Document 06VBkk7yq9VowmREjEL2r6Gk

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA NEVADA POWER COMPANY, ) ) ) Plaintiff, ) -vs- ) ) CV-89-555-LDG (LRL) ) MONSANTO COMPANY, GENERAL ) ELECTRIC CORPORATION, et al., ) ) Defendants. ) DEPOSITION OF WILLIAM B. PAPAGEORGE On the part of the Plaintiff July 19, 1993 QJ Concannon & Jaeger General Court Reporters 705 Olive Street, Suite 604 St. Louis, Missouri 63101 (314) 421-1000 WATER PCB-SD0000072290 1 IN THE OKITED STATES DISTRICT COURT FOR THE DISTRICTOF NEVADA 2 3 NEVADA POWER COMPANY, etc,, ) ) 4 Plaintiff, ) -VS- ) # CV-S-89-555-LDG (ERL) 5) MONSANTOCOMPANY, etc*, t al., ) 6) Defendants ) 7 INDEX 8 WILLIAM B. PAPAGEORGB 9 Direct Examination by Mr* Bradley 4 10 11 EXHIBITS 12 Deposition Exhibit f415 ................... ......... 58 13 Deposition Exhibit # 1217 ....... ........................... 65 14 Deposition Exhibit # 1507 66 35 Deposition Exhibit f1237 .................................................... 68 16 Deposition Exhibit f419 ............................ ....... 69 17 Deposition Exhibit I 416 70 18 Deposition Exhibit I 1494 ....... ........................... 71 19 Deposition Exhibit # 1193 ......... .................. 71 20 Deposition Exhibit I 420 72 21 Deposition Exhibit 9 709 ** 74 22 Deposition Exhibit I 709A ............................................ .... . . 74 23 Deposition Exhibit # 709B .............. 75 24 Deposition Exhibit I 1195........................................ . . . . 77 25 Deposition Exhibit 1403 **. 78 WATER PCB-SD0000072291 1 Deposition Exhibit t 89 .............................................................. 79 2 Deposition Exhibit # 352 **.. ................... @0 3 Deposition Exhibit # 435 ...... .................. ... @0 4 Deposition Exhibit $ 1446 82 5 Deposition Exhibit # 1536 ........ ....................... 88 6 Deposition Exhibit # 424 89 7 Deposition Exhibit t 3008 .................. ......... 91 8 Deposition Exhibit 9 1575 .***. 92 0 Deposition Exhibit # 421 93 10 Deposition Exhibit t 428 ............................... 95 11 Deposition Exhibit t 1196 ... ............................ 96 12 Deposition Exhibit t 439 .............. 97 13 Deposition Exhibit t 1496 .............. 98 14 Deposition Exhibit $ 439 97 15 Deposition Exhibit # 1496 .............. 98 16 Deposition Exhibit 4 1257 99 17 Deposition Exhibit f 442 ........ ....................... 100 18 Deposition Exhibit # 441 100 19 Deposition Exhibit 293 100 20 Deposition Exhibit t 292 100 21 Deposition Exhibit # 438 . 103 22 Deposition Exhibit t 361 * 103 23 Deposition Exhibit t 1729 165 24 Deposition Exhibit # 395 .............. 106 25 Deposition Exhibit I 1210 ............................................................. 107 WATER PCB-SD0000072292 X Deposition Exhibit t 1177 . . .......................... 108 2 Deposition Exhibit # 625 ....................... no 3 Deposition Exhibit 516 ................................................ . . 110 4 Deposition Exhibit # 1103 . * * . ........ ill S Deposition Exhibit 1556 .............. 113 6 Deposition Sxhibit # 1120 ....................... 114 7 Deposition Sxhibit f 310 . . ....................................................115 e Deposition Exhibit # 1335 . ........................... ...... 116 9 Deposition Exhibit 9 415 , .............................. 117 10 Deposition Sxhibit f 1566 118 n Deposition Exhibit # 1542 ...................... 119 12 Deposition Exhibit I 1542A............................................ . . . 120 13 Deposition Exhibit # 1593 ............................... ......................... 120 14 Deposition Exhibit f 872 *.. 121 IS Deposition Exhibit I 1505 ...................... .... . . . . 123 16 Deposition Exhibit # 1166 . ...................... ....... 124 17 Deposition Exhibit I150.................................... 125 18 Deposition Exhibit 524 .............. 125 19 Deposition Exhibit 9 522 **>. 127 20 21 22 < 23 24 25 WATER PCB-SD0000072293 1 m THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA a 3 NEVADA POWER COMPANY, etc., ) ) 4 Plaintiffs,) s -V- ) f CV~S~89-555-LDG (LRL) ) 6 MONSANTO COMPANY, etc., et al, ) ) 7 Defendants.) 8 DISCOVERY DEPOSITION OF WITNESS, to be used in an t action pending in the District Court of the United States, 10 tor the District of Nevada, entitled NEVADA power company, li etc*, is Plaintiff, and MONSANTO COMPANY, etc., et al. are 12 Defendants, pursuant to Notice, under the provisions of 13 Rule 26 of the Rules of Civil Procedure# taken on July 19, 14 1993, at the law offices of Messrs* Busch a Eppenberger, IS 160 North Broadway, St, Louis* Missouri, before John T, 16 Concannon, a Notary Public within and for the State of 17 Missouri. 18 APPEARANCES 19 The Plaintiff was represented by Mr. Ralph A. Bradley, of the law fir of Bradley 6 Merrell, c/e donee, 26 Jones, Close & Brown, Chartered, 766 Bank of America Plaza, Las Vegas, Nevada, 89101. 21 The Defendant, Monsanto Company, was represented by 22 Mr, Scott Bauer, of the law firm of Kirkland a Ellis, 1999 Broadway, Denver* Colorado* 80262, 23 The Defendant, Meetinghouse, was represented by Mr. 24 Robert P. Morgan, Counsel, Meetinghouse Electric Corporation, Gateway Center, Pittsburgh, Pennsylvania 25 15222. WATER PCB-SD0000072294 COMPUTES AIDED TRANSCRIPTION 1 WILLIAM B. PAPAGEORGE 2 a witness of lawful age, being first duly sworn to tell the 3 truth, the whole truth, and nothing but the truth, deposes 4 and says, on behalf of the Plaintiff, as follows) 5 DIRECT EXAMINATION 6 QUESTIONS BY MR. BRADLEY) 7 Q. Mr. Papageorge, ay name is Ralph Bradley. You e and I have sat through some depositions involving you where 9 you were a 30(b)(6) designee for Monsanto on different 10 topics in the case of Nevada Power Company versus Monsanto, 11 Westinghouse and General Electric) that's correct, is it 12 not? 13 A. It ia. 14 Q. This is the time set for your personal 15 deposition. Are you here, today, represented by an 16 attorney? 17 A. Yes. 18 Q. Have you had a chance to discusswith your 19 attorney the purposes of a deposition? 20 A. Yes. 21 Q. If at any tine youdon't understandone of my 22 questions, will you tell me? 23 A. I will. 24 Q. And when you give an answer to one of my 25 questions, I'm going to assume you understood the question. 4 * C0NCANNON & JAEGER WATER PCB-SD0000072295 COMPUTER AIDED TRANSCRIPTION 2 Pair enough? 2 A* Keep in Bind? 1 may have a misunderstanding 3 and my answer may be based on that misunderstanding. 4 Q. Well# if you think you may have a 5 misunderstanding# will you tell me? 6 A. Oh# certainly. 7 Q. All right. And if, at any time# you want to 8 take a break# you Just let me know# all right? 9 A. I will. 10 Q. Do you recall having your deposition taken 11 February 23rd and 24th of 1993 in this lawsuit? 12 A. 1 do* 13 Q. And at that point in time# you were a 30(b)(6) 14 deponent on the topics referred to in the deposition? 15 A. That was myunderstanding. 16 Q. All right. If 1 asked you the questions today 17 that I asked you on February 23rd and 24th of 1993# would IS your answers be the same? 19 MR. BAUERi Object to the form. It's 20 overbroad. There's hundreds of pages of the transcript. 21 Without presenting Mr. Papageorge with an opportunity to 22 look at them all and see which ones were based on his 23 personal knowledge and which were not# I don't see any way 24 he can answer that question. 25 Q. (By Mr. Bradley) Well, Hr, Papageorge# do you 5- CONCANNOH 6 JAEGER WATER PCB-SD0000072296 COMPUTER AIDED TRANSCRIPTION 1 think that any of the answers you gave February 23rd and 2 24 f 1993 were wrong? 3 HR* BAUERt Objection. 4 A, No, air. They were as truthful as I knew how 5 to make them* 6 Q, (By Mr. Bradley) All right. If I asked you 7 the same questions today, would your answers be the same as 8 you gave February 23rd and 24th of 1993? 9 MR. BAUER: Object to the form. Are you 10 asking him in his personal capacity or a corporate 11 representative who has been educated on certain topics? 12 MR. BRADLEYt We*re her today on his personal 13 deposition. 14 MR. BAUERs All right. Can you answer the 15 question* Mr. Fapageorge? 16 A. My answers today will be based on my personal 17 involvement and understanding and experience* as I 18 understand it. That* the way my answer will be put 19 together. 20 0. (By Mr* Bradley) 1 understand that. And if 21 -- My question* though, is if I asked you the same 22 questions today that I asked you back in February* would 23 your answers be the same? 24 MR. BAUERi Object to the form* overbroad* 25 without giving him an opportunity to look at the questions -6CONCANMON & JAEGER WATER PCB-SD0000072297 COMPUTER AIDED TRANSCRIPTION 1 and answers to know whether there is something other than 2 his personal knowledge in the answer. 3 A* I can anticipate or expect a question 4 requiring an answer which X had no personal experience, 5 other than what was given to me by attorneys. My answer 6 would not be the direct answer you night expect. It will 7 be couched in *l was told by Mr. so-and-so just last month a that this is the answer** I personally have no experience 9 with that particular activity. My answer would differ in 10 that regard. 11 Q. (By Hr. Bradley) Do you recall when you had 12 your deposition taken in February of this year? 13 A. Tee. 14 0. when you indicated -- When you gave your 15 answers, which answers were based upon information people 14 told you as opposed to information based on your personal 17 knowledge? IS A. Sir, that particular deposition, I was 19 personally confused in attempting to categorise the 20 questions, as to whether they fell into the 30(b)(6) type 21 or were based on my personal experience. So I just gave 22 the best answer, as truthful as x could make it. X did not 23 try to determine the legalities of the question, if you 24 will. 25 q. r appreciate that. My question is more -7- CONCANNON & JAEGER WATER PCB-SD0000072298 COMPUTER AIDED TRANSCRIPTION 1 narrow. My question is, when you gave your answers in 2 February# Sid you indicate when your answers were based 3 upon information given to you fey others if# in fact# your 4 answers were based upon information given to you by others? 5 A. I did not describe them as such# no. 6 0* Okay, bid you review any documents in ? preparation for today's deposition? 8 A. Tes. 9 0. what documents did you review? 10 A. I was shown the notice that - 11 THE WITNESS* This is now for my personal 12 deposition? 13 MR. BRADLEY* Y#S. 14 A. I saw a collection of documents. 1 did not 15 read each and every word in them. Perused them. 1 Q. (By Mr. Bradley) What documents did you 17 peruse? 18 A. Oh# there was a six or eight inch stack of 19 paper. I don't recall all of the -- 20 0. I want you to describe for me the ones that 21 you do recall. 22 MR. BADERs Are you specifying --* Well# I 23 think we clearly specified some documents that were for the 24 30(b)(6) that we think we're going to get to tomorrow. You 25 want to exclude them for the present purposes? 8 CONCAHNON fc JAEGER WATER PCB-SD0000072299 COMPUTER AIDED TRANSCRIPTION 1 HR. BRADLEYt Yes. Be indicated -- I think a his understanding was that ray question was limited to just 3 the documents you reviewed for your personal deposition. 4 A* Personal? I'm confused right now. 5 MR. BAUERt Be may not have known in all 6 cases. 7 A* The document that I was able to review $ briefly in some cases did apply to my personal involvement and experience. In others, they occurred prior to my l assignment within Monsanto as it related to PCBs, or 11 occurred after I was relieved of that assignment# and some 12 refer to situations in which I was personally not involved* 13 0. {By Mr, Bradley) Tell me which documents you 14 remember reviewing that included your personal involvement 15 and experience. 16 A. 2 recall a document that referred to meetings 17 that were held with representatives of Federal departments 18 and agencies, and I was one of the participants in those 1 meeting. I recall some copies of letters that I sent to 2 representatives of customers with my signature on them; I 21 recall a copy of the text that 1 used in making a 22 presentation before Monsanto's corporate management 23 committee in April of If7. That's all that comes to mind 24 at the moment. 25 0. All right. -9CONCANNON & JAEGER WATER PCB-SD0000072300 COMPUTER AIDED TRANSCRIPTION 1 A. There were# of course* others. a 0* In on effort the its ice your personal deposition 3 as brief as I* able* I take it If 1 asked you the same 4 questions today that I asked you back in February of 1993 5 regarding your educational background, your answers would $ be the same7 7 A, Yes. a Q. And X take it if I asked you the same 9 questionsregarding the work that you did at Monsanto and 10 the titles that you had while at Monsanto* your answers 11 would be the same? 12 A, Yes. 13 Q. If X asked you questions today that X asked 14 you in February of 1993 regarding the meetings you 15 personally attended, would your answers be the same? 16 MR. BAUERs Object to the form* overbroad 17 without providing the witness with an opportunity of seeing 18 hundreds of pages of deposition transcript. 19 THE witness* Would these be meetings of a 20 specific type or just all meetings? 21 MR. BRADLEY* Any question X asked you about 22 any meetings you personally participated in. 23 MR. BADERt Same objection. 24 A. X would certainly attempt to recall the 25 meetings being questioned. X may forget a few and may even - 10 CONCANNON t JAEGER WATER PCB-SD0000072301 COMPUTER AIDED TRANSCRIPTION 1 remember some this time around that 11d forgotten the 2 previous time but the intent would be the same. 3 0* (By Mr. Bradley) bet roe ask it this way. if 4 I asked you questions about meetings you attended, would S your answers * your answers would be based upon personal 6 knowledge, would they not? 7 MR. BADERt Object to the form. a A Certainly. Meetings I personally attended, 9 yes. 10 Q. (By Mr. Bradley) And if I asked you <-- To 11 the extent I asked you questions back in February, 1993 12 about meetings that you personally attended, would your 13 answers then have been based upon your personal knowledge? 14 A. Yes. 15 MR. BADERi Object to the form. 16 MR, BRADLEYt Let's go off the record for a 17 moment 18 (Whereupon, a colloquy was held between Counsel, off the 19 record.) 20 Q. (By Mr. Bradley) Did you receive any tutorial 21 sessions on toxicology or epidemiology from a gentleman 22 named William Bunt? 23 A. Mo. 24 Q. Pardon me? 25 A. NO. - 11 CONCANNON & JAEGER WATER PCB-SD0000072302 COMPUTER AIDED TRANSCRIPTION 1 0* Do you recoil a William Bunt? 2 A Yes. 3 0* Did you have any discussions with Mr. Hunt 4 where results of studies on toxicology or epidemiology S would be described and the significance of any results 6 would be discussed? 7 A. Yes. 8 Q. Okay. What was his position at Monsanto when 9 you had those discussions? 10 A. Be was a stafftoxicologistwith Monsanto's 11 Corporate Medical Department. 12 Q. Do you recall what you discussed with Mr. 13 Bunt? 14 MR. BADERt Object to the form, overbroad. 15 MR. BRADLEYI Relative 16 MR. BAUERi Compound 17 Q. (By Hr. Bradley) Do yourecall what you 18 discussed with Mr. Runt relative to PCBs? 19 MR. BADERt Same objections. 20 A. Be shared with me his latest information 21 regarding the status of studies involving PCBs that were 22 ongoing at the time. 23 0* (By Mr. Bradley) Did you have any 24 responsibility within Monsanto relative to the toxicology 25 of PCBs? - 12 CONCANHON & JAEGER WATER PCB-SD0000072303 COMPUTER AIDED TRANSCRIPTION 1 A. The responsibility relative to toxicology that 2 I was aware of, assigned to me, was one of communicating 3 with anyone - whether it be a customer, researcher, 4 government employee, private citizen <* the information 5 relating to results of studies that were couched in terms 6 that hopefully a layman would understand. 7 Q. When did you have that job responsibility at 8 Monsanto? 8 A. It started in January, 1970. 10 Q. Prior to that date, you had had no course work 11 in toxicology) is that correct? 12 A. That is correct. 13 0. Prior to January of 1970, you had no course 14 work in epidemiology; is that correct? 15 A. That is correct. 16 Q. Prior to January of 1990, you had had no 17 specific instruction from any other Monsanto employee 18 regarding toxicology; is that correct? 19 A. As long as we both understand the use of the 20 word "toxicology" here. X did have some information 21 regarding the possible effect of PCBs when carelessly used 22 by employees. 23 Q. when did you come by the information regarding 24 the possible effects of PCBs when carelessly used by 25 employees? - 13 CONCANKON 6 JAEGER WATER PCB-SD0000072304 COMPUTER AIDED TRANSCRIPTION 1 A. It started about 19 - the middle of the 1950s. 2 0. And when you began learning about those 3 possible effects* did you have a degree in toxicology? 4 A. NO. S Q. Did you have adegree in epidemiology? 6 A. No. 7 0. Did you have a medical degree? 6 A. No* 9 Q. Did you receive any training fro any 10 toxicologist regarding the possible effects of PCBs when 11 carelessly used by employees? 12 A, By a toxicologist* no* 13 Q. Did you receive any training from any medical 14 doctor regarding the possible effects of PCBs when 15 carelessly used by employees? 16 A. Yes* 17 Q. Whichdoctor gave you thattraining? 10 A. The plant doctor at the dohn F, Cueeny Plant 19 in St. Louis* Dr* Berthe* B-e-r-s-h-e, I believe is the way 20 he spelled it. 21 0. How did Dr. Bershe relate information to you 22 regarding the possible effects of PCBs when carelessly used 23 by employees? 24 A. It was aface-to-face discussion originated by 25 me after 1 had read some information that had been provided - 14 - CONCANNON 6 JAEGER WATER PCB-SD0000072305 COMPUTER AIDED TRANSCRIPTION 1 to the piantr and this had to do with many chemicals* PCBs 2 being one of them. 3 Q* Bow long did you have the this face-to-face 4 discussion with Dr. Bershe relating to PCBs? 5 A. Oh# must have been a half-an-hour at the most. 6 Q. Mow# was it a half-an-hour for all of the 7 products or half-an-hour for the PCBs? a A. About half-an-hour for the PCBs, 9 0. Other than your discussion with Dr. Berube# 10 did you receive any training whatsoever from anyone 11 regarding the possible effects of PCBs when carelessly used 12 by employees? 13 A. Yea. 14 0. Pro whom did you receive that training or 15 information? 16 A. Dr. Emmet Kelly# who was the Corporate Medical 17 Director. IS Q. Anyone else? 19 A* Mr. JackGarrett# who was the staffindustrial 20 hygienist reporting to - In Dr, Kelly's department. Those 21 are the individuals that I recall. 22 Q. When did youreceive training from Dr. Kelly 23 on the topic of possible effects of PCBs when carelessly 24 used by employees? 25 A* During the period 1965 to the end of 1969. - 15 - CONCANNON & JAEGER WATER PCB-SD0000072306 COMPUTER AIDED TRANSCRIPTION 1 Q. When did you receive that training from Jack 2 Garrett? 3 A. The same period. 4 Q. What type of training did you receive from Dr. S Kelly between 1965 and 1969 regarding the effects of PCBs 6 when used carelessly by workers? 7 THE WITNESSi I don't know what you Bean by a "type.* you mean how was it conducted? 9 HR. BRADLEY* Yes. 10 A. Dr. Kelly, as Corporate Medical Director, made 11 it a point to visit Monsanto's operating units at least 12 once a year. Be would come by the Anniston plant, where 1 13 was plant manager, review our medical practice with the 14 plant physician, stop by my office and review with me his 15 findings, his recommendations, and during those 16 discussions, we would touch on the products manufactured at 17 that plant and PCBs was, of course, among those products. 18 Q. So between 1965 and 1969, you were the plant 19 manager at Anniston? 20 A. Yes. 21 Q. And at least - Or excuse me. Once per year 22 during the time period 1965 to 1969, Dr. Kelly would come 23 to your plant and he would review findings and 24 recommendations relative, in part, to PCBs with you? 25 A. Yes. - 16 - CONCANNOH & JAEGER WATER PCB-SD0000072307 COMPUTER AIDED TRANSCRIPTION 1 Q, And when he met with you once per year# 2 roughly how much time would he spend with you on that one 3 visit per year relating to the possible effects of pcbe 4 when carelessly used by employees? 5 A, Again, about half-an-bour on a specific 6 subject. 7 Q. And how would Jack Garrett give you e information regarding the possible effects of PCBs if 9 carelessly used by employees between 1965 and 1969? 10 A. Very similar to the way Dr, Kelly did. Mr. 11 Garrett would come by the plant, conduct his audit, l'& 12 going to call it, his review, and share with me, again, his 13 findings, his recommendations. 14 Q. is it Mr. Garret or Dr. Garret? 15 A. Mr. 16 Q, Would Mr. Garret come by your plant more than 17 once per year, between 1965 and 1969? 18 A, Occasionally, he was able to come by more than 19 once, yes. 20 0. Do you recall, between 1965-- Well,let me 21 ask it this way. Between 1965 and 1969, did you meet with 22 Mr. Garrett more than once per year where you discussed the 23 possible effects of PCBs when carelessly used by employees? 24 A. Tea. 25 Q. And tell me how many times you metwith Mr, 17 * CONCANNON * JAEGER WATER PCB-SD0000072308 COMPUTER AIDED TRANSCRIPTION 1 Garrett during that# the '65 to *69 period where that topic 2 was raised. 3 A. X never (sept score# air. X know it was at 4 least once a year and some years# he was able to come by at 5 least a second tie. Q. So once or twice on year? 7 A. Yes. a 0. And when he visited your plant once or twice a 9 year# how much time would he spend with you where he 10 provided information regarding the possible effects of PCBe 11 if carelessly used by employees? 12 A. Oh# X thought I said half-an-hour. 13 Q. So really, the same time as Dr.Kelly? 14 A. Yea. 15 0. In the 1950s# did you have any responsibility 16 for disseminating information regarding the possible health 17 effects of PCBs if carelessly used by employees? 18 A. Yes* 19 0. Whatwere yourjob responsibilities in that 20 regard? 21 A. At the time# X was a member of the plant 22 maintenance department. In that department, there are 23 individuals who are involved with PCBs# either as 24 electricians, with electrical equipment# or pump mechanics 25 when they're working with pumps; pipefitters with pipe - 18 - CONCANNOR t JAEGER WATER PCB-SD0000072309 COMPUTER AIDED TRANSCRIPTION 1 lines and so on. Part of my responsibility was to make 2 certain that the employee understood the chemicals they 3 were working with and how to handle them and what the 4 effects might he if they were mishandled, and PCB was one 5 of many that were discussed and reviewed at least - well, 6 every month we would have sessions and once a year we would 7 talk about a specific product* like PCS, 8 Q. Over what period of time did you have that 9 type of lob responsibility? 10 A. As best a 1 recall, it was 1953 or n thereabouts through about 1938. Those aren't exact but 12 it's roughly the period of time. 13 0. What Job responsibility -- Excuse me. what 14 was your job title between 1935 and 1958? 15 A. Well, 1 started out as a maintenance 16 supervisor for about a year and then I was appointed 17 maintenance superintendent for the remaining period. 18 Q. In 1958, did you become plant manager? 19 A. No. 20 Q. What job did you have in 1958? 21 A. About 1958 * 1 may have missed that year a 22 little - 2 was appointed a superintendent in the plant 23 engineering department. 24 0. What work did you do as a superintendent in 25 the plant engineering department? ** 19 ** C0MCAHN0N & JAEGER WATER PCB-SD0000072310 COMPUTER AIDED TRANSCRIPTION 1 A. Oh# 1 supervised the Activities of engineer j 2 and technician that were assigned to address some of the 3 operating unit at the plant# in term of making the 4 operations more efficient# safer# Digger, Whatever it took S in an engineering sense to accomplish the need that was 6 perceived, 7 MR, BRADLEY1 it's now a little after 10i30. 8 I*0 going to take about a minute break. (Whereupon# a five minute recess was taken,) ID Q. (ByMr. Bradley) Did youever have a 11 discussion with Dr. Kelly regarding toxicology related to 12 PCBs? 13 A, Ye. 14 0, Didthat start in the early1976s? IS A. Mo. It started earlier than that. Back in 16 the late '60s. 17 Q. Did those discussions with Dr. Kelly ever 18 cease? 19 A. MO. 26 0, What was the subject matter of the discussions 21 you had with Dr. Kelly regarding toxicology of PCBs? 22 A. It varied with time. The initial discussion 23 had to do with the testing that was conducted in the *30s# 24 '40s and *50s to establish the safe levels in the working 25 environment. The discussion that 1 had with Dr. Kelly - 20 - CONCANRON & JAEGER WATER PCB-SD0000072311 COMPUTER AIDED TRANSCRIPTION 1 beginning in 170 and on had to do with the more recent 2 tooting that was being conducted at the time that included 3 exposure to animals for long periods cf time. I think that 4 about covers it. 5 0. You're retired from Monsanto? 6 A. I am. 7 0. when did you retire? e A. My last working day was December 31st, 1986. 9 Q, Up until the time of your retirement, had you 10 received - excuse me - had you attended any formal course 11 work in toxicology? 12 A* Mo. 13 Q. Op to the time of your retirement, had you 14 attended any formal course work in epidemiology? 15 A. No. 16 Q. Up until the time of your retirement in 1986, 17 did you receive any training of the sort you'd received -- 18 Let me rephrase the question. Did you receive any medical 19 training on the subject of PCBs, formal medical training on 20 the subject of PCBs prior to your retirement? 21 A, MO. 22 0. During the course of your employment at 23 Monsanto, Monsanto did have employees with medical degrees 24 working for it; is that true? 25 A. Yes. - 21 - CPNCANNON & JAEGER WATER PCB-SD0000072312 COMPUTER AIDED TRANSCRIPTION 1 Q. Between 1965 and 1975, hew many medical 2 Excuse me. Row many people were employees at Monsanto who 3 were medical doctors? 4 MR. BADER Object to the form. Lack of 5 foundation, indefinite as to whether we're talking about 6 United States or worldwide# but you can answer if you're 7 able. S A. I just don't know the total number. 9 Q. (By Mr. Bradley) Let's limit this now to 10 members of Monsanto's Medical Department. Between 1965 and 11 1975# did Monsanto have a medical department? 12 A. Ye. 13 Q. How many employees did it have during the 1965 14 to 1975 period? 13 MR. BADERt Object to the form. Lacks 16 foundation. 17 A. There again# I don't have numbers because it IS included the physicians# it included the nursing staff, it IS included the medical librarian# the secretarial help. I 26 just don't have the number. 21 Q. (By Mr. Bradley) Do you have the number for 22 the number of medical doctors that were employed by 23 Monsanto within its Medical Department in the United States 24 between 1965 and 1975? 25 TBS WITNESS* This is the corporate medical - 22 - CONCANNON & JAEGER WATER PCB-SD0000072313 COMPUTER AIDED TRANSCRIPTION 1 department? 2 MR. BAUERi I think -- That was my confusion, 3 because there are individual plant doctors too, whether 4 you * re talking about Just the corporate function as opposed 5 to the individual plant doctors. 6 MR* BRADLEYi Yes, x am talking about the 7 Corporate Medical Department. S A. 1965. Certainly. Dr. Kelly and as best i 6 mr recall, he had two medical doctors - doctors with medical 10 degrees - in the St. Louis office. 11 Q, (By Mr. Bradley) And during that same ten 12 year period between 1965-- 13 A. Excuse me. 14 Q. I* sorry. 15 A. 1 misled you. That was 1965. When you said 16 ten years, X haven't covered '75 yet. By 1975, as best I 17 remember, the medically degreed personnel in that 18 department was close to half a dozen. If Q. Between 1965 and 1975, did Monsanto employ 20 toxicologists? 21 A. Yes. 22 0. Roughly how many did they have between 1965 23 and 1975 as part of their corporate department? 24 A. By 1975, I believe, as best I recall, the 25 number had reached four. That's approximate. - 23 - C0NCANNON JAEGER WATER PCB-SD0000072314 COMPUTER AIDED TRANSCRIPTION 1 Q, And whet was the number in 1S65 approximately? 2 A. *65# professionally trained toxicologists? I 3 don't recall an individual with that type of degree. 4 Q. When did Monsanto* as heat you recall* first 5 employ a professionally trained toxicologist as part of its corporate department? 7 A, 1 believe Dr, Runt was the first* and a best B I recall* it was the late *60, 0, Did Monsanto conduct unpublished studies 10 between 1935 and 1965 regarding the environmental or human 11 health effects of PCBs? 12 MR. BADER * Objection, Lacks foundation. 13 THE WITNESS* Can you help me with the word 14 conduct*? 15 MR. BRADLEY* Either performing in-house or 16 contracted for outside of Monsanto. 17 MR. BAUER* Same objection, 18 A, The answer is ye, IS 0, (By Mr. Bradley) Okay. And how did you 20 become aware of those unpublished studies? 21 A. well* 1 mentioned earlier* Dr. Kelly would 22 review with me toxicology result that he had* That* when 23 i first became aware of the type of studies that were 24 placed with outside laboratories* and later in much more 25 detail* when I had my tutorial with Mr. wheeler in January* - 24 CONCANNOM 6 JAEGER WATER PCB-SD0000072315 COMPOTES AIDED TRANSCRIPTION 1 1970. He covered the types of studies# the years they were 2 conducted, the type of PCS that was tested, the type of 3 animal that was used and so on. Much more detail. 4 Q. What were you told about those unpublished S studies regarding PCEa? I'e interested in knowing when 6 they occurred, what animals were involved, as best you 7 recall, what it was that was being measured. 3 (Whereupon, a two minute recess was taken.) f Q. {By Mr. Bradley) I*m interested in knowing 10 when the studies occurred, what animals were involved in 11 the study, what effects were being examined, when the 12 studies occurred, who the authors were. Basically 13 everything you can remember about the studies, including 14 their number. 15 A. Oh, I certainly don't remember everything. 16 We*re talking now about unpublished reports. I'm having 17 difficulty in remembering the name of the laboratory. 18 There was a St. Louis based laboratory that was involved. If 1 remember the principle investigator - Oh. Dr. Younger, 20 Younger Laboratories, was one of them and he was a member 21 of another laboratory which went under another name. They 22 conducted the then accepted testing for industrial 23 chemicals. By then," X*m talking about that period of 24 time, the state of the science at the time. These were 25 short-term tests at quite high levels of exposure in which - 25 - ' CONCANNOfi 6 JAEGER WATER PCB-SD0000072316 COMPUTER AIDED TRANSCRIPTION 1 the animals were either fed or they breathed fumes of 2 chemicals; some of the feeding was out of their normal 3 feeding pans, if you will, and some of it was by 4 force-feeding, the Gavogue approach, where the material is 5 injected into their stomachs. Some of the testing involved 6 akin testing - shaving the bellies of rabbits and exposing ? that shaved area to the chemical. The most common animal a tested was the white rat, and the details escape me at the 9 moment as to exactly when these tests were done. 1 do know 10 there were an initial series in the *3Q8/'40s period and 11 they were redone in the *5Gs as a sort of a double check to 12 see if the results were similar, and they were. From those 13 studies, the staff at Monsanto's Medical Department was 14 able to arrive at the precautionary information that was 15 issued with the products, in terms of breathing excess 16 fumes and getting it on the skin and ingesting, and the 17 harmful effects that were noted would range irritated skin 18 to the condition referred to as chloracne and, of course, 19 with increasingly high doses, the effect of the liver, and 20 if the bad practice continued and the exposure was quite 21 great, the damage to the liver would be such that it would 22 not recover and therefore, result in potential death. 23 That's the type of information that was extracted from 24 these studies. 25 Q. Did you ever have responsibility at Monsanto - 26 - COMCANNON & JAEGER WATER PCB-SD0000072317 COMPUTER AIDED TRANSCRIPTION 1 for the wording that was used as part of any labels that 2 were affixed to PCB dielectric fluid manufactured by 3 Monsanto? 4 A. X did# yea* 5 Q. When did you have responsibility for the 6 wording of the labels? 7 A. Responsibility was assigned to me when 1 was e appointed Manager* Environmental Control in January* 1070. 9 I think it's appropriate to indicate that that 10 responsibility was not a sole responsibility. It was a 11 shared responsibility. 12 0* With whom did you share the responsibility? 13 A. With the -- Primarily* with the Medical 14 Department. 15 0. Were they responsible for making certain the 16 labels had the appropriate medical information on the 17 labels? 18 A. They always were and continued* yes. 19 Q, And what responsibility did you have* then* 20 regarding the labels in January of 1970? 21 A. It centered primarily on the reference to the 22 finding of those materials in the environment* the possible 23 effect on the environment; the need to keep the material 24 from escaping into the environment and the proper methods 25 for manufacturing it* shipping it* using it* disposing of - 27 CONCANN0N & JAEGER WATER PCB-SD0000072318 COMPUTER AIDED TRAHSCRIPTIOM , 1 it. 2 Q, in the pet led between 1965 and 1976* did 3 Monsanto have industrial Biotest laboratories do some work 4 on Monsanto's PCS products? 5 A, Yes, Q, Part of those studies were chronic studies; is 1 that correct? e A, Yes, 9 0, During those chronic studies, Elmer Wheeler 10 monitored the development of the studies? n A * Yes. 12 Q. Did Mr. Wheeler visit the 1ST Laboratories 13 between 1965 and 1976? 14 A. Yes, 15 Q. Did he visit those laboratories as part of his 16 monitoring of the chronic studies that IBT was performing 17 on Monsanto's PCB products? 18 A, Yes, 19 0, Did Mr. Wheeler tell you about his personal 20 visits to the IBT Laboratory regarding the chronic studies? 21 A. Yes* 22 Q. What did he tellyou about those personal 23 visits to IBT regarding the studies? 24 A* Primarily, a status report onhow far along 25 the studies were, what the findings to date were; some - 28 - CONCANNON 6 JAEGER WATER PCB-SD0000072319 COMPUTER AIDED TRAN8CRIPTI0H 1 prediction of whet the end result might be, as to what 2 effects one might expect* That type of discussion he would 3 have with me. 4 0* Did Mr. Wheeler indicate to you whether he 5 visited the area in which rats were housed which were used 6 as part of Monsanto* PCS chronic studies? 7 A* Oh, yes. Q* And what did he tell you? Did he tell you he 9 visited those areas? 10 A. Yes. Be visited the facilities, saw the n activities. Bathing unusual about his report. 12 0. Did fee indicate to you, either by report or by 13 any other means, anything unusual about the 1ST facility 14 where the rat were housed? 15 A. Mo. 16 Q. Did he ever discuss with you any concerns he 17 had about the sanitary conditions at the IBY lab? 38 A, No. 19 Q. Did he ever express to you any concerns about 20 the conditions under which the rats were being boused at 21 the IB? Labs? 22 A. HO* 23 Q* Did fee ever express to you any concernabout 24 animals running loose at the IBT Labs in the areas where 25 the rats were kept which were being used as part of the - 29 - CONCANNON & JAEGER WATER PCB-SD0000072320 COMPUTER AIDED TRANSCRIPTION 1 Monsanto PCS product stud/? 2 A. Never, 3 Q. Did Dr. Sunt visit the IBT Laboratory during 4 the time the chronic studies were being conducted there? 5 A. Yes. 6 Q. And did he, Dr. Bunt, indicate to you whether 7 he had visited the area in which the rats were housed which 8 were being used as part of those chronic studies? 9 A. Be did. 10 Q. What, if anything, did Dr. Hunt tell you about n the area where the rats were housed at IBT during the time 12 they were conducting the chronic studies? 13 A. That everything was in order, studies were 14 going on well. No problems that he shared with me. 15 Q. In 1956, were theretradenames for Monsanto's 16 dielectric fluid that contained PCBs? 17 A. There weretradenames, yes, 18 C. What were they? Let me help you, Was IS Therainol one? 20 A. Therainol was atradename ofMonsanto's heat 21 transfer fluids containing PCBs. 22 0. Pydraul? 23 A. Pydraul was a Monsantotradename forfluid 24 used in hydraulic equipment. 25 Q. inerteen? 30 CONCANNON & JAEGER WATER PCB-SD0000072321 COMPUTER AIDED TRANSCRIPTION 3 A. Inerteen was a Westinghouse tradename, which 2 was used with formulations made by Monsanto foe 3 Westinghouse. 4 Q Pyranol? 5 A. Pyranol is a General Electric trademark for 6 dielectric fluids bended for GE specifications, 7 Q Santovac? a A. Santovac is a Monsanto trademark for fluid a used in vacuum machinery, i Q, Was Santovac R ever used in Monsanto's PCS n dielectric fluids? 12 MR, BADERs Object to the form of the 13 question, 14 A. I'm having difficulty remembering just which 15 of the PCS mixtures Santovac was made from, it's very 16 likely that that same type of PCS ended up in dielectric 17 fluids. 18 Q. Did Monsanto ever import Therminol, Pydraul, 19 inerteen, Pyronal or santovac? 26 MR. BAUERt Objection, tacks foundation. 21 A. Not to ray knowledge. 22 Q. (By Mr. Bradley) What job title did you have 23 in January of 1976? 24 A, Manager, Environmental Control. 25 Q, And what responsibilities relative the PCBe - 31 CONCANNON & JAEGER WATER PCB-SD0000072322 COMPUTER AIDED TRANSCRIPTION 1 did you have with regard to that job title? 2 A, 1 was responsible for keeping abreast of any 3 development as it related to PCBs in the environment} 4 advising management on actions that I felt were appropriate 5 to respond to this information 1 was receiving. I was 6 responsible for communicating extensively both within 7 Monsanto and outside of Monsanto regarding this information 8 as is related to PCBs in the environment. 9 Q. With the job title you had in January of 1970, 10 would you expect to learn whether Inerteenn, Pyrenal, 11 pydraul, Santovac and Therminol were imported to Monsanto 12 if, in fact, they were imported? 13 MR. BAUER $ Object to the form. Lacks 14 foundation, indefinite as to time of the imports. 15 A. That was certainly one of the considerations, 16 but I never, in my job, received any information to 17 indicate that importation of those materials did take 18 place. So as X said, to my knowledge, it did not happen. 19 0. (By Mr. Bradley) Did you ever learn during 20 your employment at Monsanto whether the Monsanto*s 21 Corporate Medical Department assembled a file on the 22 products manufactured by Monsanto that contained PCBs? 23 A. Tea, there was a file in the Medical 24 Department. 25 Q, And I take it, you reviewed that file at some - 32 CONCANNON 6 JAEGER WATER PCB-SD0000072323 COMPUTER AIDED TRANSCRIPTION 1 point in the your career at Monsanto? 2 A* I reviewed -- I don't know that I saw the 3 total file but X saw a high percentage of it, yes. 4 Q. Did the Medical Department at Monsanto begin 5 its files in the *30s? 6 A. Yes. 7 MR. BAUERi Objection, 8 0. (By Mr. Bradley) Did Monsanto have a policy 9 of trying to maintain a corporate library, medical or 1C otherwise, that contained all of the references to 11 chemicals manufactured by it which contained PCBa? 12 MR. BAUERi Object to the form, 13 MR, BRADLEYt What's wrong with the form? 14 MR, BAUERt Vagueness with respect to the use 15 of the word "policy" with respect to the particular 16 question. 17 MR* BRADLEYi Go ahead and answer the 18 question. If A. There was a practice within Monsanto to have 20 libraries covering this subject of PCBS and its products. 21 There were at least two that I'm aware oft one, of course, 22 was in the Corporate Medical Department and its contents 23 centered primarily on health effects! the other was over in 24 Monsanto*s Research Department, which included the 25 scientific/technical kind of information, and also included 33 * CONCANNON & JAEGER WATER PCB-SD0000072324 COMPUTER AIDED TRANSCRIPTION 1 all studies ever made by Monsanto*s technical people 2 regarding properties of these materials, the potential uses 3 that they could be put to and so on, 4 0. (By Mr. Bradley) DidMonsantoever have a 5 policy whereby it kept files of any medical information 4 relating to chemicals Monsanto handled, produced or sold? 7 A* Yea. e MR* BRADLEYt Off the record for a moment. 9 (Whereupon, a conversation was held between Counsel, off 1 the record.) 11 0. (By Mr. Bradley) Between 1966and 1975, were 12 you told about any Industrial incidences in the 1930s and 13 1940s where chlorinated chemical were found to have caused 14 liver damage in workers? 15 A. Ye. 16 0. Did Dr. Kelly and Mr. Wheeler give you that 17 information? 18 A. Yes. 1 0. What did they tell you about those industrial 20 incidences? 21 A. The situation had occurred, as I remember, at 22 a plant that was coating wire with chlorinated hydrocarbon 23 chemicals in which the employees of that plant suffered 24 liver damage and, as I recall, there was some death 25 involved. This was traced back to the material at that - 34 CONCANNON & JAEGER WATER PCB-SD0000072325 COMPUTER AIDED TRANSCRIPTION 1 time called Halowexr which x understand is a chlorinated 2 naphthalene# and in that hath# there were some PCBs* There 3 was some discussion held# and X believe there was some 4 investigators involved* X remember the name Dr* Drinker. 5 X don't remember any of the others* 6 Q* Did Dr* Kelly -- Were you finished? 7 A. Not quite* 8 MR, BRADLEY: Sorry. 9 A. As I remember. Dr. Kelly was involved very 30 intimately with these discussions. The conclusion that he 11 had reached was that we ought to treat chlorinated 12 hydrocarbons as being# as having the potential of causing 13 this kind of damage without waiting for a specific study 14 being conducted for each and every one of them. 15 0. And did Dr* Kelly and Mr. Wheeler give you 16 that information in roughly January of 1970? 17 A. Yes. 18 Q. Do you know whether any of the PCBs It manufactured by Monsanto were ever determined to contain 20 chlorinated naphthalene? 21 A. I never heard of that, no. 22 Q, You*re familiar with the term "synergism?" 23 A. Yes# X believe I'm somewhat familiar with it. 24 0* Did Monsanto# in 1966 or any other time# do 25 any studies to determine whether tetrachlorobenzene acted 35 CONCANNON & JAEGER WATER PCB-SD0000072326 COMPUTER AIDED TRANSCRIPTION 1 synergistlcelly with PCBs? 2 MR, BADERi Objection* Locke foundation. 3 A* No* Not to myknowledge. 4 0* (By Mr*Bradley) Did Monsanto ever add 5 tetrachlocobenzene to its PCBs as part of its dielectric 6 fluid blends? ? A. Yes* 0 Q. As part of your work at Monsanto* were you @ familiar with chemicals that were blended together to form 10 the dielectric fluid that Monsanto's manufactured and sold? 11 A. Yes. 12 0. Did you learn in January of 1070* or at any 13 other time* whether Monsanto had performed any studies to 14 determine whether any of the chemicals added to PCBs to 15 create those blends acted synergistically? 16 A. No. 17 Q. Did you ever learn* as part of your job 13 responsibilities at Monsanto between - excuse me* following 10 1956 * that workers exposed to PCBs reported skin lesions 20 along with systemic effects* such as digestive 21 disturbances? 22 MR* BABERt Can I hear that read back* please? 23 (Whereupon* the reporter propounded the previous question*) 24 MR. BABERi Objection, Vague as to whose 25 workers are being involved* but you can answer if you're - 36 - CONCANNON 6 JAEGER WATER PCB-SD0000072327 COMPUTE! AIDED TRANSCRIPTION I able. a A. I'm aware of a reference to akin effects of 3 PCBs. I don*t recall any reference to digestive 4 difficulty. 5 0. (By Mr. Bradley) Do you know whether Dr. 6 Kelly was involved with a report involving workers exposed 7 to pcbe that reported skin lesions along with systemic 8 effects such as digestive disturbances in the 1960s and 9 then pursued a study of it? 10 A. I just don't recall that# no. 1960? 11 MR. BRADLEY: In the 1960s. 12 A. in the '60s? 1 don't remember. 13 Q. (By Mr. Bradley) All right. The situation 14 involving Balowas that you testified to was presented, at IS least in part# in a 1937 report by Cecil Drinker; is that 16 true? 17 A. Tea. 18 Q. Did Monsanto undertake -- Excuse me. Did 18 Monsanto conduct# either in-house or by outside contract, 20 any studies to determine whether any adverse health effects 21 reported by Dr. Drinker were caused by the PCBs or the 22 chlorinated naphthalene? 23 A. Mo. 24 Q. When you met with Dr. Kelly in early 1970 as 25 part of your tutorial, did he indicate to you that he 3? - CONCANNON & JAEGER WATER PCB-SD0000072328 COMPUTES AIDED TRANSCRIPTION 1 learned in 1937 that if there is a sufficient amount of 2 exposure to PCBs to cause a akin rash# or Chloracne* there 3 may be sufficient amounts to cause systemic poisoning in 4 those persons who are hypersensitive to PCBs? S A. Yes. 6 Q. in your work at Monsanto* did you ever learn 7 that workers exposed to PCBs had reported skin lesions 6 along with systemic effects* such as impotence? 9 A. what was that last word? 30 MR. BRADLEYi Impotence. 11 A. No* 1 don't recall that. Skin lesions* yes. 12 0. (By Mr, Bradley) In 1966* were you aware of 13 any study or studies that relate exposure to PCBs with 14 Chloracne? 15 A. Can you helpme with thedefinition of 16 study?* 17 HR. BRADLEYi That would include a report* 18 written report. Any effort to determine whether there was 18 reported to be chloracne as a result of exposure to PCBs. 20 A. Yes. 21 Q. (By Mr. Bradley) Whatstudy orstudies or 22 reports were you familiar with in 1966 that related 23 exposure to PCBs with chloracne? 24 A. There was an incident at the Anniston* Alabama 25 plant* Monsanto* where the PCBs were manufactured* where a - 38 COHCANNON & JAEGER WATER PCB-SD0000072329 COMPUTER AIDED TRANSCRXPTIOR 1 special production run of a very highly chlorinated PCS was a ader and this was in the *508* Some of the employees 3 developed the condition referred to as chioracne. This was 4 eventually traced to impurity of the benzene used as a raw S material at that time* That's the only report that I'm 6 aware of that related cbloraene to PCBs. 7 Q. Did the Drinker 1937 report relate cbloraene 9 with PCBs? 9 MR. BAUERt Object to the form of the 10 question. There's more than one Drinker report* I believe, 11 and without looking at the report or reports, the question 12 is over broad, but you -- 13 MR. BRADLEYs Let me rephrase it. 14 Q. (By Mr. Bradley} Do you know whether Dr. 15 Drinker ever published a report or study that related 16 exposure to PCBs with cbloraene? 17 A. I recall Dr. Drinker reporting the presence of 18 cbloraene with the mixture of chloronaphthalene and chloro 19 * PCBs. I also recall a report in which he referred 26 specifically to PCBs, but I also recall that he retracted 21 that because he was mistaken about the identity of the 22 material initially. So there were several reports that Dr. 23 Drinker is associated with here. 24 MR. BRADLEYs Mould you read back the answer 25 here? - 39 - CORCAMRON & JAEGER WATER PCB-SD0000072330 COMPUTER AIDED TRANSCRIPTION 1 (Whereupon, the reporter propounded the previous answer.) a Q. (By Mr, Bradley) In 1966, were you aware 3 whether anyone within Monsanto had concluded that 4 inhalation of fumea from PCBs could result in chest 5 irritation that would resemble a serious chest cold among 6 Monsanto workers? 7 A, Tes, 8 Q. Was that ever published in a journal or some 9 professional paper? 16 A. 1 don't, recall seeing that* no. 11 0. During the course of your employment at 12 Monsanto, did you ever learn that PCBs were present in cow 13 milk? 14 A. Yes. 15 Q. Do you associate thepresence of PCBs in milk IS as a hazard? 17 A. That's dependent on the concentration of PCBs 18 in the milk and the amount of milk that's consumed. So I 19 need more information. 26 Q, Was there ever an agency of the United States 21 that addressed the presence of PCBs in paints* use of a 22 formulation that contained Aroclor 1254? 23 A. Yes. 24 0. What was the agency? 25 A. It was primarily the Pood and Drug - 40 - CONCANNON & JAEGER WATER PCB-SD0000072331 COMPUTER AIDED TRANSCRIPTION 1 Administration* 2 C. Mas there a point in time between 196$ and 3 1975 when you learned that Aroclor 1254 was being used in 4 certain paints? 3 A* Yes. 6 Q. When did you learn that? 7 A. Sometime in 19 Let me think* Inthe late 8 * 50s * middle to late `60s. 9 0. Did Monsanto ever terminate the sale of 10 Aroclor 1254 and similar PCS mixtures for use in 11 applications such as paint? 12 A. Yes. 13 0. Was that done in August of 1970? 14 A* Yes* 15 Q. And why did Monsanto terminate the sales of 16 Aroclor 1254 and similar PCS mixtures for use in 17 applications such as paint? 18 A. Those applications were perceived tohe the 19 type that led to almost - I say almost - instant release to 20 the environment without any possibility for controlling 21 that release* So in the interest of keeping it out of the 22 environment* that particular use was terminated* 23 0* Are you familiarwith the term 24 biomagnification? 25 A * .Yes * - 41 - CONCANNON & JAEGER i WATER PCB-SD0000072332 COMPUTER AIDED TRANSCRIPTION 1 0* What is it? 2 A. This is a term that ia used to identify the 3 situation that occurs in nature where the different life 4 species form a food chain and the presence of a material at 5 low concentrations at the bottom of the food chain is 6 reflected in increased amounts up the food chain* with the 7 largest amount being consumed by the creature at the top of S that chain. Q, Have any investigators determined a formula 10 for the biomagnification of PCBs in the human food chain? 11 MR. BAUER* Objection. Lack of foundation. 12 A. As 1 remember* there were some individuals 13 that came up with suggested approaches. At the moment* 1 14 don't recall their names nor the numbers. The numbers did 15 vary quite a bit from investigator to investigator. 16 Q. (By Hr. Bradley) How did you learn of the 17 numbers arrived at by the different investigators? Let me IS ask it this way. Did you learn it as part of your regular 19 job responsibilities at Monsanto? 20 A. Tea. Uh-huh. 21 0. And did those numbers range from a thousand to 22 two hundred thousand? 23 A. That sound like the range* yes* sir. Oh-huh. 24 Q. Was the concept of biomagnification relative 25 to PCBs in the human food chain made known to you in 1970? 42 CONCANNON & JAEGER ________ i WATER PCB-SD0000072333 COMPUTER AIDED TRANSCRIPTION 1 A* IT6 * 2 MR* BRADLEY* 26*6 roughly noon* Why don't wo 3 adjourn until 1*00? 4 MR. BAUER* Okay. S (Whereupon, a luncheon recess was taken until 1*00 p.m.) $ Q. (By Mr* Bradley) At aoae point* did you learn 7 of any environmental contamination from plasticisers 8 containing PCBs? "plasticiser* being defined as however 9 Monsanto defines it* 10 A. All right. Yes. 11 0. When did you firstlearn ofthat? 12 A. The PCBs used in thecoatings for silos* which 13 led to the presence of PCBs in milk, 14 Q, And when was that? 15 A. That was 1970. 16 Q. And how did you define plasticiser in 17 answering my question? 18 A. As it relates to PCBs* these are the uses to 19 which PCBs were sold* other than for use as fluids in 20 machinery such as heat transfer units* electrical 21 equipment* hydraulic systems. 22 Q. During the '60s and '70s* were PCBs added to 23 ink? 24 A. Yes. 25 0. To sealants? -43- CONCANNOM & JAEGER i WATER PCB-SD0000072334 COMPUTER AIDED TRANSCRIPTION 1 A. Yes. 2 Q. Paper? 3 A. Carbonless copypaper, yes. 4 0- were theyused in some, for some dental 5 purposes? 6 THE WITNESSI Dental? 7 NR. BRADLEY$ Yes. S A. Yes. f 0. (By Mr. Bradley) And would all of those be 10 considered plasticisers, as Monsanto uses the term? 11 A Yes 12 0. Did Monsanto ewer know that PCBs were being 13 used to extend the life of pesticide? 14 A. Yes. IS 0. When didMonsantolearn that? IS A. There was ascientific article published by 17 personnel with the Department of Agriculture Research IS Center which described the use of PCBs as an extender of 19 pesticide for crawling insects. I# at the moment, don't 26 recall the date of that publication. On or about the date 21 of publication is when Monsanto was aware of this suggested 22 use. 23 Q. And was this publication published, to your 24 best estimate during the 1960s? 25 A. It sounds reasonable. It might have been the - 44 CONCANMON 6 JAEGER WATER PCB-SD0000072335 COMPUTER AIDED TRANSCRIPTION 1 late '50s, '60s. 2 Q. Did Monsanto ever develop products that were 3 to he used to solicit users of its PCBs? 4 MR, BAUERI Object to the form, A, I have a little contusion regarding "develop 6 products," 7 Q, (By Mr, Bradley) Let me ask it again then. 8 Did Monsanto, during the 1950s, develop brochures that were $ distributed to the public advertising the potential uses of IS PCBs ? 11 A. yes. 12 Q. And in any of those brochures, did Monsanto 13 claim that PCBs could be used as Insecticide extenders? 14 A, I believe so,yes, 15 Q, And did Monsanto mat that -- Excuse me. Did 16 Monsanto include that information in its brochure before or 17 after the report of the Department of Agriculture that you IS referred to? 19 A. After* 26 Q. in the1960's, did you ever learn that 21 Monsanto*s PCS manufacturing facilities were directly 22 causing a water contamination problem? 23 THE WITNESS* Can you help me with "water 24 contamination"? Water where? 25 MR. BRADLEYt Water near any of Monsanto's - 45 - COHCANNON & JAEGER WATER PCB-SD0000072336 COMPUTER AIDED TRANSCRIPTION 1 manufacturing facilities* 2 MR. BAUERi Objection. Vague as to whether 3 the question relates to the presence of PCB's in the water 4 or any other substance from, at or involved in the 5 manufacturing plant* which makes many other products. MR. BRADLEY Let me rephrase it then. 7 0. (By Mr. Bradley) During the *608* did 8 Monsanto learn that the PCB manufacturing facilities were 8 causing a water contamination problem by the discharge of 10 PCBs into the water* or water treatment plants* near those 11 manufacturing facilities? 12 A. Monsanto was aware of the presence of PCBs in 13 the waste waters which were transferred to the local 14 municipal treatment plants. There was no evidence that the 15 water that left those plants contained PCBs. 16 Q. Did Monsanto learn in the 1960's that PCBs 17 were in fish anywhere? 18 A. Yes. Id Q. when did it learn that? 20 MR. BAUERr Objection. Lacks foundation as to 21 when anybody in Monsanto worldwide knew that* but Mr. 22 Papageorge* you can give him your recollection. 23 A. Monsanto was aware of the presence of PCBs in 24 fish in the late '60s as reported by -if I'm not mistaken* 25 the original work out of Swedan# amongst its samples had - 46 CONCANNON & JAEGER WATER PCB-SD0000072337 COMPUTER AIDED TRANSCRIPTION 1 some fish. That would be the earliest report. 2 0. (By fir. Bradley) And did Monsanto become 3 aware in the 1966s of the presence of PCBs in shrimp? 4 A. Ten. S Q. When did it learn that? 6 MR. BAUERi Same objection. 1 A. Again* that would be about 1969. bate '60s. 3 0. is that when you learned about it? 9 A. I learned about it in early 1976. 10 Q. Pro Dr. Kelly? U A. Elmer Wheeler, 12 C. As part of one of your tutorials? 13 A, Correct. 14 0. Did Monsanto develop analytical procedures to 15 determine the presence of PCBs in water at any point In 16 time? 17 A, Tea. ia Q. When did they do that? 19 A. It started in 1967 andwas considered to be 20 accurate and trustworthy by 1969, 21 Q. Do you recall during your deposition of 22 February 23rd and 24th, 1993 being asked the question at 23 page 132* my question iss "QUESTIONi When did Monsanto 24 develop analytical procedures for the determination of PCBs 25 in water?" Objection was made by Mr. Featherstone to the - 47 - CONCANNON & JAEGER v i WATER PCB-SD0000072338 COMPUTER AIDED TRANSCRIPTION 1 scope and the answer vast "ANSWER* By 1968# the 2 methodology had been developed to the point where it was 3 considered acceptable." Do you recall giving that 4 testimony during your deposition? 5 MR. BAUERt Well# can we see a copy of the 6 transcript# please? 7 A. 1 probably said that. 1 missed it by a year. $ My memory is not that accurate. $ 0* (By Mr. Bradley) Too also indicate in your 10 answer given in Pebruary that the methodology was refined 11 by 1969t is that correct? 12 A, That is correct. 13 Q. Are you familiar with the acronym ANSI? 14 A. Oh# yes. Yes# sir. 13 Q. And what does ANSI stand for? 16 A. American National Standards Institute. 17 Q. what is that institute? 18 A. It is an institute that is available to 19 industry to establish standards for products and procedures 20 throughout any industry that has an interest in 21 establishing such standards. 22 C. Were you ever a member of a committee known as 23 C-107 of the ANSI? 24 A. I was. This was a committee that was 25 appointed to address the use of PCBs in electrical - 48 - COMCANNON 6 JAEGER WATER PCB-SD0000072339 COMPUTER AIDED TRANSCRIPTION 1 equipment, the proper handling of the PCB type materiel, 2 the proper use, the proper disposal, the proper testing. 3 Q. Did Monsanto suggest the creation of C-107 4 with ANSI? 5 A. No* 0. Was Monsanto one of two sponsors of the C-107 7 committee? 0 A. I didn't associate Monsanto*e being a sponsor. There was a member of Monsanto on a steering committee 10 working within the organisation known as NEKA, National 11 Electrical Manufacturers Association, that made a 13 recommendation that a committee be formed under the 13 auspices of ANSI. 14 Q. And the person within NEMA who made that 15 recommendation was a Monsanto employee; is that true? 16 MR. BAUERt Object to the form of the 17 question. Lacks foundation, that Monsanto or any employee 18 of Monsanto, was a member of NEMA* 19 MR. BRADLEYt Guess me*re about to find out. 20 A. There was a Monsanto individual who was part 21 of the group that came up with this decision. This person 22 was not a member of NEMA, nor was Monsanto a member of 23 NEMA. 24 Q. (By Mr. Bradley) The suggestion to start 25 C-107 was made, in part, by Monsanto and in part by NEMAj - 49 - CONCANNON 6 JAEGER WATER PCB-SD0000072340 COMPUTER AIDED TRANSCRIPTION 1 is that correct? 2 A, That is correct# yes* 3 0. The purpose of the C-107 committee vae to 4 develop standards regarding the use# handling, testing and 5 disposal of pc@s; is that correct? 6 HR. BAUERs Objection* Asked and answered. 7 A* Yes* S Q. (By Mr. Bradley) During thetime that -- 9 Nell, over what period of time was the C-107 committee in 10 existence? 11 A. The best I can recall, it was *71 through -- 12 It was still in existence in 1976, when I had a job 13 assignment change, I do not know when it finally 14 disbanded. 15 Q. Between *71 and *76, who headed the C-107 16 committee? 17 A. I did. 18 Q, Did Paul Benignua ever head thatcommittee? 19 A. NO. 20 Q. who took over the chairmanship of the 21 committee once you left in *76? 22 A. I don't know that I ever heard the name, i 23 don't know. 24 0. was there a transformer and a capacitor 25 subcommittee of C-107? - 50 CONCANNON fc JAEGER WATER PCB-SD0000072341 COMPUTER AIDED TRANSCRIPTION 1 A. Yes. 2 0. And who headed the transformer subcommittee of 3 C-107 between *71 and *767 4 A. Be had Rash, p-a-a-b. 5 Q. And at that time* where was Mr. Raab employed? 6 A. General Electric* 7 0. And what work did he did at General Electric? S A* Be was involved with transformers, located in 9 Pittsfield, Massachusetts. 10 0* And during the period 1971 to 1976, who at the IX C-107 committee was the head of the capacitor subcommittee? 12 A. Dr. Posefsky, p-o-s-e-f-s-fe-y. 13 0. Where did Dr. Posefsky work between 1971 and 14 1976? 15 A. Re worked withGeneral Electric, and I believe 16 it was a Hudson Palls, 17 Q. Do you know what position Dr* Posefsky had 18 with GE at Hudson Pails? If A. 1 don't know the official designation, I do 20 know that he was involved with technology associated with 21 capacitor manufacturing* 22 Q. Do you know whether Nevada Power Company was a 23 member of either subcommittee? 24 A. They were not. 25 Q, Did the transformersubcommittee have roughly - 51 - CONCANNON * JAEGER WATER PCB-SD0000072342 COMPUTER AIDED TRANSCRIPTION 1 seven or eight members between 1971 and 1976? 2 A* At least that* It seems to me there were 3 more. There was a roomful1 of people* 4 Q. Ana were the members of the transformer 5 subcommittee predominantly employees of transformer 6 manufacturing companies? 7 A. Yes. i Q. Was there anyone who was a member of the 9 transformer subcommittee of c-107 between 1971 and 1976 who 10 was not employed by a transformer manufacturing company? 11 A. Yes. 12 0. Who? 13 A. Well, I recall an individual that represented 14 the utility companies. 15 Q. Do you recall that person's name? 16 A. Starts with an t. 17 Q. And do you recall what organisation that 18 person was employed by? 19 A. Re was employed by Onion Electric Company in 26 the St. Louis area. Re represented some industry group and 21 I have forgotten the name of that group. 22 0* Anyone else beside theemployee of Onion 23 Electric Company? 24 A. A representative of Coble#D~o-b~l-e# 25 Engineering Company. 52 CONCANNOH & JABCSR WATER PCB-SD0000072343 COSPOTER AIDED TRANSCRIPTION 1 Q. What was Dcbie Engineering Company between 2 1971 ana 1976? 3 A. They provided a service to owners, operators 4 of transformers. 3 0. Was anyone else a somber of this transformer 6 subcommittee during the 1971 to *76 period who was not an 7 employee of a transformer manufacturing company? e A. Tea. as I remember, there were some 9 Government representatives involved on and off, Such 1 entities as the TVA Authority# OPA. I*d have to see the 11 documents to refresh my memory. That's all that comes to 12 mind at present. 