Document peNErDnGm1Z3418g4684ggELd

Monsanto U o ft u n t o C a m p t f t v 800 N . Ijnbtrgft l o u l i v a r d S t l o y i x . U i a i o u r i 63188 P h o n # : OU) 884-1000 March 12, 197^ V< Mrs. Eetty J. Billings Hearing Clerk Environmental Protection Agency Room 1019-East Tower 401 "M" Street, S.W. Washington, D. C. 20460 Re: Proposed Toxic Pollutant Effluent Standards for Aldrin-Dieldrin, Et A1 FWPCA (307) - Docket Ko. 1 Dear Mrs. Billings: In accordance with the ORDER AND NOTICE of Judge w'xlllani J. Sweeney dated February 8, 1974, enclosed are the original and three copies of the written testimony with attachments submitted on behalf of Monsanto Company in connection with the above described matter. Yours very truly PSP/jmd Enc. Phoclon S. Park Senior Attorney FfiflT225 100-3 fi . i Monsanto M OW SAJrrO IN DUSTRIAL C H I C A U >00 N . lJnaftr|ft lo v U v a r S t . L e r n t , U n s o w n 83106 ? M m : Q U I 114*1000 CO. i In He: PROPOSED TOXIC POLLUTANT I EFFLUENT STANDARDS FOR ALDRINDIELDRIN, ET AL - FWPCA (307) DOCKET NO. 1 State of Missouri ) County of St. Louis ) ,s < V. B. Papageorge, being first duly avorn says: My name is V. B. Papageorge and I am Manager, Product Acceptability for the Functional Product Groups, Monsanto Industrial Chemicals Company, an operating unit of Monsanto Company. I am a graduate of Washington University, St. Louis, Missouri vith a Bachelor of Science degree in Chemical Engineering and have received a Master of Science degree in f Chemical Engineering from the same Institute. I am a Registered Professional Engineer in the state of Missouri. I have been employed by Monsanto Company for approximately 22 years, during which period I have served as an engineer, maintenance superintendent, distribution superintendent, manufacturing superintendent, plant manager and manager of environmental protection. In my present position I am responsible for seeing that the quality of products produced by Cvo business groups in Monsanto Company is properly maintained. One of the business groups within ay area of responsibility is the Specialty Products Business Group which manufactures and markets polychlorinated biphenyl (FCB) products for use as dielectric fluids in transformers and capacitors. I am a member, and have served as chairman, of a committee of the National Electrical Manufacturers Association which has reviewed the environmental effects of PCBs and has recommended procedures to users of PCBs which should minimize the possibility of entry of PCBs into the environment. nit tl Unmantn Cmiinv 175 Farn w e .100-31 MONSANTO COMPANY'S POSITION AND RECOMMENDATIONS >* As a M j o r producer mod supplier of polychlorinated biphenyls (PCBs) to tha electrical industry for fire resistant dielectric fluid applications, we have reviewed and evaluated the effluent standards for these materials in proposed Part 129, Subpart I, Chapter I of Title 40, Code of Federal Regulations. Pursuant to this review, ve submit the following comments and recommendations: 1. The proposed effluent standards for PC3s are unwarranted and practically and economically unattainable. 2. Actions by Monsanto and its customers, which have resulted In limiting the use of PCBs only to electrical applications in hermetically.sealed units, have dramatically reduced the quantities of the more persistent PCBs Introduced directly into the environment. 3. The definition of PCBs in Section 129.09a, Subpart I should be changed to read: "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaccumulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than 60, relative to p.o-DD100.- under the standard conditions recommended in the E?A PCB test method." 4. The accuracy and reproducibility of results attainable between laboratories using currently available sampling and analytical techniques are questionable and further studies are recommended. 5. The proposed PCB effluent standard is based on inadequate toxicity information, on non-typical fish species and on an unusually high and artificial bioaccumulation factor. Fundamental scientifically-based data is lacking and no responsible standards can be developed at this time. Ve recoosaend that studies be conducted to obtain the relevant .data and that effluent standards be established which are appropriate for the unique conditions existing at each point source. 