Document rxQK0X8x720dvZmXZMgOndY6G

PARTICIPANTS PCB STANDARDS MEETINO February 28. 1974 CERTIFIED BALLAST MANUFACTURERS Mr. N. R. Clark Universal Manufacturing Co E.I.A Mr. Arnold S. Doty Dr. E. M. Moore Mr. Rudy Carlson F. R. Mallory ft Co., Inc Electrical Utilities Co. Eleetrleal Utilities Co. GENERAL ELECTRIC COMPANY Mr. James S. Nelson Mr. Stuart Rlchel Dr. Edvard L. Simons ' JARD COMPANY, INC. '-^'Mry vRtcbmrd-'afted-Kca &***/*+ ** t % NATIONAL EZECTRICAL MANUFACTURERS ASSOCIATION (NEMA) Mr. A. M. Salazar VESTINQHOUSE CORPORATION Mr. H. Sheppard Mr. N. H. Smith ' AM 00727s 156 TOWOLDMONOOOI367 MONSANTO COMPANY P. 0. Benlgnua S. S. Bergen d. B. Bonner R. B. Muneb V. B. Papageorge V. V. Withers C. Baton V. R. Richard J. R. Savage E. S. Tucker P. L. Wright >2' Market Manager Business director Vt11Itlee and Environmental Protection director Senior Selence Fellow Manager, Product Acceptability Attorney Product Manager Manager, Research and development Manager, Manufacturing .. Research Oroup Leader Manager, Toxicology ADM 007279 157 TOWOLDMONOOOI368 I AGENDA PCB EPPLPENT STANDARDS MEETIHO February 28, 2974 9:00 AM 2. Welcome - B. 8. Bergen 9:20 AM 2. Introductory Remark* - V. B. Papageorge a. Brief Review of Proposed Standard b. Critical Action Bates e. Objective* of Meeting o0 * 01 9:15 AM 9:45 AM 10:15 AM 10:30 AM 11:30 AM 12:00 Noon 12:30 PM 1:15 PM PM 2:45 PM 3:00 PM 3*30 PM 4:00 PM 3. Discussion Topics a. PCB Characteristics - Realistic Definition chemical, physical, biodegradation ' b. Sampling and Analytical Methodology Break e. Toxicity Acute Chronic d. Bloaceumulatlon - Blomagnlflcatlon e. Dilution - Stream Size Lunch e f. Proposed Effluent Standard : 8* Control at Manufacturing and Use Sites Current losses Background Break b. Sconoale Considerations 1. Aetlon Plans Adjourn AOM 001260 - 158 TOWOLDMONOOOI369 f MINUTES OP PCB EFFLUENT STANDARDS MEETINP I. Mr. Howard S. Bergen, Jr., Director, Specialty Products Business Group of Monsanto Industrial Chemicals Company, welcomed the participants. 2. Introduction - V. B. Papageorge Mr. Papageorge summarised the timetable past and future on toxic pollutants: July 6, 1973 - Toxic Pollutants list published .` September 7, 1973 - Final toxic pollutants list pub lished including PCBs and 6 other chemical classes (e.g. cyanide, mercury, DPI, cadmium, etc.) December 27, 1973 Proposed Effluent Standards published January 18, 197* Filing date for status as participant at proposed EPA Bear ing on Standards January 23, 1974 (l) Prehearing Conference with EPA (ll). NEMA, Monsanto, O.E. and Vestlnghouse recognised as participants. (ill) A total of 38 objectors ex pressed an Interest. They represented Industry or trade associations with the exception of the Michigan Vater Research Commission and two powerful environmental groups (Environmental Defense Fund and National Resources Defense Council). (IT) Presiding officer wade It clear that Hearings will be strictly for cross-examination of participants1 testimonies in affidavit fora only. AwM 0072ol 159 TOWOLDMONOOOI370 March 15, 1974 - Written testimony by 38 objectors io~be submitted In affidavit form, April 8, 1974 - Bearings open for cross-examination and rebuttal evidence. CN'/Cd/Hg first three. PCBs are 7th (third from last). Mid-May, 1974 - Bearings completed. (Evenlngs/veekenda may be used.) J4ne 25, 1974 Final atandards published - effective In one year. It should be noted that others who are affected by these atandards can still comment by March 25 to: Sr. C. Hugh Thompson, - Chairman-Hazardous and Toxic Substaneea Regulation Task Force Office of Water Protection Agency, Environmental Protection Ageney Washington D. C. 20460 Industry representatives atlll wishing to comment and who need more background Information can contact any of the Industry participants (see attached list) or Mr. W. B. Papageorge of Monsanto (314-694-4051). Mr, Rlchel (O.E.): - (l) (ll) Made a plea