13 G, And how about the capacitor subcommittee of 14 C-1G7 between 1971 and 1976? Did it have any members that o 15 were not employees of capacitor manufacturing companies? 16 A. Its, 17 Q. Who were they? 18 A. Some of the same individuals we referred to 19 under the transformer committee would also serve on the 2 capacitor committee. 21 Q. And were Onion Electric Company employees part 22 of the capacitor subcommittee? 23 A. Re would ait in on some of their 24 deliberations, yes. 25 Q. Was be a member oftheir subcommittee? - 53 * CONCANNON JAEGER WATER PCB-SD0000072344 COMPUTER AIDED TRANSCRIPTION 1 A. I would say yea. This membership was not a 2 formal kind of appointment. It was -- The membership was 3 open to anybody interested. 4 Q. Was Doble Engineering a member of the S capacitor subcommittee? $ A. NO. 7 Q. Were there any representatives from government 8 who were members of the capacitor subcommittee? A. As best as X recall# yes. 10 G. Were there any other members who were not 11 employees of manufacturing# capacitor manufacturing 12 companies? 13 A. I don't recall any. 14 0. Did Monsanto employees participate in these IS subcommittees? 16 A. Tes. I did# for example. 17 Q, Did Paul Benignus participate? 18 A. On occasion# yes. 19 Q. Anyone else within Monsanto participate with 20 the meetings and work with either of those two 21 subcommittees? 22 A. No. 23 0. Was someone from Weatinghouse on the capacitor 24 subcommittee? 25 a. yes. * 54 * CONCANNON A JAEGER WATER PCB-SD0000072345 COMPUTER AIDED TRANSCRIPTION 1 0. Mas aoneone from Meetinghouse on the 2 transformer subcommittee? 3 A. Tee* 4 0* Mho was that person who was on the transformer 5 subcommittee from Meetinghouse? 6 A. Transformers? T.R, Slots, 7 Q, And who from Meetinghouse was on thecapacitor 8 subcommittee? A. Don McClain. I think his first name was le Robert. R.D. McClain. n Q. In 1971, didn't you become aware of reports of 12 fish kills that were attributed to PCBs? 13 A. X don't associate fish kills with PCBs. X 14 just don't remember any. IS 0. All right. Do you remember hearing reports of 16 fish kills generally from a Monsanto plant where some 17 regulatory agent would contact the plant and they *d relay 10 it to St. Louis? I don't mean to trick you either. You've 19 given testimony on that in your prior deposition. Mould 28 you like to review that? 21 A. Right now, I have trouble recalling fish 22 kills, it doesn't come to me right now. 23 0. Do you recall whether Monsanto ever obtained 24 samples of fish that had been killed reportedly because of 25 exposure to PCBs? - 55 - CONCANNON S JAEGER WATER PCB-SD0000072346 COMPUTER AIDED TRANSCRIPTION 1 A* I recall Monsanto receiving samples of fish. 2 I do not recall any particular incident that I can 3 associate with those samples* 4 Q Nan testing ever performed on those fish 5 samples to determine the presence or absence of PCBs? 6 A* There were analyses made# yes# air. 7 Q. what were the results of the analyses? B A* There were PCS in the tissue. 9 Q. Okay. Did the analytical research laboratory 10 in St. Louis perform those analyses? 11 A. They performed some of these analyses# yes. 12 C. Who performed the analyses that were not 13 performed by the analytical research laboratory in St. 14 Louis? IS A. Weil# I'd have to have the specific instances. 16 There are other laboratories# governmental labs# private 17 labs and universities. IB Q. Do you recall whether the amounts of PCBs 19 found in the fish exceeded any guidelines or regulations 20 established by the Food and Drug Administration? 21 A. I recall some of the findings exceeded that# 22 yes. 23 0. Did you iearn in 1960 that crab exposed to 24 PCBs contained PCBs in their tissues? 25 THE WITNESS! In 1960? * 56 * CONCANNON JAEGER WATER PCB-SD0000072347 COMPUTER AIDED TRANSCRIPTION 1 MR, BRADLEYi 19603 2 THE WITNESSt Crab? 3 A, I don't remember. 4 Q. (By Mr, Bradley) Do you remember learning of 5 the results of any teats performed by the fish laboratory $ in Gulf Breeze# Florida? 7 A. Yea. $ 0, When did you aboutthose? 9 A. In January# 1970. 10 Q* And do you know whether it was reported by 11 Gulf Breeze# Florida that they had conducted tests on 12 certain species of fish regarding the presence of PCBs? 13 A, I recall tests being conducted at the 14 laboratory to determine the effect of PCBs on marine 15 creatures. I don't recall any test that was designed to 16 just determine the presence of PCBs in the fish. 17 MR. BRADLEYi Would you read the answer back 10 for me# please? 19 (Whereupon# the reporter propounded the previous question.) 20 0, (By Mr. Bradley) Do you recall when the -* 21 well# let me ask It this way. Did Gulf Breeze# Florida's 22 lab produce a report that described their study of the 23 effects of PCBs on certain species of fish? 24 A, I recall a report that included information on 25 the sensitivity of young shrimp to the presence of low - 57 - CONCANNON i. JAEGER WATER PCB-SD0000072348 COMPUTER AIDED TRANSCRIPTION 1 levels of PCBs. X vaguely recall reports of the studies 2 that were made to determine what effect PCBs had on other 3 marine life - fish* in particular. 1 do not recall that 4 any dramatic effects were reported regarding reproduction* 5 illnesses and so on* 6 0. What do you-- 7 A. 1 don't remember that* 8 Q* What do you recall* ifanything* about the 9 results of the exposure of shrimp to low levels of PCBs? 10 A* I recall that the newly hatched shrimp could 11 not tolerate concentrations of something like five parts 12 per billion in the water. 13 Q. Is the Gulf Breeze* FloridaCommercial 14 Fisheries Laboratory* a laboratory that tested crab and 15 analyzed the tissues and found PCBs? 16 A, 1 just don't associate crab with PCBs. it 17 does not ring a bell at all with me. 18 0. Do you remember during your deposition of 19 February 23 and February 24* 19@3 being read the question 20 on page four of Plaintiff's Exhibit 415 at the top 21 actually* it begins on page three at the end. It says* *ffe 22 have talked with scientists at the Gulf Breeze* Florida 23 Commercial Fisheries Laboratory. They have conducted 24 studies with crab and shrimp. This is the laboratory that 25 did detect a buildup in crab and also the lethal effect on - 58 - CONCANNON & JAEGER WATER PCB-SD0000072349 COMPUTER AIDED TRANSCRIPTION 1 juvenile shrimp." Did I read that correctly? 2 A. Yes* sir* 3 Q. "QUESTIONt What did you mean when you said* 4 "This is the laboratory that detected a buildup in the S crab?* ANSWERS This is the laboratory that tested crab and 6 analysed the tissue and found PCBs." 7 A. 2 don't doubt that* 3 MR* BADERI Tate a loot at it. Is Plaintiff's 3 Exhibit 415 a document authored by Mr. Papageorge* do you 10 know? It's quoted here and you don't have it here* today. 11 MR. BRADLEYi X don't have it. 2 don't have 12 it with me this very moment. I'll represent that ray 13 records indicate that 415 is a letter from w.B. Papageorge 14 to Mr. Jenkins* dated July 8th* 1970. 15 MR. BADERI Thank you. 16 THE WITNESS $ Jenkins? 17 MR. BADERt The question pending* did you read 18 the questions and answers correctly? 19 MR. BRADLEYS That is correct* 26 A. Yes* you did. 21 Q (By Mr* Bradley) All right* Do you recall* 22 does that refresh your recollection on whether this is the 23 laboratory that tested crab and analysed the tissue found? 24 A. It doesn't. I still do not recall it. 25 Q. Have you ever written that certain uses of - 59 - CONCANNON & JAEGER WATER PCB-SD0000072350 COMPUTER AIDED TRANSCRIPTION 1 PCS8 were grossly contaminating the environment? 2 A. I believe I did, yes. 3 0* When you wrote that# what uses of PCBs were 4 you indicating were grossly contaminating the environment? S A. 1 don't have a good measure for quantifying 6 grossly,* but I had in mind the uses we described earlier# 7 such as the carbonless copy paper; the inks; the sealants; 8 the calking materials; the inks# the adhesives. Those uses f that permitted almost immediate entry into the environment. 10 They were not in sealed equipment. 11 0. And did you write that some uses of PCBs were 12 grossly contaminating the environment In 19707 13 A. I believe I did# yes# sir. 14 Q. Are you familiar with a gentleman known as 15 Congressman Ryan? 16 A. Yes# I* familiar with him. Yes. 17 Q. Was he a congressman in 1970? 18 A. Yes. if Q. And he was a member of the United States 20 Congress? 21 A. Yes. 22 Q. In 1072# did Congressman Ryan introduce any 23 legislation dealing with PCBs? 24 A. Yes. 25 Q. What was that legislation? <- 60 - CONCANNON & JAEGER WATER PCB-SD0000072351 COMPUTER AIDED TRANSCRIPTION 1 A. I don't recall the exact year but as best I 2 recall. Congressman Ryan Bade two attempts to introduce 3 legislation relating to PCBs. As I recall, his first 4 attempt was to restrict the use of PCBs under certain 5 conditions. Bis second attempt was to totally ban PCEs 6 from any use. 1 Q. Do you recall when Congressman Ryan first 8 introduced legislation addressing or dealing with PCBs? 9 A. As best I can recall, about 1971. 10 Q. Do you know whether he introduced a bill to 11 ban PCBs in 1970? 12 A. That could be the bill, in *76, which be tried 13 to limit the use. it was a later bill, either *71 or *72 14 period. I may be off by a year, *78, *71, *72 period. The 15 second bill was the one that called for a total ban. 16 Q Did you ever write that many PCBs are man made 17 and were introduced to the environment because of our lack 18 of understanding of what these materials can do to the 19 environment? 20 A. X did. 21 Q. Was that written in 1976? 22 A. That sounds about right, yes. 23 0. What did you mean when you wrote that PCBs 24 were introduced to the environment because of our lack of 25 understanding of what these materials can do to the - 61 - CONCANNON t JAEGER WATER PCB-SD0000072352 COKP0TBR AIDED TRANSCRIPTION 1 environment? 2 A* There was no information that would indicate 3 that PCEs, for example* would harm juvenile shrimp. There 4 was no information that would lead to many of the 5 allegation that were occurring then* in 1970* regarding 6 the effect on reproduction of birds, it's this kind of 7 information that just was not available. 8 0* In your work at Monsanto, did you ever discuss with employees of Central Electric anything having to do IS with the alleged toxicity of PCBs? 11 A. Yes. 12 Q. Did you have more than one discussion on that 13 topic with GS employees? 14 A. Oh* yes. IS 0. when did those discussions begin? 16 A. As best I recall* very early in 1970. A group 17 of General Electric representatives came to St. Louis and 18 we had a session on PCBs in the environment. IS Q. Do you know whether you had a discussion with 20 any C.E. employees prior to 1970 regarding the toxicity of 21 PCBs? 22 A, l did not personally* no. 23 0* Do you know whether* prior to 1970* anyone 24 within Monsanto had discussions with GE regarding the 25 toxicity of PCBa? * 62 ** CONCANNON 6 JAEGER WATER PCB-SD0000072353 COMPUTER AIDED TRANSCRIPTION 1 A. Yes. 2 Q. Or who had those discussions with G.B.? 3 A* Monsanto*s medical department personnel. 4 Primarily, Dr, Emmet Kelly. 5 Q. And to whom was Dr. Emmet Kelly speaking with 6 at G.E., if you know? 7 A, I don*t know. 8 0. Did Monsanto have any discussions with employees of Meetinghouse regarding the toxicity of PCBs? 10 A, Yes. 11 Q. When did those begin? 12 MR. BAUERi Object to the form of the 13 question. Lacks foundation. 1 don't think this witness 14 would know when they began. 15 A. I have an understanding. 16 Q. (By Mr, Bradley) what is your understanding? 17 A. These discussions occurred in the early *30s, 18 * 40s. 18 0. Bow do you come by that understanding? 20 A. Prom my discussions with Dr, Kelly. 21 Q. And does it also come from your discussions 22 with Elmer Wheeler? 23 A. Yes. Be just confirmed what Dr. Kelly had 24 told me* 25 0. And did you personally have discussions with * - 63 - '* - CONCANNON & JAEGER WATER PCB-SD0000072354 COMPUTER AIDED TRANSCRIPTION 1 employees of Meetinghouse regarding the toxicity of PCBs? 2 A. Ves. 3 Q. when did those begin? 4 A. Again, a group of Meetinghouse employees met 5 with Monsanto# must have been 1970. Right after X got the $ assignment as manager of environmental control. 7 Q. After you got that assignment# would you send 8 studies that may have come into Monsanto regarding the 9 toxicity of PCBs to General Electric? 10 MR. BADERt Object to the form. 11 MR. BRADLEY* All right. 12 0. (By Mr. Bradley) Let me ash it this way. 13 After January of 1970# did you ever review any current 14 studies regarding the toxicity of PCBs? 15 A. Yes. 16 Q. Did you send copies of those studies to anyone 17 at General Electric? 18 A. Z sent copies of status reports * about a two IS page document which described the results known to date, 28 as of the date of that status report. 21 Q. Mould you also sand those to Meetinghouse? 22 A. Yes. 23 Q. To whom at Meetinghouse did you address the 24 status reports? 25 A. Oh# I don't recall. There wasn't one person. - 64 - CONCANNON I. JAEGER WATER PCB-SD0000072355 COMPUTER AIDED TRANSCRIPTION 1 0. Do you recall to whom at General Electric you 2 addressed the status reports? 3 A. Again* it would not be one person, it would 4 have been a -- 5 0* was it typically addressed to one particular department? 7 A. No. it was generally addressed to the 8 individual that I was led to believe served as the PCS 9 spokesman for either General Electric or Meetinghouse, and 10 that assignment seemed to change through the years. 11 0. Do you recall the names of any G.E. or 12 Meetinghouse people to whom you sent those reports? 13 A. 1 recall a few of them. I'm trying to 14 remember. The Meetinghouse was John -- I can't remember 15 his last name. There was Ed Simon from General Electric; 16 Hr. Raab at one point in time* at General Electric* Hr. 1? Leseski at one point in time. It was kind of a fluid type 18 of assignment, If 0. now aboutDr, sloth? 20 A. Dr, Sloth* and so was DonMcClain* and there 21 were others at Meetinghouse* Dr* -- Starts with a D. 22 Q* Daykin? 23 A, Daykin, it's been awhile. 2 just can't 24 remember all the names, 25 Q. I'm going so show you Plaintiff's Exhibit 1217 - 65 - CONCANNON 6 JAEGER WATER PCB-SD0000072356 COHPBTER AIDED TRANSCRIPTION 1 after I show It to the attorney for westinghouse, and then 2 I'll ask you if you ewer reviewed that document before. 3 A. I have not seen this document before. 4 C. Did Monsanto -- Excuse me. Did Monsanto 5 blend a product called Pydraul 312-C in October of 1973? 6 A. Yes# sir* 7 Q. Was that a blend intended for use in 8 dielectric fluid? 9 A. No* 10 0. What Aroclor comprised Pydraul 312-C? 11 HR* BABERs Object to the foundation. Assumes 12 a fact not in evidence* that there was any Aroclor in 13 Pydraul in 1973. 14 A. None* 15 Q. <By Hr. Bradley)Here there any pcbs in 1 Pydraul 312-C in October of *73? 17 A. There were none. 18 0* None. I* now showing you Plaintiff* 19 Exhibit 1597 and ask if you have ever seen that document 20 before? 21 A. 1 have seen this before. 22 0. Is that an April 28* 1972 letter from Elmer 23 wheeler to Dr. Otis Panchor at IBY? 24 A. It's Or. Otis Rancher, who used to be with IB? 25 and retired at this point in time. -- 66 - CONCANNON & JAEGER WATER PCB-SD0000072357 COMPUTER AIDED TRANSCRIPTION 1 Q. All right. And is that a true and accurate 2 copy of the letter in April et 1972 from Elmer wheeler to 3 Dr. rancher? 4 A. The only thing missing is the Monsanto logo 5 that is normally on letters of this type. 6 Q. All right. 7 A. And it * s missing the man's signature# the 8 author's signature. 9 Q. When you saw it# did it have the letterhead cm 10 it? 11 A. As best 1 recall# yes. 12 Q. And did it have the signature on it? 13 A. ?es# sir. 14 Q And other than those two omissions# is it a 15 true and accurate copy of vhat you saw before? 16 A. I believe so. 17 Q And was this a letter Mr. Wheeler wrote on or 18 about the time he gained the information that's contained 19 in the letter? 20 A. Yes. 21 Q* And did Mr. Wheeler write this aspart of the 22 regular business activities at Monsanto? 23 A. Yes# sir. 24 Q. And was a copy maintained in Monsanto's files 25 as part of its regularly conducted business? - 67 - CONCANNON 6 JAEGER WATER PCB-SD0000072358 COMPUTER AIDED TRANSCRIPTION 1 A. Yes. 2 Q. I* now going so show you Plaintiff's Exhibit 3 1237# which is a February 3# 1971 letter fro R. Emmet 4 Kelly to Griffith Quinby. S MR* MORGANt tfhat's the number? MR. BRADLEY * 1237. 7 A. i have reviewed the document. 8 0. (By Hr. Bradley) Is that a document you've 9 seen before today? 10 A. Yes# 1 have. li 0, And except for the yellow highlighting# is 12 that a true and accurate - and the Bates numbers at the 13 bottom * is that a true and accurate copy of the letter 14 that you saw that was written on or about February 3# 1971 IS fro Dr. Kelly to Dr. Quinby? 16 A. Other than the missing Monsanto logo on the 17 letterhead and the missing signature# it is. 18 Q. And was that letter written at or about the 19 time that Dr. Kelly gained the information that's referred 28 to in the letter? 21 A, Much of this information Dr. Kelly obtained 22 through decades of experience. 23 Q. Apparently# Dr. Kelly was responding to a 24 letter from Dr. Quinby; is that correct? 25 A. Yes. - 68 COKCANNON 6 JAEGER WATER PCB-SD0000072359 COMPUTER AIDED TRANSCRIPTION 1 0. Apparently the letter was authored on or about 2 the time that Dr. Kelly put together the information in the 3 letteri it that correct? 4 A. That is correct. 5 Q. And is that a document that was authored as 6 part of the regular business activities conducted by Dr. 7 Kelly at Monsanto? S A. yes. 9 0. And was a copy maintained in the files of 30 Monsanto as part of its regularly conducted business? 11 A. Yes. 12 Q. I'm going to show you Plaintiff's Exhibit 419# 13 which is apparently authored by you and It's dated October 14 26th# 1970 and ask if you you've seen that document before 15 today? 16 A. 1 haveseen this document before# yes. 17 Q. And is that a true and accurate copy of a 18 document you authored on or about October 26th# 1970? 19 A, It appears to be. 20 Q. And did you author that document at about the 21 time that you gained the information that's contained in 22 the exhibit? 23 A. yes. 24 Q. And did you author that document as part of 25 your regular business activity at Monsanto? - 69 - CONCAHNON t JAEGER WATER PCB-SD0000072360 COMPUTER AIDED TRANSCRIPTION 1 A* Yes* 2 Q. Ana was acopy maintained withinMonsanto's 3 files as part of Monsanto's regularly conducted business? 4 A. Yes. 5 Q. I'm now going to show you Plaintiff's Exhibit 416r which is a letter dated May 25* 1970, from Elmer 7 Wheeler to Otis rancher at Industrial Biotest Laboratory 8 and ask if you have seen that document before today? 9 A. I recall this document 10 Q. Is that a true and accurate copy of the letter 11 written by Elmer Wheeler on or about May 25, 1970 to Otis 12 rancher? 13 A, Again, except for the absence of the 14 letterhead and signature, it appears to be. IS 0* And was that letter authored at or about the 16 time that Mr. Wheeler gained the information that's 17 contained in the exhibit? 18 A* Yes, sir. 19 Q, Was that document authored as part of the 20 regular business activity of Mr. wheeler while a Monsanto 21 employee? 22 A. Yes. 23 Q Was a copy maintained within Monsanto's files 24 as part of Monsanto's regularly conducted business? 25 A. Yes. - 70 - CONCANNON & JAEGER WATER PCB-SD0000072361 COMPUTER AIDED TRANSCRIPTION 1 G. X' now going to show you Plaintiff's Exhibit 2 1494* which is a letter from Dr. Rally to Herbert 3 Blumenthal with the 6.8* Pood and Drug Administration dated 4 April 8th* 1378 and ask if you've seen that document 5 before? 6 A. X have seen this document before. 1 Q. Is this a true and accurate copy of an April 8 3th* 1978 letter from Dr. Kelly to Herbert Blumenthal? 8 A* Yes. Again, except for the letterhead an 10 signature. n Q. is this a letter written by Dr. Kelly at or 12 about the time he gained the information that's contained 13 in the exhibit? 14 A. It is. 15 Q. Is this a document that was authored by Dr. 16 Kelly as part of his regular business activities at 17 Monsanto? 18 A. It IS. 19 0. Has a copy of thisexhibit maintained within 20 Monsanto's files as part of its regularly conducted 21 business? 22 A. Yes. 23 Q* I'm now going toshow you Plaintiff's Exhibit 24 1193* which is an April 8th* 1970 letter from Dr. Kelly to 25 Dr, Blumenthal, and again and ask If you've seen that - 71 - CGNCANNON 4 JAEGER WATER PCB-SD0000072362 COMPUTES AIDED TRANSCRIPTION 1 document before today? 2 A. I recall this document. 3 0. la this a true and accurate copy of a letter, 4 dated April 8th, 1970, from Dr. Kelly to Dr. Blumenthal? 5 A. Yes. 6 C* Absent the letterhead and signature? 7 A. Yea. 8 Q. And was this document authored at or about the time that Dr. Kelly gained the information that's contained 18 in the exhibit? 11 A. Yes. 12 Q. And was this letter authored by Dr. Kelly as 13 part of bis regular business activities while a Monsanto 14 employee? 15 A. Yes. 16 Q. Did Monsanto maintain a copy of this as part 17 of Monsanto's regularly conducted business? 18 A. Yes, 19 0. I'm nowgoing to show youPlaintiff's Exhibit 28 428, which is a March 38th, 1970 transmittal from Dr* Kelly 21 to you, and ask if you have ever seen that document before? 22 A. I have seen this document before. 23 Q. What do you call that document? Is that a 24 memorandum? 25 A. Memorandum. It's aMonsanto In-house form of - 72 - CONCANNON & JAEGER WATER PCB-SD0000072363 COMPOTES AIDED TRANSCRIPTION 1 cor respondence. 2 Q. All right* Is that a true and accurate copy 3 of a memorandum you authored in March# 1970? 4 A. I didn't author -- S Q, Excuse me* is it a true and accurate copy of 6 a memorandum Dr. Kelly authored to you in March of 1970? 7 A* Yes* B 0* Has that memorandum authored at or about the 3 time Dr. Kelly gained the information that's contained in 10 the exhibit? 11 A. Yes. 12 0. Did Dr, Kelly author thatmemorandum as part 13 of his regular business activities while in a Monsanto 14 employee. IS A. Yes. 16 Q. was a copy maintained inMonsanto's files as 17 part of Monsanto's regularly conducted business? 18 A. Yes. IS 0. I'm now going to show you a document entitled 20 "Summary -- interim Status, Chronic Toxicity Aroclora." It 21 has in highlight the date 3-18*70 in the top right hand 22 corner, which does not appear to be part of the original 23 document. 24 MR. BADERt Does this have an Exhibit Number 25 on it? - 73 - COMCANNON & JAEGER WATER PCB-SD0000072364 COMPUTER AIDED TRANSCRIPTION 1 MR* BRADLEYt I*a sorry, Yes. 2 MR. BADER 709. Okay. 3 MR. BRADLEY s 709. 4 A. X have reviewed the document. S 0. (By Mr* Bradley) save yea seen that: document 6 before today's date? 7 A. x have seen -- Yea. The reason I'm a hesitating, it doesn't appear to me to be one piece of 9 communication. It looks to me, from the Information I read 10 that there's a considerable time period that it covers. 11 MR. BAUER) Can we go off the record for a 12 second? 13 MR. BRADLEYI Yes. 14 (Whereupon, a short colloquy was held between Counsel, off IS the record.) 16 MR. BRADLEYs Let's go back on the record. 17 Mr. Court Reporter, if you would attach a sticker 18 indicating Plaintiff's Exhibit 709-A to the portions of 19 Plaintiff's Exhibit 709 that have the Bates numbers 20 ADM005988 through ADM005992. 21 (Whereupon, the reporter marked Plaintiff's Deposition 22 Exhibit Humber 709-A, for identification)* 23 MR. BRADLEYt I'm going to separate Exhibit 24 709 from 709-A and I now reshow you Plaintiff's Exhibit 25 709. - 74 - CONCANNON & JAEGER WATER PCB-SD0000072365 COMPUTER AIDED TRANSCRIPTION 1 A* I have looked at the document. 2 0* la it a document that you've seen before? 3 A. Tea* but not as a composite. 4 0. When you saw the summary, which is page one of 5 Plaintiff's Exhibit 709, did it have any attachments to it? 0 A. Mo* This is the interim report that 1 had 7 mentioned earlier, that X got out of Mr. Wheeler's office 8 on a periodic basis describing the status of the long-term 0 studies undergone at 1ST. IS 0. well then, what I'm going to ask is that you 11 hand me back the other sheet of paper and ask the court 12 reporter to mark as Plaintiff Exhibit 709-B pages with the 13 Bates Number 67569 - excuse me, 65985, 63987. 14 (Whereupon, the reporter marked Plaintiff's Depositions 15 Number 709-B, for identification) IS Q. (By Mr. Bradley) Is Plaintiff's Exhibit 709 a 17 true and accurate copy of a summary, "Interim Status -- 18 Chronic Toxicity With Aroclors?" 19 A. Tea. 2 Q. Was that a document -- well, do you know who 21 authored that document? 22 A. I believe I do. 23 Q. Who authored it? 24 A. Elmer Wheeler, Monsanto. 25 Q. Do you know he authored it on or aboutMarch 75 - CONCANNON & JAEGER WATER PCB-SD0000072366 COMPOTES AIDED TRANSCRIPTION 2 18th, 1970? 2 A. I find that date does not notch the wording in 3 the text below. 4 0* All right. When would you estimate that that S exhibit was authored? A. Let me see. It refers to eleven months after 7 the start in May and dune of *69, which would sake it April B and May of *78. So the date of this document would more 9 likely about May or dune, *70, giving enough time for the 10 information to be transferred to Monsanto and the document II to be composed. 12 Q. Is that a true and accurate copy of a Summary 13 -- Interim Status that you reviewed in 1970? 14 A. fee, sir, 15 Q. Okay. Was it authored at or about the time 16 that the author obtained the information that's contained 17 in the exhibit? 18 A. Tee, sir, If Q, Was it authored as part of the regular 20 business activities at Monsanto? 21 A, Yes, sir. 22 Q. Was a copy maintained within Monsanto as part 23 of Monsanto's regularly conducted business? 24 A. Yes. 25 0. And it's understood that when you said it's a 76 COMCANNON & JAEGER WATER PCB-SD0000072367 COMPUTER AIDED TRANSCRIPTION 1 true and accurate copy* that you roe-ant absent the orange 2 highlighting? 3 A. That is correct* 4 Q* I'* now going to show you Plaintiff's Exhibit 5 1495* which is a letter from Elmer Wheeler to Dr. Joseph $ Calandra at industrial Biotest Laboratory* dated March 4th* 7 1979* and it shows a cc was sent to you* and ash you if a you've seen that document before today? a A. 1 recall this document. 10 Q. Is that a true and accurate copy of a letter ii authored March 4th* 1970 fro Mr. Wheeler to Mr. Calandra? 12 A. Yes* Again* it's missing the letterhead and 13 signature. 14 Q. Was that exhibit authored at or about the tine 15 that Mr. wheeler gained the information that's contained in If the exhibit? 17 A Ye. 18 Q. Was the exhibit authored by Mr. Wheeler as 19 part of his regular business activities while a Monsanto 28 employee? 21 A. Yes# 22 Q* was it* a copy of it* saintained within 23 Monsanto's files as part of Monsanto's regularly conducted 24 business? 25 A Yes * 77 COMCAMMON 6 JAEGER WATER PCB-SD0000072368 COMPUTER AIDED TRANSCRIPTION 1 Q. 1*ra now going to show you Plaintiff's Exhibit 2 1483 and ask if you've seen that document before. 3 MR. BRADLEY: Actually, let me know when 4 you're finished reviewing it, then I want to show it to 5 other counsel before 1 ask any questions about it. 6 Q. (By Mr. Bradley) Is this a true and accurate 7 copy of a letter sent by Elmer Wheeler to Mr. Speicher at a Meetinghouse on July 25th, 1956? 9 A. Yes. 10 0* Is this a document that was written by Mr. n Wheeler at or about the time he obtained the information 12 contained in the exhibit? 13 A. Yes, sir. 14 0. Mas this exhibit prepared as part of the 15 regular activities of Mr. Wheeler while he was a Monsanto 16 employee? 17 A. Tea. 18 0. And was a copy of itmaintained in Monsanto's 19 files as part of Monsanto's regularly conducted business? 20 A. Yes. 21 MR. BAUERi Were you including the handwritten 22 notes in your answer with respect to that one, Mr. 23 Papsgeerge? 24 THE WITNESSs Can you help me with your 25 question? - 78 - CONCANNON k JAEGER WATER PCB-SD0000072369 COMPUTER AIDED TRANSCRIPTION 1 MR. BRADLEY; Be wante to know whether, when 2 you reviewed it. it had the handwriting on it. 3 A. fee. Yes. I was shown this document, 4 including the handwriting, by Mr. Wheeler in January. *70. S C. (By Me. Bradley) All right. I'm now going $ the show you Plaintiff's Exhibit 89. which an October 23. 7 1959 letter from Elmer Wheeler to Mr. Speicher? A. Speicher, 9 Q* At Meetinghouse, and ask if you've seen that 10 document before? 11 A. I have seen this memorandum before. 12 Q. is that a true and accurate copy of the 13 October 23, 1959 letter from Mr. Wheeler to Mr. Speicher? 14 A. Ye. Again, the letterhead, signature are 15 missing. Other than that, it appears to be so. 16 Q. And was that letter authored by Mr. Wheeler at 17 or about the time he obtained the information that's IS contained in the exhibit? 19 A. Ye, sir. 29 Q. Mas that exhibitauthored by Mr.wheeler as 21 part of his regular activities and the regular business of 22 Monsanto? 23 A. Yes, sir. 24 Q. Was a copy maintainedwithin Monsanto's files 25 as part of Monsanto's regularly conducted business? - 79 - COHCANRON 6 JAEGER WATER PCB-SD0000072370 COMPUTER AIDED TRANSCRIPTION 1 A. Yes. 2 Q. I'm now going to show you Plaintiff's Exhibit 3 352. Is that a document you've soon before? 4 A. 1 have seen it before# yes# sir. $ 0. This is a letter# dated July 18# 1975 from 6 George Levinskas to Dr. Calandra with an attachment? 7 A. Yes. S Q. Is that true and accurate copy of the July 9 18th 1975 letter Dr. Levinskas sent to Dr* Calandra with 10 the attachment? 11 A. Yes. 12 Q. Is this a document that was authored at or 13 about the time that Dr. Levinskas gained the information 14 that's contained in the Exhibit? 15 A. Yes. 16 Q. is It a document that was authored as part of 17 the regular activities of Monsanto and its employee# Dr. IS Levinskas? 19 A. Yes. 20 Q. Mas a copy maintained in Monsanto's files as 21 part of Monsanto's regularly conducted business? 22 A. Yes. 23 Q. I'm going so show you Plaintiff's Exhibit 435. 24 A. X have seen thisdocumentbefore. 25 Q. is that aDecember 1# 1966 letter from D. wood * 80 - COHCANNON 6 JAEGER WATER PCB-SD0000072371 COMPUTER AIDED TRANSCRIPTION 1 to 0. Buchanon, with an attachment? 2 A. It is. 3 Q* la that a tree and accurate copy of the letter 4 from D. Mood to G. Buchanon, dated 12-1-66 with the S attachment? 6 A, Yes. ? Q. xs that a document that was authored at or e about the time that the author gained the information 9 contained in the exhibit? 10 A. Yes, air. u 0. was the exhibit prepared as part of the 12 regular business activities of the author when it was 13 written? 14 A. Yes. 15 Q* Was D. Wood a Monsanto employee in December of 16 1966? 17 MR. BAUERt Object to the form. Indefinite as 18 to which Monsanto entity. 19 C. Was D. Wood an employee of Monsanto in 20 December of 1966? 21 A. Monsanto Chemicals, Limited. 22 0* And where was that headquartered? 23 A. In London, England. 24 0. All right. And was a copy of this exhibit 25 maintained in Monsanto's files as part of its regularly - 81 - C0NCARH0N & JAEGER WATER PCB-SD0000072372 COMPUTER AIDED TRANSCRIPTION 1 conducted business? 2 A. Yes. 3 Q. I' now going to show you Plaintiff's Exhibit 4 1446# which ay# to your viewing# be two documents, it may 5 only be one. It has three pages# written by Dr. Von 6 Ottenger# dated February 28th# 1S38 on the toxicity and 7 potential dangers of Inerteen. it also has a med research 8 project number HR-46 submitted by Dr Von Ottenger# 9 entitled "The Toxicity and Potential Dangers of Inerteen,* 10 MR, MORGANt what`a the number on that again? 11 MR. BRADLEYt Pardon me. The number? It's 12 1446. 13 MR. BAUER: Mr. Bradley# would you state for 14 the record whether this was a document that was produced by 15 Monsanto? 16 MR. BRADLEY: I don't know. Do you know? 17 MR. BAUER: It bears the numbers that have 18 been used in the case by Westinghouse# for their IS production# the MPC numbers. That's why 1 asked the 20 question. These copies bear the KPC numbers. 21 A. I've glanced through the document. I do not 22 recognise it at all. I have not seen it before. 23 0. (By Mr. Bradley) All right. Prior to today# 24 have you ever heard of the name Dr. Von Ottenger? 25 A. I don't recall it. - 82 - CONCANNON 4 JAEGER WATER PCB-SD0000072373 COMPUTER AIDED TRANSCRIPTION 1 Q Did you learn during your tutorials with Elmer a wheeler or Dr* Kelly# or with any of the discussions you 3 had with any of the toxicologists at Monsanto during any 4 time you were an employee of Monsanto# that a medical 5 doctor with Meetinghouse in 1938 concluded that the contact 6 of inerteen which contains PCBs with the shin causes ? dryness of the skin# thickening and scaling and it appears 8 that sufficient quantities may he absorbed in this way to 9 cause damage of the liver? 10 MR* MORGAN* Object to the form of the li question* 12 MS. BRADLEY * Mhat's wrong with the form? 13 MR. MORGAN* Assumes fact not in evidence. I 14 don't think it#s ever been established that Dr* Von 15 Ottenger was with Mestlnghouse* 15 A. No such discussion ever took place. 17 0* (By Mr. Bradley) Well# let me ask one further 10 question then. Did you ever learn during your tutorials 19 with Dr. Kelly or Mr. Wheeler# or with any of the other 20 toxicologists# that it was concluded by Dr. Von Ottenger# 21 M.D.# in 1938 that contact of Inerteen with the skin causes 22 dryness of the akin# thickening and scaling and it appears 23 that sufficient quantities may be absorbed in this way to 24 cause damage of the liver? 25 A. No. - 83 - CONCANNON 4 JAEGER WATER PCB-SD0000072374 COMPUTER AIDED TRANSCRIPTION 1 O, were you ever informed by Dr* Kelly* Mr. 2 Wheeler or any of the other toxicologists working at 3 Monsanto that in 1938* a medical doctor whose last name Von 4 Ottenger determined that* in view of the possibility of a 5 toxic action of Inecteen on the liver* persons suffering 6 from injuries of the liver* including jaundice* syphilis ? and heart diseases* should be excluded from operations in 8 which Znerteen is handled? 9 A. No. 10 Q. were you ever informed while a Monsanto 11 employee that in 1938* Dr. Von Ottenger concluded that 12 workers handling Inerteen* or with frequent exposure to its 13 vapors* should undergo periodic examinations? 14 A. NO. 15 Q. Were you ever informed while a Monsanto 16 employee by anyone that workers handling Inerteen* or with 17 frequent exposure to its vapors* should have special IS attention paid to their nutritional condition? 19 A. NO. 20 Q. Here you ever informed that* in 1938* a Dr. 21 Von Ottenger concluded that the condition of the liver 22 should be checked by determining the Peteric index in the 23 blood and the excretions of urobilin and urobilinogen in 24 the urine for workers handling Inerteen or with frequent 25 exposure to its vapors? - 84 - CONCANNON & JAEGER WATER PCB-SD0000072375 COMPUTER AIDED TRANSCRIPTION 1 A. No. 2 MR. BAUER? Mr. Bradley, did we could take a 3 break when you're finished with this document? 4 MR. BRADLEYt All right. 5 MR. BAUERt x would appreciate it. 6 Q. (ByMr.Bradley) Mereyou everinformed wnile 7 a Monsanto employee that in March of 1938, Dr. Von S Ottenger, M.D.# Ph.C., reported on experiments carried out 9 in part by Raskel Laboratory on the subject of the toxicity 10 and potential dangers of Xnerteen and related Substances, 11 including a method of analysis for halogenated hydrocarbons 12 in air? 13 A. No. 14 0. Were you everinformed of a study that had 15 been performed in 1933 on rats by Dr. Von Ottenger and 1$ others which concluded that continued application of 17 Xnerteen to the skin of rats and humans causes dryness of 13 the skin, thickening and scaling and the observations made 19 in rats indicate that sufficient quantities may be absorbed 26 through the skin to produce injurious effects on the liver? 21 A. No. 22 Q. One or two questions relating to the document 23 and then we'll take a break. Did Monsanto ever inform its 24 customers that contact with xnerteen to the skin of humans 25 causes dryness of the skin, thickening and scaling, and - 85 - CONCANNON * JAEGER WATER PCB-SD0000072376 COMPUTER AIDED TRANSCRIPTION 1 that observations made in rat indicate that sufficient 2 quantities may he absorbed through the skin to produce 3 injurious effects on the liver? 4 MS* BAUERt Object to the form of the 5 question* tacks foundation* It* also compound# in the sense that there* more than one fact in the statement you 1 just quoted. You can answer# if you're able. @ A* I don't know of any advice of that nature 9 being submitted by Monsanto as it relate to Xnerteen. 10 0. (By Mr. Bradley) Did Monsanto submit that 11 information in regard to any of the product it blended 12 that contained PCBs a dielectric fluid? 13 MR. BAUER* Same objection. 14 A. There were product bulletin describing the 15 use of PCS in dielectric fluids that contained section 15 entitled "Safe Handling,* r "Toxicity* and the like, in 17 which information of this type would appear, and this 18 happened through the year in different bulletin, 19 Q. (By Mr. Bradley) in the 1956s, did Monsanto 20 produce any product bulletins that indicated that 21 sufficient quantities of PCBs when exposed to the human 22 skin may be absorbed through the skin to produce injurious 23 effects on the liver? 24 MR. BAUERt Objection, Lacks foundation. 25 A. 1 recall a bulletin that reported possible, - 86 CONCANNON & JAEGER WATER PCB-SD0000072377 COMPUTER AIDED TRANSCRIPTION 1 potential effects on the liver, damage to the liver, x do 2 not recall which bulletin and what pear. 3 0. (Bp Mr. Bradley) What is a product bulletin? 4 well# let me rephrase the question. What was the product 5 bulletin that contained that information? Bp that# I don't 6 mean what was the title of it, X mean what was the purpose 7 of it? 8 A. There were several types of bulletins that 8 described fire resistant dielectric fluids. Some of them 10 were worded in such a way to inform the uninitiated as to U the availability of these materials and the benefits 12 thereof and the proper wap to handle them and use them. 13 Some of them were designed with the intent, or worded with 14 the intent to help the reader who already is using the 15 materials on the proper treatment of these materials and 16 the recycling and reuse# and when is the right time to 17 dispose of them when they no longer can be with recycled. 18 Those are the two general topics that were covered in two 19 distinct types of publications. Now# through the years# 20 these publications would be revised# sort of updated# with 21 a different format perhaps and different pictures and the 22 like# but the basic messages were those two. 23 0. Well# is it fair to say that the product 24 bulletin# among other things# was a type of sales brochure? 25 A. Pee. It was one of the purposes. - 87 - CONCANNON & JAEGER WATER PCB-SD0000072378 COMPUTER AIDED TRAMSCRIPTSQM 1 Q. And you probably don't have any information 2 whether the particular product brochure that you've 3 testified to was submitted to anyone# other than a 4 prospective purchaser of the Arodors that were part of 5 that product brochure or sales brochure; is that fair to 6 say? You just don't know whether it was or was not? 7 A. That is true* I do not. 8 MR* BRADLEYi Let's take a break* (whereupon# a fifteen minute recess was taken*) 10 Q. (By Mr. Bradley) I'm now going to show you 11 Plaintiff's Exhibit 1536 and ask you to review that for me# 12 please? 13 A. 1 have glanced through the document. 14 Q* Is this a document from Elmer wheeler to w.R. 15 Richard# dated October 21# 1968 with an attachment? 16 A. It is. 17 Q* And is this a true and accurate copy of that IS letter and attachment? 19 A* It appears too be# yes# sir. 20 Q. Does the letter and attachment appear to 21 contain information that was acquired at or about the time 22 the exhibit was prepared? 23 MR. BAUERi Object to the form. 24 MR. BRADLEYs Okay. 25 MR. BAUERt Lacks foundation# specifically. - 88 CONCANNON & JAEGER WATER PCB-SD0000072379 COMPUTER AIDED TRANSCRIPTION 1 NR* BRADLEYi Would you read back the 2 question? Never Bind. 1*11 ask a new one. 3 0# (By Nr. Bradley) Was the exhibit authored at 4 or about the time that the author gained the information S that*a in the exhibit? NR. BAUERc Same objection. 7 A. It appears to be. 8 Q. (By Nr. Bradley) Was that document generated 9 as part of the regular business activities of Mr. wheeler ID when he was a Monsanto employee? 11 MR, BAUERi Object to the for. Compound, 12 since it's a memo with attachments. 13 Q. (By Mr. Bradley) Mas the memo with its 14 attachments authored by -- Excuse me. Mas the memo with 15 the attachments to it authored by Mr. Wheeler as part of 16 Mr. Wheeler* regular business activities while he was a 17 Monsanto employee? 18 A* The memorandum, yes. 19 0. And was the memorandum with its attachment 20 maintained, a copy of it maintained within Monsanto*s files 21 as part of Monsanto's regularly conducted business? 22 A. Yes. 23 0. l*m now going so show you Plaintiff*s Exhibit 24 424, which is a memorandum from W.fu Richard to B. wheeler, 25 dated September, 1969. is this a document you've seen - 89 CONCANNON 6 JAEGER WATER PCB-SD0000072380 COMPUTER AIDED TRANSCRIPTION 1 before today? 2 A. Yea# 1 have* 3 Q. la that a true and accurate copy of a nemo 4 written by ff.R. Richard to Elmer wheeler, dated September# 5 1969? 6 A. Yea# with some notes and so on. 7 Q. So the copy you had# or the copy you reviewed# 8 didn't have the handwritten notes? 9 A. That ie right. 10 Q. Absent the notes# it*a a true and accurate 11 copy? 12 A. Correct. 13 0. And is this a document that was written by 14 w.R. Richard at or about the time he gained the information 15 that's conveyed in the exhibit? 16 A* It is. 17 Q. Is this a document that was authored by Mr. 18 Richard as part of his regular business activities as an 19 employee of Monsanto? 20 A. It is. 21 0. Is this a document that was# a copy of which 22 was maintained by Monsanto as part of its regularly 23 conducted business? 24 A. Yes* 25 HR. BRADLEYt I'm going to ask the court - 90 : CONCANNON & JAEGER WATER PCB-SD0000072381 COMPUTER AIDED TRANSCRIPTIOH 1 reporter to mark this Plaintiff's Exhibit 3680. a (Whereupon# the reporter marked Plaintiff* Deposition 3 Exhibit Sumber 3006# for Identification.J 4 Q, (By Mr. Bradley) la this adocumentyou've S seen before? 6 A. I have seen this before, yes, sir. 7 Q. what is this document? 8 A* This document is a copy of portions of minutes 9 of a meeting of the Monsanto Board of Directors held on May 10 22, 1960. 11 0, And is this a true and accurate copy of the 12 portion of the minutes of the Board of Directors meeting on 13 5-2-69? 14 A. Tea. 15 Q. And was this document generated at or about 16 the time of the information that's contained in it? 17 A. Yes. 18 Q. Was it authored as part of the regular 18 business activities of Monsanto? 20 A. It was. 21 Q. Was a copy maintained in Monsanto's files as 22 part of its regularly conducted business? 23 A. yes. 24 Q. was one million# one hundred thousand dollars 25 spent for the expansion of the solid Aroclor facilities at - 91 - CONCANNON & JAEGER WATER PCB-SD0000072382 COHPOTER AIDED TRANSCRIPTION 1 the Anniston, Alabama pleat following April 15th, 1969? 2 A. Yes, 3 0, I'm now going to show you Plaintiffs Exhibit 4 1575 end ask you to review that. S A. 1 have reviewed thedocument. 4 0. What is it? 7 A. It*a a memorandum authored by Dr. Richard, 8 Monsanto, addressed to many individuals listed in the upper 8 right-hand corner within Monsanto. 10 0. what is the date of it? 11 A. The date is Nay 13th, 1969. 12 Q. is this a true and accurate copy of the memo 13 sent Nay 13th, 1969 from W.R. Richard to the people listed 14 on the exhibit? 15 A. It appears tobe, yes, sir. 16 Q. Was thatexhibit -**Excuse me. Is the 17 information contained in that exhibit -- Start all over 18 again, was that exhibit authored by W.R. Richard at or 19 about the time that he obtained the information contained 20 in the Exhibit? 21 A. Yes* 22 Q. is the exhibit -- Excuse me. Was the Exhibit 23 prepared as part of the regular business activities of w.R. 24 Richard while he was a Monsanto employee? 25 A. Yes. ~ 92 CONCANNON S. JAEGER WATER PCB-SD0000072383 COMPUTER AIDED TRANSCRIPTION 1 0. Was a copy maintained within Monsanto as pact 2 of its regularly conducted business? 3 A* Ton. 4 0. I'm now going to show you Plaintiff's Exhibit 5 421* Is that a copy of the minutes of the Corporate 6 Development Commission, dated 11-17-69? 7 A. It* a copy of a portion of their minutes. 8 Q. Is it a true and accurate copy of a portion of their minutes? 10 A. it is. 11 Q. And does thatexhibit-- Let meask it this 12 way. was that exhibit authored at or about the time the 13 information was obtained that's related in the exhibit? 14 A. Yes* 15 Q. Was that documentauthored as partof the 16 regular business activity of Monsanto? 17 A. Yes. is Q. Was a copy of it maintainedwithin Monsanto's 19 files as part of Monsanto's regularly conducted business? 20 A. Ye. 21 MR* BAUERt Mr. Bradley, let me state for the 22 record that I've just noticed that this document, which is 23 from the Stroh case, I believe, from the production 24 numbers, has a section including legal aspect that was 25 redacted for the purposes of this case. I'm going to tell - 93 - CONCANNON & JAEGER WATER PCB-SD0000072384 COMPUTER AIDED TRANSCRIPTION 1 you nov that it's com to my attention that it vae produced 2 in two different versions in thin case and the other case. 3 I* going to make an inquiry about whether there was an 4 inadvertent waiver in the previous case because I know in S this case, that section was redacted. If we're going to 6 make an assertion of inadvertent waiver* I will promptly 7 let you know. 8 MR. BRADLEY: Pine. 8 0. (By Mr. Bradley) The figures at the bottom* 10 What I'd like you to do is read for the record the first n sentence* beginning* "Monsanto's worldwide...* 12 A. "Monsanto's worldwide Aroclor business amounts 13 to a hundred and four million pounds per year. Seventy 14 million used in functional fluids and thirty-four million IS in plasticisers." 16 MR, BRADLEYs Let's go off the record for a 17 moment. 18 (Whereupon* a discussion was held between Counsel end the 19 witness* off the record.) 20 MR. BRADLEYs Off the record* we were 21 discussing the numbers followed by "M* versus numbers 22 followed by "M" with a line over it. 23 0, (By Mr. Bradley) would you describe for me 24 how Monsanto used* or what it meant when it had a number 25 followed by "W" and what it meant when it had a number - 94 CONCANNON 6 JAEGER WATER PCB-SD0000072385 COMPUTER AIDED TRANSCRIPTION 1 followed by *M* with a line over it? 2 A. The *W* designated thousands * the mM" with a 3 line over it - the n Bat# as Monsanto people used to call 4 it - represents millions. 5 0* I'm now going to show you Plaintiff*s Exhibit 6 428 and ask you to review that for me. 7 A* 1 have reviewed it. 8 0# Is that a document you've seen before? 9 A. Icfii I have. 10 Q. Is that a memorandum of March 6th, 1969 from 11 Mr. Richard to Mr. Wheeler? 12 A. Yes. 13 0. la it a true and accurate copy of the 14 memorandum of that date from Mr. Richard to Hr. Wheeler? 15 A. Yes. It lacks Dr. Richard's signature. 16 Q, All right. 17 A. But it's accurate otherwise. 18 Q. Does that exhibit contain information that was 19 gathered by the author on or about the date it was 26 authored? 21 A. It does. 22 q. And was that exhibit written by Mr. Richard as 23 part of his regular activities as a Monsanto employee? 24 A. Yes. 25 0. Was a copy of the exhibit maintained within - 95 - CONCANNON a JAEGER WATER PCB-SD0000072386 COMPUTER AIDED TRANSCRIPTION 1 Monsanto's files as part of Monsanto's regularly conducted 2 business? 3 A. ve@. 4 Q. I'a now going to show you Plaintiff's Exhibit 5 1196. 6 A* I have reviewed the document. 7 Q. Is that an October 21# 1968 letter from Elmer 8 Wheeler to Dr. Richard with en attachment authored by 9 1U sobrough? 10 A. Yes. U Q, is that a true and accurate copy of the letter 12 from Mr. Wheeler and a true and accurate copy of the 13 attachment? 14 A. it appears to be. 15 0* Was the letter frost Wheeler to Dr. Richard of 16 10-21-68 -- Let me ash it all ever again. Does that 17 letter from Mr. Wheeler to Dr. Richard contain information 18 that was gathered by Mr. Wheeler at about the time he wrote 19 the exhibit? 20 A Yes. 21 0. Did Mr.Wheeler generate that exhibit as part 22 of his regular business activities as a Monsanto employee? 23 MR. BAUERt Object to the form# to the extent 24 the question relates to the attachment as opposed to the 25 cover memo. You can answer# Mr. papageorge. * 96 - CONCAHNON & JAEGER WATER PCB-SD0000072387 COMPUTER AIDED TRANSCRIPTION 1 MR* BRADLEY: X was just referring to the t cover memo. 3 A* Yes. 4 Q. (By Mr* Bradley) All right. And was the 5 cover memo with the attachment maintained within Monsanto's 6 tiles as part of Monsanto's regularly conducted business? 7 A. Yes. 8 Q. I*a now going to show you Plaintiff's Exhibit 9 439? 10 A. I have reviewed the document* 11 0. is that a true and accurate copy of a 12 September 20th, 1955 letter from Dr. Kelly to Mr. Barrett. 13 MR. BADER Object. Backs foundation. 14 A. It appears to be. 15 Q. (By Mr. Bradley) Except for the yellow 16 highlightings? . 17 A. Correct. IS Q. Mas this exhibit authored by Dr. Kelly at or 19 about the time he gathered the information that's contained 20 in the exhibit? 21 MR. BAUER* Same objection. 22 A. Yes, 23 0. Did Dr. Kelly author this document as part of 24 hie regular business activities while a Monsanto employee? 25 MR. BADERS Same objection. 97 - CONCANNOH 6 JAEGER WATER PCB-SD0000072388 COMPUTER AIDED TRANSCRIPTION 1 A* Ye. 2 Q. (By Mr. Bradley) And we a copy of this 3 exhibit maintained in Monsanto* files a part of its 4 regularly conducted business? 5 A. Yes. 6 MR, BRADLEYt Mr, Bauer* one of the things you 7 and I need to discus is what is to be done with documents 8 authored by Dr. Kelly if you*re not going to produce bin) as 9 a witness. You requested that 1 raise issues with you in 10 advance* so X*m doing that now, 11 0. (By Mr. Bradley) I* now going to show you 12 Plaintiff*e Exhibit 1496 and ask you to review that* 13 please. 14 A. I have reviewed the document* 15 Q. I that an October 23* 1970 letter from Elmer 16 wheeler to Professor Lee? 1? A. It is. 18 Q. I that a documentyou've seenbefore today's 1 date? 20 A. I have seen it, 21 Q. Is that a true and accurate copy of the letter 22 sent from Elmer Wheeler to Professor Lee on October 23* 23 1970? 24 A. Exceptfor the missingletterhead and 25 signature, it is. - 98 CONCANNON S, JAEGER WATER PCB-SD0000072389 COMPOTEIt AIDED TRANSCRIPTION 1 Q. And was this document authored by Elmer 2 Wheeler as part of his regular business activities while a 3 Monsanto employee? 4 A* Yes, sir* S 0. And was a copy of this maintained within 6 Monsanto's files as part of Monsanto's regularly conducted 7 business? a A* It was* 9 Q* And did Elmer Wheeler author this document at 10 or about the time he obtained the information that's 11 contained in the exhibit? 12 A. Yes. 13 0* Going back for a moment to 439* Sad you seen 14 this document before today's date? 15 A. Yes. 16 Q. And is it a true and accurate copy of the 17 document you saw before today's date? 16 A. 1 thought we answered. Yes, except for the 19 highlighting* 20 Q. Okay* I'm now going to show you Plaintiff's 21 Exhibit 1257 and ask you to review that* 22 A. I have reviewed thedocument* I have never 23 seen it before* 24 Q Okay. I'm now going to show you plaintiff's 25 Exhibit 4442# which is a February 6th# 1956 - unless you - 99 - CONCANNON & JAEGER WATER PCB-SD0000072390 COMPUTER AIDED TRANSCRIPTION 1 correct me on the date - letter from Louis Spolyar 2 S-p*o~l-y-o-r H.D., Director of the Division of industrial 3 Hygiene* United States Board of Health* directed to the 4 Toxicology Department of Monsanto Chemical Company in St. 5 Louis* Missouri. A. I have read the document. I do not recognise 7 having seen it before. e 0. All right. I'm now going to show you what1 $ been marked for Identification as Plaintiff Exhibit 441 i and ask you whether you * ve seen that document before? n A. 1 have not seen this document before. 12 Q. I'm now going to show you Plaintiffs Exhibit 13 283* and ask you if you've seen that document before. 14 A. I have not seen the first page. The remaining 15 two pages are the previous document Dr. Kelly wrote to Dr, 16 Barrett in London. 17 MR. BAUERi Be didn't mean the immediately 18 preceding document. I think that's it there IS THE witness$ That*s the one. 2 Q. (By Hr. Bradley) I'm now going to ahem you 21 Plaintiffs Exhibit 292 and ask you to review that for m, 22 please. For your assistance* I'll represent to you that 23 that's not the entire document* that it is intended to show 24 the chapter relating to toxicity of that document* or 25 hazard. 100 CONCAKNON & JAEGER WATER PCB-SD0000072391 COMPUTER AIDED TRANSCRIPTION 1 MR. BAUERi It has a couple of chapters, 2 including the one you mentioned. 3 A. I have reviewed the document. 4 o. (By Mr, Bradley) Is that a document you've 5 reviewed before today? 6 A, 1 have seen it before, yes, air. 7 0. All right* And when you saw it before, you B probably saw the entire document? 3 A. Oh, yes. 10 Q. All right. Is this a true and accurate copy 11 of the portions of the April, 1955 report of E. Mather# 12 entitled "Process for the Production of Aroclora and other 13 Chemicals," relative to the chapters that are represented 14 in the exhibit? IS MR. BAUERt Well, object to the extent that 16 some of the pages are cut off. I think he can make out all 17 the words but there is some cut off because of the 18 xeroxing. I don't think that effects the contents, but go 1$ ahead and answer if you're able. 20 A. It appears to be, yet it's difficult to be 21 certain because the pages are not numbered and it's 22 difficult to determine whether there are any missing or 23 not. That doesn't mean they are missing, but it's 24 difficult to establish that. 25 Q. (By Mr, Bradley) Does it appear to you# - 101 - CONCANNON & JAEGER 1 WATER PCB-SD0000072392 COHPOTER AIDED TRANSCRIPTION 1 though/ right now, that there are pages Biasing? It 2 doesn't appear to you that there are pages Biasing. Let bo 3 ash you this. Does it appear to be a true and accurate 4 copy of those portions of that exhibit authored by Mr. 5 Mather? 6 A, Yes, it appears to be. Yes. ? Q. All right. And was this document prepared by 8 E. Mather on or about the date that he gathered the 9 information that's gathered in the exhibit? 10 A. Yes. 11 Q. Did E. Mather author that document as part of 12 his regular responsibilities as a Monsanto employee? 13 A. Be did. 14 Q. Mas a copy of that maintained within IS Monsanto's files as part of Monsanto's regularly conducted 16 business? 17 A. Yes. 18 0* This document vae written for whom? Who was 19 its intended audience? 20 A. It's intended for the technically trained 21 individuals at the producing plants. Anniston and the 22 Kru&aich plant in Illinois. 23 Q. It was not intended for any of Monsanto's 24 customers? 25 A. That is correct. - 102 CONCAMNON & JAEGER WATER PCB-SD0000072393 COMPUTER AIDED TRAMSCRIPTIOH 1 Q. I* now going to show you Plaintiff's Exhibit a 430 and ask you to review that document* 3 A. I have reviewed it. 4 0. is that a document you have seen before today? 5 A* X have* 6 0. is that a true and accurate copy of a letter 7 from Mr. Garret to Mr* Patrick* dated November 14* 1955? S A, Xt appears that the top has been eliminated. 9 Otherwise* it appears to be true and accurate. 1 0* And at the top, you would expect to see 11 something that said Monsanto* to/from, or something of that 12 nature? 13 A. Reference to Monsanto Company, yes. 14 Q, All right. Does that exhibit contain 15 information obtained by the author at or about the time the 16 exhibit was authored? 17 A. Yes. is 0, And was that exhibit prepared by Mr. Garrett 19 as part of bis regular responsibilities and activities as a 20 Monsanto employee? 21 A. Yes. 22 0, Was a copy maintained within Monsanto's files 23 as part of Monsanto's regularly conducted business? 24 A, It was. 25 0. I'm now going to show you Plaintiff'sExhibit 103 CONCAKNON & JAEGER WATER PCB-SD0000072394 COMPUTER AIDED TRANSCRIPTION 1 3011 which ie a document prepared by 3a*. Malloy entitled 2 "Standard Operating instructions for Aroclors," revised 3 July, 1964. 4 A. 1 have reviewed the document. 5 0. is this a document you've seen before? 6 A. I have seen portions of it. There are 7 portions I do not recognise in here. 8 Q. Are you able to say whether this a true and 9 accurate copy of the standard operating instructions for 10 Aroclors written by J.W. Malloy in duly of 1964? 11 MR. BAUER t Object to the form. 12 A. 1 see portions of the standard operating 13 instructions in this document. I also see some information 14 that l cannot relate to the standard operating instruction 15 document. 16 0. {By Mr. Bradley) All right. If you would, 17 please indicate for me which of the pages you recognise as ia being part of the standard operating instructions for 19 Aroclors written by J.W. Malloy in duly of *64. 20 THE WITNESSi Shall l use the large number 21 designation here to describe them? 22 MR. BRADLEY> Yea, please. 23 A. Starting with - well * the title page E# 24 followed by four zeroes* 93? 94 is a blank page? 95? 96? 25 97? 98 appears to be? 99? 100? 101? 102? 163? 104? 105? and - 104 * COHCAKNON & JAEGER WATER PCB-SD0000072395 COMPUTER AIDED TRANSCRIPTICM 1 106, X do not recognise or relate the remaining pages, a which goes from 107 through 115. 3 MR. BRADLEYi All right. May X see this for a 4 moment? 5 THE WITNESS; As being part of the original 6 document. 7 MR, BRADLEYt Off the record, 8 (Whereupon, a discussion was held between Counsel and the 9 witness, off the record.) 10 Q. (By Mr, Bradley) l* now going on show you XX Plaintiff's Exhibit 1729 and ask you to review that 12 document. 13 A, 1 have reviewed the document, 14 0, Is that a true and accurate copy of a letter 15 written November 30th, 1961 from Elmer Wheeler to Mr. Smith 16 at G.E.? 17 MR. BAUER; Objection. Lacks foundation. 18 A, It lacks the Monsanto letterhead and the 19 author's signature. Otherwise, it appears to be accurate. 20 Q. (By Mr. Bradley) I this a document that was 21 generated by Mr. Wheeler at or about the time he obtained 22 the information that's contained in the exhibit? 23 ~ A. Yes. 24 0. Is this a document that Mr. wheeler authored 25 as part of his regular business activities as a Monsanto - 105 - CONCANNON & JAEGER WATER PCB-SD0000072396 COMPUTER AIDED TRANSCRIPTION X employee? 2 A. It is* 3 0. Did Monsanto maintain a copy of this as part 4 of its regularly conducted business? 5 A. It did. 6 Q. 1*0 now goingto show you Plaintiff's Exhibit 7 395. 0 A. I have reviewed theExhibit. 9 0. Is that a document you've seen before today? 18 A. Yes# I have. n 0. Is that a true and accurate copy of the proper 12 handling of Aroclors as authored by Paul Benignus in i960? 13 MR* BADER* Object to the form, in that the 14 document is incomplete, but you can answer* 15 A* It appears to be a true and accurate copy of 16 portions of the full document. 17 Q. (By Mr. Bradley) All right. May I see it for 18 a moment? Is this a true and accurate copy of the cover It page* the index and chapter 12 of the proper handling of 20 Aroclors and their mixtures in the electrical industry 21 authored by Paul Benignus in 1960? 22 A, It is* 23 0. Did Mr* Benignus author that document at or 24 about the time he obtained the information that's obtained 25 in the exhibit? - 106 - CONCANNON & JAEGER WATER PCB-SD0000072397 COMPUTER AIDED TRAMSClIPTIOH 1 A. Yes. 2 0. Mas the exhibit prepared by Mr. Beni gnus as 3 part of his regular business activity as a Monsanto 4 employee7 5 a. yes. 6 Q. Did Monsantomaintain a copy of that document 7 as part of its regularly conducted business? 8 A. Yes. 8 (whereupon* a discussion was held between Counsel* off the 10 record.) u 0. (By Mr* Bradley) I'm now going to show you 12 Plaintiff's Exhibit 1210. Ask you to review that for m, n A. X have reviewed theexhibit. 14 Q. (By Mr. Bradley) Is that a documentyou've is seen before today? 16 A. X have seen it* or this particular exhibit 17 consists of portions of a full document 1 had seen before. 18 Q, May 1 see it please? Does this document IS contain two pages* then a table of contents* then a third 20 page* then a section entitledToxicity?* 21 A. Yes. 22 q. Okay. And is a true and accuratecopy of the 23 portions of that document that you reviewed* or excuse me* 24 that was prepared in May of *57? 25 A. Yes. - 107 - CONCANKOH * JAEGER WATER PCB-SD0000072398 COMPUTER AIDED TRANSCRIPTIOH 1 Q. was is that document? 2 A. This 1 another example of a product brochure* 3 publication. It's entitled "Arcelor, Resins and 4 Plasticizers for Chlorinated Rubber,* 5 0* Who is the Intended audience of that document? 6 A, Rubber manufacturers. 7 0. Are you able to discern who the author of the S document is? 9 A. I cannot. 10 Q. Does the information contained in the exhibit 11 contain current information regarding the topics discussed 12 in the exhibit? By "current** I mean current as of May* 13 1957, the date of the -- 14 A. Yes. 15 Q. was it Monsanto's regular business practice to 16 generate that document? 17 A. Yes, 18 0. And was a copy of that documentmaintained in 19 Monsanto's files as part of its regularly conducted 20 business? 21 A, It was, 22 Q, I*m now going to show youPlaintiff's Exhibit 23 1177* which is a document that you apparently authored* 24 dated February 2, 1972 to Dr, Posefsky and Mr* Raab. it 25 had attachments to it, * 108 - CONCANNCN t JAEGER WATER PCB-SD0000072399 COMPUTER AIDED TRANSCRIPTION 1 A. I reviewed the exhibit* 2 Q. ffhat is the exhibit? 