Document mp3oDqVdKvXgXkjj2a9B43VLB

HQ'QKE 3SE MPARMENT CF NHUJiaL KESOOTCES Public Hearing to Review and Receive Public Cement Upon Preposed ASniniatrative Roles Delating to the Dis- charge of Folychlorinatad Biphenyls (PCB's) Into the Waters of the State ) ) ) ) ) * rs i I SJ Hearing Held August 28 i 29, 1975 Pages 1 to 75, inclusive WTM00537 NCR-FOX-0281394 WATER PCB-00044138 APPEARAHCES advkcb raaMSFdWEE co. by Eugene Creractoll, Dewelopuental Engineering Mg*?. 6957 H. Ottawa Ave., Chicago, Illinois 60631 behgshch paper axsum . tv . Janes S. Haney, Rublis Affair* Director Bergstrom Road, Neenah 54956 . and by Richard W. Hand, Administrative Vice President 451 E. Peekham St., Neenah 54956 BROW OOtffiKK George 0.. Reihbacher,. Director of Mfg. 223 E. Hamilton st.,-Eau Claire 54701 cm CP HnHMJKEE Sewerage Crrmisalcn by Richard H. Manthe, Supervisee, Lab Services and Quality Control P.O. Box 2079, Milwaukee 53201 atMOTEE TO EXPCSE CARCBCGEN OOVEK-CP Affiliate of Outer for Public Presentation by Edward P. Tilson - 244 Lakelawn Place, Madison 53703 CCtSQUGDRSED PAPER, SC. *ar Groff Collett, General Manager, Paperboard Products Wisconsin Rapids 54494 - - and by Stratton Martin, Director, Enviromental Affairs P.O. Bar 50, Wisconsin Repids 54494 . DOW CHEMICAL Catpary by R* Branscn , ' 1702 Bldg., Midland, Michigan 48640 and by . JOfcnC. Safranski Jr., Research Manager 2020 Bldg., Midland, Michigan 48640 DOW OCMOH3 C0RPCKU3CW by . Dennis C. Besseneckec, Hew Products Marketing Coordinator ' Midland, Michigan 48640 BSmOQC 3NDOSXRIES ASS0C2AZXCH Rietoerf Rollins, Vice. President, Engineering Bowen Road, Bennington, Vermont 05201 P1AKDEAD PAPER CCKRMff by William Dryer, Director, Research and Development 200 First Ave. Narth, Park Falls 54S52 PORE HOWARD PAPER CO. by Irvin B. Qarha, 2U . Wisconsin 53203 1 -VFTH00538 f <' NCR-FOX-0281395 WATER PCB-00044139 appearances (cant.) GENERAL EIECERIC Cb. *y Stu Richel, Attorney, Environmental Protection One River Road, Schenectady, New York 12345 GENERAL ideas ty . Henry Johnson, St^ervisar, Solid Waste Management Resource Recovery Oi kh Center, Warren, Michigan 48090 - institute cr rarer chemistey tar Dwight B. Easty, Research Associate 2101 Clover lane, Appleton 54911 . IZAAK WH1CN LEAGUE CP AMERICA . A. K. Forster, State Trea. 3317 Harper Road, Madison 53704 ICEMAN UCN AND METAL CO. by Milton Iceman, President US Leman St. Fort Atkinson . MENAfflA CORPQRATICN John Strange Paperboard Division by ' Janes J. Schedgick, Tech Director . 2702 S. Telulah Ave., Appleton 54911 and by W. Allen Schenck, Vice President Highway 41, Neenah 59546 . ' . . ' MICHIGAN HEPAKM3OT CP PUBLIC HEALTH by Harold Humphrey, East Lansing, Michigan MINNESOTA DEPARTMENT CP AGRICUB1URAL SERVICES by David itacLean? Director 510 State Office Building, St. Paul, Minnesota 55155 . MINNESOTA DEPARTMENT CP NATURAL RESOURCES ty . award F. Krasch, Aquatic Biologist 390 Centennial Building, St. Paul, Minnesota 55155 MINNESOTA POTIOTICN CONTROL AGENCY by Marvin E. Beta, Senior Biologist 1935 W. Co. Id. B2, Roseville, Minnesota 55113 M3NSANID COMPANY ty William B. Papageorge, Manager, Product 800 North Lindbergh Blvd., st. Louis, Missouri 63166' and by Dr. Paul L. Wright, Manager, Toxicology 800 N. Lindbergh Blvd., St. Louis, Missouri 63166 . THE NATIONAL ASSOCIATION OF RECYCLING INDUSTRIES by Howard Ness, Technical Vice President 330 Madison Ave., New York City 10017 WTM0D539 i N C R-FOX-0281396 WATER PCB-00044140 atpeabahceS (Cent.) . NCKEHERN SOSES SOUER CCMPAMr tv . Richard Rrestin, Environmental Biologist 100 N. Baratov, Eau Claire 54701 `' ' 0'BfiHH t GOB E2J3HEERS, INC. ty ' Ralph todurg 910 M. Wingra Drive, Madiscn 53505 * . ' . . SHADE IHWBim SSSTEM5, DC. . *y R. A. Shade, President Box 730, Green Bay 54301 . ' gram IEGISIATIVE COUNCIL ty . Steven Schopler, Setmet s Technology Intern . Roaa 147; North State Capitol, Madison STATE OF WISCCUSBJ ' Division of .Health of Department of Health 4 ftvrtal Services ' tv Gacege H. Handy, M.D. ' 1 W. Wilson, Bck 309, Madison 53701 . . tKTVERSIT5f ce WXSOCKSIN . tv * Linda Weiner, Assistant Director, Sea Grant College Progxwa 1800 University Ave., Madison 53706 and ty Z. P. Tilficn, fhgineer-in-Tcaining, Water Resources Canter. 1975 Willow Drive, Madiscn 53706 . UNITED STATES INVDOMNTAL EHJiMLTlCK AGENCY tv Karl E. Brener, St A Division 230 S, Dearborn, Chicago, Illinois 60604 . and ty .' Francis J. Early, Physical Scientist, NE2C, . P.O. Bck 25227, Denver, Colorado 80225 and ty Billy Fairless . 1819 W. Pershing Road, Chicago 60609 and ty Itra Kopp, office of Tcodc Substances Washington, D.C. 20460 .. and by Gilman Veith, Research Chemist, National Water Quality Laboratory 4102 ccoke St., Duluth, Minnesota 55804 U. S. nsa 6 WXU3LXEE SHWiCSS . ty Dr. Maes B. Elder, Wildlife Biologist pied. Gldg., Ft. Snelling. Twin Cities, Minnesota 55111 U. S. POCD AND DOTS ADKDCSlSAXICtl ty Henry P. Roberta, Deputy Rogicnal Director 240 Hennepin Ave., Minneapolis, Minnesota 55401 VHRSAR, INC. by 6621 Electronic Drive, Sparing-field, Virginia 22151 3' WTM00540 NCR-FOX-0281397 WATER PCB-00044141 APPEARANCES (Cent.) WISCONSIN EIZC3KCC POKER CCfrEANI ly . Francis B. Manning, Superintendent, Environmental Planning 231 W. Michigan, Milwaukee 53201 and by . John W. Troglia, Chief Station Engineer (also rep. Kiaocnsin Public Service Ctrp.) 231 W. Michigan Street, Milwaukee 53201 KISCCNSIN PAPER COUNCIL Donald L. Bach, Attorney 121 S. Pinckney St., Madison 53701 and ty 432l'w!*College Ave., Appleton 54911 ' WISCONSIN POWER i LICHT 00. fcy Michael D. Wish, Environmental Specialist 222 W. Washington Ave., Madison 53701 WISCTHSIN PUBtlC SERVICE CCKPCRflTXCN BERGSTROM PAPER COKPAIK fcy Allen W. Killians, Jr., Attorney 777 E. Wisconsin Ave., Milwaukee 53202 WISCONSIN TISSUE MILLS ' fcy Richard C. Peterson, Deink Si$>t. 632 Reed St., tleenah 54956 1 DR. AOTCN MUBINS . 111 4th St., W&unakee 53597 ' RODERICK S. SMITH 309 B Eagle Heights, Madison 53705 DAVID A. ST!TIBER Bahopok Ball, University of Winoonain, Madison 53706 . ' . 1 4 UTM00541 NCR-FOX-G281398 WATER PCB-00044142 BEPPBV. USS DEEAR3MBEC CF NATURAL RESOURCES Public Hearing to Review and Receive Public Consent Upon Proposed Adminis- trative Pules Relating to the Discharge of Polychlorinated Biphenyls (PCB's) Into the Haters of the State )_ ) ) ) ) . Hearing Has held in 421 South of the Capitol Building, Madison, Wisconsin, on TliuradUy and Friday, August 28 and 29, 1975. * Presiding: EXAMINES JAMBS CHRISTOSCN '' Recorder: DAVID CROFT EXAMINER: Cb the record. The Department of Natural Reeouxces-of' the State of Hfocorsin has set at this time and place a public informational hearing to receive ociasenta on and i4<w p.q;osed rules re lating to the discharge of polychlorinated biphenyls, also known as PCB's into lie waters of tie State of Wisconsin. ' . .. Such owuirnLs and information received, regarding the presence and use of PCB's- . nay also constitute a basis for proposing, or reccnnending. state or federal legislation regulating the sale, use and distribution of PCB's by this Deportment. . The proposed rules under consideration today are created pursuant and proposed pursuant to subsections 144.025(1), 144.025(2) (d), 144.31(1), 147.01(1) and Section 227.014 of the Hisoonsin Statutes. The rules were proposed and raocmneadad by the Natural Resources Departments--or excuse me, the Natural Resources Board'at their July, 1975. meeting. The provisions of Chapter 227, Hisoonsin Statutes, requires that the Department of Natural Resources held a public hearing on this matter. The procedure of the tearing will be guided by that same chapter. : let the reoand shew, that notice of the hearing as required by Section 227.021, Wisconsin Statutes, was published in the proper mams: in the notice section of the Hisoonsin Administrative Register for the month of July, 1975.. Also, notice has been sent to various - interested persons the Department .determined were likely to have an interest in. this matter. To date I believe there's been also three pebble news releases regarding the. matter and the time and date of this hearing. Again, the purpose of the hearing today and tcnoexcw is to provide an opportunity to those agencies and persons interested in the proposed rules for oral content. The Department WlU also receive written consents, which will be given the same weight as any oral statements made here today or tatornw. As far as the time, allotted or aUcmed for the written-counent . suhmissicn, that'll be determined later today dr early tororrow. It is my understanding also that Ocmgressnan Alvin Baltes conducted a forus for public oaimant on PCB's in Pepin, Wisconsin on August 20, 1975 and that the record of that fanm is available to the Deportment for review if we wish it. . ' The procedure of.this hearing, due to the.muter of persons participating, will be as follows: First, there will be presentations by various parties requested to make those presentations by the Department, Again, this will be considered the Deportment presentation. Today, August 28th, the presentation by the Department will lash acmewtere between 10:00 am. and 3:00 pus. He will then open the hearing to receive public eenmehh. If wa have time between the hours of 10:00 and 3:00, we will both allow questions and receive public ccnment. - ' various copies of the agenda of the two-day teasing have baaa passed around. Again, it's teen chafed somewhat, but it gives you an idea of the time sequence. 5 . TO100S42 NCR-FOX-0281399 WATER PCB-00044143 r The hearing tcrnorrew, set for this sane place, will ccnrence at 8t30 ajn. and go until 4:00 pjt. Again, various agency representatives have been requested to make presentations on of the Department and I believe the majority are frcn the Environmental Protection agency. Without further statements, 1 will new call on Mr. Stanton Kleinert, chief of the Surveillance Section, Wisconsin EWR, to give a presentation. - MR. HEHNERT: Thank you, Mr. Christenson. My name is Stanton Kleinert. X am chief of the Surveillance Section in the Bureau of Water Quality, Department of Natural Resources. X am responsible fear the Department's investigation of polychlorinated biphenyls, or RGB's, in Wisconsin. My remarks will he confined to a discussion of the information conducted by the Department concerning the PCB's. PCB's are a family of chlorine-containing organic chemicals with varying properties. The ccrron PCB's encountered in Wisconsin include Arcelor 1242, 1248 and 1254. The latter two digits iitiicate. the percent chlorine in the ampeamd. Each Arcelor produced is actually not a pure compound but a multi-caipenent mixture containing lesser amounts of other Aroclors. In this report, all aroclors will simply be referred to as the PCB's. - Mere than 800 fish samples have been analyzed fear PCB's by the Department of Natural Resources to date. The fish analysis program has shown that many fish &cn Green Bay, take Michigan, the upper Mississippi River and the Fcoc River near Portage, exceed the Food and Drug Administration Tolerance level of 5 parts per million PCB's. The data to date is insufficient to indicate vhetter or not PCS residues are increasing or decreasing in fish, with the exception that surveys conducted in the upper Mississippi River, including lake Papin, indicate a re duction in PCS concentrations in the fish between 1970 and 1975. ' ' The State Departments of Natural Resources, Health and Social Services and - Agriculture have' a working cccaittee to review and act upon the monitoring data for PCB's in ' fish. We have also shared our information with neighboring states, the Environmental Protection Agency and the Food and Drug Administration. Xn addition to the fish monitoring program, the Department has searched for sources of PCB's. PCB's have been found above the .1 part per hiHim detection level used for screening purposes in more than half of the sewage treatment plant effluents we have tested. The higher concentrations are most common in sewage treatment plant effluents serving industrial areas sued: as Sheboygan, Neenah-Menasbs and Milwaukee. In most cases, however, the discharge of PCB's is less than one part per billion and .01 of a pound per day. . Tracing sources of PCB's reaching a large municipal treatment plant is a difficult and time consuming task. The Department is attempting to trace souroes of PCB's reaching treat ment system where the final effluent exceeds 1 part per billion. At the present time, we knew of only two municipal wastewater, treatment plants in Wisconsin which exceed one part per hi) Hen, the Sheboygan and Portage facilities. . The main source of PCB's. being discharged to the Portage treatment plant was found to be the NCR Appleton Papers Division Paper Capsule Plant in Portage. This facility had used PCB's in the manufacture of carbonless copy papers prior to the manor of 1971. After ceasing the use of PCB's' and after repeated cleanings of the holding, tanks of the facility, the ernpany substantially reduced the discharge. Residuals still remain, however,' in the sewer system and the sewer sludges, resulting in an effluent of Beveral parts per bill ion at the municipal treatment plant. . . The Department of Natural Resources has tested the effluents of 16 pulp and paper mills far PCB's. The testing has revealed that nine of the mills had measurable discharges which ranged from .1 to more than 18 parts per billion. The higher concentrations and quantities were fourti in the effluents of two mills which deink and recycle waste papers. These axe the Bergstrom paper Ccnpany Mill and the Fort Howard Paper Company Mill. PCB's are found in many kinds of Waste papers. Because their solubility in water is very low, we believe that most of the PCB's discharged from waste piper mills are adsorbed on fibers and' other particulate matter. Mill waste treatment systems which effectively remove particulate matter should also remove PCB's. The Department has checked effluents from iron and steel foundries and altnrinum foundries. The testing has shown that the cooling water effluents frets three of five aluminum foundries sampled contained PCB's ranging from 11.5 to 335 parts per billion. Close investigation of one of the alra&nun foundries, Meta Mold of Grafton, revealed the source to be leaking hydraulic fluids containing PCB's, which were being used in the die cast machines. Meta Mold is replacing these hydraulic fluids and is disposing of the old fluids by recaroendad disposal practises. We have fond PCB's in the cooling water effluent of only one of nine iron and steel foundries which have been, cheeked to date and that at a cxnazntx&tim of .9 parts per billion. 6 WTM00543 NCR-FOX-0281400 WATER_PC B-00044144  The eleetaieal industry continues to uae PQ's as dielectric fhiids in son* capacitors and.transformers. Althcugh the PCB is sealed in .the capacitor and tamsfoemer units, ease may be lost as a result of accidents or as a result o the disposal practices for defective units. In March, 1375, the Department oarrespcnded with the inajcr electrical oenpaniea in Wieocnsin to determine current handling' practices far capacitor and- transformer fluids. Tha oerrespccdence was followed by visits to many facilities. The txnpanies contacted were aware of the PCB problan. But sone ware not aware of the recentnendad guidelines of the American National Standards institute for Handling and Disposal of Capacitor and Transformer Fluids containing the FCB's. He also found that seme electric ccnpanies were storing defective capacitors con taining FCB's until a pepper disposal method could be found. As a result of this survey, specific guidance was given to Wisconsin Electric Dilities far the proper handling and disposal of FCB's. ... snow samples were collected early in 1975.to determine if PCX's were deposited cn land and water as fallout fron the air. Analysis of the snow melt water fern Racine, Kenosha, Hadiscm and Milwaukee revealed ccncentxaticns fixm .17 to .24 ports per billion. It is suggested that a major source of FOB'S, in atmospheric fallout is the incineration of papers and other materials which contain FCB's. . " ' FCB's are present in the sediments in harbors and.streams near industrial sreas. The sediments act as a reservoir'wheie FCB's may be released slowly ever a long period of time. Sediment samples have tested three and a.half parts per million in the Milwaukee River,, hear Vhft rapifjil Brims Bridge, nine parts pan mill inn in Bupm-ierr Ksrfcer siid 73 par+Ltt pw-mitUnn in the Fck River below the outfall of the.Fcrtage Sewage.Treatment'Plant. .' Presently the Department has one. chemist and two laboratory technicians working full-time analyzing fish, effluents, sediments and other, saspies for FCB's. - . gn addition. Department district biologists and environmental engineers are upon to collect samples and asks surveys of industrial and municipal facilities and treatment eystaas. ' '' '. The Department is a working runiter of the lake Michigan Toxic Substances Committee with the State of Michigan, Indiana, minis and the fiwircrenehtal Protection Agency. The committee held meetings cn March 24 and May 22 to consider the FCB problem, has cespiled infanoa- ticn gathered by the various states and EPA and has released its report and raumnwdatinns for deeding with the problan in lake Michigan. '' The- Department is also working as pert of.a. task force group with the State of Minnesota, the Environmental Protection Agency.and the Food, and Drug AJministraticn, in respending to the problan in the upper Mississippi River, Node assignments have been made and task force - maters ere proceeding with their various tasks, which include the analysis of water, sediments and fish and- the investigation of suspected sources of pollution. Meetings pf this group vers held cn May 23, June 2, June 18 and August 6. The task force has issued' its first report bn PO levels in fish. Effluent samples obtained firm the major' dischargers to. the upper Mississippi River are being tested at this time. The task force will meet again cn Septintes 15 to review and act upon the reoent data. " *' . . In simony, although we have found saury source* of dieeharge of FCB's, most of thmare la tease mmmtB aC.-lesa than one part pgr billjm, Seme of the sources,' however,. such as -fallout fron the air and diacharqes frem waste paper recycling, account far larger amounts of FCB's. We knew very little about the accent of FCB's vhich may be released from past accanulaticns in sediments in rivers and harbors. We knew little about losses of PCX's which might occur as a result of leaching fraa.disposal sites where capacitors and transformer fluids and other material a were disponed in the past. .' He anticipate that PCB levels in the. envirenuent will progressively decline with declining uae. Me are searching for ways and means, to further reduce discharges to the environ ment and welcome your participation here today to consider the effluent limitation approach to the problem. We are mindful, however, of the fact that other regulatory mechaniane may be needed to limit dicharges to the envixement. ." . Thank you. ' EXAMINER: Thank you, Mr. Kleinert. Do you have a copy of that statsuent? We have a few minutes. Would anybody wish to ask a. clarifying question? TOZCEs Can espies of that be mads available--that statement, MR. HSEHSSi It's part ed the hearing raoetd. X could give copies, if naeMaary. 7 ' '- WJMO0544 NCR-FOX-0281401 WATER PCB-00044145 EXAMINER: It is part of a hearing regard; it'll be available in tte transcript. Mr. William. MR. HULISKS: (Inaudible) . EXAMINER: Excuse me. Could you use the Bdxarpfccne here so it goes cn the reoozd. Please identify yourself. MR. VHUAMS: Allen Williams/ here for Bergstran Paper Canpany. Ycu indicated initially that you are lucping all of the Aroclars together and you would speak about PCB's genetically, including 1242, 48 and 54. Can you, though, identify which of those Aroclores you were finding in these various fish that you were testing? MR. KLEHEKT: We can--we can in sane cases. Like In the upper Mississippi River, the principal Arcelor that vre're finding in fish is 1254. In lower Green Bay, the principal Axoclcr we're finding is 1248. MR. WTO.TAMS: Thank you. EXAMINER: Does anybody else wish to ask a question of Mr. Kleinert? (No response) EXAMINER: Okay, in that case, then, we'll go on with the presentations by the Department of Natural Resources. For the benefit of those appearing on behalf and at cur request, I would request that they care up alongside Mr. Kleinert and speak into the microphone. That . way if anybody does have questions, they can apeak to them froa the other miexepbcne. And I believe that the first person cn the agenda is Mr. Henry P. Roberts, deputy regional director of PDA in Minneapolis. - tad I also request that each person making a presentation please identify thanselves and who they represent and if they are representing son-body, their title. Go ahead, sir. MR. ROBERTS: Thank you, Mr. Christenson. ' Good morning. My name is Henry Roberts. X am the deputy regional director of the Minneapolis Office of the Federal Food and Drug Administration. The Department of Natural Resources for the. State of Wisconsin has asked me to testify cn the subject: the rationale far the five parts per million tenporary tolerance for PCB's and the FDA enforcement action far carp in Lake Pepin. . As part of ay testimony, I as attaching tbs final erdar cn polychlorinated biphenyls dated July the 6th, 1973 (38 Federal Register, page 18096). This order and the accotpapying preamble explain in detail the overall problems of PCB's, the steps taken by PDA to control this problem, the tolerances established by FDA far PCB's in certain foods and the basis for these tolerances. PCB's are toxic industrial chemicals. Because of their past uncontrolled industrial applications and their chemical stability, PCB's are a persistent and widespread con taminant of the environment. As a result, certain feeds' including those of animal and serine origin, contain PCB's as an unavoidable environmental contaminants. In the case of fish, the transmission is through the water in which they live, \*ich is contaminated fay PCB's. Because PCB's are unavoidable, tenporary tolerances under paragraph 406 of the Federal Food, Drug and Cosretio Act far residues of PCB's as unavoidable environnental contaminants were established. In establishing these tolerances, the ocnrdsaicner of the Foods and Drugs took into account available toxicological data, which is smmarized in the attachment and the extent to which PCB's in these foods are unavoidable under current good manufacturing practices. - Cn the basis of these considerations, the cxiunlssioner established the following teapccary tolerances far PCB's: One, 2.5 parts per million in milk on the fat basis. Two, 2.5 parts per million in manufactured dairy products on a fat basis. Three, five parts per million in pounltry cn a fat basis. Four, 0.5 parts.per sdllich in eggs. Five, 0.2 parts per million in finished animal feed for food-producing animals, except the following finished animal feeds, feed concentrates, feed supplements and feed premixes. And six, two parts per million in animal feed eeraporients of animal origin, including fishmeal and otherby-produets e marine origin ami 8. WTM00545 NCR-FOX-0281402 WATER PCB-00044146 in finished animal feed concentrates, supplements and prensixea intended fca: food-prodtcing anisals. Seven, five farts per million in fish and shellfish, edible portion. ihe edible portion of fish excludes head, scales, viscera and inedible bones. And eight, 0.2 parts per million in infant and junior foods. . Additionally, the FDA is enforcing ah action level of 10 parts per million for KB's in paper food-packaging material, pending the ccnpleticn of a fwblic hearing to establish a formal tolerance under paragraph 406 of the. Federal Food, Drug and Cosmetic Act. I wish to emphasize that the tolerances established in 1973 were based on toe best todlogical data available at that time.. - Ha recognize, however, that .additional scientific studies, such as those conducted by Sr. Allen, who will be speaking to you sanetime today, have been ocnpleted. And We are currently reviewing these studies to determine whether revision of our tecpqrary tolerances is necessary. .. . ' As you know, IDA has jurisdiction over food only when it is offend for shipment or ia shipped in interstate, eeranerce. In the case of fish feds Lake. Pepin, wa have found shiprents of carp that exceeded the terrorary tolerance of 5'parts per .million Of FCB's. Carp - found to exceed this tolerance are subject to federal regulatory action. Such action might include seizure of the violated fish and the shippers of such fish, are also, in appropriate cases, liable to. criminal action or Can be enjoined from future' shipments. wish, to assure ' . you that EDA will continue to devote' its attention to the problem of ccrmerical marketing of. all foods, including fish that contain KB residues. . I also wish to assure you that the Minneapolis Office of the Food and Drug Afadnistraticn has beer, and will continue to work closely with the CNR of Wisconsin, toe Wisconsin State Department of Agriculture and the fishermen- to control this serious, peoblas.. . Hopefully our joint efforts will succeed in eliminating the problem in the lake. Lake Pepin, so that PCB'e will be of interest only historically, I shall be happy to answer any ' questions that are appropriate to the hearing. .. . EXAMINER: lhank you, sir. Do you have a copy of your statement available for us? MR. hcbertS: Yes. . . EXAMH331: Anybody wishing to ask clarifying statements cr questions, please approach toe mike. Would auybo^y wish to ask questions? microphone. Please step up, sir. identify yourself .and who you.,represent when you get to toe . . MR. PAPAGBOKS: I am William Papagecrge from Monsanto Crnpuy.. My question to Mr.- Roberts, the prograu indicates that you webs going to discuss toe step-by-step rationale for the arrival at the five, part per million level in edible fish. Mould you please do that for us. _ - MR. ROBERTS: I can do this by reading the Federal Register, which is part of ay attachment.- It's a rather long, long.dseHBenfc. . St's going to take--well, if were ready, you know, an hour cr two, if that's-- .. . atunazy?. _ MR. RAEiAGECKS: Is there ary manner In which you can suasarize it, sir? Just a brief ~' . : ; '. - . m. KEEFES* Rationale--and Z'a not a scientist. I'll be perfectly, honest with you. I'm not a chemist. Is based cn the amount in the* particular foods that one would in gest over a period of time. It's based on those kinds of things and this is explained in here and it is based on, of course, as you probably knew, the Japanese experience back in. the '70's. And that is--veil, maybe I can do it this way----i'll have to find---dietary sources, taqporary tolerances, taman toxiiogical data, would that be v*at we're talking about, . . However, what I'm trying to do and I'm not trying to be la^ about this, but I . just-- don't wont to read an hour of the Federal Register, It's not that interesting reading. MR. FAFAGBCHZ: Hall, sy intent, Mr. Roberts, is not,: to taka more time than is necessary, but I hove been present in many discussions at which the setting of levels in food . had been discussed and. frankly, I'm still confused as to how they arrive fnm animal toxicity data,, the incident in Japan, the type of diet that toe American-is normally1 exposed to. and the arrival at five parts per mUlim when I .also knpw cr have heard that .that five part per millim level existed long before it was ever published in tha.Feder&l Register and action levels ami actions were featea as early as 1369, as best I recall. 9 NCR-FOX-0281403 WATER PCB-00044147 So somewhere in the Food arid Drug Administration, there oust be someone *4 Knows where that five part per million number came from and Z lave had difficulty finding how they have arrived at that nudber. I'm just trying to get sens information. MR. KjfcstklS: Yen mean four and a half parts per grfTHi? MR. FAPAGECBGE: Yes, why isn't it three; why isn't it 15} why isn't it SO? Sere mat be sane basis for the five part per million. MR. ROBERTS: Cfcay. let me read this to you. This is the dietary sources of PCB and this may help explain it. - The results of ICA's total diet studies for fiscal years '70 and '72 show that quantitatively, measurable residues of PCB's are equivalent to an intake of approximately 0.06 micrograms per kilogram body weight per day or 4.2 micrograms a day far a 70 kilogram man. Because of the sensitivity of the analytical methods used, PCB's may be present in levels too low to be detected. If lewer levels could be measured, the dietary intake of FCB's fron the total diet studies would probably show an increase. It should be recognized, however, that in rare instances seme people could have more systemic exposures to FCB's in foods than those expected by eating a moderately well balanced diet, such as represented by the total diet sssples. Bence, there is a need for minimizing potential hsznan exposure. The total diet studies indicate that FCB's most frequently occur in the food composite consisting of seat, fish and poultry. Experience has shewn that most of the PCB residues in this opposite are in the fish and, to a lesser extent, in the poultry. And in the feed composite consisting of grain and cereal products, experience has shewn most of the FCB residues in this ccrrposite are derived fron the paper packaging materials. FDA's food surveillance activities have shewn that PCB's also occur in dairy products, eggs and packaged foods, in addition to packaged cereal products. . The tanperary tolerances for PCB's, using the human toxicological data described . above and I can go back and explain that if that's what we're talking about, the Tift concludes that for the short term, based on the lowest dose producing an effect an estimated biological half-life of FCB's, current levels of FCB's in the diet represent no immediate hazard. It is also true for the average total dose causing an effect in the Japanese far long-term exposure-- for long-term exposure. However, based on the most sensitive Japanese patient, i.e., lowest total dose producing an effect, the possibility of potential long-term hazards necessitates reduction of levels of FCB's in food as soon as possible. In the interim, temporary tolerances are necessary to limit htman exposure to those foods that may aentain KB's rekilting fron environrental contamination, which, as a practical matter, are presently unavoidable. These foods for which taqxrary tolerances axe established include milk and daisy products, poultry, eggs and fish-and infant and junior feeds. Infants and younger children oonsrne a greater amount of food per kilogram of body weight and thereby have a proportionately greater exposure than do adults, ft separate tarporary tolerance for infant foods and junior ' foods therefore reflects the possibility that undesirable exposures could result if oarbinatiens of certain FCB contaminated foods comprise a major portion of this.age group's diet. In order to minimize the overall dietary intake of FCB's, individual sources of FQ3 contamination Bust also be appropriately minimized. PCS' s have been shown to occur in packaged food as a result of FCB contamination of tbs paper food-packaging material. Limitations on levels of FCB and paper feed-packaging materials are therefore necessary to minimize the amount, of FCB's which migrate into the packaged food. Since FCB's can be transmitted to and concentrated in edible portions of food-producing animals ingesting FCB contaminated feed--animal feed, represents another source of FCB's in the food supply. . Limitations on levels of FCB's in animal feeds and animal feed cmpuuents are necessary, there fore, to minimise frequency and magnitude of FCB residues in food of' animal origin. Hew, do you want me to go hack and read mere? MR. BAPAtSCKZ: Ho, thank you, sir. ' EXAKZHER: Ckay. Thank you, sir. Does anyone else have any questions? Step up and identify yourself and who you represent, please. .MR. STOIBER: I'm David Stuiber, University of Wisconsin Food Science Department. I'm a faculty member within that Department. My question pertains to a abetment that was just read which states that the animal, beef, pack, fat--chicken, egg, ar the primary source of PCB's as far as the diet is concerned? 10 VTM00547 NGR-FC3X-0281404WATER PCB-00044148 HR. KEEKS: Yes. MU STOXBER: My -uesticn Is where the hell does the animal get it? I naan, if we're talking about grains, we': talking about a chicken. They have a very controlled diet. Now, I naan, they don't absorb iz frcra the air. Scmeplaoe along the line they have to be picking it qs. MR. RCEB3S: Probably they're picking it up in the feed. MR. STOXBER: Yes, well we practically eat the same thing, When you talk about grain or cereal, all right, they get a little lesser quality, hut as far as the grains ard the feeds going into these particular animals, we consume the same thing, so I assune, then, for all practical purposes, that X contain the same amount. MR. RC8EKES: Mall, remember they were chickens, how. Particularly we've got problems with fish meal and that is a major diet in some---at least saaa areas of the country. It may not be in---- . . MR. STOIBER: Primarily it's only 50 percent. MR. RCBERXS: Wisconsin. But it.is a part?--well, that's enough if it's high enough, and you know, this--we had this problem, remember when the USDA had to rmr^rur- an of the chickens down in Arkansas and Missouri. MR. STOIBEfc Rig'r-.. ' ' .' MR. EQSJHirS: I > * done--1 am. not aware pf any data on beef or peak, but we're talcing a very conservative appro.._i because it can unavoidably be in.tte rations that f<xd animals eat. We're going to inc.ude those under this thing. - MR. STOXBER: Hall, I would'just like to say that if we're going to T.inm cm food, wa ought to dan well go bade.and lock at everything that we're consuming. ' MR. HCH305: Maybe ws will. MR. STOXBER: Well, X didn't think it afould be maybe. X think we should. BXSDBBi Okay. At this time, Mr. stniber, just keep it to questions. You want to make a statonent later cn, I'll give you a chance. . . Anyone else? ' ' .' (No response) EXAMINER: Cfcay, Bank ycxi very much, sir. The statement--can X have it? Please leave the statement to make it part of the record. - Okay. Is Me. Kirechbaua of the Wisconsin Department of Agriculture tore? MR. XXRSCSBAEn: iy TM is Mnrm Wyrhbini- T rm nryl Standards Division of the: Wisconsin State Department of Agriculture. X have been requested to. discuss cur department's.food testing programs and the enforcement action that ws took against carp in the Qen Bay area as it relates to PCS'*. . . . . Our Department has the responsibility far. the administration and enforcement of Chapter 97 of the Wisconsin Statutes, which is the state: food law, as well as a ranker of food regulations pcenulgated under this law. This responsibility includes the licensing and inspection of various food operations as set forth in Chapter 97. .We also, inspect other feed production processing and distribution operations that nay not be required to be licensed. An iaportant pert of the toted food,inspection program is the sarpling and laboratory analysis of the various raw and processed food products fer adulteration and cccpoaiticn. . . There are several sections in Chapter 97 which are pertinent to tl* administration of this law and to my statasent here this mernihg. . Section 97.01 defines tie federal act as the federal food, drug and ccsnetic act as amended. Section 97.62 defines an adulterated food. With out reading the entire subsections of Section 97.02, this section states that food is adulterated, one, if it bears or contains any. poisonous or deleterious substance which is unsafe within the meaning of the federal act and two, if it is or it bears or contains any food additive vtoich is unsafe within the meaning of the federal act. X cite these-provisions since they are the basis far our using the tolerances and tsnpcrary tolerances established by PDA' for pesticides, fungicides, herbicides and in this instance, PGB's. Fishy therefore, Containing more than five parts per ml i n<-r> ecb's are eensiteai to be adulterated under Oapter 97 of the Wisconsin Statutes. .. 11 VEMQ05A8 N C R-FOX-0281405 WATER PCB-00044149 TO Beet this problem, our division has developed the following program: ' First, the objective, of course, is to permit only foods, including fish, to be sold contercially in Wisconsin marketplace that are below the tarporary tolerances far PCB's. This will be dsne with as little trauma as possible to the food industries involved. Including the fish industry. But the primary objective that we feel we have is to continue to assure the crammers that foods censured are not adulterated. TWO, a saspling program, for fish will be continued and, where necessary, increased to achieve the above objective. % specific sampling schedule for different species of fish has been developed. Our primary sampling points will be at wholesale and at fisheries? however, a few select retail samples will he taken. Four, our major emphasis will be sanpling of fish originating in Wisconsin, hut we do intend to randomly sleet samples of fish originating outside of the state. Five, in fulfilling this responsibility of keeping cwr food supply safe, the department will continue to work jointly with the Food and Drug Jdmlnistrati.cn and the Department of Natural. Resources in preventing duplication of effort and meeting fish industry problems in supplying a wholesome food to tha public. In carrying cut this program, early this spring we did sample and have analyzed in our laboratory samples fran two lots of carp in the Green Bay area. These sanples were found to oontain 8.9 and 33.4 parts per million of BCB's. Hie two lots amounting to 975 pounds of carp, were placed under holding order under authority of Chapter 97 and disposed of as being adulterated food. just recently we were requested and did obtain five samples of carp that were in a holding pend in the Green Bay area to be sold for food. All five of these sanples were found to contain more than five parts per mlllicn of PCB's, varying from a low of 13.1 parts per millien to a high of 57.5 parts per million. The fish in the pend, ameunting to 12,500 pounds, had been placed under a holding order and are not to be sold oamerclally as food. The owner is presently attempting to find a disposition fee these fish. All of the carp involved in these two actions were cbtained frem the Green Bay area. ' He have cooperated with the Department of Natural Resources in sampling and analyzing individual fish fran lake Pepin and other areas of the state. This project has been in the form of a survey and information gathering effort. He have not taken any official action on fish as part of this survey. He are hopeful that through the carbined efforts of the industries that use FCS's, the fish industry and the regulatory agencies involved, both state and federal, that we can eventually eliminate the problana concerning PCB's in fish and in foods. . I shall be happy to respond to any questim* that may be pertinent to the issue. EXAMINER: Do ym: have any copies of your statement, sir? MB. KXBSCBBKH: Fes. EXAMINER: Thank you. Does anyone wish to put questions to Mr. Xirachbeun? (No response) EXAMINER: In that case, thank you very much, sir. Is Mr.---Dr. George Bandy present? Kill you please step up, sir. '. EE. HMD?: I'm Dr. George Bandy, state health officer, administrator of the Division of Health of the Department of Health and Social Services. My presentation is to establish the relationship of the Health Department to this particular problem. Our statutory authority cones from Statute 140.05(1), which says that the Depart ment of Health and Social Services shell have general supervision throughout the state of the health and life of citizens. It shall make sanitary investigations into the causes of disease, especially epidemics, the causes of mortality and their effect on the health of localities, employ ments, conditions, habits and circumstances. And further goes on to state that the department may empower the stats health officer to act for tha department. 