176 . I(001227 6 V ebjeec to limitation of 10,000 cubic feet per second being arbitrarily assigned as a maximum stream flcv, without a sound technical basis demonstrating adverse affects, 7* The presence of background levels of PCSs at point sources should be considered when determining effluent levels. The following definition of "Background" should be added under Section 129.01a: " 'Background* means amounts of toxic pollutant (1) presently found In the waterways of the United States (including the Intake waters of a discharger), or (2) arising out of operations subject to this Parc that occurred before the effective date of this Part, but were not discharged to the waterways of the United States before the effective date of this Part." 8. Technology for the attainment of the proposed FCB effluent standard has not been demonstrated and is not available to the induatry. Unachleveoent of the strict standard proposed would have the effect of a ban on the use of PCBs with serious economic and social consequences very thoroughly described in an impact statement submitted to the Agency on January 15, 1974, by the Ceneral Electric Company. The chemical structure of polychlorinated biphenyls (PCBs) has been known for nearly 100 years. It was sot until the late 1920s that a use for PCBs was found - is i dielectric fluid in transformers. The properties of PCB -- inertness, fire resistance and a non-conductor of electricity -- are perfectly suited to those electrical applications where high-voltage arcing could occur; possibly resulting in serious fires or damage to the equipment. Commercial production of PCBs began in 1929. As the unique properties of the material became known, new uses were found. For example, their 'fire-resistant nature made them excellent choices for use in heattransfer fluids. Their Inertness gave long-lasting qualities to lubricants. Their use in surface coatings improved waterproofing characteristic. handling of the product at the manufacturing level has not presented problems as long as the normal industrial hygiene practices were followed and PCBs have always been considered less hazardous than many other chemicals in everyday use. Ennii>?8 177 1003 t T'* Trr* Therefore, it appeared thee PCSs vere a unique produet which net important needs of industry. . When questions about the effect of PCSs on the environment first surfaced, Monsanto Company reviewed its product line and the applications for these products. As more data vere developed concerning the effect of PCBa, Monsanto took steps to reduce the entry of PCS into the environment. The Company stopped the sale of FCBa for use in various applications, except where no acceptable alternatives vere available. Today, PCBa manufactured by Monsanto Company are sold only to the electrical Industry for use in closed systems as a dielectric fluid In transformers and capacitors -- applications for which there exist no acceptable substitutes. Thus the situation today la drastically different from conditions which existed only three years ago. Today about 40 million pounds per year are being carefully used in the United States by less than 50 Monsanto customers in the manufacture of sealed electrical equipment. Prior to 1971, close to 80 million pounds per year vere used by thousands of customers. This lends perspective to the current debate over modest losses of PCBs to waterways. Our manufacturing and sales reduction program was a unilateral action taken by Monsanto and was based on our evaluation of developing environmental data. The Interdepartmental Task Force on PCBs in its report (l)q concurs that the safety benefits derived. Justify the continued use in dielectric applications. Recommendation 6 under Findings, Conclusions and Recomendacions reads as follows: "6. The use of PCBs should not be banned entirely. Their continued use for transformers and capacitors in the near future ia considered necessary because of the significantly Increased risk of fire and explosion and the disruption of electrical service which would result from a ban on FCB use. Also, continued uae of PCBs in transformers and capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic producer, has reported voluntarily eliminating its distribution of PCBs to all except manufacturers of electrical transformers and capacitors." Numbers in parentheses refer to reference list attached. E001229 178 100 rt 5 Recognizing tha need for proper controls la the handling and use of PCBfl representatives of the transformier and capacitor industries, utilities and governmental agencies under the Initial auspices of the li ff Hatloua1 Electrical Manufacturers Association formed American national / Standards Institute Connattee C-107. Proposed guidelines (30) for / Ithe handling and disposal of dielectric fluids have been published. These guidelines reflect the Industry's understanding of the need for jfl proper control and hava contributed significantly toward achieving /" thla objective. I Proposals for the control of PCBs internationally were considered by the member countries of the Organization for Economic Co-operation and Development (OECD) and in February, 1973, they adopted an agreement (31 which restricts the use of PCBs to dielectric applications, non-food related heat transfer fluid applications and hydraulic fluid applications In mining equipment. This agreement is less restrictive than Monsanto's sales policy since it supports the continued use of PCBs In heet transfer and hydraulic fluids. Ve have reviewed with considerable interest the effluent standards proposed for polychlorinated biphenyls In new Part 129, Subpart I, Chapter I of Title 40, Code of Federal Regulations and have objections relating to the following: 1 Definition of polychlorinated biphenyl*. 