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(10) Zn is essential to the many metaloenxymes of all organisms and of several proteins of unknown function.

(11) Sodium increases P absorption probably due to the fact that it converts insoluble nutrients to an available supply of soluble nutrients.

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(12) Magnesium is a must as the metal in the porphyrin structure of chlorophyll and for some of the metal activated enzyme reactions.

(13) Potassium increases growth rate and assimilative work, it is the major cation of the cytoplasm with electrochemical and some catalytic functions. (14) Ascorbic acid stimulates algal growth.

(15) Pyridoxine also stimulates algal growth.

(16) Indol compounds which apparently are not produced by algal growth but in part or entirely by bacterial activity are a "must have." As plant hormones, they stimulate algal growth. Indol-3-acetic acid is a growth-promoting substance for plants. It is normally formed by bacterial metabolism of tryptophan.

The conclusion is that photosynthetic bacteria, photochemical bacteria and other autotrophic and heterotrophic bacteria could be the primary reactors that produce the nutrients and essential elements directly or indirectly in a form responsible for the growth of algae. P cannot be the growth limiting nutrient in all waters.

However, there is the other side of the coin: did algal growths increase in recent years due to an increase in the amounts in wastewater effluents of N, P, C, S, K, Ca, Cl, Mg, Na, Co, Fe, Cu, Mo, Zn, and Si among a few of the essential elements for algal growth? Is the increase due to the discharge of greater volumes of wastewaters from larger wastewater biological treatment plants with the wastewaters being more supersaturated with carbon dioxide and bicarbonates due to increased usage of sodium compounds and other bicarbonate producing chemicals in cleansing products. If the latter is the cause, it might be minimized by post aeration of wastewater effluents. Algae are generally no problem on streams probably because the most essential nutrient " carbon as CO2 is released as the water flows downstream over rocks, falls, etc.

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If phosphates are the growth limiting nutrient, uncoupling" chemical reagents are known and available to break its metabolic functions. Research seems to indicate that copper as copper sulfate and copper chelated compounds are toxic to algae and are excellent inhibitor of algal growth. Copper is a good inhibitor probably because as a heavy metal it can easily replace other metals that are so essential to the metal activated enzyme systems of algae.

Alternatives. Before too many public funds are spent on phosphate removal facilities, the cost of which may prove to be the biggest green herring run on record, studies should be encouraged to investigate use of other algal control methods and whether or not these controls must be used on a yearly basis, which may be wasteful, or just on a seasonal or "when and where needed” basis. There are algicides on the market today that are not toxic to man or to the food chain that can be used in waterways requiring control of algal growths. Depending on the situation, these algicides could be added to plant effluents or sprayed over troubled areas of a waterway at a great saving over the cost of phosphate removal facilities being required of wastewater treatment plants.

In closing let us look beyond the rhetoric horizon. Phosphorus does not appear to be the only nutrient in detergents which may stimulate algal growth in all waters. Sodium, sulfur and perhaps potassium should be more carefully explored. The extensive use of sodium and sulfur in detergents instead of the phosphorus content could have provided the increased supply of soluble nutrient complexes formely produced by seasonal bacterial activity.

Sulfur should not be overlooked, yet it has been overlooked. Sulfur is an essential nutrient element for plants, animals and microorganisms. It could be the nutrient limiting algal growth in soft waters and the nutrient which limits and promotes algal growth in all waters.

Potassium also cannot be overlooked. Like sodium it also has a great solubility potential. Probably of greater importance is the fact that findings of biochemists indicate that sodium and potassium ions along with other cations and anions resemble a storage battery with available free energy for metabolic functions. Before phosphates are crucified, the impact of the increase in wastewaters and waterways of sodium and sulfur and other nutrients besides phosphorus from detergents since 1940 has had on eutrophication should be thoroughly studied and cleared.

FOOTNOTES

1 Williams, J.D.K., Syers, J.K., Harris, R.F. and Armstrong, D.E. Adsorption and Desorption in Inorganic Phosphorus by Lake Sediments in A 0.1 M NaCl System. Environmental Science and Technology, 4:6 (1970).

2 Middlebrooks, E.J. Pearson, A., Tunzi, M., Adinaroyana, A., McGauhey, P.H. and Rohlich G. A. Eutrophication of Surface Water- -Lake Tahoe. Jour. WPCF, 43:2 (1971). Ryther, John H., and Dunstan, William M. Nitrogen, Phosphorus, and Eutrophication in the Coastal Marine Environment, Science, 171 (1971).