for greater Industry participation. Comments ean still be made up to March 25 with sound excuse for tardiness. . > EPA at January 25 prehearing Conference were reluctant to expose themselves to cross-examination* Dr. Hugh Thompson to be available for cross-examination at Hearings. (ill) Many objectors bad common Interest (e.g. environmentalists). EPA suggested a common counsel for this group. (lv) On each of first 3 pollutants, EPA would offer 2 witnesses. Mr. Doty (P.R. Mallory) asked about bearing of economic factors on standards. ' Mr, Rlchel (O.E.) stated: . (l) Lav la clear-economic factors are not relevant In establishing standards. (ll) EPA Is somewhat of a split personality on this. The ADM 007 160 TOWOLDMONOOOI371 I -3- Presiding Offleer at the Prehearing Conference ruled that econoalea are relevant. KRDC (National Resource* Defense Council) objected and was over-ruled. (ill) Industry ean and should therefore introduce relevant econoale data. SPA would be wise not to expressly refer to such data In the published standard otherwise MRDC' could go to court and EPA over-ruled. Department of Commerce It was pointed out that Sidney R. Oalller, Deputy Assistant Secretary for Environmental Affairs at the Department of Commerce wrote Monsanto on January 15 asking their views on the proposed effluent standards. Copies of Dr. Oalller's letter and Monsanto's response were circulated at the meeting. Industry should contact the Dept, of Commerce. Their legal counsel (Kr. Norland) has been active on the side of Industry in other environmental bearings. Mr. Salatsr (KEMA) pointed out that the PCB Task Force had recommended a standard for PCBs of 0.01 ppb in the main body of water. (EPA was a member of that task force). ANSI C-119 proposes to use this Task Force recommendation and print this as a standard of 0.01 ppb in main body of water. Mr. Sheppard (Vestlnghouse) queried if plant effluent standards could be set to meet O.ol ppb. Dr. Simons (O.E.) said this Implied an acceptance of ANSI C-119 by industry. There seemed to be some doubt on this., PCB Characteristics ' Dr. Tueker (Monsanto) presented hand-outs on: * (a) Monsanto's proposed definition of PCBs ' (b) Comments on EPA'a proposed analytical methodology (c) Monsanto's pre-publlcatlon paper on biodegradation of PCBs. (a) Definition of PCBs 1-A chloroblphenyls do not have long residence time. PCBs up to tetracbloroblphenyl are not of concern on environmental persistence or blomagnlfleatlon. Dr. Tucker proposed the following definition: *0* 00723* 1S1 TOWOLDMONOOOI372 -4- I c 'Polychlorinated biphenyls (PCBe) means materials containing the biphenyl group which la chlorinated and whleh have been shown to persist and rapidly bloaccuwulate In the aquatic environment, these chlorinated biphenyls are Identified as those components having gas chromatographic retention times greater than 5** relative to Pi p-DEE a 100, under the standard con ditions recommended in the EPA PCB test method." . Hr. Sheppard (Vestlnghouse) said Monsanto'a proposed definition was relevant to persistence but was it relevant for standards directed toward toxic materials? Are persistent materials non toxic? Mr, Wright (Monsanto) stated the proposed effluent standard bad two parts: (l) acute limits directed to toxicity of materials and specifically limits PCB concentrations on that basis. (11) dally load In effluent - based solely on bio magnification (relevant to persistence). ( Dr. Simona (6.B.) pointed out that section 397-A of the proposed standard refers to persistence as being a critical factor to be considered. Dr. Tucker (Monsanto) stated we were badly hurt if all PCBs are regarded as persistent and If blomagnlflcatlon factors of 200,000 are used. Researchers other than Monsanto have found bacterial degradation of PCBs and that PCBs have been found to 4* undVrgCr"aiftaboilsrs*tn-both^avtagtatr-aad-^sinwaHan^anlmals^c Mr. Kelson (O.E.) asked