2. Sampling and analytical methods. 3. Toxicity data. 4. Bioaccumulation factors. 5. Safety factors. m 6. Stream flow ratea. 7 Background levels of polychlorinated biphenyls. $ Economic considerations. DEFINITION OF POLTCHLORINATED BIPHENYLS Commercial polychlorinated biphenyl products, of which Aroclor produces are examples, are produced by direct chlorination of biphenyl; the degree of chlorination being chosen to provide desired properties. These products are in all cases multi-component mixtures and noe single entitles as Implied by the commonly employed acronym "PCBs". Foni ?,i c~\ 179 1000 While 1C la vail understood end accepted that polychlorinated biphenyl Isomers have a unique aec of physical and chenlcal properties, 1c la apparently not understood chat they bioaccumulate, dissipate and biodegrade at different races. This lack of understanding la reflected In the definition proposed In the EPA Toxic Pollutant Effluent Standards (Federal Register, Vol. 33, No. 247, page 35393, Section 129.09a) and ve quote: ' "Aa used in this Subpart, Che Cera: Polychlorinated biphenyls (PCB's) means materials containing the biphenyl group which have been chlorinated to varying degrees. There are 210 possible different PCB compounds." Ve object to this definition because it Implies that all polychlorinated biphenyl isomers are of equal environmental concern, l.e., that they all persist and bioaccumulate In the same manner In our environment. It has been veil established by academic, government, and Industrial researchers that this Is simply not true. Environmental monitoring programs have clearly demonstrated that, vlth the exception of direct high-level controllable release near points of manufacture or use, the PCSs found in our environment are the more highly chlorinated ones, l.e., those containing predominantly five or more chlorine atoms per biphenyl molecule (2 thru 13). This is true even chough the lover polychlorinated biphenyls have constituted more than 65Z of all the PCSs manufactured over the years. This is strong evidence that the lover polychlorinated biphenyls degrade rapidly. It further demonstrates that even under conditions of unlimited use, and vithout special precautions to avoid release Into our environment (vhlch is not the case nov), that the lover polychlorlnai biphenyls degrade rapidly enough to prevent bioaccumulation (4, 5, 6, 27 More recently, it has also been demonstrated In laboratory experiments -Chat chlorinated biphenyl isomers, readily undergo bacterial degradation at rates dependent upon the number of chlorines per biphenyl molecule* (17, 18, 19, 20, 21 and 37). There are also good indications Chat amble environmental PCB levels are decreasing at rates more rapidly than predicted (14, 15, 16). The rapid metabolism of these chlorinated Isomers and their lack of Importance as contributors to the chlorinated biphenyl tissue burdens la evidenced in the results of numerous studies. Riaebrough (2) reported that the chlorine composition of the FCBs detected In Atlantic Ocean zooplankton was approximately 54Z. He concluded "U.S. production of Aroclor 1254 in 1970 amounted to 12 million pounds -- only one quarte innrai 180 100 of Cho production of 49 alllion pounds of A r o d o r 1242. It night be expected therefore that biphenyls with fever chlorine atoms would .predominate in planktonic samples unless these compounds vere selectively degraded." Similar findings in fresh vater and marine fishes vere reported by Zltko (3) and Jensen ct al. (4). The disappearance of the lover chlorinated hpmologs In extracts of tissues from birds (5 34) and mammals (6 33) Indicate rapid metabolism or excretion of thp lower chlorinated homologs. As a result of. the metabolism and/or excretion of the chlorinated biphenyls containing less than five chlorine atoms per molecule, their contribution to the effluent should not be used in measuring polychlorinated biphenyl effluent from a facility. On the basis of these data it Is unrealistic to consider all poly chlorinated biphenyls equivalent in terms of persistence and bloaccumulatlon