Document k6ovOk8V1EyLv2qNJkqwgOQLn

DRAFT 1 WBP/bt 12/18/72 Office of Enforcement and General Counsel Environmental Protection Agency Washington, D.C. 20460 Re: Environmental Protection Agency . 40 CFR Part 126 National Pollutant Discharge Elimination System Federal Register, Vol. 37, No. 234, pp. 25898-25906, Tuesday, December 5, 1972 Gentlemen: We have reviewed the Environmental Protection Agency's proposed forms and guidelines for acquisition of infor mation from owners and operators of point sources subject to the National Pollutant Discharge Elimination System (NPDES). With respect to this rule making we have the following comments to offer relating specifically to Item 15, Column 3, Page 259OO; Item 13, Column 2, Page-25902; Item 14, Column 3, Page 25903: and Item 10, Column 2, Page 25904 of the Federal Register, Vol. 37, dated December 5, 1972. In each of these identically worded paragraphs the last sentence contains an extremely short list of materials which presumably are intended to be typical examples of substances which are defined in the first sentence of these paragraphs and are freely involved in commerce -in significant quantities. Included in this list are poly chlorinated biphenyls (PCBs). PCB-ARCH0743182 Monsanto Company, the principal producer of PCBs in the United States, unilaterally took steps Intended to reduce the entry of PCBs into the environment. A program was initiated for reducing the sale of PCBs which provided that sales would be made only for use in applications where (a) the products were necessary from the standpoint of the public interest and, (b) no acceptable alternatives were available. Today all PCBs manufactured by Monsanto Company are used only by the electrical industry for dielectric uses such as in transformers and capacitors. All other sales have been terminated. Recent reports supporting this use include the Interdepartmental Task Force on PCBs report entitled "Polychlorinated Biphenyls and the Environment" dated May, 1972, the Food and Drug Administration's "Environmental Impact Statement - Notice of Proposed Rule Making - Polychlorinated Biphenyls" dated May 8, 1972 and the U.S. Department of Agriculture Ad Hoc Group on PCBs' report entitled "Agriculture's Responsibility Concerning Polychlorinated Biphenyls (PCBs)" dated September, 1972. - With this current limited and controllable application involving a relatively small number of manufacturers and users, it appears to us that PCBs are not appropriate candidates for a list of "typical" materials. Inclusion will create unwarranted disruption to many owners and operators who have never used PCBs and are totally unfami liar with the material. 0002253 PCB-ARCH0743183 - 3 - We respectfully urge that polychlorinated biphenyls (PCBs) be eliminated from these lists. Respectfully Submitted, WBP/bt W. B. papageorge , Manager Product Acceptability 0002254 PCB-ARCH0743184