If proposed PCB definition would exclude Aroclor 1016. Dr. Tucker (Monsanto) Aroclor 1016 would be excluded for the most pari is lower than pentachloroblphenyl). Aroclor 1242 would be excluded to 65f or better. Aroclor 125* however would not be excluded. Mr. Papageorge (Monsanto) pointed out that of the factors listed . as being critical In determining whleh pollutants made the EPA list of 9/7/73 only blomagnlflcatlon appeared relevant to PCBs. Dr. Simons (O.E.) agreed. AON 00726* 162 TOWOLDMONOOOI373 Mr. Wright (Monsanto) stated that an acute toxleologlcal level is denned in tne FA Baals * Purpose document as c 10 ppm (96 hour LC-50). Be also believes that differences in toxicity among PCBs are minor until chlorinated as high as Aroelor 1260. Mr. Kelson (O.E.) stated that words should be used in a dis course on definition to properly screen us on acute toxicity. In reference to a comment that Aroelor 125* would not be excluded by the proposed definition. Dr. Tucker (Monsanto) offered the opinion that transformer fluids were easier to re cover than capacitors. (b) Analytical Methodology Dr, Tucker (Monsanto) stated the ZPA's proposed method for PCB analysis was being submitted toASTM. He thought the method was well written and capable of detection to ppt (parts per trillion) but it was untried and the quantitative accuracy is in question. The method was not submitted for round-robin testing before EPA adopted it. Monsanto has found that by spiking distilled water with 500,000 ppt or 500 ppb of PCBs we get values for PCB that vary by x 550* Ihe EPA, however, claims a capability of detecting absolute values at 50 ppt. Ifce EPA method Ignores interfering substances. Mr. Clark (Universal Manufacturing) said that with a proposed upper limit for PCB discharge or 0.O6AS lb./day the sensitivity of the analytical method would vary "all over the lot" depending on the size of the water "reservoir" into which the PCBs dis charge . Mr. Sheppard (Vestlnghouse) commented that if the analytical techniques on determining PCB levels are so difficult, how valid are the determination of toxic values for PCBs. ' Mr. Clark (Universal Manufacturing^ asked if analytical techniques differentiate between different chlorine levels. Dr. Tucker ,, (Monsanto) said it would depend on the PCB mixture. Aroelor 1242 could probably be identified quantitatively in a mixture with Aroelor 1260 but addition of Aroelor 125* to the mixture would prevent identification because Aroelor 125* contains PCB homologs that overlap both Aroelor 12*2 and 1260. Dr, Munch (Monsanto)said that the proposed EPA method does not use high resolution and henee handicaps identification of individual peaks. Dr. Simons (O.E.) mentioned that after EPA aet automotive emission standards (HIOX) the analytical methodology was found faulty and the atandards were delayed. In this ease, EPA is not setting the effluent standard on analytical methodology but 00^** 163 TOWOLDMONOOOI374 6- _. en factors such as toxicity and persistence. The methodology is relevant In enforcement and monitoring. This then leads to the possible argument that the effluent standard Is correct and Justified on the basis of toxicology et al, but Is not enforceable due to laek of an accurate method for absolute value deter* mlnatlon of FCB discharge. Mr. Blchel (O.E.) pointed out that EFA won't buy an answer to that argument vhleh seeks to raise the effluent standard to a level that can be accurately measured. Mr. Savaee (Monsanto) felt strongly, however, that this dilemma needed to be In the record. Others agreed. * Dr. Tucker (Monsanto) said ASTM would hold a round-robin on the EfA method and that Monsanto would participate. Be will send the name of the ASTM contact to the participants so that they can decide if they want to Join the round-robin test. Mr. Sheppard (tfestlnghouse) said he was not prepared to aeeept that the proposed efA method for determining