12 OTM005A9 NCR-FOX-0281406 WATER PCB-00044150 . In 1971, based on the federal department, or tie PEA statement of February, 1970, and a five-state meeting held in September of 1971,, we issued a warning on October 18, 1971, that tha five part per mill inn action level far PCS for market basket fish and that sports fishermen . be advised to refrain froa eating mare than one meal per veek of such fish and that pregnant wanes and children he cautioned to limit their intake to. one average size serving of such fish per veek. This was based on the available information at that time. Mr. Donald Healton of FDA, in January 30th of 1974, updated the status .concerning PCB, which he read from the Federal Register, from a--this was a presentation given at the Governor's Great Lakes Regional Interdisciplinary Festidde Council in Chicago cn January 30, 1974. Following that, Mr. Voigt of DJ called a interdepartmental meeting of Department of Apiculture, Department of Health and Social Services and DNR on May 16th and from that meeting, the public release of ft of 10th of June, 1975 and our contribution was to reiterate, based cn lack of ary additional informa tion, of the action level of five parts per. million. Ke feel that the Department has an obligation to publicize this situation, provide a warning to all citizens of tha state and very closely work with these other, departments cn any changes of information. . She Department has an additional responsibility in terms of occupational health and that is the people that work for this material, to see if wa can find ait ary evidence of epecific occupational illness in those' Employees. So date, to sty knowledge,- there has been ncne generated and we're watching as carefully as we can. . shat, six, is ny contribution. KXAMHERj . Shank you, sir. Do you have a copy of that? DR. HKOY: X don't,, but I'll write it and send it. . EXAMINER! Shank you very much. ' . Mould anybody like to ask questions of Or. Handy? . (Ho response) . EXAMINER: Okay, if there's no questions,, thank-you very much, sir. Hew, wa are heading--ve are ahead of schedule and for, that reason we can taka statements from, the audience at this time. Is Mr, Forster here? .. Sir, would you please approach the mite and mate your statement. Please identify yourself and who you represent. ' . MR. FORSTER: X am Albert K. Forster, .State Treasurer of the Xzzak Walter League of America in Wisconsin. hove been delegated on behalf of the state organization to {resent three exhibits. Number one is a current report by Franeine Zeidnan in August, 1975 issue of "Environnent Midwest" cn this problem of the PCS. And Mr. Klefnert waft ever many of the basic things he outlined on there, so I'm not going to waste too much time ch that. But this is for the record. .' ' . . Exhibit 2 deals with a resolution on toxic substances, including PCB, that was adopted at the National Convention of Xzzak Walton League in Dess Moines, Iowa cn July 9th and 13th of this year, taking a definite position cn use and application of these chemicals. X would lite to read the substance of it. Every year, thousands of new chemical substanoes are introduced to the environrent through their manufacture and use and the disposal of industrial wastes. Acimulating evidence of serious environmental and. health defects of such widely used substances as pbehoKy herbicides, polychlorinated biphenyls, fluorocarbons, heavy metals, , vinyl chloride, has intensified concern that other, .as yet unidentified ehHcieai substances may be exposing large segments of the public to grave health hazards.. . . Despite the magnitude of the risk, no oatprehenaiwe authority exists to require testing of substances before man and the environment are widely exposed to their effects. Existing regulatory mechanists which concentrate on reacting to a known hazards rather than preventing the ones, Come into play only after the envizmnental or health dotage has beat proven. Shis approach is clearly inadequate to protect the public from latent, longterm effects of exotic substances, tha delayed effects of which many nfy not -become visible until years and even decades following exposure to them. 2n the meantime, the entire earth is being used as a laboratory. 13 WTM00550 NCR-FOX-0281407 WATER PCB-00044151 Therefore, the Izaak Walton League of America, assembled at oonventicn at Dea itoines, urges a ccnprehenaive program -be established to prevent damage to human, health or enviroment from, hazardous chsaicals by one, requiring that potentially hazardous substances be thoroughly tested for safety prior to their introduction into the environment. Two, establishing the principle that manufacturers, users or dischargers of a substance suspected of being hazardous must bear the burden of proving the use of the substance as having low environmental cur health effects--adverse effects. Providing for prohibition or stringent regulation of substances feund likely to pose a significant risk to human health or environment. Then we present another resolution here fran our state meeting in Wisconsin con cerning herbicides and phencscy--all these chanicals that present a hazard, all related to base carpounds found to be very pertinent and do not break down in ecosystem. Ktereas damage fran compounds containing tetra-diesdn to animal life in producing birth nutations and other defects. Whereas, these sane cenpounds are also strongly suspected to adversely effect humans as reported, but not proved beyond doubt and that tetradirxin and one of the ingredients of herbicides is extremely poisonous and nay, under certain cixcumstaMes, produce atttiticnal tetradirsdde in fires or when exposed to heat, and, ' Whereas, airborne, these phemocy herbicides affect ell growth indiscriminately and when waterborne, is carried uncontrolled to other areas, or sinks to the beds of waters to affect that growth and. Whereas, no studies have disproved any of the above statements, and. Whereas, ocntrol in application, erven with care and strict supervision cannot curtail the application within boundaries, so that it crosses all lines established as boundaries, local, state, national, international. Therefore, Wisopnsin. Division of the Izaak Walton League in convention assembled in Stevens Point April 19th of this year, do resolve to oppose use. of any of these chemicals and to encourage use of any other oenpounds and chemicals as are compatible with the enviroment and with population and/or hanan, until such a time as these phercocy herbicides and other chemicals are proved safe to use in eocsystem. He further resolve to work actively in support of legislation to control application of phencoty herbicides end other chemicals until sure proof of safety for ecosystem is produced. EXAMINER: is that your statement, air? . MR. FORSTER: Yes, X wont to present that for your file, EXAMINER: Thank you very much. I appreciate that; Oay. Is Mr. Richard M. Manthe present? . MR. MORSE: Yes. ' EXAMINER: WfeuM you like to make a statement at this time? MR. MA1RSE: (Inaudible) ' SOMBER: (Ray. Do we have other appearance slips held that haven't been submitted yet os far as people vAo wish to make statements at this time? Is Mr. R. A. Shade present? . Do you wish to make a statement at this time, sir, or would you wish to wait? MR. SHADE: (Inaudible) EXAMINER: Cfcay. Please step to the mike and identify yourself. MR. SHADE: My name is Robert Shade, president and chairman of Shade Information System, Incorporated. We are a Wisconsin Corporation established in 1965 and alloying 250 people. We are a major concerter and supplier of carbonless business forms, a major converter ami supplier of office papers and business forms made from recycled paper, & significant sillier of post-eonmsaes office waste paper to recycling mills in Wisconsin. 14 WTM005S1 NCR-FOX-0281408 WATER PCB-00044152 In connection with itsn three, the Shade Waste Hot Progran far redeeming high quality office waste paper was started cm July 15, 1973. The Waste Hot program was the first source separation systan far recovering high quality office wastes establish'd in the United States. This unique program is being successfully carried out in businesses of all types, state and local governments, federal agencies and educational institutions. TheEPA has consulted with us, as the leader in office waste recovery,' in' developing guidelines far.mandatory source separation in federal office buildings. Both H>Aand the State of Wisconsin have established workable office waste recycling efforts in their own offices as a result of our Waste Hot program. The success of Waste Not has provided ispetus to the growth of office waste recovery and is contributing to the solution of the problem of solid waste disposal as well as resource aid energy conservation. ' '. A statement of cur corporate policy regarlng KB' s may be' in order at this time. First, we believe PCB's at certain levels are delximental to society or to the ecosystem. Secondly, we believe additional PCS' s should not be introduced as an additive to aziy product or eystm, as of now, unless alternatives, would be sore detrimental to society, and only then if nchpollutirg disposal could be guaranteed. - Three, we believe controls should be established to guarantee that PCB's are not unknowingly reported into this country. Those knowingly isperted' should be subjected to the same sale and use prohibition we apply to the domestic pebduMrs. Pour, we, believe that a great deal more needs to be known about the various varieties of PCB's. their sources, measurement, safe level, removal and disposal before any meaningful action can be taken. Five, We believe that pre-existing PCB's should be reduced: to a safe level an a national basis as soon as it is technically to do so. . Six, we believe that it wuld be premature to rule that KLsoensin cities and industries meet unattainable levels of PCB's in their water discharge because: (A) He do not know how much . pre-existing ECB is already in the air, land and water of the state. (B) We do not kna* how, where or by what means additional pre-existing. PBt's---PCB's, are being introduced into the air, land and water of the state. (C) We do not know how to officially remove and dispose of pre-existing PCB's. (D) He do hot knew.hew to effectively and continually monitor the level of the pre-existing PCB's in a water stream at the levels proposed.- Xh effect, the proposed rule asks.Wisconsin cities and industries to solve a problem by unknown means to arrive at an iiiaxplete solution that the results of which will be measured by unkown ihstruaents. ' Seven, vs believe that ismediate funding by both the public anl private sector is necessary to determine the source, measurement, safe levels, removal and disposal of pre-existing PCB's so that effective controls may be instituted at the earliest possible date. Oir. concern: He are concerned that a premature ruling might cause Wisconsin paper mills that use waste paper aa part of their fiber supply to reject all office waste paper because of the possibilities that such, waste might contain fCRpaper produced before April 21, 1971. It is then our understanding that PCB's were used in the NCR piper senufactured prior to . April 21, 1971 and those PCB's have been identified as a source of contamination. He furtter understand that no PCB's have been used in NCR paper manufactured since that date. - it is-cur-contention that as of this writing very little NCR paper produced prior to April 21, 1971 is getting into.the office waste stream. It is further cur contention that such NCR paper will constitute a continual ly mailer part ed future office waste. . . Ha submit the following information without proof because no proof is available. These are the beat estimates of individuals in our ccmpery and other .sources considered to be qualified in the art. First, we estimate that multiple copy business farms represented less than 50 percent of total office paper by weight. This means that for 100 poinds of office papers, approximately 50 pounds would he multiple part business forms. Secondly, industry figures shew that for the years prior to 1972 carbonless paper represented less than 15 percent of the multiple part business forms market by weight.. This means that only seven and a half pounds of the 50 pounds of multiple part business forms woiild have been NCR paper. Three, NCR paper contains three types of paper. First ply is always a ocated beck sheet, called a CB. The last ply is a coated feent'sheet called a CF. Tim internal piles are coated front and back and are called CFB's. Gnly tha CB portion of the paper con tained PCB's. Industry figures show that the average nwltiple part business form is an original and two copies. Therefore, the average form made feeit NCR would contain one CB, one <5B and one CF. Shis means that of the seven and a half pounds of NCR paper, five pounds might contain PCB's. as FM0DSS.2 N G R-FOX-0281409 WATER PCB-00044153 Fran the above, it is apparent that in the yeas prior to 1371, ICR paper containing PCB's could not have accounted for mere than five percent of office papers. Tl question then becomes hew jsnch of the office papers used in the time when ICR paper was--still contained PCB's is presently in office archival files, because such files are virtually the only source of 1X3% paper containing PCB's. We estimate that all PCS containing ICR paper has been oorvert--rhad been converted to ferns and used by.the end user by the end of 1972, 20 months after 1X3? ceased using PCB's. If v assume that archival files for 1972 had 5 percent PCB containing NCR paper and files for 1973 and thereafter had no such paper, we must attempt to determine when archival files far 1972 and before will be destroyed. File retention and destruction programs vary by industry and by application, but let us assvtne that most files are destroyed in three years. Oils means that 1972 files will be destroyed in 1976 and 1973 files will be destroyed in 1977, although sere files, for example real estate records, are supposed to be--are supposed to be retained in perpetuity. It should also be pointed out that many records are converted to magnetic computer tape and microfilm and the source accusants are destroyed in the year used. We believe that such file destruction programs account for less than 10 percent of the total office waste stream. Therefore, if we assume that NCR paper represented five percent of the 1972 files which will be destroyed in 1976 and file destruction represents only 10 percent of the office waste stream, we will arrive at the estimation that one-half of one percent of the office waste stream- in 1976 will be NCR paper containing PCB's. In 1977 and thereafter, the amount of old NCR paper being released to tte environ ment will go doa dramatically because most archival files for 1972 and before will already have been destroyed. There is no questicn, however, that none old NCR paper containing PCB's will be present in government and industry files for years to oane. We further estimate that only 10 percent of office waste is presently recycled. This means that in 1976, 90 percent of the office waste stream will go to solid waste disposal and it will contain one-half of one parpenr.-ram. hi f of one percent old 1X3? paper, had . 10 percent of the office waste stream will, be recycled and it will contain one-half of one percent of old NCR.paper. In both instances, the PCB's are being released to the environment. To identify and remove this old NCR paper is no easy task. Unfortunately, there is no practical means of distinguishing between old NCR paper which contained PCB's and new NCR paper, which does not. . Our experience in operating an office waste program suggests that even a massive educational program aimed at the elimination of PCB containing papers could not- absolutely guarantee the elimination of such papers from our recycling stream, Sven if such an educational program could succeed in isolating this old NCR paper from our recycling stream, it would not solve the problem because such paper would either be recycled by mills in other states or dis posed of by solid waste disposal'systems which do not eliminate PCB's fran the emdzonrent. in other wards, we could cmly succeed- - we would only succeed in eliminating this old NCR paper from Wisconsin recycling mills and we would not have guaranteed that it would be disposed of properly.. That which is not recycled will indeed find its way into the environment via rain, air movement or water flow. We cannot and the recycling industry cannot, provide the total solution to the overall problem of PCB's in Wisconsin envirorment fran either, one, the continuing source of new PCB's which are not related to the paper industry car two, fraa the many, and diverse sources by which pre----pre-existing PCB's are entering our waterways. The real answer is to provide the means by which PCB's can be effectively isolated and removed from the envirwment; This means does not now exist. At best we can only begin to alter the existing impact to one identifiable segment of the problem- which means shifting that inpact to other areas of the problem. It is only through irradiate public and private funding, we believe, and an ongoing dialogue between business and government that the information and technology can be developed to evaluate the overall problem and arrive at a meaningful solution. Thank you. E5fflMHERi Thank you, Mr.--do you have a copy of that statement? MR. SHRBE: SteS, sir. S38MB3ER: Thank you. . . Qcay, New X da haw a couple of gentians scheduled fas this afternoon who contacted me, but X believe they're here this morning and it's going to bs up to them as bo whether they wish, to speak at this time. '' 16 WTM00S53 N C R-FOX-0281410 WATER PCB-00044154 Is Mr. Boward Ness present? . MR. NESS: Ye*. EfflKfflER: Wbuld you like to speak new, sir? Please step tip to the mierophoM and Identify yourself. MR. NESS: fy nsrae is Board Hess. X at representing the National Association of Recycling Industries, Zac., whose offices axe located at 330 Madison Avenue, New York, New York, By toy of introduction, I would like to describe cur association, NARX, and the industry it represents. NARI is new in its 63rd year. It is the leading and nost oenprehensive trade association in the recycling industry. It speaks for acre than 700- marier caipanie3 located throughout, the United States, all of which share one ccccson economic. purpose, the recycling of solid waste materials into new raw material and products. Our matters are the recyelers of all types of metals, paper, textiles, rubber, plastics and other waste materials. In.the paper- industry, far exzctple, NARI's mastership includes all segments of paper.recycling. Sane of cur matters Collect waste paper firm various sources. Others sort, grade and process waste paper into' new, raw materials for sale to paper manufacturers. Our membership includes those--these consumers of recycled materials, the paper mills, and the exporters of taste-paper. Similarly, in metals, our metrbera include :firms which collect scrap metals from solid waste, fins which recover, .process, refine and convert scrap metals into new raw materials and finally, manufactures who purchase these recycled metals for utilization in products for domestic ccnsunption and expert. Bte recycling industry now pcccesses over three million tens of nenferrous metals, 13 million tons of taste paper aid millions, of pounds of textiles and other materials annually. Kith the chairman's permission, we would like to include as part -of pur presentation for the . * record, the contents of a panphlet entitled' "Recycling Resources: A Guide to Effective Solid Waste utilization". Most of the material contained on this booklet cn recycling is the result of considerable research by cur association in recent years, including data compiled as a research project authorized, conducted far, and approved by the United States .Environmental Protection Agency. In addition, we would like to include; fer the record the:following psrphlets that show the importance of recycling: "Energy in. Solid Wastes: A Citizen Guide to Saving", published by Citizens'. Advisory Committee on Emdromental Quality. Second Book "What You Can Do To Recycle More Paper", publication number SW-143 and "Khat You As A Consumer Can Do Tb Kelp Encourage the Recycling of Waste Material% publication.nurber SW-117-1, She latter two are published by the United States Environmental Protection Agency. . We believe, and every authcritive agency of the Federal Government concurs, that expanding---that expanded recycling is the most constructive step that can be taken to assure our nation the raw material supplies required for future eoonmic growth. In the face of the rapidly depleted natural resources and at significantly lower energy requirements that are needed when raw materials are used-^-when virgin raw materials are used. . The 13 miHicri tons of taste paper currently recycled each year represents 20- percent of toe nation's total raw materials need for paper fiber. It also represents the conservation of 200 million trees'each year that can either be left in place or used for other purposes. The EPA's "Report to Congress cn Resource Recovery", dated February, 1973, indicates that the use of waste paper in the paper making processes replaces limited wood pulp supplies -^ and represents energy savings of 60 to 70 percent. - Currently, only about 13 million tons cut of an annual paper production of over 60 million tons are recycled. But 35 million tons .of additional waste paper are recovered for raw material use. The doubling of our current recycling volume from 13 million tens to 26. million tons a year, a rate close to our world War XI paper recycling level, would result in industrial energy savings of 55 hilltop kilowatt hours 'of energy or 32.5 million barrels of oil a year. Further, since paper comprises almost half of the nation's collected solid waste, it represents another important energy source' after recyclable materials have been extracted for mw raw material uses. ERA states that about 80 percent of this aqnrecydable residue is ecca- Jaistibls atol can be recovered in. the farm of energy. ' .' . Of course, recycling also decreases landfill, requirenents. Each ton of material removed froa the minicipal waste stream leaves such needed space far taaaxrtw's landfill needs. According to. a repent study by the National League of Cities .and the United States Conference of Mayers entitled Cities and the Nation's Disposal Crisis, and X am quoting ftem that publication: "Kith almost half of our cities running cut of current disposal capacity, in froa one to five years, .urban America faces an inriadiata disposal crisis." We believe that effective increased recycling is truly in the bast interest of the nation and the citizens of Wisconsin. 17 WM0O554 NCR-FOX-0281411 WATER PCB-00044155 It* recycling industry oalpetes on a day-to-day basis with virgin raw material industries and, therefore, even the slightest suggestion that recycling paper is inferior to virgin product has a devastating effect on recycling. This is particularly important new that tte re cycling industty is being urged by the federal government and the Ancrican public to expand solid waste utilization both in traditional and new product areas. ' . Three years ago, when it was first, determined that seme recycled paper board contained.KB's, it vas traced to the presence of PCB's in the manufacture of carbonless carton paper produced by the national Cash Register Canpany, NCR. At that point in time, regulations were passed by the SEA to limit the KB levels. unfortunately, the KB regulations were misinterpreted hy many as conclusive findings that recycled paper was harmful to health and was therefore inferior to virgin paper. The evidence of the devastating effect of these regula tions were as follows: When the proposed regulations were issued, many consumers of recycled paper immediately cancelled their orders after seeing scare headlines in newspapers which in sane cases real "recycled paper bills". Shortly after the regulations were issued, legislation was introduced in the New Jersey General Assembly which would provide criminal penalties of up to $50,000 for the manufacture, sale or distribution of any food packaging material made frem ' recycled paper. Clearly, toe Food and Drug Administration did not mean or seek to focus only on recycled paper. It indicated that even sane virgin paper products pertained KB's and that there were many other sources of KB's, such as heat transfer fluids, hydraulic oils, lubricants, transformers and capacitors. Nor did the FDA mean or seek to produce such fear amongst the consumer of recycled materials, nor frustrate the purposes of the resource recovery act. In all fairness to this industry, which contains seme 4,000 mill workers and nany thousand more employees at the sipplier and consider level, we. simply cust set the record straight and prevent such damage frem spreading in the future. According to the FDA and industry data, we understand further that PCS levels in ` paper are continuing to drop as the production of NCR carbonless paper has been discontinued. Indeed, we have been infexmed that most paperboard new contains less than three parts per million, well within the FDA regulation of 10 parts per million. Die recycling industry is making every effort to seek out the contaminants, the NCR carbonless carbon paper made with KB's and not use them where they would be detrimental to the health of the public. During toe last two years, the recycling paper industry has seen the KB level in recycled paper drop to less than five percent of its initial estimate and the industry is still diligently working to lower this level. - We strongly urge your agency to use your full authority to eliminate KB's at the source. Ideally, it would be best if your agency had the statutory authority to direct a cenpary, corporation or government agency to withheld all existing stocks of KB and PCS containing material. But at the very least, we urge you to seek, on a voluntary basis, the removal of all existing stocks of such products wherever they may be found. KB's are not reslily discernable. They may km buried on the shelves of many of your cun offices or in the many of the hundreds of manufacturers' warehouses in the font of electrical equipment and miscellaneous fluids. Surely, these industries and agencies should cooperate in such a national peeblera, especially when such cooperation is toe nest effective and perhaps the only way to rapidly reduce kb levels in all products.' Finally, existing stocks of KB's and carbonless carton paper must be withheld fran use and, if feasible, destroyed. We hope that your agency will initats immediate discussions with those corporation and gwemneat agencies who stock such material, toward that end. The recycling industry will do its share in cooperating to remove the KB's frem the envixeanent. But to saddle the recycling industry with the full burden of raneval, when it is not even the cause of toe problem is completely unfair and discriminatory and not responsive to the total KB problem, most of which is caused by industrial companies outside the recycling industry. ' ' The recycling industry strongly supports toe Department cf Natural Resources in its effort to eliminate the KB's frm the environment. However, the imposition of the zero discharge rate at this time is unrealistic, unnecessary to achieve the objective and will have a devastating effect. . . - The proposed regulations will destroy toe present recycling programs for office waste paper. This program has taken years to stimulate and pufcin motion It is a meaningful progress since it effectively recycles the high-grade paper that is always in short supply. Wisconsin has made excellent progress in all of its recycling programs. It its one of the leading recycling states of cur nation, having demonstrated this by its excellent reeyeling legislation that was recently passed. Tb now pass new regulations that will, in effect, stifle existing recycling programs, would be a mistake. 18 WTM00555 NCR-FOX-0281412 WATER PCB-00044156 It will erroneously inply a danger and inferiority relating to recycled paper products. Compcehensive federal and private testing programs over many year's period hays fully and unquestionably proven the quality and reliability of recycled paper products and thair nonhawirdfd relationship to one!a health. . Other witnesses will tell you of the other detrimental effects of this proposal, including the loss of jobs, loss of industry expansion in Wisconsin and the loss of taxes to. the state and the loss of costs of products. . He strongly urge this agency hot to reoansend passage of the proposed effluent rates, but to one, reexamine and reevaluate the whole PCS problem as it concerns Wisconsin and two, to propose a realistic plan for achieving the objective without imposing a regulation crippling Wisconsin industry and seriously damaging its ongoing efforts to maximise energy savings and solid waste utilisation through recycling. ' '. Ohe recycling industry stands, ready to cooperate with the Department of Natural Resources and to support any reasonable legislation that will control the effluents and reduce the discharge of all contaminants into the state waterways. - Such realistic legislation must do more--Rust do more to eliminate the sources of PCB's, thereby practicing preventive medicine, rather then inadequately treat the syaptems of the problem after the damaging PCs'a have already infiltrated the entire economic system. Eliminate the entry of the PCB's in Wisconsin and you eliminate the source of the problem. Ihank you. EXAMINER: Shank you, sir. And ycu have a copy of that? KR. HESS: Yes, I do. , .. EXAMINER: Plus the pamphlets? . MR. HESS: Yes, right here. EXAMINER: Bunk you. How, ladies ,and gentlemen, since we are somewhat ahead of schedule and also sinoe Z want to get started.at 1:0.0 this afternoon with our next presentation, we will recess for the noon lunch recess. It may take you somewhat of a time to find a place to eat. please, if you- have not submitted appearance slips and . plan to be here this eftemocn, submit the appearance slips to me before leaving= ' .... - Off the record. (Noon recess) EXMQNER: Back on the'reoord, ladies and gentlemen, we're resuming the hearing which started this morning regarding preposed rules pertaining to cfflunA limitations of polychlorinated biphenyls to the waters of . the State of Kisoensin, My name is Jim Christenson. I'm sn attorney with the Department of Natural Resources and am the hearing examiner far today and Umorrow. the first part of the. program this afternoon will be presentations by various indi viduals at tbe'xequest and on behalf of tha Wisconsin Department of Natural Resources. la Dr. Harold. Humphrey here please? Would you please step to the frent, sir. DR. ELbffHFEJf: Ace you ready? BOHDER: yes, just please identify yourself and who you represent. DR. HKfHREE: I'm Harold ttaphrey. I'm environmental epidemiologist with the Mirftigan Department of Public Health in Lansing, Michigan. X was invited to asm here today to describe a study which I'm directing in which the Department of Public Health is conducting and the federal"~-tha Food and Dn^ Administration is supporting. And the study is an investigation of peraesaa in Michigan who consume fish. 19 WM0.055& NCR-FOX-0281413 WATER PCB-00044157 ws The presence of PCB's in lake Michigan fish actually came to light during tte 1968 hearings an EOT contamination of ccnmercially marketable fish. Guideline levels, as has been mentioned today, have been set at five parts per million fear PCB in fish. The continued presence of excessive levels in Great lakes fish has failed to show inprevenent, indicating a continuation of the overall pccbloa. Nooereus animal studies, have dsronstrated a dose-related affect for PCS ccrpouirls. They are fat soluble-, stored in adipose tissue. They are persistent and toxic effects appear to be related to the degree of chlorine content in the caspcurds. KB ingesticn, either directly ar through contaminated food has been shewn to cause, in animals again, liver damage, skin changes, disturbances in reproduction, pneumosuppression and abnormal type dispiaistic cellular growth patterns suggestive of possible neoplastic transformations. EXMEHER; Excuse me, sir. Could you speak tp. They're hot getting it out there. MR. HUMPHREX: The PCB contaminated fish species of the Great t,Itm represent a desirable spurt fishery and although the general population receives a degree of protection through IDA. regulations, seizures and etc., spcsrt fishing, which represents a population who, by choice, censuae millions of pounds of Great lake fish. Sport fishermen do. not receive this kind of protection. Thus the question does arise, what risk does oonsusption of sport fish represent to the health of this particular population group. Knowledge of the toxic effects of PCB's on humans cones principally frem an episode in Japan in 1968 and this is the new familiar Yushcw(phcnetic) disease, in which case----where ever a period of time about a thousand people ware exposed to daily---to rice oil, an oil used in their daily cocking and a variety of maladies were recorded in hunans, including things such as increased pigmentation of skin and nails, swelling of the upper eyelids, impairment to vision dueto eye discharge, nurtaess, edema of the limbs, persistent headaches, weight loss, fatigue, gastro-intestinal syiptcms, including ahdtiwna.1. pain and disturbances in liver function. I merely mention these because when I describe the study later, we were, asking people whether or not they had had such signs and syuptnis. The Xushcw incident ahaed that the effect in this Japanese occurrence was a lingering one and that was suggestive of the possibility that in hunans, there's a long biological half-life. Now, admittedly, consurption of Great lakes fish does not represent a magnitude of exposure, as shewn in the Japanese Xusbow incident. However, -the suggestion of a long biological half-life for PCB's in man, allows the assispticn that if PCB's are ingested and if such ingesticn continues, the. ccrpeund could acemulate in tissues for a long period of time by this long-term, low level exposure or through internal recirculation of the chemical as it remains in the body. Thus the habitual consumption of contaminated fish from the Great Lakes represents a hypothetical means for accumulated, perhaps a clinically significant dose of PCB's. TO date, data concerning prolonged human exposure to low levels of PCB as represented by fish ccnsutption in the United States has not been available. Likewise,- the relationship between the quantity of contaminated fish construed and the accumulation of .PCB's in hunans is unknown. Such infanraticn is necessary in order to assess the huran health significance of the present situation in Lake. Michigan. The study, entitled, "Evaluation of Changes of the level of Polychlorinated Biphenyls in Huran Tissue" vras begun in 1973 by the Michigan Department of Public Health with FDA support. And this is'the study I want to describe to you today. The field work phase was just completed this past spring and the analytical data is new being generated in our laboratory. I cannot give yen what will eventually pace cut of the study, that is, the hard and fast analytical data, but 1 will be able to tell you how we've approached this problem and what the study--protocol is. The investigation represents an atteopt to study the effect of exposure to PCB's from consuming fish, primarily sport caught fish froa the Great lakes. And again, the absence of of a decline in the levels of these materials in the lakes demonstrates the problem which was being addressed in 1973 does, indeed, still exist today as fax as fish contamination is concerned. The PCB study has catprised two major effects over the past two years. One is an epidemiological field survey and the ether an analytical laboratory program. The primary objectives far the study have been--and I've got five of them here. Nurtber one, to Identify exposing control populations in selected geographic locations where PCB levels.are known to be excessive in the fish. To select participants for the study and collect suitable bleed specimens,, using acceptable epidemiologic techniques. Three, to record the intake of the PCB levels in the fish meals actually being consumed by participants. Four, to develop a sensitive laboratory method for detecting PCB's--PCB concentrations in human blood. And fifth, to determine by laboratory analysis, the concentration of PCB's in participant blood specimens in order to evaluate the ingesticn of PCB via fish meals, the PCB levels in bleed of banana who do and vto do not eonstne .these fish, the variations of PCS levels in bleed due to 20 WTM00557 N C R-FOX-0281414 WATER PCB-00044158 the seasonal oonsurpticn. habits and lastly, to estimate ths metabolic half-life of PCB'g in the blood a hunans. She work far the study was done in four Michigan canaunities. I'm assuming everybody tere is familiar with the State of Michigan. If not, look at the back of your left land and the ccnnunities ware Traverse City, Manistee, laddingtm end South Haven. These are all ccnnunities that border on the lake Michigan shoreline of Michigan. In addition, from the previous study that we had done on mercury, we had available control- wmpl.es from Algenlte xrA also from South Haven far testing for FCB's. . The residents of the oamunities were selected for'the study on the basis of sport caught lake Michigan fish consuspticn habits and vere categorized as. either exposed fish eaters or noneater control people. In order to qualify as a."fish eater", the participant had to have consumed at least 26 pounds of fish per year and again, this would befreshly caught lake Michigan fish. This is the equivalent of a half a poundfish meal per week.: TO be a control person, preferably they ccnsuned no fish at all, but no more than six pounds per year was allowed to have a person qualify as a Control. The study involves approximately 200 parsons, so then X mention oamunities, I'm not suggesting that we surveyed entire ccnnunities in. the state,' but rather these would be statistically selected portions of the populations of -the carnalities. Persons were selected far participation on the basis of responses .to a personal, interview. The control group was selected by a randomly-picking names'fran the Folk City Directories for these catmmitiei and then visiting the households. so selected and the---upon visitation the decision was made as to whether ti person could qualify as a control. So the controls in the study were randomly selected. The exposed people were either picked up through the random selection, which is a very minor portion of the study group, but mere principally, the exposed group were identified by wood of mouth Or referral. . 1 t . ,. - Sport fishing in the Great lakes is a fairly visible hobby and it was quickly evident that various officials, friends, neighbors, family, could quickly identify people who were sport fishermen. These people were approached, identified end if they agreed they represented the exposed portion of the study. Of course, they had to consume at least 2$ pounds of sport caught fish per year in order to qualify as an exposed 'participant. A questionnaire was developed for use in the stud? and basically it dealt with trying to gain information from the people with regard to their'- - - to the members in their fnily, the amount and--a -special focus on the fish oonsurptirm that participant had, including a location of where they caught their fish, the species they ate, the frequency of sating these fish, the quantity of fish eaten-and the gradation of their preference-for species. Other information, such as occupation, major medical events and the occurrence of specific medical conditions was of ttese people also. Die specific medical conditions that were asked of the participants included a fairly long list end maty of .the kinds of sighsof syaptms that are typical of those reported from Japan fcar Yushow. ' Over the duration of the study, which la . has been a too-year study,. contact has been maintained with the participants to retain-their interest in the study and to collect blood specimens. Mow, a person who. participated in the study, if they were e control person they'd have been.randomly selected; they were interviewed onoa. It was confirmed that, indeed, they qualified to be a control. A 20 cc blood sample was obtained and. that was primarily the ryf theix :. The fish eaters ware located as I described, by ward of mouth, tracking people down, tstvtwg to pecplein cewnunity groups or neighborhood# or what not, potential fish eaters were located, identified, interviewed, a good deal of questioning went cn to confirm, indeed, that they qualified as fish eaters end these people were folly interviewed and asked to participate in a study for a prolonged period of time, which would, include multiple samplings of their- blood fear testing. - '. In addition, exposed fish eaters were asked to maintain a dietary log and reoord when and what kind of fish they ate. Again; the emphasis always being on--not. on ocnmercially purchased or restaurant bought fish, but Lake Michigan caught fish. And also they were asked -bo save portions of their fish meals so that we eventually, fraa fish eater participants, would have a dietary log of their fish consumption habits and a swpling of tha meals they had censured over the period of time that, wa were taking blood levels. Obviously, what we're attempting to do here is see if there's a dose relationship going on. B first year of the stu^y 168 participants wwre Identified, selected and interviewed in the sooner ani early fall of 1S73.. Of these, 33 were randomly selected.control people and 135 were initially categorized as fish eaters. I won't go.into the breakdown, but they ware disttiiaited ever the fete cities, with people fism Traverse City cocposing ths bulk of the 168 and approximately 20 to 30 re Manistee and Luddingten. 