3 A* The exhibit consists of aletter that i 4 authored addressed to Dr* Posefsky and Nr. Raab# the 5 Chairman of the Committees under ANSI 0* The subcommittees ontransformers and 7 capacitors? S A* That is correct. Attached to that letter are 9 three pages of questions and answers that I rough drafted 10 for their use. 11 Q. What was your purpose in developing the 12 questions and answers? 13 A. At a meeting held by the ANSI Committee* these 14 questions were raised and I was asked to attempt to answer 15 them* and this is my first pass attempt to answer those 16 questions. 17 Q. were the questions and answers intended to be 18 answers to potential questions from the public for users of 19 PCB dielectric fluid? 20 A. It wasn't Just -- Anybody* irrespective of 21 whether public or professional or governmental or 22 regulatory* who would raise questions of this type# and the 23 intent was to try to help whoever was being questioned to 24 give a correct answer. 25 0. And is this a true and accurate copy of the - 109 - CONCANNON & JAEGER WATER PCB-SD0000072400 COMPUTER AIDED TRANSCRIPTION 1 letter with its attachment that you authored February 2, 2 1972? 3 A. Except for the missing letterhead and 4 signature, it appears to be. 5 0. Did you generate this letter with its $ attachment as part of the regular practice of Monsanto to 7 make memorandums of that sort and letters of that sort? 8 A. Ye. 9 0. And did Monsanto maintain a copy of that 1C letter with the attachment as part of its regularly 11 conducted business? 12 A. Yes. 13 MR* BAUERs Is this a good time for our break? 14 MR. BRADLEYr Yes. 15 (Whereupon, a ten minute recess was taken.) 16 Q. (By Mr. Bradley) I'm now going to show you 17 Plaintiff's Exhibit 25 and ask you to review that. 18 A* I have reviewed the exhibit. 19 Q. Is that a document you've seen before today? 20 A. I have never eeen this. 21 Q. I'mnow going show you plaintiff's Exhibit 516 22 and ask you to review that. 23 A. 1 have glanced through this document. 24 0. Is that a document you've seen before today? 25 A. 1 have seen it in the past several weeks* - 110 - CONCAHNON JAEGER WATER PCB-SD0000072401 COMPUTER AIDED TRANSCRIPTION 1 Q, X that a true and accurate copy cf a 2 submission to the Subcommittee on Oversight Investigation 3 of the Committee on interstate and Foreign Commerce, 0,S. 4 House of Representatives by Monsanto Company, dated 5 November IS, 1979, MR. BAUER Objection. Bachs foundation, 7 A. It appears to be. a 0. (By Mr. Bradley) Do you know who authored a that document? 10 A. Mo* I don't. u 0. Do you know why it was authored? 12 A, Mo* 1 don't. 13 Q, Do you know whether that document contains 14 information that was current to whoever authored it on or 15 about November of *79? n MR. BAUERi Object to the form. 17 A. Do I personally? No. No, I don't. Since X 13 only saw this a few weeks ago* I have no background to help 19 me with it. 20 Q. (By Mr. Bradley) All right, I'm now going to 21 show you Plaintiff's Exhibit 1133* which is a February 10, 22 1971 document that appears that you authored to Mr. Lowell 23 Miller of the SPA. 24 A. I remember this letter* or a copy of this 25 letter. - Ill - CONCANNON & JAEGER WATER PCB-SD0000072402 COMPUTER AIDED TRANSCRIPTION 1 Q. Absence the yellow highlighting, is this a 2 true and accurate copy of a letter you wrote February loth, 3 1971 to Lowell Miller with the EPA? 4 A. Other than missing letterhead and signature, 5 it is. 6 0. Did you write that letter based upon 7 information contained in the letter that you had -- oh. 8 Let me start all over again. Does the exhibit contain 9 information that you obtained at or about the time you 10 authored the letter? 11 A. Yes. 12 Q. Did you write that letter as part of the 13 regular, your regular practice as a Monsanto employee? 14 A. 1 did. 15 0. And did Monsanto maintain a copy of that as 16 part of its regularly conducted business? 17 A. Yes. 18 0. You refer in here -- Well, I'm reading the 19 first sentence. *1 recently noted in the United states 20 Department of Agriculture PR Notice 70*25, dated October 21 29, 1970, that polychlorinated bipheynals must be 22 eliminated from economic poisons.* What do you mean by 23 economic poisons?* 24 A, Such things aspesticides. 25 0. Why did you refer to pesticides as an economic * 112 CONCANNON & JAEGER WATER PCB-SD0000072403 COMPUTER AIDED TRA8SCRIPTI0M 1 poison? 2 A. That's the terminology they used in that 3 notice. 4 Q. I'm now going so show you Plaintiff's Exhibit 5 1556 and ask you to review that. A. 1 have reviewed the exhibit* 7 0. le that a document you've seen before today? 8 A* 1 have. Ob-huh. 9 Q. is this a true and accurate copy of a letter* 10 dated March 3rd* 1972 from W.R. Cory* Director* Functional 11 Product Groups for Monsanto to Mr. Paul Defalco* Jr.* with 12 the United States Environmental Protection Agency* along 13 with an attachment? 14 A. Xt is* again* missing the letterhead and 15 signature. Otherwise* it appears to be a true copy. 16 Q. And does the attachment appear to be a true 17 copy of the attachment that was attached to the March 3rd* 18 1972 letter that you received? 19 A. Yes. 20 Q. And does the exhibit contain information 21 that's authored by Mr. Cory at or about the time -- Let me 22 rephrase the question. Does the exhibit contain 23 information that came to Mr. Cory on or about the date of 24 the exhibit? 25 A* Yes* - 113 - COKCAMNON ft JAEGER WATER PCB-SD0000072404 COMPUTER AIDED TRANSCRIPTION 1 Q. And was that document and the exhibit attached 2 to it authored as part of the routine# regular business 3 responsibilities of Hr. Cory as a Monsanto employee? 4 A. Ves. 5 Q* And did Monsanto maintain a copy of that entire exhibit# including the attachment# in its file as 7 part of its regularly conducted business? 3 A. Tea* Q. May I see it again# please? 10 A. Sure# 11 0. I'm looting now at page numbered NEV 012601# 12 and also numbered 711853# and it has the years I960 to 1971 13 and shows the real amounts of production of PCDs by 14 Monsanto for years 1960 to 1970 and the estimated number IS for 1971? is that correct? 16 A* It does. 17 Q. And are you familiar with thosenumbers? ia A# Tes. 19 Q. And do those appear to be accurate 20 representations of the total amount of PCBs produced in the 21 United States by Monsanto during the years represented? 22 A# Tea. 23 Q# Okay. I` now going onshow you Plaintiff's 24 Exhibit 1120# which is a three page document entitled 2$ Historical Summary of PCB Environmental Issue#* by w.B. - 114 CONCANNON 6 JAEGER WATER PCB-SD0000072405 COMPUTER AIDED TRANSCRIPTION 1 Papageorge. Is that a true and accurate copy of a document 2 you authored with that title? 3 A. It i. 4 0- When did you author that document? 5 A. 1870. 6 0. Did youauthor thatdocument hated upon 7 information that was available to you on or about the time 8 you authored the document? $ A. It was. 10 0. Did you author that document as part of the 11 regular practice of Monsanto's business* as a Monsanto 12 employee? 13 A* ye. 14 Q. And did Monsanto maintain a copy of that 15 exhibit a part of its regularly conducted business? 16 A. It did. 17 Q. I'm now going to show youPlaintiff's Exhibit 18 310 and represent to you that it is a March 38th* 1870 18 letter to you from Dr. Kelly that has both the letter* 20 itself* which is difficult to read* and a retyped version 21 with some yellow highlighting. 22 A. fes. This is similar to a previous exhibit. 23 MR. BADERt 420 24 THE WITNESS* 420. That's another copy of it. 25 MR. BRADLEYt Let me see that. - 115 * CONCANNON & JAEGER WATER PCB-SD0000072406 COMPUTER AIDED TRANSCRIPTION 1 MR. BAUER$ My notes indicate that we did 42O 2 already* 3 MR. BRADLEYt They do appear to be the same. 4 Q (By Mr. Bradley) I'm now going to show you 5 Plaintiff*a 1664 and aek you to review that document for me. 7 A. 1 have reviewed the document. Q. la that a document you've seen before today? 9 A. Yes# I have. 10 Q. la that a true and accurate copy of a May n 14th, 1970 report on a meeting with Bayer, Caffaro and 12 Prodelec, in Brussels? 13 A. Yes* 14 Q. Did the author of that exhibit write the 15 Exhibit based upon information that was available on or 16 about May 14th, 1970? 17 A, Yes. 18 Q, was that exhibit generated as part of, as part 19 of the regular business activity of Monsanto? 20 A. Yes. 21 0. And was acopy maintained withinMonsanto's 22 files as part of its regularly conducted business? 23 A. Yes. 24 Q. I'm now going to show you Plaintiff's Exhibit 25 1335, which is a letter from you to Mr. Carlington Wilburn - 11$ CONCANNON & JAEGER WATER PCB-SD0000072407 COMPUTER AIDED TRANSCRIPTION 1 in Westinghouse# July 6th# 1970 and# 1*11 show it to 2 Meetinghouse's attorney before X hand it over to you. 3 A. 1 have reviewed the document. 4 Q* Is this a true and accurate copy of a letter 5 you wrote duly 6th, 1979 to Mr. Carlingtcn Wilburn at 6 Meetinghouse? 7 A. Yes. Again# it*e missing the letterhead and 6 the signature. 9 0, And also this has highlighter and the original 10 didn*t have highligher on it? 11 A. That is true. 12 0. And did you write this exhibit based upon 13 information that came to you on or about the date of the 14 Exhibit? 15 A. Yes. Oh-huh. 16 0. And did you generate and author this document 17 as part of your regular responsibilities as a Monsanto 18 employee? 19 A. X did. 20 Q. And did Monsanto maintain a copy ofthis as 21 part of its regularly conducted business? 22 A. Yes, 23 0* I'm now going so show you a documentwhich is 24 Plaintiff's Exhibit 415# which is a July 8th# 1970 letter 25 from you to Mr. Jenkins in Massachusetts. - 117 - CONCANNON & JAEGER WATER PCB-SD0000072408 COMPUTER AIDED TRANSCRIPTION 1 A. I have reviewed the exhibit* 2 Q. Is this a true end accurate copy of e letter 3 you authored July 8th, 1970 to Mr, Jenkins? 4 A# Yes* Except that it* lacking, again, the $ letterhead end signature and there are some items that are highlighted in yellow. 7 0, All right. And does this exhibit contain a information that you gathered on or about the date of the f exhibit? 10 A* It does. u 0* Did you author the exhibit as part of your la routine business responsibilities at Monsanto, as a 13 Monsanto employee? 14 A, Yes, 15 Q, And did Monsanto maintain a copy of this 16 exhibit as part of its regularly conducted business? 17 A a VC'S 18 Q. 1* now going to shoe Plaintiff's Exhibit 19 1566, which is a letter to you dated May 16th, 1971 from S. 20 Dneno with the Mitsubishi Monsanto Chemical Company? 21 A. I have reviewed the exhibit. 22 0. Is this a true and accurate copy of the letter 23 written to you by that individual on May 18th, 1971? 24 A. It is, except for the highlighting. 25 0, And was this exhibit -- Excuse me. Does this 118 CONCAMMON & JAEGER WATER PCB-SD0000072409 COMPOTES AIDED TRANSCRIPTION 1 exhibit contain information that became available to the 2 author on or about the date of the exhibit? 3 A. it does. 4 Q. And was this exhibit prepared as part cf s. 5 Uneno's regular employment responsibilities as a Mitsubishi 6 Monsanto Chemical Company employee? 7 a. yes* 8 Q, And did Monsanto maintain a copy of this as 9 part of its regularly conduct of business? 10 A* It did, U Q, I *m now going show you Plaintiff's Exhibit 12 1542, which is a letter to you from J*R* Dueland, dated 13 July * 1971 and J*R. Durland appears to be with Mitsubishi 14 Monsanto Chemical Company* 15 A, I have reviewed the exhibit* 16 Q. Is this a true and accurate copy of a letter 17 with an attachment* dated July 8th, 1971 to you from Mr. 18 Durland with Mitsubishi Monsanto Chemical company? 19 A. The memorandum, addressed to me, appears to be 20 a true and accurate copy except for the highlighting. The 21 attachments I find pussling. I cannot relate the 22 attachments to the letter* 23 MR* BRADLEYt I'm going to ask the court 24 reporter, then, to, -- Excuse me. I'm separating this 25 exhibit and I'm asking the court reporter the mark the * 119 * CONCANNON & JAEGER WATER PCB-SD0000072410 COMPUTER AIDED TRANSCRIPTION 1 attachment as Plaintiff's Exhibit 1542A. 2 (thereupon, the reporter marked Plaintiff's Deposition 3 Exhibit Number 1542A* for identification,) 4 0. (By Mr* Bradley) Has the letter from Mr. S Durland to you based upon information that came to Mr. $ Durland on or about the date of the letter? 7 A. Yes. 8 Q, Did Mr* Durland vrite this letter as part of 9 hi regular# routine responsibilities as an employee of 1 Mitsubishi Monsanto Chemical Company? n 0* Re did* 12 A. Did Monsanto maintain a copy of this as part 13 of its regularly conducted business? 14 A. yes. IS 0* I'm now going to show you Plaintiff's Exhibit 16 1593# which is a September 13# 1971 inquiry from you to 17 w*R, Richard* 18 A, 1 reviewed the document* 19 0* la that -- Absent the highlighting# is it a 2 true and accurate copy of an inquiry you sent to tf.R. 21 Richard on or about September 13th# 1971? 22 A* it's lacking a signature# again# and it's 23 lacking a reference to being a Monsanto memorandum* 24 0. with that exception* though# it appears to be 25 a true and accurate copy? 120 - CONCANNON $ JAEGER WATER PCB-SD0000072411 COMPOTER AIDED TRANSCRIPTION 1 A. Yes. 2 Q. Ana did you -- Excase me. Does this exhibit 3 contain information that came to you on or about the date 4 of the exhibit? 5 A. ft does. 6 Q. Did you anther this document as part of your 7 regular responsibilities as a Monsanto employee? 8 A. Yes. 8 0. Did Monsantomaintain acopy ofthis as part 10 of its regular conduct of business? 11 A. ft did. 12 Q. I'm now going to shoe youPlaintiff's Exhibit 13 872# which is a letter that apparently was authored January 14 15# 1573 to Paul Benignus# who was then Chairman of the 15 Steering Committee of the C-107 Committee. 16 A. f reviewed the document* 17 Q. Is that a true and accurate copy of the letter IS you sent to Mr. Benignus on that date? IS A. Other than thehighlighting# yes. 20 G. And does thatexhibit contain information that 21 became available to you on or about the date of the 22 exhibit? A, Yes. Q. Did you author that document as part of your regular# routine business responsibilities as a Monsanto - 121 - CONCANNON & JAEGER WATER PCB-SD0000072412 COMPUTER AIDED TRANSCRIPTION i employe? 2 A. Yes, 3 0* Did Monsanto maintain a copy of that document 4 a part of it regular conduct of business? S A. e. 6 Q. Was there adifferencebetween the steering 7 committee of the C-107 and the C-107 committee? 8 A* Yet, there was* It consisted of different 9 membership* 10 Q. What was the purpose of the steering committee 11 of C-107? 12 A. To establish policy, thedirection the 13 committee was expected to take# it objectives, I guess to 14 use the word# to steer us in the right direction. 15 Q. Who else was a member of the steering n committee of the C-107 during the period 1971 to 1976? 17 NR. BAUERt By who# you mean in addition to 18 Mr* Benignus? 18 MR. BRADLEY1 Ye. 20 A. It`a been so long# I don't remember them all. 21 1 remember an individual from Maloney Electric Company as 22 being on that steering committee. I forgot his name. I 23 just don't remember the members any longer. 24 Q. (By Mr* Bradley) Do you recall whether there 25 were any members of the steering committee who were not - 122 - CONCANNON & JAEGER WATER PCB-SD0000072413 COMPUTER AIDED TRANSCRIPTION 1 employees of manufacturing companies that manufactured 2 transformers or capacitors that contained PCBs? 3 MR. BAUERi Object to the form of the question 4 because at various times Mr* Benignus was on the committee. 5 but you can answer if you're able* $ A* Other than Mr. Benignus, they were all 7 employees of companies that were members of, who B manufactured electrical equipment. 9 MR. BRADLEYt All right. 10 0. (By Mr. Bradley) What is the CEE that's 11 referred to -- Let me rephrase the question, what was the 12 CEE that's referred to in paragraph numbered three? 13 A. 1 really don't remember. 14 Q. Do you remember what any of the acronyms in 15 that paragraph refer to? 16 A. x remember 8EGRA, that's listed in Paragraph 17 Three, S-E-G-R-A, as being the equivalent in Europe of NEMA 18 in the United states. I do not recall at the moment what 19 these other acronyms refer to. 20 0. I'm now going show you Plaintiff's Exhibit 21 1585 and ask you to review that. 22 A. X have reviewed the exhibit. 23 0* Is that a document you've seen before today? 24 A* Yes, I have. 25 0. Is it a true and accurate copy of minutes of a - 123 * CONCANNON & JAEGER WATER PCB-SD0000072414 COMPUTER AIDED TRANSCRIPTION 1 seating with BPA on April 13th, 1972? 2 A. Yes, except for the highlighting. 3 0. All right. And do the minutes contain the 4 information that was generated at the meeting? 5 A. Tee. 6 0, And was it Monsantova regular practice to 7 develop minutes of meetings it held with regulatory 8 agencies? 9 A. Not in every ease hut most instances, yes. 10 0. Mas this particular document developed as part 11 of the regular business activities of Monsanto? 12 A# 13 0. And it was -- Mas a copy of it maintained 14 within Monsanto*s files as part of its regularly conducted IS business? 18 A. Yes. 17 Q. I'm going to show you Plaintiff's Exhibit 1188 18 and ask you to review that document. 19 A. I have glanced through the document. 20 0. ffhat is the document? 21 A. It's a document X prepared back in September 22 of 1971, entitled "Monsanto's PCS program," and it was 23 presented to a meeting of the ARCI Committee C-107 on 24 September 14, 1971. 25 0. X don't recall if X asked this. Is this a 124 CONCANNON & JAEGER WATER PCB-SD0000072415 COMPUTER AIDED TRANSCRIPTION 1 true ana accurate copy of the document you prepared on that 2 date? 3 A, It is. 4 Q. And did you -- Excuse me. Does that exhibit S contain information that vaa made known to you on or about 6 the date of the exhibit? 7 A. Tee* 8 0. Did you prepare that exhibit as part of the routine business responsibilities you had at Monsanto as a 10 Monsanto employee? 11 A. Ye. 12 0* Did Monsantomaintain a copy of that exhibit 13 a part of its regularly conducted business? 14 A. Yea. 15 0. I'm now going to show you Plaintiff* Exhibit 16 150, and ask you to read that document which a letter from 17 Elmer wheeler to Otis Panchor dated April # 1972. 18 A. x think wesaw thisalready. 18 MR. BRADLEY9 Did we? 20 MR. BADERt Been there and done that. 21 MR. BRADLEY < Good. 22 HR. BADERt This is one we've done before. 23 Q. (By Mr. Bradley) I'm now going to show you 24 Plaintiff's Exhibit S24 and ask you to review that, while 25 you're reviewing that. Another Versar document is 1184. 125 - CONCANNON ft JAEGER WATER PCB-SD0000072416 COMPUTER AIDED TRANSCRIPTIOK 1 MR# BAUERI Can I get a copy? 2 MR. BRADLEYt You want to borrow it and give 3 it to me tomorrow? 4 MR. BADERt x can get a copy made right now. 5 (Whereupon, a ten minute recess was taken.) 6 Q. I have glanced through the exhibit. 7 Q. (By Mr, Bradley) Xs this an exhibit you've a seen before? A. I have. ic C. What is it? n A. It's a copy of a product pamphlet or brochure 12 addressing * it's entitled, "Care and Grooming of Askarel 13 Transformer fluid.* 14 0. Can you tell from the exhibit what date it was 15 authored? 16 A. Xt*s rather difficult to read but X see back 17 on the last page, 803816, very fine print, a "54," which 18 leads me to believe it was about a 1954 edition. 19 Q. All right. And is this a true and accurate 28 copy of the document that was written in 1954 on that 21 topic? 22 A. It appears to be, yes, sir. 23 0. And was that document prepared based upon 24 information that was then available to the author? 25 A. Yes. - 126 COIICANKOK & JAEGER WATER PCB-SD0000072417 COMPUTES AIDED TRANSCRIPTION 1 Q. Ana was that document prepared as part of the 2 regular practice of Monsanto*s business activity? 3 A* Ye. 4 Q. And did Monsanto maintain a copy of that as 5 part of its regularly conducted business? 6 A. Tea* 1 Q, i* now going show you Plaintiff's Exhibit 522 8 and because of the time# this is the last set of questions 9 X have for you* If you'd review that for me# please. 10 A. 1 have reviewed the exhibit. 11 Q, What is it? 12 A. It's a copy of a product brochure entitled 13 when you want Fire Safety# Reliability* Minimum 14 Maintenance# Specify Askarei Type Transformers. 15 Q. Are you able to identify the date that 16 document was authored? 1? A. The best I can do is it appears about 1962* 18 0. Is that document authored based upon 19 information that was available in 1962? 20 A. Yes. 21 Q. And was the document generated as part of the 22 regular business activity of Monsanto? 23 A. Yes. 24 C. And was a copymaintained inMonsanto's file 25 as part of Monsanto's regularly conducted business? - 127 - CONCANNON & JAEGER : WATER PCB-SD0000072418 COMPUTER AIDED TRANSCRIPTION 1 A. It was. 2 HR. BRADLEYt It's 5s00 and we*re set to start 3 again tomorrow. So X will adjourn this until tomorrow 4 morning. 5 THE WITNESS< Thank you* 6 MR. BADERS Very good. 7 THE WITNESSs Same time tomorrow, 9t00. e HR. BRADLEYl ftOO, yes. 9 (Whereupon, the deposition was continued until 9sO0 on July 10 20, 1993.) li 12 WILLIAM B. PAPAGEORGE 13 Subscribed and sworn to before me this day of 14 ..................... ......................... ...., A.D., 19___ 15 16 17 RY COMMISSION EXPIRES* Notary Public ia 19 20 21 22 23 24 25 - 12S - CONCANNON & JAEGER WATER PCB-SD0000072419 1 STATE OF MISSOURI ) ) SS a COUNTY OF ST. LOUIS ) 3 I* John T. Concannon, a Notary Public within and for 4 the state of Missouri, duly commissioned, qualified and 5 authorised to administer oaths and to take and certify to 6 depositions* do hereby certify that pursuant to Notice in 7 the civil cause now pending and undetermined in the 8 District Court of the United States* within and for the 9 District of Nevada * entitled NEVADA POWER COMPANY, etc., et IQ al., Plaintiffs* -vs* MONSANTO COMPANY* etc., et al.* 11 Defendants* to he used in the trial of said cause in said 12 Court* I was attended at the law offices of Messrs. Busch a 13 Eppenberger, 108 North Broadway, in the City of St. Louis* 14 State of Missouri, by Ralph A. Bradley* Esq,* attorney for 15 the plaintiff; by Scott Bauer* attorney for the Defendant, 16 Monsanto Company; by Robert p. Morgan, attorney for the 17 Defendant, westinghouse Electric Corporation, and by 18 WILLIAM B. PAPA6E0RGB, the witness, in said office on July If 19, 1993. 20 The said witness, WILLIAM B, PAPAGBORGB* being of 21 sound mind and being by me first carefully examined and 22 duly cautioned and sworn to testify the truth, the whole 23 truth and nothing but the truth in the ease aforesaid* 24 thereupon testified as is shown in the foregoing 25 transcript, said testimony being by me reported in WATER PCB-SD0000072420 1 shorthand and caused to he transcribed into typewriting, 2 and that the foregoing pages correctly set out the 3 testimony of the aforementioned witness, WILLIAM B, 4 PAPAGEGRGE, together with the questions propounded by 5 counsel and the remarks and objections of counsel thereto, $ and is in all respects a full, true and complete transcript 7 of the questions propounded to and the answers given by 3 said witness; and that said testimony, so transcribed, was 9 subscribed to by the witness on the ______ day of 10 , . I, ... A* D, 1993. n l FURTHER CERTIFY that I am not of counsel nor 12 attorney for any of the parties to said suit, nor related, 13 nor interested in any of the parties or their attorneys. 14 X FURTHER CERTIFY that Deposition Exhibits that are IS marked and referred to for identification and attached to 16 and made a part of this deposition are the identical 17 exhibits referred to and identified by the witness in the IS foregoing deposition. 19 WITNESS MY BAND and Notarial Seal, given this 26 day of ................ - - A* D., 1993, at St. Louis, Missouri. 21 MY COMMISSION EXPIRES SEPTEMBER 12, 1994 22 23 JO853 T. CONCANNOM, Notary Public, within and 24 for the State of Missouri 25 WATER PCB-SD0000072421 1 2 3 August 18f 1993 4 5 Mr, william E. papageorge c/o Scott Bauer 7 Kirkland 6 Ellis 1999 Broadway i Denver# Colorado, 80202 9 Rea Nevada Power *v~ Monsanto 10 11 Dear Mr. papageorget 12 this letter# incorporated as the last page of your deposition, taken on duly 19, 1993, will serve as notice to 13 you that your testimony is now ready tor your reading and signing of same. You will recall your attorney, Mr. Bauer, 14 indicated a preference for you reading your deposition, rather than waiving signature. IS 1 am sure Mr. Bauer, or someone in his office, will 16 he in contact with you in the near future concerning the reading and signing of the transcript, 1 assume the same 17 procedure will be followed as in the past. 18 Thank you for your cooperation in this regard. IS Sincerely, 20 21 JOHN T. COMCAMNON Shorthand Reporter 22 Concannon & Jaeger 23 General Court Reporters 705 Olive Street - Ste. 604 24 St. Louis, Missouri 63101 25 JTCttad WATER PCB-SD0000072422 BCCi ?, 0- BBfftSHTJS 0, A* olsoh July 8, 1970 Xr. 7 0* Jenkins Vic# president. Sateriil* SprUgue Heotric Cortipsny Horth Ad|M| Massachusetts 0X247 r Sear to* Jenkinst X tu fortunately able to visit tout Brown St* Plant on June 17 with Eandall drahre* 2 personally found tha discussion informative and Interesting and 2 wa* float favorably impressed with the concern, and intorest expressed by your aanagwneat personnel* Ve discussed briefly cone or the point* rained In jour letter dated June 11* Z will tty in thin letter to be nor* specific. Blodcarradabilitar - Biodegradation studies conducted in our research laboratories la St* Louis. Missouri and la Ztuabon, Vales using aodla consisting or local river water* or activated sludges aoeliaatad to biphenyl give direct evidence that the lower chlorinated bipheayXs are affected. There Is soae evidence that chlorine position ea the biphenyl configuration does Influence the degree of distraction by the alaroorgsmsas* I hare enclosed a tabulation froa our IcaNin laboratory tftioh .attempt* to shoe this difference* Ve do not have foraal lafortsatlon regarding the effeet of sunlight or Other natural influence* on Aroclore* Szpcrlanee sained over aanr years indicates Arcelor* are highly stable under all known conditions present la the environment. Toxicity - ttare la ss^le evidence f^sn easy laboratories that certain spade* of birds which are at the top of the enyine food chain cannot reproduce properly fchea ^Sfa are present in their diets, fee V* 3* fished** laboratory at Oulfbreese, florlda conducted a study which Indicated that Juvenile brown shrimp did not survive in water containing 5 part* per billion of PCS* Attached are copies of reports on these studios* 14 EX. WATER PCB-SD0000072423 Monsanto baa sponsored boss attaiiea on laboratory rata ca4 does* A sizaemry of the results to data la attached* DiaBeaal - m preferred rsethod for disposal la Elga iesporature incineration. I suspect there are several ceeusrcial burner* on the aarket *ieh will perfow well* 2 personally wi&n*aed burning tuts at the John Sink Cocpany*s unit la^tulsa, COclifcoes* fe^eratare* oust exceed loCCrp to assure that cooplata destruction la achieved* tower teepex-- sturts would only vaporize the Arodera and create ataospherlo pollutioa or, worse yet, would fore, by partial oxidation, eattrials which could be highly tesds (*g. furors and dioxins)* Vith Incineration SCI la. famed Wtleh aust be scrubbed frtn the stack ass and neutralized before disposal* We ar*. planning for an Initial l&atallation In one of our plants lator tMa year* As a service to our oustoaers idio esy not have access to other Incinerators, wo have offered to accept scrap Areelor for lasodlate Stonge and eventual incineration* Tentatively, koosanto will charge 3# per pound of returned eaterlal. fids charge dees not include freight or container coots and will be reviewed tfioa final incineration coots are established* Material which is returned for disposal should be addressed to Monsanto Ceapaay, V* 0. X^uasrich Plant, Saugst, Illinois, Attentions Superv- isor Department 2bd. . dolids centaninatsd with JLrcclor* present a bigger challenge* As yet, we have not tested an incinerator with those tutorials, tintil we get sore information the best we can advise is safe burial la so authorised, properly operated land fill located awey from any " Ve have laboratory w&rk underway 00 ether forms ef destruction* as yet no conroalcally feasible approach has beta Mod* Analytical Methodology - X have attached copies of Bonssurco'o analytical procedures for the detarainatica of K9'e in wetar, sell, air and biologies! aasples* Ve are interested la ooepering our nsthed* with those devised by other laboratories* Any cooacnts your laboratory nay have would be welooeo and appreciated* ATS GG4C3 WATER PCB-SD0000072424 X hop* that tfc* abort Information lx nntful to you. Xf X.otn o of further ttrviflt, pitta* lot t lew*. Sinotrtly, Ml *r- 8. rtsru dprtfco* Eltotrlo i. JL Ortfeta Control WATER PCB-SD0000072425 5C . 11973 bee: Cunning Paton St. Louis Geo. F. FagM St. Louis re*. *rmh, Jr. >. ' '<>ii Elabr F. Wheeler St. Louis 0. L. Mollan Akron October 9, 1973 Mr. Harold Wolf. Plant Fngineor STCSTINfiHOUSE electric CORPORATION 1202 South Carlisle Street Bellefentalne, Ohio 43311 bear Mr. Wolft I an writing to you at Dave Mellon's request to cenflrn the results of your conversation on October 0, 1973, relative to the sMa irritation problems you have experienced recently with our Pydraui 312-C. Pydraui 312-C is classed as practically neu-toxie. Our neraal ex perience and testing indicates it is nan-irritating when expeeed te the skin| however, as la handling any chemical, good hygienic procedures should bo followed. In the case of skin cantact, washing with soap and water is recoaaended. In ease of eyo contact, flush ing with copious saotmts of wator is rscoundod. Given tho acuta problona you havo experienced, farther prscaueisns should bo takon. Tho uso of gloves of a si11cone-based organic solvent in soluble hand erean should bo considered to protect hands and other exposed arses. Hand ersaus of this typo are available fton: 1. Mine Safety Appliances Pittsburgh, Pa. 2. Calgan Ceumrcisl Mvisins Calgen, Inc. 7K>1 Pag* St. Louis, He. 63100 3. Sugar Boots Products Co P. 0. Bon 13B7 SaglMW, Michigan 4S605. In the event of exposure, again, tha exposed areas should bo uashod thoroughly with soap and water. WATER PCB-SD0000072426 Mr. Herold Wolfi October 9, 1973 If, despite these settees and precautions, skis irrltstios probltes persist, eertiaeee eUteest prescription should be applied to the affected ares, I would entourage you to solicit your Industrial Hygienist, Mr. M. V. Speieher, for any additional thoughts on this natter. Additionally, our nodical department is prepared to consult with you further. If you feel further discussions are warranted, plosse call Mr. Blnsr f. Wheeler at (314) 494-2194, our Manager of Cnrirennental Health, or George ftmh, Jr. M. D. at (314) 494 2111, our Associate Medical Director. I hope this enables yon te preelude future ekis irritation problems. We stead reedy te assist yen la my ueaner appropriate. I have sttaehed the OSHA Material Safety Data Sheet on fydraal 312*C far your files. Very truly yams din: ha snelf c. r. seger Selee Representative Specialty Products Group NEV 0Q64dl 705717 WATER PCB-SD0000072427 lr / April 28, 1972 Or. Otis Fanoher 624 N. Abrego Drive Oreen Valley, Arizona 85614 Dear Otlai I am ashamed that I have been;, so Blow ir* reviewing the manuaoripta and sending you our comments. I guess Sap's sending me the chronic rat and dominant lethal and mhloken study on the 18th of April finally stlxfcd me to move. First of all, Z agree we should hold up the publi cation of the chicken work until the current study Is completed. The only other comment I have of substance is that I wish we oould work In several paragraphs reviewing the Treon work on vapors published In 1956 (see en closed xerox copy of reprint). A logical place for a review of those data would be at the top of the 3rd page of your review paper, before your paragraph at the top which begins with "During succeeding years little information waa reported oonoeanlng the toxicblpgy of the__TCB~antil McLaughlin etal, 1963, etc." Most of the review articles on the FCB's have failed to indicate awareness of the Treon work. Z believe this is because the Rlsebroughs, Peaks11s, etc., ete. >the environmentalists -- have not encountered the American industrial Hygiene Association Quarterly in the review of the literature nor la it likely that they ever heard of the AZHA. In any case, Z think the work Is worthy of review even though it was inhalation data particularly since Drinker's earlier work In *37 la frequently mentioned and this again concerned inhalation. In the last paragraph of this same review paper you NEV 00856J 707815 WATER PCB-SD0000072428 Dr. Otis Fancher April 28, 1972 Page - 2 - refer to the "permissable ambient concentrations of PCB*811 as suggested by Drinker in 1939. Actually the ACOIH established the Threshold Limit Values based on Treon'B work rather than the earlier Drinker work. I believe we may have arrived at our high dietary level of 100 ppm in the studies done at Bio-Test based on the Treon work rather than Drinker*s. George Lsvinsksas is reviewing each of the papers to see if you, Map and I have missed typo's and he may well suggest some grammatical changes which we will enter on our copy and send xerox's to you and Kep. I hope to get copies of all of the studies in the hands of Bill Papageorge, Scott Tucker and the lawyers next week. X do not anticipate a lot of changes from them and hope that the attorneys agree that we can go ahead with publication. Best personal regards. Sincerely, EPW/bks cc: M. L. Keplinger Elmer P. Wheeler Mgr., Environmental Health Medical Department NEV 006564 707816 WATER PCB-SD0000072429 TX H. Bergen from WBP February 3, 1STt 1 Griffith B. Quinby, M. D. Consulting Toxicologist Preventive Medicine Post Office Box 3313 Wenatchee, Washington 98801 . Dear Dr. Quinby* Thank you for your letter of January 20, which arrived on the 27th, at v/hich time I was out of town and Just returned. I appreciate very much your interest in the polychlor inated biphenyls and am happy to reply serially to the questions raised in your letter concerning the "Monsanto Statement on PCB" printed in Environment, Vol. 12, No. 1. May I preface my answers with the comment that we take no responsibility for Dr. Risebrough^ statements in tho publication and I am assuming that your questions relate to tho Monsanto statement published therewith. Now, as to your questions* 1. The Monsanto statement supplied Environment Magazine was prepared with my collaboration and approval. iMy^interest in the toxicity of and occupational ^M^airdbvinvolved with the polychlorinated bi- phenylsand tcrphenyls dates back to 1938. I ricairVlvidly the first meeting held at Harvard under the sponsorship of Dr. Cecil Drinker to discuss the early results of research carried on under hia direction on the chloi'lnated biphenyls N6V 0211d4 729239 WATER PCB-SD0000072430 Griffith E. Quinby, M. D, February 3, 1971 Page Two and chlorinated napthalenes ^Tef, J. Ind. Hyg, Toxicol, 19* 300 (1937.17* You nuiy be Bure that the Medical Department at Monsanto has been aware of all subsequent publication!! relating to the toxicity of chlorinated biphenyls and terphenyla. The literature indicates that there was a number of incidents of industrial effects in the late 1930*a from the use of a waxy material composed of chlorinated napthalenes, chlorinated biphenyls and chlorinated diphenyl ether. I submit, however, that there have been few Instances reported since 1940 concerning ill effects in workers exposed to the chlorinated biphenyls or chlorinated terphenyls when used alone. In -;he rare cases that have been reported, the recommended procedures for safe handling and usage have been ignored. 2. Monsanto has been aware that in the early and mid1950'a there was some use of PCB's as extenders for pesticides where the formulations were applied to field crops, or, in the case of research sponsored in New York State not participated in by Monsanto, on forests for attempted control of elm tree disease. These experiments were based on research efforts of the USDA. As far as our records indi-. cate these were abortive attempts in using the PCB's in "broadcast applications" on perhaps all kinds of crops. The facts aB wc know them are that uses never did develop where the FCB'b wore incorporated in formulations for "broadcast appli cations" to agricultural crops such as vegetables, animal feed, cotton, citrus, etc. I don't have exact figures but I would estimate that something less than 100,000 pounds of PCD's were ever used in experimental or Beml-commercial applications. To me and to our company this does not represent "broadcast application" as the torm is generally used now and as it relates to the application of most common agricultural insecticides. 3. Moat cf the possible uses of PCB's recommended as possibilities in our Technical Bulletin O/PL-306 remained as possibilities. It is true that PCB's were used in specialty (industrial, corrosive resistant) paints; in specialty rubber for sealants (not automobile tireB as has teen alleged); in specialty adhesives for many purposes. They v/ere not widely used in lubricants or cutting oils. I don't know what is meant by "carburator fluids". . 729240 WATER PCB-SD0000072431 0 2 1 id5 < W. B. PAPAG-EORGE ""x October* 26, 1970 . / J. R. Savage r H. S. Eergen V. R. Richard R. E. Keller E. P. Wheeler Recent data from Or. J. ?. Hicure* a worte-indlcates the presence of naphthalene In Mphenyl~andt'' . anthracene or phenanthrene and/mbenzoftagn-ln Santovaz R used In the manufacture of Aroclors. She naphthalene, anthracene or phenanthrene could be present in the benzene used In the diphenyl unit or could be co-produced with the biphenyl, terpheayl and quaterphenyl. The difcenzofuran could result from oxygen contain ing contaminants In the benzene or, oaore likely, be formed because of the presence of the promoter, acetone. The Anniston Plant should design and execute a program for determining the source or sources of these contaminants. V. B. PAPAG50RGS 94)3b - 1* 18 uCe 7 1 j Cy WATER PCB-SD0000072432 May 25, 1970 Otis E. Fineher, Ph.D. Director Industrial Bio-Test Laboratories, Inc. 1810 Frontage Road Northbrook, Illinois 60062 Dear Otis: This letter will authorize you to proceed with a study with the leghorn chickens with the Aroclor 1242, lot number AL-55 This should duplicate the study you did previously with Aroclor 1242, lot number AK-255, except in this instance you have suggested using dietary levels of 2, 4, and 8 ppm. This sample of Aroclor represents our current regu lar production which Involves some clean-up insti tuted since the previous sample was made available to you. Ve would hope that we might find a higher "no effect" level with this sample as compared to the previous work* As soon as suitable reference standards are available, the research laboratory in St. Louis will more care fully characterize the two samples in tents of possi ble minute amounts of contaminants. Best personal regards. Sincerely, EPV:Ju liner P. Wheeler Manager, Environmental Health &4cf(0 STR 022006 WATER PCB-SD0000072433 April 8, 1970 Herbert Blumenthal* Ph.D. Chief* Petitions Rsvisw Branch Bureau of Poods* Psstioidss and Produot Safety 0. S Food and Drug Administration 200 C Street* Southwest Washington* D. c. 20204 Dear Uerbi Confirming our telephone conversation Z have enolosed Xerox oopies of the status reports for the chronic toxicity studies for our Aroolors st Industrial Bio Test* Xnc* Specifically, three of our polychlorinated biphenyls are under investigation* These are Aroolors 1242 biphenyl chlorinated to the extent of 42Jf)* 1234 !biphenyl chlorinated to the extent of 5450* and 1260 biphenyl chlorinated to the extent of 60jf) Studies Include two year oral administration to rats* two year orsl feeding to dogs and a three generation rat reproduction study* As indicated in the enclosures* the levels of admin istration are 1* 10 and 100 ppai for each of the com pounds* Further* the status reports for the chronlo dog studies represent data at the end of nine months* The enclosed copies on the rat studies show data ap the end of six months administration* As we mentioned on the telephone* we added 300 rats to the chronic studies after the original two year projeot had gotten underway to allow a sufficient niaaber of animals for sacrifices at three* six and twelve months* Hlstopfcthology has been completed on the sacrificed animals and hr* Calandrs has reported verbally that there are no positive pathological findings* WATER PCB-SD0000072434 Dr. Herbert Blunenthal April 8, 1970 Pag* Two The rat reproduotion studies ere into the seoood gener ation. At this point Dr. Calsndrs has indicated that there definitely has been no effect with any of the compounds at the 10 ppm dietary level. There is some equivocal posaible effect in the animals at the 100 ppm level with Aroclor 1254. If you have any specific questions after reviewing the enoloeed status summaries, please feel free to call Dr. Calandre or Dr. Pancher directly. Best personal regards. Sincerely. R. Barnet Kelly. N. D. Medical Director REKiJu c.o. Dr. Joseph C. Calsndrs Dr. Otis X. Pancher b.c. V. B. Papageorge* 0. w. Ingle Enclosures NEV Ol***31 7134R3 WATER PCB-SD0000072435 April 8r 1970 Dr. Herbert Dlumenthe1 Chief, Petitions Review Branch Bureau of Poods, Pesticides and Product Safety U. S. Food and Drug Administration 200 C Street, Southwest Washington, D. C. 20204 Dear Herbt I thought you would be interested in knowing that Monsanto is committed to a program which will allow the future use of our Aroclors only in those applications where escape to the environ ment can be prevented. Secondly, we have essentially a crash program under way to- find non-persistent, non-chlorinated substitute products. Already, we have two large users switching to substitutes of this type. Obviously, Herb, you can recognize the competitive aspects of developing and phasing into sales such type of substitutes so, at present, we are not making any widespread announcement. On the other hand, if the publicity gets as red hot as it did in the case of DDT, we may be forced to make such an announce ment at any time. Cordially, HEX/In R. Emmet Kelly, M. D. Medical Director 713484 WATER PCB-SD0000072436 Iter-anto no ibaArtMi St. LOUiS * H. S. Bergen - K22?.C H. L. Minckler - KMi:.*c P. S. Park - PPARK J. E. Sprincgate - JSPP.I TO * W. B. Paraageorge WPAPA We have been in cocminication with a Or. Hill of the Ohio Statn Board of Health. Ha has. foond PCS, particularly Aroclor 1254, in samples of milk from at least three herds in Ohio. He has traced this contamination back to silage fjorc three different silcs. : Or. Hill reported concentrations -of 0.2 ppm of PCB in the silage in the center of the silo and up to 20 ppm in the material next to the walls. He also stated that concentrations in the milk were between 0.1 pen and 0.6 ppm and that some of the milk had been destroyed." The silos are concrete silos whose interior surfaces were painted in 1967 using a formulation that contained 1254. I don't know if there was any other Aroclor in tits formulation nor do we know the coating manufacturer; although, this could be found out if important. Tha presence of PCS'in tha siltee came from flaking off of the material and oossibly from ' leaching out during the silage storaes. At present they will have to destroy about 150 tone of silage which is-valued at ahout 520 per ton. As a rough guess, they consider there iray be 50 other silos involved in Ohio that were painted with tis sait* formulation. They are also looking into the fat con tamination of the cows themselves. All in all, this could bo quite a serious problem, having legal and publicity overtones. - " This brings us to a very serious point. When are we going to tell our customers not to use any Aroclor in any paitt formulation that contacts food, feed, or water for animals cr humans? X tbiak.it is very important that this he dc::a. Ic may be that sore of tha easterners will assure themselves on the basis of aon-estraetabilitv that a particular formulatier, might be safe but X think we should make a blanket recom mendation against these uses. REK/ln / C. w P R. Emmet Kelly, M. D. IN* K. R(V. I*M WATER PCB-SD0000072437 Monsanto Mem ants Company BOO N. Lindbergh Boulevard St. Louie. Mltaouri B318S Phono: (314) BB4-I000 SUMMARY--INTERIM STATUS CHRONIC TOXICITY WITH AROCLORS In May and June of 1969* two year feeding studies were Initiated with Aroclors 1242, 125*1 and 1260. The materials are being fed to rats and dogs at levels of 1, 10 and 100 parts per million In the diet. After 11 months there have been no clinical effects observed In the rats In the Aroclor 1242 study. Animals sacrificed at six months showed negative micropathology. There have been no clini cal effects In the dogs and blood and urine chemistry studies at the one, three and bIx month Intervals were negative. In the case of Aroclor 1254, rats have shown a slightly depressed weight gain at 100 ppm. In the animals sacrificed at six months,there was slight Increased liver weights In males of the animals on the 100 ppm diet. Micropathology was negative at all levels. In the dogs then have been depressed weight gains In the females at all levels fed and at the 100 ppm level In themales. Blood and urine chemistry has been negative. Vlth Aroclor 1260 there has been no effect on weight gain but has been Increased liver weights In males at 10 and 100 ppm In the animals sacrificed at six months. Micropathology Is negative. In the dogs there has been depressed weight gains In the females at 10 and 100 ppm and In the males at 100 ppm. Blood and urine chemistry has been negative. The above data Indicate that these materials are about the same order of toxicity as BBT In rats and dogs. This Is reassuring In that BDT Is probably the least toxic Insecticide to mammalian species. Further, there Is general agreement that BBT has not presented a hazard In animals or man In spite of Its presence In the environment. Interim or progress reports such as above have been provided periodically to the U. S. Food and Drug Administration, the U. S. Bepartment of Agriculture and other governmental agencies. In addition, the data and the progress of the studies have been discussed candidly with Dr. Edward J. Burger, Jr., In the Office of Science and Technology, Executive Office of the President. PLAINTIFF'S EXHIBIT -m I I l ADM 005984 . ^3517 WATER PCB-SD0000072438 ADM 0 0 5 9 o 5 SUMMARY--INTERIM STATUS OF CHRONIC TOXICITY STUDIES 2 year chronic--rats at 1, 10, 100 ppm In diet Status--9 months Status--6 months sacrl flee Including micro pathology Aroclor 124g No effect clinically No effect clinically 2 year chronic--dogs at 1, 10j 100 ppm In diet Status--10 months No effect clinically Status--6 months Including blood ft urine chem. Negative Aroclor 1254 Lowered weight gain at 100 ppm Increased liver wt. In males at 100 ppm Negative path ology--all levels Lowered wt. gains* all females at 1, 10 ft 100 ppm Lowered wt. gains maleB at 100 ppm Negative * Sea report for details relative to "Mortality" . ** See report for details relative to "Mortality" and "Blood Chemistry" i <I Aroclor 1260 No effect (see below) Increased liver wt. In males at 10 ft 100 ppm Negative path ology--all levels Lowered wt. gains** females at 10 and 100 ppm Lowered wt. gains at 100 ppm Negative** <s WATER PCB-SD0000072439 ANIMAL LONG TERM STUDIES INTERIM STATUS 2-year rat chronic At 1, 10, 100 ppm Status-9 months 2-year dog chronic Status--9 months 1242 1254 1260 100 ppm Poss. liver enlargement Males 10 ppm O.K. 100 ppm Poss. Liver enlargement Males 16 ppm O.K. 100 ppm Poss; liver enlargement M&F 10 ppm O.K. 100 ppm O.K. 100 ppm Body wt. dec. 10 ppm O.K. 1M-1F died-- cause unrelated to exp't 100 ppm 1M-1F died refused foodno other gross abn. 10 ppm possible body wt. effect 5c 1 jo"Ks-ks A 4- -ra Qo Pus F1 o A/\ <2oJ n \ ADM 005986 WATER PCB-SD0000072440 animal long term studies ' interim status \ 2-year rat chronic At 1, 10, 100 ppm Status-9 months 4 2-year dog chronic Status--9 months 1242 . 1254 100 ppm Poss. liver enlargement Males 10 ppm O.K. 100 ppm Poss. Liver enlargement Males Id ppm O.Kw \ 100 ppm Poss. liver enlargement M&P id ppm O.K. 100 ppm O.K. ^. 100 ppm Body wt. dec. id ppm O.K. 1M-1F died-- cease unrelated to exp't 100 ppm 1M-1P died refused food-- no other gross abn. 10"ppm possible body wt. effect AQM 005967 > WATER PCB-SD0000072441 ADM 0 0 5 9 8 d AHOCLOR TOXICITY DATA Page 1 Toxicity Data Coat 1 fiave Need Date Bealn End Have ' Need AHOCLOR Date Date BexIn End Have Need Bealn End Have Date Need Bealn End Acute Rat-LD5o Rabbita-MLD (dermal) ' Skin Irr. ; (rabbit) ! %!> $, 200 tt! 290 100 X $ (200)* 11/15 12/ X (250)* 190 70 31 191(0 100 0 0 125 125 M 0 Vapor Inhala tion (Rats) -.'Fish (2 apaolaa) i 200 600 200 M 0 600 0 0 $ 200 11/15 12/ X $ 250 l9P 31 *7II 0 X 100 n 0 X 11/19 12/ l9p 31 *J0 n0 X $ (200)* ll/l! . 12/ X (250) in 31 1 100 0 n 125 0 0 X 200 0 0 00 00 _ 600 00 600 0 0 125 0 n1 1:f 0 i! i 600 0 i : Sub-acute 90-day rat * 1 90-day dag Fish (30-^0 day) T1 RRpaUfpMTr,orr' a**r*.*.' .1 , Chiokahu 6.000 10.000 3.000 (t) 17,000 8.000 6,000 10,000 3.000 1/2/71 6/1 0T % Defer Defer 6,000 1/2/71 6/1 10,000 0 l1 3,000 Defer Defer 6,000 1/2/71 6/1 10,000 0 '701 3.000 Defer Defer 6.000 1/2 6A 'I1 n 10.000 3,000 .,1... ** Defer T6P8tOlOiy RabVlta ! TOTAL* ' 1 ; NEED NOWi . DEFERRED! . *.500 rorr 1. , Defer $20, *175 $29,500 Defer $20,475 $29,500 Defer $19,600 $29,500 *'i i \ i * v*1**4. <} : Defer $20,275 $29,500 -- : ...... ** Control group aoat $2,100 :i , ** *' * -'i i -- j- - i -- ------- WATER PCB-SD0000072442 Toxicity Data COBt AROCLOR TOXICITY DATA AROCLOR 125ftAROCLOR 5ft6Q_______________ 1 Have Need Date . Benin End Hava Need Date Begin End Have Page 2 HB-ftO ___________ Wire Date Date Need Begin End Have Need Bogln End Acute Rat-LD^o Rafcblte-HLD (dermal)* .Skin Irr. ( (rabbit) lEye Irr. (rabbit) !;Vapor Inhalftlon (Rata) linh ji (2 apeclea) teub-ocute jOO-day raft ** 90-day dqg I Pish 's [ (30-90 day) % 200 X 250 X 100 X 125 * 200 X J 600 X 6,000 10,000 I*000. (eaftj $ 3.000 X X. X XXX X X1 X X X $ 600 12/15 1/3 1970 '71 X X $ 600# 12/15 1/31 1970 *71 6,000# 11/2/71 a/i! '71 i 1 i $ 600# 1/11 1970 71 6,000^ 11/2 2/15 70 7l : , ; | istcsetiictmi 'Rata ----- 17.000 X Defer ' .CHlokens f Teratology * Rabbita" . .. THTC---------- -- HIKED NOW: |DEFERREtfi' 8,000 X $.500 TO97T $.500 $ 7,500 * (Repeat) control troAp coat $2*100 , # Already paid i X 11/15 2/1! 1770 71 Defer ft 600 21,500 $ 6,600# ! 1 i 6,6oqf 1 i AOM 0 0 5 9 8 9 0 in 0 0 X. a < ` WATER PCB-SD0000072443 005990 Toxicity Data Cost i Have Need AROCLOR TOXICITY DATA Mono-Chioro JJ`Bate----- ' bate Begin End Hava Need Begin End Have rage J Mono-Bromo AROCLOR 6062 Date Need Begin End Have Need Begin End i/lcute |'ftat-LD50 jiRabbl ta-MLO rl (dermal) ;3kln Irr. J (rabbit) $ 200 250 100 $ 200 3rd 1st 250 |tra. *71 qtr. '7tt 2 \ 100 t n $ 200 3rd 1st 250 Itr.It *71 qtr 7tt 2 100 n II $ 200 3rd lat X 250 Itnn *7 qtr. 'l2 X 100 It m X Eye Irr. i (rabbit) 125 125 n it 125 n H 109 tl X :Vapor Inhali|f tlon (flats) 200 200 t m 200 1 n II 200 N m* Uriah (J (2 apaolea) K ` * &ub-scute j^'W-day rat ** !l 90-day bog ' *Flah ?1 . (30-90. day) fllaproduofclbn ,jHata . 1* |j Chickens _ 600 6,000 10,000 J.OOO 17.000 B,000 600 6,000 10,000 3.000 n m H n Defer Defer m n m n 6oo 6,ooo 10,000 3.000 n w ti It 0 n 0 Defer Defer 600 6,000 10,000 3.000 tt wM nN tt m Defer Defer >* ll'eratolonr fHiTLlti *.500 Defer TOTAL:-------------- TOT WEED NOWt . 20,*75 DEFERRED! $29,500 ** (Repeaitt) * Control group cost $2,100 Defer $20,*75 $29,500 Defer $20,*75 $29,500 . r t. `tJT- * Tf QX WATER PCB-SD0000072444 IbbbO O wov Textcity Data Acute *Hat-LD50 '{Rabbi te-MLD '* (dermal) [skin Irr. . (rabbit) 4Eye Irr. '' (rabbit) i'Vapor Inhalatlon (Rata) Cost AROCLOR TOXICITY DATA 2,2 Prime Dlchloro Bromo-Chlorobenzene Date Date Have Need Begin End Have Need Begin End Have $ 200 250 loo 125 200 $ 200 3rd 1st 250 Itr.M 'T1 qtr. .72 R 100 m n 125 it 200 n R $ 200 3rd let 250 qtnIt '71 qtr. 7(1 2 100 ft R 125 R R 200 R If Need [| (2 a&lclea) 600 6p0 'ub-ocute | 9^-day rat ** 1 [90-day dag 6,000 10,000 6,000 10,000 PI ah (30-90 day) leoroduotlon | Rata. k Chickens -erotology Rabbits * 17.600 8,000 4.500 3,000 ; Defer , Defer Defer TTFiri-------------IEED HOWl DEFERRED: $20, *75 $29,500 i* lRepeat) >* Control group dost $2,100 RR R II n II 600 fl 6,000 10,000 3,000 R t> If R t Defer Defer ' Defer *20,475 $29,500 '' t. Page A bate Date Have Heed Degin End WATER PCB-SD0000072445 IIPwlclty Data Cost AROCLOR TOXICITY STUDIES--INDUSTRIAL BIO-TEST LABORATORIES l------- --A-R--O--C--L-O--R--- 1---22 1Date ""I--:----- MCS 1016--kDtacte:------ 1-------- A-R--O--C--L-O--R--- 5*432Date-------- 1--------A-R--O--C--L-O--R--*5--44K2Date BTL Number Benin End BTL Number Benin End BTL Number Benin End BTL Number Benin End iffcute rRat-LDjQ Rabblta-KID (dermal) .'Skin Irr. ! (rabbit) \ iEye Irr. (rabbit) ' 6 200 250 ji 100 < 1 125 'vapor Inhalaj tion (Rata) ;200 . * *f I* ./ `J * jPlah . 6oo | (2 apeoiaa) 3ub-acute 90-day rat*. 6*600 ,90-day dog). [piati j (30-00 day) leproduotlon ' .Rata . j 10,000 : t: ` * 17,000 Defer 'Chlokana ' h . ,, Teratology rRaEblta* ; . 8,000 Defer 1,000 Defer i f-- 626.600 i *1 Defer Defer Defer - Defer Defer Defer 1 1. l, i 1 ! Defer Defer Defer 'WjVi i tj ^control tyotiy eoat 62,100 It . *` D-; Q05992 "QC * WATER PCB-SD0000072446 November 9 1970 Mr. Keith Kelly ' Manager of Purchasing Power. Systems '% ^7ectinghous<pElectric Corporation ' ' Bloomington, Indiana 47401 Bear Keith: * At our meeting In St. Louis on 30 October you asked that Monsanto clarify several items relative to the Aroclor 1242 calcs contract between our recpcctlvo companies. First, I want to confirm that our exietlng contract, by this letter, io expanded to Include Aroclor 1232*. We request that Kestinghouca use the same precautions that you now do with Aroclor 1242 to prevent the product from entering into the eivi YOXltiOTlt through spills, leakage, disposal, vaporization or otherwise. Only those applications where tho product can be totally contained should bo considered. At your convenience I would like Wc3tinghouso*a estimated requirements through June 1973. The second item is the contract termination clauce. Originally the clause was added to tho contract to protect against tho unknown. At the time, Monsanto did not know if the industry, in their use of the Aroclors, could and would be willing to "close the system" and prevent the products from entering into the environment. We did not know whether Monsanto could "close the system" within our own production facilities. Both the electrical industry and Monsanto have made considerable progress In the last six months. Monsanto management is committed to continuing the supply of this product to the electrical Industry as long as nil customers continue to take the action necessary to prevent the Aroelors from entering into the environment and until a suitable alternate product is available. This is now the intent of tho termination clause. Monsanto will terminate an agreement with a given customer if tho *changed - original letter stated 1254. 11/30/70 ^UUNTIFFSI I |d EXHIBIT I \\W nEV 006310 705546 WATER PCB-SD0000072447 Mr. Keith Kelly Westinghouse Electric Corporation November 9, 1970 lnduatryin'gencral^r that Gpecific customer does not adequately prevent the product from entering the environment. Monsanto nay terminate the agreement If a suitable substitute product becomes available. I hope this adequately covers your company*s concern of Monsanto's Aroclor plans for the future. As I said in the St. Louis meeting, it is very important that we open up the communications between our companies respective managements, tfe should proceed with arrangements for a meeting in St. Louis in the near future. Very truly yours. /iso bes H. S. Bergen W. B. Fapageorge P. G. Benignus G. R. Graham ` T. L. Qoesage Director of Sales Functional Fluids * . .. 0063ll 705547 WATER PCB-SD0000072448 Moxsanto Chemical Company St. Loins 4. Msssocxx July 25, 1956 Mr. E. V. Speicher, Administrator Industrial Hygiene * Westlnghouse Electric Corporation East Pittsburgh, Pennsylvania Lear Mr. Speicher: Shank you for your letter of July 19 requesting toxicity infor- ' nation on several of our Aroclora and atmospheric sampling . methods. * I am sending under separate cover two detailed reports published * by personnel at the Kettering Laboratories entitled, "She Toxicity of the Vapors of Aroclors 1242 and 1254." The data contained herein were condensed and presented by ib. Treon at the AIHA meeting in Philadelphia this year. It was published in the form presented In the June, 1956 issue of the "AIHA Quarterly," a copy of which I am sure you must have. I am asking Dr. Treon, .by a copy of this letter, to send you a reprint of his publication if such is available at the present time. You will note that Lr. Treon has proposed'that the hygienic stan dard for Aroclor 1242 be tentatively established at 2 milligrams per cubic meter and that the standard for 1254 be sstflfilldhBU at 1 milligram*per cubic meter. I am sorry that we do not have similar data on Arocior xaou. However, we have no particular reason to expect that a bO Per cent chlorinated biphenyl offers any greater hazard than a 54 per cent chlorinated biphenyl. * You will note further that Dr. Treon*a work discusses a modified Willson hydrocarbon apparatus used In the-sampling of his test atmospheres. In a limited amount of sampling in our own plants we have used the Willson equipment as shipped to us. I have en closed a description of the operating procedure prepared by one of our research groups which is somewhat more detailed than that provided with the instrument. You have previously seen our complete reports on the decomposition o.f Pvdraul when allowed to drip or flow onto a heated metal Inconel surface. The data in those reports have convinced us that there is no greater acute hazard should Pydraul accidentally contact metals > at the temperatures investigated than there would be with other Industrial hydraulic fluids. I do not have any* data to support any conclusions as to what might occur if the Pydraul were to be used WATER PCB-SD0000072449  I Mr. H. W. Speicher, Administrator -- Page 2 -- July 25# 1956 ms a hydraulic fluid in aatetng magnesium die castings. Ve .do have a report that one planTTShdiing large quantities of molten magnesium purposely sprayed Pydraul into .the molten material primarily to see If there would be a great deal of . spattering of the magnesium. She company reported to us that their tests convinced *them that Pydraul could be used. Whether or not they are using* Pydraul, I cannot say. *\ . * Z notd in rereading youf letter that Z have net answered your ' f. question relative to akin effects following Arodor contact.' s&L.We recommend that repeated and prolonged akin contact with any JToi one Arociors oe avoidea. We nave patch tescea several. or them wiLR'negaciVA results. 2n addition, reported cases of . . fskin irritation have been surprisingly few in view of the heavy /tonnage quantities of Arodor'manufactured and handled in the % I last twenty years. * -Ve believe, however, that care in *"g' | and good persond hygiene is necessary to avoid irritation. As with many chlorinated hydrocarbons, exposure to' sufficient * quantities over a long enough period of time could conceivably result in'chloraene.- Zn this respect, however, the Arociors are notithe potent chloracenegens. such as chlorinated naphtha lenes^ To our knowledge, there have never beefi any cased' 61' chloraene in the electrical industry1* use of these products. Zf Z can be of any further assistance, please let me losow. ^ * Very truly yours. EPW:SM3 Enclosure . cc Dr. Joseph F. Treon ' The Kettering Laboratory Mr. Paul G. Benignus Monsanto . sr P. Wheeler Assistant Director Medical Department 906236 BBRN003397 r WATER PCB-SD0000072450 0*t<*wy 23, 1959 lb*. B. Wilbur Speieho? JUtelrl otrataar, Xoduatrial Hrslane beatlnglvouao Sleatri Corporation Bart fittatourgh, Pennsylvania . Baas* HUburi /ou f your lattor of Oetobar 21 inquiring about tha aafa un of triahloredipbanyl and a mixture of 40* triahloro- C_________ __* f U -- .Wt * -* W O tta phyalaal and aheniaal proptrtiM of the Jbrotlcn sectioned 87 shma ca tho table on pages 4 and 3 of the eneloeed Aroelar bulletin. Baalooed also la a raprint Inrileasing the results of ehrcnia toslalty studio# with Arooloro^M' and 1254. Dm follewlng loatoti answering your question* aerially aro baaed on lafocwatlan aentalned in these bulletins, Z bellere prolonged and repeated skin oontaat with any of the Aroelera should bo aToldod for two reasons. Zn tha first laM, the looa hlarineted parodutta aro liquids and ara axsel- JbH solvents for ails and fata In the akin aa well aa other organls --Serials* fesondly. It la possible that prolonged or repeated akin eonteat aould land to ehlor--* I taew of only tvo tmaofr Mmto suefc experisooe baa developed during the long history of preduetlOB and uaa of tha Aroalors* Zn ana ease, an Aroalor was being uaad aa a boat tranafar --dim in a cyst-- that niliTil vapera to oaaapa when tha --tarlal --a haatod to 600?