Conn, Eric C. and Stumpf, P.K. Outlines of Biochemistry, Second Ed., John Wiley & Sons, Inc.

5 Palmer, C.M. and Tarzwell, Clarence M. Algae of Importance in Water Supplies Public Works Magazine (1955).

Mahler, Henry R. and Cordes, Eugene H. Basic Biological Chemistry. Harper and Row, New Yor. Mahler, Henry R. and Cordes, Eugene H. Biological Chemistry. Harper and Row, New York. Bowen, H.J.M. Trace Elements in Biochemistry. Academic Press, New York.

Biological Data Book. Federation of American Societies for Experimental Biology, Wash., D.C. 10 Feher, George and Fuller, R.C. Research, Chemical Engineering News, (June 1970). 11 Oswald, William J., Meron, Aaron and Zabat, Mario D. Design of Waste Ponds to Meet Water Quality Criteria. Second International Symposium for Waste Treatment Lagoons, Kansas City, Mo. (1970).

Taha, E.E.M. and El Rafai, A.E.H. Physiological and Biochemical Studies on Nitrogen Fixing Blue Green Algae. Arch. Mikrobial, 43 :67-75.

13 Arnon, Ichioka, Wessel, Fujiwara and Wooley. Molybdenum in Relation to Nitrogen Metabolism. Physio. 1. Plantarum, 8: 538-51. 14 Hochester, R.M. and Quastel, J.H. Metabolic Inhibitors. 1 Academic Press, New York.

Hon. WARREN G. MAGNUSON,
Old Senate Office Building,
Washington, D.C.

INTERNATIONAL CHEMICAL WORKERS UNION,

Akron, Ohio, October 13, 1971.

DEAR SENATOR MAGNUSON: In the recent past, many State and local governments have passed widely divergent legislation in an attempt to control pollution through the regulation of the content of detergents. Other government units are in the process of considering this type of legislation. Although this type of legislation has the worthy aim of controlling pollution, the lack of uniformity in acceptable use levels has created a state of chaos.

The confusion is increased by inconsistent reports from the FDA and the Environmental Protection Agency regarding the potential hazards of the use of phosphates, NTA, and other chemical components used in the manufacture of detergents.

This has resulted in severe disruption of employment in the industry, and made it difficult for researchers to develop non-polluting detergents that will meet a patchwork of State and local requirements.

Pollution is clearly an interstate problem that requires a federal solution and uniform standards.

For these reasons, on behalf of the International Chemical Workers Union, I urge your support for Senate Bill 2553, otherwise known as the Detergent Control Act.

Passage of this Act would permit an effective program to regulate detergent pollution under a set of national standards that would eliminate the disaster of needless unemployment in the detergent industries and the segments of the chemical industry that supply materials to it. Research and development could also proceed with the assurance that investment and production would no longer be threatened by well meaning, but often uninformed legislation at the State and local levels.

We support the effort to eliminate pollution, but are convinced that it can only be done through a coordinated program at the federal level with unified goals and planning procedures.

With best wishes and the expectation of your support, I remain

Sincerely yours,

THOMAS E. BOYLE, President.

WESTINGHOUSE ELECTRIC CORP.,

POWER TRANSFORMER DEPARTMENT,
South Boston, Va., October 14, 1971.

Hon. WILLIAM B. SPONG,

U.S. Senate,

Washington, D.C.

DEAR SENATOR SPONG: During your consideration of the toxic substances legislation now before the Subcommittee on Environment of the Committee on Commerce, we would like you to be aware of our interest in the use and regulation of polychlorinated biphenyl fluids, commonly referred to by the acronym PCBs.

Here in South Boston we use PCB fluid as an insulator and coolant in power transformers which will be placed in buildings and in sidewalk vaults where fire could cause serious personal injury and property damage. At the present time, there is only one domestic manufacturer of this fluid, and despite continuing research, we have not yet found a satisfactory substitute for it.

Monsanto Chemical Company, our sole-source supplier, calls its product Aroclor. Westinghouse uses the trade name Inerteen for it. General Electric Company calls it Pyranol. Throughout the transformer and capacitor industries it is generically known as an Askarel fluid. Whatever the name, this PCB family of insulants is characterized by stability. They have a very high flash point and an even higher combustion temperature. These very qualities which make them desirable for our application also makes them very persistent if allowed to escape in the atmosphere.