as does the proposed regulation. Therefore, for environmental purposes, the definition of PCBs should focus upon those vhich are of concern and ve recommend that the following definition be aubstltuted for that proposed In Section 129.09a, Subpart I, Title 40, Code of Federal Regulations: "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which Is chlorinated and which have been shown to persist and rapidly bloaceumulate In the aquatic environment. These chlorinated biphenyls are Identified as those components having gas chromatographic retention times greater Chan 60, relative to p,p-DDE 100, under the standard conditions recommended in the EFA PCB test method." ANALYTICAL METHODOLOGY * Ve have ho reason to doubt that the reeosaended IPA PCB test method Is capable of detecting parts per trillion (ppt) levels of PCBs In waste waters. However, our experience with analyzing industrial waste waters for PCBs at the parts per billion (ppb) level prompts us to be concerned about the following areas, some of vhich are not covered adequately In the test procedure. 1. Sampling Procedures 2. Correction for Laboratory and Reagent Background 3. Correction for Non-PCB Sample Interferences 4. Absolute Verification inm 181 l o o ;.q - \8 5 Physical State of PCBs (Adsorbed/Dissolved) 6* Quantitation 7 Precision in- Accuracy Our concern lies la che face chat any method, especially one as complex as a PCB analytical method, which is Co be used for effluent control purposes must be tnoroughly evaluated and its accuracy and reproducibility proven. If this la not done, the effectiveness of any effluent limit, no matter what Che level, will prove to be .difficult, If not impossible to determine. For example, ve have found that If waste water streams are not sampled properly, the PCB levels found depend on the sampling procedure employed and bear no relationship to the amount of PCSs discharged. For this reason, sampling procedures used must be designed for che discharge in question and clearly stated. To our knowledge, this has not been done. Ve also note that no provisions are recommended for correcting the apparent PCB level found In a sample for laboratory and reagent background. It la our experience that as one approaches che ppt level, `this background can significantly affect the observed FCB level. Vlth regard to correction for non-PCB sample Interferences, we feel Chat, while the procedure notes many of the possible Interferences, it does not reilly address Itself to those which are more likely to be in Industrial waste water streams. For this reason, if the electron capture chromatogram does not match the PCB being manufactured or used, complete absolute verification of all components counted as PCB must be validated via an alternate technique such as gas chromatography/mass spectrometry. Ve also note Chat the recotmnended ETA PCB test method does not specify a mtana of differentiating between dleaolved and adsorbed PCBs. Ve believe this should be done since there is a definite difference In the toxicity and availability for bioaccumulation of dissolved and adsorbed While the scheme proposed for estimation (quantitation) of PCBs Is logical, it suffers from che same shortcoming as do the multitude of ot! procedurea which have been proposed. It la an empirical estimate and only a reflection of che real PCB level. Therefore, It should be determined via an alternate, more-elaborate procedure how closely the calculated PCB levels (for each of the cases) -are to the real PCB level: ao chat they may be corrected. F/i01233 182 ioo:rn t -9- Last, but doc least, the precision and accuracy of any procedure propo as a standard method should undergo a chore ugh inter-laboratory evalua If this has noc already been done le must be carried ouc prior to the oat of Che procedure for enforcement purposes. The accuracy and precision of the Monsanto PCS procedure has been subjected to a pre liminary evaluation. Prior to this evaluation, ve probably would have overestimated the precision and accuracy of our procedure. The exact details of the evaluation are available. i Briefly, samples were prepared by spiking distilled water with 500 pob PCBs. Individual preparations include blanks (no FCSa), Aroclot1^ 1242 Ar oclor 1254 only, A r o d o r 1260 only, all 50-50 two-component mlxtur and a 1/3 1/3 1/3 preparation containing all three components. Six samples of each mixture were prepared and analyzed by two experienced analytical laboratories. Bach result, expressed in ppb of the individual Aroclor, was converte to percent of the total added. Analysis of variance was run on all data taken together and on each laboratory Independently. The 95S confidence limits observed for individual results were: Either Lab 87.5 + 55.22 Lab A 8 1 . 