21 . NCR-FOX-02814 WATER PCB-i The proportion of fish eaters to controls that were included in the study was intentional. We had. fewer controls than we did fish eaters. This figure was arrived at on the advice of statisticians during the planning stage and as X mentioned earlier, we had control people from an enrlinr study of mercury in Michigan to draw cm for additional control sanples. At the end of the fishing season in 1973, blood samples were drawn fear all participants and it was intended that this sampling would provide a measure of PCB levels in these people--in the blood of these people at the end of a fish-eating season and would also provide data for future oenparisans for the next year. The following spring, spring of '74, a subset of the Traverse City group of fish eaters were sanpled prior to the resumption of the fishing, season in order to evaluate changes in PCB levels in these people during the winter layoff, again remembering where folks--folks go cut and get fish from the Great lakes and there is a definite time when you can and can't take a boat cut, at least without risk of life and lirfc. '- Another subset of participants was sanpled at--two times during ease day to provide a fasting and a nonfasting blood specimen. The point of this was to determine if, depending cn the lipid mobilisation of the body during fasting, if this also mobilised PCB levels in tie body from their stores in the adipose, thereby changing the blood levels. And the secondary purpose of this was also to determine which kind of blood sanple should be taken cn a routine basis, whether it he fasting or nenfasting. During the second year of the study, again the principal cities were Traverse City, Manistee and Imddington were revisited and approximately 100 people included in the second phase, sane of the fish eaters were from the previous year and sane new people with an aphasia cn higher fish ccnsunpticn habits, were recruited.' Hot, these people, at this time, were followed in very great detail fraa the beginning of the fishing season to the end and when X say in detail, this--I'm thinking of multiple sauries of blood during the summer, dose maintenance of their . dietary logs and records, encouragement to keep these up, reminder to save portions of their fish meal. Essentially what we were trying to do is make sure that the fish consumers were keeping as close track as possible of their actual oansimpticn of lake Michigan fish. And as X said earlier, this was--we were trying to--we will eventually atterpt to see if there's a dose relationship here that we can establish. Blood specimens were collected during the stumer to represent--several times during the simmer to represent an increase--to represent changes in TO level which might he occurring during the intake of fish. Then at the oonclusicn of the fishing season, the fish eater participants were asked to refrain fxcm eating any further fish. In other words, abstain. And once their fish eensutpticn ceased, that was the zero time, then samples were taken at 15 days, 30, 90, 120 and 180 days after they ceased eating fish. The atteapt here was to see if we could evaluate a change in the PCB level in the humans---in the blood of the banana over this time and establish a half-life for PCS in blood. That fairly wall describes the protocol of the study and alludes to the kinds of things that we are trying to find. X might just add here that the analytical testing of the blood, the collpored blood samples is done at the Michigan Department of Public Health . laboratory. A gccd deal of time and effort went into developing a suitable analytical technique, the complicating factor being the presence of COT in the blood of most people and that causes interference in the identification of PCS and secondly, the affiliation of any PCB's in the with the lipid oarpeoenta to toe bleed requiring extraction...-an extraction step. The third procedure that was finally agreed on is a fairly direct one using gas chromatography, but a number of different techniques to improve the sensitivity of detection of PCB in blood were tried and eventually rejected for the final technique that is In use. The sensitivity of this procedure is five parts per billion concentration in aid this is primarily being the peaks for Aroclor 1254 and 1260 are the standards that are used to verify the PCB's that are being measured. And the recovery of PCB from spiked sanples is running between 94 and 100 percent, so that the technique appears to be fairly accurate. Now, I would like to conclude with a couple of things that wo have cane up with just in the last couple of days with regard to seme things that we're seeing out of the study. Again, cn the twain of testa on the blood samples, X can't make any statements yet regarding that because of the fact they're not available. However, we have taken a lock at the response to the questionnaire portion--the portion ef the questionnaire regarding the health symptoms. Basically, as X g-M a nerrent ago, this was a list, sort of a laundry list of syrptots asked in the way, in the sense of I'm going to list acme health conditions. Tell me the ones you've experienced, when the conditinn, began and if you saw a doctor for it. And then you run through a list of about 18 different things. These items included things such as mating--numbness and tingling of the liabs, discharge and swelling of the eyelids, skin eruptions and problems with akin . 22 WTM00559 N C R- FOX-0281416 WATER PCB-00044160 pigmentation and tha like. This Is a mean type of list. And basically what has been seen so--bo far as that is careened, there's no difference, between the fish eaters and the central people in their responses. No statistically significant difference. BfflMINER: Does that ocnplete your statement, sir? MR. ECMEEKEY: I have one mare ccraoent to make. DCAMINER: Cfcay. . HR. HMPHREY: Cue other piece of information which is beginning to evolve is a ---the characterization of the fish ooinsuqoticn of people.. Una people classified as fish eaters or the exposed people, ws found oh the basis of looking at 75 of these, the range of fish canstnption, poundage, was from 25 pounds to 260 pounds a year is what tiny recorded they ate. She bulk of the people, 56 cut of 75, ate fish- in the 26 to 60 pound range. Thirty-five people ate fish at the rate of 26 to 55 pounds. . Basically what I'm saying here is that it appears that fish eaten? we're talking about--about a meal a week so far as.consumption rate. There were only ten people vho ate greater than 84 pounds of fish, per year and.of these, only three ware above 206 pounds of fish a year. How, at 200 pounds of fish per year, that's approximately 20 fish per month. So again, this is not fully completed yet, but it appears that even when you seek heavy fish eaters, by world standards, these are not vast ccnsurpticn quantities. And the--the other thing that characterized the fish eaters is they--although they catch the fish, they tend to distribute their catch among a family cr friends, viiich leads -to. a member of people having an occasional fish, irieal at least and the amount of fish that they ocnsvme is not consistent frem year to year. They might catch 50 pounds in one year and depending cn the waves, the weather am the ability to actually catch fish. They may only eat 20 pounds the .second year. . In conclusion, we're optimistic that this investigation will, for the first time, provide information about PCB's in haaans from the Great lakes situation. And we're optimistic that it will provide data on the amount of fish oensurptien by people in the Great lakes area. The PCB dose received frem Great lakes fish, the body levels of PCB's of both control and exposed persons, annual changes in PCB level- and half-life changes in PCS levels in fish. Bank you. ' dene. DfflMINERj Dr. Buephrey, I just have you will provide a Copy of that when you're ' MR. HUMPHREY: Yes. - '- \ EXAMINER: I just have a couple of real quick questions myself. Do I understand that the sapling, itself, the blood sapling is eaapletad? MR. HMEHREY: Yes, that's ooerect. EXAMINER: And when do ycu expect the results of the sampling to be published? MB. HUMPHREY: We're obligated by contractual arrangement with EDA to have this data ready by the first of the year or during January. EXAMINER: And would it be possible to provide the Department of Natural Resources with a copy of that study and the results? MR. BCMPHHEYs I expect it could be; yes. . EXAMINER: Ckay. Thank you very much. Kw, does anyone else have ary questions of Dr. Bxphrey? Wbuld you please step up here to the mike, sir. It is being recorded and that way we can get your statement. Please identity yourself. . MR. TTTflfM; My name is Bd Tilacn. I'm trying to find how long the study is going to be eontinued. X might have missed that. .' ' MR. HUMPHREY: The study has been going m fee two years. It started in 1973. It was--the field portion was oarpleted this past summer. It----the support---tha financial support for the study has been & contractual arxahgmnent with tha EDA so so te as that phase of it is Concerned, it is finished. Obviously the. interest in the problem remains and it--at this ament there is ho definite plan to go forward, but as generally the ease with these kinds of things, I'm s maiy intriguing questions will be raised by the results. ' 23 . WM00560 NC R-FOX-0281417 WATER PCB-00044161 EXAMHGR: Ckay. Any further questions? CNo response) SSSMDERj Ckay. Thank you very such/ Dr. amphrey. Is Dr. J. R. Allen present? Okay. Vfculd you please identify yourself and make your presentation sir? . DR. AT.TCTi: I'm Professor j. R. Allen of the Department of Pathology at the University of 'Wisconsin. I've been doing research on the polychlorinated biphenyls for a matter of years. In 1967/ even before the Japanese outbreak of polychlorinated biphenyl intoxication, we were doing research on the particular effect of the polychlorinated biphenyls on the liver, particularly on the liver enzymes. Following news of this outbreak, we modified some of our experiments to include same of the biological effects that might be experienced frtatt exposure to the PCB's. Our first procedures were to try to establish the most suitable experimental animal model. And within a relatively short period, we found that the nsnhuman primate developed the syaptems and the ' lesions E/milar to those that occurred in the Japanese outbreak of 1968. In our initial studies we were trying to determine really at what level these ocnpbunds were toxic. Early studies had 300 parts per million in the diet, produced extreme morbidity and mortality within a period of two to three months. As was the case with the Japanese, these nenhaaan primates; they were rhesus monkeys, developed a loss of hair, swelling of the face, accumulation of fluid underneath the skin, a loss of the eyelashes and a decided acne. Case that died, and all of them did eventually die, they had a severe gastritis, marked thickening of the walls cf. the stomach and ulcerations of the wells of the stomach. In our subsequent, experiments we fed another group of rhesus monkeys 100 parts " per million in their diet. - It was in a period of three weeks they began to develop the signa and the lesions that 1 had mentioned that occurred in the 300 parts per million groigp. And here again, within a period of approximately two to three months, all of the animals had expired. In our next experiments, we decreased the level of intake of these animals to approximately 25 parts per million of the polychlorinated biphenyl and I must mention here that this is the PCS Aroclore 1248 that was used in all of the experiments unless I mention another ecupound. In the 25 parts per million group, we fed animals for a period of two months, and at 25 parts per million they developed the loss of hair; they developed the loss of the eyelashes, subcutaneous edema and a decided acne within a period of approximately three weeks. By two months, it was obvious that these animals were.... they were ill and unless they were removed from the experimental diet they would have expired. He took them off of the experimental diet and one of the six experimental animals expired two months after having been removed from the diet, here again with the classical signs and lesions of PCB intoxication. He have followed these six1....the remaining five animals for a period of new approximately two years. After two years, they're still showing signs of PC3. intoxication. These animals have been bred. He have had at least six infants freet the five surviving animals. They are extremely snail and average weight of a rhesus monkey at birth is about 475 grams. These animals invariably weighed in tbe neighborhood of 350 grams. They had detectable levels of PCS's in their tissues at tbe time of birth, thus indicating a transplacental movement of this material from the mother through the placenta into the infant. As we left these infants on their mother and they nursed, there was an increasing level of PCB's in their tissues, thus indicating and substantiating the Japanese work as well as otters that there was an acarmilation of the polychlorinated biphenyl in the mother's milk aid could be given to the infant at the time of nursing. so in these experiments after, two years, we have definitely shewn that there is a rprffjet-orxT. of PCB's in the mothers and there is a continued elimination of this material via the placenta to the infants. NOW, probably the one of the more interesting experiments that we have done and this has just recently been oaqoleted, is we fed levels that were similar to and cne-half that permitted in certain foods destined far human ccnsunpticn. We fed levels of 2.5 and 5 parts per million. And you know, in certain fish products that they are allowed five parte per million, others, why--other food products certainly it may be less than this. However, to as surprise, these animals at levels of 2.5 aid 5 parts per million in their diet and they were consisting this on a continuous basis and hot as man would as he eats fish or whatever it stight.be. They're consisting this diet containing 2.5 and S parte %r 24 . HIM00561 NCR-FOX-0281418 WATER PCB-00044162 million within a period of approximately two months, these animals began to lose their hair; they to lose their eyelashes. Obey began to develop chlotoacne. Within approximately four months, they began to show irregular menstrual cycles. They had attains--^particularly the five parts per million group had attained a relatively steady state of the PCB's in their tissues at six months. We attainted to breed these animals to control males. . We----in the 2i5 parts per million ve were able , to get---well, all of the animals conceived, md this we determined by Tnaiinc (phonetic) assays. All of the animals conceived and within a relatively short period of time, they:--the five of them were able to carry their infants to tens. The three remaining animals either aborted or resorbed their fetuses. These are the 2.5 parts per .million. Six of the eight experimental enimls on the five parts per million conceived; however, only one of the animals ves able to>.carry their infant to term. 'tte remaining animals either aborted their infants or they were resoarbed. These data indicated to us. .that really there would appear to be no marked effect upon the ability of these animals to conceive, yet there appeared to be a decided effect upon their ability to carry thai-r infants to term. We have carried these, animals on this diet for over a year. They have still persist in showing signs of PCB intoxication. Ke axe presently in the prooess of evaluating the biological effects of the PCB1 a cn the infaints, particularly as it relates to their physical status and to any ;behavicral eat learning .abnormal i'ties that may arise in these infants. We axe initiating studies that are underway at the present time to mare closely simulate the intake that man may have as .he eats the fich or other foods that are exposed to the ECB's. And hopefully within the next year we will have seme data as to whether these levels will be trade. However, at the present time we have.ret established a level of PCB when rnroanwi on a'continuous basis that is ncntcodc to the nonhuaan primate. . Hopefully the levels that we will---we are feeding at te present tire will be mntcKic. This is one aspect of cur studies. He have also done extensive metabolic studies con cerned with the absorption, this tissue distribution and metabolic fate of. the polychlorinated bipteyls. This to us is.quite interesting in that in these studies we have determined that there is, particularly with the lower, chlorine isomers and 2'm sure that it's already been men tioned that the cannezcial PCB's are imposed of many isarers, that.there is an entirely different lastabolie fate of the KB's in the nonhumah primate and in the laboratory rat. The laboratory rat is able to hydrcucylate these oespbunds and excrete then quite readily. The :nonhuaan primate does ist do this nearly as readily. It has to go through an intermediate metabolite known as the arena oxide intamtedi&te. This particular1 arena oxide is capable of oarbining with tissue micro- ' molecules such as KNA, ESA and protein and may give rise to extreme deletrious effects. These . studies are.being pursued in detail in our laboratory at the present time. He do not know and. it is our concern what the lew level exposure, particularly in the renhuman primate, of-these-ccnpcunds will be--maybe not today,, but in .five years ot ten years and i-h-ig is our concern at the present time and these studies, are being carried out in labcoratory animals and also in quote,, 'the test tube", in vitro experiments. . \. BMUHER.; Thank you, air. Only cna question far nyself. What's the. Invest level of PCB foods that are being fed to the monkeys at the present time-^--the rhesus monkeys? -OR. AUKt The lowest level--the lowest level that is being fed to these monkeys at tte present time that we have ary data at all oh is 2.5 parts per million in the diet. BOHItER: Gkay. Thank you very such. Does anyone else have questions of Dr. Allen? question. Sir, would you please step up to the microphone, identify yourself, state, ycur . DR. HMEHBESf; I'm Harold Hurrpfarey. I'd like to know, have you had the Arcelor that you've been feeding, confirmed as to its purity? Are there.eay contaminants in it? - DR. AIXEJt! This we have done and this is a point of I think all of our concern. There are two that I'm aware of that may be there in these Aroclors and certain there's a recent report in nature indicating that seme of the Aroclors are contaminated with the dioxins, which are vary potent terratogens in seas of the--and the lb 50 on these and seme of experimental fmimaia is quite low. The other are the dibenzal fucans (phonetic), which are also rather toxic. So yes we have and it is, as far as I'm concerned, free of these particular contaminants. There are others, X don't know. These are the two that ve have contemned ourselves with. - 25 . WM0O562 NCR-! WATER * / BffiMINER: Thank you. Dr. Kwrphrey. Anybody else have questions of Dr. Mien? (No response) us? ' EXRMJNERs Dr. Mien, do ycu have a synopsis or a report that you could file with DR. MIEN: I'll firri it. EOMINER: Thank you very nuch. I appreciate your appearance. Ckay. The next person appearing on behalf of and at the request of the Department of Natural Resources is Mr. W. B. Papagecege. Kill, you step up here please, sir? Yen can just please identify yourself and make your presentation. MR. EARAGECRGE: I am--can everybody hear me? I am William Papagecrge. I am William Papagecrge, manager of product acceptability with Msnsanto Company, located in St. Louis, Missouri. I've been associated in varying degrees with polychlorinated hiptenyls for a little over 20 years. I have been intimately associated with than practically full-time for the past five and a half years. And during that period of time I'd just like to take this opportunity far a few moments to express three areas of Concern I have which in my opinion prevent us from really identifying our problem and, of course, ctioe we've identified it, take appropriate action to cope with it. The one that oanes to mind immediately is this tendency on many of us to use the acronym PCS to describe really over 200 different ctendcals, maty of which have different properties, both cbanical and physical. Samples of that would be the rate at which these materials would , degrade if exposed to similar conditions, There is a demonstrated difference.' It's my ' considered opinion that if we could just turn the clock back and only use let's say 1221, a 1232 and even a 1242 and no others, we. probably wouldn't be sitting in this roam today. I just den't think a problem would have developed. ' Another area that we might want to consider briefly, tte presence of PCB's has been reported and they are described as being ubiquitous, they are found in places that have challenged us to try to explain just why and hew would they, get there. There axe, of course, as you knew, ' many reports in the scientific literature relating to PCB's. The last ranter I'd heard quoted were there were at least 1,500 known. Most of the reports' that I personally have seen address themselves to reporting presence of PCB's in the environment. And invariably, those of ycu that follow the literature will note these are described as being equivalent to Aroclor 1254 or 1260. Now, sene of the earlier work--this goes back to 1970, 1971, there were a few investigators that identified say an Aroclcr 1248 occasionally or a 1242 and there was even a few that had a 1232 identified. But as time goes on and the present time', more and mere of these reports reflect what appears to be an Aroclcr 1254. This ought to be telling us something. . The effect* on the environment----we still need an awful lot of informatics: to tell, us a lot mere about the fate and effect of these PCB's on the environment. There have been sane speculated reports that' try to tie in the presence of PCB's to sane observed effect. Mary of these early reports have been discounted since then. 1 have in mind, for example, the reference to the demise of the brown pelican off southern California because the egg shells just couldn't support the weight of the hen and the eggs weren't hatching. That was disproved by the laboratory located in Laurel, Maryland, by Dr. Robert Eeath. There was a report in 1970 regarding the sea birds and seals in the north, sea. That was discounted later by the ministry in the United Kingdom. There was no relationship established because they found that apparently healthy animals of the same species had higher levels of FCB in them than those that had met their demise. . Hell, the only reason I mention those is to point out that we still lack a lot of information. Evidence that animals are affected cr creatures are affected by levels of PCB's have generally, have to ay knowledge--to ny knowledge have cane, from laboratory studies. And in those instances the levels used appear to me to be higher than those found in the true, natural environments and then I personally find it very difficult to translate the pristine conditions I have personally observed in a a laboratory With such situations as you might find out in the real world. And with ccnplex materials like PCB's I personally wonder about this jtaping into conclusions that we find ourselves doing. Another area, and 1 think this is most important, is our ability to sample and analyze and get reproducible results within a laboratory and ism laboratory to laboratory, Wa 26 WTM005S3 NCR-FOX-0281420 WATER PCB-00044164 have found within our own canary between two laboratories, we find as much as piTM or mirnw 50 percent variation. There is sane dispute about ability of laboratories to cane up with the sane answer, far the sane sample. Under the auspices of the ASTK, there's a study raw uiderway, a round robin, in which 12 laboratories representing industry, government, both Raradiim aid U.S. and gjiniercial laboratories and academic laboratories , to participate in a rourd robin and we are looking forward to see diat the results will tell us. So mud) for that. 1 was asked really to talk about past.tues, current uses aid amounts produced aid.sold in the United States. The past uses, as most of you peehebly know . by new, were many aid varied. They seem to really be a function of the economy, aid its growth and a function of advancing technology. The initial uses were primarily, of course, the dilectrie uses in transformers aid capacitors. During world War II there was such developiental work going cn so shortly after World War II these materials found themselves, in uses such as special paints, inks, sealants, caulking materials, plasticizer for thei then new synthetic rubbers, An attenpfc was made to use sate of them in floor tiles to make then fire resistant. These kinds of uses. They go cn aid on. Virtually anything you can imagine, at one time or other, someone tried FCB's in them. ' . ' . ' The big inputs came through about three specific areas. Following a serious fire in one of the automobile txanasissien plants in Michigan. The change, ftan mineral oils to fire resistant hydraulic fluids took place, kid KB's played a big role in that, industrial hydraulic fluids. MOt your automobile hydraulic fluid, not the .airline hydraulic fluid, but industrial types. Generally where there's hot molten metal and high pressure hoses and they do leak and the intent is to keep fires to a minimum. Another big use that developed was the need for fluids that could withstand high temperatures to be used in heat transfer systems. As our technology evolved, the need far higher aid higher temperatures came about and this offered an opportunity to, use high temperatures and not have to resort to high pressures, which in many areas require licensed operators and safety devices of all sorts. . A third big use that came about in the early '60's was the application of the carbonless copy paper that we all know about. So each of these represent* a sharp rise in use aid as sort of a gradual increase following the growth of our eocnsny. In 1970--early 1970, Monsanto.decided to withdraw fraa these uses which in our opinion represented almost a total aid quick release into the environment. So we withdrew from all of these sealants, caulkings, paints, varnishes, lacquers, plasticizer for synthetic rubbers, matings for fabrics, all of the uses that'as X said earlier, in essence amounted to full and easy release into the environment, either through poor incineration or disposal in sewage systans or open garbage dorps aid the like. This occurred--then this went into effect in August of 1970. The next material1 that we removed' from use car the next application was its application in the carbonless copy paper and this started to phase out in late 1970 and tlwi last.truckload was delivered as 1 recall about April, 1971. And during that period it was a decreasing amount into that prooess. ... .... - . . Finally, in.1972 we withdrew fin the heat transfer application because we had learned from experience that although these could he sealed tight systems, it turns out that we couldn't rely, cn this, and so we withdrew from the marketplace, forcing our ecc-customers to : geek alternative fluids aid I'm told to this -day they have not found any. Me have not found ' any that are fire resistant. So they had to redesign their systems, introduce fire walls, sprinkler systems, fire detection devices aid pay increased insurance premiums. So today aid as of 1972 wa sell only to the dielectric applications, such as the transforners and capacitors we've all.htord of. Aid this is dene under certain legal require ments from our customers. They don't like this aid X can appreciate why, but they're asked to sign a docupent in which they assize full possession and ownership of the material as soon as ' it leaves our plant gate and they maintain, control cn it from then on Cuto In conjunction with this withdrawal fran the marketplace, we also found that we had to build exarsalves an incinerator to dispose of the liquid wastes because we kept telling our customer? don't dispose of it improperly and they always cams bade, well, if we can't do it the old way, what;do we do with it? . So we designed a liquid incinerating unit and we offer that service to a custaner for a fee. There are, of course, since then cannercial units also available operatod fcy people in the business Of disposal. .- The production aid sales data; I have here, a chart that I'll leave with the examiner aid there are a few copies for those of you are interested. This Inforaation is the best we could put together froa our existing records. It takes us back to 1957, gives us the full year for 1974 aid a the last page is the first quarter of this year. The peak year was 1970, when we produced 85 million pounds and there's a breakdown there by use category aid at the bottom of the page fcy taoelore type .that you aright tSnd interesting. ' 27 UTM00564 NCR-FOX-Q281421 WATER PCB-00044165 Currently we ere producing at about the 40 million pound per year rate. We have shut down one unit that used to be located in Alabama and disposed of that unit. The production is oomentrated in Illinois, across the river frm St. Iouis. Those 40 million pounds go into these dielectric uses. I'm told that this year in particular, it's about---half of it goes for transformers and the ether half goes to capacitors. The ratio -varies with eccmnic conditions and the needs of the marketplace. I'd like to point out seme interesting pieces of information in this. Keep in mind the 40 million pounds used today go into sealed systsns which we believe can be controlled to a satisfactory degree, This would indicate then that the additional 40 million, in essence, got out into the envirennent within the year. Once ycu reach seme sort of equilibrium, amount put in equals arrant that's escaped. So 40 million pounds per year are no longer entering the envirennent in this country. I am not trying to speak for the rest of the world. I like to think that sanething canparable is happening in Europe and in Japan, of oourse. Another interesting bit of information, through the years *b have tried, knowing that the higher the chlorine level, the mere persistent the material, to shift downward in the chlorine scale and trying not to sacrifice dielectric properties or fire resistance. So we've eliminated the use of, for example, Aroclcr 1260 in transformers. And our customers agreed to go with the use of 1254. We have gotten away froa the use of Aroclcr 1242 and introduced a distilled version of Aroclcr 1242, which ve refer to Arcelor 1016. This Arcelor 1016 contains one percent or less of the five chlorine and higher isoners. The old 1242 used to contain about ten percent. Now, we're not sitting fere saying that this is the panacea or the curea.ll. All we've saying is that we believe that this is a step in the right direction. Should any of this material, get away from us, and it can happen, the chances of it being handled by the environment are that much better than they would have been with the higher chlorine isomers present. We have been criticised in a, way when people look at these numbers to say that the rationale follows this logic. Aroclcr 1254 is the type found in the environment. Monsanto says that they have reduced the open uses and yet their report stows they make as such Aroclcr 1254 as they used to in the past, therefore the pebblm continues. The fallacy in that type of thinking is that they do not take into account that 1254 used today is in a steel box into which --you can only get into it with a tool, a wrench, for exanple, to open up a pipe plug or what have you. In the past much of that 1254 ended 19 in adhesives and inks and caulking materials, varnishes, traffic paints and so an. So there is a decided difference in the type of application and its exposure to the envirennent. Another change, of. course, is the 1254 that is now substituted for the old 1260. So the amount of 1254 remains sanewhat the same, but it's certainly in a different application. I do not have a prepared statsrent, Mr. Examiner, but I do have the table and I also have a statement that describes cur marketing polity which is available--anybody which I have paraphrased as 1 spoke. very nudu BOMIUEH: Ckay. Fine. I'd like a copy of each if X could, please. Thank you - Is that the end of your statanent today? MR. EAPAGEEBGEt Yes, sir. BOKD9ER: Ckay. Dees aiycne have questions of Mr. Papageorge? Please Identify yourself. MS. VE3MEK: I'm Linda Weimar with the University Sea Grant Program. X worrier, can you tell me, are any foreign catpany selling FCB's in this country and if so, about tow much of the PCS'a consizned are ocniing from that source? MR. PAPAGECKGEs I can tell you what I've been told by the Office of TtecLc Substances at ESA. Mow, there are representatives of that grot$> in the audience. ESffJSNHU They're casing tanerrew. 1. HffAGBCSGEs They'll be here tomorrow? I can enly give you second-hand informatim. AH 1 know is there's sons cosing in and that's been reported by B?A. And if they can't halp you, I'd be happy to--whatever the examiner desires. Nhafc is appropriate. 28 WTM00565 N C R-FOX-0281422 WATER PCB-00044166 SXHOXSR: If you wish to give a paraphrase of what year understanding is, fine. We can verify that tomorrow with HA. ' ' MR. PftRSGBCPGS: All right. I am told that in 1974, I'll try to recall: tl* lumbers as best Z can, about 40,000 pounds of a material that has 42 percent chlorine was recorded as entering this county and about 350,000 pounds of a.chlorinated turf fennel (phonetic), this is . a three benzine ring group, which, has. about 60 percent' chlorine was recorded as having entered this country. And if that turf fennel is anything like the material Monsanto produced when we were making it.... we no longer make1 it, Z would suspect--I would not be surprised that it contains up to about 10 percent of biphenyl in it and which would, get chlorinated. . Does that help? EXAMINER! Would you please step- up the srtaeptena. ' MR. T3XSCN: My name la Tiinon. Bd Tilsen here. Z was in the--Z was speaking with somebody in the electrical industry and he said that the name under which your product is marketed is Paranol; is that true? MR. PAPASaOAGE: jPyranol is a trademark of the General Electric Corporation and we blend a material and package it for the General Electric Company. . MR. THSCN: Well, given that---what I'm trying to bring out here is that that might: scundbetter, for instance, to make a reference to.a paraffin carpcund, which this is not, as opposed to a benzine derivative, a dibenzine derivative which it is, which might alert people . to the todcify of it. However, ny question here isvhcw do you avoid troubles with trademark--tradonark restrictions given that Pyranol is apparently a registered trademark of Abbott laboratories far pararemihcghendl. MR. PAPAGECRGSs Sir, Z'm hot aware that that's true.. All Z know is Pyranol, R-y-r-a-n-o-1 is aregistarad trademark of the General Electric Cenpasy. ' MR. TZLSCN: Ckay. That explains it because this is P-a-r-e-n-o-1. It's p-a instead of p-y. . MR. BARRfflOHQSs Z'm sorry. That's right. P-y is the GE txadaoark. . EXAMMERt Ary other questions? Step up to the microphone please and identify yourself. MR. HREMERs. Z'm brl Bremer, U. s. EPA, Chicago. X have a couple questions. Mow, you indicated that you have an incinerator system v&ere easterners say send beck liquid wastes; is that right? MR. PAPAGECBGE: That is correct. MR. BteyERs What do they do with their rags and their solids and so forth, this type of thing? I've encountered this on a couple of inspections where we have customers that, will --they'll have.liquid waste end they say "Wall, yes. We can send that back to Monsanto." But during our rebuilding process and so forth, we have rags and other things that; are contaminated with the product. VSiat do we do with that? And we tell them, well, we'll ask ycu. that do they do with it? ' ' . '. MR.. PA2AGECRCE: All right. That's a good question, a difficult question to answer because facilities far the proper incineration of solid material, are not to ny knowledge available today on a eomercial basis. There are a few snail omits where you can take a drum of material, sort of a muffle furnace and seal the door and let it evaporate or vaporize, for a 24-hour period and destroy them in that fashion. But there is, to ay knowledge, no oemaarcial incinerator that will handle solid material that requires high temperature incineration. Therefore, lacking that resource, we.have to reluctantly suggest, because, we don't have a better answer, that they find a wen operated, properly operated dry landfill and dispose of the material in that fashion. And that's the best we can do today. MR. SHEMERi would you clarify something for me on your Areolar 1016 and 1254. 1 saw a. publication that ms, oh, X guess in press or in progress and I notice some graphs and so forth in there and it indicated that you do have soma degradation of 1254. And on looking at that data it seemed that 1016 ms somewhat the sans; is that true 'in terms of degradation? . 29 ' WTM00566 NCR-FOX-0281423 WATER PCB-00044167 Jt HR. PAPAGBCRGE: No, there is a closer resentolance to 101$ to 1242. I don't bw which report you have in mind, but 1254 from the reports I'm familiar, does show an observable difference. Thera is hot that ouch similarity. Do you have a bacteria study in mind or an animal residue study? MR. BRHffiR: No, it was just one of your in-house reports and maybe someone craild clarify that for me later, but it seemed that when X looted at the graphs in there, that the 1254 and 101$ were quite similar in terms of that degradation and this is why I expected that possibly in terms of persistence of 1254 in the enviroment that, because of your production figures and so forth, in terms of 101$ that we might expect somewhat of the same problem or a similar problsu with 101$. It's a concern of ours. MR. PWASBCEGE: x'd be very surprised--in fact, it isn't a rational oonelusion, knowing what we knew about the isomers present in 101$ and the isomers present in 1254. X think the chemist wall tell you that there is--that's an easy difference to detect cm the gas chromatograph chart. There is a definite difference in the two. And the 1016 is more closely --more closely resembles the fingerprint of 1242 and not 1254, so in degradation natters you will more likely find 1016 behaving sere like 42. X'd like to discuss that with you at your convenience. MR. BREMER: Yes. New, those experiments that we're talking about here and sane of the in-house studies you're done have been done in the laboratory and you indicate there is that degradation. Khy don't we see this sort of thing in a sewage treatment plant? MR. EAPAGBCB35: Well, I don't bw why you don't. We do. The village-----the village treatment plant, at Sauget, Illinois shows a definite distinct drop from the input that we put into it that the total stream that the village system gets, measures, X forget, something, like say 10 parts per billion, just to pick a number of KS's. The outfall is a definite ` reduction. So something is happening and of course we look at the sludge. Tte sludge plus outfall still is less then input. In as big a system as that, it's difficult to make a good material balance, hut there's sane indication that something does take place. MR. BREMER; Well, what do we do with these contaminated sludges then? Co you have any recomendatirms far that? Contaminated sludges and- sediments and the old sediments that we have there that are contaminated. Do we send those to a landfill or-- MR. PAPKB3RGE: That's--as X said earlier, lacking anything better, a landfill. X personally would like to see the day semeday when this country has a network of incinerators that we can all use. But I'm afraid that's in the distant future. MR. BHS4ER: X have one other question on shipment. When your Aroclors are shipped, far exarole, to GE or another appropriate caipany, are they shipped by tanker route or are they in barrels or hew do they receive them? MR. RXPA3EDRGE: There*8 two modes of shipment--I'm sorry, three nodes. Most of the volute moves by tank car on railroads'. The aeccod highest volume move is in steel drums of a special heavy duty steel because this material is, of course, heavier than normal oils that we run across in trade. The third node is by tank truck. That is a very email portion of the total. MR. BREMER; Co you have any idea on these modes of transparation? For exanple, by tank car or tank truck, how these are flushed or is the sane tanker maintained far Arcelor? Is it ever used anywhere else? MR. BW?AGECH3S: These vehicles, whether they be rail cr motor, are dedicated to that service. Cleanout is very seldom required. If there is ail accidental contamination, we clean than in cur own plant through cur own control system and it becomes part of our plant effluent, so we're very, very careful. MR. BREMER: So that they cannot flush those at any other point in route then? MR. BAPACEOECE: Well, they should not and they're told not to and X have no evidence to indicate that they have tried to clean them en route. 