* Several aortaan developed "blaeJd&eadB* --ieh --ro found by an Industrial phyaieian but ahlsh in his words ware aa inlgalflsant that Mm aao ware not awara of theas oar would a general pcaasitiaosr notloo than* Zhia indlsmtea to -- howrror. CfifiN OOOC WATER PCB-SD0000072451 a. Milbur Speieher~?age 2--October 23* 1959 that sufficient exposure, whether by Inhalation of vapors or skin contact, can result In ehloracne which I think we oust assume could b an indication of sore serious svsteala injury if the exposure was allowed to continue, A second case of slid ohloraene about which we have any knowledge resulted froa workmen dipping their hands in ths liquid Aroelor as if it were mineral oil or vegetable oil, Xn addition, their clothing sooner or later became impregnated with the material and thus exposure was magnified, You asked at t&at temperature local exhaust ventilation should be provided. Although the distillation range for Aroelor 1242 is 3k5-360C. and 385-420C. for Aroelor 1200, I feel that good practice dictates that local vthanat ventilation be provided i&en eny of the Aroelors are heated above 150?, in open oar in any systems where the material is not in a completely enclosed system (vapor-proof tanks, kettles, pu&ps, piping, etc,). This may be ultra conservative because aa the distil lation ranges and vapor pressure curves (page 12 of the Aroelor bulletin) indicate, the loss of vapors at 150?, should not be significant except In any work area where general ventilation or air changes do not exist. Your next question related again to possible skin and systemic effects and X believe it is answered above, Xa connection with the 40 trichlorobnsne-6o Aroelor 1260 combination, X believe the thoughts expressed above also apply. X understand that ths trlchlorobenzenc which is used is a mixture of the 1,2,3-, 1,2,4-, and l,3,5~lsoBaers which will begin to distill at 205C, Again, X believe this indicates a low vapor pressure for the solvent st room temperatures. Ths only reference we have to trichlorobenaene toxicity is con tained in ths Public Bsalth Service Publication Mo, 414 entitled "The Salogemted ^rdroearbons Toxicity and Potential Dangers" by Dr, V. ?, won Oettingen, tJ.J. Government printing Offlee, 1955 (pages 297*296), Dr. von Oettingen refers to some work done in 1937 shish indicated that the triehloroberoene was less toxic than mono or dichlorobenzene, Xn my opinion, a reasonable MAC for this material would be 100 parts per million, Tho enclosed publication cn the toxicity of Aroelor 1242 and 1254 suggests in MAC for 1242 of 2 milligrams per cubic meter which is tvles that reooraaended by ths ACOIB for a chlorinated di phenyl of unstated chlorine 0ontent. Xn ths ease of 1254, ths publication suggests that the KAC of 1 milligram per cubic meter "recommended tentatively for safe Industrial practice by the American Conference of Governmental industrial Hygienists is reasonable. On the other hand, reference ts Henry tayth's Cummings Muriel Lecture of 1956 In which he discussed the basis for ths then existing "hygienic standards" indicates that G8RN 000003 cnnnn^A 60 WATER PCB-SD0000072452 S&, I. taibus* ^either--Page 3~0tobe* S3# 1959 Beery batcm that Ca ef X /u.b. far Aroelor 1242 and 0*3 ag/tUB ?w Areolar 1234 are acre mltrtlt. Za the ohmsm ef any eferenie tcLelty data on Aroelor 1260, w suggest an mo f 0o5 ag/eu*a, the earn ae la the as of 1234, I hare boon la see plant ifeere these aaborlAle were used for eapaaltore and trenaforecrs, She sat and hardline aod the proviaiona of exhaust ventilation Mn not la aeeorda&ee vita shs thoughts stressed above, Tha enly reported difficulty was ease slid eye irritation when ispragnatiaa eafcinste where the items were heated fee HO-ISO^C. released vapors of trlshlcs*benaono and the Areeler late the wortcrw *fcca the eabineb deere sere oymrd, a ay dad, &aah s&blaots aheuld be ventilated to yrmirvi the ropers rathe? then Alloa thee be be released late the Z bare teld that your deepen? has had mm 20-25 yet with the preduota dlseusaed above, Zt was suggested that a. 7rt| easagsr of tranafccaer naaifisturlng at your Charon Plant would be a source of infeewa- tl oxperla&ee with Zbsrteea PPO. Alailarly, IS*. a. S, Jharbury ef your Bloomington, Indiana Plant has been lated with the use of Areola? 1248. perhaps you hare al- exposures with these geotimer. If la learning ef their prastla&l ex- Z leek forward be mairtng you In Plttaburgh next week. Sinaarely, User P. thealer Assistant Streeter CBfth OCCCCh C000095 61 WATER PCB-SD0000072453 >m c v' Monsanto MoAMftto Comov 00 N. lindMrgh toulvrd St. IMH. Wmon 63100 Men*: !3U: 8*4-1000 July 18, 1975 Dr. J.C. Calandra Industrial BIO-TEST Laboratories 1310 Frontage Rd. Northbrook, 111. 60062 re: AROCLOR 2-year Rat Feeding Studies Dear Joe: The attached table summarizes a comparison of the 3 revised AROCLOR reports (12^2, 125^, 1250). In 2 instances, the previous conclusion of "slightly tuaorigenic'' was changed to ''does not appear to be carcinogenic". The latter phrase is preferable. May we request that the AROCLOR 125^ report be amended to say "does not appear to be carcinogenic". The number of hepatomas reported for AROCLORS 1260 and 12^2 have been interchanged. This appears to have arisen from con fusion regarding the numbering of the animals. The original reports show tumors in animals with numbers in the 100-300 range for AROCLOR 1260 and In the 500 to 800 range for AROCLOR 12^2. This leads me to conclude that the numbering scheme shown in the second set of reports is correct. With AROCLOR 125^ confusion is compounded. The original report showed tumors in animals with numbers in the units to teens, but the revised report shows animal numbers ranging from ^0 to 1000. Can this be straightened out? I was unable to reconcile the differences in the animal numbers between the first supplemental report and the original reports, I had inquired as to the changes in the numbers. As I recall, I was told that the sections had been renumoered when the new slides were made and that a key relating to the sets of numbers 8jsn i0073'i vnni^l received jul 21 W'5 WATER PCB-SD0000072454 c * Dr. J.C. Calandra July 18, 1975 Page - 2 - ; ' - ' would be supplied. This has not been done. It may not be necessary for ABOCLORS 1260 and 1242, but AROCLOR 1254 remains unresolved. Insofar as I can see, the remainder of the reports appear acceptable. Kindest personal regards. Sincerely, George J. Levinskas, PhD Mgr., Environmental Assessment and Toxicology /bkp att. cc: Dr. George Roush, Jr., M.D. 1001272 1007.J.1 WATER PCB-SD0000072455 r * ./ _ Product - Supplemental Report #1 (malledj( AROCLOR 1260 conclusion slightly tuaorigenic hepatomas 3 range of test animal nos: p. 9 600 to 800 p. 10 1000 series p. 11 70 to 100 p. 12 500 to 600 p. 13 600 to 700 p. 14 700 series Supplemental Report #2 (JCC delivered! ` does not appear carcinogenic 7 100 to 300 800 to 900 10 to 40 80 to 200 200 to 300 200 to 300 AROCLOR 125^ conclusion hepatomas slightly tumorigenlc 6 slightly tumorigenlc 6 AROCLOR 12^2 conclusion slightly tumorigenlc does not appear carcinogenic hepatomas 7 3 range of test animal nos. as In report #2 as In report #1 for AROCLOR 1260 AROCLOR 1260 I nni m3 10073!) WATER PCB-SD0000072456 * . -J. z z vitkla Of i lstur ZKtirtd 01* Yola in ftorWmls. capias of this lottor ill o to tho apjrropriato Zs idoxmtioo of ooold bo fzatofol if by ppsopri*to this pcahla* is i hsvo boon boryiag t boas oboorbod into ha lay ontiroly ssfo r itedor 7 .f # -% . - ?. * 1, 35 pry 10 WATER PCB-SD0000072457 * ( cc; Mr-. sf** RISING S *TR A N. Q OP/BO AKTHiQUAGt nuraM>34ss m--um n>m mn im. iOWIWOl IM41 AllwqiWOi )M4M STOCKWOW* V4 uMn n November 28, ic. Monsanto Europe BRUSSELS 3 Belgium For the attention of Hr. S. WOOD Dear David, re; ARCCLQHS As mentioned, there has been some publicity in Sweden concerning investigations made at the Institution of Analytical Chemistry at the Stockholm University. These have revealed that a group of products called iUpU--tA* 'tT Polychlorinated 31-Phenols - PCS for short - accumulated in r'g^r-aTrT organs or animals. They* are said to be - related to DDT and equally poisonuous. The findings were discussed at a meeting of scientists at the Wenner-Gren Centre in Stockholm on November 22. Below please find a translation of an article in the Swedish daily paper "Dagens Nyheter":- "It Is found in salmon and in pike. It.is found in sea eagle living on fish. It is found' on the^sur- face of the needles of the fir trees, that is Tin the air. It Is found in the hair of -a-five months baby... * " .. >. The scientists working with biocides have for 57 long time seen this something as unknown "peeks? on /their gas chromatographs and at a meetlng^qt the Wenner- Gren Center, Research Assistant SSren Jensen of the Institution for Analytical Chemistry at the Stock holm University could reveal the Identity of these peeks. It has been found that they consist of a group Of poisons, Palvehlafl-wafegd - (foT short ?C3) which are closely related "ov~ahd equally poisonous as, DDT. PC3 is broken down cozxslderably slower than DDT and gives rise to damagybf liver and skin. PCS is not STR 017391 .--- . * t WATER PCB-SD0000072458 MESA, Brussels - Mr. D-. Wf ' . used as a herbicide. Ip isr not; manufactured In- Sweden but is supposed to used by the industry' to quite some extent. No special industry can- so. far be accused of the rm. Research Asst. S. Jensen has tested 200 fishes and- a number of birds. He has taken several samples c-f air and has reached the conclusion that ECS Is equally common, in Mature as chlorinated, hydrocarbons^ of the type of DDT, BEE, and Lindane. Eves, fish In Laddjajaure in Lapland contain ECS. Mr. Jensen has. also found that PCS does not appear In animals living on a vegetarian diet, such as the elk. In the course of his work, Mr. Jensen has not found anything indicating that the aource of contamina tion comes from agricultural additives. It is, however, obvious already now that PCS is most frequently found In organisms living in water or feeding frost water animals. In all examined pikes PCS was found. In a sea eagle found dead outside Stockholm It was found that the liver contained. Q g of mercury per,kilo. 76 mg PET and consider~ ably more PCB. The exact figure has not yet been determined. PCS is found in water and in air, and not only in the Swedish air, hut also In e.g. London air. Mr. Jensen has not yet been In London for sampling but could Identify the poison by studying a gas chromatogram of air published in a British techni cal journal. 1 Mr. Jensen bar also examined the hair of his family and himself and has found PCS on all samples. Most PG3 was found in. the hair of his wife but most sensational was that the girl aged 5 scnths had more PCS in her hair than her brothers and sisters of 3 and 6 years. Probably the girl had got the poison via the mother's milk. In the State Museum Mr. Jensen has examined the. whole collection of sea eagles datin' back to lSSO. By testing It could be established tnat PCS was present only Is birds from 194* and thereafter while birds collected before 1944 were quite free from PCS. The use of PCS in Sweden is not established in detail. According to American sources these types of products are used in the manufacture of a variety of heatresistant materials. They are used for electrical insulation, for fire-proof heat transport In hydraulic oils, in lubricating oils used at high STR 017392 WATER PCB-SD0000072459 temperature and pressure,, in- paint-S; and as pig.ments in various plastics, FC3 is not- imported only as such. Zt is also part of several finishedproducts. Nothing is known as to the way in- which it reaches the water and the air. According to Mr. Jensen, products containing PC3 should have this openly declared. PC3 is equally harmful whether absorbed via the skin, through the food, or by inhalation. In con tact with the skin it can cause m dema.. For DDT the highest permissible concentration in the air has been set at 0.5 - 1 mg/cu.metre. For PC3 it has been mentioned to be 0.5 mg/cu.metre. Mr. Jensen will now try to get more complete analytical material. He hopes eventually to be able to disclose the source of the contamination and will also increase his cooperation with toxocologists and geneologists." Another daily paper, Svenska Dagbladet, has a similar article. Here it is mentioned that Mr. Jensen,, workins under Laborator (Professor) Gunnar Widmark, has disclosed facts which will have far-reaching importance since the findings have proved a new source of pollu tion of the nature. One of the participants at the meeting was Or. A.7. Holder, of Scotland, scientific contact man between the twelve OJE.C.B. countries, who has established coordinated analysis of chemicals used and found in nature. I suppose there is no doubt that what has been termed Polychlorinated Biphenyls is equal to Aroclor. There is also no doubt that the published facts will cause considerable unrest in several quarters. We probably will have to have Aroclor registered with the Swedish Board of Poisonous Substances and the industry will have to be particularly careful in handling the material. The problem in some cases of course say be the disposal of used material. X understand that there hardly exists a convenient method of destroying Aroclor and that possibly burying unuseable material say be the only answer. We shall be glad to bear from you soon. Yours sincerely WATER PCB-SD0000072460 mi--1 expert--*1 ladtnt* that Xnerte-- is la-- --U tku trichlerebensenej that the Utaka of ftil doees (fiUJjr large quntittai, perhaps 8 to B tablaapo--fnla) will oa--a faypereade of ell inter--1 organa, extansire 4t|amU of tha liwer, and damage of the --coos --abranea of the lUaulu With s--ller daaaa theta afreets are laaa severe and thara la evidently aooa tendency toward healing If further absorption of tha toada notarial la prevented* . Tha eontaet of Znertean with tha akin causes drymasa of tha akin, thieksnlng and scaling, and it appaara that aaffletant quan- tltias nay ha abaorbad la this way to oauaa daaaga of tha liver* Zt appeara that for abort exposure concentrations of 0*8 og par liter of air represent tha naxlaal allowable concentration, and for continued axpoaura, coacantratlcma below 0*05 ng* par liter of air. Dangerous concentrations, or at la&at potentially dangerous concentrations, nay be recognised by drawing 10 liters of air at a rate of about 1 liter per 8 minutes through a teat tube contain ing 1 cc of ethyl alcohol, cooled in dry ice or in an lee salt . mixture, and then pouring the aloohol carefully ou the surface of t h few cubic centimeters of water in a test tube* If the cancantra- ducad between tha two layare* ' For the aafe handling of Znerteen it appears necessary that NPC0T)0d8920 WATER PCB-SD0000072461  1 .--*. concentrations of its vapors in air are kept belew 0.0* mg* par lltar of air by adequate forced ventilation at the site of tha production of such njori Oreateat personal hygiene ia of paramount Importance* Coo* taoiaatlan of the akin should ba avoided by psapar protective garments such as gloves, caps and coveralls* ZB case of accidents or vith short exposure to higher coneantratlons, of and abort 0*fc mg* par litar of air, raspirators or opan air masks shoold ba an Ihs skin should ha kspt inaaculctaly claan and ointments such as lanolin or Aquafor should bo applied to tha skin after tha washing of tha hands* in rle* of the possibility of a toxic action of this notarial on the liver, persons Buffering froa injuries of tha liver (Jaundice) syphilis, ana heurt diseases should ba excluded froa operations in which Xnerteeu is handled* Workers handling Iuertean or with frequent exposure to its vapors, should undergo periodic examinations; special attention should be paid to their nutritional condition, and the condition of the liver should be cheeked by determining the icteric index in the blood and the excretion of urobilin and urobilinogen in the urine* Regards the treatoent of toxic effocts of Znortoen, the local irritation of the skin should be treuted with bland ointments after l, | the toxic material has been removed by intensive washing and scrub bing* In case there is evidence of injury of the liver, a diet rich in carbohydrates, administration of glucose and insulin, and ' _< duodenal lavage wl$h magnesium sulfate may be beneficial* If Inert* 200681 WATER PCB-SD0000072462 * 0 fi has been svalloeed, auetiea suoh i soap eater or autanl eater should be etv ianediatalj. 2fci should be followed by gastric lavage eith a suspension oX activated charcoal In outer, sad saline eathartles such as Bpsoa salts should be dran to reuove any toxic notarial Iron the intestinal tract. o.k8.86 4 ^^oif &400*f0jif$ \ NBG00008922 r*MM" "'"ninniL 200682 WATER PCB-SD0000072463 *. ?ro \\oo3 *V- J*r; ig :. t .` 1 I:':-. 4- f Medical Research Project No. MRTHE TOXICITY AMD POTENTIAL DAUGERS^IJjERTEEN . Submitted by W. F. von Gettingen, H.D.', Ph.D . Director Haskell Laboratory of Industrial Toxicology Wilmington, Delaware. W^GHOUSfELSIC&M?aCO. OUA-EOBX r.-\4 erviasKWJHC.: '*S~ V;S4**-.* ...^y N?C0Op08923 200683 WATER_PCB-SD0000072464 Ths Toxicity ud Potential Danger* of laarteen sad Rclittdl Bubstaaoee, Including a Method of infill forBalogemated Hydrocarbon* In Air. V* J. ran Oettlngem, 1UD*, MuD* She toxicological experiments on this problem vert onrried out by Dr* J* B* Foulger **nd Dr* A* J* Fleming of the Deportment of Toxicology end the pathologic*! etmdioe vere mode by Dr* V* S* Itend, Jr* of the Deportment of Pmtholegy of the Haskell laboratory The materiel vae inreetlgoted with oral edalnletretion to rdii application to the akin of r&ts, and in inhalation experl* manta* She latter vere planned in eueh a way ae to approach aa closely as possible the actual conditions encountered in the use of this material in transformers, in order to evaluate the maxima] ha sard vhieh may be encountered in its use for title purpose* for comparison, additional tests vere made regards the toxic effects from inhalation of vapors from Pyranol and Transformer Oil (Meet* inghouse) In addition, a method was vorked but for the deter* minatlon of Znerteen in air* Xffmct of Oral Adalalatratlon. In order to determine the minimal fatal concentration of Jttsrteen for rats, 100 animals vere given by stomach tubs single doses of Znerteen, as indicated in the table* Dose ' '.9o* of cc*/kgm* animals treated Vo* of dead Tims of dsatb Par cant mortality 1.0*1.48 1*8*1*89 a.0*Sc *49 fe*8*8*99 2*0*8*49 k6 *4 10 . JJO 80 ft 4 * vlthin 8 days 19*8 9 8 * 8 * 37.8 8 ft * s a 80.0 10 9 * a 1 50*0 1ft 1ft * 8 78.0 200684 WATER PCB-SD0000072465 a Zb that#, ue in subsequent cxperlasuts, nil ruts shoved sifBS of discomfort immediately following ths administration, later they became decreased and refused, frequently, water sad foodj vlthin fi hours they became week and stuporous, so that they wars finally uaabla to rise* Khan this stage was reached thajr invariably died* One of thasa rats was found to suffar frau albuminuria, o&a devtloped trouors of tha hauu and fore-limbs, and oaa shoaad severe hemorrhages froa tha intesti nal tract* She table indicates that with oral administration the minimal fatal dose of Z&erteea for ruts, which kills 76 par cant of tha aniuals within i> days, is &*0 to S*dll c. per kilo- graa body weight* Upon pathological examination of SO of thasa aulunls, those that hod died spontaneously showed congestion of the iunea. which was combined with edema and hemorrhage in several instances* Tan of tha aniuals had aottled gray or yellow livers and in three Instances there was a diffust pallor with moderate yellowness* In 6 out of 6 aniuals studied microscopically the liver showed narked and rather extensive hyaline necrosis in the central part of tbo lobules; the liver cells in this area revealed fatty de generation of the cytoplasu; and in k aniuals that tiled 5k and 54 hours after the treatment these oells contained increased ? 4 ,; numbers of mitotic figures* In the oajorlty of the aniuals ths f ' juicosa of the intestine was congested and the fecal material in . the intestines contained old blood; and In one instance fresh blood was found in the lower third of the ileum, lower colon, jvriwswsrtSi *NPC0'iT008925 200685 WATER PCB-SD0000072466 * and slgoold* Microscopically the JlflMitl r ** salmals presented typical hcnorrhaglo erosions of the aaooaoj another showed haoorrhagic areas In the mucosaj and in the reaalnlng animals postoortea changes did not allow an exact investigation* In order to follow up the toxic effect of Zacrteen on the liver, a group of SO white rata was treated in the aane way with alngle oral doaea of 1*13 to 1*&0 ce* per kilograa body weight* Six of theae were killed 3, 8, and 11 days, respectively, after the adalnlstratlon* Upon pathological examination it waa found that two of the 6 animals killed after Z days had bloody nateriala in their atonacha <.nd in 30 per cent of theae aninala the liwer was slightly yellow in color ana the liver cells were large and con tained numerous aitoaes and occasionally there w*-s necrosis of cells immediately about the central Tains, animala killed uftar 6 days presented a alight enlargsaant of the liver with a ques tionable yellowish color, the llvet cells were large, those arour the centri.1 veins were dark, and occasionally there was some fetty degeneration of these cells* fiats killed after 11 days showed no important gross pathology* Microscopically, all sec tions showed a slight swelling of the liver cells with occasions vacuolization oJ the cytoplasn* lio other organs showed patholob- changes referable to the exposure* ,, In order to study the effect of reaeated of Inerteon, 3 groups of 10 rats each were treated in the folio* log ways ' vr- NPCQ0008926 I 200686 WATER PCB-SD0000072467 4 The first group mo*It4 fro* 0.&5 to 0,M ee pr for S eonseeutlre days* Bone of thoa died and b were killed after the Brd treatment for psthologleal uuIbaUu. the second group was fed dosos fron o,B5 to 0M ee. per kiln* Too died following the Sad doao and g vara killed for autopsy after the Srd adalnlstrstlca, Xa the third group the doaea ranged fron 18 to l.TB ee* par kilo. One rat died after the 1st, three after the and, and four after the 8rd treataent, and the remitting anlnals ware killed four days after the Srd treat ment, Upon pathologic*!' examination the lirere of the rats of the first group appeared somewhat lighter than usual and one showed large yellow areas; there was t diffuse slid swelling of the lirer cells r.ith sons polychrosasla; occasionally th<. cells showe sons raeuolur changes ol the cytoplasm, hut in general these changes were not rery severe. In < rets of the third group tviiich died after 3 treatments the stonachs were dilated with food and in two of these there tic also sons old blood present, liicroscopioally, one rat had snail inflaaaatory ulcers in the fore atooach and another showed henorrhugie orosions of the pylorus, dll stowed sons hypcrania of the llrer and in one rut this was of nettled appearance, tficroscoplcully tv.o rats shotted swelling ; of the lirer cells with fatty degeneration of those in the centri 'parts of the lirer lobules. Two others presented central necros: ' of the lirer cells t.lth hyperplasia a:' the endothelial cells in these areas, one showing in addition, nuacroua nltotlc figures 1 NPC600D8927 200687 1 WATER PCB-SD0000072468 tho liver calls. Of t rats which ears killed 4 days following the 3rd administration, one hat' * uu.ll aaount or blood la the 6t ttrie content. She livers of both anlauls *p;*Mrec aodtrately enlarged urtd nlcroecojlcellj there wae a generalised swelling o*' tb* llrer cells sith seat polychronasl*. One rut suffered fros a fairly general vacuolar degeneration of the liver cells and another pro*anted vacuolar changes In the central part of the lobules. Xn order to eonpare the toxic effects of Zaortoon with trlchlorobenasne and ethyl-tetra-peatu-cblorobsnsana, a group of 10 rats was given dally doses of trlchlorobensene ranging from 0.36 to 0.5B oe per kilo body weight. One died after the 1st. four after the Lad unci four after the 3rd idoinistrutioa, the routining rat rua killed 4 days fallowing the Era end last treutaent. It appears, therefore, that dally doseo of 0.66 to 0.56 cc. per kilo of trlchlorobensene killed 90 per cent of the animals with 3 doses, whereas it was found that doses of 0.6L to 1.04 cc. per kilo of ethyl*.totra-aenta-chlorobentena. given in the suae way, killed only 10 per cent, and Inarteea in doses of l.hS to -1.78 cc. per kilo, given in the ssue way, idlied 80 per cent of the rats. : Upon pathological examination, anlaals which tore treated 4f Tilth trlehlorobanaane aau which died s pontaneously shoved a , passive congestion of the lungs and the liver; the wtnamrha vert distended vith food; in four soae blood was present In the A NPC00008928 200688 WATER PCB-SD0000072469 gastric content# and in ana Instance there an# a hemorrhagic rollon of the aueoaa* In two rata the liver shewed irregular aottling. Liver sections of all aniaals showed naorasla of the llrar calls around the central rain# and those in the outer parts shored vacuolar degeneration* la rats which died b to 4 days after the first treatment there eaa son* endothelial hyperplasia in the areas of nscrotic liver cells* One presented an increase in the nunber of aitotle figures in the liver cells* Of the 7 rate treated vlth ethyl-tetra-oanta ohiargfonay^. the one which died spontaneously after the Srd dose showed con gestion and hemorrhages of the lungs* generalised passive con gestion of the spleen* bone narrow unu other viscera* distended stoaach* and aoderute yellow oottling of the liver* the liver cells belnc mildly swollen and showing fine vacuolar dageneration. The animals which were killed shaded only a questionable enlarge- neat of the liver and kidney onu a slight swelling of the liver cells with occasional Vacuolar degeneration, >blch changes were extreaely olid* It aaaears. therefore, that Inerteen la cunrlddrably less toxic than trlchlorobcnsanc. the minimal fatal dose with oral Kdafnfatnitlnn. killing Vfl th anlnAlal 8.0 cc. per kilo rat: whereas etiiyl-tatra-penta-chlorobgnsane does not i-oaefcr to be nearly as, toxic with oral sdainlstration. The cstholeif^f warcs observed after oral administration of Inorteen aone: r to be fairly consietent and QbViwia. .Irtrfifi flam V- HSS58 NPCO0608929 200689 WATER PCB-SD0000072470 T rtiieh are fatal In one or two dsrs. nilTf of the tiwffc- hmuMIm. r ^ llyp with necrosis around the t.1h. and lnali. 9f ttt JilltrtC MW11* mama Ifchlti thw day mtrlc Irritation and hepatic ditration with iilmi of Meiintlitt. the latter Is decidedly more iiarkad affp slxht dars. end after alsren d no Aafiniee n-- nafchalaer nar be JirilMt. It ehooid alee n olic*d out that claitla lare day an^LP to br more Inlurt-W alum en*K gjyn in fraction*. Effaet of ^jpliofatlan tin the Bkln* 9 lea vhitfc rata **re treated dally with an ayplication of about 0*5 cc. of Inerteau to the shared skin of the baek* pre cautions being taken to ;>r<'Yent absorption through the gastro intestinal tract by licking toad by inhalation* All rats lost weight durint th experiment hut thsy shoved nh toxic sirens aside fron a slight rsstlessnasa at ths beginning of the ex periment* At the site of the ^oainistration the skin becans dry* thickened and scaled xithout any fissures being formed* Similar reactions vere obsarred on the hitman skin especially on the hands* cheeks and forehead* One or the rats died after 11* and three after lb treatments* the regaining being killed ' iA hours after the lbth application* Upon pathological examination the Hear of all aninals -* v.ii found to be dark gray brown in color with Bottling on the NPC00008930 200690 WATER PCB-SD0000072471 surface. in those rata which died spontaneously there was fatty degeneration of the llwer eella with neerotia of those around the eentr&l veins and In imiauls killed at the and of the experiment there was a aild aweiling of the liver eella with oeeaaioaal vacuolar degenerati on in aoae. Microscopically the akin r.t the aite of application of rets ehowed hyperkeretiniaation with occasional blister formation, one fcntf.i showed perlfolliculltls, one. hyperplasia of the epithelium rather than liyperkeratiniaation, and in Z rata there- wee a olid fibroblastic proliferation with sons round call infiltration in the underlying connective tissue* It appeara. therefore, that the contact of Inarteen with eh akin does not only cause local reactions each as dryness, tfrlekanltyt out scaling of the akin, but also svstaalc effects as indicated by the Injurious effect on tho liver. tiff*"*- nf Inhalation of Tawors. In evaluating the toxic affects of inhalation of vapors liberated fron Incrtuen at elevated temperatures, utteapta were m&ue to reproduce conditions more severe thou would be .net in the overheating of a transformer* In these experiments rats, were exposed in a United space of about 1 cubic foot . capacity to the vapors of the boiling aaterial which entered directly Into the chsuber through a hole in the bottom. In each experiment i ruts were exposed on 6 to 66 occasions for _t 0 minutes, twice doily, to vapors fron Inerteen, Pyranol, or c. NPCD0OO8931 200691 WATER PCB-SD0000072472 franefomor Oil (leetinghouee)* During this tine they shoved irritation of ths skin, vhieh appeared to bo ooot named oa those ports of the body not protected by heir, sou vuleh per- sistsd for soas ties after the exposure* Pyranol uppeered to produce the aost effect lu this respect, folloved by Inerteen end Transformer Oil, in the order given. Zu opposition to the k rats exposed to Pyranol and Transformer dll, out of 6 rets exposed to Iaerteen lest weight, but no other toxic signs were observed* Xt is quite possible that rets exposed in this vsgr absorbed sons toxic aateriel through the gastro-lntestlnai tract by licking the fur during or after the exposure since the mate rial had a tendency to condense on the vails of the chamber and on the surface of the animals* She maximum concentration of Inerteen to which these rats were exposed vus determined as about 0*5 ug* par liter of air* ' Upon pathological examination of ruts exposed In this vay on 14, C5 and 06 occasions to Xnertesn, no definite pathological signs could bo observed in the liver or other organs which could be referred to the exposure* 2wo rats treated with 41 exposures to the vapors of PyrunoJ shoved no definite cellular changes in the liver uithough in one there was an increased number ol mitotic figures in the liver cells* Two rets exposed on 44 occasions to the vapors of Trans former Oil (vostinghouse) shoved no definite pathological changes of the internal organs* .4 NBC66608932 200692 WATER PCB-SD0000072473 10 In order to stady the effects of flttiMMLlB 10 rata vara exposed B boars dally m ft days a avail for ao days to eoaeaatratlans of o*0ft i|< to 00I i| of laortm par 11tar of air* They shoved no toxic nor pathologies! alcna rafarable to tha emyosurej thara vert no definite ohanges of tha rad blood corpuscles or tha hcnoglobln* She solatia vara killed S days after BO exposures* It appeara. therefore, that neither frequently reputed abort exposures for 2D ninataa each to concentrations of 0,B of Inartean per liter air, nor eontlnaad axaosure to concentre- tlona of 0.0b to 0.0ft nc. oar liter air cause a definite toxic ftfWt ttt 11TIE* . Detemlnatlff*! eventrations of Inartean In-the Ain. ' In order to dataralne tha concentration of Inartean vapors In tha air, tha following naphelonatrlc method eaa corked out, after several other procedure a had bean considered. A definite volume of air to be tested la dram at a rate of about 1 liter every 4 nitratea through a teat tube containing 5 cc. of ethyl alcohol, Immersed in dry ice-acetone Mixture in order to prevent the evaporation of the alcohol* At the end of the campling 1 cc. of the alcohol was mixed v-lth 10 cc. of die- tilled water and the resulting turbidity vss measured with a photo electric call, using a sodium vapor lamp as the source of light. .. The turbidity of unknown samples vaa compered to the *mmbNPC00008933 200693 WATER PCB-SD0000072474 11 taifcldltgr produced hr team itudiidi ate* p ef tviohloro* ben*-- and ethyl alcatel* Shi* aethad im satisfactory readings ever a ruga fraa 0*80 to 8*0 ag* par litar of air ud when the original dilation* vara taken late aeoout, It vac aufflcisntly aenaitive to latent fteUttu aa lav 0*08 ag* of Xaortaon par liter of air* She netted la not pacific for the vsrloaa aenbera of the halogunted hydro- earbona but alacc the vapors liberatod fru Xaertesn audit mtaly of trlchlorabensuo, es vlll be ohovn below, It nay be uaod for the determination of Inertaon vapora la air* _ In ardor to obtain inforaatiu regarda chaagea of the concentration of vapora In air with tee dlatenoo fru the source of production, aaaploa of air were toku la a cloaod apace at varying distances fraa boiling Znerteen and the fonoting concentration* voro deterainodl Distanoe (inches) Cucutrctiu ag* per liter Id 4*60 80 1*86 9 1.14 86 1*14 bhen auploa acre taken at Various distances ovar an opan beaker of boiling Znerteen the reaulta vere at follow*: Distance ; (inohes) .t 8 10 18 SO Conceatratlu ag* per liter 0*88 0*48 0*84 0*84 UPC00008934 200694 WATER PCB-SD0000072475 u These uptriwati ataov that the aoneentratlona of Iaertesn In air decrease rapidly with tha dlataaca fvoa the aouraa af their production* . Sa erdar to atody variations of tha eaneoatretlone over a pariod of tiaa and alth diffarant temperatures, & earrant af 10 litara par ainuta of air vas pasaad orar tha surface of Soar- taan of about 10 square inches, eontalnad in a flask and thanaa into a ball Jar* Staples vara taken tram tha Jar at various intervals after tha flow vas started and with various tcupernturea She following onosotrationa vara deteralnedi Sin# of sampling in hours Concentration of triohlorobensena in ag. por liter Tenparatura of trlehlorobsnaana in flask *C, * 0*89 8 0*81 0,60 1 1.W 4 1*70 1 1*80 88 88 88 0 60 80 Inertaan 0*88 88 Shis tabulation shos that tha datsmlnations aada at 8SC and with tha 6 hour aample vara alaost tha sane for triehlorobanaane (0*60 ag par liter) and Xnerteea (0*88 ag par liter) Shis suggests tha poaaibility that tha bulk of tha vapors lit yreted froa Znertssn at this teoperatura nay ba trlchlorobensane; so that tha hazards froa inhalation of Xnar* * . * # taan vapors are idantioal alth those froa the inhalation of '* NlC0 000893 5 200695 WATER PCB-SD0000072476 IS trlehlerobeasene. Xa order to confirm this* SSi oc. of XMrtoen were eubnltted to fractional distillation and tho following rtsalts wore obtained* Fraction Xwperature of dlst|natlan Feline eoUeeted eo* hpeeifle Boiling Qravlty Feint "8* of fraetien 1 8 6 4 Residue M0 840-884 4-880 880-800 above 800 88 48 48 SO ISO 1*488 1*478 1*488 1*877 1*888 808-818 888 840 889 m Sloes tho specific gravitjr of trichlorafeoaseae is 1*486 si tho boll ins point 8O6"O*-&1S*0*, it is evident that up to 40*0. the vapors consist exclusively of trlchlorobenssae and that for this reason ths above ntrrr* that far ost conditions tho hniarAa fron vaoorB of lnsrtssn fere Identical with tho fro* trichloroboaxens. aSshL* Zhs experiments discussed in this report show that with oral administration Xnerteen is considerably less toxic than trichlorobenseno* the minimal fatal dose hilling fron 70 to 7S per cent of the rats being around 3*0 cc. per kilogram bod/ weight and 1*4 to 1*0 per kilogram body weight* respective!/. Fatal doses will cause passive congestion of all viscera* ex yf tensive degeneration of the liver* and ulceration of the gastric mucosa* With sublethal doses these effects ere less severe and there is evidence that they will heal when no further exposure occurs* '' m <*.. -NPG00008936 200696 WATER PCB-SD0000072477 14 Continued application of Xnertean to the shin of nti and Ira--at ocusoe diyneas of the aktft, talc--nlag cad scaling! and the observation* made In rats indicate that sufflcl--t quantities nay be absorbed through the attln to produce injuri- oua offsets -- tbs liver* Rapestad Inhalation for short periods of concentrations of 0*9 as* of Xnertoen vapors par liter of sir* or repeated inhalation for 6 hears of cone--t--tlons of 0*08 to 0*08 mg* per liter of air causes no definite injurious offsets in ruts* Yapors liberated fro* boiling Pyraaol, Znerteen* and Irans- foraer Oil (Vestiaghouse) are Irritant and the irritant action decreases fron Pyranol to Transformer Oil (Vosttngbouse), In- erteen being intermediate in this respect* * Zt has be-- shown that vapors liberated fron Inert*-- under conditions approaching those as night be --countered in traneforners consist --inly of triehlorobeassne* a sinpls method for the determination of Zaerte-- (tri- chlorob--s--e) vapors in air is giv-- If 10 liters of uir are drain at a rata of about 1 liter every ninutcs through a test tubs containing 1 cc of ethyl alcohol, cooled in dry ice or in an lee salt mixture, and the alcohol is then poured care fully -- the surface of a few cubic csntiaetsrs of water In a test tubs', a ring of turbidity is produced if the cuacoatrs- tion of Inerte-- (trichlerobens--e) is over 0*09 mg* per liter of air* If undar these conditions a white ring is produced, *' * *- NPCC0008937 200697 WATER PCB-SD0000072478 1 the air tested should be regarded vltb susplelem end should bs improved by aor* ventilation* It wi fonaet that the ooMmtratlaB of Inerteea (trl- chlorobensens) in a closed gpece 14 inches above the surfuos of boiling Zknttn 1 4*1 ug* par 11too had la an .open space 5 laches abova tho surTaceof boiling Znertesn la 0.56 mg, par liter* and when the temperature in a transformer, itandlai in o closed roan (vault)* rises to 90*6. tho ulr map contain 1*8 i|( par lltor of air* Froa tho animal experiments roportod, it appeara that concentrations below 0.08 ac par liter of ftlr will cuuse no toxic signs or symptoms oven with continued exposure. Regards artvqitlvs Measures, the following map be snggeatedi It appear* to be of puranount import:nce that the conteal- nation of the air be reduced to concentrations below 0.0S mg. per liter of air by adequate forced ventilation at the site of the production of such vapors* Greatest personal hygiene la not lass important* Conteal- nation of the skin should be avoided by wearing proper protective gerasnts such as gloves* caps* and coveralls* In case of sodden -qr dth exposure to higher concentrations of and above 0*S mg, pe liter* respirators or open air assies should be. worn. the skin should be kept inuaeulutely clean and ointments such as lanolin jar Aquafor should be applied to the skin after washing the hands. In view at the hepatotoxic action of this compound, ladl- >i vlduals suffering froa Injuries of the liver* syphilis* and heart *- NPC0V008938 200698 I WATER PCB-SD0000072479 diseases should be nelndid from opmtiou la vhlob Inertesn it handled. Vorluri htndl Ing Xnertean or lth frequent exposure to Ita fapori should hv periodic examinations, special attention should b paid to their nutritional condition, ana th condition of th* liver up bo cheeked by determining the letorlc Index In the blood, and the urobilin and urobilinogen excretion la the urine* Regards the treatment at tmtla affaet^ produceu by exposure to Xnerteen, It appears advisable to inornate the resistaaee of the liver by carbohydrate diet; adnlnlstratlon of glueose and insulin nay be advisable, and duodenal lavage with nagnesiun sulfate nay be tried* bocal Irritation of the skin produced by laerteen should be treated %*ith bluad ointments after the toxic, material has been reaoved by intensive waelilni; and scrubbing. In case Xnertecn bos been taken by south, the toxic material should be removed froa tho stomach by eaetlcs such as soap eater or nustard eater, and this should be followed by gastric lavage with a suspension of activated charcoal in eater and saline cathartics such as Epson salts* Si8*38 4* *- NPC0TT008939 200699 I WATER PCB-SD0000072480 E. P. Wheeler - St. Louis October 21, 1968 Polychlorinated Biphenyls In the Environment W. H, Richard WHICH R. E. Kelly, M. D./ W. H. Hunt Scott Tucker - Queenv Plant a. A. Keller - "CT ray ton c'VJfTT * H. Bergen - HH BERO W. K. Johnson - WJOHN Attached la a Xerox copy ol a technical paper which Scott Tucker and I picked up In Washington recently. This was provided us by Donald A. Spencer of the National Agricultural Chemlcala Association. Mr. Spencer requested that the paper be held "confidential" until such time as it may be published. Spencer Indicated that if this paper were distributed one of his principal "sources" would refuse to give him prepublica tion information In the future. Rlsebrough's presentation (the attached) was made at a meeting of 20 to 30 toxicologists held at the University of Rochester in June. The meeting was billed as "The First Annual Conference on Toxicology" and was underwritten presumably by the AEC whlcn has had contracts at Rochester for many years. Attendance was by Invitation only. The meeting dealt "exclusively' with pesticides with about one-third of the papers relating to mercury. As far as Spencer knows the papery Including the attached, will undoubtedly be printed as proceedings of the conference although I suspect individual authors were given permission to publish elsewhere. In a few words. Rleebrough has found PCBs along with chlorinated pesticides In a number of species of fish and birds along the California coast as well as in waters off Baja California and Central America. He further reports PCB In fish from the Channel Islands and Puget Sound. No PCB was detected In the liver of tuna taken in the Oalapagos Archipelago. Scott Tucker is going to scrutinise the analytical aspects and particularly the validity of some of the assumptions made by the author. cs Attachment Elmer P. Wheeler 726683 WATER PCB-SD0000072481 POLYCHLORINATED BIPHENYLS IN THE GLOBAL ECOSYSTEM PERSONAL COMMUNICATION NOT A PUBLICATION NEV 018633 726684 WATER PCB-SD0000072482 POLYCHLORINATED BIPHENYLS IN THE GLOBAL ECOSYSTEM ABSTRACT Compounds identified as polychlorinated biphenyls, pollutants of industrial and agricultural origin, are now widely dispersed in the global ecosystem. Tissues of peregrine falcons have contained the highest concentrations so far measured. Significant amounts are also present in several species of pelagic sea birds. The geographical distribution patterns indicate that the polychlorinated biphenyls, DDT, and the other chlorinated hydrocarbon biocides, are dispersed predominately by air transport. The polychlorinated biphenyls are powerful inducers of hepatic enzymes which degrade oestradlol. Their enzyme inducing activity in pigeons is approximately four times as great as that of technical DDT and si* times that of p,p'-DDE. Both the polychlorinated biphenyls and p,p'-DDE could account for a significant portion of the environmental deterioration which has caused the aberrant calcium metabolism observed in raptors and other species of birds since the Second World War. MEV OlBOlH 726685 WATER PCB-SD0000072483 2 Deterioration of the environment has proceeded at a rapid pace and It is universally accepted that it has caused the extinction of some species and has profoundly Influenced the relative abundance of others. Whether chemical changes in the global ecosystem have been sufficient to cause widespread harmful effects is still a matter of controversy, yet the Interpretation of Ratcliffe's findings that the calcium metabolism of British peregrine falcons (Palco nereerinusl changed adversely just after the Second World War is unambiguous (1). A widespread change in the chemical environment has occurred which has affected not only the calcium metabolism of the peregrine falcon but also of other raptors and terminal avian carnivores in both Britain and North America. In every case thin eggshells have been associated with populations which were declining and which were also contaminated with the synthetic chlorinated hydrocarbons which have come into general use since the war. Moreover, geographic variations in eggshell thicknesses have been correlated with the amounts of chlorinated hydrocarbon residues in populations of peregrine falcons, bald eagles Kaliaeetus leucocephalus. ospreys Pandlon haliaetus, double-crested cormorants Phalacrocorax auritus, and herring gulls Larue argentatus (1,2). Ho other environ mental change, such as radioactive fallout, has shown comparable variation over e wide geographical area. Calcium physiology Is intimately related to reproductive physiology and is to a large extent regulated by steroids such as estrogen and vitamin D (3). All or most of the synthetic chlorinated hydrocarbon biocides so far tested induce hepatic enzymes which degrade steroids NEV 018655 726686 WATER PCB-SD0000072484 3 by hydroxylating them, thereby increasing the rate at which they are excreted (4, 5, 6, 7, 8, 9). The relatively small amounts required to produce this effect (6,1Q,}1,12,13) and the discovery that small amounts of DDT appear to have estrogenic effects (4) have made irrelevant much of the parts per million approach to pollutant ecology based only upon toxicity data. In both Great Britain and North America it was the decline of the peregrine falcon which has initiated concern about the possible harmful effects of environmental contamination. In the distinguished tradition of British field ornithology, the population collapse in Great Britain was veil documented (14,15,16.17) but in the United States the eastern population was extinct before competent observers were aware of a general, widespread decline (18). Breeding peregrines persist in apparently normal numbers in the Pacific northwest (19) and in the Arctic (20,21). A small remnant population remains in southwestern North America. In 1967 we collected an unhatched, abandoned egg in Baja California, Mexico. Analysis of this egg (Table I) showed that it contained almost 5 milligrams of p,p'-DDE, indicating a high level of contamination in both the adult female and the local peregrine population. Considerable effort was made to Identify the unknown peaks present In the chromatograms but thesafattempts were unsuccessful until the reports appeared from Sweden (22,23) and Great Britain (24) identifying polychlorinated biphenyls In European wildlife. The published chromatograms of the commercial mixture of polychlorinated biphenyls (PCB) and of an extract of a European kestrel (Falco tlnnunculus) (24) were very similar to those NEV 018636 726687 WATER PCB-SD0000072485 4 timea_o_tha unknown-peako -In _theag ssjtjpasJte. proved-to be-idntical with those of several PCB compounds on DC-200 end QF-1 columns (25) and on a nixed SE-30:QF-1 colunn. The chlorine content of several extracts and standards was determined with a Dohrman mlcrocoulometric detector and a method of quantification of the PCB peaks was devised based upon peak heights produced in the electron capture detector related to standard p,p'-DDE (25). Toxaphene, a mixture of polychlorinated camphors^ has been reported to be resistant to nitration, whereas DDT is destroyed (26). PCB is also^destroyed by this procedure. In Table I are presented the results of analyses of peregrine falcons, all of which were originally trapped for the purpose of falconry, which died shortly afterwards in captivity from a variety of causes and were then donated to us for analysis. Significant amounts of PCB were present in Arctic peregrines only a few months old (Ros. 5 and 6), but higher residues were present in a second year Arctic bird (llo. 2) and exceptionally high residues were present in an adult trapped in California (no. 4). In birds 2 and 4 the total lipid reserves were very low, and in both the brain levels of DDE and PCB were high, perhaps at toxic levels. Fat mobilization during reproduction or in times of starvation or stress could be expected to cause significant changes in the internal distribution of chlorinated hydrocarbons. Steroid hydroxylase activity in the liver might increase at this time. Dieldrin concentrations were lover than in the peregrines analyzed in Britain, but DDE concentrations were approximately comparable (28). nV 018637 726688 WATER PCB-SD0000072486 5 In Table II are-presented the results of analyses of peregrine prey species* remains of which were collected at eyries in Baja California! Mexico. With the exception of the remains of one mourning dove (Zenaidura macroura) and of three fi?h bats (Pizonyx vlvesi), prey material found at four eyries consisted of 6ea birds. Of these* the eared grebe (Podlceps casplcus) and the black petrel (Loooelanla melanla) constituted 32% and 25%, respectively* of the remains. Black petrels, like other petrels and shoarwaters (29,30, Table III) contained especially high concentrations of both DDT and PCB, a fact which eppears to result from their feeding upon organisms at the sea surface, which would receive the components of aerial fallout. Reproductive success in this population of peregrines appears to be subnormal. In 1968, each of two pairs hatched only one young, both of which were fledged. Two other pairs apparently fledged only one young per eyrie and none was observed to hatch or to fledge more than a single young. In the past, two to four young, the number normally produced by healthy peregrines (20), were raised by each pair (31). The region is wilderness, with little or no human interference, and is remote from sources of pollutant application. In California, numbers of breeding peregrines have been reduced by at least 80% in recent years. Despite minimal human interference, peregrines have disappeared from the nearby Islae Coronados in Mexico, where it can be inferred that they preyed upon seabirds. The remaining few pairs in California, however, appear to be reproducing normally and rear, when undisturbed, 2 to 4 young each year. They are found, like most of the surviving peregrines in Great Britain (17), in a relatively NEV 018638 726689 WATER PCB-SD0000072487 6 low levels of chlorinated hydrocarbons. Twenty seven remains of 16 prey species collected at a coastal eyrie which produced three young birds in 1968 Included 8 mourning doves, one rock dove (Coluoba llvla), 2 woodpeckers, 8 passerine species, one grebe and 6 shoreblrds (Scolopacidae). Ho analyses of the prey species from that region have yet been made, but mourning doves from San Diego (Table III) contained very low residues. On the basis of the residue data available on land and water birds in California (29,32), it Is a reasonable hypothesis that the food species of this pair and of other successful pairs at inland eyries are less contaminated than water birds preyed upon by peregrines elsewhere. A clutch of eggs collected in this region contained the normal, prewar, amount of calcium, whereas other peregrine eggs from California collected since the Second World War have contained significantly smaller eaounts (2). Despite official protection, the surviving birds are still subjected to shooting by sportsmen and to harraSsment of the eyries. If these could be effectively reduced, the population might yet survive. In Table III are presented the results of analyses of marine and terrestrial birds and of three species of fresh water fishes for PCB and DDT content and concentration. From the ratio of total DDT to PCB, it is apparent that regional fallout patterns for the two compounds exist. In almost.mil of the fishes (25) and the birds from San Francisco Bay which have been analyzed, this ratio is between one and two. Among the birds this was true for the peregrine falcons (Table I), the western gull eggs, the Caspian tern eggs and one of two black-crowned night heron eggs (Table II). The other black-crovmed night heron egg had a typically ''ocean" profile, suggesting that the adult female had spent the winter 0v*b39 726690 WATER PCB-SD0000072488 . .& along the coast. In.most of the birds from the Farallon Islands, which are 27 miles west of the Golden Gate Bridge, this ratio Is between 2 and 5. In Panama, where PCB contamination might come from the Canal Zone and Industrial areas In Panama City, the ratio Is between 1 and 2 (Table III). In the Gulf of California, a region relatively remote from the sources of either DDT or PCB contamination, this ratio 1b in most cases approximately 9 or 10. This was true In the egg of the peregrine falcon (Table 1) In all of the black petrels and least petrels analyzed, in the Craverl's Murrelets (Table II), in five of six osprey eggs, and in six of seven western gull eggs (Table III). Among the exceptions, the fish bat, with relatively more DDT, but with low concentrations of both DDT and PCB, was the most divergent, with a ratio of 43 (Table II). It is not clear whether this reflects differences between avian and mammalian physiology or a fundamental difference in feeding habits. The exceptions among the osprey and western gull eggs had relatively more PCB; the profiles of the chromatograms resembled those of the Caspian tern from San Diego. The adult females might, therefore, have come from the other side of the peninsula of Baja California. In the eggs of both the elegant terns and the Heermann's gulls, this ratio is lower, reflecting higher amounts of PCB relative to DDT. Both species migrate out of the region following the nesting season and most likely acquire their PCB residues elsewhere.. In sea birds front, the Pacific, whether in the fulmars, red phalarope, ancient murrelet and rhinoceros auklet, species nesting in the Arctic and the Forth Pacific, or in the shearwaters which breed in Australia, Hew Zealand and Chile, this ratio was usually between 5 and 10. PCB was not 018640 726691 WATER PCB-SD0000072489 8 found in eggs of the Adllie Penguin, brought from Cape Crozier, Antarctica and kindly made available for analysis by Dr. R. E. Feeney. In these, however, the amount of DDT on a lipid weight basis was very low and the ratio of DDT to the lowest amount of PCB which could have beer, detected was only 18. A larger amount of fat material from Antarctic organisms, which would yield a sufficient amount of DDT would, therefore, have to be analyzed before concluding that PCB has not yet reached the Antarctic. The presence of PCB in the few land birds analyzed shows that it is also distributed among terrestrial ecosystems in North America. The PCB concentrations in the three species of fresh water fish from Clear Lake, Lake County, California, were very low, lower than those in marine fish from San Francisco Bay and Puget Sound, and in several cases, lower than those in fish from the Pacific Ocean (25). Individuals of species resident in industrial areas have, as expected, higher PCB levels than individuals,of the same species from more remote regions. Analysis of 10 eggs from 10 clutches of the western gull from the Ferellon Islands showed an average DDT concent of 412 micrograms with a standard error at the 95% confidence level of 102 and a PCB content of 136 + 55. DDT and PCB content-of 4 eggs from 3 clutches from an island in San Francisco Bay was significantly higher (Table III). Seven eggs from 7 dutches in the Gulf of California contained 385 + 230 microgrems of DDT and 45 + 30 mlcrograms of PCB. The DDT content is, therefore, not significantly different from that of the Ferallon eggs, but the PCB content is much lover. - Birds from the Gulf of California also contain dleldrin and endrin (Tables II and III) but the number of analyses is as yet insufficient to 726692 WATER PCB-SD0000072490 9 compare their relative abundance to that of DDT end PCB. Despite the inability pf the Shell Chemical Company to find any chlorinated hydro carbons at the mouth of the Colorado River which drains Into the Gulf (34) It Is likely that some do enter from that source. A significant fraction, however, must come from the atmosphere (35), and air transport best explains the presence of PCB in remote areas. They are poorly soluble in water and have very low but finite vapour pressures (36). Incineration of PCB-contalnlng materials would greatly increase the rate of entry into the atmosphere. Since PCB is used in the manufacture of many industrial products, the high amounts found in San Francisco Bay, Puget Sound (25) and San Diego Bay presumably result from direct discharge of Industrial vastus into these waters. The PCB compound with retention time 1.25 on DC-200 columns and 1.33 on QF-1 columns, relative to p,p'-DDE, is one of the more prominent peaks in San Francisco Bay extracts end in the commercial mixtures, yet it is not present or is present in relatively lower amounts in extracts from Baja California and Panama. To test the possibility that PCB might be subject to degradation by ultraviolet light, standard PCB solutions in hexane were evaporated to dryness in petri dishes, or over leyers of water and 3Z HaCl solution, and irradiated at a distance of 4 inches with a 15-watt germicidal lamp emitting at 2537 A. In each case, the major change' in the chromatograms of the Irradiated PCB was a reduction in the relative height of this peak. The effect was more pronounced when PCB was irradiated on the aqueous surfaces. Peregrines could, therefore, acquire PCB as well as the other chlorinated hydrocarbons, over all of their global range. Do PCB NEV 01864* 726693 WATER PCB-SD0000072491 10 residue data are available for prey species from.the Atlantic, but compounds which appear to be PCB have been Isolated from seals (33). A second year male peregrine spent the winter of 1967-68 on Isla Pacheca, Panama, where the pelican, booby, and frigate bird eggs of Table III were collected. The high concentrations in all of the petrels analyzed euggest that the fork-tailed petrels (Oceanodroma furcata), a major prey species of the Peale's race of the peregrine falcon In British Columbia (19, might be similarly contaminated. T!.e vl:ltr>- teilr.i kitj in becoming clunC-nt in ar*.rn of California where insecticide use is intense, yet because it preys primarily upon the short-lived and herbivorous vole Microtus. the species accumulates very low residues of cither DDT or PCS. The American kestrels and the barn owl eggs analyzed also contained very low residues. Both species are very common in California. In contrast, the single Cooper's Hawk, a species which elsewhere has shown thinning of eggshells (2) and which preys upon blrdsi contained high amounts of both DDT and PCB (Table III). The percentage of p,p*-DDE in the total DDT residue has been given in the tables below. In almost all cases it is above 80 percent. It is most likely, therefore, the most ecologically relevant of the DDT compounds although the differences in estrogenic activity among the various DDT compounds (4) suggest that biological effect does not necessarily reflect parts par million concentrations. Previous work (13) has shown that both DDT and dieldrin Induce hepatic enzymes in the pigeon which, in an in vitro preparation, increase the metabolism of progesterone end testosterone. This work has now been extended to study the metabolism of oestradiol by enzymes induced by N6V 018<>`'3 . 726694 WATER PCB-SD0000072492 11 p,p1-DDE, technical DDT (Dupont) and PCB (Aroclor 1262). The experimental procedure previously described (13) wae followed except that the chlorinated hydrocarbons were Injected intramuscularly rather than given orally and in the separation of oestradlol and its metabolites, the solvent system used was the upper layer of a mixture of benzene:heptane:methanol:vater 7;3t8;2. The strips were monitored with an autographic strip scanner. The profiles obtained for the various Inducing agents are shown in figure 1. It will be noted that the profile of the metabolites obtained following enzyme induction using DDE and DDT are identical, but that a different metabolite is produced by the enzyme induced by PCB. The amount of metabolites formed was calculated from the radioactivity of the peaks. The results obtained are given in Table IV. p,p'"DDE at body concentrations of 40 ppm in the pigeon significantly increases the rate of oestradlol degradation by the induced hepatic enzymes under the experimental conditions. It may be concluded, therefore, that DDE in nature increases the rate of metabolism of estrogen and other steroids a6 they pass through the liver. The metabolites produced are more polar and their biological activity is most likely altered. On a weight basis, the PCB preparation had an oestradlol degrading potential approximately 5.6 times that of p,p*-DDE and 4.1 times that of technical DDT. PCB and p,p'-DDE may, therefore, be the most ecologically significant pollutants now accumulated by organisms. Studies on the activity of induced enzymes in the rat at various times after a single injection of DDT or dleldrin have been made by Ghazal (37). He found that it took 70 days for the activity to fall to half its maximum value in the case of DDT and 15 days In the case of NEV 016644 726695 i WATER PCB-SD0000072493 12 dleldrin. Experiments with dieldrin on pigeons show that only a quarter of maximum activity remains after a month. Thus, there is evidence that the effects of these induced enzymes can persist over a long period of time although more studies are needed to determine the steroid degrading potentials of livers of those species contaminated with chlorinated hydrocarbons. The profile of the metabolites should be some indication of - the history of exposure to chlorinated hydrocarbons. Decreases in eggshell thickness and eggshell weight have amounted to as much as 19% in both Britain and America (1,2). Chances of eggshell breakage are thereby greatly Increased (1,14). Humidity may significantly affect the hatching success of duck eggs (38,39) and decreased eggshell thickness in poultry has been shown to cause decreased hatching success through increased water loss from eggs (40,41). The environment in which birds now exist is no longor the same as that in which they evolved; it is unlikely that any species has the genetic capacity to meet the selection pressures resulting from the abrupt environmental change which has produced the thin eggshells. Several mechanisms may account for the aberrant calcium metabolism observed in peregrines and other birds. Vitamin D, a steroid, is essential for the absorption of calcium from the alimentary tract and Increases thelevel- of calcium available from bone resorption (42,42). Hens deficient -in Vitwin D lay eggs with lower eggshell weights, less yolk calcium, and presumably, with lower Vitamin D contents. The developing embryos of such eggs utilize less calcium from the eggshell (44). Reduced levels of estrogen and androgen could be expected to reduce the deposition of medullary bone, a major source of calcium during egg and eggshell formation 726696 WATER PCB-SD0000072494 13 (3,45,46,47). Lowered estrogen levels could also affect both the amount of calcium normally excreted (48) and the concentration of serum calcium which normally increases under estrogen stimulation as a result of liver synthesis of yolk proteins which are bound to calcium (45). Induction of steroid metabolising enzymes by chlorinated hydrocarbons could affect any of these processes. Vitamin A mobilization is also Influenced by estrogen (49,50) indicating that eggs of contaminated birds might be deficient in vitamin A. Bumblefoot is a foot ailment that has showed an increased Incidence in captive peregrine falcons in recent years. Both prophylaxis and treatment involve the administration of vitamin A. Fortunately, all of those hypotheses are subject to experimental test; alienated molecular biologists are now in a position to perform an enormous and Invaluable service to the world's wildlife and to those concerned with its preservation. The peregrine falcon is a species long highly revered and respected. G.H.Thayer (51) has described it as "the embodiment of noble rapacity and lonely freedom". A subtle irony therefore exists in the fact that the peregrine may be the first species to be extirpated by global contamination. R. W. Risebrough, Institute of Marine Resources, Department of Nutritional Sciences, University of California,Berkeley,Calif. 