measurements ft Instrumentation Branch Paul E. Des Rosiers-Staff Engineer Industrial Pollution Control Elizabeth Anderson-Staff Chemist - Ofc. of Teoh. Analysis Oordon Everett - Director - Ofc. of Tech. Analysis Marllee Miller - No title Olenn Pratt - Chicago Region Enforcement Kathleen Schirmer- Staff Ass't. (New Toxic Div. not established) B. Background of Meeting The Task Force for FCB's with representatives from various Federal agencies Including FDA EPA TJSDA and coordinated through the Office of Science and Technology, will soon release its voluminous report on the PCB*s problem. Monsanto has cooperated with the involved agencies and had some insight Into what would appear In the report. We agreed generally with nearly all of the report recommendations but could not concur with two recom mendations (as we understood them) i PLAINTIFF'S EXHIBIT /S & 1 T NEV 000715 716676 V - 2- V (1) Water quality standard for FCB's to be set at 0.01 ppb for rivers and lakes. (2) Zero detectable level in dischargee from plants producing or using PCB's. An inconsistency existed in that we understood that the 0.01 ppb water quality standard was derived from a calculation involving 10>year low flows in the Mississippi River and a 3 lbs/day discharge from our WOK Plant (their understanding of what we were discharging to the river - the 3 lbs/day is equivalent to about 0.01 ppb in the river with no allowance for background). A meeting was requested to discuss these recommendations with Dr. Buckley, with Intent to prepare a formal presentation for them. However, due to time pressures in SPA, the meeting was set up on 1 day's notice. Our Information and comments had, therefore, to be presented Informally, with little time for preparation. The Monsanto group met to plan for the meeting on Wednesday afternoon, the various assignments/presentations were prepared that night and were reviewed on the plane to Washington, followed by another quick review in Warren Easley's office. Our objectives for the meeting were: (1) To Induce EPA to recommend a more realistic water quality standard than the 0.01 ppb - say, 0.1 ppb. The higher level would be more in the range of reasonable precision by the average laboratory and would recognize a small PCB background. NEV 000716 716677 c -3- v. (2) To induce EPA to drop the "zero discharge" concept and to allow a reasonable discharge (5 lbs/day) in terms of lbs per day - not concentration. 5 lbs/day is con sistent with requests of the electrical Industry using PCB's. (3) To induce EPA to allow a reasonable time to attain the discharge limit. C. Minutes of Meeting (1) Following "round-robin" introductions, . Papageorge stated our appreciation of this first opportunity to discuss with them the problems involved with plant discharges. He stated our desired format, which was to have various plant people discuss what we had done and were doing to control PCB discharges and to explain the problems Involved. Buckley concurred. (2) Art Leisy spoke briefly of the complex nature of the VQK Plant, the relationship to Sauget Village and the concern within manufacturing of the environmental Impact of wastes from the manufacturing processes. (3) Dick Blowers discussed physical growth of the plant, complexity of the sewer system, size and extent of our current program for ln-plant waste reduction and control. He pointed out that PCB's were a major one of numerous concerns where we were actively planning recycling or otherwise reducing wastes. He did not discuss the type of waste treatment Sauget Village is contemplating. Some remarks from Glenn Pratt and others about secondary biological treatment were Ignored. NEV 000717 716678 V -4- V (4) Bill Engman described the PCB containment and ln-plant reduction program (full text la attaohed). At the close of hlB talk, he stated the present level of discharge as follows: (a) From PCB manufacturing facilities - 2 to 4 lbs/day. (b) From the Tillage waste treatment plant, 5-10 lbs/day. (5) Dr. Buckley went through his rationale for the proposed Halts: (a) PCB In water la toxic to fish at very low levels - under 1 ppb for some speclea. (b) They know from experience that PCB levels magnify greatly from water to fish - he said 75000X. With that factor and a FDA allowable limit of 5 ppm, allowable PCB concentration In water would be: 5 ppm 75000 - 0.07 ppb (approx.) With using a safety factor (7) this brought the allowable water level to 0.01 ppb. Buckley stated his Intent that the 0.01 ppb level not be Imposed as a legal standard but be used as a working limit. (c) As a check on the reasonableness of that level, he had calculated the effects of our discharge of 3#/day (their figure) on the Mississippi River at 10 year low flow of 50,000 cu ft/sec. NEV 000718 716679 That also equals 0.01 ppb at the low flow (or about 1/3 of that at average flow of 175j000 ou ft/see which would allow an additional safety factor). (d) They (EPA) have no aetual measurements of FCB levels in the Mississippi south of LaCrosse, tfls. and don't plan to do any water measurement work. Buckley appeared disappointed that we have no actual background level measurements in the Miss issippi River. They will plan to do monitoring by fish concentration studies - if fish PCB con centrations