PCBs have attracted much public attention recently because unacceptable amounts have been found to be prevalent in some food areas, particularly birds and fish. They are suspected of being genetically damaging to these forms of life. For many years they have been used as a component of hydraulic fluids and heat transfer fluids. They have also been used in paints and plasticizers— two applications where potentially toxic substances could be released to the environment. In our industry, their use is confined to electrical equipment where the tanks are sealed and the system is considered to have a "closed" cycle. It is our understanding that Monsanto Chemical Company now confines the sale of its PCBs to closed cycle system users.

As of this writing, an American National Standards Institute Committee headed by a Monsanto Chemical Company representative has been organized to propose United States standards for the control and use of PCBS for electrical apparatus. Westinghouse is represented on this committee.

Westinghouse is working diligently in our own factories and research laboratories to find an alternate fluid for use in power transformers. To date we have been unsucessful in finding a substitute that will meet the necessary insulation requirements and fireproof characteristics. Our capacitor people are trying out a substitute fluid for their application, but we do not have sufficient experience with it yet to establish reliable data on its performance characteristics or its biodegradability.

Inerteen-insulated power transformers constitute about one-fourth of our South Boston production. Our total 1971 requirement of Inerteen at this plant is expected to be approximately 375,000 gallons. While these transformers can in some instances, be replaced by dry-type transformers, there are many appli

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cations where dry-type istallations are impractical. To achieve the same electrical function with equivalent efficiency, a dry-type transformer is generally larger than a transformer using Interteen as an insulation, thus making it more costly. Moreover, many existing buildings and sidewalk vaults would have to be enlarged or modified to accommodate dry-type transformers.

Given the present state of the art, it would be fair to say that an economically and technically acceptable substitute liquid is not yet in prospect. More time is needed. Complete analysis of the technical data we are accumulating, weeding out those fluids lacking promise, would precede negotiation with potential suppliers on the basis of projected requirements to determine availability and cost. Full review of the economics of changing to a new dielectric liquid would further refine our potential substitutes. Exhaustive testing of the chemical characteristics of each possible alternate, its operational stability and compatibility with other materials used in our manufacturing process, would follow. PCB-type materials have been used in the manufacture of power transformers for more than thirty years. There are many millions of gallons in transformers already in use throughout the United States, and this PCB material is as potentially hazardous as the like material in transformers currently being placed in use. Nevertheless, the total amounts used nationally in our type of product application are much less significant, for example, than the amounts of DDTtype materials which present a similar potential environmental hazard. Also, we reiterate that while DDT-type materials have been used largely in "open" applications Inerteen is used by us in a "closed" system which, by its very nature necessitates monitoring by maintenance personnel with a relatively high degree of technical sophistication and competence. It does not seem, therefore, that there would be any significant increase in the potential national environmental hazard if the use of PCB-type materials were restricted to closed cycle systems for a reasonable period of time-ample enough to permit industry to find suitable alternatives.

At our South Boston plant and elsewhere in Westinghouse, we are alert to the hazardous nature of this PCB material, and we exercise high standards of control as we incorporate it in our transformers in a closed circuit system. Careful effort is made to insure against its escapement into the environment through warnings to handling personnel (See Attachment A), special instructions to customers about draining the hermetically sealed system, return of all waste liquid and contaminated materials to the PCB manufacturer for destruction at temperatures in excess of 4000° F., and monitoring of plant effluents (See Attachment B). Nevertheless, we approve legislation such as your Committee is considering, designed to protect environmental quality by prescribing high standards of control in all stages of the use and disposition of PCB material, including limiting its use to sealed or closed systems if deemed necessary; but we are concerned that polychlorinated biphenyls not be peremptorily banned from manufacture and use, since we believe the public can be adequately protected without such action. We would be most appreciative of your assistance in this matter and are prepared to supply you with any further information you might wish.

Sincerely,

Attachments.

JOHN G. ALDWORTH,
General Manager.

71-179 O 72 pt. 3 23

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THIS PRODUCT CONTAINS POLYCHLORINATED BIPHENYLS.
EXTREME CARE SHOULD BE TAKEN TO PREVENT ANY ENTRY
INTO THE ENVIRONMENT THROUGH SPILLS, LEAKAGE, USE,
DISPOSAL, VAPORIZATION OR OTHERWISE, REFER TO
WESTINGHOUSE INSTRUCTION BOOK FOR INFORMATION ON
DISPOSAL PROCEDURES.

BATE

OPORTION 21.032 STANLESS STEEL #7904-19-SATIN FINISH-ETCHED FILLED WITH BAKED RED ENAMEL
AREA 9.37 SQ. IN. RETURN TO SO.BOSTON DISTANCE BETWEEN CENTERS OF HOLES 532=14

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