1. BRS4SU ------ steel drums fear transport are returned to you or------ 6, HgaSBOasiBt The <ly time m ssa the return daw is when return scrap material earns back to us. MR. BREMER: to do receive scrap material than? 30 WTM00567 NCR-FOX-0281424 WATER PCB-00044168 MR. FAPAGECRGE: . Ves. MR. BREMER; Hot just liquid. MR. PAPAGEGRCE: Wedi, I scant scrap liquid. MR. BTEME3?: Liquid? * MR. RAEAGBORGB; Right. Ho solid. I can't handle solid. ' MR. BREMER; That's about all I have. Thanlc you. EXAMINES: Thank you, sir. . . Are there any other questions at this time? Please identify yourself, sir. . MR. FORSTER: A. X. Forster, Madison, X2aak Kaltcn League. What amount of time and energy is devoted to medical research on tte part of Monsanto so that the iconsuaer will get relief when he eats fish that has over 5 join's of PCS and he doesn't have to limit himself to once a week or once a month? How can you overca* that? And has anything been done along medical lines--after all, we. eensvxners, we want to knew whether we could live after consuming fish or any food products that have an excessive amount of PCB. How can we overcome that? MR. RAPAGEORGE: X appreciate your concern. I'm a eemsuner also, really. And this is not to say that your remarks axe not appropriate'. Eitm the moment we' were led to believe that PCB1 s om1d be a pcoblot, this was bed; in the late 'SC's, we, through our medical department, which is responsible in Monsanto for toxicology studies and the like, visited the appropriate then-existing government agencies and remember at that tine EPA was ret in existence ard I'm that they were frustrated because they could get no guidance as to the types of studies that would lead us to better understand what these materials were doing to the envirorment aid to people. lacking any guidance, we came bade then and decided we would conduct the studies that-we have been conducting for years whenever we desire to register a chemical for feed use. Hot that we intended to. petition the material for food use, but we felt that this was the proper way to go. Therefore, we asked the Industrial Biotest laboratories, located in the outskirts of Chicago, . to conduct two-year feeding studies with dogs and rats. They conducted, X think it was 120-day leghorn chicken studies. Ttey conducted three gerwratim rpmrhv*-im etirij Wi mutogenic studies and sate aquatic studies,' fish studies; ;' . So we have done what we feel is a responsible bit of work in trying to define tte chemical as it. is normally done using animals and birds and fish. You ask what are we doing about health studies, we, of course, have always paid particular attention to cur atplcyees through the years, through the 40 years we manufactured these materials and I'm told by our medical people that there's nothing that shows up that is unique to that group of people. In the meantime,' we are new in the midst of a study in which we are going back and looking at people who have worked in that department for long periods of time. in our mult, individuals' do. move in and out of that department. The same.pecple aren't: there'year after year after year. Sane people seek different types of wark and others feel that that's the work they-wish, so they ask to work in it. So-we do have a turnover. So far that study is not ccsplete, hut there's nothing that shows in this study that is different froa the base population of people in the greater. St. Louis area. I don't knew hew else to describe our activities other than we feel this is unique fear an industrial chemical. He have dene mare than erver's been dene-far industrial ii to date. ' '. ' ' ' . MR. FOSTER: Nell, you're to be. ocemended for that. Further, what is the statistical recced of any death due to--due to overuse of PCB? MR. PAPAGECRGE: I'm not aware of any death; in spite of t*at I-- MR. FORSTER: Huaan death. MR. PARAGBQRGE:. Hasan deaths.' I'm not aware of any human deaths, in spite of the popular press articles, that have been attributed by tie knowledgeable people and this---my source .is primarily Food and Drug Administration toxicologists, that it's teen attributed--directly attribuad to FCB's. '. ' MR. FORSTER: Thank you. 31 WTM00568 NCR-FOXWATER PCB- EXAMINER: Thank year, sir. . The gentleman in bade. Please identify yourself, sir. MR. OCEHSCN: Henry Johnscn, General Motors. .The Chan Co facility in New York is listed by the Federal EPAaa a hazardous waste facility. Aren't they also licensed by tte State of Hew York to handle PCS contaminated combustibles? . MR. PAPAGEQRGE: Did everybody hear that question? Yes, they are, to ny knowledge. They are handling many PCB's; yes. DR. MITIiTOG; My name is Anton Milling and I'm just a--although I have dene sane studies with, in particular, prime dichloryl biphenyl, but I'm not presently involved in any chlorinated biphenol research. Well, you mentioned that your ecupany has dene studies cr> chlorinated biphenyls and the study was given to a biotest in Chicago; is that correct? MR. PAPAGECRGE: The studies I mentioned with Industrial Biotest were the typical animal feeding studies; is that what you had in mind in reference to? DR. MTTXiTTC: Yes, definite eynpteos and so forth; is this what they were doing? MR. PAPAGBOHE: Yes, that is right. DR. MHUN3: Okay. How does that study compare with Dr. Allen's findings, who just gave a report, I think, before ycu? Was it as severe? Were the findings as severe? MR. PAPAGEQRGE: I am Kit a toxicologist. I can report to you ny understanding of the studies at Monsanto--had conducted far it and I'll have to leave it to you to ocmpare with what you heard Dr. Allen mention. . * Our studies with the rats and dogs can be samarized in this fashion. She high levels---and the studies were conducted at 1, 10 and 100 parts per million in the daily diet of the animals for two years. And as you know, the two-year period is near the life span of the rat. Of course, a dog lives longer. In the cases where the higher chlorinated material, the Aroclar 1234, 1260, at the high level, 100 parts per million, these symptoms were noted along with ease rarer ones, but the obvious ones are the animals exposed did not gain weight as rapidly as the controls. They wee analler in their growth increase. Also, the livers of these animals were enlarged and seemed to be trying to cepe with the exposure. Now, with the chickens, it appears the reverse is true; with tte lower chlorinated, the Aroclcr 1242, seem to affect the ability of their egrg to hatch. Via noted that at one part per million the eggs were hatching. At ten parts per million, no hatching. So we reran the studies at 2, 4 and 8 parts per million. We found an effect at 4, no effect at 2, so we concluded Bcmewhera between 2 and. 4 parts per million in the diet of the white leghorn chicken, its egg batchability will be affected. Reproduction studies, as I recall, at again the mammals, at' the higher levels^--the higher chlorinated mixture, as I rstenber, the second generation, second litter sensed to ba affected in the reproduction. DR. MTTJ.TMl: day. Has there been ary work done with Aroclcr 1618? MR. PAPAGEQRGE: The work with Aroclcr 1016 has--which came about later, was confined to the 90-day study, which was identical to the 1242. So we concluded that the two-year would probably look like the 1242. DR. MULING: So--well, it seems to me, that, that 1016 is not ary less toxic; is that right? MR. PAPAGBCRGB: He have never that is right. We've never claimed it's less toxic. Ha said it's more degradable. DR. MmiBS: Ckay. Thank yax. SCAMntER: Further questions? Please identify yourself, sir. A. B3PPH2KAM: Mark Bepple&m, Hoofer Ecology Center. You said that Moaaato signs a con-tactual agreement with eiataaars, uhkh lets ' 32 WTM00569 NCR-FOX-0281426 WATER PCB-00044170 Monsanto off tte hxk, I guess, if any accidents happen car something like that, bit my question is then therefore you could identify exactly where all yon: PC3 cuujxuixls are going; right? Is that correct? HR, PAPA3E0KS; We can tell you fron our shipping record the delivery point. Beyond that we do tot know whether it gees into a transformer, a parti radar capacitor or where that piece of equipment finally is used. .. MR. OBPIIXAM: But you do identify a shipping point aid a customer, right? MR. PAPAGBORGE: Xas, yes. MR.. BCPPIfiraM: Ckay. Is that---could that be made, public record car is that strictly confidential? Z mean, could you tell the State of Wisconsin these are our customers in Wisconsin or would you be willing to? ' MR. PAPAGEeRGE: It's against our corporate policy, which is not unique to Monsanto, not to talk about our customers specifically. I can tell you, however, that through legal means, federal EPA did get a list of pur custaners. MR. BCPKEM: Ckay. One other question. With the transformers and the steel tanks, I was just wondering, do' PCB's have a really stable, long life. I mean, has anyone compared the life of PCB's with these steel tanks? MR. PAPAGBORGE; Yes, there is quite.a bit of information. Again, keep in mind I am not in the tranformer business personally Mid I am going to try to pass on to yew my under standing. There are, fee example, I'm told, transformers that were filled 40 years ago still in service doing a job. Apparently: they're hot stressed to the. point where the fluid is damaged in any way. and they keep doing their job in, day out and cause no problm. . On the other hand, we have varying degrees-of .success of how long that fluid lasts. Depending on the service the unit is placed under, maybe its design and maybe an oversize or under sized unit is placed in service so it's'stretched more so it requires a little more attention than . normal, 90 we get varying degrees of failure of the fluid. I hope that answers your question. It's a varied pattern. MR. KXPZEKAM: ' 1 thank you. EXAMINER: Are there any further questions? MR. VBUH: My name is Gilman Veith. I'm with the 0. S. EPA in Duluth. I share your concern over, the inferences that people studying, the emrirennent sometimes make or feel forced to make. But in that same light, .1 have a great deal of concern over the inference, that PCB's, because they cannot be accounted for on a mass balance basis, are degradable in the environment. And you mentioned,- for example, you do see a decrease in- the Sauget, Illinois sewage treatment plant when you try to dp a mass balance of the effluent and the influent and the-sludge and I'm wondering if you could provide for the hearing record data to, you know, that would have---I've dene a few studies cn sewage treatment plants. 1 find it very difficult to try to do a mass balance to really conclude /anything and Ifa wondering- we have seen, of course, the decrease in the efluent:and whether or not it's absorption or stripping through the secondary-----through the aeration, or through degradation, I haven't been able to conclude myself and I think it's important for a ramfcer of reasons. Che is -there seems to be seme' concern that it is not possible to adequately treat PCB wastes to get them down, so that if there is a process to: treat it, whether it just simply be biological absorption onto a flock, I' think this trxild be quite useful. And the seoond thing is that when we look for degradation of camounds, if you want to test whether or not DDT dees, in fact, degrade, you can find DDD; ycu can DOE; you can find DMJ in the environment. If we want to get sane indication that ehloridane degrades, we can identify cxychloridane as a residue in the fish. let then we cane to PCB's, we do net see these metabolites, end I'm wondering if these compounds have been identified as degradation products in the sewage treatment plant and I guess the second part of that really is-has Monsanto checked the losses in such plants due to just simply stripping. As you knew, PCB's has a substantial vapor pressure and there seats to be graving information that aerial transport of PCB's as a source of contamination is becoming---maybe a significant zeute and a secondary--I mean an aerated sludge, process could, indeed, simply be stripping the KB's from the waters. MR. PAPAGSORGE: Very good. For the benefit of these who don't know what we've dens in on; laboratory, we have tried to siawlata in toe laboratory, toe situation that might occur in a murucipal treatment system. We went to one of the local, municipal plants, obtained 33 - WTM00570 NCR-FOX-0281427 WATER PCB-00044171 tte sludge as a culture and set up in the laboratory units in which we introduced the slulge with the proper nutrients and the ratio of water to sludge and bubbled air and the ratio that might be found in the--in the plant, a sewage treatment plant. We then add the material we wish to test. How, thi3 test was not designed by Monsanto far KB's. It's a test that was developed back in the days, you may remember, when we had the hard detergent, soft detergent problem. SO we just mimic that situation. I recognize that this problen of evaporation of the material, the KB's, the transport by the air stream running through the bath, or the deposit bn the sludge itself could account for the disappearance. So we set up studies in which we pass this air through a series of absorbent bubble trains and all and check to see if the PCB's were out there, I forget how many, six or so bubblers in a train. We assured ourselves after repeated trials that it wasn't there. We then looked on the sludge, itself, and satisfied ourselves that we could make this material balance and still there's, a disappearance of that fingerprint. We have not and we were hoping others would start these kinds of studies, but we've been disappointed thus far. Vfe have not identified the products of this degradation, which is your frustration and mine also. We don't knat what it becomes because we've been asked this question, could the material that results have prohlans, maybe worse than the original? We can't answer that because we do not know, we have made sane studies on the amount of COj evolved and it shows us that there is an cocodaticn going an. That paper, incidentally has been published in the "Journal of Bwironnental Contamination and Technology"-- something like--I think that's the title. We've also had cur Monsanto researchers in Europe publish a like kind of study and I'm sure you've seen Dr. Metcalf's work out of the University of Illinois. Those are the only three papers I'm aware of that address themselves to degradation of PCB's by mieaxbes. EXAMINER: Thank you very such. Any further questions? '* . Please identify yourself, sir. DR. VAN DUSER: My name is Arthur Van Duser. I'm a physician with the Department of Health and Social. Services. And I apologize to the ccmnittee and to Dr. Papageorge if this question may have been asked before, but it relates to the problem, I think. Are you familiar and could you update me personally at least as to what's being done oh the national level to prohibit or to change the importation of these materials? I think most of us feed, that Monsanto is trying to do a good jab, but we worry about what's oaring in through imparted sources or from manufacturers elsewhere. EXAMINERj I believe that was touched an before. Well, maybe you can give the answer again. EPA will be here temorrew with that same information, too, but go ahead if you'd like to repeat it. -' MR. PAPAGECOGE: It's ny understanding, sir, that cur regulatory, agencies do not have the statutes it needs to prevent the Importation of this material. DR. VAN KISER: Ycu are saying the gates--peripheral gates are certainly open as of the present time as far as you know. MR. PAPAGEDB3E: Yes, sir. You may have heard of the--the group of nations that call themselves the-----that under the auspices or banner of CECD, the Organization for Cooperation Economic Developement. These nations have an agreement regarding PCB's and the agreaient reals as follows: "The producing nations, those producing PCB's, will sell them only to txanfazmers, capacitors, nonfood heat transfer applications and as a functional fluid--hydraulic fluid in mining equipment." That's modeling into tte Monsanto practice. Even in Europe we don't follow ttat practice. As an aside, and not definitely written in the agreement is that each of these nations presimably are to respect the mother nations' attitudes, if you will, towards PCB's. So if the U. S., for example, does not go along with the beat transfer and hydraulic fluid application, they're not supposed to ship material into this country for that application. There is evidence that that's not being followed. 1. T3ISCN: Bd TUscn here. I thought I'd like to read this off because thin is bora Manual of General Tcsdcity---if the specific name is needed I can get it at a future time. It lists under chlorinated diphenyl oxide, which have a high likelihood of being a decotposition product of PC3's, says under disaster hazard, "dangerous vhen heated to deocraposition? it emits highly toxic faues." And then rate chlorinated diphenyls, it says rate tautology--this is an 34 VTM00571 NCR-FOX-0281428 WATER PCB-00044172 extract, "coddas of chlorinated dipterals are cere tesde than the unoddized materials." wob just by way of camEnt on the material that's already been presented. ' EXAMINER: Okay. Sank you, six. Are there ary further questions? MR. BREMER: Karl Eretrer, D.S. EPA in Chicago. Fcxgot this one before. X just went your general opinion. Sou necessary do you think FCB's are in electrical systems, particularly in transformers and is it because Of electrical code that we're fighting with right now or what? - MR. PAPAGBQEGE: She electrical coda refers to .fire resistance. So it's really fire resistanse that is the benefit that ve all enjoy, whether we recognize it cm: net. Without this characteristic, nary, many of the units new installed in places that have high people concentrations or high property values like in factories and what have you, X think you can . see the benefit of having a fluid that would rot bum should the unit foil dramatically, with hxiis of fire being scattered in all directions. . . MR. BREMER: Kell, the reason X asked the question was X have had conversations with a number of electrical manufacturers and they indicate that-technology is developed to a state where breakers and so forth, can be used, for exanple in a building in the event that you have this arcing and so forth that occurs in a transformer system that particular types of breakers and' so forth can prevent the--ycu knew, the actual, arcing aid. burning or explosion of a transformer and X was wadering if we might, you know, be able to use same of this technology rather than kind of sticking with what we have. And the other thing is the advent of the dry transformer, which we realize, ycu know, is a thing that +rik*x more space. It's a different size and therefore, well, people are, you knew, they're a little reluctant to use something a little.different because of the way it has been done and you know that it's like this in---oh, you kriow, just in the building industry itself and in manufacture. But I just wonder if maybe we could--we could think of using cur technology, up-to- date technology and use this type of, let's say a breaker system with another type of oil that; you know, would efficiently do the job rather than using something that we knew--we've determined is pretty toxic and yet we keep saying, well, `it is in a closed, system, you know, and here we have something that, okay, it's in a closed system. Kell, you have the other thing where just simple maliciousness on the part of same people where they'll---okiy, they'll put a bullet hole in a. transformer or something of this type.' You have the fluid go out an the ground and/or you have a leaking of it just by, you know, defectiveness of the carponent or whatever it is. And it just seems like a vicious kind of circle, but X was just, you know, ay consideration is--well, X think, you knar, myself, that electrical code can be changed. You knew,.that it doesi't haive to employ these in-house transformers in large buildings. They cculd be put outside. Technology could : use-the particular breaker systems that we have developed and we could use other substitute fluids which are available at this time. . It's just n$--I just thought that maybe you felt the electrical code, you knew, may be holding us back, too. X don't know. ' ' MR. PAPAGECRGE: I am not perscr.Uly qualified to speak for the electrical-- I know really very little about the electrical codes and electrical engineering and the alterna tives available in design. I understand there hay be sons people speaking cm that matter later. YOU my wish to reserve your question far them. . . MR. BREMER: Yes, fine. . MR. PAPAGBDHGE: I just am not qualified to speak toward ttat. . . MR. BREMER: Thank you. EXAMINER: Any further questions? (No response) EXAMINER: okay. In that case, thank you very much, Mr. Papegecrga. I appreciate it. At this time we'U take about a IS-minute recess and stretch our legs. It's pretty weens in here. (Rooms) EXAMINER: Cteay. tfe're back on the record, ladies and gentlemen. Please be seated. ' . 35 WTM00572 NCR- FOX-0281429 WATER PCB-00044173 Me are entering into the public content partim of the hearing today. I'd first like to call Hr. Jerry Dimer for carment. MR. DUMER: Thank you, Mr. Christensen. I'm here cm behalf of Lt. Governor Martin Schreiber who unfortunately couldn't be here, but he has a statement that he would like me to tread. I would like to direct my testimony to two points. .The first is to ccnmend the Board of natural Resources and the Department of Natural Resources for holding these hearings. For over a year, I have believed consideration of effluent standards for PCB's is a valid first step toward .eradicating the documented dangers of PCB contamination. And I find it most encouraging that Wisconsin is cnce again taking the lead in protecting our environment. The second point is that effluent standards are only the. beginning, because effluents are only one of nary ways PCB's are released into the environment. As a result, aetiem to curtail PCB contamination will only be effective when PCS use has been restricted to the greatest extent possible. Hopefully, these hearings will provide enough information for the appropriate standing cemnittees in the Legislature to take this action. Currently only PCB's used in the.electrical industry in transformers and capacitors are considered irreplaceable. X believe it is necessary that all other uses he carefully examined and in all cases where less toxic substitutes exist, PCB use should be banned. In addition, the essential uses of PCB's in transformers and capacitors should he critically reviewed in order to determine the feasibility of developing replacement products. Further action by the Department of Natural Resources and the Legislature should be aimed at encouraging other states and the U. 5. Environmental Protection Agency to follow Wisconsin's-lead in considering effluent standards for PCB's and eventually terming all . replaceable uses of the chssical. Hopefully, also, these hearings will call attention to the myriad of PCS-oontaining products new being used far a variety of purposes. Although Monsanto Chemical Corporation is tie only domestic producer. Great Britain, Frances Germany, The U.S.S.R, Japan, Spain, Italy and Czechoslovakia all manufacture PCB's. Insufficient monitoring of imports makes it impossible to knew hew maty materials containing PCB's enter the United States, or how much is actually manufactured worldwide. I should note that the Environmental Protection. Agency has instituted a voluntary reporting program far imports containing PCB's. Unfortunately, the H>A has no statutory authority to mandate this information. However, toxic substances control legislation presently before Congress would provide the authority to gather necessary data. Why wtuld Z mention the toxic substances control legislation at this hearing? Because this hearing,, whether it considers effluent standards or an outright ban of nonessential PCB uses, is still reacting to the problem of chgracal pollution with hindsight, not foresight. The real solution lies in ensuring the harmful chemicals never reach the marketplace. Scientific evidence of the adverse effects of toxic materials mounts daily. Several hundred new chemicals appear in the marketplace every year. None of than are tested for possible harmful effects on health or emrirarment. Only after the adverse effects are firmly deesaiafited is action considered. This is the case with PCB's and it was the case with DDT and Dieldrin. Besides providing the EPA with the authority to demand data en toxic substances, a toxic substances control act would provide the mechanism far testing potentially harmful chemicals before they become an environmental or a health hazard. Testing of materials such as PCB's before they become a problem, before they are allowed to be placed cm the market, is the only prudent approach for the future. This hearing will collect information for effluent standards far PCB's. I would ask that each participant, and all those who will-use the testimony delivered here, be mindful of the fact that these standards are only one step. The success of the fight against the hazards of PCB contamination win be measured to the degree to which widespread intergovernmental action is achieved and the degree to which we realize that action based on hindsight will always be less than enough. Thank you. SIGNER: Thank yen very much. Hr. Disassr. Is Mr; James Allen present? Mr. Allen? 36 WM00573 NCR-FOX-0281430 WATER PCB-00044174 MR. MADISCN: Yes. EXAMINER; Please identify yourself and who you represent. MR. MRDISCN: For the record, my nans is Allen Madison. . . SCAMINERs Excuse me. ' ' MR. MRDISCH: Base secretary, Congressman les Aspin. Mr. Secretary, markers of the board, the hearing examiner, Mr. Christensen, first of all, 1 would like to thank you for the, opportunity to submit testimcry. for, these very important hearings. In view of the essential nature of this hearing and the nmber of people wishing to testify, I shall try to be precise and brief. ' - . He are here to discuss the subject of TCB's, polychlorinated biphenyls. To residents of Wisconsin and others of the Great Lakes states, this is not a new problem and it is one which we are all striving to solve. . The Secretary and the Board of the Dqarttamt of natural. Resources have presented . us with two choices in this natter: (A), a bah of the discharge of polychlorinated biphenyls, either in pure form or in substance, mixture, products or cccpounds into, state waters or (B), a limit of ho more than .005 milligrams per. liter of PCS as treasured in a 24-hour, canpcsite sanple, shall be discharged into state waters. X urge you to sqpart.a complete ban of the discharge of polychlorinated biphenyls into Wisconsin's waters. After long, deliberation, I feel that this is the most expedient way to attack this problem.. . Research into the harmful. effects of FCB ccnmrrpticn or assimilation has been intensified in resent years due to the increasing awareness of the potential dangers of this toxic group of substances. He in Wisconsin are fortunate to have the advice and assistance of Dr. Janes Allen, pathologist at the university of Wisconsin, whose research on the effect of KB's on rhesus monkeys has offered us an invaluable insight into the possible harmful effects these substances would have ' on humans. ' . , that recent research has offered to us is a further strengthening of the opinion of maty federal, Wisconsin and other Great lakes states':agencies, that FCB's pose a potential long term hazard to barrens. Cn the federal level, the U.S. Food and Drug Administration has instructed " -that the maxims: aViewable concentration be limited to five parts per million. Recent research done by Dr. Allen on animals has shown that a dosage of five parts per'million of the FCB's has produced toxic manifestations in a month's time. Lower dosages of FCB's have also been found to produce toxic manifestations. . . This, then, leads, us to ask what level of FCB concentration in the envirereerit can be viewed as safe for human ponsunptioa. The answer to this question is that we just do not know. We do have evidence as to what effects pertain levels of contamination have on animals, fish, birds, minks, monkeys, etc., and we have documented evidence of what a large dosage of FCB's can do to humans. This example involved 1,000 Japanese, who in 1969 acidentally ate ' PCS contaminated rice. . . Because KB's are retained in body fat, the symptoms of the contamination lingered in many for years. Longterm effects of this are still undetermined. Sixteen human deaths were attributed to this FCB poisoning. The babies of two pregnant women were still born and the babies of nine wmea shewed symptoms of chlariabj,phenyl poisoning. FCB oontemination has hit very hard in Wisconsin industry and has the potential to hit harder. Contamination of fish in Lake Michigan, Lake Pepin, in the Green Bay Hatchery and along the Mississippi has laid a further, blow to catmercial fishing in Wisconsin. In addition to ocemercial fishing, sport.anglers in certain areas'have been advised to limit their intake of : certain fish to one meal per wede. I aa sure that we are all aware of the federal and state . investment of many millions of dollars to restore the Great LaJte* fisheries and its habitat. This dual effort was to detannins methods to control lanpreys. This, involvement was largely successful, but is being undermined by the even greater problem of FCB oontarinaticn. The State of Wisconsin has the largest mink industry in the nation. The effect of FCB's cn mink living near Lake Michigan, has been documented. The Hatlcnal Waters Quality Laboratory has tested minks which had eaten fish with .6 parts per million of FCB's. These aides failed to reproduce and suffered a mortality rate of 71 percent. The- possible longtern and even shart-tarm effects this could have on Wisconsin mink industry: could be devastating. Wisconsin is also affected by FCB contamination of milk. Thera have been instances of Bsilk oentoaimfeioa frem silage which was stored in concrete stave Silos. The FCB source was 37 VTM00574 I NCR-FOX-0281431 WATER PCB-00044175 & traced to a sealant used cn the inside walls of these silos. KB's were found to be efficiently transferred froa the silage to the cows' milk. The U.S. Department of Agriculture surveyed a number of fanrs around the country that were using contaminated silos. Levels of KB residues in milk fat were approximately 10 parts per million. There have teen instances in other individual farms of residue levels as high as 28 parts per millicn. It is interesting to note here that FDA guldendps for maximum PCB residue is equivalent to 2.5 parts per mi Him in milk fat. The U.S. Department of Agriculture views this as a potential danger in farm families who drink milk from their cwn ccws fed m contaminated silage. Potentially, intakes ofPCB's for ever 15 to 20 years could approximate the level of short-term intakes that caused the serious effects in Japan which I have mentioned. The Wisconsin Department of Agriculture, the Department of Matured Resources, and the Wisconsin Division of Health/ have fully cooperated with the U.S. Food and Drug Administration, the U.S. Environmental Protection Agency and other Great Lakes states in . intensifying research into the sources and harmful effects of PCS and in setting tolerance levels. Their combined efforts have beer, vitally instrumental to determining the possible obliteration of this environmental and human tcocic substance. . In 1972, the tfcnsanto Canpany sole producer of PCB's in the United States, voluntarily agreed to limit the sale of PCB's to those industries with closed systems. This agreement also limited the use of PCB's in the manufacture of electrical transformers, insulators, grail capacitators and similar itaas. It was hoped that this action and action taken by the Food and Drug Administration vwuld limit the level of PCB in the environment. According to the U.S. Environmental Protection Agency estimates, PCB levels have risen in many areas and remain the same in others. This is rot encouraging, to say the least, and is, in tny. opinion, a dangerous indication. What I feel theTM what Z feel the implications of this are is that our past monitoring, testing and control of the use of PCB's has not been strong or effective enough. ' We are all aware of what the known PCB sources are and it has been my impression that many people would prefer the discovery of present unknown PCB sources before placing a ban eft the use of PCB's. I believe, Mr. Secretary, that this is not the best way to attack this peoblsn. . A ban of this industrial impound would necessitate an intense search into areas where levels of PCB's are either expected or thought to be located. It would greatly increase our knowledge of what PCB .soirees actually are. It would greatly enhance our efforts towards a total obliteration of this hazardous chemical. . Such a course of action has been urged by the Minnesota Pollution Control Agency and its regional task force, the Upper Great Lakes Cccmittee of the Great Lakes Fishery Cormissicn, and by Nathaniel Peed, assistant secretary of the U.S. Department of the Interior. Mr. Secretary, I submit to the board today a three part, proposal which I feel must be adopted to eliminate the PCB problem. - First, I ask the Department of itetMMl Resources to ban the discharge of KB's into Wisconsin waters. .' Second, I plan to initiate action on the federal level for an imtediate ban cm the new production and importation of PCB's and products with a PCB content. In reference to existing supplies of PCB's, Z feel that a five-year phase-cut of these applies be enacted. Third, I feel that it is necessary that an intense study of leng-term health implications of the consumption of PCB's be made. This study should include a complete analysis of the nature of the mace than 250 different chemical compounds of polychlorinated biphenyls. The elimination of all source points of PCB contamination, both in Wisconsin and in other parts of the nation is contingent on the adoption of this proposal. I also think that this board would be interested in knowing of actions taken by other nations of the world regarding the PCB problem. Sweden requires a permit for the manufacture and use of these industrial chemicals. The. Canadian .government is about to pass a toxic substances act, much stronger than the Ttodc Substances Control Act being considered by the U.S. Congress, japan, qn industrial nation similar to the United States, has recently banned the production of PCB and has initiated a phase-out of existing supplies of PCB's, similar to what I have proposed. . The action I call for----a ban on the.use, manufacture and importation of poly chlorinated biphenyls--is not an unprecedented act. It will be, I firmly believe, to the benefit of the citizens of Wisconsin, and of the United states. 38 WTM00575 NCR-FOX-0281432 WATER PCB-00044176 . ay vhms. Thank you, Mr. Secretary and the board for allowing me this opportunity to express .. . EXAMINER: Do you have a copy of that statement, sir? . Blank you. Mr. Donald Bach. Are you ready fear your presentation, sir? MR. BACH: Z ant attorney Donald L. Bach of the law firm DeKitt, McAndrews and . Porter of Madison, Wisconsin.. lappear today on behalf of the Wisconsin Paper Council, trade association for the pulp and paper industry within Wisconsin. There are 49 pulp and paper nulls within Wisconsin operated by 34 major eaipanies, with a. total of 14B.other associated plants, including converters and distributers, which are additionally located in Wisconsin. The pulp and paper industry employs 45,000 people, who produce an excess of five million tons of pulp and paper products annually. Bie total payroll for these parsons is approximately $410 million on which personal incane taxes of $6.5 millien are paid. Bie Wisconsin paper industry itself pays annual taxes to local,. state and federal governments of approximately $53 million. Wisconsin manufactures more than 11 percent of the total production of pulp and paper products in the United States and is the number one paper-producing state in the country. Although.the paper industry is obviously extranely critical one to the state, it is not honnal for the ley person or even many technical experts to know a great deal about its manufacturing processes,. A rmfcer of elements are essential '.c the paper industry, among them being high concentration of capital investment, skilled labor sufficient amounts of self generated or purchased energy, water and, needless to say, cellulose in the form of either wood pulp or waste paper. Most paper is made from the fiber of trees harvested fran scientifically managed forests of which, within Wisconsin, more than 1.4 million acres are owned by the paper * industry and managed under professional management plans. . Ito date, more than 130 million trees have been reforested in the State of Wisconsin by the paper industry and on a current basis, an average of approximately two and a half million trees are being-additionally planted every year. . . Wisconsin, however, is not only the leading state, in paper malting, but also the nxsber one state in paper retooling. At least 19 Wisconsin paper firms .recycle fibers to seme extent and several firms make a specialty of it, producing papers widely known for their adapta bility and strength. A fifth of Wisconsin's annual paper production, about 760,000 tens, is made from recycled, post-consumer wastes. Recycled paper distributed from Wisconsin throughout the nation includes such things as paperboard, corrugated boxes, cones, folding cartons, industrial wrappers, solid, fiber boxes, napkins, tray covers, roll stock, toweling, tissues, test liner, container Chip board and a wide range of fine writing, printing, business and office papers. . Sane Wisconsin paper makers have been producing recycled paper and paperboard since the turn of the century. As a result of such recycling,, weed fiber, resources and the use of residue from the manufacture of other wood products such as lusher and plywood.are being extended each year. It is estimated that wood chips, Slabs, edging, sawdust and the like provide 25 percent of all the mod used to make pulp. . we face a paper and fiber, crisis in this country, although assuring that adequate forests are made available.for the harvesting of timber, there is no imtediate danger that the . nation will run short of trees. This begs the point,.however, that the nation is fast running out of solid waste disposal sites and continually overcGnasrdng its natural resources, although, fortunately our forests are unique in that they are renewable resources. . It Should be noted that paper products are at least 40 percent of the nation's solid waste, with garbage cmpoelng only 24 percent, metal' 10 percent, glass 12 percent and miscellaneous items 14'percent. Since paper is approaching half of the waste bulk, recycling obviously is a technique with great environmental as well as canonic potential. New Vork City alora spends $6 million annually to dispose' outdated issues of the Nav York Times. The unfortunate thing is that currently only 12 percent of the nation's paper is being recycled as compared to 4& percent during World War II in the United States and as ccnpared to 40 percent today in Japan and West Germany, the two highest recycling nations in the world. . . . Hem, Should recycling be encouraged? The answer is obvious, zt must be encouraged. Beading froa Governor Iucey's charge to the recycling task force appointed by him in July, 1971, Z quote as follows: The ever-increasing, demands upon the supply of cur natural resources denenstrates the necessity fob reuse of our waste materials. Wa cannot continue to s&tply dispose of society's wastes without jeopardizing our entire future. The present methods of solid waste disposal, such as landfill and 'incineration, joes a threat not only to our supply of natural resources, but also to our air, land and water. The shortage of land around our urban centers . and the increasing levels of air pollutants leaves society no choice but to recycle our solid . 