quantities and types of FCB in samples and animals was accurate enough so that toxic limits eould be defined on the basis of FCB levels of question able accuracy. Toxicity Mr. Bosmer (Monsanto) etated that the original EFA publication on Water duality Criteria came from a publication by McKee and Volfe for the State of California. The MeKee/Volfe volume was well done and EFA did not change much of It. There Is now a new 2-volume SPA edition extracted from the work of 10 committees of the National Academy of Sciences. . The toxicity of FCBe Is related to salmon egg studies and Monsanto doubts the validity of this. Monsanto has made their criteria were sound. Since then Russell Train*has been sued by NRDC and other groups on the grounds that the toxic pollutants - ' list is not long enough and the proposed standards are too len ient. Mr. Wright (Monsanto) went through the rationale used by EPA in arriving at a fcb discharge maximum of 0.0646 lb./day. Be also shoved how the standard could be changed and yet be consistent with published data on FCBs. Details follow. (a) FDA aet arbrltary proposed tolerances: 5 ppm in fish for human consumption 5 ppm in components for animal feed 0.5 ppm in complete animal feed 00-U* *0* 164 TOWOLDMONOOOI375 7 i (b) Monsanto would not disagree with these tolerances. (e) PDA has presented - acute toxicity Units (point sources) - chronic toxicity limits (daily load) Acute toxicity Haltst 96 hour LC-50 studies for PCBa show: *-280 ppb In fresh water (bluegill) '''10 ppb In coastal or seawater (pink shrinp/oysters) Published data based on naterlals leaving an outlet and going Into a body of water. Acute Units have no direct relation to chronic Units. Chronic toxicity Units; The EPA equation is: Chronic Unit X water flow rate X safety factor gn/day discharge Xn Karine organisms the chronic limit is set as fofflgg* O.OI67 ppb Xn fresh water the ehronle Unit has been determined by using 0.5 ppm as toxic limit for salmon eggs and a 200,000 blomagnlficatlon factor. This gives a ehronle limit of S&S.MO * 0,0025 PBb ` data from Stalling A Keyer (Fish Pesticide Lab, V. S. Dept, of Interior, Colombia, Ko.). Dr, Simons raid that in response to repeated requests by O.E. to the Columbia Lab the only reference they have been given is a Stalling A Keyer paper presented in Carolina in 1971 and which contains no mention of a 200,000 factor. Kr. Wright (Monsanto) stated he has seen only one literature reference to an accumulation factor of ~200,000 and that was in the hepato pancreas of a pink ahrlmp. If the PCB level was calculated on the basis of the total shrimp then the accumulation factor was only 22,O0. Other references give accumulation factors of 1000-75,000 for whole tissues of various fresh water organisms. Accordingly, Kr. Wright proposes that a blomagnlflcatlon factor oT 30.00O ana not oe useo. oe also proposes that we retain the chronic limit of 0.5 ppm with out debating the salmon egg issue. ` ADM 007267 165 TOWOLDMONOOOI376 -8- This would load to a discharge level for KBs: g;5 30.000 X10.000 X (flow rate) - 0.5 % X (safety factor) . M (conversion Into lb./ <uy) 0.*59 lb./day Pile compares to the proposed standard of 0.06*8 lb./day. The aafety factor cones from the ZPA's Basis and Purpose document supporting the proposed effluent standards. It Is supposed to take account of non-point sources of PCBs and la the same as 6 of the 9 toxic pollutants proposed for EFA standards. Monsanto's Medical Department, feels this safety factor la arbitrary and confers no real toxicological benefit. If deleted, the revised bright FCB discharge level would be 0.918 lb./day. One of the most critical Parts of the discharge equation is the water flow rate. A significant number of dielectric FCB manufacturers have plants on rivers where the flow rate Is under 100 efs or If of the EPA cut-off flow of 10,000 cfs. Several plants discharge Into sewage plants which In turn have