94720 D. B. Peakall, Established Investigator, American Reart Association, Langmuir Lab., Division of Ecology and Systematica, Cornell University, Ithaca, Dew York 14850 S. G. Berman, Department of Zoology, University of California, Davis, California 95616 H. II. Kirven, San Diego Natural History Museum, P.0. Box 1390, San Diego, California 92112 P. Relchc, Institute of Marine Resources, Department of Nutritional Sciences, University of California, Berkeley,Calif. 94720 NEV 018646 726697 WATER PCB-SD0000072495 Table X: Chlorinate- hydrocarbons in North Aaericai. .eregrine Falcons. Concentrations in parts per Billion* vet weight * dry weight >' or lipid weight. * Sample ' Dleldrin Total DDT^ ZDDE PCB DDD/PCB 1. Unhatched egg Baja California (vet) 2. Second year ^ migrant from Arctic breast muscle (wet) breast muscle (dry) brain (wet) carcass (wet) carcass (lipid) 3. Immature, California ^ 0.11 181 m 0.87 62.5 102 99 296 85 70 5000 97 10.2 10 94 28 84 98 21 93 19.7 1420 3.5 4.7 3.5 breast muscle (wet) liver (wet) brain (wet) brain (lipid) carcass (wet) carcass (lipid). . 4. Adult, California ^ breast muscle (wet) liver (wet) brain (wet) brain (lipid) carcaS* (vet) career# (lipid) 5. Immature ^ migrant from Arctic breast muscle (vet) breast muscle (dry) liver (wet) Nil . NM 0.04 . 14.4 7.7 2.8 90 92 89 9.4 4.5 1.5 0.50 36 19.3 0.11 20.2 92 10.8 1.6 300 160 Nil NM 0.31 3.7 1.7 50 127 77 49.5 595 85 2600 87 98 80 57 86 34.6 415 87 65 1980 1.5 1.7 1.9 1.9 1.3 1.4 1.4 1.3 NM 2.3 81 0.16 14 7.8 0.54 181 1.0 92 0.10 10 018647 726698 WATER PCB-SD0000072496 Table 1, continued brain (wet) body fat (wet) KM KM carcass (wet) 0.07 carcass (lipid) 0.44 Immature Arctic migrant (B) breast muscle (wet) KM breast muscle (dry) 0.43 50.3 9.3 63.7 83 82 82 1.9 6.0 69 0.032 3.2 0.80 5.5 12 16 12 0.6 1.9 3, * DDT residues include: p,p'-DDT, p,p'-DDE, p,p'-DDD (p,p'-TDE), p,p'-DDMU, Ojp'-DDT and o,p'-DDE. EM: not measured, k Chlorinated hydrocarbon contents of the egg vere: A,700 micrograms p,p'DDE; 40 oicrograms o.p'-DDE; 29 nicrograms p,p'-DDT; 7.4 aicrograms p,p'-DDD; 37 micrograms p,p'~DDMU; 5 micrograms dieldrin; 12 mlcrograms heptachlor epoxide. Concentrations vere calculated by assuming a volume of 47.3 ml., the average value obtained by measuring 11 clutches of peregrine eggs from California in the Museum of Vertebrate Zoology, University of California, Berkeley, and by assuming a density of 1.0. c Second year female, captured In October on the Texas coast during migration. Died in captivity shortly afterwards, no apparent cause of death. No body fat. Total body content of chlorinated hydrocarbons: 35 mg. DDT, 10 mg. PCB, 0.44 mg. dieldrin, 0.18 mg. heptachlor epoxide. Total body lipid, 7 gm. ** Plumage characteristics of both 3 and 4 were Intermediate between those of typically resident California birds and the arctic race tundrius, as described by White (27). No. 3 was immature female of the year trapped in the southern San Francisco Bay area in the winter of 1966. Observed feeding in the area for a week prior to cepture. Died suddenly after eating a dead gull. Moderate body fat. Total body chlorinated hydrocarbon content: 13 mg DDT, P NV 018648 726699 WATER PCB-SD0000072497 6.8 eg. PCB, 0.07 eg. dieldrin, 0.09 mg. heptachlor epoxide. Total body lipid* 63 gm. . 6 Adult female. Trapped In the southern San Francisco Bay area in the winter . of 1966. Observed feeding in the area for a month prior to capturo. Died shortly afterwards with no apparent cause of death and no body fat. Total body chlorinated hydrocarbon content: 52 mg. DDT* 40 mg. PCB* 1.0 mg. dieldrin* 1.0 mg. heptachlor epoxide. Total body lipid, 20 gm. * First year female trapped on the Texas coast in October. Lost at Ft. Mugu* California* the following January and was shot by a sportsman 3 weeks later. Abundant body fat. Total body content.* 7 mg. DDT* 0.6 mg. PCB, 0.05 mg. dieldrin* 0.17 mg. heptachlor epoxide. Total body lipid* 110 gm. ft First year female trapped on the Texas coast in October. Died shortly afterwards of heat prostration. 0vfa<'9 726700 WATER PCB-SD0000072498 Table II. PCB and DDT in prey species of Peregrine Falcons in the Gulf of California. Content in micrograms of whole bodies and eggs; concentrations in parts per million vet weight (W) or lipid weight (L). Species ^ N DDT P8 DDT ZDDE FCB ppm PCB DDT/PCB ppm Eared Grebe (13) Whole body 3 0.28,0.26, 97 12.1 see Black Petrel (10) Whole body Least Petrel (6) Whole body Eggs Fish Bat (3) Whole body 8 810 (685-1344) 3 99 2 30 (23-37) 7 25 (15-31) 9.2(W) 81 see 1.0(W) (0.90-1.14) 9.2 3.2(W) 83 t 84 0.71(W) 62 e 0.35(W) 9.3 3.1 (1.2-5.0) e 10 0.58 0.02(W) 43 (0.45-1.06) Craveri's Murrelet (2) eggs (one clutch) 2 Whole body, adult Whole body, adult 1 1 230 (c) (223-238) 37.1 295 39 (L) 80 0.31(W) 85 2.4(W) 85 ee see as ' 4.5(L) 8.7 0.039(W) 7.9 0.26(W) 9.2 Elegant Tern (1) Eggs Beeraan's Gull (1) Eggs 8 15.5 5.0(L) 90 (9.6-24.3) 3 195 (94-278) 48 (L) 95 e 1.5a) 3.9 (0.8-3.6) 8.1(L) 5.9 (3.5-11.3) ^ All specimens were collected in the vicinity of four peregrine eyries in Baja California. Numbers in parentheses are the number of remains of each prey species which were found at the eyries. Also found were remains of one cormorant. (Phalacrocorax bp.), one Bed Phalarope (Phalaropus fullcarlus). one Northern Pbalarope (Loblpes lobatus), and one Mourning Dove (Zenaidura macroura), but local specimens of these species were not analyzed. Eggs of least petrels, elegant terns and Heermann*a gulls were from different clutches. Eared grebe: Podiceps casoicus: black petrel Loomelanla taelanla; least petrel: Halocvptena microsoma: fish bat: Pisonvx vlvesj: Craveri's Murrelet: Endomvchura cravert: elegant tern: Thalasseus elegans: Heermann's gull: Larue heerroannj. ^ not measured. Interfering peaks on chromatograms. both eggs also contained 0.08 ppm dleldrin (lipid weight) and 0.17 ppm endrln (lipid weight). NEV 018650 726701 WATER PCB-SD0000072499 Table 111. PCB and DDT In the global ecosystem. Content In micrograms and . concentrations in parts per million wet weight (W) or lipid weight (L). Species White crapple (1) Black crappie.(2) Bluegill(3) Adllie penguin, ^ egp.s Western grebe, ^ breast muscle Fulmar (6) A B C Pink-footed(w7') shearwater Sooty shearwater (8) A B C Slender-billed (9) shearwater Ashy Petrel (10) Brown Pelican, eggs, Panama eggs, Baja Calif< N Total DDT Hg ppm ZDDE 1 1 1 5 0.78 (0.59-1.04) 1.83 (W) 6 2.10 (W) 6 5.5 (W) 6 0.128 (L) 74 26.4 (W) 5 PCB DDT/PCB Jig ppm -- 0.004 475 (W) 0.003 660 -- 0.005 1200 <0.044 jig/egg >18 -- 0.098 270 (W) 1~ 1 --' 1 10,475 1 2,000 1-- 1-- 1 1,265 1-- 3 2,158 (1644-2826) 6 59 (18-183) 53 (47-59) 0.41 (V) 76 3.4 (W) 89 17.5 0*0 96 -- -- 0* 3900 3.0 (W) 93 277 0.08 (W) 0.34 (W) 6.5(W> 5 10 2.7 0.42(W) 7.2 12,3 00 94 10.3 (W) 86 2.3 00 85 -- -- UK 1.200 10 0.9(W) 12 32.0 (W) 92 -- - 2.1(W) 15 59.3 (W) 95 389 (298-482) 9.8(W) 5.5 11.5 (L) 61 23.1 (47-78) (18-30) 1.55 (0.97 3.2) ( )10.0 1 81 10.4 (9.0-11.7) 6.5, 4.0 t Nev 01865JL 726702 WATER PCB-SD0000072500 Table III, continued I Frigatebird(1?* eggs, Panama 3 9.6,8.7,30.0 Brown Booby eggs, Panama 4 20.8 (16.4-24.5) Brandt's Cormorant('147) 17 eggs 326 Pelagic Cormorant eggs Cinnamon Teal^^ White-tailed Kite*17* eggs, clutch A 2 128 (125-130) 1 4340 4 11.4 (9.8-12.9) Unhatched egg B 1 5.1 Unhatched egg C 1 5.3 Clutch I> 2 8.3/egg Clutch E 3 10.2/egg Clutch F 4 31.9/egg Cooper's Hawk*1*** 1 8,500 Golden Eagle*1* egg 1 150 Osprey, Baja Calif.*2*** 6 127 (30-264) Merlin*21* 1 435 American Kestrel*22* see 88 8.4,5.7,84.0 1.1,1.5 0.4 8.2 (L) 89 12.2 4.8(L) (6.5-18.9) j7 -- 91 113 -- 2.9 -- 90 10.9 (W) 70 62 (48-75) -- -- 0.91 2.1 12 0.76 (W) 77 0.34 (W) 82 0.35 (W) 73 * 82 9.0 (L) 57 s 80 25,2 (W) 90 2.0 (W) 98 6.4 (5.5-7.8) ~ 1.8 0.84 -- 6.0 3.6 __ 1.5 4.3/egg see - - 2.0 4.0/egg ... ' 2.6 3.6/egg ... 8.5 -- 6.3 4.0 17.5 0.23(W) 8.5 55 (L) 85 (7.3,3.0, 103)(24, 7.0,19) 2.9 (V) 94 55.4 -- 8.5,10.1 1.3,11.2 9.7,11.1 0.39 (K) 12.7 Whole body, adult eggs, 2 dutches Black-crowned night heron (23) egg egg 1 5.1 0.044 39 6 2.4/egg 0.20 (W) 93 3.7 0.031 1.4 1.0/egg 0.09(W) 2.3 1 541 1 869 -- 89 330 -- 1.6 -- 99 23 -- 36 NEV 018652 726703 WATER PCB-SD0000072501 Table III, continued Western Gull^2*^ eggs, San Francisco Boy, 3 clutches eggs, Farallon Is. 10 clutches eggs, Baja Calif. 7 dutches Forster's Tern('25)* 88s Caspian Tera^12^ eggs, San Francisco Bay eggs, San Diego Bay Red Fhalarope('27) Common Murre ^2^ eggs Casein's Auklet^2^ Ancient Murrelee^33 Rhinoceros Auklet^33^ Mourning Dove (32) Bam Owl*33* ~hr eggs, one clutch cA T-- eggs., one clutch Meadowlark*3** 4 803 (632-1123) 10 412+102 -- -- 7 ` 385+230 ' 2 665 (598-732) -- 85 805 (580-1310) -- 1.0 89 136+55 3.0 97 45+30 9.1,10.5, 5.0,12.3, 10.6,10.7, 10.5 89 114 (91-137) -- 5.8 2 1269 (1216-1322) . _, 89 805 (660-950) 1.7 5 1430 (991-2430) 88 1010 (550-1600) 1.4 1-- 0.78 (W) 79 -- 0.10 8 6 1945 (932-3621) 151 (L) 90 558 (364-1010) 1-- 5.8 (W) 98 -- 1-- 1-- 0.75 2.7 90 97 ~ -- 2 12.0,33.1 0.19(W) 77, Hot 93 detected 3 27.7/egg 1.25(W) 95 10.4/ 2 143/egg 6.6 (W) 96 egg 14.4/ 2 21.2,448 0.18, 77, 3.3 (W) 93 egg 2.5,28.1 45 (l) 35 0.16 0.15 0.36 36 5 8 .ct 0.47(W) 2*7 0.66(W) 10 ... 8.4, 15.9 Unless otherwise specified, analyses were of whole bodies. Endrln and dieldrln were identified on the basis of retention times on both QF-1 and DC-200 columns. 1. Pomor.ls annularis, 284 gm.. Clear Lake, Lake Co., Calif. May 1968 2. Fotaoxla nigromeculatua, 212 gm., Clear Lake, Lake Co., Calif., May 1968. 3. Lepomis taacrochlrus, 229 gm., Clear Lake, Lake Co., Calif., May 1968. NEV 018653 726704 WATER PCB-SD0000072502 Table III, continued 4. Pygoacclla adeliae, Cape Crosier, Antarctica, October, 1967. 5. Aechmophorus occldentalls. Clear Lake, Lake Co., Calif., May, 1968. ' 6. Fulmarus elaclalla. A and B- Monterey Bay, Calif., Hov. 1, 1966. C: Point Reyea, Calif., December, 1967. Fulmars breed in Alaska. . 7. Puffinue creatopu8. Breeds in Chile. Collected in May, 1968, in the Gulf of California. 8. Pufflnus grlscus. Breeds in Hew Zealand and Chile. A and B: Monterey Bay, November 1, 1966. C: Gulf of California, May, 1968. KM: not measured. Interfering peaks. . 9* Pufflnus tenuirostria. Breeds in Australia. Monterey Bay, Dec., 1966. 10. Oceanodroma homochroa. FaralIon Islands, Calif. May, 1968. 11. Felecanus occldentalls. Panama eggs were collected on Isla Pacheca and Isla Pachequilla, Gulf of Panama, Feb. 1968. One egg contained 0.06 ppm dieldrin and 0.06 ppm endrln, another contained 0.16 ppm dieldrin and 0.07 ppm endrin (lipid weight). Baja California eggs were collected at Bahia de los Angeles, March, 1968. One egg contained 0.24 ppm dieldrin and 1.13 ppm endrin (lipid weight). ' 12* Fregata roaenifleans. Isla Pacheca, Panama, February, 1968. 13. Sula leucogaster. Isla Pacheca and Isla Pachequilla, Panama, February,1968. Two eggs were analyzed for dieldrin and endrin. Dieldrin: 0.08, 0.18; endrin: 0.06 and 0.011 ppm (lipid weight). 14. Phalacrocorax penicillatus. Farsllon Islands, May, 1967 15. Phalacrocorex pelaglcus. San Mateo Co., Calif. 16. Arms, cyaqoptera. San Diego, April, 1968. Adult male. 17. glanus leucurus. A: Contra Costa Co., Calif. April, 1968. B and C: Contra Costa Co., May, 1968, 2.and 3 young raised, respectively. D: abandoned, Contra Costa Co., May, 1967. and ?: destroyed nests. Contra Costa Co., . March, 1968. - 18* Acclplter cooperii. Balboa Park, San Diego, Feb., 1968. First year female, died of trichomonai8i8. 79* Aquila chrysaetos. San Lui3 Obispo Co., Calif. April, 1968. Unhatched egg in nest where one young was raised. Egg also contained 4.7 mlcrograms of dieldrin, 1.9 mlcrograme of heptachlor epoxide, but no endrin. 20. Fandion haliactua. Gulf of California, March, 1968. One egg also contained 0.10 ppm dieldrin and 0.25 ppm endrin (L). 21. Falco columbarlus. Immature, Utah. December, 1967. . 22. Falco aparveriua. Adult was road kill, Mendocino Co., Calif., December,1967. Eggs frew Davis, California, 1968. 23. Nycticorex nyctlcorax. Eggs from different clutches, San Francisco Bay, MayTTSSr -- --------------- 24. Larue occldentalls. Standard errors, 95X confidence limits. 25. Sterna forsterl. San Diego Bay, May, 1967. 26. Hvdroprogne caspia. 1967. 27. Phalaropus fulicarlus. Monterey Bay, November 1, 1966. 726705 WATER PCB-SD0000072503 . Table III, continues I 28. JJxift aalee. Farallon Islands, Vay, 1S67. 29. Ptvchoranphua aloutica. Farallon Islands. April, 1966. 30. Synthllboraaphus antiquum. Monterey Bay, Nov. 1, 1966. 31. Cerorhlaea monocerata. Monterey Bay, Nov. 1, 1966. 32. Zenaidura macroura. San Diego, July, 1968. 33. Tvto alba. Clutch A from Contra Costa Co., Calif. March, 1968. Clutch B from Yolo Co., Calif., April, 1968. 34. Sturnella neelccta. Davis, Calif., December, 1967. NEV 018655 726706 WATER PCB-SD0000072504 Table IV Increase of oestradlol metabolism by pigeon liver homogenates from birds treated with various chlorinated hydrocarbons Control DDE (40 mg/kg) DDT (40 mg/kg) PCB (20 mg/kg) Amount of polar metabolltles formed In mpnoles 29.3+ 6.5 76.2 + 13,1 93.1 + 11.2 160.0 + 10.5 Each figure Is the average with standard deviation of a group of four birds. In all cases 500 mpaoles of oestradiol-6,7-T (500 mc/mM) was present In the Incubation mixture. Incubation time 30 mins, weight of microsomal fraction used was 300 mg. All chlorinated hydrocarbons were injected i.m. Into the pectoral muscle 7 days before sacrifice. ` ov b*b 726707 WATER PCB-SD0000072505 CONTROL Figure 1. Chromatographic separation of oestradiol and its metabolites. The. large peak is unaltered oestradiol. * NEV 018657 726708 WATER PCB-SD0000072506 References 1. Ratdlffe, D. A., Nature 215, 208 (1967). 2. Hickey, J. J. and Anderson, D. W., in preparation. Anderson, D. W., personal communication. 3. Sinkles, K., Calcium In Reproductive Physiology (Relnhold, New York, 1967). 4. Welch, R. M., Levin W., and Conney, A. H., Chemical Fallout. First Rochester Conference on Toxicity, in press (1968) 5. Hart, L. G., Schultlce, R, W., Fouts, J. R., Toxicol. Appl. Pharmacol. 5, 371 (1963). 6. Hart, L. C., Fouts, J. R., Kaunyn-Schmledebergs Arch. Exp. Path. Pharmnkni. 249, 486 (1965). 7. Conney, A. H., Welch, R. II., Kuntzman, R., Burns, J. J., Clin. Pharmacol. Therap. JJ, 2 (1966). 8. Conney, A. H., Pharmacol. Rev. 19, 317 (1967). 9. Kupfer, D., Residua Rev. 19, 11 (1967). 10. Gerboth, G., Schwabe, U., Arch. Exp. Pathol. Pharmakol. 246. 469 (1964). 11. Glllett, J. W., J. Aer. Food Chem. 16, 295 (1968). 12. Schwabe, U., Arraelnlttel-Forsch. 14, 1265 (1964). 13. Peakall, D. B., Mature 216. 505 (1967). 14. Ratdlffo, D. A., British Birds 51. 23 (1958). 15. Ratcliffe, 0. A., Bird Study 10, 56 (1963). 16. Ratcliffe, D. A., Bird Study 12. 66 (1965). 17. Ratcliffe, D. A., Bird Study 14. 238 (1967) 18. Hickey, J. J., ed. The Population Bloloav of the Peregrine Falcon (University of Wisconsin Press, in the press). 19. Beebe, F. L., Condor 62, 145 (1960). NEV 018656 726709 WATER PCB-SD0000072507 20 Cade, T. J., White, C. M., and Haugh, J. R., Condor 70, 170 (1968). .21 Enderaon, J. H.,' and Berger. D. D., Condor 70. 149 (1968). . Jensen, S., Mew Scientist 32. 612 (1966). . Wldmark, G., J. Ass. Off. Anal. Chem. 50. 1069 (1967). Holmes, D. C., and Simmons, J. H., and Tatton, J. O'G., Nature 216. 227 (1967). Risebrough, R. W., Chemical Fallout. First Rochester Conference on Toxicity, in the press (1968). 26. Erro, F., Bevenue, A. and Beckman, H., Bull. Environ. Cont. Toxicol. 2, 372 (1967). 27. White, C. M., Auk 85, 179 (1968). 28. Jefferies, 0. J. and Frestt, I.. British Birds 59. 49 (1966). 29. Risebrough, R. W., Menzal, O. B., Martin, D. J., and Olcott, H. S., Mature 216, 589 (1967). 30. Wurster, C. F. and Wingate, D. B., Science 159, 979 (1968). 31. Walker.. L. W., personal communication. 32. Keith, J. 0. and Hunt, E. G., Transactions of the Thirty-First North American Wildlife and Natural Resources Conference (Wildlife Management Institute, 1966). Holden, A. V. and Marsden, K., Nature 216, 1274 (1967). Aldrln. Dleldrln, Endrin (A Status Resort). The Shell Chemical Company,1967. Riaabrough, R. W., Hugget, R. J., Griffin, J. J. and Goldberg, E. I)., Science. 159. 1233 (1968). 36. Technical Bulletin/PL-306. Monsanto Chemical Company. 37. Chaaal, A., Koransky, W., Portig, J., Vohland, H. W. and Kleapau, I., Arch. Exntl. Pathol. Pharmakol. 249. 1 (1964). 38. Jones, R. E. and Leopold, A. S., J. Wildlife Management 37. 221 (1967). NEV 018659 726710 WATER PCB-SD0000072508 i 39. Mayhew, W. W., J. Wildlife Management 19, 36 (1955). 40. Buckner, G. D., Martin, J. II. and Peter, A. !!., Amer. Journ. Phvslol. 71. 543 (1925). 41. Buckner, G. D., Martin, J. H. and Peter, A. M., Ky. Agr. Expt. Sta. Bull. 291 (1929) 42. Nicolaysen, R. and Eeg-Harsen, M., Vitamins and Hormones. 11, 29 (1953). 43. Coates, M. E. and Holdsworth, E. S., Brit. J, Nutrit. 15, 131 (1961). 44. Hart, E. B., Steenbock, H., Lepkoveky, S., Kletsien, S. W. P., Halpin, J. G., and Johnson, 0. N., Jour. Biol. Chcm. 65, 579 (1925). 45. Simkiss, K., Biol. Rev. 321 (1961). 46. Clavert, J. and Benoit, J., C. R. Soc. Biol.. Paris. 136, 509 (1942). 47. Ryes, P. and Potter, f. S..Anat. Rec.'6Q. 377 (1934). 48. Common, R. H., J. Agric. Set. 23. 555 (1933). 49. Gardener, 0. E., Phillips, W. E., Mow, V. A. end Common, R. H., Nature 170. 80 (1952). 50. Pleck, P. A., Miller, W. S. and Ward, C. M., Proc. Biochem. Soc. 90. 33 (1964). 51. Thayer, G. H., Bird Lore 6. 47 (1904). 52. The major support was provided by the National Science Foundation Grant GP 6362. Work in Baja California was supported in part by the National Science Foundation Grant GB 7600 to the 9an Diego Society of Natural Histrry. The oestredlr-1 degradation studies were supported by the United ' 3 Public Health Service Grant E.S. 00306. Pure p,p'-DDE was kindly svpp'.ied by the Federal Drug Administration. Aroclor samples were kindly scp^lled by the Monsanto Chemical Company. We thank P. L. Ames, M. S. Covltsr, H. L. Davis, Mama Dias, R. E. Feeney, Dr. Luis Howell R., J. Jehl, W. Kerr, F. MacIntyre, Ing. E. Mayo, Sr. R. Marmolejo L. and other NEV 018660 726711 WATER PCB-SD0000072509 authorities of the United States of Mexico, E. McMillan, D. Kendola, the Morro Bay Audubon Society, H. S. Olcott, H. J. Peeters, A. C. Rlsser, R. L. Rudd, Janos Saabo, Lie. Dario Tovar, I>. V. Walker and R. Winslow for their assistance. NEV 018661 ?267l2 WATER PCB-SD0000072510 Monsanto 1- ,wiy. b. Richard - Research Center September 9# 1969 DEFENSE OF AROCLOR - I r. riAJi&i TO ,S Wheeler - EUHES * ?. Bedgea.. PHODG Bet. l fen B2ER0 general Policy . Make the Govt., States and Universities prove their ease, but avoid aa much confrontation aa possible. Comply and work with public officials to meet or*exceed requirements ahead of time. Adverse publicity and competition are the real weapons. . Analytical fin Air * - Which Aroclors are present? Where?! for ArocTor tin Water- Which l q, . .. (in Animals cinterfere? jAg Beep track of how much contamination - which sources. p~ r~ ove -B- l-oharafu--l - Let Govt, prove its ca^ se, on case by c| ase \ Monsanto Visit-govt. Blolabs * in search of toxicologic ( experiments and evidence * vs. Aroclors to keep up . progress. Monsanto Prove Bloharmless - Limited work at Ind, Bio-test - Safe" toxic /man level for / mammals via (fish Bats Seek evidence of Blc thickens da riah Question evidence ag us Question shrimp tcxic . especially other tc chemicals. . If Aroclor bad, oth must be worse. Probable Outcome Ve can prove some things are OK at low concentration, give Monsanto some defense. . . . We can't defend vs. everything. Some animals or fish or Insects will be harmed. . Aroclor degradation rate will be slow. Tough to defend r^alnst. Higher chlorination compounds will be worse ..t lower chlorine compounds. . *,, . ^ ,, , 84174 Therefore we will have to restrict uses end clean-up as mieh^aa vg can, starting immediately. 1 H PLAINTIFF'S . EXHIBIT! * CV Q "7 J MON 0209 I VS-JSJ WATER PCB-SD0000072511 or 3 -a- Therefore ve will have to work for alternate products in end use appUentlonss for Aroelor production facilities. Clean Tip Arodors and substitute products where necessary and wen required, before"fSrtata of publicity and competitive activity over whelm us. Water Pollution aeena to be first Issue Arodor product la refractive, will settle out on solids sewerage sludge - river bottoms, and apparently has a long life. Tlorlda or gulf Coast -- Arodor 125* - Aroelor 1260 pres< ' ---------- Issue. *0-200 ppb - causing problem at ?ensacola (Monsanto} in plant effluent-causing " with shrimp. - can't risk shut-down of plant. federal and State can extrapolate to other plants la . Gulf area. San Francisco - Aroelor 125* and 1260 . r Beperted Aroelor to be present In San franelaee lay. Jteported to be thin egg sheila In birds - - let of screaming - . Great Lakes Warf studies on DDT m . Aroelor 125* will be found! Arodor 12*2 will be found? Air Pollution - Possible spread - but less of an Issue right now. '* Analytical work more difficult. ; <^1 Direct Contact with SPirwowdluHcett y-i Doesn't seem to be an Issue - except for food heat transfer Ve don't believe Aroelor la being used as carrier for Inaeetldda - sprayed around - . . . * 1 Ve are not positive but most uses are "closed" systems-! or products used In solid plastics, or adhesives, or \\ sealants. -* s_. - . . . :.$*?: ' MON 0210 4 0079 WATER PCB-SD0000072512 ?. Fluids Product - Hydraulic fluids * Air Compressor fluids Heat Transfer: ' Cspseltor fluids Transformer fluids Possible Pollution by ?olW ? Customers Plant Operation by Custoae TMi lulug external Tee, leakage external In* leakage external Tes, leakage from plant - Scrap materials. *o. Should he clean. Tes, Reworked trana* formers Possible ; Johnson Hofc Castings. Leakage int< Leakage int< In product l closed for < In product t closed for e Capacitors can go to land fill dumps. Probably not burned, in A1 containers. *+ Heed to take eve of Aroclor in discarded transformers. Product could be drained and reworked. Probable Conclusions Air. Cospressor fluids Hydraulic fluids * ; Product could be esnght at sachlnee but will take a lot of clean-up work with castewers. Yill hare to have replacement product - with lass-sensitive components, York from this base on clean-up to prevent more pollution problems. e* Must expect * shrimp" experiments. Vest Florida State, to be "aired" sometime soon; next few months. This will lead to bad publicity and competitive action vs. all Pydrauls. . ' - . * * * Ye will have to try to confine to Aroclor 125* end Aroolor 1260. v * *. . 4 0080 MON 0211 WATER PCB-SD0000072513 Vt will have to taka action before that time. Gulf Coaat . Action ir. Richard Fallon/ Richard Be able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in 2 month's time before Nov. 15# 1969. Eave trial product in hands of Gulf Coast accounts and distributor before Bee. 15. Fallon Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS___ for insurance. Richard/ , Suggest possible substitution of Aroclor 5442 for Aroclor 1254 in hydraulic and compressor blends. 2. "Wheeler Judges lower order of toxicity and solubility for 5442 series. Rave to test product in pump test for deposits. Fallon/ Suggest field trials of our own all-phosphate Richard ester. Fallon/ Vork with large customers to clean-up streams. Kuhn/ Bring in Findett as mfg. partner in the recycle Kountx business. Get money out of recycle operations. Inland-Waterways- . Vheeler/ Be close enough to Great Lakes studies to Judge Richard situation. Are there animals which are being * affected by the concentrations found? Richard Be prepared to replace Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and In air compressor fluids. Richard Be prepared to replace all Aroclor 1242 or 124? in 6 months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. Heat Transfer ^, Fallon/ Roush/ Xounts Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. . Fallon/ Roush Need to replace PR especially in food or sensitive product areas whre the product is getting into water. Sec dish washer compounds. See letter 2. Wheeler to j; Fallon. . Ve have possible rep cement products in Themlr.: : . mom nviv Therr.ir.`._ llli>* M'l ll WATER PCB-SD0000072514 Action Kuhn . Kuhn/ Fallon Try to assure adequate production of Theminol ' 66 In face of decreased Aroclor production. Ea and terphenyl supply mty beecmt short. Switch customers to Thermlnol 55 or Therainoi 66 ahead of pollution problems in customers plant. Work with customers on plant and dumping practices. Findett already set up to rework. Need to make them a manufacturing aim. Ve get sale of recycle-rework fluid.* Capacitor Capacitor plants have re Fluids purification and recycle systems but up to 5* of product can be lost by poor plant producers and off-quality material. Mkt. Benignus/ Bryant 556 of production could be - * tr / Iff lbs/year. This Is a big M?ijSms 1088 for the typof rg-Hooges pollution we are trying now to guard against. ,, Capacitor products Enclosed in A1 or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capael tor products. Recommend we try to save this product fo: a time. Action Eng.,TSDPlant Pol lution Con trol Bodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. Ve have set-up to accept material for rework into . hydraulic fluid but this relocation is not a satis factory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical. Must start now to get con trol of off-grade material. Recommend replacement future Aroclor busine with other products. Rave 2 years. Action Monsanto must help plant dean- ' up of customer plants decantation* - coalescing, adsorption, dis posal of adsorbent or recycle of adsorbents. .. Konsanto badly needs "know-how" for clean-up. * Monsanto should seek Govt, contract money for clean-up research, (See me R. Binnina. X>. Nelson) unk 1 /v 4 0082 WATER PCB-SD0000072515  Transform*!* Action * ` Benlgnua/ ` Bryant - Transformer Plant ean operate In a clean, efficient manner with recycle of off-grade Aroclor. . Should advise disposal of . filter element materials so aa to minimize chance of water pollution. Incinerate '-'or dispose. * . Reworked transformers pose a threat if the Aroclor Is dumped Into a water stress. Product transform can remain dose no exposure fer Should try to ret business by clear, by education of a tomers. too. Action Benlgnus/ Bryant Should try to minimize chance of dumping "old" fluid by re working and by educating co. shops and collecting product for rework or disposal. Dalton Is set up In England to rework electrical grade fluid. Xuhnyfcountz Plndett? Heed rework facility here +' disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Krummrlch or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals / they choose to find harmed. / Action - Take steps to see that every precaution Is taken to prevent Aroclor entering water streams. Try to reduce to ppb level. . * P.Bodges-Seek a Govt, contract on adsorption and Incineration TSD cycles - MAC. . Eagrg.- . Eountz Take samples of streams and river water and mud . ' evidence for before and after clean-up.* Samples *. '. can be stored for further analysis If we* can11 *. - keep up current with analytical determinations. '. * Apply Monsanto elean-up methods to oustomer plant ei**a up and pv$cdurt*, . 0 0083 WATER PCB-SD0000072516 Action - Engrg. fc Mfg. . Kountz end Kuhn Evaluate liquid Incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at l-4g" lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. .. Hydraulics 20% of 4 lbs Beat Transfer lOJf of 2fT lbs Capacitors ** * 5% of 2CfT Transformers 5% of 15JT . 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. it Mfg TSD Kountz k Kuhn Set up an incinerator to handle Aroclor dis-\ posal - preferably one which will handle \ solids such as muds - slurries as well as ; liquids. Have in operation within 12 months. Ideally have incinerators available different/ sections for disposal. J Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio Test Continue studies to establish PDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Rework with R. Keller-S. Tucker the number of samples which are to be analysed for Aroclor in tissue. Try to see if Aroclors are changed metabollcally. Does concentration level off, decline if feeding is stopped? v Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Aroclor levels of toxicity, then we will have to have, biological studies on these species to con firm or deny adverse findings. "* JL 4 0084 WATER PCB-SD0000072517 # - o 4 . Biodegradation Studies ! " ' * Set up rate of biodegradation studies with Xnorganlo Dlv. on Arodor 1242 vs. Aroelor 1254 * Aroelor 5442 vs. Aroelor 5450 Swisher Chlorinated diphenyl ether Chlorinated paraffin vs. ehlorlnated naphthalene * ' Chlorobrono Aroolora 1242 and 1248 . Baxter Contact Baxter and Lidgett at HCL regularly for results on Lidgett Aroelor degradation. They are reported to he moving on MCL laboratory experiments. Establish eontaet with ehlorophenol degradation studies of Cellu-Chea Group. .- * VRRsxos V. R. Richard 4 ' 4 0085 WATER PCB-SD0000072518  m- * \ / 4 7i. OF MEETING Or THE CORPORATE DEVELOPMENT COMMJT^rj November 17, ]96d Present: -V . -. Messrs. J. H.* H. J. a. j. i. E.-J. C. H. J N. " 3ock, Chairman S:b 1 * Sck Gin is Putaall Sommer . Ehlars, Secretary ORGANIC DIVISION. LAV AND MEDICAL DEPARTMENTS -- REPORT ON POLY" CHLORINATED BIPHENYLS Present: Messrs. C. J. Smith, J. Mason, T. K. Smith. H. S. Bergen, - . J. E. Sprlnggate, R. E. Kelly, E. P. Vhaalar, Rodney --x Harris, Jr.. D. V. Millar, W. C. Robinson I*--] Monsanto's worldwide Aroclor bus 1 ness_amounts to 104 JT lbs./yr., * 70r. used In functional fluids and 34 M* tn plasticisers. This represents $22 M In sales. Products range from monoch1orobiphenyI 11 PLAINTIFF'S EXHIBIT Mil STR C015<G " 20 WATER PCB-SD0000072519 78. j to decachlorobiphenyl, terphenyls, and chlorinatad terphenyls Production location* arc at Anniston, Alabama, Sauget. Newport, U.K. and Yokkalchl, Japan. . * fnvlronmantal Aspact* C. P. Whaalar Tha 5 and.6 chlorinatad biphenyls (Aroclor 1254 and 1260} hava baan found at Itaitad locations In watar. In birds and soma forms of aquatte Ufa. Recent indications ara that such biphanyls may affact raproductlon of fowl Ufa and aay ba toxic to shrimp. Thasa products ara not toxic from tha acuta standpoint to man or fish but thara Is soma avldanca of ecological buildup In cartain watar deposits, in fish and ultimately In bird Ufa. - Aroclors 1248 and lower In number ara believed to ba biodegradable but this has not baan conclusively established as yet. . * Legal Aspects - D. V. Millar Tha law In tha field of manufacturer's liability Is changing rapidly. Although tha law Is unsettled, tha present general rule is that if a manufacturer knows or should know that a product of Its manufacture may causa damage If not properly used, ha has a duty to give adequate warning to customers and users. Recommendations from tha legal standpoint consist of 1. Taka steps to Insure that PCS'* ara contained and not dis charged in plant effluent. .- 2. Provide adequate warnings to customers and users. Including advice as to disposal methods. 3. Establish testing program to determine preelse effects of PC8's on birds, aquatic Ufa and animals and to determine the possible eseape of PCB's from plasticizers. Plan of Action - H. S. Bergen and J. E. Sprtnggate The availability of alternate products to satisfy customer requirements was reviewed. Main problems are that no replacement product Is available for capacitors and replacement produets for other uses pose a pollution problem. tn plasticizer uses, evidence Is not available as to whether Aroclors escape from end products, either through leeching or by dispersal I'n burning. . *` 4 . .* \ The .recommended plan of action Is to establish a tailored program for each business -group-and each customer market situation to assure that the loss of PCB's In the environment. If any, is minimal. . ., STR 001541 WATER PCB-SD0000072520 73. 1. Appoint a Project Manager - responsible for the overall management of the Aroclor pollution problem. He would be assisted by a Task Force from members of each business group plus Medtcal, Law, Engineering and Manufacturing. `2.. Notify all Aroclor customers of PCS problem. 3* Reduce and affectively control PCS effluents from Monsanto plants. .. 4. Educate customers on need to reduce and effectively control PCB effluents at their plants. 5. Develop and implement new packaging systems for Aroelor 1254/1260. . 6. Introduce to market, replacement products for Aroclor 1254/1260. * 7. Continue and expand biodegradation test program with Aroelor series, particularly 1242, 1248 and 1254. ' 8. Continue toxicological test program, 9. Accelerate present analytical test program. ` . 10. Determine feasibility and cost of eliminating 5/6 Cl. in Aroclors 1242 and 1248. 2 11. Study incineration products. 12. Develop business plan to offer: - Monsanto Fluid Reclamation and Recovery.with Enviro Chem. (Reclamation already under*way at Findett.) Cost of this program is estimated at approxlmataly $400M SARE and S7.00M capital to change equipment. * Conclusions: in light of the reeent and developing evtdence of a possible threat to cartain speeies of bird and aquatic life, we should plan' to discontinue the manufacture*of Aroclors 1254 and 1260.* The Olvlslon Is instructed to develop a program to discontinue these products and report this to the Committee. The status of Aroclor 1242 should continue to be tested to determine whether It contributes to this problem. Other products which mi$ht be involved should also be examined. * (Excerpt to Messrs. H. L. Mincklar, Rodney Karris, Jr., R. E. Kelly, T. K. Smith.).' SIR 001542 WATER PCB-SD0000072521 -* i'' .1 '<,AVi#s il`Vv' 1 -j# .% * - .z > r't >t * # * a %es- i* R. Richard - Fesearch Center t*n sMet TO : `March 6, 1553 AEGCLOr. '..'ILELIfE ACCUSATIONS E. Wheeler - EUHES H. Bergen J. Sprlngate V. Schtli: D. Olson R. Kelly J. Garrett P. Hodges ?. Pari: R_ Keller ` ~E. Tucker KBERG VJSCMA EOLSO REELL JGAaa PKOEG ppare JFQ JFQ Risebrcugh ir. a recent paper "Nature" , Vol. 220, Esc. attacked chlorinated biphenyls in three ways: i9se (1) a pollutant - widely spread by air-waterj therefore an uncontrollable pollutant. (2) a toxic substance - with r.o pemi ssible allowable levels causing extinction of peregrine falcon by induced hepatic enzyr.es v.-hich degrade steroids upsetting Ca metabolism lead ing tc reproductive weakness, presumably through thinner egg shells. (5) a toxic substance endangering nan himself; implying that the peregrine falcon is a leading indicator of things to eocte. As outlined in Science ,Vol. 153, Pg. 5A8, Environmental Dafsns* Fund (ELF} is attempting to write new legal precedents in conservation law by hearings and court action. In the Wisconsin case, water quality standards are at issue. "A substance shall be regarded as a pollutant if its use results In public health problems or lr. acuta or chronic (injury) to animal, plant or aquatic life". Wisconsin is one of 7 states which now have federally approved quality standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration's Water Quality Standards Branch, D1/2 would fit the definition of a pollutant upon a shewing that it is haiinful to aquatic life. These people in SEP are saying we eust not put ctrecs on any living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group Is pushing hard on the extension of the word harmful. They claim "enzyme ^ inducer" activity is the real threat of BET and PCB's anc are using 7 these arguments to prove that very snail amounts of chlorinated .*2 hydrocarbons are. "harmful". ` Monsanto is preparing to challenge certain aspects of this problem s but we are not prepared to defend against all of the accusations. 'd&M'A'' ' will eventually knew where any pollution is taking place the extent of the pollution. W - mPLAa ItNarTIFF'S PLAINTIFF'S EXHIBIT ^PLAINTIFFS ^EXHIBIT - EXHIBIT - 28 MON 0125 WATER PCB-SD0000072522 E. Wheeler March 6, 1^69 (b) We are not prepared to defend ourselves against the accusa tions cade of enzyme and hormone activity, the Isolation of enzymes or metabolic produets, the indirect accusation of cancer, or the splitting of genes, when this accusation is made. Whether we can defend this route or not needs further discussion. (c) Through the Industrial Bio-Test program we are to establish the long term allowable Units of chlorinated biphenyls fcr certain birds-fish-animals by feeding experiments, pathologi- * cal examination, and tissue analysis for chlorinated biphenyls. Vc nay be able to answer reproductive ability in scue animals. DET has been under attack for sene years because of its chlorine content, its persistent ability to be identified, and the wildlife problems attributed to it. We will still be under the sane attach by the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where doss this leave U3? Under identification and control of exposure - we will be able to identify and analyze residues as well or better than anyone In the world. We will probably find residues other than DET and ?C2a. We will probably wind up sharing the blame in the ppn to ppb con centration level. We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operations. We ca wo^k fr minimum exposure in mnufacture and disposal of capacitors, transformers and heat transfer systems, and*minimize losses fcr large hydraulic users. But, we can't easily control hydraulic fluid losses in small riants. It will be still more difficult to control other end U3ts such as cutting oils, adhesives, plastics and KIR papsr. In these appli cations exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl is shown to have sotie long term enzyme or hormone activity In the ppm range, the appli cations with consumer exposure would cause difficulty. Riscbrough has taken known Aroclor samples and elalm3 to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which . have exposure problems. Since Bisebrough'i* paper in "Nature", See. 1SS3 has Just been published, it is timely, perhaps imperative, th't this pauer and its implications be discussed with certain customers. This is a rough one because it cccld mean less of business on crpty and false claims by Eisetrough. Well prepared discussions with Ino. Bio-Test, Monsanto biochemists. MON 0126 5 GOV V . WATER PCB-SD0000072523 2. Wheeler -3- Karch 6, 195= position of DDT manufacturers should be determined as s guide. We are being accused of the tame things attributed to DDT. I have written this nemo to clarify some of the issues. Hay I please have comments. Thanks, . as Att. W. R. Richard . _MON. 0127 . 5 0 0 7 uu ' WATER PCB-SD0000072524  -. { ) . Ei P. Wheeler - St. Louis October 21, 1968 Polychlorinated Biphenyls In the Environment . 1 I. W. R. Richard . Y/RICH C. Payton - CPAYT H. Bergen - HBERO W. K. Johnson - WJOHN 4 Attached 1b a Xerox copy of a technical paper which Scott Tucker and I picked up In Washington recently. This was provided us by Donald A. Spencer of the National Agricultural Chemicals Association. Mr. Spencer requested that the paper be held "confidential" until such time as it may be published. Spencer indicated that If this paper were distributed one of his principal "sources" would refuse to give him prepublica tion information in the future. Risebrough's presentation (the attached) was made at a meeting of 20 to 30 toxicologists held at the University of Rochester in June. The meeting was billed as "The First Annual Conference on Toxicology" and was underwritten presumably by the AEC which has had contracts at Rochester for many years. Attendance was by invitation only. ' The meeting dealt "exclusively" with pesticides with about one-third of the papers relating to mercury. As far as Spencer knows the papers, including the attached, will undoubtedly be printed as proceedings .of the conference although I suspect individual authors were given permission to publish elsewhere. ** In a few words, Risebrough has found PCBs along with chlorinated pesticides in a number of species of fish and birds along the California coast as well as In waters off Baja.. California and Central America. He further reports PCB in fish from the Channel Islands and Puget Sound. No PCB was detected in the liver of tuna taken in the Galapagos Archipelago. Scott Tucker is going to scrutinize the analytical aspects and particularly the validity of some of the assumptions made by the author. cs Attachment . Elmer P. Wheeler . / NEV Ho 732171 WATER PCB-SD0000072525 c(_ Mf '4* ^^ vC' (o<? re ^<r^c//"//",J" V .^f--------- --- . Ut{ .. V ^y-T-Vi C //-j/>< c/ - . CHLORINATED UYDU0CARR0v',S IN' MARINE ECOSYSTEMS ` /0/yX- R. W. nicsbrough . Institute of Marine Resources Department of Nutritional Sciences University of California, Berkeley ABSTRACT .. 'Polychlorinated biphenyls, vhich are widely used os plasticizers and in the manufacture of many industrial product::, and the DDT compounds have been found to be widely distributed in marine ecosystems . of the Pacific Ocean. Marine birds contain higher concentrations than fish; tissues of the Peregrine Falcon have contained the highest concentrations which have been so far recorded. The polychlorinated biphenyls have nnt yet been detected in samples of airborne particulates but their observed distribution in the sol^indicates that they are dispersed by wind currents,. Their effects upon natural peculations, including man, are as yet unknown. The DHT compounds .arc also . accumulating in the sea and are present in highest concentratiorjs in marine birds. Their distribution indicates that coasrn-? areas ard not the primary-sources of contamination of thepelagic. species. A quantitative approach to the problem of aerial transp-irt of pesticides to the sea has been made by analysing the pesticide content of airborne particulates. The results indicate that wind transport can account for the observed distribution of DDT 'onpounds in the California waters and that* the amount of pesticides entering the ' tropical Atlantic As fallout from the Northeast Trades is comparable to that entering the sea from a major river system. REPORT 1 K The accumulating evidence that no part of the world is now fvt- of pesticide residues, the products of atomic explosions, or of a variety of industrial pollutants has produced subtle but profound changer in our conceptu of remoteness, isolation, and cf our own.position in the world-wide ecosystem. There has 'ecer been any " questien'that local ecosystems may be irreversibly changed by the introduction of synthetic chemicals, whether these Introductions be purposeful or incidental. The sea is the dominant feature of the vorld-wida ecosystem. The accumulation of significant amounts of several pollutants In marine organisms, pollutants vhich are non-polar and tncrefore water-insoluble but lipid-soluble, not only elicits an uncertainty about the long-term utilization cf the sea as a source of human food, but has suddertly raised the question of the ultimate survival of a number of species of sea birds. These comprise a very large fraction of the world's wildlife and doubts about their future wouid have been considered preposterous and untenable only 3 or A years ago. .* * * ` . 4 , * * .* , * r ; '* ,, . * nev 022111 732172 WATER PCB-SD0000072526 UiJ fr e yr?'tz v " CHLORINATED HYbROCARBOi'T IS' MARINE ECOSYSTEMS r R. W. Ri^-sbroogh . Institute of Marine Resources Department of Nutritional Sciences University of California, Berkeley ABSTRACT Polychlorinated biphenyls, v/hich are widely used as plasticizers and in the manufacture of many industrial products, and the DDT compounds have been found to be widely distributed in marine ecosystems of the Pacific Ocean. Marine birds contain higher concentrations than fish; tissues of the Peregrine Falcon have contained the highest concentrations which have been so far recorded. The polychlorinated ' biphenyls have n^t yet been detected in samples of airborne particulates but their observed distribution in the indicates that they are dispersed by wind currents.. Their effects upon natural peculations, including man, are as yet unknown. The DDT compounds .are also accumulating in the sea and are present in highest concentrations in marine birds. Their distribution indixates that coastal areas arc not the primary sources of contamination of the`pelagic, species. A quantitative approach to the problem of aerial transport of pesticides to the sea has been made by analysing the pesticide content of airborne particulates. The results indicate that wind transport can account for the observed distribution of DDT 'ompounds in the California waters and thao the amount of pesticides entering the tropical Atlantic's fallout from the Northeast Trades is comparable to that entering the sea from a major river system. REPORT The accumulating evidence that no part of the world is now ten- of pesticide residues, the products of atomic explosions, or of a variety of industrial pollutants has produced subtle but profound changer in our concepts of remoteness, isolation, and of our .own.position in the world-wide ecosystem. There has ">o:cer been any question"that local ecosystems may be irreversibly changed by the introduction of synthetic chemicals, whether these introductions be purposeful cr incidental. The sea is the dominant feature of the world-wide ecosystem. The accumulation of significant amounts of several pollutants in marine organisms, pollutants which are non-polar and tncrefore water-insoluble but lipid-soluble, not only elicits an uncertainty about the long-term utilization cf the sea as a source of human food, but has suddently raised tks question of the ultimate survival of a number of species of sea birds. These comprise a very largo fraction of the world's wildlife and doubts about their future would have been considered preposterous and unt.e.nahje only 3 or A years ago. NEV 022118 732173 WATER PCB-SD0000072527 - if perhaps tecauscC.^sh kills have provided the mos -dramatic evidence of / t 4 / // / i/ /apnedsteiclsidewehecorenthaamveinaftrieoqnu, epnetlsyticciodnesisdtiesdtriobfutmioonnitsotruindgiesthein the United Stales levels in major river systems [2,7}. In spite, of the low solubility of chlorinated hydrocarbons in water [4], their tendency to pass into the vapour phase [16,1,5,'6,12], their persistence, in soils [3,10,18], and their presence in very low concentrations in some streams draining areas of intensive application [17], rivers do transport large amounts of stable, persistent pesticides to the sea. A large proportion of these pesticides are adsorbed to silt particles which are p.'wt of the runoff from areas of application. Thus, the Sacramento and San Joaquin rivers, which drain the Central Valley of California, one of the most -heavily pcsticided areas of the world, annually bring about 1,900 kg of chlorinated hydrocarbons into San Francisco Bay [2,21], and the Mississippi contributes about 10,000 kg of the GUlf of-Mexico [7,21]. . . When the Institute of Marine Resources began a study of the distribution . of chlorinated hydrocarbons in marine fish, we expected to find, therefore, --much higher levels in the fish from San Francisco-Bay-than-in-the-fish "from the Pacific Ocean [24]. The data of Table I, however, show that collections of - --the Northern Anchovy and of the English Sole from the coastal tvaters contained as ouch as or significantly more total BBT residue .than did the collections from San Francisco Bay. Total DDT concentrations were highest in the collection from waters off Los Angeles, but anchovies from the Channel Islands area off Port Huencme also contained significantly more residue than the anchovies of San Francisco Bay. Since no major river system enters the Pacific Ocean from Southern California,' the source of these pesticides could not be agricultural drainage waters. Similarly, the data of Table II, which set forth the distribution of total DDT residues and of polychlorinated biphenyls in several collections -of marine fish, including Shiner Perch from San Francisco Bay, Hake, Jack ( Mackerel and English Sole from the coastal waters of California, Blucfin and . .._cllowin Tunas from waters off Baja California and Central America, and Skipjack Tuna from South America and the Central Pacific, sh.ow that almost all total . PDT residue levels fall within the'range of 0.2 and 2.0 parts per million, wet weight, including those in the Blucfin and Yellowfin Tunas, which are more pelagic. Only the Yellowfin Tuna from the Galapagos region and the Skipjack Tuna contained lower total pesticide residues. The majority of fresh-water fish from Wisconsin analysed by the Wisconsin Conservation Department in 1965 contained loss than 0.2 ppm of total DDT residue [27].' Moreover, fish from a stream in Wisconsin which drained an orchard where chlorinated hydrocarbons had been intensively applied over the years contained lower pesticide residue * than did the marine fish from the Pacific Ocean [17]. These combined observations indicate that it is very unlikely that pesticides in marine fish have originated - only in coastal waters contaminated by local agricultural runoff. . The polychlorinated biphenyls tPCB) occurring in fish and other marine organisms are assumed to be industrial pollutants. They are used extensively in industry as plasticizers and in the manufacture of paints, resins, electrical insulators and other products, and ere available in railway car amounts. Since they a,e very stable, resist degradation, have significant vapour pressures, are poorly solubip in water and highly soluble in lipid, it is inevitable that they should be concentrated in biological systems. Their chemical structure is NEV 022119 732174 WATER PCB-SD0000072528 ,* / O t . J , Riscbrough-3. in some respects similar to that of several chlorinated hydrocarbon pesticides, inciuding DDT and the benzene hexachl^ridcs, so that it is to be expected that they would behave similarly in their movements through ecosystems. They are highly toxic to nan when inhaled as vapours 19,25] and the more heavily chlorinated components have greater toxicity. Their presence in concentrations as high as . one part per million on a wet weight basis, and several times higher on a lipid weight basis, in species which are used as human food, should be a matter of considerable concern. At the present time it is not entirely clear how the PCB enter marine food chains, but they could easily be introduced into the atmosphere as vapours during manufacturing processes, when high temperatures increase vapour pressure, or by gradual volatilization over a period of time or even when materials containing them are incinerated. ' The PCB peaks had been evident in chromatograms of our extracts of marine fish and birds but remained unidentified until late in 1967. Extracts of tissues and of an unhatched egg of a Peregrine Falcon, a species whose decline and local -extinction has frequently been attributed to pesticides, contained exceptionally high amounts of the unknown compounds 122). Attempts to identify them were unsuccessful until reports appeared from Sweden (30] and from Great Britain (16] that PCB had been Identified in wildlife with the use of mass spcctrography and gas-liquid chromatography, respectively. The published chromatogram (14] was virtually identical with those we had obtained from the Peregrine Falcons extracts. The commercial PCB preparations are mixtures of several compounds. Of these, those having the following retention times relative to p.p'-DDE on DC-200 and QF-1 columns have been detected in marine fish and birds: DC-200: 1.25, 1.4B, 1.75, 2.05, 2.41, 2.50, 2.90, 3.41, 3.88, 5.53 dieldrin: 1.00; p,p'-DDD: 1.27; p,p'-DDT: 1.68 QF-1: 1.10, 1.33. 1.40. 1.65, 1.-72. 2.14, 2.59, 3.23, 3.88, 4.84 dieldrin: 1.49; p.p'-DDD: 1.75; p.p'-DDT; 1.91. 4 The retention times of the three principal peaks, are underlined. Similar values for the DC-200 column have been reported from extracts of seals from the North Atlantic (13]. Because of the similarity of retention times, it is evident that large amounts of PCB will interfere with the determination of p,p'-DDD and p,p'-DDT on DC-200 columns and with p,p'-DDD on QF-1 columns. Conversely, in many extracts, the PCB contciit can*be determined only after DPD and DDT hava been removed by saponification with alcoholic KOH. The quantitative measurements of the ?CB compounds were made as follows: it was assumed that each produces the same peak height in the electron capture detector as the same amount, by.weight, of p,p'-DDE. `After summing the contributions of the individual peaks, the total' was multiplied by 4.2. Measurements of standard solutions by this method yielded results close to the predicted values and to those obtained by measuring the total halogen content with the microcoulomctric detector. Measurements of the PCB in the fi*h extracts were made from .pooled extracts. Unlike.the DDT compounds, the PCBs.appear to be relatively more abundant in San \ .. . ` . NEV 7321*75 WATER PCB-SD0000072529 O Risebrough-4. ,) Francisco Bay, but their presence in Yellowfln Tuna taken off Central America indicates a wide geographical distribution. Concentrations of the chlorinated hydrocarbons, both pesticide and PCB, tend to be an order of magnitude higher in marine birds than in fish. In Table III are listed the total DDT arid PCB concentrations In tissues and in entire birds of several species. Table IV lists the DDT and PCB content of those eggs so far analysed. The latter values will eventually be also expressed as parts per million, lipid weight. Prom the data in Tables III and IV it is evident that both DDT and the polychlorinated biphenyls are widely distributed among marine birds, which are the terminal carnivores of a complex variety of food chains in the sea. Sooty and slender-billed shearwaters are pelagic species which breed in New Zealand and Australia, respectively and which spend the southern winter in the northern Pacific. Rhinoceros Auklets and Ancient Murrelets breed on the coasts of British Columbia and Alaska, whereas Kittlwakes, Fulmars and Red Pharalopes breed in Alaska and the Canadian Arctic. All of these specimens were collected in California, so that it is not clear how much DDT-and PCB the birds had ingested on their breeding grounds. In the pelagic bird species, in most of the fish from the ocean and in the other specimens from areas remote from sites of application, such as Baja California, the ratios of DDT to PCB are of the same order of magnitude and most values are between 5 and 15* If both PCB and DDT were dispersed around the world by the same transport Bystem, their relative concentrations in "remote" areas would very likely be similar. Additional data are needed to support this hypothesis; eggs from tropical regions and from Antarctica have been obtained and will eventually be analysed. In many of the specimens from San Francisco Bay and San Diego Bay this ratio is close to one. Absolute concentrations of PCB also tend to be higher, suggesting that.the most important sources of contamination are local. ` The sample sizes of Tables III and IV are very small; many samples, however, remain to be analysed. Only tentative suggestions can be made from the data, but .a consistent pattern is evident. Thus, the Western Gull egg from San Francisco Bay and the Pigeon Guillemot egg from the coast near San Francisco contained more PCB than the egg of each species from the Farallons. Of the two night heron eggs analysed, one had an "ocean" profile: high DDE, low p, p'-DDT and DDD, high DDT/PCB ratio; the other had a "bay" profile. The Caspian and Forster's Terns nest side by side on the dikes in San Diego Bay, yet the DDT/PCB ratio is much lower in the Caspian Terns, which feed primarily along the coast, than in the Forster's Terns, which feed along the brackish and fresh-water dikes and canals. The two Californic Peregrine Falcons had both been feeding In San Francisco Bay prior to capture; in both the ratios of DDT to PCB are near unity. The high DDT concentrations recorded in the Bermuda Petrel $2/ and in the-Skua from Antarctica /2>/, which are species of the high seas, also indicate that coastal regions were not the primary source of contamination. A quantitative approach to the problem of aerial transport of pesticide; over the sea has been made by measuring pesticide concentrations in airborne NEV 022121 732176 WATER PCB-SD0000072530 o Risclrough-5. Mrllculntes i?-l]. Over the pa?*- year, Goldberg, Griffin and others at the Scripps institution of Oceanography have collected airborne particulate matter . on nylon mesh screens coated with glycerin which had been mounted on the Scripps f pjor in La. Jolla. Dust collected on such screens in several areas of the world / had previously been shown to contain.thc mineral talc in concentrations much t higher than expected on the basis of its natural distribution [31]. Talc has been extensively used as a diluent for pesticides, in addition to other industrial applications. Moreover, the rate at which talc has been deposited on glaciers shows a significant increase after 1940 I31]. Analysis of the airborne dust collected on the Scripps Pier showed that pesticides, predominately p,p'-DDT were present in concentrations ranging fjjm one to eighty-one parts per million, . corresponding to a mean value of 7 x 10 grams per cubic meter of air. The method traction'ates against those materials carried on particles less than . several micra or present.as vapours. This value is therefore a.lower limit of the amount of chlorinated hydrocarbons in the air. No PCB peaks were . observed in the chromatograms of the dust extracts. These were then pooled, concentrated, and saponified in order to degrade DDT and DDD. PCB was not present in the saponified extracts and a maximum concentration of 5 ppb was calculated for the dust samples, 10,000 times lower than that of the total pesticides-. Since the ratios of PCB to DDT observed in fish and birds is much higher, it would appear that the PCBs remain ns vapours in the air and do not adsorb to particulate matter. In the near future we hope to obtain air samples which have been passed through a cold chamber in which PCBs, pesticides and other compounds present as vapours would condense. The winds at the Scripps pier in La Jolla are predominantly landward with ,an unknown fraction of air from nearby agricultural areas. Although the lack of knowledge about air circulation patterns and fallout rates makes difficult at the present time a calculation of the amounts of pesticides brought to the. coastal vraters of California by winds, such a transport system could account for the unexpected geographical distribution of the DDT compounds in fish. The Science Research Council of the United Kingdom had earlier mounted a similar screen on the eastern tip of the Island of Barbados in an attempt to collect extraterrestrial dust of mtitoorite origin. The Northeast Trades at Barbados have blown over 5000 kilometers of;the tropical Atlantic and it was therefore considered highly unlikely that "any dust accumulating on the screen could be of continental origin. This assumption was, however, in errort since significant quantities of airborne particulate material were collected on the screen which upon mineralogical and biological examination proved to be most likely from Africa and Europe. Fallout rates of the dust over the tropical. Atlantic and its contribution to the bottom sediments were calculated [8], Gram samples were subsequently made available to us for analysis. The con centrations of pesticides in the dust ranged from less than one part per billion to 164 ppb, with an average value of 41. Knowledge of the fallout rate over the oC'.