3 + 46.4X Lab B 9 3 . 7 + 19.22 . The repeatability for t.he individual labs, based on repeat testa of samples having identical prepared compositions was: Lab A +*42.02 Lab B + 11.62 . Ve feel that these results demonstrate the importance of evaluating tfc precision of any PCB procedure. Note chat the test did not include sampling problems, used distilled veter free of interferences, and was carried out at a relatively high PCB level (500 ppb; 500,000 ppt) by two experienced laboratories. It la expected thet, if sampling proble were involved, end Che level of PCB present was extremely low, the accuracy and precision of any PCB method would decrease considerably. 183 1 0 0 70 i -10- % V qt BACKCROUND FOR PROPOSED EPA EFFLUENT STAKEARP' j'i la ha establishment of the proposed effluent standard the primary basis for toxicological consideration ease from the Water Quality Criteria. October, 1973. (Federal Register, Vol. 38, pages 29646 et seq., Friday, October 26, 1973). These criteria were, in turn, based on Water Quality Criteria, 1972. by the National Academy of Sciences and the National Academy of Engineering. The Water Quality Criteria, October, 1973, have not undergone the normal reviev, criticism, c o m e a t and revision before final adoption. We object to the uae of challengeable portions of a proposed publication in the development of critical effluent atandards. We note in Water Quality Criteria, 1972. in those sections pertaining to polychlorinated biphenyls, the frequent use of unpublished data and the disturbing use of qualifying phrases such as "...may adversely affect...", "...apparently related...", or "...the work...suggest..." In our opinion, none of the discussions present adequate data to support establishment of responsible effluent standards for ?CSs. On page 5 of Water Quality Criteria, 1972, the Cotanittee emphasized the Importance in understanding that there Is a distinction between criteria and standards and that the words were not interchangeable nor or they synonyms for words such as objectives or goals. The report further states that lc?ls necessary to establish scientifically-based recoomendac for each assignable water uae, implying availability of practical methods of detecting and measuring which can be applied to monitoring. Once these fundamentals are available, political, social and economical factors enter Into the decision-making process to establish atandards. In our opinion, these procedural steps were not followed in arriving at the proposed effluent standards for FCBs. The maximum acceptable concentration in fresh water that would be permitted by the proposed standard is 0.002 mg/1. The rationale describe in the Statement of Basis and Purpose, Toxic Pollutant -Effluent Standards la based on results of a preliminary study which have suggested (not yet proven) a threshold PCB level for selmon egg mortality. We cannot accept the selection of salmon as representing organisms which are usual or may potentially be present in water systems near facilities described la Section 129.09, Code of Federal Regulations. The cumulative sales of FCBs in the United States since 1930 has been estimated to be about 500,000 tons snd that total world production was probably 1,000,000 tons (1). About one-half of the PCBs were used in applications where containment was difficult and losses into the environment were common. With this amount of material discharged into the environment, it is of considerable importance to note chat extensive harm predicted by some theories has not been found and documented. S#la -VI Fool 184 ! \ . 10070" 11 This lack of evidence Indicstes Chet all of the PCBs do sot persist In the environment as a result of factors such as the biodegration ve have discussed previously. Also, the PCBs thaw do persist nay not be reliable because of s m e factors not clearly understood at present. One characteristic which undoubtedly Is of significant importance is the ability of PCBs to adsorb tenaciously to particulate matter. Under these conditions, can PCBs be rightfully considered to be environmental active and, if so, to what degree? There exists st present a critical need for data relating to partition coefficients between water and sediments and diffusion coefficients In sediment (1, 22, 39, 40). Although many reports have been published on the subject of poly chlorinated biphenyls and living organisms, the majority of these describe the presence of PCBs In the environment. Presence should not be assumed to imply adverse effeet. To our knowledge, no published report exists which conclusively relates the mortality of any wildlife species to the presence of PCBs. The only reported mortalities are those