treated liquid flowing Into rivers or streams with very low flow rates. For a river with 100 cfs flow the EPA maximum discharge would drop to 0.000648 lb./day or 0,102 lb. in a 250 work-day year. Even a revised standard of O.910 lb./day at 10.000 cfs would only be O.OO9I8 lb./day at 100 cfs or **2.3 lb. fer 250 work-day year. Clearly this Is a staggering target to ave to meet. Mr. Doty (Mallory) pointed out that In the present language of the EPA standards municipal sewage systems are not considered point sources. Mr. Blchel (O.E.) was of the opinion that where a plant dis charged into a sewage system without treatment and hence Into navigable waters the plant could have to comply* with effluent standards on toxic pollutants. Mr. Papageorge (Monsanto) felt we should not be complacent and regard discharge to sewage plants being the answer to problems. Mr. Bosmer (Monsanto) stated that 20,000 cfs represents the largest flow the ePa will consider on the grounds that all Industry would move to the largest river. The opposite of that argument Is that it encourages small plants on every stream In the country. Mr. Sheppard (Weetlnghouse) raised the issue of sedimentation. Blnee it appears that all the experiments to establish toxic values were run without sediment effects being considered, the real-life values were questioned. PCBs attach themselves to sediment. Furthermore the sediment moves down river and so FCB would be dispersed from the point source. Zt was pointed out by Dr. Richard (Monsanto) that Aroclor 125* 1 soluble In water up Fo 50 ppb ana that in time partitioning between sediment and AON 00724b 166 TOWOLDMONOOOI377 9- water eould taka place. Hr. Wright (Monsanto) agreed that the discharge Halts were extreme cases in the absence of sediment considerations and this was worth study and incorporation Into arguments against tne proposed levels. Pr. Simons (O.E.) queried whether we were correct la concen trating our attacks on the criterion of toxic effecta of mammala eating fish and ignoring the possible argument that fish per se smst be protected. Mr. Wright (Monsanto) said the proposed standard says both, in salt water, standards are proposed that would protect the species that eat organisms containing FCB. Zn fresh water, if 0.5 ppm in salmon eggs correlates with <5 ppm In salmon then we are protecting salmon. Be also said that the chronic limits and blomagnlfleatlon limits he was proposing would protect the species themselves. We should, however, beware of arguing for higher levels in fish because we could draw EPA and FDA into conflict. The FDA levels in food, fish etc., are temporary tolerances and any arguments against their validity could lead to a reduction in these tolerances. Mr. Savage (Monsanto) queried whether raising the level in organisms could cause possible danger to predators. Dr. Simons (O.E.) quoted from page 39 of the Basis ft Purposes document which states that the body burdens of birds and mammals should not Increase over present levels. Page 51 of the same document cites a Wat. Acad. Sel. report which gives 2.0 ppm FCB as tolerable level In flesh of whole fish. 2.0 ___ s 0.1 ppm PCB _. 200,000 is given as tolerable level In water divided by a safety factor of 5 to give a maximum PCS concentration In water of 0.002 ppm. Thus EPA accepted 2 ppm PCB level in fish but got to water concentration of 0.002 ppm by using a high level of 200,000 for blomagnlfleatlon and an arbitrary factor of 5* i If we were to revise the proposed EPA standard by: (l) using 2.0 ppm as chronic limit in fresh water species instead of 0.5 PPmj (ll) substituting 30,000 instead of 200,000 for blomagnlfleatlon factor; . and . (ill) ignoring safety factor of 0.5 then the maximum permissible discharge in lb. FCB per day would be: 2.0 ,, 10.000 5.4 -- 3.6 lb. xx A&rt 00720V 167 TOWOLDMONOOOI378 10- For the plant situation on a river with a flow of only 100 efs the discharge