39 WTM00576 MCR-FGX-D281433 WATER PCB-00044177 tastes. If the present rate of increase and use of natural resources continues without regard for recycling/ ue say face a shortage of natural resources." The report of the Governor's Recycling Task Force on solid taste issues and jRfavi in 1972 in February, contained on page 26, the following statsnent; "It is appropriate to the task force charge to strengthen the traditional role of the Wisconsin industry in pulp and paper manufacture. Therefore, it is suggested that a singular opportunity exists here and row for expanding the base of paper manufacture by using essentially recycled fibers." She same report on page 15, notes that in fourteen counties, that we are prodioing 200 tons-----202 tons of waste newsprint per day, 101 tens of waste magazines daily, 101 tons of waste corrugated paper daily, over a thousand tons of mixed paper and other types of corrugated paper daily and 368 tens of used daily. These are significant amounts. They are shameful amounts. There are volumes and amounts that America and Wisconsin recycling industries are dealing, with, and in case of same of Wisconsin's paper oenpanies, they have been dealing with since the very beginning of the 20th century. What has Wisconsin as a state, in addition to its paper industry, done about it? Governor Incey in June of 1974 signed Chapter 305, Laws of 1973, creating the Wisconsin Solid Waste Recycling Authority. This was a law strongly supported by the Wisconsin Paper Council, even though it did not directly affect the econanic interests of its Berbers. In that law, the _. Legislature clearly declared that the people of Wisconsin have a right to clean ani vtolescne envircrneiit and that prevailing solid waste disposal practices, i.e., landfilling, burning and the like throughout the state result in an unnecessary environmental damage, waste valuable land and other resources and constitute a continuing hazard to the health and welfare of Wisconsin citizens. . . Manufacturing any product is not a clean, tidy process. Generally it is noisy; usually it is dirty and normally Mark with large machinery is involved. It normally takes skilled labor of which Wisconsin is fortunate to have an anple and sufficient svpply. The point being, however, that in the manufacturing process, certain natural rsources are consumed and related byproducts are discharged or Blitted as part of the process themselves. . * Recognizing this inpact an the environnent on which it depends, the Wisconsin paper industry had expended prior to 1975 approximately $126 million cn water pollution abatement equipment. It is the estimate of the industry that within the next five years an wfM-iirirai $153 million, at a minimum, will be expended far a total investment of appicodnately $280 million for water pollution abatement equipment alone, not one cent of which is attributable to production equipment. In 1953 an average of -218 pounds of BCD per ton escaped to Wisconsin rivers from the paper mills. In 1972, this figure had been reduced to 65 pounds per ton, with the ultimate figure expected to be reduced even further. This is doubly renarkable when one considers that pulping can produce up to 700 pounds of BCD per ton of pulp produced and that the paper industry in 1953 was producing only 2.8 millicn tons of paper and paper products per year, whereas in 1972 its production had increased' to almost 4 million tens annually. The renoval of suspesded solids frem effluent also showed a narked decline between 1953 and 1972--fraa 92 pounds per ton to 39 pounds per ton, with the ultimate amount to decline even further in the future. . as to air pollution, prior to 1975 the Wisconsin paper industry had invested approximately $34 million in air pollution abatement equipment and anticipates that between 1975 and 1980 it will infest at a miniman, an additional sum in excess of $60 million. In rewgh figures,, therefore, the paper industry in Wisconsin alene will have spent by 1980 approximately $375 mill ice for air aid water pollution abatement equipment, approximately $8,200 per otployee cn What is very envirarrentally necessary, but is unproductive by itself. Mow, on the issue of polychlorinated biphenyls, by this time in the testimony, I think Z need spend a little time in identifying PCS's or their historical uses. I do wish to point out, however, that far an extended period of' time, these substances have been used, particularly within the electrical industry. For example, for purposes that have been dwmed and are still deemed to be socially acceptable and beneficial' in terms of their ability to reduce explosion and fire and to protect hunan life and' human welfare. One of the many varied uses of ROB's prior to 1971 had been in the carbonless copy paper, which has accumulated in the files of many businesses and nunerous governmental agencies and have .stayed there for seme time, tut frem time to time, also gets sorted out and heoaae part of the solid waste chain. It has been only relatively recently that attention has been drawn to KB's because of their widespread distribution, in the envixesment. As a matter of fact, many eonmentators have referred to the fact that PCB's have beccca ubiquitous and that even a total cessation of manufacturing and the use of KB's would not result in the rapid disappearance of the material, i.e., ultimate disappearance fraathe mrirement will take many years 40 NCR-FOX-0281434 WATER PCB-00044178 regardless of any total ban, even if a total ban were desirable, which it ia most emphatically rot desirable. At this point I wish to sake very clear what should be obvious at this time. Waste xarm* collectors and recyclers do not manufacture KB's, nor do they use then in their nzmufacturing process. However, to the extent that certain transformers and capacitors cn their premises nay or may not have PCS fluids in than, such materials might be cn their premises. Further, to the extent that recycled waste paper does contain traces of PCB's, this contaminate is introduced into the industrial systsa and heccmes part of the industrial waste discharge of the paper waste recycling facilities. ' At this point, several very' critical issues mist be noted by the Wisconsin Department of Natural Resources, namely: Cne, quoting from the Kay, 1972 report of the Inter departmental Task Force an PCB's entitled PCB's and the Enviirament, I quote, "..uxce scientific information about PCB's is needed. Only general statanents can be made about how PCB's reach the environment, how they reach target organisms and how much is. present." Ke could not more fully concur with this analysis of .the scientific level of knowledge or lade thereof about PCB's, nor mere fully offer our assistance as an industry to cooperate with the government to achieve an effective system for assessing and controlling PCB's. ' .' Two, you oust understand that a very email, portion of the total arcunt of PCB's ' manufactured domestically by Monsanto were used for'Carbonless paper, which is the chief assured source by which wastepaper contains the PCS contaminant, tooclor 1242 by weight containing relatively lower amounts of chlorine than other domestically produced and sold PCB's, was used in the production of carbonless paper. Between 1958 and 1971/ at which time the use of PCB's in the manufacture of carbonless paper was ceased. .Appradmately 47/8 percent of Monsanto's PCB production was of Aroclor 1242. However, of its entire domestically sold production during those years, a little over 21 percent was used for plasticizer applications. Plasticizer applications . include.not only use for, carbonless paper, bub also for adhesive, . textile and other surface coatings, inks, investment casting wax and sealants. Therefore,, we know that something considerably less than 10 percent of Mcnsanto's total PCB production between 1958 and 1971 was used in the manufacture of- carbonless paper, all of it being Tutelar 1242. - Three, to be emphasized repeatedly, since 1971 no'PCB's of any kind have been used to manufacture carbonless paper. Four, Arcelor 1242 used in: the manufacture of carbonless paper has significantly different structural constituent characteristics, whereby its stability and persistence are less and its degradeability appears to be significantly higher than its cccpscatively acre highly chlorinated Aroclor relatives. ' . Five, based cn studies reviewed by us, it is hot Aroclor 1242, the carbonless paper Aroclor which has carmcnly been found in large concentrations in Ccramroial fish. All of. the above can be restated concisely as follows: Only a snail portion of total PCB domestically produced were utilized far purposes of manufacturing carbonless paper and as to those particular Aroclocs, they art relatively less stable and persistent, appear to be more degradeable and are less susceptible to accimulaticn in fish than are their related, mere highly chlorinated Arcelors. As a result, the impact of the waste pager recycling industry cm the issue of PCB's, when taken in this light, is substantially put into a mere proper and positive perspective. As to the proposed CNR regulations, many studies have been pub! ishfd and many articles written relating to the existerae of PCB'b in the.gryircranent. The presence.of PCB's in tte envixoment, however, should not be assumed-to imply a negative effect. In fact, including -----again quoting ccm KB's and the Envircnent, on page 17 it states. "At the levels in which they axe found, KB's do nob appear to present an iasdnent hazard." Again, based on studies reviewed by us, we have seen ho conclusive published report relating to the death of any wildlife species because of the presence of PCB's; The only reported mortalities have.been those achieved in laboratory experiments; Most of those laboratory studies related to the higher chlorinated, more persistent PCB's,. while most, if net all of the effluents proposed to be regulated, contained primarily the lower chlorinated; less persistent type. Mo one can deny that the proposed CNR regulations are aimed most directly at the waste paper recycling industry in Wisconsin. ' Based cn appearance, very little thewght vent into the drafting of these regulations and,, in fact, they would appear not to represent the approach recoBcroded by the EKR staff which is, presumably, more qualified than many lay persons, whether on the Board of the Department of Natural. Resources or not, to make judgements of a technical nature. The adoption of either proposed regulation would be an economic catastrophe for the paper industry in Wisconsin., ' 41 WTM00578 NCR-FOX-0281435 WATER PCB-00044179 it Being concerned about the environment and attainting to do sanething about it are responsible goals and actions. As I have pointed cut, the paper industry has been the leader in both areas in the past and will continue to do so in the future. However, z sust cement that the suggestion of these so-called alternative regulations, with the full fcxoe and effect of the' prestige of the Environmental Quality Ccmnittee of the Department of Natural Resources Board can be classified as approaching the irresponsible. Quote, "current scientific knowledge gained fro* laboratory animal experiments if often inadequate to allow reliable interpretation of the data in terns of possible* effects on man. Ehe scientific basis for interpreting such tests must be improved. He situation regarding PCB's is not significantly different from the problems of other toxic substances which cau^e concern when they cane in contact with man, his food and his environment. Certainly continued vigilance on the part of the governmental agencies, industry, universities and many other agencies, both within and outside the government will be necessary to achieve an effective system for assessing and controlling the hazards of toxic substances, including PCB's." Hat's also from the report entitled KB's and the Environment. At this point we think there are several issues, that the CNR should answer in the very near future. Vihat is the toxic level of concentration and the degree of exposure necessary to achieve either mortality or an imminent hazard to health, to humans or wildlife? What is the background level of PCB's in Wisconsin waters? What Aroclors constitute these background levels? In the fish being tested in lake Michigan, Lake Superior and lake Pepin aid in various Wisconsin rivers, what Aroclors are being detected? What is the background level of Aroclcr 1242 in the waters most suspected of contamination by the Department? ' Zs it not true that Aroclor. 1242 is more degradeagle and less persistent in the * environment than its more highly chlorinated relatives? Of PCB's? Under what provisions of the Wisconsin Statutes do you propose to ban the discharge Do you propose, whether or not you are required to do so pursuant to Wisconsin Statutes 1.11, to issue an environmental and economic inpact statement prior to your promulgation, of any FCB ban? An ancillary problem that I'm sure the EKR staff has contemplated is the alternative methods of dealing with PCB's. Ctbviously burning contaminated waste paper is net the solution because unless such burning is done at extremely high temperatures and is in excess of 2,000 degrees Fahrenheit and in extremely efficient incinerators, the PCB's will simply be emitted to the atmosphere, to once again fall on land or into the water. Likewise, landfilling is not the solution because of the quantities of wastepaper involved, thereby necessitating more landfills. Again using the material from the Interdepartmental Task Force Report on PCB's issued in Kay of 1972, it has been estimated that the total injection of KB's into the American environment between the years 1932 and 1972 was approximately 30,000 tons in the atmosphere, 60,000 tens in the water and 300,000 tons to the landfill. Out of this total, remaining residues in 1972 were calwiiated to be approximately 20,000 tons in the air, which would be ultimately redistributed on either land or in water, 30,000 tons in water and approximately 200,000 tons in dunps. The conclusion 1b obvious, that PCB's in water are degrading more quickly than those emitted into the air cr placed in the land. . X think it is time for us to recognize that we all knew less than we would like to know about PCB's. Because of their persistence and because of uncertainties about their impact, the new production of this substance has all but been eliminated and is now used for only very specific and limited purposes. An inventory must be made of where PCB's are caning fran, the type of Aroclors that are being discharged, emitted and landfilled, the best methods of decreasing these discharges, emissions and landfillings and to put acre proper perspective on the existence of this substance in our environment. In the last legislative session alone, Senate Bill 339 and Assembly Bill 463 were introduced and would have required the state to purchase paper with a certain specified amount of recycled fiber in it. In addition, if you will view the current letterhead stationery of the Wisconsin Department of natural Resources, you will note that it says on. the bottom: "This is 100 percent recycled paper". If you will look further at the notice for board meetings of the Kisconsin Department of Natural Resources, you wdU likewise note the statement that "This is 100 percent recycled paper". and gentlemen, you are promoting the use of recycling. And we thank you fear that. Vou are also pro tasting the disposal of PCB's. let us take a reasonable approach to this problem together. We appeal to you fear reason, rat us admit together that we do not know enough 42 WTM0057S NCR-FOX-0281436 WATER PCB-00044180 at least at this point to take a stand such as proposing these ill thought out proposals, The result he an economic catastrophe for a significant, portion of Wisconsin's paper industry, ghe cctrmittrent of this .industry is to Wisconsin .and its awirorraentally pure future. It has invested and will invest over $300 toil lien dollars prior to 1980 to acqcnplish this goal. It further has a goal canton with Governor Incey to decrease landfill sites, and to recycle to the maxinun solid wastes so as to preserve our natural resources and to beautify cur state. It is . indeed unfortunate that more reasonable and more well thought out proposals for regulations have not been brought forth so that seme hind of an attempt could have been made even at this point of tbs hearings to work cut sane kind of meaningful regulations. We only hope, after the review of the entire hearing record, with written material to he submitted subsequent to the oral testimony that realistic, reasonable, feasible and responsible regulations will be proposed by the Department of Natural Resources, which will bolster its refutation as a defender of the envirorment, while at the same time, not place it in a position of ridicule, because it has suggested regulations so badly researched that they have became negotiable prior to the tine they ere published far hearing. Thai* you. . EXAMINER: Hun* you, air. Do you haws * copy of that? HR. BACH: Yea, I do. . EXAMINES: Thank you. . Mr. Gecmge Reinbacher? MR. EEBfflKHER: My name is George Reinbacber. I'm director of manufacturing for tte Absorbent Products Division of Brcwn Ccngiany and the manager of its operations at the mill in Eau-Claire, Wisconsin. * She mill, at Eau Claire employs approximately 7Q0 people , and has. an annual payroll in excess of $7 million. We pay over $100,000 annually in property taxes and are one of the major industrial employers in the Eau Claire area. During the past two years, we. have spent almost two million dollars .to reduce stream pollution and estimate that, a similar amount will be sprat ' during the next two years to ccrpleta the' secondary wastewater treatment plant. Our primary raw material, the secondary fiber or waste paper, which is shipped to us fron all over tie country. Annually over 70,000 tons of this materia'), is repulped, cleaned and manufactured into usable sanitary'products. Use of waste paper permits us to compete . economically and also provides us with usable furnished when so-called virgin pulp is not available. The problem of identifying and sorting waste paper is unique in that generally speaking, 1,700 to 2,000 pounds of various types of paper that we use are generally; shredded and baled together in 72-inch bales. The material canes frem printers, office buildings, department stores and recently, from aunicipal and private recycling centers. There is no practical way , of sorting and identifying random KB contaminated, paper. Brown Carpany does not deliberately buy or use RGB in its productive, processes. Nevertheless, the. carpany is concerned that the. proposed regulations will introduce an extremely serious problem in any paper mill using recycled pfipaay, ' ` '' '' ' . Our industry is caught in a situation Which is not of our making and over which we have little practical, control. The' whole concept of recycling waste paper is at stake. Via firmly believe that where recycled paper is involved, the regulations must recognize the temporary nature, of the problem, the 1cm concentration of contaminants that is involved and the ^practicality of identification and segregation of raw materials. .Otherwise the whole concept of paper reuse must be reconsidered and greatly curtailed, which could. result in economic disaster to the Eau Claire mill, es well as others using waste paper furnaces. .. . Thank yew. . . EXAMINER: Thank you very much, six. Thank you. - Is Mr. Patrick Mantis present? .' . . Mr. Richard wand? MR. V8a: My name is Richard Wand and X am the admibistxative vice-president of Bergstrom Paper Ccitipany. I am resper.sible for supervising and coordinate all staff activities of the Qcccpary and 1 direct corporate efforts in tits area of environmental management. ' 43 . . WTM00580 NCR-FOX-0281437 WATER_PC B-00044181 Die Bergstrom Paper Caqaany is a manufacturer of fine printing and voting papers and since cur founding in 1904, we have best recycling taste paper to make our products. Ke own no and rely on waste paper for approximately 65 percent of our total fiber raw material requirements. Mary of our products are produced froa 100 percent recycled waste paper and we are the nation's leading producer of printing and writing papers from secondary fiber. Ke have manufacturing facilities in Heenah; where we ecplqy about 570 persons and until April of this year we also operated our mill in West Carrollton, Ohio, where we employed approximately 575 people. Bconcndc conditions, resulting in declining paper markets, forced us to close our chio operation this spring. All but ten of our Ohio personnel have beat terminated or placed on - layoff and three paper machines with a daily capacity in excess of 400 tons of paper have been idled for an indefinite, period of time, pending improved market conditions. In 1974 and prior to closing our Ohio plant, Bergstxaa produced 225,000 tons of finished paper and recycled 141,000 tons of waste paper. This averages 18 truckloads and 8 rail cars of waste paper each day for 350 day's a year. In Keenah we have an annual payroll of approximately $7.5 million and we annually expend another almost $2 million for fringe benefits. In 1974 we paid Neenah real estate and personal property taxes in excess of $220,000. . . Since 1952, when installed one of the first wastewater treatment systems in the paper industry, cur cenpany has spent in excess of $4.5 million on pollution abatement facilities. Plans for an additional $3.2 million secondary wasteater treatment system for our Keenah mill are currently being reviewed by the Department of Natural Resources. I give this background information by way of demonstrating our cuupary's eocncmic Importance to the State of Wisconsin, to suggest our 70-year ocnmitment to the cause of recycling, and to reiterate our concerns for protecting the emdroment. In spite of the fact that recycling has been practiced since before the turn of tee century, an alarming fact remains that the rate of recycling is actually declining in this nation. According to recent EPA figures, this country is recycling only about four percent of its textiles, 13 percent of its zinc, 13 percent of its aluminum and only 19 percent of its waste paper. This waste paper rate eonpares to a world War II rate of 27 to 30 percent. ' Recently environmentalists have been among the strongest supporters of tea ooncept of resource recovery, that is, recycling because it makes gdod cannon sense to tap our massive solid waste stream to recover materials which can be utilized at their highest econcxnic value. Recycling saves tremendous amounts of energy. It greatly reduces the need to bum or bury solid waste, which now costs cur municipalities a national average of $2$ for each ton. It promotes the conservation of our precious raw materials and it makes us less dependent, therefore, on foreign cartels and it results in substantially reduced air, water or solid waste pollution. And yet we now face a proposed rule to totally ben the discharge of polychlorinated biphenyls, KS's, into the environment. That, very simply, will put virtually all paper recyclers out of the recycling business and both the proposed zero discharge rule or the proposed rule to limit PCB discharges to .005 of a milligram per liter or five parts per billion, which, as a practical matter, constitutes a total ban, could well put the Bergstrom paper canany out of business. Allow me to elaborate cn this. The Bergstxaa Paper Carpany has never, to ay knowledge, purchased PCB's for use in our production processes froa Monsanto or froa any other foreign or domestic supplier. BCD's are not and they never have been an additive to Bergstrom paper products. ' In May of 1974, Bergstran Paper Crapary cooperated wdth the Industrial Wastewater Section of the mat in a survey of all of our mill conditions and wastewater characteristics as they related to the monitoring and reporting requixsnents of our KPDES permit. In analyzing a composite sample froa our main outfall for PCB's, the Department found a discharge level of .0185 parts per million. It was assumed that the source of the PCB's was carbonless waste paper and our ccnpary assisted the Department by sending samples of such waste paper to the State Lab for testing. In Martel of 1975, we were advised that the DNR had conducted wtVHt.taviI sample tests cm our effluent in February of 1975. Hie Department then requested that we first analyze our general types of waste paper process to identify the specific source of PCB's and to determine if it is practicable to significantly reduce the discharge of PCB's by eliminating certain kinds of wastepapar. And secondly to determine if leaking teat exchange fluids os hydraulic fluids eould be & soiree of BO discharge. ' ' 44 WTM00581 NCR-FOX-0281438 WATER PCB-00044182 At considerable expense to. the cmpany, we oenplied with, the Department request and conducted extensive tests on. 14 wastepaper samples and-cn cur hydraulic fluid. Ho KB's were detected in the hydraulic fluids .and the Department has been provided with the results of the paper sanple tests. The inportant fact is that all" 14 wastepaper staple tests showed sct&e traces of either Arcelor 1242 or Aroclor 1254, ranging frtm less thin .1 of a part per millien to 3.6 parts per million. Hie vast majority of the PCB's detected in the wastepaper were of the Aroclor 1242 variety, which was the only Arcelor known to be used, in the production of carbon less paper. We are. advised that KB's have not beenused in the production of such carbonless papers since early 1971. - We are also advised by the Institute of Paper Chemistry that in order to detect PCB's in wastepaper samples at less, than 500 parts per bill ion for Aroclor .1242 or 100 parts per billion for Aroclor 1254, which are the current limits of detectability; we would have to test tussive quantities of wastepaper in order to arrive at a concentration level in which the minute quantities of PCB's could be identified and counted. Indeed,. this lack of technical capability to accurately measure, much less continually monitor the PCB's in both, the wastepaper'we eonstzne and in our effluent, would suggest to us that there is no known way to enforce either proposed rule short of closing all recycling operations. . In order to identify and eliminate those grades of westepaper which currently show PCB contamination at mure detection levels, we would face both enormously expensive and physically impractical, if hot impossible, processes. Few laboratories are even equipped to take on such a sampling or monitoring project on a regular basis; The point we're trying to make is this. KB's.did exist--do exist in the environ ment today. Through the voluntary efforts of the manufacturer, Monsanto, and those utilizing tte product, .current ccnsimptim is'limited to closed systems which minimize the entry of more PCB's into the environment. By placing a restriction on the discharge of PCB'-s, not necessarily ' by the manufacturer or by his customers, but by those recycling companies who find themselves inadvertently obtaining KB's in their wastepaper, will result in catastrophic damage to cur business and to the cause of recycling. '. . In the past few years, a marker of programs have been iitplanented to separate materials fran the solid waste stream. Ibe proposed rules would be devastating to such efforts. For exanple, we recycle sorted office waste which canes to us as a result of a major office waste recycling program, which includes 'among its participants governmental agoicies of the State of Wisconsin. . Fran time to time, old carbonless papers from office files find their way into this program. A ban cn PCB's would very simply put an end to the program. The Wisconsin Solid Haste Recycling Authority will face a similar problem in dealing with residual materials ' from a variety of establishments.' ' ' _ . Representative Aspin has earlier suggested time approaches to the preblan. He concur that additional health studies are necessary and we certainly concur with a ban on the impest of KB's. But with respect to his suggestion of a total ban cn discharge of PCB's in effluent, which after all, is the subject of this hearing, we must point cut that this is only possible through the termination of recycling, operations. - .. . We believe teat dsera is 'no recycling mill in the country which could consistently meet a zero PCB discharge level, no matter how careful it might be in attainting to isolate old caxbcnless papers, since PCB's are a pervasive background occpdnent in a variety of wastepaper grades. The Bergstraa Paper Ccnpany, 50 percent of whose wastepaper exceeds the limits of POT detectability, would be forced out of recycling were the Department to izposa either of the proposed rules. Since we have no guaranteed backup supply of virgin pulp, we sincerely fear that a halt.to our recycling would farce us to go cut of .business altogether. 5he additional . cost of purchasing virgin pulp would force such a major increase in the price of our products merely to cover this .added expense that we could ho longer ccnpete in the paper markets. . Our objections to the proposed rules can be sunnarized as follows: Regarding both alternative rules, no. 1 and no. 2, your own Department staff at the June meeting of the board to the finding of PCB's. in melting snev, which illustrates the problems'.of achieving zero discharge. To the best of cur knowledge, there is ho technological method for achieving a zero discharge of- this possible contaminant and we believe a five part per billion limitation' to be tantamount to zero discharge in view; of current measuring technology and techniques. Furthermore, we roust respectfully suggest that there are a lumber of other issues which must be resolved before ary PCB regulation should be considered.. First, there is no physically practical ca: eocmanically feasible method for continuously tasting either wastepaper samples or effluent to insure either a limitation on any PCB contaminated wastepaper used in our production or consistent ccsrpliance with tee discharge limitations being proposed. ` WTM00582 NCR-FOX-0281439 WATER PCB-00044183 f Secondly, there is no evidence that restricting the discharge of FCB's will substantially reduce the number of PCB's currently in the enviroroent since solid wastes currently being recycled would have to be disposed of either through landfill or .incineration. In neither process is there a destruction of the chemical compound. Thirdly, there is no substantial body of scientific knowledge to. dancestrate that the ingestion of`minute quantities of FCB's is harmful to human life, to the best of our knowledge. Indeed, wa knew.a few laboratory experiments to assess toxicity in which Aroclar 1242, vhich is the one found in old, carbonless paper, has even been the test median. . Fourthly, there is no evidence known by us which would suggest that Arcelor 1242 found in our effluent is the same Arcelor found to acctnulate in the fatty tissues of fish, fowl or other wildlife. Indeed, though it has been docisnented that Arcelor 1242 was the most plentiful Arcelor produced by Monsanto, few traces of this variety are being found in the envirorment. ' It is apparent from the testimony gathered at these hearings that legitimate questions of concern have been raised about PCB's. it is also apparent, Z think, that wa have great gaps in bur knowledge about the effect, the degradability, and the econemics of eliminating PCB's. Ke believe that it would be unconscionable fear the Department to pratulgate these proposed rules without better documentation, to shew that the proposed discharge limita tions are necessary; that they are attainable and that they ore of sufficient benefit to merit halting recycling in the State of Wisconsin. ' Since being, alerted to the possible problem of FCB's, we at Bexgstraa have attempted to oooperate with the Department of Natural Resources to the fullest. In our independent research, we have discovered that the cnly thing everybody seems to agree on regarding FCB's is that nobody really knows that much about that. Authorities are split an questions of taicieity. Experts - dispagree on safe alternative products. Scientists have divergent views on questions of PCB stability arid degradability. If there is a prcblon, those of us in recycling will do cur share to find reasonable solutions to the problem. But a hasty,, ill-conceived decision to pramlgata either the proposed rules will raise ecorotic havoc with an entire recycling- industry, which, by its very nature, is one of the most environnentally considerate industries in the state. Ke strongly urge rejection of these proposals and the creation of an unbiased task farce to review and research the PCB situation and the adoption of reasonable regulations if it is shown that regulation is necessary to protect the people of Wisconsin. - Thank you. '. EXAMINER: Thank you, air. Can you provide me with a copy of that statement? MR. WA1C: Yes. ' EXAMINER: Thank you very much. Mr. William Dryer. MR. DRYER: My name is William Dryer and I am director of research-end development for the Flambeau Paper Company. The Flambeau Paper Company is a semi-integrated sulfite mill and paper mill located at Farit Fails in Price County. Flambeau employs 525 people and has an annual payroll of $5,800,000. We purchase about 90,000 oords of wood each year frbm our Wisconsin or local loggers at a cost of about $2,700,000. Ke pay $4,100,000 in federal taxes; $600,000 in state taxes and $136,000 or about 25 percent of the City of Park Falls taxes each year. We operate in a part of Wisconsin which is considered to be a depressed area. We produce pulp using the calcium base sulfite process. Our paper machines manufacture bonds, duplicators, mimeograph. Xerocopy, envelope; offset, manifold, register bend and many specialities. Since we are not able to produce all of the.fiber required by cur paper rtachires, we are krom as a semi-integrated null. We must purchase seme kraft pulp, which is produced by the sulfate process and is the most readily available source of virgin market fibers. We also buy wastepapers to keep cur paper machines operating. During normal times, cur purchased wastepaper consists of envelope dippings and other unprinted wastepaper. However, whan market pulp is scarce, wa will purchase other types of wastepaper and keep our paper machines running. One other item I would like to explain is "brete1*. This is the name given to spoiled paper in paper mills and finishing room. It is generated by any number of causes during the 46 WTM00583 NCR-FOX-0281440 WATER PCB-00044184 processing and packaging operation. IE it la .not, contaminated, it .la .usually repulped and the fibers returned to the papensaking process. ' The proposed Administrative Code-provisions to prohibit or severely limit tie discharge of polychlorinated biphenyls, if adopted in their present form, will have devastating effects an. all paper carpanies in the State of Kisconsin which' are' not octupletely integrated. I would like to cite our oecpany as a case in point. Virile cur sulfite mill has the capacity to produce about 125;and a half tana of pulp each day, our paper machines can use in access of 290 tons of fiber during the same period of time; During rormal times the difference is made up by. using purchased kraft, our paper machine broke and our finishing recta brake and. purchased wastepaper.. Early in 1974, at a meeting of the Swedish Pulp and Paper Mission held in Chicago, we were told that Europe would soon be in importing rather than exporting pulp. She seme set of conditions exist in the United States. We are expanding our papermaking capacity such-- at a much faster rate than we are expanding our ability to produce pulp. During the simmer and fall of 1974 when the demand for paper was high, Flambeau was unable to purchase enSugh kraft to fill its requirements. Even by buying all the wastepaper we could obtain, we still were unable to secure eriough fiber to operate all of rur paper machines continuously so that we could fill all of the orders for paper. ' On December 3, 1974, we took ccrr .ito. sairple* froa cur outfalls and had them analyzed by a.consulting laboratory for 24 char, .is, including polychlorinated biphenyls. Vo ay surprise, our effluent contained 2.3 part: sr billion of PCB's. My feeling was that our consulting laboratory had erred in their testing. After learning mere about the nature of PCB's, I now feel that this test was correct even though we did not knowingly use any ' pre-1972 no carbon reproduction, paper in cur furnish. - PCS's will tend to stay with the fibers or particulate matter, Cqnnercially there is no way of telling which broke contains PCB's and which does nut, unless you can trace the origin of the paper back to its furnish. If brokewas used in that furnish, then the . origin of that broke must be traced back. also. Probably sane of the wastepaper we used then kraft was in short supply, was madefraa furnish containing sane'pre-1972 no carbon reproduction paper. How seme of the paper made by our oanpany during the last three-quarters of 1974 contains PCS's. We Jmcw that part of what was made on December 3rd did; If alternative 1 is adopted, I would have to advise our company to dispose of all our.purchased wastepaper and all of cur finishing room broke to paper mill--to paper mills in other states. V'e could no longer use purchased, wastepaper in our furnish and we could use none of cur - finishing roam broke until we were certain that it was manufactured only from virgin fibers. Our mill`Would never again sun at 100 percent capacity, for during the times of recession we would not have orders to run at full production and during the times when the demand for paper is high, we w*wld not be able to purchase enough virgin- fiber to fill our needs. By having to use all virgin fiber, our furnish costs would raise, and we would no longer be ccnpetitive with mills in other states. . If alternative 2 is adopted, we would try to operate as we did during, the last three-quarters of 1974. He would not use office wastepaper, re; would we use NCR no carbon reproduction paper,. Our purchased wastepaper sorting costs wndd increase and since other mills would have to use the same type of purchased broke as we are new using, we probably will have to firvi ourselves having to shut.our paper machines down at times for lack of fiber. The paper industry does not knowingly add PCB's to its products. The PCS's added prior to 1972 will decaipose with time. Recycling of wastepaper will, not increase the amount of PCB's in the envirorment. PCB's are concentrated in pre-1972 no carbon reproduction paper. Both the federal and state governments are large users of this type, of paper. At present, the Department of Natural Resources discharge monitoring report form is printed on no carbon reproduction paper, sooner or later these completed forms will have to be difijosad of. New is the time for government to find out which of their forms are contanviretted with PCB's and which are not. Contaminated farms ehTMid be segregated and disposed of in a sanitary, landfill. Forms free of PCB's should be fwtiJHed as such and recycled. This would do mare for reducing PCB's in cur water and air than either alternative 1 or 2 and at the same time it will conserve air natural resources. Thank you. . 30SHIHKU Thank you, sir. Could X have & eepy of that? la Mr. Inaaan here? Mr. Milt Ionian? 