-aii mtiuO. possible an estimate of the quantity of pesticides entering the tropical Atlantic between the Equator and 30 N. This figure, a minimum value since the jucovory of very small particulate materials was low, was 600 kilograms a year, which compares with the value of 1,900 kilograms entering San Francisco Bay in the San Joaquin and Sacramento Rivers (21]. It cannot be concluded that thise oesticides had originated only in Africa; the DDT residues accumulating Hfc* 732177 WATER PCB-SD0000072531 t /O Risebrough-6. ) the rare and declining Bermuda Fetrei |J2] might have come from any part of Host of the chlorinated hydrocarbon content of the particulate material of marine nir consists oi p.p'-DDT, p,p*-DDE, however, comprises the large proportion of the total DDT in marine fish and birds. The percentage of DDE is lower in fish from San Francisco Bay and Puget Sound; DDT and DDD are comparatively mure abundant. DDE, however, comprises only 22% of the total DDT residue entering San Francisco Bay in the San Joaquin River [2] and in - bottom mud, where anaerobic conditions might prevail, DDT can be expected to be converted to DDD rather than to DDE 115,29]. From mammalian and insect toxicity studies it has been concluded that DDE is relatively harmless. Recent research at the Patuxent Wildlife Research Cent.cr, however, have indicated that the toxicity of DDE to birds is much higher than expected and may he about one half that of p,p'-DDT 128]. Like p,p'-DDT, p,p'-DDE is capable of Inducing liver epoxidase enzymes 111]. Such enzymes degrade sex hormones by hydroxylating them {19] and thereby may affect calcium metabolism. No evidence of abnormal calcium metabolism has yet been observed in sea birds, but a significant decrease in eggshell weight of several birds of prey in Britain after the Second World War is evidence of a fundamental change in the environment [20], ' The effects of the PCB compounds upon natural populations remain unknown. The highest concentrations so far recorded were in an adult female peregrine Falcon from California, where the species has recently undergone a sharp decline [22], . Application of the persistent biocides and the release of nondcgradnble waste products into the environment have frequently bee" justified by arguments that point out that local populations of organisms remain relatively uncontaminatcd and that", especially in the case of the chlorinated hydrocarbon insecticides, even the persistent compounds disappear with time. It is abundantly clear that these arguments'have become misleading, irrelevant, and wrong. Pollutants do go everywhere. Those which are non-polar, water-insoluble and which have finite vapour pressures will eventually appear in marine food chains. The DDT compounds and the polychlorinated biphenyls have already done so to an alarming degree. ' NEV 022121 732178 WATER PCB-SD0000072532 o /. i TAJJLE I Risebrough-7. ') . .csiducs iii collections of Northern Anchovy (J^jirnulis mordax) and .ish Sole (Parophrys vctulus) from San Frar.cisco Bay and California fital waters. t' . I/ _____ ________ ____ ______ _______ . 9 / Species f locality, date N Mean Wt (g) p,p'-DDEb Total DDT Northern Anchovy . San Francisco Bay July 29, 1965 San Francisco Bay November 4, 1965 Monterey November 30, 1965 Morro Bay June 16, 1965 17 29 . 30 29 12.4 (6-22) 0.21 +0.05 4.0 (2-5) 0.11 . +0.05 26.5 (21-35) 0.68 +0.19 25.9 (19-33) 0.45 0.12 Port Huencme February 24, 1966 15 11.6 2.44 (2.8-21.5) +0.77 Terminal Tsland Los Angeles, June 25, 1965 44- 11.7 (6.5-20) 10.2 +2.1 English Sole ' San Francisco Bay July 29, 1965 18 14.3 0.14 (5-35) +0.02 San Francisco Bay November 4, 3965 . 33 17.3 (7.5-53) 0.13 +0.03 San Francisco lightship December 1, 1965 Monterey February 15, 1966 15 253 )175*-306) 0.12 +0.03 15 195 (89-262) 0.53 0.13 0.59 0.11 0.33 0.04 0.90 0.22 0.74 0.22 3.04 1.00 14.0 1.9 0.55 0.07 0.55 0.12 0.19 . 0.04 0.76 0.16 a from R. W. p/isebrough, P..B. Henzel, D. J. Martin, Jr., and H. S. Olcott in preparation. DDT residues include the two isomers of DDT,p,p'-DuT nEV 0221^ N 732179 WATER PCB-SD0000072533 oJ TABLE I, continued Kisobrouch-8. and o,p'-DDT and their metabolic derivatives: p,p'~DDE, o,p*-DDE p.p'-DDD and pp'-DDU. wc-t weight parts per million, means, standard errors, 95% confidence limits .. .' tiVi 02 22l 5 732180 WATER PCB-SD0000072534 < / / r f ! Kisebrough-9. TABLE XI DDT and polychlorinated biphenyl (PCB) residues in marine fish. b Species, locality, date N Mean Wt. Total Z . PCB DDT/pjja (8) DDT p.p'-DDS Northern Anchovy * Terminal Island June 25, 1965 44 11.7 14.0 83 (6.5-20) 1.9 1.0 14 Shiner Perch ' San Francisco Bay . 14 October 20, 1965 5.5 (4-8) 1.0 0.1 28 1.2 0.R San FrancisCo Bay October 20, 1965 10 26.7 1.4 (10-48) 0.3 35 *0.4 3.5 Snn Francisco Pay 15 15.3 1.1 33 1.2 0.9 \f . November 4, 1965 (8-493 0.1 English Sole San Francisco Bay July 29, 1965 18 14.3 0.55 25 0.11 (5-35) 0.07 5 San Francisco Bay November 4, 1965 33 17.3 0.55 24 0.11 (7.5-53) 0.12 5 San Francisco 15 253 0.19 63 0.05 lightship, Dec. 1, (175-306) 0.04 1965 4 Monterey February 15, 1966 15 195 0.76 70 0.04 19 (89-262) 0.16 Jack Mackerel 1 Channel Islands - 33 81.8 0.56 57 0.02 28 November 22, 1965 (45-141) 0.10 Bake ' Puget Sound January 29, 1966 22 281 0.18 23 0.16 (185-350) 0.05 1.1 0221^6 732181 WATER PCB-SD0000072535 TABLE II, continued Rischrough-10. Hake Channel Islands February 24, 1966 Bluefin TunaC ' Body muscle 6 384 (61-872) 7-- Liver . j .9 -- Yellowfin Tuna Liver** Liver* 13- -- 13 -- Skipjack Tuna Liver8 Body Muscle Liver*1 Liver* 3-- 13 -- 25 12 --. 1.8 +1.1 68 0.56 +0.24 0.22 +0.13 45 45 0.07 +0.02 0.62 +0.19 13 30 0.057 23 0.051 18 +0.014 0.056 +0.023 11 0.029 +0.008 21 0.12 15 0.04 14 .0.04 6 ' NDe >7 0.04 15 0.1 ND 0.6 >30 ND >30 ND >20 a from Risebrough et al. 124)Concentrations in wet weight, parts per ` million. Meant,' standard errors, 95% confidence limits . ^ Northern Anchovy (Engrauli s word ax), Shiner Perch (Cymatoeaster aggre^ata), English Sole (Parophrys votulus), Pacific Jack Mackerel (Trachums symmctricus). Hake (Merluccius nroductus). Bluefin Tuna (Thunnus thvnnus). Yellowfin Tuna (Tnunnus albacares). Skipjack Tuna (Euthynnus pelamis).- C Isla Gcronimo, Baja California, Aug. 29, 1965 ^ Tower Island, Galapagos Archipelago, Nov. 6, 1965 6 N.P. not detected, less than 0.01 - NEV 022127 732182 WATER PCB-SD0000072536 .O TABLE II, continued ) f-Central America (90 W, 8* N) Aug. 23, 1965 Hawaii, November, 1965 ** Galapagos Islands, November and December, 1965 * Cape Pasado, Ecuador, September 1, 1965 Kiscbrough-21. 022126 732183 WATER PCB-SD0000072537 ) Riscbrough-12. .I TABLE IH DDT3 and PCB residues in marine birds** and in *-he Peregrine F;ax. con k Species, locality, date focal X DDE PCB DDT/PCB DDTC Cassin's Aukletd Ancient- Murrel*t ; Fulmar* Fulmar* . Red Phalarope Rhinoceros Auklet*1 ' Slender-billed shearwater* Sooty shearwater^ Sooty shearwater^ Peregrine Falcon*1 5.8 0.75 0.41 3.4 0.78 2.7 32.0 12.3 10.3 98 0.16 99 0.15. 76 0.08 89 ' 79 0.34 0.10 97 1 0.36 92 2.1 94 1.2 86 0.9 36 5. 5 10 8 8 15 10 12 ' breast muscle, second , year female, migrant from Arctic * 104 breast muscle, immature California 13 breast muscle, adult female, California a . 112 99 99 98 22 4.5 . 10.5 . 1.2 109 1.0 . . a: from Risebrough et al. [23] abd Risebrough, Kirven and Herman [22); b; entire bird analysed, except Peregrine Falcons; c: includes p,p'-DDT, 'p^'-DDD, p,p'-DDE, p,p'-DDIfU, p,p'-DDE; parts per million, vet weight; d: Ptychoramphus alcuticus, adult female, Farallon Islands, April, 1966; eJ Synthliboramphus antlquus, Monterey Bay, Nov. 1, 1966; f: Fulmarus glncialis. Monterey Bay, Nov. 1, 1966; g: Phalnropus fulicarius, Monterey Bay, Nov. 1, 1966; h: Ccrorhinca monocerata, Monterey Bay, Nov. 1, 1966; i; Puffinus tenuirostris. Monterey Bay, Dec. 12, 1966; 35 PufHnus r.risous, . ' Monterey Bay, Nov. 1, 1966; k: from Risebrough, Kirven and Herman [22). NEV 022129 732184 WATER PCB-SD0000072538 /o >) TABLr IV DDT and PCS content in eggs of several bird species. flist'broirgh-13. Species, locality N Total Z BCBa DDT/PCB DDTa p,p'-DDE Brandt's Cormorant (Phalacrocorax penicillatus) Farallon Islands 17 326 91 113 2.9 Pelagic Cormorant (PVia] acrocorax pelaRicus) San Mateo Co. Calif. 1 2 128 90 (125-130) 62 (48-75) 2.1 Murre Uria aalge . Farallon Islands 6 1945 - 96 558 (932-3621) (364-1010) 3.5 Pigeon Guillemot Ccpphus grylle Farallon Islands *1 110 -95 20 5.5 San Mateo Co. 1 103 , 91 62 1.7 Cassin's Auklet Ptychorampbus aleuticus ' -' ~ ' Farallon Islands Western Gull Larus occidentalis 2 147 97 15 10 (127-167). . .. (12-18) 1 Farallon Islands 1 423 95 118 3.6 San Mateo Co. San Erancisco Bay 1 235 94 112 2.1 1 458 87 480 0.95 NV 0^130 732185 WATER PCB-SD0000072539 o TABLE IV, continued o Black-crowiicd Night Heron Nycticorax nycticorax San Francisco Bay Caspian Tern Hydroprogne caspla San Francisco Bay- San Diego Bay . Forsters Tern Sterna forsteri San Diego Buy i Least Petrel Halocyptena microsoma Baja California c Feregrine Falcon Falco peregrinus ' Baja California 1 541 89 330 1.6 1 869 99 24 36 2 1269 89 (1216-1322) 805 1.7 (660-950) (1.3-2.0) 5 1430 88 1010 1.4 (991-2430) (550-1600) ' . ' 2 665 89 (598-732) 2 30 " (23-37) 84 114 (91-137) 5.8 -. 3.1 10 (1.2-5.0) - . ' 1 4830. 97 471 10 a: total micrograms; b: samples pooled for PCB analysis, p,p'-DDE content ranged from 63 to 1240 micrograms; c: from Risebrough, Kirven, Herman 122]. I NfcV 022131 732186 WATER PCB-SD0000072540 O .. .J Riscbrough-lJ. REFERENCES Il> ACREE, F., JR., BEROZA, M., BOWMAN, M.C. J. Agr. Food Chem. 11 (195?) 278. (2] BATLEY, T.E., IIANNUM, J.R., J. Sanit. Eng. Div. Amcr. Soc. Civil Engvs. 93 (1967) 27. . (3] BARTHA, R., LANZILOTTA, R.P., PRAKER, D., Appl. Microb. 15 (1967) 67. * (4] BOWMAN, M.C., ACREE, F., JK., CORBETT, M.K., J. Agr. Food Chem. _8 (I960) 406. .. (5] -BOWMAN, M.C/, ACREE, F.`, JR., LOFGREN, C.S., BEROZA, M... Science 146 (1964) '1480. . (6] BOWMAN, M.C., ACREE, R., JR-., SCHMIDT, C. H., BEROZA, M. , J. .Econ. Entomol. J>2 (1959) 103S. ' [73 BREIDENBACH, A.W., CUNNSUSON, C.G., KAl.WHARA, F.K., LICHTENBERG, J.J., GREEN, R.S., Public Health Rept. 82 (1967) 339. 18) DELANEY, A.C., DE1ANEY, A.C., PARKIN, D.W., GRIFFIN, J.J., ' GOLDBERG, E.D., RE1MANN, B.E.F., Geochim. .Cosn:ocliim. Acta ` 31 (1967) 885. _ (9) Documentction of Threshold Limit Values, 4JL (Committee on Threshold Limit Values, American Conference of Governmental Industrial Hygenists) 1966. [10J FAHEY, J.E., ZUTCHER, J.W., TURNER, M.E., Pesticides Monit. J., 1 4 (1908) 30. . 111) G1LLETT, J.W., CHAN, T.M., TERR1ERE, L.C., Agr. Food Chem. 14 6 (1966) 540. - 112) HARRIS, C.R., LICHTENSTEIN, E.P., J. Econ. Entomol. 5& (1961) 1038. `' * {13) HOLDEN, A.V., MARSDEN, K., Nature 216 (1967) 1274. 114) HOLMES, D.C., SIMMONS, J.H., TATT0N, J.O'G., Nature 216 (1967) 227. ' 115) JOHNSON, B.T., GOODMAN, R.N., GOLDBERG, ll.S., Science 157 (1967) 560. . ' '' 116) LICHTENSTEIN, E.P., ANDERSON, J.P., F011REMANN, T.W., SCHULZ, K.R., Science 159 (1968) 1110. .- - 117) MOUBRY, R.J., HELM, J.M., MYRDAL, G.R., Pesticides Monit/ J. Jl ' . 4 (1968) 27. 118) NASH, R.G.. K00LS0N,. E.A., Science 157 (1967) 924. {19) PEAKALL, D.B., Nature 216 (1967) 505. ` {20) RADCLIFFE, D.A., Nature 215 (*1967) 208. . {21) RISF.BROUGH, R.W., HUGGET, R.J., GRIFFIN, J. J. ,, GOLDBERG, E.D*., . Science. 15 (1968) 1233. ' {22) RISEBROUGlC R.W., KIRVEN, M.N., HERMAN, S.G., in preparation 123) R1SEBROUGH, R.W., MENZEL, D.B., MARTIN, D.J., JR., OLCOTT, H.S., " Nature 216 (1967) 589. . {24) RlSEliROUGH, R.W., MENZEL, E.B., MARTIN, D.J., JR., OLCOTT, H.S., in preparation. 125) SAX, N.I., Dangerous Properties of Industrial Chemicals, Reinhold, New York, (1963). 732187 WATER PCB-SD0000072541 Risebrough-16. REFERENCES, continued {26} TATTON, J.O'C., RUZICKA, Nature 2)5 (1967) 346. {27} THOMPSON, D.R,, Wisconsin Conservation Department Survey Report, February 14, 1966. . {28} United States Department of the Interior, Fish and Wildlife Service; Wildlife Research Problems Programs Progress 1966 Resource Publication 43, Washington, b.C. . [29] WEDEMEYER, G., Science 152 (1966) 647. [30J WIDMARK, G., J. Ass. Off. Anal. Chem. 50 (1967) 1069. {31} WINDOM, H., GRIFFIN, J.J., GOLDBERG, F.D., Environ. Sci. Technol. 1 (1967) 923. .. [32] WURSTER, Q.F., JR., WINGATE, D.B., Science 159 (1968) 979. [33} The National Science Foundation, (grant GP 6362) provided financial support. I thank P. L. Ames, E. D- Goldberg, S. G. Herman, M. N. Kirven, H. S. Olcott, P. Reiche and R. L. Rudd for their assistance.. The Monsanto Chemical Company generously provided samples of Aroclor 1254 and 1262. NEV 022133 \. 732188 WATER PCB-SD0000072542 13 3 U U 3 3 1 3 *3 ggn fir. D.Y.X. Hardy*" Dr. X.k. Bevaan. C ftcosanto Chemical Coeoagy St. loaii, Kliioari Siptubir 20, 1^55 Dr. J.W. Bwmt London Voor aeso 6eptesbsr 6 to hr. Xason iHXLOft TOXICITY Howard Kasco has fivta at your neao of Septteber 8. 2 vlll be happy to dlsousa this vith Dr. Htvaan during hit visit bsr. Z think, hovsver, there iri several points tbit 2 can anivar you now. You eonoent upon the diffarence in toxicity between jLroclor .119* and 1242. This is not particularly turprltin* because in th ssrlisr work it was found that toxicity increased vlth chlorination. Of course. froa the standpoint of volAtillty in tha cam of Inhalation or absorption froa the fat froa tbs point of view of Ingestion ir iaportent. rankly, there vn not too (mt i difference Utvit& tbs tv coapoundi, hovtver. Is 70a know, tbs saxlsua sllovsblo C eoncsntrsts Is 0.1 nl/eubie aettr in tbs case of 1254, And os hlfh as 10.0 E(i in tb casa of 1268. 2 think tbs foratr is too low ond tho latter is too Dish. 2n this country th#y don't ass tbs XiCs vs ry routinely, bat esrtAinly in Inti end 2 think it voald bs Alright to eonsidtr 0.2 **a/cubic neter os psrfsctly soft. I don't knov bov you voold cot ony particular advantag* in doinc oors vork. Shat is it tbot you vant to prove? I believe your vork should be directed tovirds finding oat vhst the concent rations ore of Aroclor during different operations .vbetber it .is industrial or palntint. Tbs re ports you have seen froa Hatterins Laboratory ore tbs re sult of approzlnately 115,000 to #20,000 expenditure by HOC* liCe's position can be suA&arlzed' in this fesblon. tie knov Arodors are toxlo but tbs Actual Unit has not been pre cisely defined. It does not nake too nueb difference, It seeaa to ae, because oar aain vorry It vhst vlll happen If an individual devtlopes any type of liver disease ana fives a history of Aroelar exposure. I as sura the lories vould not pay a crest deal of attention to UiCs. s4xsi 1139 Cm) WATER PCB-SD0000072543 ssa Pact 2 itpttabar 20, 1955 iWCtOR 20X2CSI Vt, thtrefora, MTlw ttary new droolor as* froA tbit point of vitv* If it it t& industrial tpplieatioe where vt oan tat air concentrationa tad bat# tost reasonable expectation that tbt air concentration* will ttay the teat, vt Art aueh aore liberal Is tbt att of Aroolor. If, bovtvtr, it it dittribottd to bouttboldtrt vhart it can bt used la almost any tbapt and fora and vt art never able to laov bov such of tbt eoaetntratloo they art tzpottd to, vt art aueh aore triet* lo amount of toxicity teatlai viU obviate tbit latt dileant aad tbtrtfort 2 do not believe tap aort teatla* would bt juatified. Let* a ttt vbat oar diteutilo&i vltb Or. Xtwsaa aad yourself briax out* BBKlk B. Beset Kelly, X.D 4 WATER PCB-SD0000072544 October 23, 1970 Prof, O. Fred Lee Water Chemistry Laboratory The University of Wisconsin Madison, Wisconsin 53706 Dear Dr. Leei I never have received my copy of your letter to Herb Stoklngor dated August 14 which you referred to In your letter of September 23. Jack Oarrett has x>ecelved your letter of October 13 and I now do have a copy of your earlier letter and the position statement. As you indicated In your letter to Jack, there Is no reason why you should not discuss the results of our on-going toxicity studies with Dr. Calendra and his associates. I have enclosed a copy of my letter to Herb stoklnger with copies to you. Dr. Caiandra and I>r. Mount concerning the statue of our studies and the detailed results available at this time* In connection with the position paper, I have the fol lowing commentst 1. In the second paragraph on the first page, there is a reference to pesticide formulations and the possible direct contamination of natural waters. Z think you know that the polychlorinated biphenyls were never promoted as components in pesticide formulations for wide-spread dispersion on crops* orchards, eto. The fact le that the U. S. Department of Agriculture developed recom mendations for the possible use of the waxy type Aroelors In pesticide formulations for painting interior surfaces. The USDA data indicated that hard surfaces (painted or metallic) sprayed with lindane or benzene hexachloride containing Aroolor 5460--a 6o chlorinated terphenyl, not PCB-- remained toxlo to flies, ants, roaches and silver fish for as long as three months compared to one NEV 006635 WATER PCB-SD0000072545 Prof* O* Fred Lee Octobar 23, 1970 Pag* Two week's effectiveness for formulations of the pesti cide without Aroclor f>460. Th* waxy Aroolors, 12^4 and 1260, may also have ended up in some similar formulatlone. Zn any case the amounts used were Insignificant, we think, in terms of any threat to contamination of natural waters. 2. In the second paragraph on page two. Winter Melg'e publication in the JAMA is mentioned. Correspondence with the author following publication confirmed the fact that the chloracne was of such a mild nature that even trained dermatologists would probably have missed the evidence of the chloraon*. To our knowledge, there have been no published reports of any chloracne episode since 1952. The question can be raised then as to whether the chloracne problem is of any real significance. 3. The third paragraph on page two refers to the chronic studies currently in progress. The first sentence implies that the two-year studies are complete. Secondly, there maybe a trend to convert completely to the metric system which would warrant units such as "mlcrograea per gram". I believe, however, that the practice in reporting dotes fed to animals In chronic studies generally la to use a 'parts per million1 reference. Perhaps this is due to the fact that acute doses are usually expressed in terms of "milligram per kilogram of lody weight' of the test animal. This latter point I would Iceve to the Judgement of Drs. Stokinger and Cnlnndra. Similarly, a comparison of toxicity of that of DOT should rest with them. I would add that as recently as laat month at a mooting with Garth Fltzhugh, he expressed the opinion that the Aroclors are much less toxic than DDT1'. There is no question that the comparison varies depending on what species of mammals, birds, fish or possibly insects one is using to make a comparison. Obviously, whether one is talking about acute or chronic toxicity is relevant. Our own opinion at Monsanto is that the general statement that PCB's are no more and probably leas toxic than DOT can be supported. NEV 008636 WATER PCB-SD0000072546 Prof* O. Fred Leo October 23# 1970 Pago Throe At the present tine, we do not think that a drinking water standard Tor the PCB`a showing up In the envir onment should be lower than that l'or DDT. I apologize for the delays Involved in answering your request for informstion and comments. Sincerely, Elmer P. Wheeler Manager, Environmental Health iiPW: Ju c.c. Dr. Joseph C. Calandra Dr, Donald I. Mount Mr. William II. Papogeorge Dr. Herbert E. Stokinger NEV 008637 707889 WATER PCB-SD0000072547 0 October 11, I937. prolonged exposure to Aroolor vapors I volved at high teapersturae or by repeated oral ingestion will lead to systsaio toxic ffsots. ' Repeated bodily contact with the liquid w Aroolora may lead to an sens-fora skin eruption. Suitable draft ventilation to oontrol the vapors evolved at elevated teaperatures, ~ ae well ae protection by suitable garaente " - froa extensive bodily ooataot with the llq- V ' nil Aroolors, should prevent any untoward , effeo. t." 4. ` . Zn talking with Dr. Kelly before these three paragraphs were written, we Agreed that they night ae well be phraeed ae that thtfy oould be ueed not only in the Aroolor booklet, but qnoted in oorrespend#not as that nay bs neo> sasary* ' L.A. Watt WATER PCB-SD0000072548 J Toxicology Department Hon*onto Chemical Company St* Louis, Uissouri Soar Sir*i Ono of our Indiana, induatrio* ii using your ARCLCR 1248 (tetraehlorodiphenyl) as a hoat transfer madia ( up to 400 F) la th* extrusion of Tsnito 2 plastio* Considorablo vapor of arelor is prasont in tho workroom duo to looks in tho "olosed" system* Several workers have reportedly beoone ill due to the inhalation of these vapors* This plant called us as to any knowledge relative to the toxlelty of this produet* We did not have any data that could be transmitted to then* The so^ealled illness was vague in that we could not learn from the plant what the exact complaints were* We would appreciate any Information which you have on the toxieelogy of this material* * Toups very truly, /* \ LnStpa Louis W* Spolyar, M. D., Director Division of Industrial Hygiene Indiana State Board of Health &426, PLAINTIFF'S 1 [ EXHIBIT I 1 B0CC32O8 PUBUC NIALTM te "TUI APT MB SCItMCS OP PSKVOITIM* IIIUM, PMUMIM Ufl Ml MTUeu AMO UCMTAL 1**1. cibnct TMaewoM eecAMisse community i**on.* c.-a a.---- 1I . 4451 ' 42 * WATER PCB-SD0000072549 0 IKTWl MM WAVS State op Indiana TAT* BOARD OR HEALTH February 28, 1950 Dr. R. bast Kelly Medical Director Monsanto Chemical Company St. Louis 4, Missouri Dear Doetor Kellyt ' Thank you vary nuoh for T^!T `r*Ty latter of Febru ary 14, relative to the use oS^Xroolors )in industry. The plant under question is the Brasil plant aieatloaed in your letter. The chief ooaplaints vere irritation of the upper respiratory traot plus possible liver damage. At the time of our study Aroelor was circulated in galvanised pipes and most pipes ware leaking* It was suggested that new pipes be installed and local exhaust employed. Plant repiped with eopper tubing and installed a local exhaust system over extruder rolls. With tills improvement very little Aroelor vapors were escaping. This probably will solve their pro* blem. Further the plant is considering building an enclosure around the extruder and rolls so that this equipswnt will be both enolosed and exhausted. Thanks again for your help. * Verytruly yours. MULd (j)' liJK, Spolyar, M. ., Director Division of Industrial Hygiene Indiana State Board of Health ursipa WATER PCB-SD0000072550 2** ^ ytftTXu ttjl Tfe- *T7 ;^-s_ / */& "^s Fnnnnas 56 002539 WATER PCB-SD0000072551 Hocsanto Chenlcsi CfiEbany CKI fir* D.Y.H. Hardys* Or. H.R. Havcan. St. Louis, Kissouri September 20, 1955 fir. J.W. Barrett London fcour aeco September 8 to hr. Nasor. JlBOCLOR TQX2CHY Howard Nason has given as your seao of September 6. 1 will be happy to dleouse this with fir. Nevnan during his visit hart. 2 think, however, thart art several points that 2 can anever you now. You cocoant upon the difference in toxicity between Aroclor 125V and 1242. This is not particularly surprising because in the earlier work It was found that toxicity Increased with chlorination. Of course, fron the standpoint of vol atility in the case of Inhalation or absorption fron the cut fron the point of view of ingestion ere important. Frankly, there was not too treat a difference between the two compounds, however. As you know, the maximum allovsble concentrate Is 0.1 al/cubic otter in the case of 125V, and as high as 10.0 mga In the esse of 1268. 2 think the former is too low and the latter le too hlch. 2o this country they don't use the MACs very routinely, but certainly in England 2 think It would be alright to consider 0.2 agm/cublc meter as perfectly safe. * V-khd^fi6^ adv fir* doing more work. Whet le It that you want to prove? 2 believe your work ebould be directed towards finding out what the concentrations are of Aroclor during different operations .whether It .1* industrial or painting. The re ports you have seen from Kettering Laboratory ere the re call of approximately 115*000 to #20,000 expenditure by ' MCC'a position can be summarized' In this fashion. We know Aroclors ere toxic but the actual Unit has not been precleely defined. 2t doe a not sake too such difference, it seeae to at, because our aaln worry le what will happen If an individual develop*! any type or liver disease and gives a history of Aroclor exposure. 2 am sure the juries would not pay a great deal of attention to HiCs. Fonftoa? WATER PCB-SD0000072552 Pace 2 $ept saber 20, 1955 iAOCtOft TOUCH! tfe, therefore, review tvary new Aroclor utt fros this point of viev, If it la an Industrial application where vt can fet air concentrations and have aoat retsoosbls expectation that the air concentrations will stay the taae, vt are cuch sort liberal In the use of Aroclor. If, however. It Is distributed to householders vhere It can be used In alsost any shape and fora and vt are never able to know hov such of the concentration they are exposed to, ve are such core strict. lo aaount of toxlolty testlni vlll obviate this last dlleosa and therefore 2 do not believe any sore testInc would be justified. Let's see vhat our discussions with Dr. Kevsan and yourself brine out. BKKtk B. Enact Kelly, K.D. +\ I*;nnna8 58 WATER PCB-SD0000072553 COPT NO PROCESS POR THE PRODUCTION OP AROCLORS, PYRANOLS, ETC. AT THE ANNISTON AND AT THE WM. 0. KHUHCHCH PLANT April 1955 ---------------------- E. Mather Distribution List (amended July 19, 1956) 1. Hr. J. S. Brough, London 2. Br. N. B. Dyson, Newport 4 Newport T.I.E. file 3. Mr. 0. V.'Taylor, Newport 4. Mr. 0. V. Taylor, Newport * Newport Process Superintendent 5. Mr. V. E. Hamer, Ruabon 6. Mr. J. 7. Stlckley, St. Louis 4 Krumarieh Plant 7. Mr. J. 7. Stlckley, St. Louis 4 St. Louis Library 8. MCL file at St. Louis 9. Mr. D. B. Hosmer, Anniston 10. Spare held in M.C.L. file at St. Louis 11. Dr. V. A. Hayward's file Ruabon also Section IZ, Specifications and Test Methods, to Newport Analytical Department. WATER PCB-SD0000072554 VI. PROCESS IN DETAIL, contd. VI - 2* Process Detail Packing The finished Aroclcrs are run off into drums, a piecs of dla cloth being tied on the pipe outlet for the lighter"Iroclors, and a piece of fine gau2e for the heavier Aroclcrs, which have to be handled hot. This, of course, is to arrest stray bits of pipe scale etc., but the precaution is now omitted at the Krummrich plant when materia] are being filled*directly from the delivery of the filter. Newpor arrangements for filling and weighing drums are discussed in Londc Engineering Pinal Report, September 1951* page 1D8 and 1 F3-10, also in the start-up reports, July 24, and September 27, 1951. The drums must be clear, and dry, especial care being needed with electrical grades. Newport complaint NP/61, November 1951, of turbidity in 1248 was traced to the presence of water in the drums Apparently, in presence of water, the Aroclor reacted on the galvanizing of the drum. Newport plant report, December 1951, mentions the installation of equipment for drying the drums. Care is taken not to do any packing if there is KC1 fume in the al: The gaskets for the bungs of the drums have to be correctly chosen. A sample of the gaskets supplied by the Melrath Supply & Gasket Co. to the Krummrich plant was sent to MCL, April 1947. See also the ...k discussion ~o.wgaaketa-.Gn*-paga--2 jv-'Seetiorv Kity*T}e-l-owv v Mr. Pemberton, December 1950, collected samples cf the labels used at -the Krummrich plant; cne a patent list label, and the other a warning label on toxicity. The effect of exposure of Aroclors to metal contact is discussed in Section VII,'comments, page 17 below. Generally speaking, the dietilled Aroclors are packed in galvanized drums, the undistilled ones in black steel drums. Flaked or milled solids were packed in barrels or Leverpac containers, bulk solid or resinous Aroclors go out in friction type lid drums, (galvanized for the distilled grades). Storage and blending of the distilled Aroclors is done in steel vessels sprayed with tin or zinc, or alumintm lined. AO* 0C253 Fnonorr? 47 i WATER PCB-SD0000072555 VI. PROCESS IN DETAIL, contd. VI - Proce Detai Packing, contd. Since the Aroclors are such effective solvents , they damage, arc are damaged by, ordinary paints, lacquers, insulating varnishes,*' This feature is important in connection with hydraulic fluids * containing Aroclors. See, for example, MCL Research Progress re** 1151. DP 5V26/7 and DP 54/277/6 and 1152 DP 4/ic/7 and 8* July 1$ etc., also the Section III, Physical & Chemical data, above. Dru for electrical grades cf Aroclors are not painted. Newport Plant Technical Committee meeting, April 14, 1953, page 2 reported some promising teats with lacquered drums for electrical grades. It was decided not to use lacquered drums for resinous Aroclors on a returnable basis, because the lacquer suffered at the high temperatures likely to be used in melting the material f: the drums. Aroclors also are dispatched in rail cars. At the Krummrlch plant the manhole of the car is protected by a tarpaulin tent during fil Newport plant report for July 1954 mentions the installation of tank-filling facilities. The Krummrlch plant operating instructio; August 10, 1954 mention that rail cars for Pyranols and Aroclors are insulated and have either a steam coil or a steam Jacket. The: are lined with Aluminium or else sprayed with tin and zinc. Only dry air is used for unloading. MCC have a "Christmas Tree" fittin* a one piece fitting carrying air valve, dip pipe, release valve x _anci..Rr3.aaure--gauge^^fQr-.^e^on*r*t-> -tanks*.* ^improVtintTTo 'cira the coil cr Jacket of the rail tank in cold weather. Galvanized or lacquered drums are used for Pyranols. KnnwwS C M OC252 48 WATER PCB-SD0000072556 XI. HAZARDS. Toxicity x: hazar- - There are many literature references*to harmful effects of th t- of "chlor acne" resulting from exposure to chlorinated especially in cases where people working with small electees!V ponents have been exposed to the fumes of hot, highly chlorinated Aroclors. Chior acne is sometimes accomjsnied by gastric troubles'* and there are literature references to liver troubles*. ** There was some trouble of this kind among the production workers < Anniston in the early days of the development of the Aroclors. A' that time highly chlorinated Aroclors were being made from diphen: which had come from low grade benzene. Since good benzene has be used, the same Aroclors have been made without trouble. In March it was reported that the Anniston diphenyl and Aroclor plants had 12 years without lost tine accident. Prom the start of Aroclor manufacture at the Krummrich plant the operators have been supplied a clean change of clothes every day, and time has been allowed at the end of the shift for bathing. Operators are advised to wash hands and face before eating. The Anniston operators do not have the same issue of clean clothes. - ,, . ^ * Percy May, "Chemistry of Synthetic Drugs" , 3rd edition, page 1' The "Chemist Analyst", September 1W> Volume 36, No.2 page 33 -aad^a -reporAr4>y--1 n.--Anniat-or^ piant^-1937,- -gi-ve-de on the toxicity of diphenyl. MCC Bulletin P-ll^/mentioendsitiQoon) to 1,.0 mg. per cb. m i.n a.ir as t.h, < highest safe concentration of higher Aroclors, and 10 ng. ter more`highly chlorinated Aroclors. H. B. Edkins "Chemistry of Industrial Toxicology", page .^9 give 0.5 to 1.0 mg. as the allowable limit in working rooms. The MCC Bulletin "Physical Properties of Aroclors" mentions syatemic effects arising from the oral injection of Aroclors. See the letters, E. Mather to P.J.C.Haywood, December 17, 1551. Mather to Newman, January 8, 1952, reviewing the literature on t toxicity of Aroclors. See also correspondence relating to the article in Chem. & Ehg. Hay 17, 1954, pages 2038 and the warning labels menti^ed on page VI-3^ above. AGP CO WATER PCB-SD0000072557 c XI. HAZARDS, contd. xi - Hazi St. Louis, Main Office Mr. P. J. C. Haywood Newport (Airmail) c ^ Mi* dT c # c Mr. W. H. Ritchie`,-Rua Dr. H. R. Newman, Ruab Mr. S. M. Kulifay, Kru: Dr. D. S. Weddell, St. Mr. P. T. Marshall, St December 11, 1951 AROCLORS: .-TOXICITY Since writing to you on December 3rd I have come across . C a letter of nine to Mr. W. M. Cooper, London, June 24, 1948, (copies to W.D.S., W.H.G., and others), calling attention to an article in the J. T. Baker Company's "Chemist Analyst", Volume 26, Mo. 2, page 33, September 1947. I attach a copy of this article, and I think you will agree that the warning relates only to really bad exposure, not such as should occur in ordinary analytical work. On October 27# 1947 Mr. Barbre of the Krummrich plant sent a copy- of the Journal to Dr. Jenkins at Anniston for comment. Dr. Jenkins did not make any comments at the time, but the following extract from Mr. Barbre's letter is inter esting: "During the 11 years of production here only one man evidenced dermatitis. Ke had also shown similar symptoms in several other departments. When making Aroclor #1270 which is flaked, a noticeable amount of fine fume solidifies in the air. If men are exposed to it during hot humid weather, the skin Is Irritated, but we have not had any difficulty in curing cases of dermatitis from it". E000040 E. Matr.er C WATER PCB-SD0000072558 XI - HAZARDS, contd XI Kaza: The Chemist Analyst, Vol. 36, No. 2, page 33, J. T. Baker Chemical Co., Phllllpsburg, n. /. September 1947 * ON THE TOXICITY OP THE "AROCHLORS" (sic) Robert M. Brown, Chief Industrial Hygiene Section, Division of Health Dept, of Public Welfare, City of St.Louis, Mo. _ ' A recently published article (Maglio, M. Martin, Chemist Analyst, 32.94. (1946) ), has recommended the substitution of one of the "Arochlors" as the melting-point bath liquid in preference to the customary sulphuric acid. As stated in that article ''Arochlors" are a group of chlorinated diphenyls produced by the Monsanto Chemical Company. There is need therefore to give warning. Por the toxicity of these compounds has been repeatedly demonstrated, both from the standpoints of their absorption from the inspired air, as well as from their effects in produ c.lng a serious and disfiguring dermatitis when allowed to remain in contact with the skin. Since these effects have been repeatedly observed, industrial hygienists have taken care to see that the proper controls have been established wherever these products are used. Por example, the maximum allowable concentration of chlorinated diphenyl for an 8-hour working day is 1 milligram per cubic meter of air. It is probable that nothing like an uncontrolled Indust.-ial expo sure will occur -in the laboratory. However, whether an individual is subjected to a possible acute exposure to chlorinated diphenyl, and its serious consequences, will depend upon the size of the Mltlng-point bath, the caution with which it is used, and the temperature to which it may be heated. Likewise, with careless handling of the material and the resulting contamination of the skin, clothing, laboratory towels, work-table surfaces, etc. the way is left open for the producing of dermatitis. Scrupulous cleanliness must be insisted upon wherever this material is handled 1. The foregoing remarks have been prompted by the belief that in re commending the use of a material with which is associated a potenti. hazard from the health standpoint, it is very important that the possible consequences be presented together with recommendations fc: correct handling. Ennft04151 51 ACM CCZ WATER PCB-SD0000072559 XI. HAZARDS, contd. XT Haza Mr. A. C. W. Pennington of Newport, reporting on his Arne--'can tour, December 29, 1950, page 5, writes: "" ` "HEALTH AND SAFETY"; "At Anniston, no special protective clothing is provided the Diphenyl and Aroclors operators. A daily change of clothin was provided in the past but this practice ceased before the wa Gauntlet leather gloves and face shields are, of course, availa as required on the plant. " Tins of cold cream ointment, theatrical quality, are to in the building, but the application of the cream is left to th< operators decision of the Job in question. The men are expecte< take a bath, in their own time, at the end of the shift. A gooc quality soap, and alcohol for rubbing down purposes, are provide The operators are sufficiently trained in the need for personal cleanliness that a record of bath taking is not warranted. ' "Emergency showers are provided on each floor of the Diphe building and safety notices are widely used. "At St. Louis, Plant B, the Aroclors building is rated a toxic department. Each operator is provided with a complete set of clothing comprising hat, coat, trousers, combination under clothes, socks and rubber shoes. A clean change of clothing, except shoes, is placed in the operator's locker in tine for the following shift. Men working extra shifts are given a clean set of clothing. Canvas gloves and goggles are provided and 'Ply' hand barrier cream is available for use when necessary. "Twenty minutes' paid time is allotted for bathing at the end of the shift but, again, no record is kept that baths are actually taken. Theoretically, food is not allowed to be eaten within the Aroclors building. Instructions are issued that hands and face should be washed well before eating. "Bnployees in to::ic departments are given an annual medical examination and a lung X-ray every three years.". EnoniMg 52 ACM OC WATER PCB-SD0000072560 XI. HAZARDS, contd XI Kazan: Toxicity, contd. A good deal of work has been done on determination cf the va-cu- pressure of the Aroclors, and on the determination ofJconc--.c-a- of Aroclors in air. See pages 9-, Section III, above, for~a"su~ of this work. 1* " In 1950 (letter April 20, N. P. Rapps to E. Mather) the Admiralt; expressed interest in the determination of micro-quantities of * Aroclors. MCC have a method for the determination of traces in air by means of the "Halidometer". Mr. Ellenburg, March 15, 195^, mentions work done by H. B. Richar Jr., of MCC, June 17, 1953, on the determination of the concentra of Aroclors in air. Mr. Ellenburg also states: "------------work on the safe limits of Aroclor vapour concen tration in air is being carried on by the Medical Department at the Kettering Laboratories in Cincinnati. This work on animals is well under way, and will help us to know a little better Just what is the safe limit of Aroclor Vapours that one might work in." A question has been asked about the possible harm to plants if Arc containing paints are used in greenhouses. The reply is that most paints are somewhat harmful, and there is no evidence that Aroclor make then worse. Aroclors have been used as rabbit repeliants, wi out doing any harm to vegetation. Care is needed in laboratories etc. where Aroclcrs are used in heating baths; there should be very positive ventilation. The vapours of hot Aroclors are distinctly irritating to eyes and nose above a concentration of about 5 mg per cbm in air. Newport plant report for December 1951 records bums by hot Aroclor -- a case of a splash into a man's eye -- without serious damage. Packages of Aroclors leaving the Krummrich plant tear a label call: attention to possible toxic effects. Ennnn43 c-j ACM CC 4 WATER PCB-SD0000072561 XI. HAZARDS, cohtd x: Haza Fire Hazards Diphenyl, of course, will burn, and reasonable care is needed in handling it. Precautions with toluene are mentioned also on page VI-29# and under "Special Risks", below. The Aroclors are handled as if non-inflammable. Drums of materia are melted in the middle of the operating building, by open gas" flames, and open gas flames are freely used to heat pipelines. An instruction, dated April 28, 19^8, calls for a dally inspectior of safety showers, fire extinguishers and gas masks, a check list being provided. Flanged Joints on Aroclor heating system can be a source of fume. See the notes on gaskets, page 2, Section XII, below. Phosgene may be generated in electrical flashes and fires in trana formers containing Aroclors, but this is not thought to be a major risk. Safety Equipment Each operator in the Krumnrich Aroclor plant is supplied with goggl rubber covered gloves, canvas gloves, rubber shoes and fume respira See also page XI-1. A spare suit of clothes is kept in a case in t % --usual ^aid --cabin* tV'-gaS-'Sa *(chlorine), fire extinguisher, (toluene, diphenyl), stretcher, safe showers, drinking fountain, eye bath. Special Risks ' The usual care is necessary in dealing with chlorine, in lighting the gas furnaces, and in handling hot materials, steam lines etc. Diphenyl might start to burn in chlorine gas if conditions in the chiorinator were badly out of line. A Davis "Vapotester", model K-l*. Type A, (Division of Davis Energene ' Equipment Co., Inc., Newark, N.J.)- is held in the department for use in testing the air of the working building after tcluene has been used, and for testing vessels before men are permitted to enter, and before "flame certificates'' are given. The Instrument contains a E000044 ACM C0 f 54 WATER PCB-SD0000072562 c XT. HAZAJRL3, contd XI - 7 Hazard; Special Risks, contd. catalytic cell electrically heated to a fixed temperature, and th. air to be tested Is aspirated through It by means of a "squeeze ball". If combustible vapours are present, the temperature of tht cell rises, and the indicating thermocouple registers on a cali brated scale. The instrument has a zero adjustment, and it Is checked twice a month by the instrument department. Flame certificates must give the number of the Vapotester used, also the data of its last cali bration by the instrument department. The instrument has been use ful in detecting gas escapes, and in tracing spills of gasoline, etc., from a neighbouring oil refinery into a public sewer which runs under Monsanto territory. Mr. Benignus, of St. Louis, September 1953., discussed the dangers of using Aroclors In Indoor paints. He discounted the possible dangers from phosgene formed by flash discharge* In transformers charged with Aroclors. - See the references to safe handling of glycidyl phenyl ether on pages IX-161 etc. v.Vk JR. c F.nnon^5 ACf* 55 OC25 WATER PCB-SD0000072563 At St. LotUa C(CTZ?.'7IAL *r. k. m. Webber Oats November 14, 1955 To Hr. H. B. p&trlck Roftranct At Krummrich Plant Subject DEPARTMENT 246 (AROCLORS) Zt is tha opinion of the Medical Department that the eating of lunches should not be allowed in this department for a nunber of reasons. (1) Aroclor vapors and other process vapors could con taminate the lunches unless they were properly pro tected. (2) When working with this material, the chance of contami nating hands and subsequently contaminating the food is a definite posslbllty. (3) It has long been the opinion of the Medical Department that eating in process departments is a potentially hazardous procedure that could lead to serious dlfflcultles. While the Aroclors are not particularly hazardous from our own experience, this is a diffi cult problem to define because early literature work claimed that chlorinated biphenyls were quite toxic materials by ingestion or inhalation. In sny case where a workman claimed physical harm from sny contaminated food, it would be extremely difficult on the basis of past literature reports to counter such claims. * - JSQsSMB Cm m 38 : paa 004414 MON 0309 WATER PCB-SD0000072564 MONSANTO COMPANY anniston, alasama STANDARD OPERATING INSTRUCTION! 701 AR0CL01S Revised: July 1964 Copy Mo. AS* Prepared by: J. V. Molloy Production Supervisor I. 6. Moody Production Superintend* -TV* 4 vLv* CONFIDENTIAL a aiGu=i wm0093 64 ADM 0C WATER PCB-SD0000072565 f I r I I Knororn ADM 002506 65 WATER PCB-SD0000072566 OPERATING INSTRUCTIONS A&OCLORS SAPSTY AM) norslurry?me S*ft7 of operation* la tha Aroelor Plant dapenda on the individual operator. Matarlala baing handlad and oparaeioaa auat ba obaarvad eloeely to guard agaiaat tha following: l. Chlorine Gaa 2. Thermal lurai Cauae & Action to Prevent Chlorina gaa la a vary toxic corroaiva gaa. Laaka or high praaaura can occur to libarata it. Action to Prevent: a. laport Chlorina gaa axpoaura iaaadietaly for traataant with Aatldota. Milk My ba uaad in lid eaaaa to relieve throat irritation. Oxygon fro tha raauacltator in tha Wapanaary ' la available. b. Keep gaa aaak in good condition. Reap a good canlatar la tha aaak. Uaa thaaa typa aaaka only In Chlorina concantratlona to 2*31 Chiorit in air. c. Oaa a Scott Air Pak in eoncantratlona of Chiori gaa above 31 la air. Three unite are available in tha AroelorBiphenyl Departaant. d. If caught in Chlorine gaa without a aaak, hold your breath and go croaa wind until you are out of range of the gaa. Place a handkerchief over your noae in aaall quantltlea of Chlorlaa. a. Report all Chlorina leaka for repair iaaediateT. Make temporary repaira with tape if poeslble. f. Za eaae of e aejor Chlorlaa leak the aource of Chlorine gaa auat be atopped. Votify tha Chlorina Plant Iwdiately If tha praaaura on tha Chlorina enifold excaeda 30 palg. Cut off liquid Chlorina fro* the car. Contact with hot unineulated product llaea at tha ehlorlnatora and atlll araaa. Contact with unlnaulatad atea* linea and opaa eteaa. Coneact with hot Aroclora fro* broken linea or leaka. Contact with open flaaua at atiila or fro* heating linea in the departaant. 1,000095 66 ACM C C WATER PCB-SD0000072567 ( OPDATISC DJST&0C7I0HS A&OCLGU B. SATKTT ASP HOC3EX1ZFISC Action to Prevent: 2. Thermal Bum* (Coat'd.) n. bw that contact with equipa.nc and product will cause 4 charnel burn duo to tho high temperatures. Hake changes la oporotlono with this hasard In alnd. h. Know tho first old treetaeat for burns. Cold Wotor Treatment (Soo Appendix A Eaorgoocy Section). * Veer glevos oad long sloovo shirts with tho sloovos rolled down when oporsting. Clowes ond clothing con make tho differ between first oad second degree burns* d. Keport unlnsulteed lines for repair of lasulotloa. e. Use only steam lines with hose oad hoee clomps la good condition. f. The following oporotlono ore hosordouO and should be done with core: (1) Cotehlag series ot the Aroclor chiorInstor eirculotlng puaps. (2) Seafling the Solid Aroclor still receiver. (3) Drawing bottoms on the Aroclor still 3. Explosion . Aa explosion could occur In the ehlorln* by slugging liquid chlorine to the dis tributor or shutting off the voter die charge valve on the chlorlnotor cooling coll. Slugs of Liquid Chlorine could react foot enough to cause excessive pressure in the vessel. A rupture of th chlorlnotor could occur. Closing the water discharge valve on the chlorlnetor cooling coll isolates voter In the coll. As the reaction occurs releasing heat, the voter will vaporise end could split coll ond tnak. Action to Prevent: Observe operation of the Chlorine veport ead do not let liquid Chlorine get Into the roteaeters. Pipe lines will be frosted. FAfl(W6 67 ACr cc. WATER PCB-SD0000072568 OFQATXSG OtSTOUCTIORS A10CL0U 3APETT AHP HOCSEaZPIUC 3. Kxplosieo (Coat'd.) b. In eats Chlorine fssd Uses are frost- eloss liquid Chlorine feed valve to ti vaporizer. Chock stean addition to.ti vaporizer. Xaspeec oporscion of the veporlzer. Do not start up until sour of trouble has been locited. e. Do not close velve In water discharge line fro* the chlorlnstor coll. d. Observe te^ersture of the chlorlnstor periodically end be sure It Is not too hot (180C aart :) . A. Tails Slipping on esaent floors, stairs, Arooa floor, les conditions; tripping ovs objects (hose, pipe, velve handles, et or losing footing on ladders, etc., cai cause falls. Action to Trsvont: a. The majority of nlnor, serious, snd net miss Injuries In the Arocler Dept, ere the result of falls. Prevention Is al% within the ability of the operator by u of expert operating practices. b. The following ltesss should be done: (1) leturn hose to rack after using. (2) Keep operating areas dean of all foreign objects. (3) latum ladders to racks vhen not In use. (A) Keep gloves on and bands out of poc especially going up stairs. (3) Place guards around any area that presents a hazard that should be guarded. c. Poor lighting due to burned out bulbs should be corrected at once. Poor light lag due to lnedequece facilities should be reported. d Kflaonsw Spill Bust bo cleaned up loaedleeely following their occurrence, leport eny eplll thet can not be cleaned up within Che ehlft to the Chief Operator. SpiJ*` ere to be reported in the log book. 68 WATER PCB-SD0000072569 0?ntATG DtSTMCTlOBS A10CWB3 SAyiTT AFP HOPS*rgg>IBG 3. Firu Fires can occur by: Biphenyl, Sencowex if 0r gantowa: ignition. Chlorine problems la tbo veporix. allowing reaction with steam to release Hydrogen. Furnaea burner backfire. Wood, rags, or paper on hoe line* Sparks from voiding apparatus or opoa flames. Action to Prevent: a. Area Bust be doer of trash or flaama nateriais. Use trash skips and cans* b. Saoka only in areas so designated. e. Baa spark producing equipment only vii a fire parnit and proper inspection.- d. Use care in lighting gas torehs or th still furnaees. e. Fire fighting equipment includes: (1) TWo wheeled dry powder units. (2) Bose house with 200 ft. of hose. (3) Two dry pwdar hand extinguishers, One CO2 hand extinguisher. (4) Two 3/4" water hoses. (5) Hose connection north of Santcwax. (6) Scoet Air Feks. (7) Fire truck in fire house. f. Observe visitors in the plant and be sv they observe safety rules. 6. The following is a list of the ehoBicals handled in the Aroclor Plant operations and the precautions to be taken during their handling: a. Chlorine Can j.'prrnc8 Chlorine is a vary toxie corrosive gas. Le or back pressure can occur and liberate chi rise gas in the area. Operators should hav their cartridge type respirators handy at a tines while la the area. Use of gas seeks explained in Section B-i. 69 WATER PCB-SD0000072570 OPDUTIHG ISSTIUCTICRS AEOCLQBS sxmrr mp HonsHnrffTXfl 6 a* Chiorla Gat (Coat'd*) If you art caught vithout a gas Mik ,ni larga counts of chlcria. g., ar# llb,,. hold your braath aad go cross viad until you ara out of raega of cha gaa. Onca o f tha area, obtala an aaargaaey gaa aaa aad ratura to tha araa aad corract tha t: b. Biphony1 e. Santovax & d. Saatovax C a. ferric Chlorlda f. Attapulgus Zarth g. Bydracad Lima h. Cruda Aroclora d vietin af chlorlaa gaa fuaaa aitt ba r< aa quickly aa poaalbla frea tha gaaaoua i Placa patiaat oa hia back with head aad t alavatad. Milk nay ba uaad la aild cases a rallaf frev throat irritatloo. If tha patiaat haa a topped breathing, atare arti ficial raaplratloa iaaedlataly. llphaayl la a flaonable material which wi burn. Buraleg ahould not ba dona la tha praaaaca of Blphaayl or Blphaayl vapors, alelag point la 68.7C., flaah point 106 tha flra point 1269C., aad tha auto ignlt. temperature la 258C. Inhalation of Blph fuaaa la not racoaaaadod alaca it can cau; a drugged efface oa tha paraon. Saatovax K la a flaonabla aatarlal which t burn. It la relatively non-toxic to huaat baiaga. Bovover, tha vapora of Saatovax 1 ara irrltaelag to the mucous membranes ant bronlehlal tract. Prolonged breathing of tha vapora ahould ba avoided. The neltlag point la 140C. Saxe aa Saatovax B, alaca it la tha cruda aatarlal prior to dlatlllatioa. Parrlc Chlorlda la a black-brovn aolid. I causes only slightly Irrltaelag effaces oa tha akin or aaicous membranes. When heated it rill decompose end release eoxlc fuaaa of HU (hydrochloric acid). It will react vlth water eo produca toxic and corrosive Ba fuaaa* This aatarlal la a dried earth. Ho danger la handling. Wash off with waeer to clean Bo particular hazard la handling this as tax Tha dust la Irritating to the eyes end skit aad should ba washed off with water. Cruda Aroclora are hot since ell are bandit In steam eraced or Jaekeeed lines. They ea easily cause thermal burna in contact with WATER PCB-SD0000072571 OPtUTISG XNST&OCTXOHS AiOCLOlS sjjttt up Hocsnapac 6. h. Crude Aroders (Coat'd.) the skin. Prior to air bloving the *^*^*1 HC1 fuaas anerained ia ie which oro irritating to tho skin or *coue aaabranes. i. Bydrofon Chloriao Coo Thio t corrosive got vhieh la toxic. Z io irrieating to tha aueouo uabracu( hho eyas, aad to tha raapiratory tract. Xt will react with water to iora Hydro chloric Acid. J. Still Bottoas or Eaiidua fuaat froa a till bottoas era toxic. Th ora axtraaely irritating to tha aueous neabrsnes, to tha eyes, and raapiratory tract. HOOSBaPUC Tha Aroclor ehloriaator aad still oporators ora responsible for house keeping during thair shift. Coed housekeeping is the nark of good operations, safety practices, quality, aad costs. . Housekeeping duties are equal la i^ortaace with all other operating dutla Poor Practices Action to Prevent 1. Hoses, valve handles, dip a. toplaca after ase. sticks, rags, and other notarial os ground or floor, b. Hove piece to store ell accessory operating elds. 2. Product leaks c. Keport needs to supervision. a. Tighten valve packing glaads aad flange belts. b. laport leaks to Chief Operator for aalnteaance alteration. 2. Trash aad crude druns a. Contact chief to have drvsas noved fr area. 4. Product spills or eleaa out nesses b. Vse trash skip ia area aQH cq a. Prevent necessity of eiean-out by keeping tracing, insulation, or Jacks ia good repair by getting Iteau turns la for nalnteaaace work. b. Spills oust be cleaned up when they a node. Clean up will continue through the foilwring shifts to finish the Jot Fnnnioo 71 WATER PCB-SD0000072572 O^LiAlIKG INSTRUCTIONS AHOCLORS 32. DETAILED INSTRUCTIONS III. Loading Refined Aroclora Arodors are shipped in fivs gallon cans;. 55 gallon druma; 4,000, 7 OCC and 8,000 gallon eank cars; and 3,000 or 4,000 gallon tank trucks to * cuitoaari. a. Spotting Tank Cars Normally tha railroad twitch crtw will spot cars at tha Aroclor loading dock. Occasionally it will ba nacassary to move a car. Vhan It is nacaaaary usa tha half traek and pull tha car into position. (1) Obtain halp to move tha ear. (2) Attach hook on cable at front of tha half track to a strong part of tha car. Do not hook onto tha ladder or other weak parts. (3) Release tha winch and lat out 15 to 20 feat of cable to connect to tha car. (4) Release tha brakes on tha car. (5) Usa the half track to pull tha car into position. Put tha half track in four wheal drive. Do not uaa the winch to pull tha car. (6) Stop pulling tha ear whan it is in position. (7) Sat tha brake on tha car. (8) Remove the cable hook from tha car and wind up on tha winch drua. b. Pilling Tank Cars or Trucks Aroclors are shipped in lined vassals to protect the electrical pro* parties fro* cootaari.natlon. Moat vassals are lined with aluainua or a sine-tin lining. (1) Inspection of car or truck for loading: " (a) Inter each ear or truck for inspection prior to loading. If necessary clean out the vassal. All material in tha tank should be removed. Damaged lining areas should ba cleaned . of rust particles. Report daaaged areas. (b) Use a tank entering permit and a fire pernit when entering a car. Observe safety rules for each permit. (c) A fellow worker oust be on top of the car holding the rope harness. Vear the safety belt harness, an air mask, gas test the car, and uaa a light when entering a tank car or truck. Fnnmoi ADM C02513 . 72 - - ' t * - WATER PCB-SD0000072573 OPERATING INSTRUCTIONS AROCLORS 33. DETAILED INSTRUCTIONS 111* b. (1) (d) Fill out tank inspection sheet. (2) Put itM on the enr after it ia dean. (3) Check to be sure there Is enough Material in a storage tank to load a car or truck as required. (An 8,000 gallon car requires about 63" of Material in #2, #3, and #4 storage tanks. (4) Circulate the Material in the storage tank for two (2) hours, sample the tank, and have the sample checked for loading by the laboratory. If Material is in specification proceed with loading of the tank. (5) Install diaper cloth sock in the filter in the loading line and place a sock over the end of the loading line extension. (6) Attach extension to the loading line at the dock and place sock end into the dome of the car. (7) Connect ground vlre to the car. (8) Set valves in the loading line fron the storage tank to the loading dock. Do not open valve in line at the car. , NOTE: Cara ahould be taken to see that the correct valves are opened so only the desired Arodor enters the loading line. (9) Start pump at the storage tank. (10) Open valve in drain line at the loading dock and allow one drum of Arodor to flow through the line to flush out the loading line. (11) Close valve in drain line and open valve in line to the can. Approximately 2% hours is required to load a car. * (12) When the car is loaded, stop the pump, and dose valve to the loading line. Fill car up one to two feet into the dome of the ear. (13) Kamova loading line fron car. (14) Take samples from ear and send to laboratory for final analysis. (See Schedule) - AOM 0C25l' 73 WATER PCB-SD0000072574 operating isstr,jctic:3 AROCLORS DETAILED DESTRUCTION3 III. b. (14) SAMPLES TO BE TAXBT POR LI07ID AROCLOR LOTS MATERIAL TAME CAES - TRL'CES or DRCTR 1221 2 x 1/2 Gllon 1232 2 x 1/2 Gallon 1242 3 x 1/2 GAllon & l x 5 Flat 1248 2 x 1/2 Gallon 1234 3 x 1/2 CAllon 4 1x5 Fine 1260 3 x 1/2 CAllon 1262 2 x 1/2 GAllon (15) Clot# and tightan lid on cat. (16) Seal car and reeord seal number and car number in Aroclor log book. c. Filling Prune . Liquid Aroclor can be druoaed from the storage tanka or the filtrate receiver. Solid Aroclora that are drummed are normally filled from the etill receiver. Solid Aroclora 1268 and 3460 are normally flaked and bagged. Aroclor 2365 la a non-distilled product which Is drummed from the blowing tanks. The following steps should be followed when material la to be drummed:.- (1) Send a representative sample (1/2 Gal. for Liquid Aroclora) of the material to the laboratory for Inspection. If the meterlal Is via storage tank It should be circulated for two (2) hours. Material In a filtrate receiver or blowing tank should be agitated for 20 to 30 minutes. If material Is in specification proceed with druaad.ng. (2) Check the scales to be used. Set the scalas for the weight specified for each drum (See Table IV). (3) Start the pump. mom 03 ACM 0C2515 74 WATER PCB-SD0000072575 . Material 1221 1232 1242 1243 1254 1260 . 