Document gaG0YGG7GQq8qEgkEdLB8aLDe

INCIDENTAL PCB'S ______ SUMMARY BRA has stated that they plan to regulate 'incidental PCS'a* generated at levels of 50 ppn or less in chemical processes. CMA surveyed its membership and concluded that only about 13,800 pounds per year of PCB's are generated by respondees, believed to accounjt for 1/3 of all chemical industry sales and a significantly larger' fraction of all chlorinated chemical sales/production. Of this 13,800 pounds .per year, all but 5% (~660 pounds) are disposed of in BPA approved facilities, l.e., incinerators, landfills, etc. Of the total incidental PCB's generated, about 90t are the "noncotmaercial" mono- and dichlorobiphenyls which readily biodegrade in the environment in a few weeks. The 660 pounds per year of incidental PCB's not disposed of at time of manufacture exist as either chemical intermediates and industrial compounds or are encapsulated in commercial products such as polymers and paint films. None of these uses or products pose any significant exposure risk to the public, workers or the environment. This (60 pounds per year of incidental PCB's EPA proposes to regulate is innocuous in that it poseB no significant risk nor added burden to the environment or populace. Currently, about 750 million pounds of "old'' PCB's are still present in the environment and 350 million pounds of these are authorised by EPA- for use in electrical equipment. BPA authorises this continued use in their new proposed regulations, while recognizing that approximately 600,000 pounds of PCB's annually leak into the environment from this equipment. To further put this issue in perspective, note that the quantity of PCB's likely to be generated between now and the year 2000 would be less than 1/2 of It of the current environmentally free PCB's expected to biodegrade during the same period. 5/3/83 J. B. Craddock HONS 011984