Notes
on
FFC
Meeting
on
March
20,
2003
Attendees:
John
Quarles,
John
Kolojeski,
Ridgway
Hall
representing
Narragansett
Tracy
Mehan,
Geoff
Grubbs,
Sylvia
Horwitz,
Mary
Smith
representing
EPA
Representatives
for
Narragansett
requested
this
meeting
with
Tracy
Mehan,
Assistant
Administrator
for
the
Office
of
Water,
EPA
to
discuss
issues
related
to
the
pending
decision
concerning
the
toxicity
of
FFC
under
the
Clean
Water
Act.
The
following
points
were
made
by
Narrangansett
Representatives
during
the
course
of
the
meeting:

1.
The
legal
focus
of
the
FFC
toxicity
determination
requested
by
the
Massachusetts
should
be
on
whether
FFC
was
considered
on
of
the
"
cyanides"
in
1976.
A
chronology
(
attached)
dating
back
to
1973
was
handed
to
EPA
officials
at
the
meeting.
Looking
at
this
issue
historically,
it
is
clear
that
FFC
was
not
a
"
cyanide"
in
1976.

2.
If
EPA
found
in
2003
that
FFC
was
toxic
then
it
would
have
the
authority
to
add
FFC
to
the
list
of
toxic
pollutants.
However,
since
Superfund
incorporates
only
the
older
list
of
toxic
pollutants,
FFC
would
not
be
toxic
for
purpose
of
the
pending
Massachusetts
litigation.

3.
The
Massachusetts
court
considered
the
fact
that
the
total
cyanides
methods
includes
FFC
and
said
that
this
was
not
dispositive
of
the
FFC
toxicity
issue.

4.
Regarding
the
current
toxicity
of
FFC
 
FDA
has
approved
the
use
of
FFC
 
Gov.
Thompson
of
HHS
recently
announced
that
the
FDA
is
encouraging
manufacturers
to
submit
new
drug
applications
as
an
antidote
for
radioactive
cesium
and
thalium
poisoning.
 
There
is
a
real
question
about
how
easily
FFC
disassociates
in
the
environment.

5.
A
determination
that
FFC
is
a
toxic
substance
under
the
CWA
would
have
significant
impacts.
A
written
summary
of
these
impacts,
taken
from
the
Administrative
Record,
was
handed
out
at
the
meeting
(
attached).

EPA
listened
to
these
statement
and
asked
several
clarifying
questions.
Tracy
Mehan
indicated
that
EPA
was
having
a
peer
review
panel
look
at
the
science
surrounding
FFC
and
will
be
involving
EPA's
Office
of
Research
and
Development
in
this
analysis.
Narrangansett
representatives
asked
for
the
charge
to
the
peer
review
panel,
and
for
any
documents
that
were
provided
to
the
peer
reviewers.
EPA
promised
to
provide
those
to
Narrangansett
representatives
after
the
meeting.