are under 0.73 ppm, the ambient water is likely to be under 0.01 ppb. (6) As to allowable discharge, Buckley said they were con sidering a policy of zero "knowing discharge" (a term new to us and meaning any discharge above the absolute back ground level). This would appear to allow continuation of our background discharge plus a minimum amount from production facilities. He said that, where we were presently down to 2-4 lbs/day from our production unit, we could probably do more work and get to 1-2 lbs/day and that (plus our background) would be our "zero knowing discharge". (Mote, in a later telephone conversation with Bill Papageorge, Buckley confirmed the above and said he planned to circulate a private memo within KPA explaining what "knowing" and "non-knowing" discharges meant and that our present discharge from production facilities of 2-4 lbs/day appeared reasonable 716680 NEV 000719 c -6- c (7) Scott Tucker questioned ability to measure at the 0.01 ppi level. Dr. Forciati stated that their Athens, Oa. and Cincinnati, Ohio Analytical Labs are capable of easily detecting 0.01 ppb of PCB's In environmental samples, but they would not feel confident enough In their numbers to attempt enforcement at this low of a level. He went on to state that, "they would be confident enough at the 0.1 ppb level to go to court." When presented with the results of our Internal round robin study (FCB method accuracy and preolslon) at a level approximately 50 thousand times higher than the proposed 0.01 ppb number, he again stated their labs were achieving better results. He also Indicated that they were making quantitative FCB measurements via mass spectography at the nanogram level. (Notes from Scott Tucker - "Based upon our lab experience, I would say that Dr. Porclatl Is a little overly opti mistic with regard to the accuracy and precision of current PCB methodology. Dr. Porzlati extended an Invi tation to Monsanto to visit their facilities and It Is currently planned to contact him and arrange a visit. The objective of the visit will be to get a better feeling for their PCB analytical capabilities and to establish direct contacts with their analytical people"). (8) Paul Hodges raised the question of mixing cones. Dr. Buckley had stated that full flow In the river was used In calculating dilutions In the river because there was no acute toxicity problem with fish around the outfall. NEV 000720 716681 VV -7- Hodges pointed out that, when the Federal report Is re leased, the states will move to enact PCB water quality standards and disoharge regulations. Some of them, specifically Illinois, use limited mixing zones to determine compliance with water quality standards (in Illinois the sample is taken 600 feet downstream from the outfall). Hodges requested that the Federal report spell out the principle of using full dilution In the river. Buckley agreed. (9) As an aside after the Meting, Glenn Pratt (Surveillance, Chicago Regional EPA office) said that they were concerned about the levels of mercury being reported to Illinois since they were over 0.25#/day. He said he had written a letter saying they wanted to come to see us about mercury and about PCB's but had not sent the letter when the sub ject meeting was arranged. He would be contacting us in 2-3 weeks. Art Leisy had, earlier In the meeting, in vited Pratt to Inspect our PCB production unit and con trol facilities. D. Summary and Conclusions (1) We feel that Dr. Buckley Is taking a reasonably realistic approach to control with his "knowing" and "non-knowing" discharge conoept. However, we are dubious thatt (a) It will hold up as the document Is reviewed within higher levels and other branohes of BPA. (b) The Illinois Pollution Control Board will be as understanding as is Buckley when they move to formulate water quality standards and dlaohur* 716682 NEV 000721 -8- regulations for PCB'. We would expeot the Board to Move shortly after publication of the Federal Task Force document and announcement of standards and resalations by the Federal BPA. (2) The 0.01 ppb water quality limitation Is likely to hold up even though measurements at this level are not aocurate and the Federal people have very limited data on PCB concentrations in rivers and lakes. It is also likely to become or to be used as a legal standard. (3) Apparently, Buckley moved quickly In his calculations establishing the 0.01 ppb limitation from the FDA level of 5 pp* in edible portions of fish to magnification of 75000X from water to lipid portions of fish (see C-5 above). This provides an additional safety factor to the 71 In his calculations. This was not really challenged at the meeting* (4) We don't know whether or not 0.01 ppb is exceeded either above or below our outfall in the Mississippi River. We have analyzed two large adult Mississippi River carp for FCB's. They contained apparent FOB concentrations of 1.4 ppm and 5.1 calculated on the whole fish basis. Using Dr. Buokley's concentration factor of 75*000 indicates that the river could contain 0.02 - 0.07 ppb at the point where these fish were collected (this assumes that the 75*000 factor could apply to whole fish - we are uncertain about this). Further flsh/Sratav onitwrtmct is needed. 716683 Paul B. Hodges NEV 000722