would be 0.036 lb/day or 9*0 lb. per 250 work-day year. These levels are still far below tne 5 ib./day given in xsfinc-107. Zt is therefore apparent that ether aspects of PCBs auat be highlighted In order to get away from FOB discharge levels as low as even our "revised proposals. Aspects to concentrate on are: (1) Definition of FCBs that excludes biodegradable bonologs. Ihls could exclude 90JS or better of Aroclor 1016 and 6556 or better of Aroclor 1242. On that basis, discharge levels would be as follows: PCB Type "Stream Discharge (lb.rtB equivalent/day) Flow (cfs) EPA wrlght Simons/wrlght Any PCB Any PCB Aroclor 1010 Aroclor 1016 Aroclor 1242 Aroclor 1242 10,000 100 10,000 100 10,000 100 0.0648 0.000648 0.04tt 0.00648 0.1$4 0.0019 0.918 0.00918 9.1b 0.0918 2.75 0.027 " ' 3.6 r 0.036 3573" 0.36 10.0 0.10 (2) Try to change stream flows from the present value of the flow rate in cubic feet per second (cfs) expressed as the probable low rate occurring during a 7 consecutive day period once in lo years at the effluent point. % If the average flow rate over a period of time (to be agreed on) was used, the lowest flow rate In the equation could conceivably be raised by a factor of 10 from 100 to 1000. In the Slmons/Yrlght version for a standard the Aroclor 1016 discharge could be raised to 3.6 lb./day at 1000 cfs flow and Aroelor 1242 to 1.0 lb./ day at 1000 efs flow. (3) Magnitude of FOB Point-Sources It Is possible that EPA and environmentalists are totally misinformed on the number of plants still using FCBs. In the U.S. today there are: ADM 007290 168 TOWOLDMONOOOI379 11 i 1 PCB manufacturing plant --18 capacitor plant* using PCB --27 transformer manufacturing plants using PCB In the past there were probably 1500-2500* plants using PCBs. Only 2-3% of these plant* continue to use PCB today. * (Subject to closer checking If necessary*) Xn the past ~97Jf of plants using PCBs purchased --40 million pounds of PCB per year. Konaanto'a PCB salea policy has therefore - reduced number of using plants to -- 2-3Jf of previous total. - eliminated -- 40H lbs. PCB sales per year. The EPA standard would limit PCB discharge per plant to 0.0648 lb./day or--32 lb./day across the U.S. (--50 plants). This equates to--800 pounds In a 250 work-day year. Since fish have survived throughout the 40+ years that PCBs have been produced and widely used, the standard proposed by EPA seems far too drastic. Turning again to the Slmons/Vrlght proposal we can estimate the effect In terms of annual PCB discharge Into water across the U.S. at lOOOcfs: Discharge As Discharge (lb./dav) "TS Total Per No. 250 days Plants (pounds) i As Persistent PCBs Discharge No. US' (lb./day) Plants Tots: Any PCB 3*6 Aroelor 1016 3.6 Aroclor 1242 1.08 Aroelor 1254 ____0.36_____ *1 18 4 *2___ 900 16200 1080 2070 i.2 1 300 0.3 18 1620 0.36 4 360 0.36 23 2070 20.250 4350 * Plant Is on river In excess of 10,000 efs. Using this technique an argument ean be made in favor of the ANSI C-107 proposal of 5*0 lb./day. SUM 007291 169 TOWOLDMONOOOI380 12 Proposed Effluent Standards Dr. Simons (o.E.) summarised the points he felt bed to be dealt with in trying to change the proposed standard: 1. Higher persistence of bltfter PCBs versus alleged lover acute toxicity 2. Background levels of PCBs 3* Written testimony of participants and correlation Toxicity BPA Basis k Purpose document (page 50) states that 96 hour LC-50 to fish cannot adequately measure toxicity of FCB. Where is time demarcation between acute and ehronlc. Chronle effects can be either lethal or non-lethal. Why are PCBs on the list on toxic grounds? LD-50 for FCB is such that it is not considered toxic to humans. For protection of aquatic life the Wat. Acs. Scl. set a 96 hour LC-50 of 10 ppm or leas. In proposing a definition for PCBs, Dr. Simons (O.B.) felt we should stress: (a) lack of persistence of homologs below tetraehlorobIphenyl. (b) chronic toxicity does not arise for the lover homologs because they are non-persistent. ( . **'!