47 WTM00584 NCR-FOX-0281441 WATER PCB-00044185 * Is there any other individuals representing the Wisconsin Paper Council present to give any kind of testimony? Hr. Richard. Beilins. Vtould you like to sake a statement sir? HR. ROLLINS: lank you, Mr. Christenson. My nans is Richard Rollins. I'm here on the behalf of the Electronic industries Association, the EIA. ' The EIA is a national association far the manufacture of electronic ompraenta and equipment. I speak on behalf of that body today and represent 14 companies that operate 16 plants for the manufacture of capacitors in this country. Hbhe of these plants is located in Wisconsin. I would bring a few statements--a few questions in regards to what are capacitors and transformers and where they're used and we begin with capacitors and transformers are devices to store, control and direct the flew of electrical power efficiently and econonically. PCB's are used as an insulating fluid in these devices. PCB filled capacitors are found, among' other places, in outdoor lighting, fluorescent lighting, air conditioning and television receivers. PCB filled transformers are found, among other places, in railroad cars, apartment houses, large office buildings, industrial plants and utility substations. Tte primary reason for the use of PCB's in capacitors and transformers is their quality of nonflammability. While certain present alternatives do have other needed characteristics, no present alternative provides the nonflannabllity dorandad by our customers and by due regard for p,ihlic safety.. . Govemoental agencies have recognised the need for the continued use of PCB's in restricted circumstances, namely sealed electrical applications. In 1972 the Food and Drug Administration exerpted the safe use of PCB's in electrical capaeitators and transformers from . the requirement that PCB's no longer be permitted in feed-related establishments. That's in the 38 Federal Register, 18096. In 1972, also, a Federal Interdepartmental Task Force found that continued use of PCB's in transformers and capacitors was necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB use. that is under the Federal Report Mo. HF-PCB-72-1. While recognizing the need for continued use of PCB's in electrical applications, one nay not ignore the need for strict control over the discharge of PCB's. Thus, our nestership has implemented controls resulting in a total daily discharge of less than 11 pounds, that is less than two gallons, and that represents .014 percent of the 79,000 pounds used daily. Our handling and disposal practices are in accordance with the guidelines established by the American Rational Standards Institute, C107.1-1974. - Thank ycu. EfflMIHBR: Thank ycxi very such, sir. ' Mr. E. P. Tilscn. Would you have a statement? ' Please identify yourself aund who you represent. MR. TXLSCH: My name is Edward Tilson and I'm an engineer-in-fczaining, actually ay PE license is pending review. I represent, today at least, the Water Resources Center at University of Wisconsin. And this is a letter that the center has sent to this--to the attendees of this public hearing cr. polychlorinated biphenyls. Dear Participants: This letter will hopefully serve to advise you that we at the center are also presently concerned with polychlorinated biphenyls, most especially as regards the Mencnonee River Pilot Watershed Study being sponsored by the International Joint Catmissicn and the U.S. Environmental protection Agency. This study, centered on the Mencmcnee River watershed in the Milwaukee area, has PCB's as a selected water quality parameter within group C (organic) as determined on water and sediment sanple3. This class of cccpcunds will be a focus consistent with the stated objectives of the study. One, to determine the types and quantities of potential pollutants moving in flea/ systems towazd: lake Michigan. TWO, to define sources and characteristics of potential pollution in terms of urban land use and three, to develop a model to facilitate extrapolation of findings to ether urban settings. It is, however, to be noted that identification is not so much directed toward individual point sources in tots study as toward diffusa origins, that is, the correlation of parameters to land use. 48 WTM0O585 N C R-FOX-0281442 WATER PCB-00044186 In turn, nanufacturing land use would be expanded to industry type according to standard industrial classifications'. Further Iteration would allow quantification of deviations fran the derived calibration-coefficient means by sub-basin. Hie finding , of PC3 levels above limits of detection within the sttdy area is perhaps consistent with ita heavy industrial character, featuring chemical producers, electrical equipment manufacturers, machinery fabricators and transformer switch yards. . - One of our staff is investigating the possibility of in-stream synthesis of PCB's frcm the waste products of industry present in the Watershed. However, since this study is in its initial phase, I will not elaborate except to say that such a source has apparently not been hitherto considered. Certainly the ubiquitousness of this potential origin has much in cecum with the ubiquitousness of PCB occurrence, most dramatically in snow-melt watera. Yet even should such a mechanism withstand further scrutiny, this could not be construed as likely to exonerate other potential sources. '' '. ' Hoping that our center's service is useful to you in the future--the signer is most sincerely, John W. Cioadrich-Mahoney, specialist, water resources, for the Water Besouroes Center, University of Wisconsin in Madison. ' I'd just sort of like to footnote to. that that what could be. said of this is that to the extent that seme industries ape saying that there is a prcblaa of ubiquitousness, it is not to say that this isn't being looked into,. And then toe- second thing right be to say that I vets in a. program, a graduate program in engineering, economic planning and within' that program there tended to be a stress, rather than en money and cash flews, ratter instead in terms of social resources.. And one of the social resources which is not.being properly applied today, the nunber of biologists and chemists such that when the applications cane into Water Resources. Center, the credentials are such that people would like to hire two or three of than, hut they cnly have the funds to hire one. _ of ECB'S. ' And this certainly is a resource which could be increasingly applied to this problem EXAMINER: Thai* you very much, Mr. Tilaan, I appreciate your testimony. Is there ary other person present this afternoon who wishes to make an cml state ment at this time? - (No response) EXAMINER: In that case, Z only have--have tus questions going to'" a declaim will be made by the Department with an anhoinesnent tanarxow. First of all, by a show of hands, how many persons in the rocm feel that they may purchase a copy of the transcript or feel they should have a review of the transcript? Okay. Thank you very much. New, a related question, as Z stated earlier in the introductory rararks this morning. There Will be a written oemsent period regarding the proposed rules and the subject matter of the hearing today. Kw,'a.question has-been raised and I believe it's been raised by, as one party, the Wisconsin paper council, as to the appropriateness of cannenting after the transcript's teen available, so they could have a more detailed, review of what was said. I'd like to know if there's any other parties who have that----ehare that same feeling. If there are, also' could I have a show of hands, of that? ' ' * Okay. This will be considered and I will make an anrnoncement temerrow regarding the ocsinent period and also availability of the transcript. Of ccurse, the transcript is always available fee purchase, but the decision is being made now* as to whether we'U make it available to all matters of the public, at least in limited areas. ' For your information, before Z adjourn the tearing today, the hearing tomorrow will start at 8:30 in the morning and presently scheduled are four or five gentlemen representing the Envircrtemtal Protection Agency or the office of Toxic Substances. So perhaps maty of the questions you-have or information you're locking to can be given tcSacerew. Are there any questions before I adjourn the hearing today? (No response) EXAMINER: In that case, the hearing is adjourned 'til tonserew 'til 8:30. Thank you very natch. (Bearing adjourned) 49 WTM00586 NCR-FOX-0281443 WATER_PCB-00044187 * EXAMINER: Ladies and gemtlsnen, we're resuming the hearing regarding proposed effluent diesharge limitations rules by the Department of natural resources. As in the presentations yesterday, the Department of Natural Resources have asked various people frcra governmental agencies as well as industry to sake presentations on behalf and at the request of this Department. It appears that this morning presentations will be made by representatives of the Errvirormental protection Agency and that the presentations will last the bulk of the naming's testimony. Hus afternoon will be three for public concent and questions may be asked to the 0. S. Environmental Protection Agency, although there will be no cross-examina tion. With that, I'd like to call Mr. Glenn Schweitzer, who's the director of the Office of Toido Substances. . MR. SCHWET12ER: A limited ranter of cepies of ay presentation will be available after I complete ay remarks and particularly for the press. . I greatly appreciate the opportunity to present the views of the Envircrmental Protection Agency concerning the environmental problems associated with the manufacture, use, distribution and disposal of polychlorinated biphenyls. Since its initial days, the agency has been concerned with practical steps that cculd be taken to clarify and reduce the envircrmental risks attendant to caitnercial applications ofPCB's. More recently, the agency has intensified its efforts to help insure that unnecessary hazards are effectively curtailed. Dais, we fully share ycur concerns and we will continue to work with state governments and other interested organizations in seeking feasible solutions to this problem. In view of the background papers that are available and the detailed statements being presented by specialists at these hearings, I will confine ay remarks to a brief review of tte history of the PC3 problem, recent developments which have lead to increased concern and the spread of EPA activities directed to PCB's.'1 I will then cement briefly on a few aspects that are of particular concern to the State of Wisconsin. In May, 1972, tie Interdepartmental Ibsk Force concluded that PCB's were highly persistent, could be found in all parts of the environment, could bioaccumlate in fish by a factor of up to 75,000 and could have serious adverse effects cn human health. The task force urged discontinuance of all uses of PCB's except vises in closed electrical systems and called for early enactment of the toxic substances control act to provide a needed regulatory mechanist to AmI with PCB's and other problans of this type. . largely, as a result of the activities of the task force, the Monsanto Cotpany, the sole U.S. producer of PCB's at that time, voluntarily limited its sales to.manufacturers of i-inccA electrical systsns. Also, EPA psrorptly announced that it would begin restricting the discharges of industrial effluents so that the levels of PCB's in rivers and lakes do not exceed 10 ppt. PDA took steps to establish PCS tolerances for several types of food, ranging frcra .2 ppm in baby food to 5 ppm in fish and to limit PCB contamination in food packaging and in food plants. . As further followup to the task force recairaendatlecis, the General Services Administration amended its procurement specifications to ban PCB's.in paper and the Department of Interior prohibited future use of PCB's in off-shore oil operations. The American National Standards institute issued guidelines fas industry cn the use, disposal and labeling of PCB's. - Internationally, a decision of the Organization for Eooncmic Cooperation and Development, tte CECD, provides that PCB's shall not be used for industrial or acnraercial purposes except in certain closed systens. However, even in respect to the accepted uses, the CECD council that PCB's should he--should only be used when adequate environmental controls are exercised and when benefits cutweight the risks and recarmended that countries work toward the elimination of PCB's in small capacitors.' This decision leaves it to the neater governments to go beyond the council agreerents aid, in effect) invites governments to phase cut PCB uses wherever possible. Japan, in the wake of PCB cantminaticn of rice oil that adversely affected 1,000 people, banned future production or import of PCB's. More recently, the Canadians have begun to collect necessary data for restricting PCB's pursuant to a new Environmental Contaminants Act which should be enacted this year. Now, turning to recent developments. Recent research results have heightened concern over the toxicity of PCB's previously documented in the report of tha Interdepartmental Task Force. Concentrations as lew as 2.5 and 5 pfra have produced sericus adverse effects in monkeys. I believe you discussed- these effects yesterday. A still unpublished report indicates malignant liver ttsnors in rats exposed to cne grade of PCB at levels of 100 ppm. Several reports of chloroacne encung workers exposed to PCB's have also been received. Also, ocncenttations of 5 ppm in fish eggs have resulted in xy mortality. SO VTM00587 NCR-FOX-0281444 WATER PCB-00044188 In considering these effects, it is important to rsasaber that there are eight caonercial grades of PCB'a and their toxicity characteristics may vary to sene degree. However, there is ns basis for assuming that any one of the grades is hot'a potential hazard. As a result of the FEA actions described above, the PCS levels in foods have been steadily declining, At the iTM time, however, the levels detected in fish and wildlife appear to have increased. Available monitoring data fee PCS's in the ambient air, water sediment, soil or human tissues do not provide a good basis for estimating national environmental trends. For exanple, analyses of water samples have, seldom extended into the parts per trillion range and thus only rarely have PCB's been detected. Limit-pri adipose tissue sanples for fiscal year 1972 and 1973 indicate a slight downward trend with levels in' excess of 3 pm being observed. Unusually high levels of KB's have been detected in recent months in the fish and Z needn't tell you this, in Lake Michigan, lake Pepin, the Hudson River and Southern California. PCB's have been detected in sludge from sewage treatment plants as well as in the effluents, fraa these plants. PCB's have been identified in only two drinking water supplies during the past year. There have been at least five water spills involving PCS leakage from.transformers during the past year and currently there are tens of thousands of capacitors, each containing several gallons of PCB's, awaiting disposal. ' VJiile Monsanto is believed to be limiting its sales to manufacturers, of closed electrical systens, information has been received by EPA indicating that PCS reprocessors may be. selling PGS's far other uses. It is believed that-most of the PCS ifiperts,. which exceeded 375,COO pound' in 1974, are not used in closed electrical systems. Among the PCS uses which are known to persist in the United States at present are. applications in investment casting processes, heat exchange fluid and hydraulic fluids. There are a variety of other potential uses of PCB's, although firm evadenoe of such current use is not in hand. With regard to substitutes, J)cw Chemical has developed a product for use in large ' power capacitors, and Dow Coming has a product vhich can substitute fee PCB's in certain transformer applications. At lease one of these substitutes is reportedly being introduced at the present tire in Japan. Mow, turning to reoent regulatory actions, in 1973, water quality criteria were proposed to limit PCB's ,to 2 ppt'in ambient waters; Also a national effluent standard .fear.PCB's was proposed under Section 307(a) of the Federal' Water Pollution Control Act. PCB's were included in the advanced proposal' of a hazardous substances list under Section 311 or the Federal Water Pollution Control Act in 1974, That section relates to spills of hazardous chemicals. Finally, HPEES permits that limit the discharge of PCB's have been issued for at least six. facilities. Preliminary reports indicate that, approximately 10 to 15 other discharge pesuts may contain effluent limitations for PCB's, in addition, the efff.lwnt guidelines.promulgated for the steam electric power generating category contain limitations requiring no discharge of PCS's. A sig nificant percentage of the permits issued for this'category to date contain these limitations. And as you knew, several states are currently considering imposing limitations cn PCB's. mow, I'd like to identify for you the spread of EPA activities currently in progress directed to PCB's. A water qualify criteria level of 1 ppt will soon undergo interagency review prior to final pecnulgaticn. The originally proposed level of 2 ppt has been reduced in view of the rwtent ecological effects date. Detailed dccurentatim necessary to' 'support a national standard for water effluent discharges under Section 307(a) of the Federal Rater Pollution Control Act, is being asseoblte with issuance of a revised national standard scheduled in the tear future. Proposed levels of harmful quantities of PCB's accidentally released into navigable waters ami rates of penalties for such spills are currently being developed pursuant to Section 311 of the Federal Water Pollution Control Act. ' A laboratory demonstration program is underway to develop and test control technology, for treatment of PCS manufacturing wastes, including the aqueous effluent fraa PCB users and the discharge frrm leaks fraa transformers and capacitors. Tte scientific literature oenbeming the health and ecological effects of PCB's is being reviewed. Further, a continuing research program is investigating the-metabolism and effects of PCB's. As part of this program, several studies have examined the effects of PCB's in rats after long-term feeding regimes, especially effects on reproduction, liver function, carcinogenesis, and hemoglobin metabolism. , collection ate analysis of adipose tissues are continuing. Several laboratories have bam conducting research on tee ecological effects ate environmental fate of PCB's. 51 WTM00588 NC R-FOX-0281445 WATER_PC B-00044189 m Studies of the behavior of PCB's in soil, particulary after spills aid tte likelihccd that the PCB's might reach the groundwater, are underway. . Analyses of the technological and the cost aspects of substitutes for PCB's in closed electrical systems have been initiated. Technical assistance is routinely provided on the storage and disposal of FCB-ccntaining wastes. In addition, test burns of capacitors containing such wastes in a high temperature incinerator are planned for 1976. During the last few weeks, a number of additional activities have been initiated in response to the recent concerns that have been raised over PCB's and I'd like to just itemize those right now. , The National Academy of Sciences has been requested to give special attention to whether a drinking water standard for PCB is needed. Meanwhile, monitoring far PCB's in drinking water supplies is being expanded. -' Information concerning the best campling and analysis techniques far PCB's in different media is being assembled and rendered to provide guidance to the regions, to the states, to contractors and other interested organizations involved in monitoring. & limited number of ambient air, water, sediment, soil and fish simples are being collected and analyzed throughout the country. This data, together with existing data, will pro vide an up-to-date overview of the current levels of environmental contamination of PCB's. m response to local concerns, several regions will be measuring PCB levels in effluent Streams from industrial and municipal sources, receiving waters and associated fish pop ulations to assist in relating specific discharges to environmental levels of particular concern. information concerning the use and distribution of PCB's and the level of PCB's in effluent discharges has been requested fern 84. ccrpanies, which are believed to handle PCB com pounds or mixtures in their operations. These .requests for information have been made pursuant ' to EPA's authority under Section 308 of the Federal Hater Pollution Control Act and Section 114 of the Clean Air Act. . A special review of past and recent data to assess the carcinogenic potential of PCB's is underway. ' Test data on the chemical properties and potential biractlvity of substitutes for PCB's have been requested from Dew Chemical and Dew Coming. nparted PCB's and polychlorinated terphenyls are being analyzed to identify possible contaminants. In addition, the techniques for detecting PCB's, FCT's and polybraninated biphenyls are being to determine whether interference among the substances prevent reliable analysis for any one of them. . General guidance for disposed of wastes containing PCB's will be developed. The Department of Defense, the General Services Administration, and other agencies are being requested to review and to amend as appropriate their procurement specifications and those of their contractors concerning the purchase of PCB's and materials containing PCB's, Consultations with the Japanese Government are being initiated concerning their experience in implementing a ban on the production and impart of PCB's. Consultations with the CECD governments are continuing in an effort to determine the effectiveness of the 1973 decision in reducing the PCB problem on a worldwide basis and to encourage expeditious carrying out of the provisions of the 1973 agreement. And finally, consultations are being conducted with the Canadian Government to inform them of our information and activities concerning PCB users in Canada and to coordinate future actions. Mow, the remainder of cy statement I would like to direct to those questions that were specifically identified by the State of Wisconsin of being special interest diking these hearings. First, with regard to the aquatic envirerment, EPA considers a PCB concentration of 1 ppt in the ambient water environment represents an. appropriate goal fee the natien. This conclusion is reflected in the Hater Quality. Criteria which are currently undergoing final review prior to pccsmiLgation and will be elaborated further by another EPA representative later this morning. We would suggest that this goal serve as very broad guidance in developing strategies on a nationwide basis and locally to control discharge of PCB's- into our waterways. 52 WTM00589 NCR-FOX-0281446 WATER PCB-00044190 However, we are not prepared at this time to provide more specific guidance on tre control strategies that should be adopted nationally or locally concerning the regulation of individual dischargers. He are developing a nationwide strategy with a significant oaqwient of our approach to be reflected in a revised trade effluent standard for tea's scheduled for proposal early next year. At the same time, we recognise that a nationwide standard might not be adequate in addressing local problems in seme areas euid the Control strategies adopted locally may of necessity require an elaboration of the national approach. In any event, we believe that better infonnatim is reeded concerning the specific facilities discharging into the aquatic environment before reaching a final judgement on a national standard. Also,- it is important to clarify the portion of the PCB contamination problem which can be attributed to specific dischargers and the practical feasibility of reducing'the discharges. As a key step in this regard, on August 16 ve requested from 84 eatcaiu.es detailed infonation concerning their activities involving PCB's including details on their uses of PCB's and mcnitoring data in the effluent stream and in the receiving Waters. Kith this infotmatim in hand, we believe we will be in a much better position to develop meaningful regulatory approaches which take into account the realities of current industrial activities. Now, turning to. the Toxic Substances Control Act, as Z have indicated, EPA is currently utilizing or preparing to utilize authorities tinder the Federal Hater Pollution Control Act .which address the problem of effluents and spills containing PCB's in an effort to reduce the envircnnental levels of PCB's. Additional authorities may also. be used if warranted by further information concerning levels of PCS*3 in drinking water or even possibly in air. Ecaever, each of these available authorities has a limited focus and none provides the most, critically needed authority to limit selected uses and distribution of PCB's.. Indeed, even with the cooperation of Monsanto to limit production as well as the use of existing authorities, it seems clear that the PCS problem will continue to persist in sane form. . Under the pending Thxio Substances Control Act, however, EPA would have the needed authority and could deal with the problem in a. far sore effective manner. In addition, authority --in addition to authority to restrict the production and use of PCB's, the legislation would, if necessary, enable EPA to require testing concerning the health and ecological effects of the proposed substitutes for PCB's. _ . . . With regard to the limitations that might be considered under this.' legislation, the 1972 .Task Force Report concluded -that there were appropriate substitutes, presumably at reasonable cost, for all nonelectrical uses of PCB's. Ka have, no'infeoetion which would contra dict this conclusion. However, we currently are carefully analyzing each PCB use and the technological, environmental and cost aspects of possible substitutes to insure the soundness of that original conclusion. Also, We are carefully-reviewing the recent developments cehbeming substitutes for PCB's in closed electrical systems before reaching oiir final conclusions concerning the extent and character of limitations that would be . appropriate under the toxic substances control act. ' He are optimistic that we will have this new authority within a far tenths, but as you know, further moygnent in this regard rests with the Congress. . Finally, one key aspect of the Bade Substances Control Act should be emphasized, namely the authority to review new chemicals before they are marketed and, if. appropriate, require testing or take steps to limit the production or use, if there is reason to believe a .hazard to toman health or the enyiroment might ensue. This preventive or front-end approach to the control of chanical hazards would provide a far more reasonable and more cost-effective approach than current efforts to correct problms after the damage has been dona. Not only would the public benefit from the esvizonnental point of view, but also the economic costs to industry would be minimized by taking actions prior to the time that major investments would have been made. It is clear that the past policies of allowing uncontrolled proliferation of chemicals such as KB's into tbe environrent, chemicals which have proven to be both persistent end hazardous can no longer be tolerated. ' . . With regard to the experience in other countries, which is of interest to. you, we do have sane information frail Japan which I would like to report to you. The most relevant foreign experience in regulating PCB's has probably been the recent effects in Japan where PCB'S have been under government regulation since 1972. The Japanese Goverrmant has recently provided us with sane preliminary insights as to their experience. The following cotments axe based on Initial reports we have received and ve plan to obtain more definitive information in the near future. According to infsanation just provided by the Japanese Government, there has been practically re production, import, or expert of PCB's in Japan since 1972. .The only two eatpaniea which had been producing PCB's in Japan stopped production and suspended sales in early 1972. . S3 . ' wmaosao NCR-FOX-0281447 WATER PCB-00044191 J. Cne exception has been the production of PCB's fee railroad transformers which was discontinued is Septofcer, 1973. Dse of existing stocks of railroad transformers and condensers, but no new equipment using PCB's is pennittad. Even this limited use is subject to the restriction that i discharge of PCB's to the environment may occur.' Beginning in 1976, paper plants will be prohibited fran accepting PCB contaminated paper for recycling and such plants will be required' to build . treatment plants which will meet general discharge standards. Further, we understand that the assart of equipment using KB's has also been virtually eliminated as of September 1972 and for these few products which have been permitted into the country, importers must cooperate with the ultimate users to insure that the ccngonents Containing PCB's are recovered and properly disposed. Disposal is regulated by the Waste Disposal and Public Cleaning Control law which was amended in February, 1975 to include PCB's. Currently there are no regulations for labeling or handling PCB's. The present limitations cm the use, import and export of PCB's are based cn Article 3 of the Chemical Substances Control Law which went into effect cn June 10, 1974. Any manufacturer who wishes to produce PCB's in the future must apply to tle Ministry of International Trade and Industry, although approval of such a request is regarded as highly unlikely. The Japanese Government projects that a total ban on PCB's will' take effect in approximately six to ten years, when the current stock of equipment containing PCB's is exhausted. The Japanese has established PCB contamination limits for fish and shellfish of 3 ppm far near-share varieties and .5 ppm for ocean varieties. These limits are derived frem a basic limitation for huran intake of 5 milligrams per kilogram of body weight per day. Guide lines first set in 1973 for water quality and bottom sediment were revised in February, 1975 to hot detectable, defimi as less than .5 ppb for ambient water and lb ppm far bottom sediment. These stardares are not necessarily permanent standards, since they were set with current monitor ing capabilities in mind. Under the water Quality Centrol Law, the authority used in setting these standards, penalties are imposed for exceeding authorized limits. Monitoring of the water quality and bottom sediment by each prefecture is Required by this low. We have only very sketchy information concerning effluent limitations in Japan. According to the reports we have received, the Japanese Prime Minister's Office Ordinance based on Article 3 of the water Oaality Control Law sets the mwtiniffi permissible PCB oonsentration in effluents at the point of discharge into rivers at lakes at 3 ppm. Coupled with this limitation is a provision authorizing a penalty fee exceeding the effluent limit. The environmental levels of PCB's in Japan have subsided in the last two years and are expected to continue to diminish. In a 1974 survey of bottom sediment, including over 1,700 samples, 14 samples had PCB concentrations of over 50 ppm, 37 of 10 to 50 pprr. and 21 of 5 to 10 pjsu In the previous year, seme PCB levels had exceeded 10,000 ppm. Mo such peaks were found in 1974. Concentrations of PCB's in the milk of mothers were down' over the previous two years, although 25 percent of the sanples were contaminated. The Japanese Association far the Disposal of PCB's is responsible, along with local Govexments, for the collection and temporary storage of household electric appliance and other electrical equipment containing PCB's. The association will develop PCB treatment technology and treatment plants for disposal, although the latter effort has been delayed by public opposition to .the. select!TM of proposed treatment plant sites. Substitutes for PCB's that are currently in use in Japan include for carbonless copy paper, alkyl napthalene and alkyl pbenyleihane for heat transfer, diphenyl, diphenylether, alkyl diphenyl, alkyl naptbalene, alkyl benzene and mineral oil and for transformers and capacitors, mineral oil and silicone oil. In conclusion, I would like to stress that EPA intends to continue to give high priority to the problem associated with PCB's. The recent data on toxicity and levels of environmental oontaminaticn have heightened our ooncesns and have stimulated considerable ns* activity. Much is known about PCB's and much more will be known in a few months as cur current data collection efforts are brought to fruition. In recognition of the national interest in the PCB problan and particularly the interest in the Great lakes area, I am pleased to announce that in late fall, EPA, in cooperation with other federal agencies, will sponsor a national synposium in Chicago to further clarify selected aspects of the PCB problem. The State of Wisconsin herewith receives our first invitation to participate. I'll be pleased to try to respond to questions if that's in order. EXAMINER! Thank you. Do you have a copy of your report, sir? 54 WM0O591 NCR-FOX-0281448 WATER PCB-00044192 ,3l. SCSHEISZER: Yea. -p.-rjOTER: Thank yew very much. Boes the Department have any queetiais of Mr. Schweitzer? MR. KIEINERT: Mr. Schweitzer, I'd like to address sene questions to the effects e the EPA to establish effluent standards for PCB's. Earlier EPA had proposed an effluent standard far ICS's aid Z understand fret-, your cements here this morning that this general, standard concept isn't sonmthiag that you're pursuing right now. You're mere or less looking at industries as groups in trying to reach limitations on discharge; is that .correct? MR. SCHSffirrZER: I thinh what you're saying is correct, hut I'm. not sure the implication is correct. We have not necessarily abandoned the notim of a national---we are . planning to propose a national standard for PCB dischargers. Whether that, standard will he a series of numbers directed at specific types of discharge or whether it will be one nurfcer is undecided at. the present time. Zs that responsive to your question? . MR. ktptwbrt: .1, think so. What is the timetable dr could you make an estimate when effluent standards would he established nationally? . . MR. SCBHEITZER: The timetable for proposing a standard is late February, z cannot' give you a mere specific--I can't give you a timetable on when this data would be prdsulgated final or when it would to into effect; .1 think the pronulgaticn date depends largely on the reaction of the interested, parties and the public to the proposal and the length of time that the hearings would taae. The date at which the center would he. effective would, depend on whether or not the finally promulgated standard is challenged- and if it is challenged the time that the court litigation takes. So i can't give you a date for when the standard-would be prcnulgated final, nor wten it would be effective, given the uncertainties involved in going fron a proposed standard to cne that's in effect. , * MR. KTKTWEgTi z have another question on your cements on the Japanese actions. I believe you indicated that the Japanese have established an effluent standard of three parts per million; is that ceerect? . MR. SDSEITZERs That is the report that we have' received from the Japanese govern>ment. We have--it is.a preliminary report; it has hot been cemfixmed and I really don't tecw what it--Z raised my eyebrows when X saw that norber myself, but I wanted to give you what we have ard that's all we have and we have not.confirmed.it. But we do have a report which soys that. Yes, sir. ' MR. lOEUffiKT; Okay. Thank you.. BOMZKER: Mr. Schweitzer, just one quick question before X open the rest of the program up to questions, you stated that there Will be a national sympesias in Chicago in late fall. Bo you have any tentative date---definite data for that symposim. MR. SOSiEXTZSU November. EOMIHER: Ckay. Thank you. New, ladies and gentlemen. I'll open it up to questions, please try to confine your questions to remarks Mr, Schweitzer made. There will be technical people here from the--from EPA. MR. SCEKECrgER: Mr. Chairman, may 1 make one--*-if there are any questions of a policy nature, I would prefer to take them at this time. There are--technical people will be happy to answer technical questions, but if they're policy questions, new is the time to ask them. . ' .' tSAMZHEK: Ckay. Fine.. Would anybody like to ask him questions? . VOICE* Are copies of your statement available? MR. SOKEITZER: We have a limited muter. X think that we had saoething like 20. X just------ . EXAMINER: All right. The question wes whether there was copies of the statanent and Mr. Schweitzer's response was approximately 20. . Aiiy further questions? (No response) 55 VM00592 NCR-FOX-0281449 WATER_PCB-00044193 s EfflMIHERt Ckay. In that case, thank you very such, Hr. Sdseitzer. Is Mr. G. D. Veith present? . Please identify yourself and who you represent. MR. VEIUI: My name is Gilman Veith. I'm a research chemist wdth the Environnental Protection. Ageixry at the National Hater Quality lab in Duluth, Minnesota. My duties there involve the development of analytical methodology fdr isolating and identifying persistent organic chemicals in natural waters and aquatic organists and research ccnceroirg the bioconcentratim of organic chemicals in aquatic organisms. . My testimcry today will be taken frtn cespleted and ongoing research and it will show that the PCB's are bioaoncentrated in fish by factors greater than. 100,000. it will enphasize that the PCS residues resulting bioconentratirg from 10 parts per trillion of PCB's in the water have jeopardized the food resources of lake Michigan and will discuss, in part, the rationale used for tie ere part per trillion water quality criteria for PCB's. There are really three points I'd like to make today and cur bioooncentxation studies have shown these. The first is that bicaecuraulaticn of PCB's in fish can be modeled by phamaketics and appears to respond to a first order uptake model. The second is that the residues in the fish at steady state, being saaewhere in the order of 30 days, is directly related to tta water concentration that they are exposed to and that the decrease in the cf the fish residues canret be expected without a decrease in the water concentrations. Third, cnce PCB's are accurrulated by fish, pUnrfTaHnn of the FCB residues is immeasurably slow in elimination studies exceeding three menths. Consequently PCS residue concentrations--I use the word concentration rather than total burden or a residue. The PCB concentration in fish frem contaminated waters decrease only by dilution of body mass through growth. _ More Important than the direct toxicity of PCB's to aquatic organ!ms in establishing effluent regulations for the protection of the environment are the extremely high fat solubility and persistence of these chemicals. Research during the past five years has shown that although PCB's exhibit acute and chronic toxic effects in fish at concentrations txnparable to those of other chlorinated chemicals, the high fat- solubility of the PCB's caused fish to accmtulate hazardous residues, that is, with respect.to consumers of the fish, from water concentrations far below the concentrations that affect the fish directly. This tendency to form residues con.PCB's in water is measured by a concentration fat bioconcentration factor, which is a ratio of the concentration in the fish to the concentration in the water and the bioooncentraticn of PCB's in fish far the mare highly chlorinated compounds, exceeds 100,000 times the concentration, in the water. - The second property of PCB's is the fact that these chemicals do act degrade is the aqueous environment as rapidly like the hulk of the natural chemicals which yjqrisa wastewaters. The resistance of these chemicals to' degradation causes then to persist in waters far belrw the dis charge and the accaculation of residues in waters such as the Great lakes nay be, in fact, directly related or the direct result of KB usage many miles frtm the lake. ' The terms "degradability", "mare degradable" and "ncndegradable" have all been applied to PCB's. And the data show that only the PCB's containing one and two chlorines have been degraded by mieroerganisss in natural water systems and that PCB's containing three and four chlorine atars to those of Aroclar 1016 and. 1242 have shevn sane selective degradation, as well as ocmplete resistance to degradation under wastewater treatment conditions far periods of time far exceeding those oaimonly eaplcyed in waste treatment facilities. Equally inportant, any reservoir water tends to accumulate PCB's in the biota and the sediments. They act more or less like any biological reservoir acts, like a fiord. Con sequently, low level discharges may lead to a growing accumulation of PCB's in large water systems, such as the Great lakes. ' Regarding the bioocnoentraticn studies that we've done, an understanding of the bioooncentxation of chemicals in organisms is essential to. understand the dynamics of these chemicals in the enviresment. Ocsmlderahle confusion exists regarding the relative significance of various update mechanisms, due in part to the absence of detailed definitions of the fystaa's study. Much of the early literature assmed that bioconcentration in the aquatic enviroiroent was haBud <au tdie trophic level or food chain, concepts. However, exposures of fish to water containing these hydrophobic ehssieals danenstxated that fish can bioconcentrate cheaicals directly from the water. Update on be approximated by a first order rate process and that process apppeared to be that of cfaanical partatiming fitm the water to the lipids in the animal. Otis has led to proposals where food 56 WTM00593 NGR-FQX-0281450 WATER PCB-00044194 chain biccorcentraticri----the food chain bioccrxssntration medal ia rejected in favor of a chemical partitioning model. As with many kinetic models in dynamic systems, multiple pathways are often observed and the relative significance of the various rate expressions is really dependent on the conditions imposed. Therefore, the selection of either a food chain model or a chemical partitioning model for the aquatic environments requires that the conrlitinns of the ecosystaa be considered and defined. She biocchoentratien of PCB's in laboratory studies where the mixtures are added ' directly to the water have been, studied for numerous aquatic organisms and the observed bio . concentrations for PCB's varies with Organisms of different lipid content and different exposure conditions. ' I'm including two--ifippendix I and H, which are studies by Nebeker and DeFoe at the Duluth laboratory' as well as a paper of ay owi that show that the bicccnentration for Aroclor 1254 in fathead minnows ranged from approximately 110,000 to 240,000 and that the bieconcentraticn factors for predominant PCB mixtures in the fathead minnows, that ia fish enerally less than ten percent.lipids, at 25 degrees, ranges frda 30,000 to approximately 250,000, That is, what I'm describing here is the range that we've seen for the ccmrcnly encountered PCB isomers and as you get sen highly chlorinated, the hibooncentration factors are greater. '. . in. 1370, the annual report of the Fish Pesticide Research lab in Columbia, Missouri, showed that the bioscncentzaticn factor for Arcelor 1254 in. the scud was approximately 22,000. It was also 45,000 after 48 bouts in Daphnia macna and 13,000 in mosquito larvae after only 24 hours. What I'm trying to do. here is just desan}*--there's a lot of organists that have been studied and they all seen to be in .sanewhat of the. same range of exceeding 10,000 and over 100,000. After 60 days in an -exposure to Aroclor 1242 and Aroclor 1248, the'maxinun bioconciemtraticn factor in Ganroarus was found to be appraxirately 3C,000 and 50,000, respectively. Also, the bioccncentraticn factors ranged fron 20,000 to 60,000 for blupgllls and catfish eaqosed to Aroclor 1248 and - Aroclor 1254. Sane evidence exists that the biooonentration factors measured in the laboratory are essentially the 6ame as those found in the river .erwiroixnent. Far example, appendix shews that the laboratory derived bioconcentration factor for Aroclor 1248 in fathead minnows range from 100,000 to 240,000. Appendices in.and IV is.a.report on PCB's in the Milwaukee River system and the near-shore environment of Lake Michigan, report that goldfish in the lower Milwaukee River accumulated'Aroclor 1248 approximately 70,000 to 200,000 times the estimated PCS concentration in the water and that difference is dependent largely on the fat content of the fish. In May--in the May, 1573 report to the Lake Michigan Bade Substances Coimittee, the Michigan Hater Resources caanissibn presented evidence that the raaxinaa-concentration of Aroclor 1254 in the Saginaw River shad was 165. micrograms per gram, whereas typical water concentrations were about one microgram per liter to a maxima of 2.9 micrograms per liter. This is equivalent to a hioconcentraticn factor of 60,000 up to perhaps 150,000, which seems to be in good agreement with the laboratory-derived ccnumLraticn factors. ., Also presented in this report is data to shew that the concentrations of PCB's in the intake waters in the mmicipalities along the Lake Michigan shore are, with one exception, all below' ten parts per trillion--ten ng per liter. This indicates that the maxima ccncen--bioooncentxation factor for saelt in the lake where the main concentration is an the order of 2.7 mierogrisns per liter, is approximately 300,000. Kid that the maxima bioocncentratian factor for large trout may be as high as 150--or 15 times 103. So that's 1,506,000. Appendix V presents data concerning the mean concentrations of PCB's measured in Lake Michigan--or Lake Superior fish captured in 1972 and 1973 frem western Lake Superior. The data indicate that the PCB concentrations in smaller, low lipid fish, contain up to approximately 1.5 mierbgfams per gram--parts per million, whereas a large trout' PCB's in large trout have been measured up to 5.6 micrograms per grasu . . Also presented are estimates of PCB's concentration in the western Lake Superior water intake and a bioassay control tank of the national Hater Quality Lab in Duluth. These estimates were made using a foam plug extraction technique in triplicate, perchlccinating the. detracts to fom decachlorohiphenyl and measuring the deeachlorobiphehyl formed. The data indicate that approximately one to two ng or parts per trillion of KB's, measured tut Aroclor 1254 are present in the western Lake Superior near-shore waters. ' The mean concentration of the smaller fish of the order of .9 micrograms per gram, which would indicate an overall bieecneentration factor in Lake Superior fish of approximately 900,000 or--that's right. 