Abstract

Disposal of carbonless copy paper (CCP) paper sludge during the 1960s contaminated a site in the USA with PCBs. Despite historic records of CCP sludge disposal and absence of evidence of any other disposal, a dispute arose among the parties over the source of the PCBs. Aroclor 1242 is well documented as the PCB mixture used in CCP, yet Aroclors 1242, 1248, 1254, and 1260 were reported by the analytical laboratory. How could the PCBs at a single, small site be reported as four different Aroclors? Some claimed that there had to be at least four Aroclors source inputs to the site. Disposal of four different Aroclors at this site would simply defy logic and the historic record. Weathering of the mixtures is part of the story. A larger issue is the conflict between the intent of the USEPA 8082 method to determine the total PCB content in environmental samples to facilitate environmental cleanup and disposal decisions within a regulatory context versus the data users' intent to identify the PCB sources. This inappropriate extension of the data leads to erroneous conclusions. To mitigate problems like this, laboratory analysis requests need to be matched to the intended data usage; conversely, the data must not be over-interpreted beyond the limits of the method. The PCB analysis community needs to develop a better articulation of the limits of Aroclor identification for the broader community that may naïvely assume that if the laboratory reports "Aroclor 1248," then someone must have placed Aroclor 1248 at the site. After all, when a laboratory reports "lead" or "chloroform," those identifications are never in question.

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