1262 1262 - 101 Toluan* 1262 - 101 Xylan* 1260 - 101 Toluana A13B3B 5442 2565 4465 Inartaen PFO TklLZ 17 AROCIOR FINISHED COCOS DRUM WEIGHTS Drun Uatahta tba. - 5 Gals. & 55 Caia. 50 or 520 50 or 550 55 or 600 55 or 600 60 or 600 60 or 600 60 or 600 60 or 600 60 or 600 60 or 600 65 or 675 50 or 450 500 50 or 500 Mi, 360, AC* CC?51fc i;onnm4 75 WATER PCB-SD0000072576 0FE3A7ISG INSTRUCTIONS aaoclors 36. DETAILED mSTEUCTIOKS 17. Tlaklnn Arodors Arodors 1266, 3460, and 3060 *ri flaked on a drua flaker and ba22.1t: in 100 lk. bags * M a. Praoaratlon for Tlaklni (1) Place hot Arodor boat on cba pips lines, valves, and flakar bold tank. Hast tbs Arodor systsa up to 230C. Obssrvs temperature on tha aulti-point rscordsr In tbs cblotlnaeor control rooa. (2) Pump Arodor to ba flaked Into tbs flakar bold tank. (3) Check tsopsraturs of notarial la tbs bold tank. Zt should bs 22QC. oln. Ta^eratura recorded on #3 still nulci-oolat rscordsr. r b. Start-Do of Flakar Systsa (1) Turn electrical beat in tbs flakar pan on about 20 to 30 alnutas before start-up. (2) Open valve in water line feed to tbs flakar drua. (3) Start the flakar drua. Start breaker at discharge of flakar. (4) Open valve at bottoa of the flakar bold tank. (3) Open valve at sight glass to start Arodor feed Into the flakar pan. Observe flow la sight glass. Adjust valve to aalntaln tbs level in the flakar drua about one inch froa tbs top of the drua. (6) Observe operation to be sure the drua Is picking up the aatarlal. (7) After the flaker has run 13 to 20 alnutas notify tha Chief . Operator aatarlal Is in the hopper to be bagged. () Continue to flake until the flakar bold tank Is aapty. e. ttutdown of Usher (|) normally the flakar will be run until the hold tank Is aapty. (2) Allow the drum to pick up aatarlal froa tha pan until It will no longer contact tha hot liquid product. (3) Stop the flaker drua end the breakers. I ) < ACM 002517 loom 05 76 WATER PCB-SD0000072577 OPERATING IKSTR'JCTICSS AROCLORS 40. DETAILED mSTRUCTICWS VI. Mlllltn Aroclori Aroclor 1268 is the only Aroclor which is sold as 4 *111*1 orodur* The material aasc first bo flokod. * 0. Soloct tho druae of materiel to bo milled. b. Cheek tho feeler to bo ured. Piece e new drum under the milling archie* to collect tho 1266. c. Cruehed dry ie* la ueod during milling to keep the aechin* cool. Thla keope tho Aroclor 1268 froa clogging up the machine. d. Start the *111 end auger. * 7111 tho bucket with cruehed 1268. f. Blond dry lee with tho 1268 end feed It into the hoppor over the ill. Ufa approximately five pounds of dry ice to each 100 pounds of Aroclor 1268 that la allied. g. 7111 tho druas to the specified weight (noraelly 200 lbs.). Stencil tho druas with the near of the product, lot number, not weight of each drum, and the initials of the person doing the work. h. Continue this operation until the required number of drums are filled. Then atop the milling machine an* clean up the series, the milling machine, and the milling room. 1. All drums filled are palletised and moved to the loading platform for transfer to the warehouse. I 1 ' KILLING Ennoi06 ACM 002518 77 WATER PCB-SD0000072578 ^Hr /BCC D. F. Smith - St, Louis November 30, 1961 Mr, Bruce Smith General Electric Company Evendale - Building TOO Cincinnati, Ohio Dear Mr, Smith1 Mr. a. V. McKinney of our Cincinnati office has asked me to forward data and comments concerning the toxiolty of our industrial fluids Pydr&ul F-9 andcpydraul A-200. Enclosed are two sheets summarising the animal toxicity data and known human experience with these fluids, Mr. McKinney mentioned that you were interested specifically in the toxiolty of the vapors of these fluids and secondly, in the possible hazards resulting from skin contact. As indicated in the enclosures, exposures to high concentra tions of vapors for a short period do not constitute a serious hazard. At normal temperatures, the vapor pressures of the fluids are suoh that little vapor is present in the atmosphere. When the fluids are in a system under pressure and at elevated temperatures, economical and efficient use of the fluids dic tates minimum leakage be allowed during normal operations. In the event of a system failure suoh that the fluid ie sprayed as a mitt, either into the atmosphere or against molten metal or hot surfaces, the toxicity hazard ia not serious since the concentrations of the mist, vapors and/or decomposition products would be discomforting to the degree that workmen would not voluntarily expose themselves for sufficiently long periods to experience a serious toxic effect. In regard to skin contact, the possible reaction following pro longed and repeated skin exposure is more apt to be one where the fluids have acted as a good solvent, much like a oommon paint thinner or remover. Like many organlo liquids, these WATER PCB-SD0000072579 Mr. Bruce Smith - Page 2 - November 30, 1961 fluids can dissolve the natural oils and fats on the surface of the skin, leading to drying and craoking. For this reason, we recommend that prolonged skin contact be avoided. Although we have not made a complete chemical analysis of the decomposition products when either fluid is thermally decom posed, the survival of animals in suitable exposure chambers to massive concentrations of vapors, smoke and decomposition produots Indicates that phosgene is not a major component of ouch decomposition produots. Depending on the conditions of pyrolysis or decomposition, the products include carbon mon oxide, carbon dioxide, water vapor and aldehydes, such as one would expect with the decomposition of any complex organlo compound. The only significant additional product would be hydrochloric aoid. This may add to the acrid and irritating properties of the decomposition products and may be accountable for its discomforting or unpleasant effect on the nose and throat. For praotloal purposes, this could be considered an advantage in that the irritation limits the amount of exposure that any person would experience. If I can be of any further assistance, please let me know. Very truly yours. Elmer P. Wheeler Assistant Director Medical Department EPWjdh Enclosures 2 cc Mr. Gordon W. McKinney Monsanto Chemloal Company 2330 Victory Parkway Cincinnati 6, Ohio NfcV OQJdVO 703128 WATER PCB-SD0000072580 2 THE PROPER HANDLING OF AROCLORS AND. THEIR MIXTURES I IN THE ELECTRICAL INDUSTRY \ 'V ' , ' bUlM* .. _ ^ - - t * . >n Monsanto Chemical Co. Organic Div. Sales' Dept. 800 N. Lindbergh Blvd. St. Louis 66, Mo. i i 1 J Ii i P. C. BENIGNUS RtvIiW jtmitrr 1940 wn***8 1 ../ME 0000% ** , " *t -1 WATER PCB-SD0000072581 INDEX Introduction - Page 1-2 Chapter 1 - Page 3-12 Page 3 Page 4 Page 12 Chapter 2 - Page 13-19 Page 13 Page 17 Chapter 3 - Page 20-21A Page 20 Page 21 Chapter 4 - Page 22-25 Page 22 Page 23 Page 25 Chapter 5 - Page 26-28 Page 26 Chapter 6 - Page 29-61 Page 29 Page 31 Page 31 Page 32 Page 38 The Proper Handling Of Aroclors And Their Mixtures In The Electrical Industry Procedure For Unloading Tankcars Of Aroclors And Aroclor Mixtures k) Description of the Cars iB) Procedure for Unloading the Cars C) Drum Packaging Storage Tanks (A) General Description (b) Detailed Description Gasketing and Pump Packing (A) Suggested Types Of Packing and Gasketing Materials (B) Gaskets For Askarel Capacitors and Transformers Sampling Methods *1 The ASTM Standard Method Monsanto Methods C) Drum Sampling Laboratory Analysis and Procedure (A) For Treating Aroclors and Their Mixtures with Earth Test Procedures (A) General Information (b) Detailed Instruction and Testing Methods 1. Procedure for Cleaning Electrodes 2. Dielectric Constant and Power Factor 3. Dielectric Strength me 000091 WATER PCB-SD0000072582 Page 44 ^ Page 47 - Page 49 - Page 51 Page 52 Page 55 Page 59 Chapter 7 - Page 62-73 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Chapter 8 - Page 74-76 Page 74 Page 74 Page 75 Chapter 9 - Page 77-79 Page 77 Page 77 Page 78 Page 79 4. Resistivity 5. Corrosion and Chemical Stability 6. Inorganic Chlorides 7. Acid Number 8. Moisture 9. Hydrolysis Stability Test . for Aroclor 10. Thermal Stability Method for Aroclors Typical Properties Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Pyranol 1481 Pyranol 1488 Pyranol 1467 Pyranol 1470 Inerteen PPO Quality Requirements of Aroclors Prior to Use in the Electrical Industry Quality as Supplied to the Electrical Industry Typical Electrical Quality of Aroclors Used in the Industry Capacitor Impregnation Transformer Filling Earth Refinement of Aroclors to Arrive at the Desired Elec trical Qualities Earth Treatment in the Laboratory Preparatory to Analysis Earth Treatment by the Plant Manufacturing the Askarel Earth Refinement by the User Capacitor Manufacturers Transformer Manufacturers The Effect of Earth Refinement on Removal of Tin Tetraphenyl Scavengers from Transformer Astcarel fcftfVlK70 ME 000092 WATER PCB-SD0000072583 Chapter 10 - Page 80-93 ' Page 80 - Page 83 Contamination Avoidance of Contaminating Askarel Capacitors Avoidance of Contaminating Askarel Transformers Chapter 11 - Page 9^-97 Page 94 Page 95 Chapter 12 - Page 98-IOO Page 98 Page 99 Page 100 Reworking Contaminated Transformer Askarel Normal Conditions Arced Conditions Dermatology and Toxicology Skin Exposure Exposure to Vapors Vapors from a Severely Arced Askarel Transformer Attachments: Drawing No. 31-20847, The Tank Car Drawing No. 31-20848, Dome Detail Drawing No. 9C-8170-5, The Horizontal Storage Tank Drawing No. D-13362, The Vertical Storage Tank Drawing No. 9C-8248, The Breather Drawing No. 9C-8278, The Varec Gauge Drawing No. 9C-8178, The Unloading Platform (.'001 K*71 t-- 000093 WATER PCB-SD0000072584 CHAPTER 12 DERMATOLOGY AND TOXICOLOGY Skin Exposure Aroclors, or askarels, accidentally spilled on the ` skin do not cause an acute toxicity hazard, nor will they cause serious Irritation. The materials should be washed from the skin with soap and water. Prolonged skin contact should be avoided. If work clothes become impregnated with these fluids, they should be removed and washed. When sampling tank cars, canvas gloves and safety glasses, or goggles, should be worn. No special clothing is required, but the workers1 garments should be laundered at least weekly and changed, if Aroclors or askarels are spilled on the clothes. If accidental burns occur from contact with hot askarels, the burn should be treated the same as any ordinary burn. Aroclor, or askarel, adhering to the burned area need hot be removed immediately unless treatment of the burn demands it - in which case, soap, and water, or.repeated washings with a vegetable oil should be used. Accidental''contact with the eyes results in painful irritation, but not permanent damage to the tissues or the Bight. In event of such contact, the eyes should be flushed with a large amount of water for at least 15 minutes. The patient should then be referred to a physician who will treat with an ointment to soothe the eye. *98' F001R72 ME 000094 WATER PCB-SD0000072585 Exposure to Vapors Vapors from hot Aroclor, or askarel, have a degree of toxicity and should not be inhaled over a prolonged period . of time. Experimental work on animals indicates that the maximum safe concentrations of vapors in work rooms is in the range of 0.5 to 1.0 mg. per cubic meter of air. Harmful amounts of the materials are readily detectable by odor and irritation to the eyes. Usually, people can detect concen trations of askarels in the amount of 1.0 mg. per cubic meter of air, which is the level regarded ks the safe work room limit for an 8 hour day exposure. Capacitor impregnations may be done at temperatures as high as 266F. (130C.). Following impregnation and draining the chamber, exhaust ventilation should be applied to the chamber to prevent askarel vapors entering the work room. Also, when opening a heated capacitor impregnating chamber, the workmen should wear a respirator during this short interval of exposure. If transformer askarels are used at temperatures above 125 to I50F. to fill an open.transformer, exhauBt ventilation should be provided In the immediate area^ The many years of satisfactory and safe UBe of Aroclors, or askarels, by the electrical industry for impregnating capacitors and filling transformers has demonstrated the Industry's ability to handle these fluids without hazard to the workmen. It Is both simple and In line with "good housekeeping" and personal cleanliness to exercise the suggested precautions in all cases. -99- FftOl WA N'E 000095 WATER PCB-SD0000072586 Vapors from a Severely Arced Askarel Transformer Experimental data indicate that when askarel is decomposed <by an electric arc, insignificant amounts of chlorine and phosgene gas are liberated. The gas is almost entirely hydrogen chloride, which is readily detectable by its odor and its irritating characteristics in even small amounts. Thereby, adequate warning of its presence is provided and significant amounts of fumes would be lijcely to cause a hazard only in a closed area. Individuals would not voluntarily expose themselves to serious toxic levels of the hydrogen chloride gas fumes. -100- FAM - ME00009G WATER PCB-SD0000072587 ' AROCLOR Resins end Plasticizers fo r Chlorinated Rubber f AljR AROCLOR Resins and Plasticizers for Chlorinated Rubber Technical Bulletin 0*124 May, 1?37 Monsanto Chemical Company, Organic Chemicals Division, St. Louis 1, Mo. Introduction h/fonsanto produces a series of chlorinated biphenyls and polyphenyls Identified by the trademark Aroclor* for use as plasticizers and resins for chlorinated rubber base lacquers, varnishes and punts. These protective coatings are fire resistant, corrosion resistant, chemical resistant (to acids, alkalies and water), and have good electrical insulating properties. '* V/hen properly pigmented, these coatings have good weatherability. Chlorinated rubber films plasticized frith an Aroclor grip common structural materials in strong adhesive bonds. Addition of an Aroclor improves the flexibility and life of chlorinated ' rubber and plastic coatings. 1 he formulations suggested in this bulletin are common in commercial practice. They are given as a starting point or guide in developing formulations that expand the outstanding qualities of these compounds. 905992 f M onsanto Technical Bulletin 0 *1 2 4 May, 1957 WATER PCB-SD0000072588 ? Some important applications for protective and decorative coatings plasticized with ArecSbr compounds - - ' . Wood and metal used In yachts, barges and other marine craft. " Structural steel for bridges, buildings, roofs and - power-lines. . Structural materials at chemical plants, pulp and paper mills, textile mills, petroleum refineries and gas works for protection against acid fumes, alkalies and gas. ' Tank cars and other rolling stock and construction machinery for protection against corro sive materials and weathering. Equipment and stop-off lacquers used in elec troplating. . ` Masonry floors and walls. Concrete swimming pools. Highway markings. Cable coatings requiring fire resistance, chemical resistance, and excellent electrical properties. Textile coatings resistant to chemicals, fire and water. ~ 1000S5 905993 WATER PCB-SD0000072589 TABLE OF CONTENTS . Page Naming and Preparation of Aroclor Compounds.._____ __________ __ 3 Properties of Chlorinated Rubber General....--------------------------------------------........------------------...___ 4 Physical..............------------------ ..........------- --------- ...... 4 ' Chemical Resistance------- ....------ ---.--......-------------- ----- ..... A Electrical------------------------------- ------------ ......------------------------- .... A Mechanical...----------------------------------- .....5 Thermal....._.........--....... 5 Physical-Chemical___________ --______________ 5 Viscosity Types_____ ____________....---------------------------- 5 Solvent Compatibility..........................._...................... 6 Formulation and Properties of Chlorinated Rubber Formulation for Aroclor Resins__ ____............_.............___ & Formulation for Aroclor Plasticizers___ __________________ __......... 6 Properties of Formulated Films..____________ ....._________ _______ 7 Applications - Alkaline-Resistant Coatings------------------------------------------------------------------ 8 Chemical-Resistant Finishes...--.......--.....-- ---------- ....... 6 Marine Finishes.................-- .--.....------------------------------- 9 Emulsion Paints.;... ....___ _--............ ------ --- ------------ ... 9 Adhesives---..................................................................... -----------------------10 * Paper and Textile Coatings................................. 10 Electrical Coatings------------------- 10 Printing Inks----------------------- ...10 Resins for Chlorinated Rubber..--...II Monsanto Plasticizers for Chlorinated Rubber.............................. 11 Toxicity______________________________________12 Shipping Information --.1.--...--...-----------------------------1---------....... 12 Trademark Index.........--........------------- ..... ...--.........--...13 Util bulletin replaces technical bulletin P-124. 100030 - 2- 905994 WATER PCB-SD0000072590 Naming and Preparation of Aroclor Compounds Benzene Bubbled through molten lead I Biphenyl and Terpheny! Mixture a, Chlorinated Biphenyls {Aroclor 1200 Series) 1221, 1232, 1242,1248, 1254,1260 Chlorinated Terphenyls {Aroclor 5400 Series) 5442, S460 . Note: The last two digits in a numbered series refer to the degree of chlorination. Aroclor 1248 is a bi phenyl with 48 per cent chlorination. Aroclor 5460 is a terphenyl with 60 per cent chlorination. Two special mixtures are: Aroclor 4465--a 60:40 mixture (biphenyl to terphenyl) with 65 per cent chlorination. Aroclor 2565--a 75:25 mixture (biphenyl to terphenyl) with 65 per cent chlorination. The physical properties of the Aroclor plasticizers vary gradually with the degree of chlorination. At low percentages of chlorine, such as Aroclor 1221 and 1232, the compounds are clear and very, fluid. At 42 per cent they resemble vegetable oil; at 48 per cent they thicken slightly and look more like a medium-grade mineral oil At 54 per cent chlorine, the compounds are quite viscous; if a bottle containing them is turned upside down, the bubble rises slowly to the top. At higher percentages, the biphenyls become gumlike, and a fingerprint on 'the surface lasts several days. Then at 68 per cent chlorine, the. range is complete; Aroclor 1268 is a white powder. The terphenyls {Aroclor. 5442 and 5460) are both yellowish solids; The gradual change in physical properties often allows a processor to select a plasticizer particularly suited for his operation. For example, if he wants to dry mix the plasticizer, Aroclor 1268 could be used. I: melts at higher processing temperature and can act as a solvent-plasticizer. ' . . 100037 ' 905995 WATER PCB-SD0000072591 Toxicity Animal toxicity studies and 20 years of manufacturing and use experience indicate that Aroclor compounds are not serious industrial health hazards. If the materials are heated to volatilization, ventilation should be provided to prevent inhalation of vapors. This is true of other major components of the formulation as well i& the Aroclor compounds. Repeated or prolonged shin contact should be avoided although there are few instances of shin irritation. Human patch tests with finished products containing Aroclor compounds have shown no irritation. Mon santo will furnish information on specific Aroclor compounds upon request Shipping Information Regulations Standard Containers ---None -- Steel and Fiber (Aroclor 1268, 5460) drums. Rail Classification Chlorinated diphenyl (synthetic resin, liquid, XOIBX) Synthetic resin, liquid, XOIBX Snythetic resin, other than liquid, XOIBX -- Aroclor 1142,114S, 1154, 1160, 1162, 1168, 1221, 1252, 1242, 1248, 1254, 1260, 126S -- Aroclor 1260 mix, 1262 mix -- Aroclor 2565,4065, 4465, 5042, 5060, 5442, 5460 True! Classification ' Synthetic resin powder, XOI Synthetic resin, lumps or solid mass, XOI -- Aroclor 2565 -- Aroclor 4065, 4465, 5042, 5060, 5442, 5460 -12- 905996 . 100096 WATER PCB-SD0000072592 t m v# February P, 197? Sit- TH-'ii*// f Dr. A* Pooefeky 5 Industrial and Power Capacitor Products Department Generel Electric Coooany John Street Hudson Fell. Hew York l?Q39 Hr. C. L Roab Distribution Transformer Department General Electric Company *> 100 Wood lawn Avenue Pittsfield, Massachusetts 01P01 Gentlemen} " Attached is a Question end Answer Hat for responding to PCB Inquiries which I offered to mall to you at our December 10th ANSI C-107 meeting. I recognise that the list la not complete but I hone It will serve a a good atert with further additions made by your respective committee. Ehould any helo be required , from Monsanto in responding to additional questions, please let me know. Sincerely, V. B. Papageorge Manager, Environmental Protection Aig attachment 0 cct Messrst A. M. Sslasar P. 0. Bcriignus WATER PCB-SD0000072593 Questions end Answers For ANSI PCB Question What is PCB? Answer PCB are lnltlela which stand for polychlorinated biphenyl. PCB Is a family of chlorinated hydrocarbons which have long been used as a ftre-roc Iptant safety fluid In electrical componenta. ' Question Is PCB In Askarel? Answer Aekarel Is a generic nano for the PCB-contsluing fluids used In electrics!"transformer and capacitors. Individual electrical equipment manufacturers have different trade names which describe .their specific fluid. Question Explain the current environmental flap over PCB. Answer . In the mld-CO's, scientific instruments became sophisticated to the point where perts-ner-mllllon or even oorte-per-bllllon of substance could be detected In the environment. Swedish scientists, looking for DDT. encountered "interferrlng substances" in their laboratory analyses. These Substances they identified as PCB. Subsequently other scientist* In other porta of the world looked for and found PCB in a variety of samolco} thus leading to the conclusion that PCB exists In the worldwide environment. oz^ql 734652 WATER PCB-SD0000072594 PCB Questlonn nr.d Anewrra Tor ANSI 4* Question How does PCB got Into the environment? Anewer Probably through Iraorooer handling, use end dlsoocsl* A frecuently cited accident occurred In Japan in 1008 when PCS leaked Into rice oil which the Japanese use for cooking. Levels In the oil reached P,000 to 3,000 parts-per-olllloa* However, It should be emohaslced thet when properly handled, used end disposed of, PCB can be as eafe to use as any other chemical -- many of which are much more dangerous than PCB. 5* Quectlon' Is PCB toxic? Answer Toxicity Id e relative term. Some studies hove shown it is toxic to certain snecles of birds and fish* More Important, PCB 13 a persistant chemical which builds up in the environ ment* It, therefore, should not be allowed to escape to the environment* 6. Question Does PCB ceuse birth defects? Answer Again, some studies have shown It can be detrimental to the reproductive cycles of certeln species of wildlife* NEV 0245987 734653 WATER PCB-SD0000072595 PCB Questions end Answers For ANSI 3 7. Question Zc the public in any immediate dangerf Answer The Federal Government at a pres* conference In September, 1071, flteted emphatically that the nubile was In no danger from present levels of PCB now In the environment. The/ eaid prooer etepa were being taken to reduce further escape of PCB which would ultimately reduce even the low levels currently being found in the environment* - 8* Question How can PCB be disposed of? Anrwer Under high temperature, controlled lncinerotion, PCB breaks down into hydrochloric acid, carbon dioxide and water. There are three commercial incinerators in the United States which can handle disposal of used fluids. Contact your supplier for information about returning used fluids for proper disposal. ob*' VBP P/P/7? 734654 WATER PCB-SD0000072596  I 25, 1934 HEFOHT OF OR* 1BBDZB1CS B. SLEW 0? PiTCE TESTS HIDE OH MUSRIlt aSCSITSD TROt SWANK RB5S1BCH. OB. The objeet of this investigation eaa to detemina whether or not the various chlorinated diphaayl expounds submitted or impurities contained therein sight ha tha causative agent producing tha dematitia ifcich had datalopad among sobs of tbs workmen in tha plash* Large ihlte rabbita vara uaed In asking the patch testa to dot amine the set ion of the various materials subaitted on tha akin* Tha procedure vaa to share tha aniaal 36 hours before tha patch vsls applied ao that there vould be no broken akin to interfere with or to aggravate the test. The satarial being tasted vaa sized vith ethyl alcohol, alt bar getting a solution or e suspension for fee purpose of diluting tha material* Tha patch van left on for various pvloda during tha teats -- sane for 24 hours, others for 48 hours* The patch vaa than removed and tha ezpoaed area watched for two veeka to be sure that the test vaa negative* This vaa dona to avoid tha chance of aot observing any latent or delayed action such aa do sonatinas take place la mMlH"g patch teats* Tor our own information the nstarlals which vexe negative vere applied in a concentrated form in duplicate teats to see if a dernatitls sight not develop under these eiremstancea* light independent tests were Bade vith each material and were sale on different days vi th freshly prepared solutions to be sure that no error had crept in* Controlled testa vere Bade caeh time with tha alcohol and ganzes used to detezBlne vhether they sight not be the eansatlve agent causing the observed lesions. Given bale* is Dr* man's report, shoving designations given tha various sstcrisis by Svaan Besearch followed by Dr. Tlisn's designation and report of eaeh specific material: iroclor 1268 (Lot 3. made before s/l/g). Iroelor 1362, Lot 3*-- dll eight testa vara negative. The tvo teats vith concentrated material vere alec negative* in intrademal teat vaa negative, /frails lgMttat notebook 9c* 176, page 121; prepared by Scrria "5 94.SS Uphegi "* a-sjC styrene and atyreac hi A boiler: iroelor 1262^ Lot notebook 176, page 121, vaa negative to all testa including th*'concentrated and lsfiradczmal* ADM 003165 O la SeP) WATER PCB-SD0000072597 1x08lor Speoial (Lot notebook Ho. 192, page 9} prepared bf Bubbard, at IZjL diphenyl aad 2Sfc styrene aad styrene high bollsri, (LIgold iroclcx. eoeclflo grarltr 1,53), iroelor Special notebook Ho, 192, page 9:-- Thia ehwieal gare a poattlwa tast alto aaab of tba eight application*, it alao gare a poaltira rosption alto tba latradaaal taat, Tba type of daraatitia aa* slid, iroclcx 1248 (Lot 9, nada 3/30/34): lroclox 1218, Lot 9t 111 eight taata gawe a poaltlwo reaction. Tba iatradexmal taat aa* alao poaltlia, Tba reaction aa* slid, Ixoclor 1218 (Lot 8. nada 5/2/33): ixoclcr 1218, Lot 3 ill eight taata gare a poaltlia reaction with this compound. The Intradaxmal taat aa* also pealtlie, I feel that the dermatitis produced bp tbl* anterial aaa all&ar than to* tao prealon* compound* ableb were alao found to ba poaltlia, in aaieral taata it did not make It* appaaranoa fox 24 hour* after tba patch bad been remowed, ixoclor 1269 (Lot 8, Dry Ground! made 6/22/32): ixoclor 1289, Lot 8, ground dry: ill alght taata were aegatlie, Tba aone la trua of tba two taata nada with tba coneantrated material. Tba Intraderaal taat gare negatlie reaction. iroclor 1269 (Lot notebook Bo, 176, page 121; prepared by Barrie, of 989 diphenyl aad 4,9JE atyxeno aad atwreao blah boiler -- dry around) t ixoclor 1869, Lot notebook 176, page 121, dry ground: ill eight taata vara nagetlwe. The concentrated teat* were alao negatlwe. Tba lntradaraal tast gare negatlwe reaction, ixoclor 1269 (Lot* notebook Ho, 176, page 121: aama aa lamed! to air abore but wet around) ixoclor 1269, Lot notebook 176, page 121, wet ground: ill eight teata ware negatlwe* The two taata nada with concentrated material ware alte negatlwe, Tba latradanal taat gate a negatlwe reaction, ixoclor 1269, Lot 3, notebook Bo, 192, para 10 (drr around In pebble mllll: V iroclor 1269, Lot 3, notebook Bo. 192, page 10: Tba eight pateh testa were negatlwe. The tests aada with concentrated material wart alao negatlww. The intradaxmal taata gawa a aagatlwa reaction. ADh 3I66 I WATER PCB-SD0000072598 Halowax foOQOt Halowmx 10001 This compound g&T* a positive teat in all of til* eight t**t* la tillsh It ni applied. Th* reaction tu different froa that of th* thre* iroelor* giving a posltlT* reaction* Thar war* alii * bat thla matarlal gar* aa ulcerative area* galowax feOPli . Halowax 1001} All t*ata with thla compound, both coventrated and dilata, war* negative* Halowax #1004} Halowax 1004} All tasta with thla matarlal, both concentrated and dilata, war* negative* Styrene Bichloride (notebook go, 192. pax* ldlt Styrana Olehlorlda: Kotabooh 190, pag* 15: Stary test mad* with this matarlal was positive* It warn noticed that the rabbit palled rey when thla ehealeal was applied even la the dilata foa* Thla also gave aa ulcerative laalom* AroolPT 1248 Special (Batoh a. Sample 04 - made lo/d/aQ)} . Aroclor IMS Spoelal Batch &-0-1. Mad* 10/4/30} Thla Iroelor gore a Terr alight raaetloa with the akin but oa* must car that it la potitlve* iroelor I2fi0 (Lot 32. made d/g/Sll: iroelor 1260* lot 32* Had* fl/23/3l): ill al git teats war* negative* So Intradaanal or eoaeoatratad tasta were made* iroelor 1262 (Batch 81, ample Hade 7/8/3011 iroelor 138S* Batch 8A* Hade 7/6/30} All tests wars negative, Chlor Ithrl Benzene (notebook So. 192. page 211 > Chlor ethyl benzene. Sotabock 192, page 21: Every test made with thla material gave a positive test* The lesion was of sa ulcerative type. nMwvimtad Styrene (Hhtebook Sc* 192. page 19 -- 5/16/34): Chlorinated Styrene. notebook 192, page 19. 5/16/34: Every teat mads with this eoapotmd gave aa alterative laalon. ACM OC 3167 WATER PCB-SD0000072599 / <' f1, 4 fir* Vilaa* a ecnaaata in copied Terbatla, u folio**j "Camactai m One la impressed with the fast that eaeh of tl iroelora giving a positive reectioa nit of a fluid nature* Attempts were made to expose tha animals to vapors bat observations made us eoaelada that tha only difference m that tha animal would ba exposed to tha hot satesi al and it vaa wall ]oowa that tha raaotlea whara aaeh aa azpoaora la glvea la acre severe* Oaa eaaaot bat fail that any styrene compound whleh may ha found to ba praaaat aa aa Impurity la tha eanaa of your trouble* I waa rathar aospriaad that more of tha compounds submitted did not ahow or giro raactioaa with tha akin* It haa baan afaowa la some laraatigatioaa that ehlorlaa did not prodnoa a dermatitis ihaa aatallle alaetrodaa vara aaad but did if tha aatallle alaotrodaa vara raplaead by oarboa alaetrodaa* Tha theory waa advanced that some organic ehlorlaa compounds vara pzodaead la the latter eaaa* I would suggest that you atudy yoar ventilation eyrtam la plaeea where fu&ea are gi^en off* That aeaaa ba proTided for tha mea to taka a bath with aoap and water if tbay eaaa ia eoataet with tha type of material found to ba positive* 3y tfcia I aaaa if a leak or apillaga ooeura* Tha innadlete bathing under these circumstances should be Insisted on. Z found that where I had gotten the material oa ay hands If Z washed then thoroughly no trouble arose* (Si giad} VTaderiek B. 711na v ADM 003168 I WATER PCB-SD0000072600 "9 s t 9 b k i 0 tt SUBMISSION TO THE SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS OP THE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE U. S. HOUSE OP REPRESENTATIVES By Monsanto Company 800 N. Lindbergh Blvd. St. Louis, MO 63166 November 16, 1979 ACH oco 7*^ WATER PCB-SD0000072601 i/i 1* HISTORY 0? MONSANTO PRODUCTION AND SALES OF CHIORTvittp ai?H5!T Monsanto entered the chlorinated biphenyls business in 1933, when it purchased the Swann Chemical Company. Production and distribution increased until the early 1970s, when, in response to reports o its presence in the environment, Mon santo restricted sales of chlorinated biphenyls. ?a 1977, the company ceased production and distribution of chlorinated biphenyls in cooperation with the electrical industry. Chlori nated biphenyls were banned (except for "certain applications) in the U.S. in 1979. Sales and Distribution The chemical structure of the polychlorinated biphenyls has been known for nearly 100 years. Commercial production of these materials was initiated in 1929 by the Swann Chemical Company in response to the electrical industry's need for improved dielectric insulating fluids which would also provide increased fire resistance when used in transformers and ' capacitors. (See para. 2, page 2 of the Interdepartmental Task Force on PCBs report, "Polychlorinated Biphenyls and the Environment," May 1972 - Attachment 1-1.) As the unique functional characteristics of these materials became more fully understood, additional uses were found. Their fire resistance made them an excellent choice in high pressure hydraulic applications associated with high risk of fire such as die casting and steel production. Their thermal stability and fire resistance were valuable in heat transfer systems. ' ; ACM 0C0763 WATER PCB-SD0000072602 1/2 Their stability, low water solubility, low vapor pressure'and solvency power made them attractive in carbon .k less paper systems. Their fire resistance, thermal stability and viscosity characteristics made their use desirable in hot melt adhesives and other plasticiser applications. Chlorinated biphenyls, therefore, evolved as a unique class of chemicals which met important needs for both in dustry and society. In some instances, fire and building codes required the protection of life and property offered by chlorinated biphenyls. It was within this framework that Monsanto and other producers developed a growing worldwide business for these versatile products. For a retrospective discussion of the benefits of chlorinated biphenyls, see Attachment 1-2. The following charts show the data for chlorinated biphenyls through Monsanto's voluntary phaseout program to termination of production and sales in 1977. Significant points in these charts are: a. Heat Transfer -- Between 1970 and 1972, a task force of Monsanto engineers worked closely with customers to replace chlorinated biphenyl fluids with materials of equivalent thermal stability but with unavoidable lower fire resistance. Phaseout was completed in 1972. b. Hydraulic Fluid -- Development of replacement fluids begin in 1970, and sales of chlorinated biphenyl-based fluids were discontinued in 1971. - - -> * `"ad* GCC76A WATER PCB-SD0000072603 MONSANIO INDUS?RIAL CHCMICALS COMPANY 1957 thru 197S (Thousands ol Pounds) ADM 000T65 9f MOPMCIWM W|MtlCM! Ut IM(I ONfllie tAICt t rAtiooat NMofAotaMhd |S>ll|Hl| Mot MiMN C?.MwMlata.aw Nttothtt lIlMlH Aoid*ua A4dW*"** QIM? fKIQMUMlt fewwAfaii tft l|t| fe*taa iim:hi AmIm ItM Ntl* **MmttIimm IimNI Mlt m 9l IW m(ii m Wl IM mt WM ft ItMft m nt MimiWm MM t n IM Mtlt tit Mil VM* II t fit MMi MM Ml MMl n 9 MM 'mImt M MM MM MM IMM Mt M M 9IM tMt MM MM IM m9 ItM tit it Mill M m Mminlt m m MM MM MMf MM 9 ttM tilt tltl IMM MM Ml Mt >' Mitt MMMlt tIM tM IM M Mtlt Mlt tIM MM Ml IM 9 MI MUt MMt M MV Mlt Ml tMt MMt MM M VM MMt tMt tilt MitMnM 9 Jfl Mitt MUt tMt MV MM ItM mVImM tut Ml It ttM Mlt MM M<1l4t Mi t m MMt MMt MM MV Mi MM VVM MMt mn tit It mu ttM IM MM M Mt t m MMt ItM ttM mv MM mi MM MMt tMM t Mt V tmt Ml Mil MM M IM MM mi tMM mn ItM VM MM MM tMM MM nt M Mitt MM MM Mil IM M HIM IMM HH MM VMM tMt tmt MM MM Mlt IMVI MMt tMt t MM tut IMI ItM ttM `.MMt M If Mil iti MM Mil Mt MV t IM M Mttt MM t1i1l1l IM Mt tmt lini MM MMt MM MM mt litit IMlt MMt lM Ml til IMI MM Mil II Ml Mt ItM ttM tmt imi MM IMI Mil NM MMt mtr t Mlt nt MlM Ml? MM Mlt IN Mil Mil NNI MMt MM mt Ml Him mhi MM t ItM III imi in Ml lilt t MM MMt mi Mt vtt t t fIM tMVt t t ft nt t tut it tmt Wl im tfMV tIM mt tiit MMt tm t t Hilt VMt t t t t tftM tmit n . ttM MM t t tMM tv t titt IM t mut Mil tvnt Mill Mlt t t tmt IMM t t ft t mm t tm t t t VMM ItM !% HIM IM t t tmt MUt t It t MM t ItM t t t MMt mt HIM >?< MM1 t t t t t MU IMM t t t t t t t It ItM t t f MM . t t # t t t t t WATER PCB-SD0000072604 r~ 75,000 r U.S. DOMESTIC SALES OF PCBs BY CATEGORY (The Uppermost Curve Represents The Total Sales.) EPA BAN 65,000 h U.S. Domestic Sales (103 Lbs) 55,000 45,000 h 35,000 h 25,000 h 15,000 h Cl 5,000 h o oo O' 1963 1965 1967 1969 1971 1973 1975 1077 o WATER PCB-SD0000072605 r- 75.000 65.000 55.000 s 45.000 35.000 U.S. DOMESTIC SALES OF PCBs BY GRADE (The Uppermost Curve Represents The Total Sale) r 1268 1262 1260 1254 1248 1242 1232 1221 1016 U.S. Domestic Sales (105 Lbs) 25.000 15.000 10 5,000 n oo O 1963 1965 1967 1969 1971 1973 1975 1977 1979 WATER PCB-SD0000072606 c. Plasticizer Applications -- Sales of most chlorinated biphenyl plasticizers were terminated in 1970, with phaseout completed in 1971. d. Miscellaneous Industrial Uses (such as vacuum pump fluids) -- Sales ended by 1971. These voluntary restrictions resulted in a 64 percent reduction in Monsanto sales of chlorinated biphenyls from 1970 to 1972. K However, termination of sales for dielectric uses would have resulted in severe economic and social dislocation. This was recognized by the federal Interdepartmental Task Force on PCBs which concluded in 1972 that "Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCS use." (See para. 6, page 4, of Attachment 1-1). Therefore, Monsanto agreed to continue supplying the products to manufacturers off electrical power distribution equipment who use chlorinated biphenyls only in sealed systems such as capacitors and transformers. In continuing to sell to such customers, however, Monsanto required assurances that the materials would be safely handled and properly disposed.of. In yaking this decision Monsanto believed 1) that V * entry of chlorinated biphenyls to the environment could 171 ADM CQ0763 WATER PCB-SD0000072607 -/ be effectively limited and controlled by users (see Attach ment 1-3, Westinghouse report presented at the January 3, 1972, meeting of the National Industrial Pollution Control Council), 2) proper maintenance and decommissioning practices could limit fluid escape from transformer operations, and 3) withdrawal from production for these applications would have stopped production of equipment essential to the safe and efficient distribution and use of electrical energy. In addition, a more biodegradable lower chlorinated product (ARCCLOR1015) had been developed by Monsanto for use by the capacitor industry (see Attachment 1-4). Steos Taken in Labeling and Transport Practices for Oncoino Dielectric Sales, 1972-1977 Monsanto shipped PC3 fluids in both bulk carriers and in drums. Bulk shipments were made in Monsanto-owned rail road tank cars, which were used exclusively for that service, or in customer-owned tank trucks. Drum shipments were made in special reinforced drums. A multilingual warning label was affixed to each package giving a brief description of the nature of the contents and appropriate actions to be taken in the event of a spill or leak. We also supplied a label to be used on return shipments for incineration, which gave similar information. Industry Guidelines . In June, 1970, the Board of Directors of the Power Equipment Division of the National Electrical Manufacturers Association appointed a committee to review the chlorinated AROCLOR is a trademark of Monsanto Company ADM CC0769 WATER PCB-SD0000072608 1/5 biphenyl situation as it affected electrical usage. As a result, in April, 1971, American National Standards Committee -b C107 was established to develop guidelines for the safe use, maintenance and disposal of askarel* and askarel-soaked materials used in electrical equipment. Monsanto participated in this committee. A final draft was completed by November, 1972, and the Standard Guideline was published in 1974 as ANSI C107.1-1974 (Attachment 1-5). * Monsanto's Withdrawal from the Chlorinated Bisher.vl Business l When Monsanto decided in 1970 to restrict sales of chlorinated biphenyls, there were no satisfactory alternate materials for closed-system dielectric uses. This view was later affirmed by the E?A. At least as late as a 1975 press conference, the EPA reiterated it would not ask Monsanto to stop production because that would shut down the electrical power industry and the railroads in short order. The EPA objective was to find a way to proceed without shutting down the country. That was precisely the objective to which Monsanto had been committed since 1970. The problems encountered in replacing chlorinated biphenyls were rooted in their unique fire resistant and dielectric characteristics and in their role in electrical and industrial applications for 45 years. The challenge facing the electrical industry was to replace chlorinated * "Askarei" is a generic name for fire resistant dielectric fluids, including those which contained polychlorinated biphenyls, made to meet specifications set by transformers and capacitor manufacturers. . AOM 00077Q WATER PCB-SD0000072609 i/ o biphenyls in an orderly manner, without creating other hazards of equal or potentially greater magnitude, and at the same time avoiding serious power and transportation disruptions. Monsanto expended considerable effort and money in major research programs aimed at developing environmentally compatible replacement fluids for the electrical industry. The level of this research was greatly reduced in 1976 when the electrical industry developed the technology to adapt other compounds to its needs. It now appears the ongoing demand for liquid-cooled transformers will be satisfied by using silicone compounds. In the capacitor industry, the trend has been toward materials such as phthalate esters. In adopting these substitutes, the electrical industry has been forced to accept lower fire resistance. New safety devices have been required to ensure that replace ment equipment will not lead to increased risk to society from fire hazards. In our press statement of October 5, 1976, Monsanto said we would complete distribution of all inventories and withdraw from the chlorinated biphenyl dielectric business'by October 31, 1977. In making the announcement, Monsanto said the company would have targeted an even earlier shutdown date had transformer and capacitor manu facturers' conversion timetables permitted. All chlorinated biphenyl,'production \vas halted by Monsanto in July, 1977, and all customer shipments were completed by September, 1977. - ACM 0CC771 WATER PCB-SD0000072610 At the time we stopped PCB production, Monsanto established policies.which precluded licensing of chlorinated biphenyl technology and restricted sales of biphenyl to uses which would not involve halogenation. ?C3s continue to be manufactured by other firms in Germany, France, Spain, Italy and certain eastern European countries. They continue to be widely used throughout the world. Reasons for Monsanto Phaseout , Scientific knowledge about the presence of ?C3s in the environment, and about its possible significance, began to evolve during the late 1960s (see, e.g., Attachment 1-6). That evolutionary process, which is still incomplete, began with two events--one in Japan and the other in Sweden. In 1968, about 1,000 people in Japan became ill from eating rice oil heavily contaminated with Japanese-produced PC3s as a result of an industrial accident which has ccme to be known as the Yusho incident. The level of PC3 con tamination in the rice oil was 2000 to 3000 parts per million, extremely high concentrations. Conclusions about that inci dent have been clouded by the unknown impact of impurities in the Japanese PC3 concerned (see pages 160-167, Attachment 1-7). However, the incident sounded a cautionary signal. In Sweden, Soren Jensen, using new analytical technology to investigate DDT residues in the environment, reported the possible presence of PC3s in fish tissue. Monsanto and others began immediately to study the Swedish work, following preliminary news media reports in late 1966.- ADM CCC772 WATER PCB-SD0000072611 1/3 Before the findings could be confirmed or duplicated in the U.S.r analytical methods had to be refined in order to definitively separate PCBs from other chlorinated hydrocarbons that were known to be present in the environ ment. New techniques were required to enable researchers to detect these chemicals in the low parts per billion ranges being reported. The presence of PCBs in the environment in the U.S. was confirmed by 1970, but little was known about their potential impact. Because PCBs were reported in the environment and tests indicated they could accumulate in the food chain, Monsanto voluntarily decided to terminate sales of chlorinated biphenyls to open applications ~ those which could result in losses to the environment. Plasticizer and carbonless paper applications fell into this category. Because of the contamination of rice oil in Japan, food processors using Monsanto's chlorinated biphenyl heat transfer fluids were advised to change to alternative heating methods and Monsanto reemphasized the need for improved monitoring of finished food products to preclude contamination by any heat transfer fluid. The decision was made in 1971 to terminate all heat transfer fluid sales of chlorinated biphenyls, substituting other products with equivalent thermal stability. High.'operating pressures cause hydraulic systems to leak. Monsanto therefore alerted users to manage wastes ;; A0* 0C0773 WATER PCB-SD0000072612 1/9 to eliminate PCS discharge to the environment, as new ' hydraulic fluids were developed in 1971, we terminated sales of those containing PCBs. As described earlier, Monsanto agreed with the electrical industry and government that the benefits to society of continued chlorinated biphenyl dielectric use outweighed the low risk of uncontrolled release from these sealed applications. The key to managing the risk was sound maintenance practice and disposal'control. With particular reference to the use of PCBs in human food and animal feed processing facilities, the FDA proposed usage regulations in 1972, which were adopted in 1973, and continue in force today (21 CFS 109.15; 110.40(b); 500.45). Although a variety of effects of PCBs has been postulated from research of widely varying quality, there is no evidence of environmental levels of PCBs being a major human health hazard. However, it became apparent that the public perceived risks associated with continued PCB dielectric use and pre ferred to forego its undoubted functional benefits. Therefore, in October of 1976, we advised dielectric customers that it * was our intent, consistent with their progress with substitute products, to terminate chlorinated biphenyl production and sale by October, 1977. Each of them forecast how much product would be required to effect an orderly technical transition. In 1977, we made sufficient dielectric chlorinated biphenyl % to satisfy the forecast transition demand and made final ACM 000774 WATER PCB-SD0000072613 shipments in September. The small residual inventory was incinerated in our pyrolysis unit, bringing to a close our chlorinated biphenyl business. In summary, Monsanto's decision to withdraw from the PC3 business was based on concerns about environmental presence rather than health effects. %\ ; ac* CCC771. WATER PCB-SD0000072614 2/1 2. INFORMATION ON HEALTH EFFECTS Chlorinated biphenyls range from liquid to solid, depending upon the degree of chlorination. On 'the basis of singl# dose animal tests commonly used to identify and label hazardous materials, they would be considered to be relatively harmless substances. Monsanto has conducted such acute toxicity and irritation tests on several chlorinated biphenyls over the years (1). Questions have been raised in four areas of possible health effects of chlorinated biphenyls. These have been related to 1) skin (reddening, chloracne), 2) systemic effects (liver damage, respiratory effects), 3) environ mental exposure, and 4} potential carcinogenicity. A review of the literature from the 1930s and 1940s on the health effects of chlorinated biphenyls contains statements such as "Much of the literature that refers to chlorinated diphenyls is referring to the mixture of chlorinated diphenyl with chlorinated naphthalene." and "A number of the references recorded under chlorinated naphthalenes also discussed chlorinated diphenyl. It is difficult to determine the role played by the chlorinated diphenyls, as, in most instances, they were mixed with chlorinated naphthalene" (2). A parallel situation occurred during the late 1960s when reports of the detection of polychlorinated biphenyls in the environment . %\ ACM G0C7 7fc '3 WATER PCB-SD0000072615 2/2 began to appear. There was confusion and disagreement as to whether polychlorinated biphenyls or other halogenated hydrocarbons such as DDT were being measured, since the latter had already been identified as environmental contaminants. Skin Sometime before 1934, Swann Chemical Co. observed dermatological symptoms in workers exposed to chlorinated biphenyls. In May, 1934, Swann Research, Inc., requested Dr. F. 3. Flinn of Columbia University's College of Physicians and Surgeons to conduct an investigation "to determine whether or not the var-ious chlorinated diphenyl compounds submitted or some impurities contained therein might be the causative agent producing the dermatitis which had developed among some of the workmen in the plant." He commented on these studies as follows: "One is impressed with the fact that each of the Aroclors giving a positive reaction were of a fluid nature. Attempts were made to expose the animals to vapors but observations made us conclude that the only difference was that the animal would be exposed to the hot material and it was well-known that the reaction where such an exposure is given is more severe. "One cannot but feel that any styrene compound which may be found to be present as an impurity is the cause of your trouble. I was rather surprised that more of the compounds submitted did not show or give reactions with the skin. It has been shown in some investigations that chlorine did not produce a dermatitis when metallic electrodes were used but did if the metallic electrodes were replaced by carbon electrodes. The theoryvwas advanced that some organic chlorine compounds were produced in the latter case. ADM 0007 77 -J WATER PCB-SD0000072616 2/3 "I would suggest that you study your ventilation system in places where fumes are given off. That means be provided for the men to take a bath with soap and water if they come in contact with the * type of material found to be positive, ay this I naan if a leak or spillage occurs. The immediate bathing under these circumstances should be insisted on. I found that where I had gotten the material on my hands if I washed them thoroughly no trouble arose." In his transmittal letter to Dr. J. N. Carother3 of Swann Research. Inc., Anniston. Alabama. Dr. Flinn stated: "It may interest you to know that the dermatitis which was produced by your materials in the .case of rabbits cleared up in a couple of weeks, indicating that unless there are repeated exposures the effects are only of a temporary nature. As I said before. I believe that if washing facilities are present and the men are instructed to use them it will do much to supplement the increased ventilation which you have installed." (3) In the published literature, "the first observations on the development of acnelike lesions among workers in the United States coming in contact with chloronaphthalenes and chlorodiphenyls as well as acute yellow atrophy of the liver occurring among such workers were reported in 1935" (4). Results of Swann studies were published in 1936 (5). There is a letter report dated December 22. 1949. to Dr. R. E. Kelly (Monsanto) from Dr. L. K. Halpern of the Barnard Free Skin and Cancer Hospital (St. Louis) describing a human patch study. This consisted of applying film treated with 11.5 percent AROCLOR and gauze moistened with 100 percent AROCLOR to skin of the upper arm of 213 volunteers using the \ ADM 000776 WATER PCB-SD0000072617 technique developed by Dr. Louis Schwartz, .Medical Director of the United States Public Health Service. Dr. Halpern reported "If the procedure recommended by the United States Public Heilth Service is sufficient to distinguish between chemical compounds that are innocuous when applied to the skin and other compounds that are primary irritants or sensitizers, then it would seem that Aroclor has no primary irritant effect nor is it a sensitizer of high potency." (6) Monsanto records show that this study was conducted with ARCCLOR 1254. In 1963, Monsanto received reports of subacute rabbit dermal studies it had sponsored on several chlorinated diphenyls. Salient features of these studies, conducted according to then-currently acceptable procedures, are summarized below (1). AROCLOR 1221 1242 1243 1254 1253 No effect level* ^50 Local skin effects Systemic injury 150 250 none none 50 10 75 50 none none none liver injury 10 500 75 1250 yes yes liver liver injury injury * All dosages in rag/kg/day ** Sased on 20-day dosing and 14-day observation periods \ ACM 0CO775 WATER PCB-SD0000072618 2/3 These studies showed that repeated and prolonged skin contact with the higher chlorinated biphenyls could produce skin irritation and that harmful amount* could fce absorbed under such conditions. They also demonstrated that there was a safe level of exposure for each material, and that thev could be handled safely if the earlier precautions to avoid excessive skin contact were observed. Systemic Effects On June 30, 1937, a symposium on systemic effects resulting from inhalation of chlorinated hydrocarbons was held at the Harvard School of Public Health. Dr. R. E. Kelly of Monsanto participated in the sessions at which results of investigations requested by manufacturers of chlorinated hydrocarbons were presented. Subsequently, three papers summarizing the results of those studies appeared in the scientific literature (7,8,9). with respect to chlorcdiphenyls, the Harvard group concluded that "...it appears safe and it is certainly easily attained, to ventilate so that the air breathed dees not contain more than 0.5 mgm. per cu.m, of any of these compounds...". In a separate unpublished report to Monsanto Company (10) Dr. C. E. Drinker of Harvard described the results of inhalation studies conducted with compound =1263, having a chlorine content of 68 percent. He concluded, "#126S, if handled with ordinary precautions as to ventilation, should be entirely harmless to'workmen.* \ AC* CCC76C WATER PCB-SD0000072619 2/6 Monsanto sponsored a study at the University 0f Cincinnat Kettering. Laboratory on "The Toxicity of the Vapors of AROCLOS 1242 ?* and AHOCLOR 1254*." A report of those studies (11), presented at the 1956 meeting of the American industrial Hygiene Association, stated that the investigation "...was undertaken because in the earlier literature deaiinc with the toxic effects of Aroclors, no distinction has bean drawn between the toxic effects of chlorinated biphenyls and those of chlorinated napthalenes..>. No injury was observed after prolonged intermittent exposure of several species of animals to AROCLOR 1242 at air concentrations of 1.90 to 8.63 micrograms per liter. Animals subjected to comparable exposures of AROCLCR 1254 shoved signs of apparently reversible liver cell injury. The authors concluded their observations by saying "It should be noted that it was necessary to heat these Aroclors in order to increase the rate of volatilization sufficiently to attain the concentrations maintained in these experiments. To the extent that their industrial usage is carried out at ordinary temperatures, the hazard of their inhalation may well be slight or entirely absent." These studies confirmed earlier work which indicated that no harmful effects were to be expected if these materials were used with adequate ventilation since it was necessary to heat the substances to generate sufficiently high air concentrations to injure the test animals. '* 3 ADM OGCf81 WATER PCB-SD0000072620 Prior to 1956, the American Conference of Governmental Industrial Hygienists (ACGIH) had established a Threshold Limit Value (TLV) of 1 mg/m3 for chlorodiphenyl. in 1956, the > listing was changed to read chlorodiphenyl (42% chlorine) as 1 mg/n3. The 1957 list showed chlorodiphenyl (42% chlorine) as 1 mg/m3 and an added TLV of 0.5 mg/n3 for chlorodiphenyl (54% chlorine). The latter two values have been unchanged since then (12). Results of the Monsanto-sponsored study (11) contributed to the decision of the ACGIH to lower the TLV for the more highly chlorinated biphenyls (13). Environmental Exposure In response to reports of the presence of some ?C3s in the environment, Monsanto, in 1969, initiated preliminary toxicity studies which led to a series of long-term tests. These tests, on the three predominant commercial polychlorinated biphenyls (ARCCLOR 1242, ARCCLOR 1254, AROCLCR 1260), consisted of 2-year (lifetime) feeding to rats, 2-vear feeding to dogs, 3-generation rat reproduction studies with 2 litters cast per generation, rat teratology studies and dominant lethal mutagenic studies in mice. Toxicity and reproduction studies in chickens were performed to evaluate possible untoward effects in birds such as decreases in eggshell thickness. This series of studies (1) represented the most comprehensive safety tests of the time, and was similar to the tests required for food additives, although Monsanto certainly had no intention of applying.for a food additive permit. AOM QC07B2 WATER PCB-SD0000072621 2/8 The highest dietary level (100 ppm) in the lifetime rat feeding studies produced a weight depression at 24 months in females fed AROCLOR 1254 and liver weight increases in all groups except males fed AROCLOR 1242. As with other halogenated hydrocarbons, the important histopathologic changes were present in the livers of animals sacrificed at the end of the study. These consisted of hepatocellular (liver) alterations such focal hypertrophy (localized enlargement), cytoplasmic lipid chances and in some animals from the 100 ppm groups, hepatomas or chclanciohepatomas (benign tumors). There was no evidence of hepatocellular carcinogenicity with any of the AROCLOR products. In the dog 2-year studies, some slight decreases in body weight gain were noted. At the highest feeding level (100 ppm) of AROCLOR 1260, there was evidence of gastrointestinal inflammatory lesions and ulcerations. In the rat reproduction studies, none of the AROCLOR products produced adverse effects in the 2 litters of the first generation. In the second and third generations, there was a reduction in the mating index and a decrease in the incidence of pregnancy at the 2 highest feeding levels (10 p?n and 100 ppm). The ability of females to carry pups to delivery, once conception had occurred, and to successfully nourish the young was not affected by the three AROCLOR products, to changes were produced in the reproductive tracts of either male or female rats by any of the 3 AROCLOR products. ADM OOC7 8 3 fit WATER PCB-SD0000072622 There was no evidence of teratogenic or mutagenic changes with any of the chlorinated biphenyls at maximally tolerated dose levels in' rats and mice. In the chicken toxicity/reproduction study, AROCLOR 1260 was without effect at all test levels. AROCLOR 1242 and AROCLOR 1254 at 100 ??m in the diet decreased egg hatchability. Poor hatchabiiit of eggs was found from hens fed 8 ppm of AROCLOR 1242. AROCLOR 1242 at 10 and 100 ppm and AROCLOR 1254 at 100 ppm were associated with reduced eggshell thickness. Chick viability was affected by both substances at a dietary level of 10 ppm. r. Data developed by Monsanto and information gained from the Yusho incident in Japan were cited by the Food and Drug Administra tion (FDA) as a basis for establishing tolerances for chlorinated biphenyls in various foods in 1973 (14). Subsequently, the FDA proposed a reduction in those tolerances (15). In 1976 it was reported that AROCLOR 1248 in the diet of * monkeys, at or below FDA tolerance levels for chlorinated biphenyls, adversely affected reproduction (16) . FDA limits on FCBs in the human diet are related to a safe level of 1 /ig/kg body weight/day (14). The studies carried out by Allen and coworkers (16) were at dosage levels of approximately 89 and 183 jug/kg/day. Their work suggested that there could be a previously unknown effect on reproduction in primates and they failed to define a no-effect level. Monsanto, therefore, undertook a detailed monkey reproduction study with carefully administered dosages at and below those previously studied. G0C784 WATER PCB-SD0000072623 2/13 In the Monsanto study, 32 female and 16 mala rhesus monkeys, divided into 4 groups each consisting of 8 females and 4 males, were given daily dosages of 0, 5 pg/kg, 25 pg/kg or 100 pg/kg of AROCLOR 1254. The in-life portion of that study, which lasted about 14 months, has been completed. At Monsanto's highest dosage (100 pg/kg/day), which corresponded to the low level in the Allen study, we find that AROCLOR 1254 has similar effects to those reported earlier for AROCLOR 1248. The results at the lower levels are not completely evaluated. r- Potential Carcinogenicity - Animal Studies In 1975, Dr. Renate Kimbrough reported the induction of liver carcinomas in female rats fed AROCLOR 1260 for two years (17). The same lot of AROCLOR 1260 was used in her study as in Monsanto's earlier test. Monsanto's study showed that AROCLOR 1260 as well as AROCLOR 1242 and AROCLOR 1254, produced liver injury, but no cancers. Therefore, an extensive reevaluation was made of the original liver slides from the Monsanto studies as well as additional liver sections from all rats in the Monsanto two-year feeding studies. These slides were examined independently by Dr. D. Gordon of Industrial 310-TEST Laboratories, by Professor w. Richter of the University of Chicago and by Professor Parvis Pour of the Eppley Institute for Research in Cancer. In addition. Dr. Pour evaluated sections of liver from rats in Dr. Kimbrough's study. v" v ADM CCC765 WATER PCB-SD0000072624 No carcinomas were seen in the livers of rats from the Monsanto studies, and Dr. Pour did not concur with Dr. Kimbrough' diagnosis of liver cancer in rats from her study (13) (see Attachment 2-2). The different criteria by which pathologists diagnose cancer, and the reported findings of cancer induced by polychlorinated biphenyls in various animal species, have been discussed by Dr. J. C. Calandra (19) (Attachment 2-3) . In 1977, the National Cancer Institute reported results of a bioassay for possible carcinogenicity of AROCLOR 12S4. That report stated that AROCLOR 1254 was not carcinogenic under the test conditions (20). Human Epidemiology Studies The toxicity testing described above has provided a foundation for understanding the potential effects of chlorinated biphenyls. However, firm conclusions cannot be drawn without human epidemiological data drawn from exposed populations. "The view that human health risks resulting from exposure to chemicals may be determined experimentally by testing laboratory animals is one that is widely accepted in the scientific community and has been adopted by EPA. Because experimentation on human beings raises ethical questions and because epidemiological studies often provide incomplete information, toxicology studies on laboratory animals are often necessary. However, because the extrapolation from animals to man is subject to some uncertainty, corroboration > \ :i ADM 0GC7ofc WATER PCB-SD0000072625 2/12 of laboratory teat data with sound epidemiological information is desirable." (U.S. SPA, Support Document/Draft Voluntary Environmental Impact Statement for Polychlorinated Biphenyls, 1978). Such epidemiological data on PC3s is now becoming available. Monsanto is aware of seven epidemiological studies done in the U.S. of persons exposed to PCBs. They include persons with occupational as well as community exposure, and the effects studied range from deviations in'biological parameters, through reported symptoms and illnesses, to the occurrence of death from various causes. Selikoff and colleagues studied 326 volunteers who were occupationally exposed to PCBs. They report the percentage of those workers with various dermatological, gastrointestinal, neurological and other symptoms, as well as the percentage with abnormal values of clinical chemistry parameters and of pulmonary function. They concluded that reported symptoms and abnormal findings in physical examinations were not related to duration of employment or level of ?C3s in the blood, except for abnormal dermatological findings and abnormal levels of. soma indicators of liver function. Although the authors claim to nave found an unusual impairment of pulmonary function in their study population, no effort was apparently made to detrmine whether this impairment was related to the other findings (see Attachments 2-4 and 2-5). 1* N * > .