* gnorfr-arute^borlblty*no-?rel-'dtffeeences-*r>` between Aroclor 1016, 1242 and 1254.- Participants need to consider: Do we have the best definition? In the tentative BPA analytical method we should take note that In the table on p.3-22. the percentage of PCB was not controlled. Hr, Carlson (E.D.C.) pointed cut that in its present form the standard could saddle present PCB users with all other dis continued uses. Dr. Richard (Monsanto) pointed out that FDA and Boxboard Manufacturer's Association nad agreed on a protocol that protected recycle paper users from Just sueh a situation. Mr. Bergen (Monsanto) asked that copies be circulated to participants. . , AOH 007292 170 TOWOLDMONOOOI381 We need to word our definition* to exclude realduel*. Participant* should exchange proposed drafts on wording re garding residuals by March 7. 0. S. stated we should not approach the hearing on the basis that things ca^t be done, feather iatce the proposed standard and point out wnat it weans in real life. Xn G.E.'s ease they use X H ID./year and yet can't lost 0.5 drops per day. Stream flow rates make the matter worse. Shis Is point on whleh Dp. Thompson should be cross-examined. Of the participants present, 5 plants discharge Into sewers with outlets Into rivers (very small except in 2 eases). Three plants discharge Into small rivers. Wo one at the meeting could cope with the 1PA standard as It is proposed. Only"Jard expressed an opinion on wnawevei xney could live with. (Jard stated 27 lb. Aroclor 1016 per day. This would be 2.7 lb. PCB by our proposed definition.) AuH 007293 171 TOWOLDMONOOOI382 14. - Participation at EPA Hearing ---------- --- . .Definite participation: Monsanto 01 Vestlnghouse . Undecided: Electrical Utilities Jard HEMA Wo participation: Electronic Components Mallory Objectors of record could adopt non-responding company as witness. G.E.'s testimony will fall into the following areas: - Explanation of why PCBs are used - Consequences of ban on customers - Inadequacy of EFA/Wat. Acad. Sel. statements - Bow standards would apply to O.E. - Inadequacies of the Standard .. - definition - methodology - logic behind the standard Other contributory actions: - Involve Federal Energy Office (e.g. Aerovox letter on motor-run capacitor contribution to ease energy crisis.) _I ^^^Involve.R.E^CU/othar^agqnc ies *slong -Jbf petrochemical producers' FEQ report. % - Power Systems Group of IEEE will circulate a posi tion paper on PCBs (technical aspects) in the dielectric industry to Congress, EPA, PEO and Dept, of Commerce (target date: April). AON 00729* 172 TOWOLDMONOOOI383 15 Action flans 2. (W. B. Papageorge) Circulate to participants eoples of . PDA/Boxboard Manufacturen protocol . on PCSs in recycle paper. 2. (Participants) Exchange drafts on testimony regarding PCB reslduals/baekground levels with each other by March 7. (Monsanto contact should be V. B. Papageorge.) 3* (Participants) Subnlt to V. B. Papageorge their thoughts on proposed PCB definition (to exclude 1-4 chlorine honologs). A. (Participants) Conaunieste with eaeh other on how best to hsndle sedimentation phenomenon (as raised by Mr. Sheppard of Vestinghouse). 5. (E. S. Tucker) Send out name of ASTM contact for participation in round-robin on proposed EPA analytical method. 6. (Participants) Vrite to Dr. Caller of Commerce Dept, opposing EPA standards. (See Caller letter to Monsanto and Monsanto response.) 7. (Participants) Those who have not responded to EPA can still write Dr. Thompson by March 25. Si ^A,-Salac*xvjCaJ.^e^jUftgtn/l&PjgUU* Edison on the proposed standards. (b) Determine role NEKA, will take on affidavits/testimony at EPA bearing. 9. (V. B. Papageorge) Obtain PEC report and send to Mr. Nelson (O.E.). 20. (Participants) Involve F.E.O. in EPA Hearing along lines of Aerovox letter to Secretary Simon. AON 007295 173 TOWOLDMONOOOI384