57 WTM0O504 NCR-FOX-0281451 WATER PCB-00044195 m In sanmary, the data frctn the Great Lakes demonstrate that tie PCB's are present in the waters of late Superior and late Michigan at concentrations below ten parts per trillion, but the concentrations of K3's in the fish are more than 100,000 times the measured concentration in the water and that the PCS residues which bioconcentrate in fish fran water concentrations below 10 ng per liter have produced PCE residues in lake Michigan fish particularly that are significantly in excess of the PDA tolerance of five mierograms per liter and more importantly, the effect level of oansuoers, such as minks and subhuman primates. ' . And I'd like, to introduce in the record at this time one correction that was made yesterday. I believe someone attributed the mink feeding studies that have gone on to the National Water Quality lab in JXlluth and this is an error. We haver--to my knowledge have not mink feeling studies, but the two major groups that are doing this are Bob Ringer at Michigan State University, working with the mink ranching and Platteneau at the University of Welton ` in Canada. Mow, concerning the ratimale far the water quality criteria farPCB's, it has been stressed that the rationale for water quality criteria for cumulative chsaicals, such as PCB's, ccnnicer the result of environmental monitoring programs in order that the ramifications of the criteria can be assessed. Data cn PCB's in the environment indicate that the large bioaceuaulatiom factors produce residues which are of primary importance. Far example, as has been discussed, Kebekcr has sheen that .45 micrograms per liter of Aroclcr 1254 produced 50 percent reduction in midge reproduction; 1.3 miexograms per liter prcduced 50 percent reduction in Dephnia reproduction: 1.3 miexograms per liter produced 50 percent reduction in fathead minnows. DeFce, in Appendix H that I'm including here has shewn that approximately 300 parts per trillion of Aroclcr 1243 and Arcelor 1260 were the highest concentrations not preducting a discernible effect in the fathead minnows. And although the 300 ng or parts per trillion of PCB's is an approximate no effect level for these fish species studied, the residues acctnulated in these fish at that concentration Of the water was approximately 250 parto per million in the animal. Although the 300 parts per trillion did not produce a statistically significant chronic effect in the fish, the residues accumulating in this fish at this concentration would prohibit the use of this fish as a biological resource for hunans due to the PDA action level of five mierograms per gram. Moreover, in this 14 and a half parts per million of body weight of Aroclcr 1254 in the diet of coho salmon have caused carplete mortality after--in 240-day feeding, studies, suggesting that the high residues in mall fish may endanger predator fish. Since FCB residues are an important--a more important consideration than direct effects on aquatic organisms, criteria are proposed by considering residues in relationship to the IDA tolerance level of five mierograms per gram. In NWQL experiments, the residues in fathead minnows closed for 20 days at 300 parts per trillion were approximately 250 Farts per million. TO assure the five microgram per gram or parts per million residue is net surpassed, the concentration of PCB's in the water would have to be reduced 50 fold to approximately six parts per trillion in the water. That's case one. Case two, the mean concentration of PCB's in Late Michigan coho salmon is approximately 15 parts per million and Ringer et al that I just alluded to, have shewn that these residues cause carplete mortality in the mink. ."These data indicate that two mierograms----that these data indicate that two mierograms per gram of FCB'a in coho salmon should be a jraxinm concentration fed to mink. "She concentration of PCB's in the open late Michigan is estimated to be less than 10 parts per trillion and to obtain the residue tolerance proposed by the FDA for late Michigan fish, at least a three fold reduction, even if the levels are at ten parts per -trillion, a three-fold reduction in the water to a mnximun of 3 ng per liter cr mere--3 ng per liter or mare likely less than 3 ng per liter would be necessary for this reduction to the FDA limit. To attain an eight-fold reduction in the fish residues for mink feed, 1 ng per liter is likely to be the largest concentration possible if these fish are to be used far mink feed. Concentrations of PCB's in western late Superior has been estimated to be .8 of a ng per liter, with approximately 50 percent relative air. The mean concentration in Late Superior fish range cem below 1 microgram per liter to--in the smaller fish to 3 mierograms per liter. This is a mean concentration now in the larger trout, tbwever, a larger trout presently contain --sane larger trout presently contain mace than five mierograms per liter. This suggests that increasing the water concentration to 2 or 3 ng per liter would therefore jeopardize the cannereial marketability of the lake Michigan fish, if not the entire ecosystem. Because of tisa mounting evidence, such as the above fwm bath field aid laboratory studies on bioeoixentxatiens of PCB's and the adverse effects of PCB residues on the aquatic resource consumer, proposed water quality criteria for KB's is cm part per trillion,, 58 NCR-FOX-0281452 WATER PCB-00044196 EfflMHER: Do you have a copy of that? MR. VEITH: Yes. EXAMINER: Cfcay, Does the Department have any questions? MR. KLEINERT: Dr. Veith, I'd like to ask a question about the fonn of the KB's in the fish. The higher percentage chlorine Aroclcrs are camcnly found in the fish, the 1254 and the 1248. Yet we find in our monitoring that a lot c the KB that we're identifying is 1242. Is there a selection in the retention in. the fish of the various kinds of PCB's? - . MR. VETIH: Hell, as I---there's probably two problems here that wa have to identify.. One is that yai have to he certain that ycu're analyzing the water that the fish spends most of his time in and then you can't be certain that the fish isn't going into harbors'. So that often times if Arcelor 1242, for example, is monitored in a river system, you can't, you knew, expect necessarily that you're going to find Arcelor 1242 as the predominant KB mixture in the receiving water, such-as Green Bay cr lake Michigan dr the Great Lakes. . A second and mace important consideration is there, ia-- there does seen to be a preferential csr a higher hiiyiomwulnticn of the more hrrhly chlorinated KB's and as. I indicated, the range for Arcelor 1242 up to Aroclor 1260 seems to La on the coder of between 30,000--all of than fall in the range of 30,000 to 250,000. And--so teat given equal quantities of these two cteraicals in the water, you oould expect to find twice as much Arcelor 1254 in. the fish as ycu oould of the mare--the lower chlorinated compounds. And coupled with that is a cqarcn practice of the ctemist to dilute the extract ia the fish analysis so that the major peaks are on scale . and that this does is it means that the mailer peaks, that maybe they're actually in greater quantities, are neglected, and the electronic capture response for a gas chnnatograph increases very remarkably as you go up adding more, chlorines. It just makes it much mere sensitive so that. you can detect smaller quantities of Aroclor 1254 then yew can Aroclcar 1242. And so that coupled with this--with the .increased bip&beunulaticn and then the techniques of the chemist to scale to the biggest peak to quantitate, they essentially ignore peaks which are--look minor, hut on a mass weight basis they definitely aren't. And it's, oarpletely inaccurate to say that the 2, 3 and 4 chlorine PCB's do not exist in lake Michigan. It's true that the predominant uuupuunds that are observed by gas Chromatography resanbla Aroclor 1254, but we have presented evidence--COS analysis clearly shew that the die, the tri- and the tetrachloro isonars are there and so these canytwids aren't mysteriously disappearing frm the environment. ' . ' ..... . I mean that may be- an incorrect statement. I can't really say that they are not disappearing, but at least they are present; they are not shewing uq> in the larger lake systems. . MR. KIEBS39: Thank you. * EXAMINER: Can we obtain a copy of that? MR. VEITH: Yes, sir. .` EXAMINER: Okay. Thank you. Does anyone else have questions of Mr. Veith? ' - Please approach the front and identify yourself. . MR. SCHRACCNAGEL: My name is Schraufnagel, Department of Natural Resources. X have a question------ , EXAMINER: Speak into the mike, please. That way we can tear what you're saying.. MR. SCEBADF1BGEL: The question X have is X follow ycur reasoning on the one part per trillion, but is there any difference cr variation for more eutrephic waters, or waters that have mere sediment, for instance, the Mississippi River cr lake Winnebago. Do you think that would make ary difference on the magnification or the amount in the water that would accaailate in the fish? .. . MR. VEITH: Well, x guess X don't have any evidence to directly relate eutrephic waters with the bioocncentraticn, but. there does seen to be, you knew, sane evidence that the-- state -c aitrophicaticn of a body of water will effect, the KB concentration in the water. That ia, you'll have just a lot more organisms present to adsorb the material out of water. The bloaeaumilatlan is in aU of the organises in the water. As to the availability and X guess the question to be raised would be the availability of adsorbed material or whether or not there's---if ycu measure the total water sample, the ervaila- 59 . NCR-FOX-02814 WATER PCB-l -a bility of all of the pcb's present and I don't know that this la a question to be considered, for example in the lake Michigan, lake Superior systems. However, in the river systems, as I nmntioned, the Milwaukee River systm, and especially 19 above Estterbrcok Park has large masses of algae. In fact, they' usually get the algae hloaas in these reservoirs where these fish were taken fraa and so I don't knew---I cannot say with any data that the presence of suspended material in the river does or does not affect the bioccncentration factors and this is a very hard thing to get a h*nrn cn and 1 think it's the main reason for looking for field investigations that would help to verify the--help us to interpret the laboratory results that we're getting. MR. saffiAIffNSGSLs Cue scare question and that is the range of reliability on your tests in water. Hew--with what results--accuracy of results can you get in tte one trillion --one part per trillion range? . MR. VEITH: Hell, I think I indicated, certainly when ycu get down at that level, we have, I think, approximately a. SO percent relative air in the data. And the'waters, I think, can be routinely measured. Bis is--I'm speaking of lakes and same streams can he routinely measured--well, have been for five years, on---at apnrodirately 10 part per trillion level, tut of course, well, I believe I could perhaps defer that'question to a speaker later cn who will dis cuss the analytical methods, but my feeling would be that that is the option of a chemist, is to consider the sample that he's analyzing and do--use his discretion to came up with the--what he can say and what he can't say about the sample. MR. 9CBRN3FHAGEL: Thank you. BiAMXKER: Thank ycu, six. Does anyone else have questions? (Ho response) EXAMIKERs Okay. In that case we're going to take a five-minute recess so we can' arrange to copy of----the statanent's that Mr. Schweitzer mads. Thank you. (Reoess) BOWDSERs Okay. Cn the record. . He'll continue with the presentation by request and cn behalf of the Department of Haturel Resources and I'd like to request Mr. Fairless. Is he present in the roan? Before this gentleman gives his presentation, we are getting copies of the state ment made by Mr. Schweitzer. If there aren't enough, we'll try to get rare and if that doesn't even work cut, we'll take the names and send copies of those who need them. Okay, sir. * MR. FAZREESSs My name is Billy Fairless. I'm deputy director of the Central Regional Laboratory, Region V, u.S. EPA, My statement will describe -the analytical procedures that the Central Regional laboratory uses to perform routine monitoring analysis far pcb's and other pesticides. He collect one liter samples in glass bottles with teflon lined screw caps. The first portion of an extracting solvent is used to rinse cut the bottle and is added to a -two-liter separatory funnel with the bottles. The samples are extracted twice with 100 milliliters of 15 percent volume by volute ethylether/hexane and once with hexane. The extract is dried with sodium sulfate concentrated to about five milliliters in a Kudema-Danieh evaporator. The volume is then reduced to four milliliters using a stream of dry filtered air, Miiwtnd to exactly four milliliters and split into two portions. Portion I is spiked with phorate placed in a two mini lifer vial, fitted with a screw cap and analyzed far phosphorus-containing pesticides. The analysis is performed on a perkln-Elmer model 900 gas chromatograph using a flarae-photcmctric detector in the phosphorus mode. The instnxeent is equipped with an automatic sanpler suggested for a 10 microliter injection and a Perkin-Elmer PEP 1 gas chromatographic data reduction system. He use a six foot by onefourth inch glass colutm packed with 4 percent SE-30 and 6 percent OV-210 on 80 to 100 mesh gas chran Q .fax the original analysis and a feat by one-fourth inch glass colixxi packed with 1.95 percent CV-17 and 1.5 percent OV-210 on gass chran Q 80 to 100 mesh far confirmation. Gas ehxacatograph conditions are as follows: the inlet temperature is 250 Centigrade, detector temperature is 240 degrees Centigrade. The oven is programed fraa 200 degrees Centigrade to 265 degrees Centigrade at four degrees per minute. Carrier-gas is nitrogen at a flow rate of 60 milliliters a minute. The saeemd peetim o the extract is placed cn a coluae s FlorisU, with one-half 60 WTMQ0597 NCR-FOX-0281454 WATER PCB-00044198 inch of oodium sulfate at the tap an! the bottom of the Florisil for drying purposes. 5X0 fractions are collected from the Flarisil. 5he first is with 200 milli liters of 6 percent ethyl ether in hexane and the second with 200 milliliters of 50 percent ethyl ether in hexane. Each of the fractions is concentrated to less than two milliliters in the same manner as used for the extract, diluted to exactly two milliliters with hexane, with Oieldrin, that's the 6 percent ether fraction, or Aldrin, that's the- 50 percent ether fraction and placed in a 2 milliliter vial with a septan cap for gas chromatographic analysis. . Each fraction frdn the Florisil colunn is analyzed using a Perkim-Ebrerncdel 3920 gas Chromatograph equipped with a two-colusn injector, splitter, automatic ampler with 10 micro liter syringe, two colusis leading to electron capture detectors. And the sane PEP-1 data reduction system is used. Colurhs are both 6 foot by a quarter inch.glass. One is packed with 4 percent SE-30 and 6 percent 07-210. 2he other with 1.95 percent 07-17 and 1.5 percent OT-210, both on 80 to 100 mesh gas chrcm Q. 5he oven terperatore is 205 degrees Centigrade; the carrier gas is 5 percent methane in argon for both coharns. .. A measured aliquot of each senile from the 6 percent.ether fraction which is thought to contain PCB's as based on the gas chromatogram we obtained from that fraction, is removed from the vial and placed onto a column of deactivated silicic acid. She first fraction is eluted with hexane, 45 milliliters and the second with 150 milliliters of 80 percent methylene chloride, 19 percent hexane, 1 percent acetonitrile. Each of these fractions is concentrated to less than two milliliters as previously described, diluted with hexane, spiked With Oieldrin ard placed in a vial for gas chromatographic analysis. The fractions are analyzed fear PCB's and pesticides on a Perkin-Elmer model 3920 dual-column electron capture detection system. A quality assurance program is maintained to measure the precision and accuracy of the results. 5he program includes scheduled calibration of all instruments used in the analysis to insure that they are working properly. 3t> monitor possible contamination of tte. samples while * they are being analyzed, reagent blanks axe run after each step of the analytical process, that's extraction, Florisil chraratography, solicic acid, chromatography and. gas chroratography. Seme sampl es are divided in half and. one fraction is. spiked with a known amount of the compound we're analyzing for. the recovery of the spike insures that there are no unusual chemicals in the sample that would interfere with the analysis. As a final check we analyze three standards with each grap of up to 35 sanples to insure that the total analysis achate is working properly. A procedure similar to this is being used by tee State of Wisconsin, the detection limit fee this procedure I've described is between .1 and .5 mierograms per liter of a specific PCS. Variable detection limit depends on the mount, of .other organic material in the sample. Mplicate analysis, of real sanples. run at different times in our laboratory, agree to within 10 or 15 percent at a concentration of 'approximately one microgram of PCB per liter of water sample. Xn a recent round-robin study in which sanples were sent to the six laboratories---state ' ' laboratories in Region V, that's Indiana, Illinois, Michigan, Minnesota, Wisconsin, the laboratories reported values between 0.82 and 2.2 micrograss per liter fear a sample that actually contained 1.5 miexograms per liter of Arochlor 1254. it's my opinion the chances of misidentifying a PCB using these procedures are negligible if the concentration is above 1 microgram per liter. As a final cchment, I Would note that we can include a chlorination step in the analytical procedure, which chemically charges all of the PCB's to decachlorobiphenyl, If this is done, we lose the. ability to identify the specific PCB's, such as Arodor 1254, 1251, or we can lower the detection limit to between 50 and 10 ng of PCB per liter sampled: Therefore, in summary, it appears that there is no particular problem with analyzing water samples for individual PCB's concentrations above .5 micrograms per liter, or for total PCB's at concentrations above .05 micro grams per liter. ' ' EXAMINER: shahk you, sir. Does the Department have any questions? . MR. lOEINEKr: Ho questions. EXAMINER: Do you have a copy of that presentation? Shank you. Are there any other questions. Shark you very much, six. . Mr. Francis Early. ' MR. EARLS': My nans is Francis Early. Z'a a physical scientist in tee Process Control Branch at the National Bhforwment Investigations Center of the .Environmental Protection Agency. I tm here today to address the prehlsa of reducing the discharge of polychlorinated bdphehyls to public waters. A problem of real concern at this time must be the relatively high discharge oanceateratioas shown certain and ap mills which ara dainking paper. ' 61 . 1OT005.98 NCR-FOX-0281455 WATER PCB-00044199 VOICE: Speak up, please. HR. EARLY: Yes. Fran certain--a problm of real concern at this tine must be the relatively high discharge concentrations from certain pulp and paper mills which deink paper, for the record, let me briefly sketch the general process used for deinkin? paper, a deinking pulp producer buys wastepaper which is carefully selected for the end product which he intends to make from the deinked pulp. These papers are slurried in hot water with wetting agents or dispersants and an alkaline or acidic agent to adjust the pH. Other chemicals are used as required, toceslurried,. the paper, now undeinked pilp, is screened and cleaned to rsrcve undispersed materials, pieces of metal and grit. The actual deintong-usually takes place in a series of washers which are often operated in countercurrent process streams. The undeinked pulp enters the system of washers at one end while the clean water is introduced at the opposite end. The deinked pilp and the dirty water, in turn, are discharged at opposite ends. A primary objective of this process is to recover quality fiber, free fran ink, chemicals and pigments, as required by the needs of the end product peper, one oor more stages of bleaching may also he used. ' ' Where do PCB's enter this process? In the wastepaper which is the raw material for the process. They are discharged with the dirty waiter because they are essentially associated with and attached to tie pigments and are rsmcved during the deinking process. Having removed the un desired materiel, which includes KB's in this case, with water, the processor now is faced wdth a problem of removing the KB's frcm the water before discharge, of recycling the water to tteir process. These waters can be given primary and secondary treatment in order to meet the require ments of the NPEES permit program, which require dose control of biologic oxygen darani and susperdod solids, along with other requirements. He note here that there is extensive literature cn the presence of PCB's in water and their introduction into the food chain. However, few of these--little of this literature " addresses how the KB is present in the water. Dr. Peter Schccr of the Gulf Breeze Erwiromental Research laboratory, in an article which will seen be published in September or October this year, in Higland in the international journal, water Research, has demonstrated that Arcelor 1254 is soluble in water at concentrations of less than .1 part per billion, that this means is that ary of the material. present- in water in greater amounts than this must be either in the foam of attach ments to suspended solids or in the form of an emulsion stabilized by a surface active agent. Since only a small portion of the total amount of FOB material can be in true solution, the limiting--true solution states limiting the discharge of these materials can be enhanced by improved suspended solids removal and effective secondary treatment for the removal of cocygeivccnstining materials. The effect of improved suspended material removal on KB discharge is intuitively evident, since a significant portion of KB is undoubtedly attached to the suspended particles, because all PCB's are extremely lyophcbic in Mater and therefore have a strong tendency to coalesce with other materials of like nature and to adhere to iycphofic sites cn suspended particles. The reduction of PCB's to he gained fay secondary treatment needs a little mare explanation since colloidally dispersed KB not removed by an effective primary treatment probably is stabilized by a surfactant; it sheuld be very sensitive to biologic treatment. TO estpand, the dispersant cr surfactant which is sabi It zing the PCB particle must be biodegradable, since natural surfactants are' biodegradable and by national policy, all axmercial surfactants must be. Since the surfactant"--once the surfactant has been degraded far enough to destroy its ability to emulsify and stabilize PCB particles, the KB removal problem or solution becomes the same as in the primary treatment except the suspended material that will carry tte PCB will be the biomass, which in the secondary clarifier or stilling basin will cany down the PCS. This fact is confirmed by recent data fran California, which show PCB sludge magnification factors of up to 9--of about 9 to 1. Although PCB's may' have been ingested by the organism of the biomass, it is likely that it is just carried down as with the biomass. In either case, it will he effectively removed from the water with the secondary sludge. In conclusion, I think we can say that although PCB discharges from these deinking paper mills now tend to be rather high, we can look forward to eignifleant reductions in discharge concentrations as the programmed and projected treatment systems required by tte NPDES program became effectively operational. Thank you. KXAMlNEK: Thank you. So you haws a oepy of your report? MFU S3MXt Yes, 1 do. 62 NC R- FOX-0281456 WATER PCB-00044200 EXAMINER: Any questions? Co you have any questions? MR. KIEINSEE: Mr. Early, from your gjimenta, it's your belief that the removal Of suspended solids or the effective removal, of suspended solids will tad to effectively the JPCB'sj is that ooxrect? .. ' . '. MR. SARIS: Yes, remove a portion. I'm not sure howimah. . MR. KIEIKERT: Hie other factor involved in addition to removing tte suspended solids is the second part of the--- MR. EARLY: That is correct. She biologic treatment system--an effective biologic treatment system. ' .. '1 EXAMIKER: Those questions were put to Mr. Early by Stan KLeinert, Departsont of natural Resources. Coes anyone else wish to have questions of Mr. Early? (No response) EXAMINER: In that case, thank you very such, sir. . That's it far the ERA, isn't it? MR. KLEINERT: Yes. . BfflMINER: Okay. In that ease, the presentation by the Deportment of Natural Resources, with the aid of various other agencies and industries is concluded. Ws will now ocn- ' . tinua with public content by various parties who have attended this hearing for that purpose. I'd like to first call on Mr. Dennis Bessenecker, Dow Corning Corporation. . - MR. EESSEHECKER: Yes,, ay ease is Dennis Bessenecker frtm Dow Coming. I'd like to enter this statement for the record relative to the use of Dow. Coming 2-1090, dielectric liquid as a replacement for KB's in power tranformers. . Q2-1090, dielectric liquid is Dew Coming's version of a polyrtlmethlailoxane fluid qualified for use in electrical applications. The technical feasibility of using silicones in transformers has been shewn by over 20 years of,experience in military speciality transformers end several years of use an the Japanese National Railway and use in a lumber of .power transfemroers in the.Midland; Michigan.area. In addition to these actual applications, support for tie use of sili cones is contained in over 30 years of accumulated data on dielectric properties, and ccxrpatibility with materials of ccnstructicu. Concern for fire, explosion, hieelth'and environmental hazards strengthens the rationale for using silicones. - Silicone liquids of the type advocated for this application are much less flammable than typical tranformer.mineral oils and. actually have a higher flash point than many PCB containing transformer liquids. And although these silicone liquids will bum, they, have a relatively low heat of combustion, a high flash point and fixe points and have been, shewn to be self-extinguishing in static pan type bum tests. li^y appear to offer a level of fife safety greatly superior to min eral oils and only less--slightly less than PCB based liquids. The silica* liquid suggested for use in transfanners has been evaluated by Underwriter's Laboratory and has received a flsmability classification umber. . Simulated transformer explosions involving a PCB based liquid, a silicone i and. a mineral oil showed that only the mineral oil. continued to bum after the explosion. There was no fire with either the PCB or the silicone. ... Yellowing a review of the ectensiva data, several insurance companies have given their permission to pursue the use of silicone liquids in transformers used by their custorers. Because no general policy has been established to date, insurers hove tivHr-m-n* that they will evaluate each application on an individual basis. '. " Silicones; often used in small concentrations in the preparation, of certain foods, have a very low level of toxicity. The toxicity to masmals and aquatic life and plants have been investigated and.continue; to do so. The exIrately low toxicity of silicones make it difficult to detect toxic reactions in the test subject; Studies directed towards defemiimxj the tendency for silicones to bioocncentrate have bees negative. It was hot possible to shew that faioaccuaulaticn was souring. 63 WTM00600 NCR-FOX-0281457 WATER PCB-00044201 It has. often been stated that sillcones are persistent because they do not biodegrade. Although no evidence of bicdegradabi 1 ity has been shown, silicones do degrade in the envixorecent. Contact with soils and water causes the liquid to rapidly depolymerize to volati-ve species. Once airborne, these nuu-jHalu are chsnically degraded in the presence of ultraviolet light. Known chem istry also suggests the possibility of chemical degradation in water. Hie present listed price of silicone fluid is approximately twice the price of PCS ligiHda and I'd like to make a comment on that after I conclude, however, the price differential would be expected to decrease as the volute of silicone fluid used increases. Hie cost of monitoring, controlling, spill cleanups, the potential--possible liabilities and disposal should be such less for silicones. Sms, in the long term, the total cost of using silicones would probably not be greatly different frcm the total cost of using PCB's. . And the eminent Z would like to make is the fact that we are on a' program right now of caimercializing the silicone fluids; it is available. Kith cur rebate program in our efforts to accumulate and extend our data bank car let's' say, service life data, we are offering a rebate systaa and with the rebate below the liBted price of sniocne fluids, we are very close to PCB's at the present time. EXAMINER: Do you have a copy of your statement, sir? MR. EESSEKECKER: I have a number of copies. EXAMINER: ckay. Just leave one for me. I think you can leave the rest there. lhank you very much. Is Groff Collett present? Please step up for a statement. ' ' Ckay. Please identify yourself before you make your statement. MR. COLLETT: Yes. My name is Groff Collett. I'm general manager of Paperboard Products far Consolidated Papers of Wisconsin Rapids, Wisconsin. - This is the recycling area of our business, in which we procure used or waste paper and recycle it to make paperboard. This recycled paperboard is ultimately converted into such items as folding cartons, paper cores end cans, and various laminated paperboard products. He have one iraehine manufacturing paperboard and this machine supports the employment of approximately 340 people in central Wisconsin. Annually we consume or recycle about 33,000 tens of post consumer waste, keeping it from the solid waste stream. The payroll for this operation was $4.6 million in 1974 and federal, state and local taxes amounted to about $1.3 million. -- . He share your concern with our enrixeranent and have rfade substantial effort to prevent any of our operations frtn having a deleterious effect vpon society in general. rmg'HriatHi has invested more than $40 million in environmental improvement programs; we anticipate capital and operating expenditures far environmental control will amount to $26 million for the three^'ear period, 1975 to 1977. We also feel strongly the responsibilities we have-to bur Eoployees far maintaining stability of ecployment, as well as providing a fair and reasonable return to cur shareholders. He believe the EOT. is serving its intended purpose when calling possible hazards to the attention of the public and to the attention of those who have control over the processes which are believed to be responsible far this potential problem. He very frankly do not term at the mount the extent to which our operations are a source of ECB discharges to the state's waterways. Excuse ne. Ha are aware that certain types of waste fiber containing PCB's and essentially all the normal grides of reclaimed fiber which we use at Consol idsted could possess extremely snail amounts of PCB's. Since we have rot been engaged in the production of paperboard for direct contact with food, we have rot been making routine analyses of the PCS input into our process. It is csly within the last few months that we've been made aware of ary potential danger to the state's waterway* as a result of cur recycling operations. When this was first called to our attention, primarily through tits press aid I'd like to digress from our prepared etatonent for just a rament and say that this fact that ue got our information originally primarily through the press, is a matter of seme concern to me. I thought that we had established the long record of a willingness---shewing a willingness to week with the OtR on all problems related to our envirement. As we have done, we've shewn a willingness to work with such government agencies as the state recycling authority. And our industry has worked with the FDA in establishing information on PCB's in foed board. Unfortunately, the first contact we had with the T3SR on this whole matter is when we got notice that they were considering regulations that have the threat of putting us out of business, Let me go back to ay prepared, statement. ' 64 ^T&0060l NCR-FOX-0281458 WATER PCB-00044202 When this was first.called to our attention, primarily through tte press, we . immediately attainted to make Erne deteminatlcns. Unfortunately, our hasty effort was largely fruitless since our saddling tpchnigups and new appear to have' been less' than representative of actual conditions, Tte truth is that we we sent samples to an outside agency' for analysis; they came back and they reported that it wasn't detectable at their level of one part per nriiHm and we threw up cur hands and said that was inadequate. The state's talking about five parts per billion, not parts per million. And now we're starting all over again. f&ile our report states that cur effluent did not contain measurable quantities of PCB's, a review of our techniques has convinced me that they are inadequate. So w have now embarked on another testing program which we believe will be much, acre meaningful. This program is going to cost us thousands and thousands of dollars and unfortunately, we are not at all sure of what the results will mean when they are completed. I say this because we are testing only the influent and effluent to cur paperboard machine, which is the only machine in pur company utilizing waste fiber,which is the reported source of PCB's. If we deteetthe presence of PCB's, we then have to determine the effect of cur 7.9 million dollar treatment plant tsw tinier construction win have en this effluent. # , Given this situation, what are the alternative courses of action which .are available to cur company. You understand we have very few facts and Z really doubt that there is anyone in this country who can claim to have enough facts on this matter to. know the best coarse of action for a single company, state or the entire country. There are only a few things we know with reason able certainty, cne of these is that the PCB's are present in snail quantities in most of the normal grades of wastepaper or reclaimed. fiber. In sane oases, the presence is probably so stall as to be meaningless. They are reported to degrade very slowly. To the best of my knowledge, there is.no practical way of rsnewing then from cur environment unless they can be collected and incinerated at very high temperatures. The second fact is that ve have been in the recycling business in central Wisconsin since 1917 and had hoped to rerain in profitable operation for many years to came. If we are banned from discharging any PCB's at all with our present technology, we would have to back away from the use of wastepaper. Up until new, ve have been encouraged under national environcental goals and yes, under Wisconsin goals as well, to support `reclamation programs for the recovery of these waste fibers and recycling than into paperboard. .' . 'If the EKR bens all discharge of PCB's, we have one of several alternatives. We could consider switching to virgin fiber. We firmly believe that the dost of this switch in central Wisconsin would be prohibitive and it is not an eccnaaically supportable alternative. . The second alternative'is attaipt to be mere selective in our reclaimed fiber procurement and I believe this could achieve sane reductions in the PCB's we take into cur process through the use of wastepaper. Cur research personnel, tell us that the oenplete elimination of PCB's by this method is impossible and a substantial reduction would be an extrenely costly and probably unreliable procedure. '' Kith a zero discharge requirement, I quite frankly see absolutely no way wb aould continue to reclaim waste fibers. . ... Then vs ask what rate could we achieve? Honestly, I do not know. At the ament, the five parts per billion level sounds so dose to aero that I faelieve.it Would have tin seme impact. The whole subject matter is much too new to even have a meaningful opinion-on ths subject. Another alternative is to consider various treatment processes on the PCB's which might be present in cur effluent. We are willing and even anxious to do this and will start with ths cenpleticn of cur treatment facility previously mentioned. - X realize that there can be many errors in tbe thoughts I have set forth here. But I believe that they are honest and logical thoughts based on the information presently available to me. Time will probably do a good job: of pointing out the errors and I guess that is the - cnly point. I can make with you today. Hasty action that leads to unrealistic levels of PCB dis charges could have a very, adverse impact on cur recycling operations and on tin economy of central Wisconsin. It would undeubetdly brdr^ ours to a halt and put 340 people out of work. This might be the result, even though the effect an the presence of PCB's in our environment could be nil. X urge you,, therefore, to take the time and seke the effort to study the serious impact of these preposed--these proposed regulations will have upon our economy and the conservation of our natural resources. m welcome the input you make to cur technical understanding of the problem and va would be glad to cooperate in your studies aid the evaluation of alternatives which are available to us in order to protect our environment. .' 