SUBPART R: PRIMARY UAO SHELTERS Section 230.280 ' Primary lead Smelters The Board Incorporates by reference 40 CFR 60.

Reg. 28154 (June 2, 1977) " The function of the industry-EDF meeting you mention was to frankly discuss differences between the industry position and that of EDF with the hope that mutual understanding of one another would lead to a clarification of the issues.

In this situation, any malfunction in the emission recovery system which removed vapors from the blowdown tank or an excessive VCM feed rate could quickly lead to overpressuring the tank.

The testing was conducted on a mixture with chemicals having varying degrees of biodegradability, leading to potential misinterpretation of the results.

Analytical Research Section BW Attachments Copies to: FK ^ JCL RTF D2 SAL 0000881.14 TABLE 1 ORGANIC PRIORITY POLLUTANTS FOUND IN LCCP 002 OUTFALL Compound tW: nz rue To 1uone Xylenes Ethylbenzene Pheno1 Naphthalene Di (2-ethylhexyl)phthalate Concentrations in ppb by 624 by 62 244 --60 2 -- -- -- ------ -- 110 16 8 26 11 Antimony Arsenic Beryllium Cadmium Chromium Coppor Lead Mercury Nickel Se 1 on i inn SiIvo r ThaIlium Zinc Al uininum Bn r ium Bo ron Cobn1t Iron Magnosium Molybdonum Mangane sc Tin Titanium Ca1cium St routium Vanadium Sodium TABLE II DISSOLVED METALS IN LCCP 002 OUTFALL Concentration in Mg/Liter by ICP by AA <0.25 0.006 <0.005 <0.015 o7oT3 0 _ o24 <oTT5 <0.075 <0.03 <0. 5 o. n 6.8 0.15 <0.05 1 .0 12 <0.05 0.45 0.13 0.24 220 0.71 0.026 62 < o. o rr <0.002 1.6 sSAI' 00008 U?

VVC 0000X3099 TABLE I DTSSt )LVF D METALS IN VCM 101 OUTFALL Antimony Arsenic Bery11 ium Cadmium Ch romium Coppe r Lead Mercury Nicke 1 Se1enium Silver Thailium Zinc Aluminum Barium Boron Coba 11 Iron Magnesium Molybdenum Manganese Tin Titanium Ca1cium St rontium Vanadium Sod i urn Concentration in Mg/Liter by ICAP by AA <25 0.005 < 0.5 < 1.5 < 3.0 1.9 <2 5 < 0.013 < 7.5 < 0.002 <3 <50 3.4 <15 8.5 <5 8.8 1.6 26 <5 7.2 < 0.0 < 2.5 23000 74 < 2.5 180 TABLE 11 DETERMINATIONS ; BY CHEMICAL ANALYSES ON VCM 101 OUTFALL Parameter Total phenols Tota l cyanide.

Again reminded them that we required 90 days lead time to get material from our European plant to manufacture the mix.

This only includes measurements directly assessing the absorbtion of chemical into the body, which for us would be urinary phenols and blood lead measurements.

This analysis leads to the conclusion that there Is no measurable risk at current exposures, a position which Is supported by the failure to find any cases among the general population.

COMPUTER Inventory control, energy and blood lead programs are in use and functioning properly.

I cannot imagine anyone better to lead EPA's Office of Air and Radiation at this critical time in EPA's history.

Washington, D.C. 20036 November 5, 1982 KtCLIVtD r)F.C 1 3 1982 R.U DANIEl Dear Sir: The lead story in "Government Concentrates" on page 28 of your September 20, 1982 issue misses the essence of CMA's concerns over the benzene risk assessment.

The current description could lead to unnecessary Superfund reporting.

Cleaver Derailment on ICG Three loaded VCM tank cars leased from Union Tank Car Company were derailed on the Monroe Lead in Aberdeen, Mississippi last week.

Other considerations under proposed Permit No. 31F00006 GD may concern lead testing and monitoring of rain overflow.