achieved in laboratory studies. Not enough Is known about the fate and effect of PCBs In the natural and diverse aquatic and marine environments to properly design laboratory studies. Results from such studies are not extrapolatable to the natural situations and any conclusions derived from such studies must still be considered speculative. Fundamental scientifically-based data Is lacking and, in Its absence, the establishment of effluent standards for polychlorlnat< biphenyls cannot be made intelligently and responsibly. In the establishment of the PCB effluent standard for freshwater systems a bloaccumulatlon factor of 200,000 was selected. This factor has no extrapolatable relationship to either the residues of PCB in salmon eggs or to PCB residues of fresh water orage fish. The only published report (27) of an accumulation factor of the magnitude select* was that for the hepatopancreas of the pink shrimp, Penaeus durarum. Even though an accumulation of 204,000. In the hepatopancreas has occurr* nearly complete elimination of PCB from that tissue was achieved when the shrimp were placed In water free of added FCB. The equilibrium whole body accumulation plateau indicated an approximate accumulation factor of 22,000. These results are in agreement with those reported b; Stallings and Kayer (29), and with the studies of Ryther (28) , Grelchus at al (24) and Cruap-Velsner, at al (22) showing equilibrium blomagnlfl* Cion factors between water and fish ranging between 1,000 and 75,000 pending on the presence and absence of sediment and the specific PC3 mixture present. These data would support the selection of a factor considerably lover than the factors which were applied. 10019.H6 185 10070.: 4 > 1 i 1 J \ ( i J 12- Arbitrary safety factors were applied-to the tolerable chronic H a l t tc establish the so-called "critical chronic H a l t " which was then used tc compute the maximum allowable effluent. These safety factors were proposed to account for a multitude of variables, Including non-point sources, multiple discharges and industrial growth. The safety factors proposed were identical for 7 of the 9 materials for which effluent standards were prepared. These safety factors, resulting in approximac two-fold reductions, are so small aa to be of no beneficial toxicologic consequence. Ve re c o m e n d that no safety factor be applied. In establishing the effluent standards, an attempt was made to distinguish between types of receiving waters by classifying them as streams, lakes and impoundments, estuerles and coastal waters. Ve do not believe this attempt to distinguish water bodies Is by any measure adequate. Vater bodies are universally known to be complex systems with no two systems alike. With e complex material such as poly chlorinated biphenyls, the determination of possible adverse effects ii each vater body becomes exceedingly difficult. The uniqueness of each vater system sc each point source must be considered. A key parameter used to further describe the water body is the flow rate which was limited to the probable low rate of stream flow occurrlx during a seven-consecutive-day period once in ten years. Ve do not agree that this la realistic or appropriate. In our opinion, approprl* control is achieved using avenge stream flow rotes. Further, the maximum flow rate that ean be used in .calculating the dal! discharge permitted has been arbitrarily set at 10,000 cubic feet per second. This limit is based on a nondegradation philosophy which tolerates limited diffusion and on a desire to discourage industry frot locating facilities on large main Inland waters and coastlines. This limitation deprives our society of the. Judicious use of an important g: natural resource. Discharge limitations should be based on the effect: a material will have on a vater system, giving consideration to its si and flow rate. For PCBs, proper control will not occur by Imposing maximum flow rtte conditions, but by applying results from scientific studies vhleh properly define how each water system responds to the presence of PCBs. RESIDUAL POLYCHLORINATED BIPHENYLS Because of their ehemlcal end physlcsl properties, PCBs can be found 1 soils snd waters at point sources long ifter a discharge has occurred. This source of PCBs to the environment will diminish with time but its presence will distort snd misk results from current control activities To maintain control of losses, emphasis should be directed toward discharges resulting from current snd future uses of PCBs. F o n t ?.R7 186 i n O T G . i 13 Sine* thle problea of background level occurs vleh 11 materials In Tarring degrees, ve propose the following revisions: Troa Section 129.01c(b), delete the words "in intake waters