65 WTH0G602 NCR-FOX-0281459 WATER PCB-00044203  Thank you. EXAKIKER: Go ycu have a ccpy of your statanent? Thank you. I appreciate your appearance. Mr. W. Allen Schenck. Present? Please Identify yourself and proceed. MR. SCBEN2K: My name is Allen Schenck. I'm vice president, technical and environmental, far Ker-asha Corporation, Neenah, Wisconsin. ` I'm speaking for the John Strange Paperboard Division of Menasha-Corporation. This paperboard. mill manufactures combination boxboard fran recycled paper and has done so for over 25 years. Two hundred and fifty people are employed at **< location. The annual payroll is $3 million. '- Up to January 1, 1975, John Strange had invested $400,000 in water and air inpruvanent. Che million, one hundred thousand dollars will he spent in 1975. Ttese expendi tures are a high percentage of the net worth of the mill. The plant is in with all environmental orders. Approximately 75,000 tens of paperboard are produced annually. The principal products are tube ana can stock, carton, stock, chipboard and cylingaar specialties. These products are, and historically have been made fran 100 percent recycled filer. The present grades of recycled fibers used are 50,000 tons of old corrugated, 25,000 tons of mixed paper, 8,000 tens of news. These products are purchased principally through recycled fiber dealers. ' MO PCB's are used in the manufacture of cartoinaticn box board. Ttere are no knewn- PCB's in electrical or hydraulic equipment in the mill. Of the total annual product at John Strange, about 20 percent is utilized in food packaging. Cenbinaticn boxboard for food packaging is made fran recycled fibers sleeted to minimize PCB's. Board which exceeds ten parts per million, the PCB is diverted to nonfood end uses. . Ten parts per million is the Interim level set by' the Food and Drug Administration far food packaging materials. Experience in the manufacture of these grades has demonstrate! that in the course of 24-heur run or. longer, peaks of PCB's above ten parts per million can occur. However, the frequency and intensity of these peaks has decreased dramatically since 1971, uten PCB's stepped entering the vastepaper use and reuse cycle. This trend is industrywide. Data collected fran the majority of canbinaticn boxboard mills in the United States shows the following: in 1971 87,percent of the board made met the FDA limit of ten parts per million. In 1972, this had increased to 94 percent. In the last half of 1974, It was 98.5 percent. In the first half of 1975, it was 99. 5 percent. * The data far 1974 and 1975- each represent over 2,000 analyses. They were collected from 70 percent of the canbinaticn bexboard mills in the United States as part of a quality--co operative quality.assurance program with the Food and Drug Administration. The data is submitted to demtestrate that PCB levels are decreasing rapidly. It should again be pointed out the recycled fiber utilized in the manufacture of these boards was selected- to minimize the presence of PCB's. There is no practical method to select PCB free' paper in bale form. Tin. selection I speak of is based an the grade and the source of the wastepaper and cannot be foolproof. He have no definitive test data on the PCB ebnoentratien in our.effluent. As a result, we do not know the distribution of PCB between the outgoing paper and the outgoing effluent. If the conservative assumption is made that' the finished board has two parts per million of PCB, that 80 percent of the PCB in the raw materials stays in the paper, that 20 percent goes cut in the effluent and that the effluent amounts to 3,000 gallons per ton of paper. The concentration of PCB in the effluent would be. 40 parte per billion. It appears that a maxinun pemsissible level of five parts per billion could not be maintained with available recycled fibers. John Strange Paperboard could go to virgin fibers, but they most certainly would not stay corpetitive with combination boxboard mills in other states. If this operation was discontinued, it would mean the loss of the jobs end the loss of the payroll outlined at the start of ny statement. This would also mean that 85,000 tons of wastepaper would have to be disposed of by means such as landfill or incineration. There are undoubtedly other sources of PCB, but the current level of PCB's in re~ cycled paperboard result from actions securing prior to 1971. This source of P has been dis continued. The level of KB is expected to decline and. the broad base data presented supports this. He cannot excape the fact that PCB's are in the recycled paper system and they cannot be legislated away. They are, however, declining rapidly. 6 WTM00603 NCR-FOX-0281460 WATER PCB-00044204 Xt is requested that the proposed, rulings not he implemented. It Is requested that the State of Wisconsin, through Department of Natural Resources, devise, a practical method of monitoring PCB's to be certain that the downward trend continues as expected. Blank you. EGWONER: Blank you very much. Could you provide a copy of that at your convenience. HR. SCHENCK: --I'll get it retyped. , ' EXAMINER: Blank you vary such, sir. Milton Lcaman. . . '. MR. lOWiai: My name is Milton lonnan, president of Iceman Iron and Metal Company, established in 1913. Our business is a scrap processor of ferrous, nenferrous arid fiber scrap. In laymen's terms it's scrap iron, scrap metals, such as copper, brass,, aluminum,-zinc, lead, and scrap newspaper, cardboard , ledger grades, sane of then called the sulfite grades. We employ 5 to SO people. Our payroll is $22,379 per year. Our state and local taxes only last year were $53,294. Any material we process, particularly wastepaper, reduces the amount of land required for the inrrifni use. Bie statistics that Z have show that 60 percent, of the solid waste in the landfills is exposed of paper fiber. .'Bie- conclusion x hope that you.draw is that we are today the largest conservationist, ecologist and/or envdronnentalists. . Because of the nature of this hearing, X will dwell on the wastepaper aspect. Besides our present plant in Feet Atkinson, by means of industrial revenue bonds,: we are building a half a million dollar plant for the recycling of wastepaper in Janesville, Wisconsin. " Aside from this _ prepared text, it's frightening to knew that I'm going--a3 an entrepreneur, putting this much, money in an investment and it may not work. X mean, it could possibly be cut out. So X have--very apprehensive at this point. But this plant, as well as our present plant, purchases newspapers via paper drives, cardboard, tab cards, ledger grades, which is either old or hew, business forms of any kind, from qarcnercxal establishments, industrial plants, banks and printing oaqahies. This material' is sorted by band into specific grades of wastepaper to-be shipped to the paper mills. The following are grades of paper segregated and baled by the papier stock dealers to be shipped to paper mills. I've listed sate of these just to make you aware that it's just not wastepaper. Biere's specific grades. Bose's no. 2 mixed paper, no. 1 mixed paper, super mixed paper, boxboard cuttings, ho, 1 news, overissue newa----I'll skip saae. of' these i..get into ..possibly the ones that would her """wall, in the mixed paper, it's very easy that sanabbdy threw away a federal form that's got tte PCB in it. In the ledger grades it might be in sane industrial plant that has sane old'records. But to our*--so I'm just trying to give you sane of tbe.grades that we have. . There's also 46 grades of wastepaper from our trade association and national association recycling industries. They're all listed here to give you an idea of what the grades of paper are aid tto specifications. The ones that--and other grades that would be affected here could be the-- what we no. 1 sorted colored ledger, manifold ledgers, and. aid forth. The effect of no PCB discharge to us, a. scrap processor, is related to what the paper mills Mill purchase. Xn the' area of the high grade papers that cone from the banks, industrial plants, it is possible we will not be able to ship this paper to the mills if they, are curtailed in their purchases. Wat does that mean? As. you go down the line the alternative would be to take the to the landfill and we would charge these institutions. ' erne thing X would like to point out very emphatically, the scrap processor pays for everything when the econdsics are there. They pey people far it, which helps circulate rocney. At present, our customers 'are paid far what we pick up. Total restriction of FCB. would affect toe economics of our customers arid cur operations. . At present we have no means of identifying F type of carbonless paper fran other carbonless grades of paper. If there is a means of identifying the chemical, we do raise this ques tion, can we sccrfc it out eocnanically? Again, if we cannot, it will, go to the dump. Pardon me, the landfill. ' Xt appears to me if we cannot process the material, it ends tq? in the landfills, Biat FCB will still end up in. the water table or our environment. FCB was banned from the1 use in carbon less paper a few years. . Bwe amount in the wastepaper should be considerably reduced. I'm speak ing as a layman, not as a technical person arid X found this in other, grades of sura? that we have fff.nrtiBri throughout the years. Mien it's stopped at the scusce, it eventually just dwindles. My fear is that I have an eutopic of a 100-ton--could be atheusands of tens of paper. It could be because sewewhera there was 10 pounds as 100 pounds Of carbonless paper. X don't know the ehsaistry of the specific PCB. I'm not mentioning pure FCB. But just think of it, maybe 50 pounds of carbonless paper and say 100 or 1,000 tons of paper. If it's possibly there, w'd have to threw it in a laMfill. 67 WTM00604 N C R-FOX-0281461 WATER PCB-00044205 -"HI The paper recycling industry has had enouefc problems. This is the first we've had anything that really involves the environnent. We've hod unfair freight rates, unfair tax advantages carpared to paper mills who do not use wastepaper; if you'll pardon the expression now, harrasscent by the DNR in attempting to license us. We're in court on this issue right how and sales tax discrimination resulting in a Supreme Court case. The confusion that I'm trying to shew you is that we are supposed to be the greatest ecologists and conservationists, we have the public backing. We have the legislative hacking. But we're constantly having problems with the--Shall we say the bureaucrats in our state. . I'm aware of the danger of PCB's. In ny views, I express the effects on our industry. I feel the answx is in the control by a realistic percentage than a total ban. At this point in history I feel the dye is cast. There cannot be a total ban. It will end up--that is, feint the wastepaper point of view, it will end vp in our environment whether it goes through the paper mill or the landfill. -. EXAMINER: Do you have a copy of that presentation, sir? . MS. LCSMANs I just gave it to you. EXAMINER: Ch, okay. Attorney Bach, as I understand, you went to make a motion and a swmwry? MR. BACH: My name is Attorney Donald L. Bach and I represent the Wisconsin Pager Council, the trade association for the pulp and paper industry in Wisconsin. Mr. Examiner, far the recced and because of the extreme complexity of the issue, we would like to formally move the tribunal to grant a 30-day period following the furnishing of transcripts in which written briefs and ccmrenta could be made. EXAMINER: That motion will be taken into consideration and the determination made price to the closing this morning. MR. BACH: Thank you, Mr. Examiner. - Cn behalf of the Wisconsin Paper Council, I'd like to sunnarize the key points in the testimony and positions offered by council members over the past two days. One, we recognize that there is a potential problem with the introduction of PCB'a into the environment. . Two, the paper industry has not created this problem.. The paper industry does not use PCB's in its processes and the paper industry finds itself caught in the middle of this controversy merely because of its recycling efforts which would be halted by the adoption of the proposed rules. Three, the proposed regulations place an incredible burden on cur industry, requiring removal of PCB's to levels one thousand times mailer than the Mood and Drug Administra tion's tenporary tolerances as applied to food board. Four, our industry has a history of cooperation with government agencies to reduce . PCS levels in cur finished products. We will continue to cooperate with the Food and Drug Administration and with the CNR to find solutions to the PCB problem. Five, we strongly support strict controls on the manufacture, distribution and use of PCS's and we favor a national ban on the Importation of PCB's. Thank you. . ' . SMOKER: Thank you, sir. Before we continue with further public oauaent, does anybody wish to eminent or apeak to the motion made before this hearing today? Being the 3D-day comment period requested after availability of the transcript? (Mo response) EXAMINER: Hr. Richard Manfehe. wold you wish to make a sfeateaeBh at thia time? MR. MAMHE: (Xnaadble) 68 WTM00605 ' NCR-FOX-0281462 WATER PCB-00044206 EfflMINERi Ctay. Xfcank you. Mr. Manthe vi11 submit a written statement. X* Mr. Eduard Tilnon present? . Xs there anyone else present at this time that wishes to take an oral statsaent? VOICE; X have a question on the transcript. Ear and when would they be made available and has that been decided? . . OSM2NER: Okay. She question vent to the availability of the transcript. X think before going further we'll take between five and ten-minute recess to consult with the recorder. The hearing is closed for five minutes. "' - (Recess) . EXAMINER; ladies and gentlemen,, please be seated and we'll continue with the bearing. (Stay, ladies and gentlemen, the motion of the Wisconsin Paper Council regarding consents has been considered. The determination is that the earnest period, will be extended frm today's date through 30 days after availability of the transcsipt,'or'Nenrember. first, whichever is earlier.. It appears at the present time the transcript may be available by the 20th of September. Ail parties filling out an appearance slip will be notified by letter as to availability of the transcript and the oost. There also--at least my reccarendation will be limited availability to the public of the transcript in at least the six district offices of the Department and the Madison office so that the public may view the transcript without cost. The .district offices are located in Spooner, Wis consin, Rhinelander, Green Bay, ia Crosse, Eau Claire, Milwaukee. Okay. Mr. John Troglia. Is he present? MR. XR08ZJA: My name is Jehft.W. Troglia and X am chief station engineer for the Wisconsin Electric Power Ccnpany. X am a graduate of the University with a Bachelor of Science Degree in Electrical Engineering. I'm a registered professional engineer in the State of Wisconsin. ' I've been enployed by the Wisconsin Electric Power Ccnpany for approximately IS years, during which pericd X have served as substation design engineer,, generation and trans mission planning engineer and. project engineer responsible for distribution of substation, design. In my present position, I'm responsible ..for the design of transmission stations, bulk power substations and power plant switchyards on the Wisconsin Electric Power Cetpany System. I'm an alternate member of the National Electrical Code caaaittee'Panel #13, which is responsible for those code articles dealing with.transformers, capacitors, resistors, reactors, transformer vaults and equipment and systems of over 600 volts ih general. I'm a member off the Unit Substation Subcomaittee of the MBX High Voltage Apparatus Caaaittee and a marker of the XES. ' My testimony today is in behalf of tee Wisconsin Electric Fewer Cecpany and the Wisconsin Public Service Corporation. X would like to state at the outset that the. operations of the Wisconsin Electric Power catpany and the Wisconsin Public Service Corporation do not appear to be greatly affected by either of the two proposed rules regarding the discharge of FCB's into the waters of tee . State of Wisconsin. Our only use of PCS material is in capacitors and transformers which are clc*d electrical systems. However,' other industries in Wisconsin are greatly affected and the above remarks should not be construed as diminishing their problems. Our presentation today is concerned with submitting information to the Department, of Natural Resources' regarding current uses of FCB's by the electric utility industry, Wisconsin Electric Power Company and Wisconsin Public Service Corporation. We understand that a Monsanto Corporation representative, among others, will present material concerning the technical,. . acosmic and scientific aspects of pcb manufacture and usages so we will hot address those areas. TJvs best statement of the, history of PCB's in the electric industry, including benefits, risks and alternatives is contained in Chapter 2 of tee American National Standard Institute Guidelines for Handling and Disposal of Capacitor and Transformer Askarels Containing Polychlorinated Biphenyls, C107.1-1974, a portion of which X should like to read into tee record at this time. Chapter 2.5 was Interdepartmental Task Fossa on PCB'a, An in depth study ef PCB's has recently been ccnpleted by five executive branch departments of the federal govenssent. This . 69 WTM00606 NCR-FOX-0281463 WATER_PCB-00044207 n, Interdepartmental Task Force on PCB's issued their report entitled Polychlorinated Biphenyls ani the Envircnnent in May, 1572. fie following conclusion is quoted frcm page 4 of this repeat. fie use of PCB'a should not he banned entirely. Their continued use fee transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result frem a ban on PCS use. Also, continued.use of PCB's in transformers and capacitors presents a tMtvItwiI risk of environmental contamination. The Monsanto Cenpany, the sole dccestic producer, has reported voluntarily eliminating its distribution of PCB's to all except manufacturers of electrical trans formers and capacitors, unquote. He should also like to subsit a copy of the entire ANSI Guidelines for the record. The only use made of PCS material by Wisconsin Electric Power Ccnpany and Wisconsin Public Service Corporation is in closed, in other words, sealed electrical systems, such as transformers and capacitors. Handling procedures have been adopted by both companies that parallel the ANSI Guidelines. Bowsver, pursuant to the July 9, 1975 letter from Mr. Brooks Becker, director of the Bureau of Air Pollution Control and Solid Waste Management of the Wisconsin Depart ment of Katural Resources, to all Wisconsin electric utilities, Wisconsin Electric Power Ccrpany Task Farce has been established to reevaluate KEPCO policies vis-a-vis the reamaehdaticns in that letter. Ccnpany policy is new being revised to insure that in the future scrapped transformers ard capacitors will be sent to approved disposal centers, which are all cutside of Wisconsin. Wisconsin Public Service Corporation also initiated positive controls on the disposal of PS cn June 22, 1972. Since that date, all scrap capacitors and transformers containing PCB have been collected and stored centrally, pending disposal in accordance with reocnmenced guidelines. It should be noted that the recommendations in Mr. Becker's letter were basically to follow the ANSI guidelines. In sumary, it would seen apparent that the CNR is well aware of the voluntary efforts of industry to guard against the potential dangers of PCB materials. We have outlined in brief the history of PCB's Including the benefits, risks and 'alternatives. There are compelling reasons, both technical and eooremic, for the continued use of these materials. EXAMINER: Thank you very such, sir. . Is there anyone else at this time who wishes to make a public statement? Mr. Tilscn, are you ready to make a statement at this time? HR. TILSCN: (Inaudible) EXNGNER: ckay. Let's recess for five minutes. ( (Recess) EXAMINER] Ckay. Indies and gentlemen, back cn the record and there'll be an oral presentation with slides by Mr. Tilson. -- statement. Mr. Tilson, please identify yourself, who you represent and present your .' MR. TUSCH: Ckay. Ckay. My name is Ed .Tilscn and as I say, toy PE license is pealing review. I'm today I'm representing Gcmnittee to Expose Carcinogen Coverup and the ttare is with can*r for Public Representation. This--I may hot be too articulate because I really didn't quite have things together. I was taping ewer inert: to put things in a more finished farm and I won't be reading frem anything. It'll be mere extesgceanecua. During the presentations we heard leading up to this, a lot of material was brought out in the record that I've more or less been researching and becoming aware of myself previously. And I've been very intrigued with the' work of Dr. Allen because you see there 1 think a major envircauental---well, it's actually a public health problem. This is one thing 1 vent to say that Idris is not, I don't think, an ezrvixconental problem so such as it is a public health problem and I think that the handling of this matter, polychlorinated biphenyls, points up that public health has actually been sarewhat slighted as a process of the past few years, because there have been a lot of Departmental mergers cn the federal and state level in which public health has largely been thrown into environmental agencies and in that sense,' there has not been sufficient awareness of the problems that can develop into major public health problems--major public health--you'd almost call it catastopbe, although I've seen that word sort of misused during the hearing. 70 WTM00607 N C R~FOX-0281464 WATER PCB-00044208 . As a result of ny cwn experiences In working in the environmental field as an engineer and seeing that most engineers gravitate toward administration, I've been kind of disappointed at the way in which engineers approach these kinds of situations and.I've been more positively impressed in the way biologists approach them. In other voids, I've' gotten the feeling that engineers working for biologists are a better team than biologists working for engineers. And I think the basic reason, for this is that engineers tend to think in terms of things, in terns of quantities, in terms of getting something done, producing results. And I think that that's not the kind of approach you're going to want when you're dealing with things that can lead to public health peohUms, . I think this is pretty well pointed 19 in 1st Corinthians, in which the quota is that "God hath chosen the foolish things of the world to confound the wise and God hath chosen the weak things of the world to confound the things which are mighty." And all life is really fcurded on a chain which evolves from very simple unicellular organists and the Various toxins which were put into the environment can effect then and can effect the entire life chain. And X think this is a thing which we're seeing with PGB's, because even though the quantities are very stall, around the limits of detection, this--this, is part of the problem that there's extensive bieeoncen- txaticn of these to levels wherein fish---they're approaching--they're approaching levels that could probably, in years to cote, induce liver cancer, stomach cancer, birth defects, reproductive malfunctions, and the concentrations are in the fatty tissues, which slows up in very high concentra tions in the liver and also in the brain. '' . Ifce brain is a very, carplesc thing, the---they- --esoteric neural pathways. I do think there, is a problem here no natter hew much certain industries tty to. play this down by presenting what they feel is eooncmie catastrophe fear them, when in actual fact, I don't think that's the I have sane maps iq> here in which I point up sene of the---the sources Of ICB's. . I don't know where Monsanto's plant is located, but, of course, they've presented themself previously. X tend to have a feeling on this that transformers tend to be a fairly conservative use of this material frem which it's reasonably difficult fcr.it to get into the environment. I think a very high priority should be placed on developing a substitute and there are reports that substitutes do exist. Obis was what people on the Natural resources Board have said. Item that standpoint, I'd like to see this replaced, even in transformers, but in the meantime, the critical thing probably becomes to limit inparta, given that many of these corporations are said to not be following Monsanto' s self-regulation. Nonetheless, transformers--they were a target, for instance, when I was at Standford during the radical unrest. The transformers were shot 19 a lot and, of course, whatever was in teem leaked out. So, I mean,, that's always something to be considered that even what you consider as conservative is not always conservative use of materials. ' Owe industry that I'm essentially concerned with is tee paper industry and this is not because I feel that the paper industry or the specific sector of it which deals with deinked paper and carbonless copy paper is not making an effort to dean up, but I think there's an inherited problem frem past years and I'll eeme back to this later, but people at DNR on the technical level, the lower level professionals, have tried to call attention to this. And yet what has cone out of there has hot really cnllhd attention to this and I'd like to return to that later. Hie--I----the sources which are a problem with this are Mud Paper Ccnpeny in Merrill and then there's National Cash Register subsidiary, which I understand is at Portage. Appleton Paper is a subsidiary of National Cash Register. I'll paint to these on the map over here. maps are? EffiMMERt Before you go any further, Me. Tiladn, would you please state what the MR. TIISCNs Okay. This is the---the erne on tee left is an aerial map. It's a pretty good asp far illustrating things, I think. And the one on the right is a regional planning mop put out by the Sea Grant Program. SSAMXMER: What area does the regional map cover? ' MR. SXLSCN: Of Green Bay. EXAMINER: duy. Also 1st me caution you, Jfc. Siiesn, we perhaps only, have tea minutes left of taps, so. ' 71 WTM00608 MCR-FOX-0281465 WATER PCB-00044209 im MR. TUSCNi I mean this is Merrill ard this is Pearlage down bean. I don't think that these are major problaas. Merrill, maybe, but any sediments from Merrill will be picked up and--like in Petarwell reservoir. (Inaudible) I'm not too familiar with that. But in any case, carbonless copy voter, one of the higher concentrations is a relatively recent use of this. I understand PCB's given their peak stability have been used in premiums for about 40 years, which means you have a problem of 40 years accumulation. - Now, in Green Bay, I'll try to go to my slides. Xhe companies involved in this are Bergstrom and Neenah, possibly American Can Company, because I understand PCX's are used to get the--to get like wax paperboard type products, like milk containers and things like that, ` paper cups out of the molds. Combined Locks has Appleton Paper for Combined Locks. Again, National Cash Register is a subsidiary. U. S. Paper at DePere and I had difficulty finding it because it doesn't appear on this map. Zt seats to be very obscure. ' And then, of course, Fort Howard, which has a person on the. Natural Resources Beard, John Brogan, and then a third kind of problem exists in Green Bay, because that's where the sediments go to. I tried to do sate field sampling and I'll return to that in a second. I guess I need the lights off now. Ckay. Let's start. Ibis is a statute of Bridges (phonetic), the ancient Baltic river goddess. This is about 3,000 years old. What I'm trying to say by this is that 3,000 years ago our ancenstors didn't pollute the envirorment. Whether they would have if they could have is a question, but the thing is what will the envirorment and the public, health generally be like 3,000 years from now. _ Ckay. Ibis is portage. There was sort of an abortive trip out there locking for National Cash Register. Khile we were still in the air we couldn't find it too well. later on, I found roughly where it was before I got a sample. I thought that was it, but it turned out to be a hospital or a school or something. It has a cross on it in any case. New, you can see sandbars on the river that caused us problems because we were using a sea plane and things are backwards, I can see. It will be a problem later on. We took this seaplane and vs went out and came bade. Later on 1 used the land plane. This is very hard to see that there are cows here, and CNR is really down on cows because cows don't pay a lot of taxes and they don't employ a lot of people, so ecus are--and farmers are very such under attack. This is going to be very rough because this is backwards., 1 was given misinformation on hew this carousel worked. Could we step the tape and everything while we change it, because it'll really be a problem. EXAMINER: Ckay. (Off the record) ' EXAMINER: Back on the record. MR. TTLSCN: I'll try to go through these really fast. This is a-----this is Kimberly- Clark. While sulfite process is not involved in this, there is a possibility that deink pwip from the deinking plants is used in kraft pulp, so at least cne of these should be picked out to look at. . ' Here's Bergstrom cutfall. This is algae. And I'm suspecting that algae aid weeds are bioconcentrators of this initially getting into the fish. This could be used to--that in a positive kind of way by--rather than using pesticides, just wmed harvesting, weed and algae harvesting and then you're biocencentrating these residues in the past 40 years in tie algae. This is working downstream. It becomes a little obscure in here cne of these----I think this may be Kimberly-Clark at Kimberly which since tie Neenah Plant doesn't lend itself to very good sampling because the sediments are roughly sooured out. It's rock Wowwf--i there and this----wait a second, this one here--I think thta is the National Cash Register at Appletcn----at Combined Lodes, Appleton Paper, which has been involved in carbonless copy paper. Okay. There it is again. This.is Nicolet Paper, which 2 thought was U.S. Paper, since O.S. Paper doesn't appear on the regional planning map. Bit in any case, C.S. Paper is off to the right on the sms bank as Nicolet Paper. 72 WM00609 N C R~ FOX-0281466 WATER PCB-00044210 w And Fort Board, which is---and there you see the outfall with the plume extending downward. And this is caning up aver it. And an the right you see the treatment plants. X mean money is being spent, I think,, to' clean .this-up presently and maybe a little bit of an improvement is needed in that. But tte problem is an inherited one fron the past 40 years and there I'm being left off at Neenah to face the hostile natives. This is the most exotic piece of sanpling equipment I had because I managed to get same of that nud later--they're excavating-at Neenah for seme sort of -outfall. Here we see sane of the' algae and sate people fishing. I had a lot -of pictures of people fishing that didn't cate . cut--one of which was Like people taking baskets of fish away.. So I mean it's no one fish a week. I mean, this is an area where there's very---sate people are involved in very heavy fish censunption and there's a little boy even, you knew, a. little boy with his grandfather, I mean it Would have been a really gecd picture, X think, to shew this pcOblkn. ' ' . . This is the Bergstron Paper outfall. Here's an area, X think, where sediments have accumlated fron the breakdown of the fibers casing out of the plant and ttere's a lot of lily pads. Kell, what was interesting was that there was like an oily slime covering a lot of this plant material and the plants' cells were oily. X think that these plants are probably preferentially taking oily material; it' s part of their metabolian. And X think this might be a thing which could be explored. - This is a landfill which is being put down in that area and X think this might be tie best way to contain a lot of these sediments. If you put a clay layer, which is then run. over by sheepsfoot rollers, to provide an infiltration barrier and you do groundwater studies to make sure that there's ho major groundwater flew through this area. But this would be a way of retaining any sediments that are found to contain' large amounts.of PCB. . this is Kimberly-Clark. This outfall was apparently plugged. It's a measure of the progress that is being made. . ' - This is down near Menasha. This is, X think, this would be an outfall that would pick w?> material from American Can. Canpany, possibly Strange Piper Cornany, John Strange. That's American Can locking under the trestle. This is very largely rock button. That's what I used-- nry delicate professional hands are not used to the rigors of the norm. I'm really sore. This is American Can again. And this is John Strange... I'll try to get this a little bit better into focus, but it shows that they're using wastepaper also, so this is quite extensive, this problem. ' . American Can--and this is returning. X'll just shew where the sediment areas were. This ms the one fran Bergstran and Kimberly-Clark might be putting' out. American Can, John Strange, Menasha Corporation. I don't think is involved in this; Strange does use sane, waste- paper, probably not very much. American Can may use it as a release fron the malt. But anyway that second ..sludge bank is dewn here . Me also have sludges all along this shcre, the west shore of Little lake Buttes des Marts. A lot of sediments. - Kimberly--this is where Kimberly-Clark is--so that a spot check could be make on kraft paper industry. Contained locks where Appleton Paper is. X think at that time it was called Contained Mills. I'll point to tJ.S. Paper and this is Fort Howard over in here. ' And Fort Board is.this projection where there are shallows adjacent to it. See this is Fort Board in here. . . And in Green.Bay, this is--I'll show Atkinson's Marsh, which was recently filled with sediments fron Green Bay. That has been since filled and Aany Corps of Engineers was allowod to fill that if they used sheet piling to keep the wastes fran getting back. . ' This is where most of the wastes have, acomulated actually, cut in' Green Bay, where you would probably find very good nwrple--samples shewing high PCB content. . - The- interesting thing is that money exists to clean this vg>. There's $15 million in Section 115 which apparently a lot of people don't know about, because X think if ttey had knawn about it, they would have spent less---really less effort in trying to see that it didn't fieme out. Instead they would have maybe admitted to' it.- But X don't knew. Maybe that motey is gone new. This is a clamshell dredge. X don't think that would ha a good sort to use. There's a lot of resuspension fron that, and a dipper dredge the same thing. A cutter heal is for very hard material. This, 2 think, maybe would work pretty well in the area of U.S. Paper in DaPere, 73 VTM00610 NCR-FOX-0281467 WATER PCB-00044211 Fort Howard at Green Bay and actually out in the--in the eastern portion--western portion rather of lower Green Bay. Ibis ia a. suction device. And there is a source called jetting at laminar flow rates, jetting at ienthic deposits at laminar flow rates, which indicates that there ia--there's not nnch auspensi ra----resuspension of pollutants observed when jetting, when the laminar flow rates are done. In other words, when it's done very slowly. And James Jones of the Any Corps of Engineers feels that very such could be done along this line if the proper techniques are followed. In other wands, the industry has not been too--it's been sloppy and he thinks there's a need to clean 151 there. Hiis is a floating dry dock. I thought maybe this would be a way of--not so such a floating dry dock, but an equivalent thing which has doors across. A landing ship dock could.be used to rstove these sediments, but now I don't think that's the best way. I think it would be best to put up, not so much sheet piling, but like a breakwater kind of effect, like retaining well and fill in the area behind that ever a period of time, using this technique for dewatering of dredged areas, mis is from civil engineering. And then what could happen would he it would be made into a landfill and a day layer far infiltration harrier could be put over that. EXAMINER: clay. Me hawe about two minutes. MR. TUSCN: Okay. In dosing, I'd just like to sort of say that I don't--I really don't feel that the Department of Natural Resources, not withstanding this conference, has really been on top of this problem to the extent they should be, because there really has beat mstorandums around on this since 1971 and in 1973 ETA almost had to 1 if you read the Great Lakes reports and such, the ETA was really the people that axe pushing CNR on this. And I'll read fran a report, the Eooz-Allen and Hamilton report for reorganization of EUR and one of tte things they say is that "long chains of ccrmand lend thanselves to delegation problans since it can become difficult to determine who in the chain is personally responsible * for specific results. They can also create -unnecessary organizational distance hetween professionals at a lower level win have detailed information and persons at the top of an organization who have a need for detailed information on a selective basis." My observations have basically been that the lower level people would like to see the environmental and public health problems addressed to. This is tbs people at a professional lower level and 1 know the Natural Resources Board, fran ny conversations with than. They want to see it dealt with. So the reason I think that there hasn't been mare action forthcaning on this is some where in between I question whether----as is often hcought out, whether it's necessarily at the Secretary's level, and I think what will have to be done on this is that people will have to take less cognizance of how such taxes an industry pays, bar many people it enploys and this kind of thing. And instead, the industries also have to sit down and be.willing to atploy technology which, as X say, I think does exist. There's biological treatment of chloropbenolic wastes, which is a relative, a related compound. They've had luck with mildly acid reduction techniques far de gradation of polychlorinated biphenyls, mis can he done on a current basis, a restriction of the use of PCB's will cause---will be---cause the level of FCB's in wastepaper to drop over a period of time and then the sediments problan can be addressed. And I think that rather than industry saying that they really can't do it, but rather instead working to see what they can do. There's a lot of chemists; there's a lot of biologists, which are unemployed and there's sort of almost a need to spend money, X think, to get the econany going again and X think these are resources which should be applied. X don't think problems should really be covered up. X think they should be dealt with and X think the people in the organization --I would specifically like to mention two people. X think Stan Kleinert, here and Maurice Van Susteren I think are very dedicated professionals. And X think in seme way they should be singled out fox sane special oaraendaticn, may a Governor's caanandation or something, for the extent to which they've pushed this, X think. X think with it, not necessarily being a thing which is endeared ttem with the administration of ENR. So anyway, x guess on that I'll close. EXAMINER: Ckay. Thank you very nuoh, Mr. Wlson. I appreciate your appearance. Please provide us with copies of your slides and a memorandum of what's referred to in the slides, identifying the slides and referencing material you used. Xt would be good for typing up the transcript. Thank you. Is there any other party who wished to make an oral coctment at this time? (No response) . - EXAMINER: Ckay. Kith that X win be here for a start time this afternoon to sea 74 UTM0OS11 NCR-FOX-0281468 WATER PCB-00044212 if anyone wishes to appear for consents in that we did issue news releases stating that we would be here, otherwise, I have no Information as to other parties .>ho wish to appear. All of cur presentations are cccpleted. If those of you who are here do wish to leave at this tine, then we will adjourn for a noon lurch. But if .you aren' t going to be with us after lunch, again, there'll be no further hearings. ' . The content period is extended to 30 days after availability of transcript or November 1, whichever is sooner, and you'll be--all those filling cut appearance slips will be informed. - ' On behalf of the Natural Resources Board, Secretary Voigt and the Department, I wish to thank you for your assistance and participation. We will new have a noon recess and. readjoum at 1:00. Thank you. . . .- (Soon recess) . EXAMINER: Cn the record. The bearing into the proposed Administrative Code rules limiting the effluent dis charge and pertaining to polychlorinated biphenyls which was recessed for the nocn lunch period, is reconvened. ' Zt is presently 1:30. No new persons' who wish to give oral statements have appeared in the hearing root. Therefore, at this time, the record is--excuse me. The hearing is closed with the record to be held upon for receipt of contents pursuant to time limits stated in the before lunch recess address. . ' . Thank ycu. The hearing is closed. (Hearing closed) . 9-9-75 &s 7S~ N C R-FOX-0281469 WATER PCB-00044213