for a discharger". Add an additional definition in Section 129.01a: " 'Background' mean amounts of toxic pollutant (1) presently found in the waterways of the United ; .States (Including the intake waters of a discharger), . or (2) arising out of operations subject to this Fart that occurred before the effective date of this Fart, but were not discharged to the waterways of the United States before the effective date of this Fart." ECONOMIC CONSIDERATIONS At our FCB manufacturing facility, ve developed and instituted an aggressive control program whleh ve described before the Effluent Standards and Vater Quality Information Advisory Coraiittee, EFA (41). Tet, in spite of all our efforts, ve cannot today meet the proposed affluent standard. In response (42) to an Inquiry from the U.S. Department of Commerce, ve emphasl2ed that technology has not been developed to the point that facilities could be designed to meet a reasonable standard. However, analytical techniques suggest a conceptual design using adsorption, settling and filtration of aqueous waste, followed by incineration of the adsorbent, probably carbon. Ve estimate the capital cost of such a facilityi sized to handle our plant waste, at 5600,000, not including a dedicated Incinerator for the disposal of the adsorbent material. \Annual operating cost would approximate $150,000. `The value of Monsanto's annual FCB production is about $8 million, while the value of the electrical devices made therefrom Is an order of magnitude larger. If Monsanto were to cease production of FCBs, the Jobe of 55 employees would be eliminated directly, while those of an additional 47 employees in a supporting facility would be in jeopardy, total payroll Involved is on the order of $1.5 million. Hut impact of a FCB ban on our customers can best be described by them. However, it is apparent that capacitors or transformers made without FCBa will be less fire-resistant than present products, thus leading to an undeterminable incidence of fires, higher Insurance races, and additional protection facilities. In the case of capacitors, the replacements are likely to be larger and less efficient, thus consuming ore of the resources required in their manufacture. A more cooplete 187 10070- 14 analysis of the consequences of e PCS ben ves developed by the General U e c t r l c Company end addressed to Dr. Karthe Sager, Chairmen, Effluent Standards and Veter Quelle? Advisory Committee, EPA (43). Ve concur . with the General Electric Company's conclusions. Our purpose In consenting on the proposed standards is to aid the Agency la the development of realistic affluent standards which will achieve the intended objectives without serious technical, social and economic disruptions. Ve recognize the seriousness of this endeavor tad find a statement made by Hr. John R. Quarles, Jr., Deputy Administrate Environmental Protection Agency, of considerable Interest. At a recent confercace, Mr. Quarles (26) rated: "Ve have found it virtually impossible to devise intelligent standards which specify an appropriate degree of control over toxic pollutants Irrespective of the sources of those pollutants and factors affecting the feasibility and timing of their abatement." The difficulties which could be anticipated in establishing affluent standards were recognized by the National Academy of Science in its preparation of Water Quality Criteria. 1972. In a review which appeared in the Environmental Reporter (38) dated August 24, 1973, the following pertinent statements highlight some of the areas of concern: "Knowledge of local environmental conditions la essential prior to application of any water quality recommendations for marine aquatic life and wildlife..." "NAS said application of recoemendations to a local situation is unique beesuse it requires an under' standing of the circulation of water and the resultant mixing and dilution of pollutants, a knowledge of bio logical species and determination of the most sensitive species, and an evaluation of the transport of materials through the food web." "NAS said It is not practical to make recomiendatlons for the relatively persistent organic pollutant based on veter concentration, especially when partition :sft coefficients are unknown." T' Ti>m ?r9 188 100700 15- I Wt cmn appreciate Mr. Quarles' concern, particularly as It applies to PCBs. Lacking good seleatlfle lnfomatlon on the fats and effects of PCS# la complex water systems each having unique characteristics, wo urge extreme ears be taken to avoid the promulgation of effluent standards which are unattainable and unwarranted. i Subscribed and sworn to before &e this V. B. Papageorgb. i I A_ day A A - j My Coaalaslon expires - t } s' Fnoi?40 I189 m 0-f J. j1