-iO _ ACM 0CC767 WATER PCB-SD0000072626 2/13 In spite of a correlation of some liver function parameters with PCB exposure, the prevalence of abnormal liver function was low. The authors state, "The paucity of other ah-o^alities on physical examination was striking; this included a very low prevalence of abnormal liver findings." (emphasis in original). The Center for Disease Control examined liver function and blood levels off chlorinated biphenyls in a sample of PCB workers, their families, and exposed persons in the community, in Bloomington, Indiana. This study found very mild liver dysfunction (increased levels of the enzyme GGTP) and increased blood levels of a cholesterol-like substance in persons with higher blood levels of PCBs. It is not clear if these findings have any relationship to actual illness (see Attachment 2-6). The Michigan Department of Public Health conducted a study of 182 persons who regularly consumed sports fish, a source of PCB, and classified as "exposed", "intermediate" and "controls" according to the amount of fish consumed. A direct relationship was found between the amount of fish consumed and blood level of PCB. However, no significant difference was found between the controls and the exposed in the incidence of 19 health conditions, many of which described the symptoms reported for Yusho disease. Furthermore, in 12 of the 18 conditions, people with the condition had lower blood . Vi-:' ADH CCCl&& WATER PCB-SD0000072627 */L4 PC3 levels than those without the condition. The authors conclude, "As a croup, the exposed participants had no health problems or medical conditions that could be correlated with PC3 levels, exposure to Lake Michigan fish, or known symptoms of PC3 poisoning" (see Attachment 2-7). NI0S3 has completed a study of mortality rates ip. workers in a transformer plant where there was exposure to PC3s, but Monsanto is unable to comment because a report of the study is not yet available. The South Carolina State Department of Health and Environmental Control recently completed a study of 32 workers in a capacitor plant, 10 of whom were regularly exposed to PCBs. Details of the study available to Monsanto are limited to these contained in newspaper reports, but the study apparently involved a medical examination and a determination of blood PC3 level. The authors state that the study "clearly shows that at present there is no evidence of physical harm resulting from working with PC3s." (See Attachment 2-8) These four recent studies appear to constitute the most extensive epidemiological work yet done on chlorinated biphenyls. They each indicate an absence of morbidity (ill health) associated with significant exposure to PC3s. The Mobil Corporation carried out a study of the occurrence of cases of cancer in a population exposed for varying lengths of times between 1949 and 1957. Plant medical ADM 0CC769 WATER PCB-SD0000072628 2/13 records were used to determine the occurrence of cancer in this group`between 19S3 and 1975. However, records were not available for about 20 percent of the eligible study group. The 41 men who were actually studied differed from the populations described above in that they were employed in a chemical plant which manufactured a number of different materials to which they might have been exposed during their working careers. The study found an excess of skin cancer (melanoma) based on three cases. After a'preliminary report of these findings was made, the Mobil Corporation informed NIOSH that there had been "a substantial change" in the definition of the cohort, and that an analysis of the changed cohort might show quite different results. As far as Monsanto is aware, that analysis has not yet been completed. In 1975, independent of the Mobil effort, Monsanto began to gather information for a mortality study of employees exposed to ?C3s at its W. G. Krummrich plant in Saucet, Illinois. Because the plant had manufactured a number of chemicals those persons exposed to PCSs typically had a mixed exposure to other substances as they moved from job to job. Because the work histories of past employees were not computerized, it would have been necessary to identify those who had worked with PC3s by a manual search through 6,000 records. A preliminary identification was made of 50 deaths from various causes among past workers with PC3 expostire, and a 000790 AOM WATER PCB-SD0000072629 2/15 review of these suggested a possible excess of lung cancer, but not of skin or pancreatic cancer. This preli.-ninary finding was announced in 1976. ' A further attempt to identify a cohort yielded 89 men who had been exposed for at least six months in the period 1945-1965, who were then followed to determine their vital status as of the and of 1977. There were no excess deaths from pancreatic cancer, but 4 lung cancer deaths were found where about 1.5 would be expected. 'Smoking histories were not available. The accuracy of the determination of this cohort was limited by the necessity of conducting a manual search of the records. At the present time, computerization of the Xrummrich work histories is underway, and should be completed early in 1980. At that time it will be possible to better define the exposed population, and to better determine the other substances to which the population was exposed. However, because of the mixed nature of exposures in a chemical plant, it is unlikely that the Monsanto study can ever be as specifically related to PC2s as those conducted by Dr. Selikoff, CDC, the Michigan DOH, and the South Carolina DCH. % \ 0C0791 AuH WATER PCB-SD0000072630 Section 2 Bibliography 1. Unpublished reports of studies conducted for Monsanto Company. 2. Irish, D. 0. "Chlorinated Diphenyls, pp. 1340-1343 in Industrial Hygiene and Toxicology, Patty, F.A., ed., Inter science Publishers, New York, 2nd rev. ed., 1963. 3. Flinn, F.B. "Report of Frederick B. Flinn of Patch Tests Made on Material Received from Swann Research, Inc." May 25, 1934. 4. Schwartz L. "On Outbreaks of Halewax Acne ("Cable Rash") Among Electricians." J. Am. Med. Assoc. (1943) 122; 158-61. 5. Jones, J. W. and Alden, H. S. "An Acneforrr. Dermatergosis". "Arch. Derm. & Syphilol. (1936) : 33., 1022-1034. 6. Halpern, L. K. "Project W-31 Aroclor (Report on Patch Testing)." December 22, 1949. 7. Drinker, C. K., Warren, M. F. and Bennett, G. A. "The Problem of Possible Systemic Effects From Certain Chlorinated Hydro carbons." J. Ind. Hvg. & Toxicol. (1937) 19: (7), 283-311. 8. Bennett, G.A., Drinker, C.K. and Warren, M.F. "Morphological Changes in the Livers of Rats Resulting from Exposure to Certain Chlorinated Hydrocarbons." J. Ind. Hyp. & Toxicol. 20:(2), 97-123. 9. Drinker, C.K. "Further Observations on the Possible Systemic Toxicity of Certain of the Chlorinated Hydrocarbons With Suggestions For Permissible Concentrations in the Air of work rooms." J. Ind. Hyg.v& Toxicol. (1939) 21:(5), 155-159. ACH C00792 WATER PCB-SD0000072631 10. Drinker, C.X. "Report to the Monsanto Company." September 15, 1938. 11. Treon, J.F., Cleveland, F.P., Cappel, J.W. and Atchley, r.w. "The Toxicity of the Vapors of Aroclor 1242and Arocior 1254" An. Indust. Hyc. Assoc. Quart. (1956) 17:(2), 204-213. 12. American Conference of Governmental Industrial Hygienists. "Threshold Limit Values for 1955." AMA Arch. Indust. Health (1955) 11: 521-524. "Threshold Limit Values for 1956." AMA Arch. Indust. Health (1956) 14s 186-189. "Threshold Limit Values for 1957." AMA Arch. Indust. Health (1957) 16: 261-265. "TLVs Threshold Limit Values for Chemical Substances in Work room Air Adopted by ACGIH for 1979." 13. American Conference of Govermental Industrial Hygienists. " Documentation of Threshold Limit Values For Substances in Workroom Air." (1977) 4th printing, Cincinnati, pp. 51-52. 14. "Polychlorinated Biphenyls (PCB's)." Fed. Recis. 38: (129), July 6, 1973, pp. 18096-18104. .15. "Polychlorinated Biphenyls (PCB's)." Fed. Recis. 42;(63), April 1, 1977, pp. 17487-17494. 16. Barsotti, D.A., Marlar, R.J. and Allen, J.R. "Reproductive Dysfunction in Rhesus\Monkeys Exposed to Low Levels off Poly chlorinated Biphenyls (Aroclor 1248)." Fd. Cosmet. Toxicol. (1976) 14: 99-103. , J. ACM CC0793 WATER PCB-SD0000072632 & / <* J 17. Ximbrough, R.D., Squire, R.A., Linden, R.E., Strandberg, J.3., Montali, R.J. and Burse, V.W. "Induction of Liver Tumors in Sherman Strain Female Rats by Polychlorinated Biphenyl Aroclor 1250." J. Nat. Cane. Inst. (1975) 55: 1453-1459. 18. "Histopathological Re-evaluation of Livers from Rats Treated with AROCLOR." (.Industrial Bio-Test Laboratories, Inc. Reports and Eppley Institute Reports.) 19. Caiar.dra, J.C. "Review of the Technical and Regulatory Aspects of Aroclors" June 27, 1975. 20. "3ioassay of Aroclor^1254 for Possible Carcinogenicity". National Cancer Institute .Technical Report Series. No. 38. (1973). \ . \J ADM 0C0794 WATER PCB-SD0000072633 3/1 3. MONSANTO ACTIONS RESULTING FROM HEALTH DATA Monsanto has been responsive to health questions about chlorinated biphenyls over the years. Those responses have been consistent with "state of the art" procedures available at the tine the questions were raised, it should be noted that Monsanto's decision to leave the PCS business was based on concerns over environmental presence, not health effects. Skin and Systemic Effects ,: VThen first reported in 1935 (1,2) , the occurrence of skin and systemic effects from ehloronaphthalenes and chlorodiphenyls constituted a new occupational health problem. It rapidly became of concern to federal and state occupational health personnel and to their industrial counter parts. Monsanto was among the sponsors of and a participant in the studies and the subsequent symposium held on this subject at Harvard University (3). In addition, Monsanto conducted its own studies on various polychlorinated biphenyls (4,5,6,7). Earlier, Swann Research, Inc. had conducted human patch tests on these materials (8). Results of these efforts suggested that controlling skin contact and vapor inhalation would permit safe industrial use of these substances. In 1936, Monsanto began developing a corporate medical program. From the start, Monsanto's Medical Director ensured that chlorinated biphenyl workers at Anniston were included in this program. This consisted off periodic physical examinations, good work practices to ensure personal .J CCC795 WATER PCB-SD0000072634 cleanliness of employees, adequate ventilation of the work areas, a$d overall good industrial hygiene practices. The buildings at the Anniston plant were relatively open and most of the processing was done in closed equipment. There fore, employee exposure was relatively low. However, since some customers were using chlorinated biphenyls at elevated temperatures, with a greater potential for exposure, precau tionary statements for handling them were prepared for customer use as early as 1937 (9) (see Attachment 3-1, 3-2, 3-3). As additional information developed, it was incorporated into Monsanto work practices and distributed to customers by way of correspondence, technical bulletins, and other corporate publications (see Attachment 3-4). In addition, upon request, Monsanto technical and medical personnel visited customer plants to advise them on safe handling of polychlorinated biphenyls. Finally, the Monsanto-sponsored studies on AROCLOR 1242 and AROCLOR 12S4 led the American Conference of Governmental Industrial Hygienists (ACGIH) to lower the Threshold Limit Value (TLV) for the higher chlori nated biphenyls in 1957 (10). Environmental Presence In late 1966, Soren Jensen of the Karolinska Institute in Sweden reported the detection of polychlorinated biphenyls in the environment. This was confirmed by 1970. In the interim, Monsanto's European office had entered into dis cussions 'with the Karolinska Institute in an attempt to obtain details of the findings. In early 1969, representatives .: AOW C0C796 WATER PCB-SD0000072635 1/ -i of Monsanto wont from St. Louis to Sweden to meet with \z Jensen. He was not available, and discussions were held with his professor. Dr. Wto idraark. At about the same time, Monsanto decided to develop data on the chronic oral toxicity of chlorinated biphenyls.' Although there was no intention of su petitioning for such use, the extent of these tests was d typical of those designed for the evaluation and establish ment of the safety of direct and indirect food additives. JC* This series of tests was undertaken because it represented i~. . K the most comprehensive requirement of safety at that time (11). FDA was informed of the voluntary testing program in October, * 1969 (12). Subsequently,'as evidence of environmental presence < increased, those studies were expanded in scope. Chicken 'T _ studies to determine the effects of chlorinated biphenyls on * i avian species were completed in 1970 and 1971. Results of 3 : ... all these studies have been distributed to the FDA and other L^ regulatory agencies. During this time period, Monsanto expanded the warnings on its product labels to include cautions H:.' * against allowing escape to the environment (Attachment 3-5). Jt When, in 1976, reproductive disorders were reported in monkeys fed chlorinated biphenyls (13) , Monsanto undertook . * * a study to determine the validity of those findings. The Monsanto study is being conducted with AROCLOR 1254, a large volume material, instead of the relatively low volume AROCLOR e 1248 used by the earlier investigators. Potential Carcinogenicity In 1975, after Dr. Kimbrough reported that ARCCLOR 1260 produced liver cancer in rats (14), Monsanto undertook a .O ACM 0C07S7 WATER PCB-SD0000072636 review o liver sections from its earlier studies on AROCLOR 1242, AROCLOR 1254, and AROCLOR 1260. in addition, it retained Dr. Pour of the Eppley Institute for Research in Cancer to review all liver sections from all of the AROCLOR studies, i.e., Monsanto's and Dr. Kimbrough's (15). That review showed no occurrence of liver cancers. Finally, Or. Calandra was retained to review and comment on available literature dealing with carcinogenicity of polychlorinated biphenyls (16). Results of those evaluations have been made available to regulatbry agencies. - . :J AOM 000796 WATER PCB-SD0000072637 */ y Section 3 Bibliography 1. Schwarts, L. "An Outbreak of Halowax Acne ("Cable Rash") Among Electricians*" Am-j5d-.__Associ.>(l943) 122: 158~161 j 2. Jones, J.W. and Alden, H.S. "An Acneform Dermatergosis." 3 Arch. Derm. & Syrphllol. (1936) 33^: 1022-1034. 3 3. Bennett, G.A.,Drinker, C.K. and Warren, M.F "Morphological Changes in the Livers of Rats Resulting From Exposure to 3 Certain Chlorinated Hydrocarbons." J. Ind. Hyq. & Toxicol. 1 20: (2), 97-123. 3 4. Drinker, C.K. "Report to the Monsanto Company." September IS, 1938. 3 5. Halpern, L.X. "Project W-31 Aroclor (Report on Patch Testing)" 3 December 22, 1949. 6. Treon, J.F., Cleveland, F.P., Cappel, J.W., and Atehley, R.W. 3 "The Toxicity of the Vapors of Aroclor 124Z and Aroclor 125^ 1 An. Indust. Hyg. Assoc. Quart. (1956) 17:(2), 204-213. % 7. Unpublished reports of studies conducted for Monsanto Company. 3 8. Flinn, F.B. "Report of Frederick 3. Flinn of Patch Tests Made on Material Received from Swann Research, Inc." May 25, 1934. l 9. Watt, L.A. Monsanto internal memorandum. October 11, 1937. l 10. American Conference of Governmental Industrial Hygienists "Threshold Limit Values for 1955." AMA Arch. Indust. Health 3 (1955) 11: 521-524. 1 "Threshold Limit Values for 1956." AMA Arch. Indust. Health (1956) 14: 186-187. ] "Threshold Limit Values for 1957." AKA Arch. Indust. Health (1957) 16: 261-265. s . ) ACM 0C0799 WATER PCB-SD0000072638 11. Unpublished reports of studies conducted for Monsanto Company. 12. Wheeler; E.P. Letter to A.R. Glasgow, October 3, 1969. . '** 13. Barsotti, D.A., Marlar, R.J. and Allen, J.R. "Reproductive Dysfunction in Rhesus Monkeys Exposed to Low Levels of Polychlorinated Biphenyls (Aroclor 1248)." Fd. Cosset. Toxicol. (1976) 14: 99-103. 14. Kimbrough, R.D. Squire, R.A.,Linder, R.E.,Strandberg, J.D., Montali, R.J. and Burse, V.W. "Induction of Liver Tumors in Sherman Strain Female Rats by Polychlorinated Biphenyl. Arcelor 1260." J. Nat. Cane. Inst. (197S) 55,: 1453-1459. 15. "Histopathologieal Re-evaluation of Livers from Rats Treated with AROCLOR." ^Industrial BIO-TEST Laboratories, Inc. Reports and Eppley Institute Reports./ 16. Calandra, J.C. "Review of the Technical and Regulatory Aspects of Aroclors." June 27, 1975. %\ j. ADM ocoaoc WATER PCB-SD0000072639 4. CUSTOMER RECORDS Over the years, Monsanto developed the normal commercial records on its sales of chlorinated biphenyls. They were useful for sales and service calls, accounting, production forecasting, and, when decisions were reached to limit chlorinated biphenyls, customer lists served as the basis for our notification visits, telephone calls, letters, and publication mailings in the period 1970-1972, as we phased out all but dielectric chlorinated biphenyl sales. ' S .o ADM CC0801 WATER PCB-SD0000072640 5/1 S. COMMUNICATING WITH CUSTOMERS Notification Procedures Beginning in February, 1970, Monsanto notified its customers of the early reports that PCBs had been detected in the environment. Additional information was transmitted to customers as it became available, along with details of Monsanto's phaseout. The notification letters included as Attachment 5-1 indicate the priority given to terminating applications that seemed relatively likely to lead to environmental release, were food related, or used the more highly chlorinated products. We cooperated with users of hydraulic fluids and heat transfer fluids to discontinue PCS use. t Simultaneously we introduced AROCLOR 1015, a lower chlorinated product for capacitor use, and restricted transformer fluid sales to equipment manufacturers only. In the case of both capacitor and transformer producers, we emphasized the need for control of PCBs. In 1974, Monsanto revised its dielectric literature to conform to the ANSI guideline (Attachments 5-2, 5-3, 5-4) which resulted from the industry work with ANSI referred to earlier. In 1976 the ANSI committee was reconvened to consider the need for revision of the guidelines. Completion of this task has been deferred pending issuance of EPA regulations on PCBs. Monsanto Provided PCB Disposal Assistance to Customers In 1969 MOnsanth started testing the efficiency of PCS destruction by high temperature pyrolysis and constructed ADM 000802 WATER PCB-SD0000072641 5/2 a 6 million pounds/year unit which was completed in May, 1971. ^ This incinerator was designed, and was demonstrated, to destroy PCB wastes at 99.9998 percent efficiency (Attachment 5-5). By September, 1971, this unit was in continuous operation and was destroying both waste from our production and PCBs returned by customers as they converted to non-PCB replace ments. When phaseout from nonelectrical applications was complete, the incinerator was used to destroy waste PCS which collected from ongoing dielectric use. A system was developed to properly handle customer return of wastes (Attachment 5-6). When some customers did not follow our suggested procedures, Monsanto reemphasized the need for proper packaging (Attachment 5-7). To assist in proper handling, posters were prepared and distributed to further educate those responsible for collection and handling of PCB wastes (Attachment 5-8). In the period 1975-1976, large (approximately 80 million pounds/year) commercial facilities became available which could handle controlled PCB incineration more efficiently and economically than Monsanto's small prototype unit. These units incinerated PCBs until their operations were curtailed by the need for a specific permit under the CPA disposal regulations, for PCBs, which became effective on April 18, 1978. The first permit has yet to be issued. The potential risks\of accidental PCS contamination have undoubtedly increased because of the delay in CPA implementa tion of its incineration policy. ... u AO 000603. WATER PCB-SD0000072642 [ 5/3 tabal Warnings In 1970 Monsanto modified the labeling of PC8 packages to emphasize the need to keep it from the environment (Attachment 5-9). Subsequently, labels on drums were written in seven languages (Attachment 5-10). Assistance with Identification of PCBa Because of the changes in composition of PCS dielectric fluids since their introduction, Monsanto worked with the ISC to document such changes. This led to ASTM standard D2283, which lists the composition of all transformer askarels used at various times since 1932 (Attachment 5-11). Monsanto researchers worked within ASTM to develop refined technology for determination of PCSs in the environment. This resulted in approval of ASTM D33Q4 (Attachment 5-12) which has become standard methodology for ?C3 quantification. While many laboratories have the necessary equipment, proficiency in the methodology varies widely. Monsanto's Applied Sciences group regularly consults with laboratories as they gain experience in testing for PCBs. Regulations require many such tests to be performed. The testing load has been greatly increased by the policy EPA adopted in controlling PCB-contarainated oils at the 50-500 ppm level. This is causing serious delays in reporting of test results. We recognized that after Monsanto terminated production of chlorinated biphenyls small samples of products which had \ previous commercial significance would be required for research and standardization of detection equipment. . j - A0H CGC60< WATER PCB-SD0000072643 4 r f a* 1 5/4 Arrangements were concluded with a laboratory supply house to take custody of a limited drum quantity and to supply such samples. Continuing Research Monsanto is funding studies at two major universities which are directed at finding innovative appreachas to reducing PCB levels in the environment. Jy - oooeos WATER PCB-SD0000072644 <3/ - .t 6. PCB DISPOSAL , During the years Monsanto made chlorinated biphenyls, the quantity of waste produced was relatively low and consisted chiefly of distillation residues, after separation off the useful product mix. Until 1971 these residues were landfilled. From 1971 to 1977 production waste was incinerated. Sr \ r u aoh 00000a WATER PCB-SD0000072645 BCCt J. MASON - JMASO H. S. BERGEN E. P. WHEELER - EV.'HEE J. D. EARLY - WASHINGTON W. S. CLARK - WCLAR February 10, 1971 Mr. Lowell E. Miller, Director Pesticide Regulation Division Environmental Protection Agency South Agricultural Building Washington, D.C. 20250 Dear Mr. Millert I recently noted In United States Department of Agriculture PR Notice 70-25 dated October 29, 1970 that polychlorinated biphenyls must be eliminated from economic poisons. We at Monsanto understand and are In complete agreement with this action as indicated in correspondence Dr. R* E. Kelly, Monoanto's Medical Director, had with Dr. Harry W. Kayes and Dr. C. Cueto, Jr. when the Pesticide Regulation Division was part of the U.S. Department of Agriculture. . I am deeply concerned, however, to note that this elimination has been extended to include the poly chlorinated terphenyls. We have thoroughly searched all available literature and communicated with many laboratories, industrial, academic and regulatory, and been unable to find evidence that would indicate the polychlorinated terphenyls are contaminating the environ ment or that they are responsible for adverse effects on fish or wildlife, Wo realise the importance of preventing the contamination of the environment but seriously question whether the polychlorinated terphenyls can be properly classified as contaa&nihts. Does your division have available any infoxw^bH or data which would Justify the elimination of thiilNMterialo from economic poisons? Sincerely, /leo W. B. Papageorgo Manager Environmental Control NEV 011520 711772 WATER PCB-SD0000072646 Hearing Clerk Environmental Protection Agency Room 1019 - East Tower 401 M Street, S.W. Washington, D.C. 20460 Re: Environmental Protection Agency (40 CFR Part 129) Water Program Proposed Toxic Pollutant Effluent Standards Federal Register, Vol. 38, No. 247, Pages 35388-35395 Thursday, December 27, 1973 Gentlemen: ' On January 18, 1974, in accordance with Section 104.6, Part 104, Chapter I of Title 40, Code of Federal Regulations, we filed objections relating to the polychlorinated biphenyl effluent standards proposed in new Part 129, Subpart I, Chapter I of Title 4o, Code of Federal Regulations. As provided in "Order and Notice in the Matter of Proposed Toxic Pollutant Effluent Standards for AldrinDieldrin et al. - FWPCA (307) Docket No. l" dated February 8, 1974 by William J. Sweeney, Administra tive Law Judge, we offer the following comments des cribing our objections in greater detail. or manufacturer of These products are , and in fact. WATER PCB-SD0000072647 2 7 On some occasions a chemical compound with__specTTlc unique property's is deve^bojjed^firs^-- possibly through ijrtfovative research, or even^by'-ha^penstance -- and Wien an end-use is found. The chemical structure of PCB has been known for nearly 100 years. It was not until the late 1920s that a use for PCB was found -- as a dielectric fluid in transformers and capacitors. The properties of PCB -- inertness, fire resistance and a non-conductor of electricity -- seemed to be perfectly suited to those electrical applications where high-voltage arcing could occur; possibly resulting in serious fires or damage to the equipment. Mcmeanto-began (commercial production of PCB in 1929. As the unique properties of the material became known, new uses were found. For example, their fire-resistant nature made them excellent choices for use in heattransfer fluids. Their inertness gave long-lasting qualities to lubricants. Their use in surface coatings improved waterproofing characteristics. NEV 025237 WATER PCB-SD0000072648 -3- Handling of the product at the manufacturing level has not presented problems as long as the industrial hygiene practices were followed and PCB has always been considered less hazardous than many other chemicals in everyday use. . UH/S'C'c Therefore, it appeared-thgt. PCBs were a vamy product which met -itoe^needs of industry. Lat^/^rT'bhe 1960s,^^o^histicated"ana^rtical procedure^ Here deve\op^d''which co^il^.^etect very-minute ^quantiti of PCB iX'hature. Policing this analytical breaky^ \ ,^ ^\ X\ h, resoarcheps discovered that^PCB Could possibly \ e affecting Contain forms\)f aquatic, marine^ terrestrial and avian wildlife. YTM environment. re find stability \ IB, whale so standpoint^of' many industrial applito be-'Ui^esir^b^'^n^tern^s of.< our CURRENT USES When questions about the effect of PCB on the environ ment first surfaced, Monsanto Company reviewed its product line and the applications for these products. CowrfrKmo ft'C- errp-cf- of 'Ktien As more data were developed the environmental ...^rew, Monsanto took steps to reduce the entry of PCB into the environment. The NEV 045438 WATER PCB-SD0000072649 -4 Company stopped the sale of PCB/&S3? -us-e--in-- imnl 1 rn t-.1 nns . Aifr!T*TTtr whPi'P no flf.cpnhaMo al (-ornaHiiao Today, PCB manufactured by Monsanto Company is sold or.iy to the electrical industry where it is used in closed systems as a dielectric fluid in transformers and capacitors -- applications for which nimlni irtnini /there <2x/'s+e. ..... continues- to be no acceptable substitutes. Gurren-tely -there'jre about" fui'Ly electricai~~equipmanlLjiianufac- tnrrrn npprovrrMiy 7T7rrrtTmtin for HM'V-nnil ~i. Our manufacturing and sales reduction program was a unilateral action taken by Monsanto and was based on our evaluation of developing environmental data. Interdepartmental Task Force on PCBs in its report (l), concurs that the safety benefits derived justify the continued use in this application. Recommenda tion 6 under Findings, Conclusions and Recommendations reads as follows: "6. The use of PCBs should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical NV 025239 WATER PCB-SD0000072650 -5- service which would result from a ban on PCB use. Also, continued use of PCBs in transformers and capacitors presents a minimal risk of environmental contamina tion. The Monsanto Company, the sole domes tic producer, has reported voluntarily eliminating Its distribution of PCBs to all except manufacturers of ele< ' ` ` transformers and capacitors." DEFINITION OF POLYCHLORINATED BIPHENYLS Commercial chlorinated biphenyl products, of which Aroclors are examples, are produced by direct chlori nation of biphenyl; the degree of chlorination being chosen to provide desired properties. mat-.prijijR. are-rglatlv-e-l-r-inerb.--clvemi.ca.lly-resistant. readily soluble--in--moat-common -organl.cjsp1 vents, and have water -solubilities .on the. order...ojf_25^200 .ppbfc These products are in all cases multi-component mixtures and not single entities as implied by the commonly employed acronym''PCB^ In--feofr-j--Mre-eofnmereial mfat- r;flri t-.hpnT'oftl rally wr-OVr"7<TrrT5^gT< t componente-containing-O-lO 'chlorine -atoms- per-b-iphenyl fflolecula r M NEV 025240 738495 WATER PCB-SD0000072651 -6- While it is well understood and accepted that etaob chlorinated biphenyl isomershafa a unique set of physi cal and chemical properties, it is apparently not ^ understood that e&eh IsotniMvcrrSb bioaccumulates .and Jr biodegrades at a different rate. This lack of understanding is aanpiwr- reflected in the definition proposed in the EPA Toxic Pollutant Effluent Standards (Federal Register, Vol. 38* No. 247, page 35393* Section 129.09a) and we quote: "As used in this Subpart, the term: Poly chlorinated biphenyls (PCB's) means materials containing the biphenyl group which have been chlorinated to varying degrees. There are 210 possible different PCB compounds." We object to this definition because it implies that altf Chlorinated biphenyl isomers are of equal environ mental concern, i.e., that they all persist and bio accumulate in the same manner in our environment. It has been well established by academic, government, and Industrial researchers that this is simply not true. Environmental monitoring programs have clearly demonstrated that, with the exception of direct highlevel controllable release near points of manufac ture or use, the PCBs found in our environment are the more highly chlorinated ones, i.e., those NEV 0252^1 WATER PCB-SD0000072652 -7- containing predominantly five or more chlorine atoms per biphenyl molecule (2-l3). This is true even though the lower^p;cMhlorinated biphenyls have constituted >65# of all the PCBs manufactured over the years. This^ is strong evidence that the kv**' pW bihrA,(fi i*frs!,chlorinated isomers degrade rapidly. It further iici>,.r H li mif Pc tmcgpois that even under conditions of use, and without special precautions to prevent release into our environment (which is fcgwly not the case now), that the chlorinated degrade f^ ^ -v rapidly enough to prevent bioaccumulation. 1 ~ /3) More recently, it has also been demonstrated in labora tory experiments that chlorinated biphenyl isomers, readily undergo bacterial degradation at rates depen dent upon the number of chlorines per biphenyl-molecule (17, 18, 19 > 20 and 21). There are also good ' Indications that ambient environmental PCB levels / ( /w- are decreasing, at rates more rapidly than predicted (14, 15, 16). The rapid metabolism of these chlorinated isomers and their lack of importance as contributors to the chlorinated biphenyl tissue burdens is evidence in the results of numerous studies. Risebrough (2) re ported that the chlorine composition of the PCB de tected in Atlantic Ocean zooplankton was approximately NV 02b2<2 73R4Q7 WATER PCB-SD0000072653 -8- 54$6. He concluded "it might be expected therefore that biphenyls with fewer chlorine atoms would pre dominate in planktonic samples unless these compounds were selectively degraded." Similar findings in fresh water and marine fishes were reported by Zitko (3) and Jensen, et al., (26). The disappearance of the lower chlorinated homologs in extracts of tissues from birds (5) and mammals (6) would also indicate mebah&Hra--breaitrioww--rrf. the lower chlorinated homologs. Hie-f-ormation of- 4-chloro-4 * -hydroxyblphenyl--from 4.-chlorobipheriyl - in rabbits has been reported~{7). .aj Ijb^haa oloo.-been suggested that hydrcucylatloftof the-lower-chlorine- homologs--i-a~a--general._inetabolie pathway*--resulting-in- complete ~'degra datlorT, In '"birds and mammals-. As a result of the relatively rapid Yy'C * C-'-` ^ CTW J. nnd rr-mp+^te flp-rndaflon of the chlorinated biphenyls containing less than five chlorine atoms per molecule, their contribution to the effluent should not be used In measuring polychlorinated biphenyl effluent from a facility. T .j Oo .the baolG of thoco data-we bcleve A.t -to be- un- poh realistic to consider all'K chlorinated biphenyls equiva lent in terms of persistence and bioaccumulation as does the proposed regulation. jif,3fcherefore, Nsng0*et for environmental purposes, the definition of NEV WATER PCB-SD0000072654 PCBs^focus upon those which are bjewfcy of concern jjL*. 4-Mjlu. and we recommend that a moro ouitoblo definition weraQ "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaccumulate in the aquatic environment. These chlori nated biphenyls are identified as those components having gas chromatographic retention times greater than 60, relative to p,p-DDE = 100, under the standard con ditions recommended in the EPA PCB test method." InX^gge3-ting this definition, we want jib updersjtood \J\* that wfc^are not proposing the unrestricted release ,-/c'r of the ldwfer chlorinated/biphenyls. e only suggest that the data indicates fchat our environment has shown the capabllitv of handling these materials when ncjunts were unkrifcf^in^Iy releas, d and that this, Tilth trie Indust:fci!&l" strict^on of sales to non-dispersj/tfaf uses, wi^JKe^hasis on/re cycle add propterydisposal, has already Brough this aspect rnnder control. NV 025244 WATER PCB-SD0000072655 10 - ANALYTICAL METHODOLOGY We have no reason to doubt that the recommended EPA , ( po-.t) |-C.> VV.*.< V PCB test method is capable of detecting ppt levels of PCBs In waste waters. However, our experience with analyzing industrial waste waters for PCBs at the ppfclevel prompts us to be concerned about the following areas, some of which are not covered ade quately in the test procedure. J 1. Sampling Procedures 2. Correction for Laboratory and Reagent Background 3. Correction for Non-PCB Sample Inter // ferences 4. Absolute Verification 5. Quantitation 6. Precision and Accuracy Our concern lies in the fact that any method, especially one as complex as a PCB analytical method, which is to be used for enforcement purposes must be thoroughly evaluated* If this is not done, the enforcement, and A hence effectiveness of any effluent limit, no matter what the level, will prove to be difficult, if not impossible. ' czc<r* < * OO v- / For example, we have found that if* waste water'streams bep mV properly. ~JLhe PCB levels found depend . NEV 025245 738500 WATER PCB-SD0000072656 11 - on the sampling procedure employed and bear no relation ship to the amount of PCBs discharged. For this reason, sampling procedures used must be designed for the dis charge in question and clearly stated. To our knowledge, this has not been done. We also note that no provisions are recommended for correcting the apparent PCB level found in a sample for laboratory and reagent background. It is our experience that as one approaches the ppt level, this background can significantly affect the observed PCB level. . With regard to correction for non-PCB sample inter ferences, we feel that, while the procedure notes many of the possible interferences, it does not really access itself to those which are more likely to be in indus trial waste water streams. For this reason, if the electron capture chromatogram does not match the PCB being manufactured or used, complete ab**l**fce=dbJfc4-Pi- oe-ttun of all components counted as PCB must be vali dated viaUCK3fIS. JLtc no ,.^o * ( i ` ' Of y), While the scheme proposed for estimation (quantitation) ^ of PCBs is logical, it suffers from the same short coming as do the multitude of other procedures which have been proposed. It is an empirical estimate and NEV 025246 738501 WATER PCB-SD0000072657 12 only a reflection of the real PCB level. Therefore, It should be determined via an alternate, more-elaborate procedure how closely the calculated PCB levels (for each of the cases) are to the real PCB levels so that they may be corrected. . Last, but not least, the precision and accuracy of any procedure proposed as a standard method should under go a thorough inter-laboratory evaluation. If this has not already been done, it must be carried out prior to the use of the procedure for enforcement purposes. The accuracy and precision of the Monsanto PCB pro cedure has been subjected to a preliminary evaluation. Prior to this evaluation, we probably would have over estimated the precision and accuracy of our procedure. The exact details of the evaluation are available. Briefly, samples were prepared by spiking distilled water with 500 ppb PCBs. Individual preparations include blanks (no PCBs), Aroclor 1242 only, Aroclor 1254 only, Aroclor 1260 only, all 50-50 two-component mixtures, and a 1/3, 1/3, 1/3 preparation containing all three components. Six samples of each mixture <> / p f were prepared and analyzed by .two/analytical labora tories ^ Each result, expressed in ppb of the indi vidual Aroclor, .was converted to percent of the total added. Analysis of variance was run on all data taken together and on each laboratory Independently. NEV U252<7 WATER PCB-SD0000072658 - 13 - * The 95/6 confidence limits observed for individual results were: Either Lab 87.5 + 55.256 Lab A 81.3 + 46.456 Lab B 93.7 + 19.256 The repeatability for the individual labs, based on repeat tests of samples having identical prepared compositions was: Lab A + 42.056 Lab B + II.656 We feel that these results demonstrate the importance of evaluating the precision of any PCB procedure. Note that the test did not include sampling problems, used distilled water free of interferences, and was carried out at a relatively high PCB level (500,000 ppt) by two experienced laboratories. It is expected that, if sampling problems were involved, and the level of PCB present was extremely low, the accuracy and precision of any PCB method would degrade considerably. /rpA -^-----P-R--O--P--O--S--E-D-f--E--F--F-L--U--E--N--T----S--T-A--N--D--A--R--DIn the establishment of the proposed effluent standard the primary basis for toxicological consideration came from the Water Quality Criteria, October, 1973, (Federal Register, Vol. 38, pages 29646 et seq., Friday, October 26, 1973). These criteria were, in turn, based on Water NEV 025246 WATER PCB-SD0000072659 - 14 - Quality Criteria, 1972 by the National Academy of Sciences and the National Academy of Engineering. . The Water Quality Criteria, October 1973 have not undergone the normal review, criticism, comment and revision before final adoption. We object to the use of challengeable portions of a proposed publication in the development of critical effluent standards. We note in Water Quality Criteria, 1972 in those sections pertaining to polychlorinated biphenyls, the frequent use of unpublished data and the disturbing use of qualifying phrases such as "...may adversely affect...", "...apparently related...", or "...the work...suggest." In our opinion, none of the discussions present ade quate data to support establishment of responsible effluent standards for PCBs. On page 5 of Water Quality Criteria, 1972, the Committee emphasized the importance in understanding that there is a distinction between criteria and standards and that the words were not interchangeable nor or they synonyms for words such as objectives or goals. Ihe report further states that it is necessary to establish scientifically-based recommendations for each assignable water use, implying availability of practical methods of detecting and measuring which can be applied to monitoring. Once these fundamentals are availablej political, social and economical factors enter into NEV 025249 WATER PCB-SD0000072660 - 15 - the decision-making process to establish standards. In our opinion, these procedural steps were not followed in arriving at the proposed effluent standards for PCBb. The maximum acceptable concentration in fresh water that would be permitted by the proposed standard is 0.002/^g/l. The rationale described in the Statement of Basis and Purpose, Toxic Pollutant Effluent Standards Is based on results of a preliminary study which have suggested (not yet proven) a threshold PCB level for salmon egg mortaility. We cannot accept the selection of salmon as representing organisms which are usual or may potentially be present in water systems near facilities described in Section 129.09, Subpart I, Title UO CFR. Although many reports have been published on the subject of polychlorinated biphenyls and living organisms, the majority of these describe the presence of PCBs in the environment. Presence should not be assumed to imply adverse effect. To our knowledge, no published report exists which conclusively relates the mortality of any wildlife species, aquatic, marine, mammalian or avian, to the presence of PCBs. The only reported mortalities are those achieved in laboratory studies. Not enough is known about the fate and effect of PCBs in the natural and diverse aquatic and marine NEV 02525Q WATER PCB-SD0000072661 - 16 - environments to properly design laboratory studies. Results from such studies are not extrapolatable to the natural situations .and any conclusions derived from such studies must still be considered speculative. undamental scientifically based data is lacking and the establishment of effluent standards for polychlorinated biphenyls cannot be made intelligently and responsibly. In the establishment of the PCB effluent standard for freshwater systems a bioaccumulation factor of 200,000 waB selected. This factor has no extrapolatable relationship to either the residues of PCB in salmon eggs or to PCB residues of fresh water forage fish. The only published report of an accumulation factor of the magnitude selected was that for the hepatopancreas of the pink shrimp, Penaeus durarum, (27). Even though an accumulation of 204,000 in the hepatopancreas has occurred, a neaiy complete elimination of PCB from that tissue was achieved when the shrimp were placed in water free of added PCB. The equilibrium whole body accumulation plateau indicated an approxi mate accumulation factor of 22,000. These results are in agreement with those reported by Stallings and Mayer (30)j and with the studies of Ryther (28), NEV 025d1 7^DCf\n WATER PCB-SD0000072662 - 17 - Greichus et al (24) and Crump-Weisner, et al (22) showing equilibrium biomagnification factors between water and fish ranging between 1000 and 75,000 and would support the selection of a factor considerably lower than the 200,000 which was applied. We suggest, from a review of the available literature, that a hJ i' ' Abritrary safety factors were applied to the tolerable chronic limit to establish the so-called "critical chronic limit" which was then used to compute the maximum allowable effluent. These safety factors were proposed to account for a multitude of variables, including non-point sources, multiple discharges and industrial growth. The safety factors proposed were identical for 7 of the 9 materials for which effluent standards were prepared. These safety factors, resulting in approximately two-fold reductions, are so small as to be of no beneficial toxicological con sequence. ' . In establishing the effluent standards, an attempt was made to distinguish between types of receiving waters by classifying them as streams, lakes and impoundments, estuaries and coastal waters. We do not believe this attempt to distinguish water bodies NEV 025252 738507 WATER PCB-SD0000072663 - 18 - is by any measure adequate. Water bodies are universally known to be complex systems with no two systems alike. With a complex material such as polychlorinated bi phenyls, the determination of possible adverse effects in each water body becomes exceedingly difficult. The uniqueness of each water system must be considered. A key parameter used to further describe the water body is the flow rate which was limited to the probable low rate of stream flow occurring during a sevenconsecutive-day period once in ten years. We do not agree that is realistic or appropriate. In our opinion, aoeqnafte control can be achieved using average stream flow rates. Further, the maximum flow rate that can be used in calculating the daily discharge permitted has been arbitrarily set at 10,000 cubic feet per second. Ihis limit is based on a nondegradation philosophy which tolerates limited diffusion and on a desire to discourage industry from locating facilities on large main inland waters and coastlines. This limita- tion deprives our society Judicious use of an important great natural resource. Discharge limi tations should be based on the adwpee effects a ,, material will have on a water system, rtffc^On its size NEV 025253 77R*;np WATER PCB-SD0000072664 op flow rate. For PCBs, proper control will not occur by Imposing maximum flow rate conditions, but by applying results from scientific studies which properly de fine how each water system responds to the presence of PCBs. RESIDUAL POLYCHLORINATED BIPHENYLS Because of their chemical and physical properties, PCBs can be found in soils and waters long after a discharge has occurred. This source of PCBs to the environment will diminish with time. To maintain con trol of losses, emphasis should be directed toward discharges resulting from current and future uses of PCBs. Since this problem of background levels occurs with all materials in varying degrees, we propose the following revisions: From Section 129.01c(b), Subpart A, Part 129, 40 CFR, delete the words ,rin intake waters for a discharger". Add an additional definition in Section 129.01a: "Background" means amounts of toxic pollutant (l) presently found in the waterways of the United States (including the intake waters of NEV 015254 738509 WATER PCB-SD0000072665 - 20 - a discharger, or (2) arising out of operations subject to this Part that occurred before the effective date of this Part, but were not discharged to the waterways of the United States before the effective date of this Part. PCB DISCHARGE CONTROL - MANUFACTURING FACILITY During the late 1960's, as more data were developed indicating PCBs could possibly be affecting certain forms of wildlife, Monsanto voluntarily undertook a two-phased program to keep the product out of the environment. One phase Involved the limitation of sales of PCBs which was described above. Hie second phase involved the control of discharges at our manu facturing location. Since 1969, we have Invested more than 22 man-years of work and millions of dollars in this program. In our manufacturing area, we have taken a number of significant steps to contain PCBs. In essence, we have made the department a "concrete bathtub". Drain age is directed to trenches and piping, and then to one of two 3,000-gallon settling basins. This in sures PCB containment in case of accidental spill or equipment failure. NEV 025255 738510 WATER PCB-SD0000072666 - 21 We have also Installed an Incinerator to safely dis pose of PCBs. This Is accomplished through incinera tion at or above 2000P. When small quantities of PCBs are collected into the settling basins in the manufacturing area, they are later pumped into drums, and eventually incinerated. In the Incinerator area itself, drainage is directed to trenches and piping which flows to a 10,000-gallon basin. Recovered PCBs are periodically pumped to storage, or incinerated. In the manufacturing area, we have also rerouted rupture disc lines and atmospheric vents through catch tanks, or redirected them to settling basins. This insures that, If a rupture does occur, PCBs will not get into the environment, but will be contained in a controlled area. We also provide nitrogen blanketing on storage tanks to eliminate any "breathing" of the tanks and resultant PCB escape. We have installed mist eliminators in vapor lines -- once again to eliminate the possibility of PCBs leaving the manufacturing area through these lines. Finally, we have replaced underground sewers with above ground sewers, and repaired or combined others, so NEV 025256 WATER PCB-SD0000072667 738511 - 22 that we can monitor the effluent from the department. In addition, this will prevent any unknown buildup of PCBs in our sewer systems or any contamination of PCBs into other sewers. Much of the success of our efforts also depends on maintaining a high housekeeping level in the depart ment itself. Among the housekeeping responsibilities our operators have assumed, are these: All pumps are checked for leakage on every shift. Drip pans that collect leaks are emptied into scrap PCB drums. All leaks are reported and documented so that corrections can be made and settling basins observed. ,,FloorDry,, is used to absorb any liquid PCBs that have spilled or leaked. If it be comes necessary to flush PCBs to the settling basin, a minimum amount of water is used. Sampling drums and scrap PCB drums are quickly palletized, labeled, and transferred to the Incineration area. 738512 Through these kinds of programs, we feel we have literally built a "concrete bathtub" to catch and NEV 025257 WATER PCB-SD0000072668 - 23 - safely dispose of PCBs at our manufacturing location. We have also developed sophisticated systems to monitor our effluent. Monitoring effluent streams for PCBs is not an easy effort. Measurement can be changed dramatically by taking the sample at different places along the sewer main, by changing the level at which the sample is taken, by changing the speed at which the sample is taken, or by varying the velocity of the effluent. But we have purchased the best available laboratory equipment, which enables us to determine PCB content in the parts-per-billion range. Here again, however, many factors affect our findings. The minimum detection level of PCBs on a routine basis contained in distilled water is one part per billion (+ 2556). If "dirty" water - i.e., that containing other materials which interfere with the determination of PCB -- is analyzed, the minimum detection level is 100 ppb + 25#. Monitoring is difficult. But we feel with our experience and acquired "know'how", we're doing the best possible Job, And we do this Job 24 hours a day, 365 days a year. We have also established loading and shipping safe guards to minimize accidental PCB loss during trans portation. Specific written instructions are on every container we ship. 738513 NEV 025258 WATER PCB-SD0000072669 - 24 - We have provided facilibies for safely disposing of used FCBs returned from customers. As mentioned above, we installed a specially designed PCB incinerator, at a cost of $790,000. We have received an operating permit from the Illinois EPA for this incinerator, which meets all EPA requirements. This incinerator completely destroys PCBs received either from our manufacturing area or from customers. Finally, we have moved toward the manufacture of a more biodegradable polychlorinated biphenyl . In 1971, we installed a new distillation column in our manu facturing department at a cost of $970,000. This allowed us to separate the higher chlorinated, less biodegradable compounds from the lower chlorinated, more biodegradable ones. Our PCBs are known by the trade name Aroclor. We manufacture different grades of Aroclor (1016, 1242, 1254, for example). The lower the grade number, the less chlorinated and more biodegradable is the product. The attached table reflects how our production mix has changed to more biodegradable products while the production of higher chlorinated less biodegradable products has declined. We believe we can confidently assert that we have taken strong measures to contain PCBs and keep then out of the environment. NEV 025259 WATER PCB-SD0000072670 iVfc & & WATER PCB-SD0000072671 - 26 - SUMMARY 1. Actions by Monsanto and its customers, which have resulted in limiting the use of PCBs only to electrical applications in hermatically sealed units, have dramatically reduced the quantities of the more persistent PCBs introduced directly into the environment. 2. There are over 200 chemical entities collectively known as PCBs. The chemical and physical charac teristics of each of the isomers are not all alike. There is ample evidence that the higher chlorinated isomers are the type found in wildlife organisms and are, therefore, of environmental concern. We have proposed a definition describing the more persistent PCBs. 3. We-~are concerned- with^he accuracy and reproducibility of results attainable between laboratories using currently-available sampling and analytical tech f\J-K.Sj ,, /' . t/ niques and further studies ar$-psposgd. 4. Wo ore cuncei'irgtt with-a PCB effluent standard, based on inadequate toxicity information on a non typical fish species and on an unusually high 0^-AaU^cL'v~ awd unique bioaccumulation factor. Vte. sincerely * - <* . .. believe- good-ee4entiXio-4nforma.tlon is lacklng-and no-responsAbie standard can be-.developed at-this timer NEV 025261 738516 WATER PCB-SD0000072672 - 27 - 5. We object to a limitation of 10,000 cubic feet per second being arbitrarily assigned as a maximum stream flow ut-a^sound--beoHn11 a 4*- roana-fc-ra-tlRg a-dverse . aLCac-fcB-.- 6. Wfi. hnU-^re-^hc presence of background levels of PCBs should be considered and propusu a definition Our purpose in commenting on the proposed standards is to aid the Agency in the development of realistic efflu ent standards which will achieve the intended objectives without serious technical, social and economic disrup tions. We recognize the seriousness of this endeavor and find a statement made by Mr. John R. Quarles, Jr., Deputy Administrator, Environmental Protection Agency, of considerable interest. At a recent conference, Mr. Quarles (31) stated: "We have found it virtually impossible to devise intelligent standards which specify an appropriate degree of control over toxic pollutants irrespective of the sources of those pollutants and factors affecting the feasibility and timing of their abatement." NEV 025262 WATER PCB-SD0000072673 738517 - 28 We can appreciate Mr. Quarles' concern, particularily as it applies to PCBs. Lacking good scientific in formation on the fate and effects of PCBs in complex water systems each having unique characteristics, we urge extreme care be taken to avoid the promulgation of effluent standards which are unattainable and un warranted. Respectfully submitted. NfcV 0252^3 WATER PCB-SD0000072674 738518 HISTORICAL SUMMARY OP PCB ENVIRONMENTAL ISSUE ! By i W. B. Papageorge I i Polychlorinated biphenyls have been commercially available for over 40 years, and, as many of you are aware, are produced world i wide In many of the Industrially developed nations. As with many industrial chemicals, early studies to determine the toxicity properties of these materials were designed to provide the appropriate Information to guide the manufacturers and users In its proper handling, storage and shipping. This understanding of the polychlorinated biphenyls resulted, through the years, in a remarkable record of very few Incidences of human exposures re sulting in observable effects. In each reported Instance the i existing evidence Indicated that improper Industrial hygiene prac tices were being followed. , i During the late 1950's and 1960's increased interest in the pres ence and effects in the environment of chlorinated hydrocarbon pesticides resulted in the development of sophisticated analytical methodologies with capabilities of detecting these substances at i extremely low levels of concentration. In the use of gas-liquid chromatography for the determination of DDT and its metabolites, investigators were puzzled by the pres ence of response peaks which could not be Identified. Generally, i these peaks were ignored, and, in some laboratories, they were considered as possible metabolites of DDT. 5 1 In late 1966, Drs. Jensen and Widmark, Analytical Chemistry Lab oratories, University of Stockholm, identified these peaks as poly chlorinated biphenyls and claimed to have found these materials 1 in many foods, human milk, infant hair, pine needles and in feathers from a mounted eagle in a museum. The results of this study were published in 1967. 1 During 1967 other investigators, using Jensen's method, established the presence of polychlorinated biphenyls in samples from the environ ? i ment. By late 1967 and early 1968, presence in the environment was fairly well established, but in many Instances could not be explained. All oi* the early reports indicated that the polychlorinated biphenyls being identified represented mixtures of the higher chlo \ rinated isomers. 4 At this point, Monsanto launched a multi-point program aimed at obtaining more information about polychlorinated biphenyls and their presence and impact on the environment. This program included the followings 1. Develop analytical methodology V PLAINTIFFS EXHIBIT I I %o 2. Conduct biodegradation studies N6V 021523 729578 WATER PCB-SD0000072675 2 3. Conduct animal toxicity studies 4. Develop alternative materials for PCB applications 5. Develop a program for the recycle or proper disposal of scrap polychlorinated biphenyls 6. Develop a continuing program of informing our cus tomers of significant developments 7. Cooperate fully with industrial, governmental and academic laboratories Studies performed throughout the world have resulted in the fol lowing findings: 1. The presence of polychlorinated biphenyls in the environment has been confirmed. 2. Some Isomers of polychlorinated biphenyls are more resistant to degradation than others. 3. The early claims indicating that PCBs result In widespread thinning of eggshells in wild birds have not been confirmed. 4. Massive fish kills attributed to PCBs have not been confirmed. 5. Biological magnification in the food chain does occur. 6. Some species of marine and wildlife are very sen sitive to low levels of PCBs, e.g. brown shrimp. Borne species of fish, invertebrates, mink. - 7. PCBs identified in samples obtained in remote areas represent the higher chlorinated isomers. Samples obtained near a source of the commercial material contain the lower chlorinated iBomers. 8. High doses of polychlorinated biphenyls present in rice bran oil resulted in the presence of toxic effects in over 1,000 Japanese. 9. The effects of chronic long-term, low-level exposure to humans has not been established. 10. High levels found in human food and animal feeds are traceable to known sources. Because of its presence in the environment and indicated effect on some species of wildlife, coupled with the concern regarding NEV 02152< 729579 WATER PCB-SD0000072676 the effect on humans of low-level, long-term exposure, Monsanto voluntarily instituted a worldwide program for terminating the sale of polychlorinated biphenyls to those uses in which control of escape to the environment was impractical. NEV 021525 729580 WATER PCB-SD0000072677  St Louis March 30, 1970 H. S. Bergen - HSERG H. L. Mir.ckler - KMI!'C P. S. Park - PPARK J. E. Sprir.ggate - JSPR RETYPED FOR LEGIBILITY W. B. Papageorge WPAPA We have been in communication with a Dr. Hill of the Ohio State Board of Health. He has found PCB, particularly Aroclor 1254, in samples of milk from at least three herds in Ohio. He has traced this contamination back to silage from three different silos. Dr. Hill reported concentrations of 0.2 ppm of PCB in the silage in the center of the silo and up to 20 ppm in the material next to the walls. He also stated that concentrations in the milk were between .0.1 ppm and 0.6 ppm and that some of the milk had been destroyed. The silos are concrete silos whose interior surfaces were painted in 16? using a formulation that contained 1254. I don't know if there was any other Aroclor in the formulation nor do we know the coating manufacturer; although, this could be found out if important. The presence of PCB in the silage came from flaking off of the material and possibly from leaching out during the silage storage. At present they will have to destroy about 150 tons of silage which is valued at about $30 per ton. As a rough guess, they consider there may be 50 other silos involved in Ohio that were painted with the same formulation. They are also looking into the fat contamination of the cows themselves. All in all, this could be quite a serious problem, having legal and publicity overtones. This brings us to a very serious point. When are we going to tell our customers not to use any Aroclor in any paint formulation that contacts food, feed, or water for animals or humans? I think it is very important that this be done. It may be that some of the customers will assure themselves on the basis of non-extractability that a particular formulation might be safe but I think we should make a blanket recommendation against these uses. REK/ln R. Emmet Kelly, M. D. m is E00M39 90 WATER PCB-SD0000072678 y **-. C ' - ""st.JXc Kerch "30 ^;1976!.>.- 1 . --- . ' B.: ^po'geoxgc2-: TlV??APAT4:jJ;:^rJr^^ s.' Bergen -.' K2Z? r V.i n c V. 1 a r.. - 1K>' St r>.Vrf?P^Z'.: `Springca^te- ^sTe';l>cca`iin.-.con:it3nication. viti -a.1 DrV .Bill^of 'the'Ohio1" nor c6" -e>:n cw.:.the .'coating nnnafacttrer; .'elthouch,1 hisco found! ;ou t* i f iwor te .n t ;*?2 Th e presence of. >C3 in'the" sil '.-icajr.e from. fle'king.off.'.'of.r^teriel .'and .possibly.froa"->-" (,M:frf-2etching'onti'dirring.- theVsilage./s torece'v..' At "present'.thay;:v :-~- y^'r^y bethat. sene"of " the' cos termers will" assure thence Ives `o: .r-..:_ ::"basis "'of; non,fi?xtreetebi-li ty that a pivrticuler fonr.nlati WATER_PCB-SD0000072679 BCCs P, 0. BSTCCBTOS L. A* OLSOH 19T0 Mr* Carlington kilburn Manager# Engineering Vestlngheusa neetrie Corporation South S9itoi)| Virginia m Star Oorji * X have md pour Process Specification SSltOCA, disposition of Scrap Inerteen and Inerteen Contanlaated Materials* and X found it an excellent document which roflaeta Vestlngheuse's concern about th PCS problaa and la a major atop forward toward improved control, . X do have one concert that X would Ilka to past on to you. The suggestion to burn solvent or oil contaminated with Inerteen dost not refer to asy alnlaua ooabustlon teaperature* As we dlaeuaaed previously# total destruction of PCB*s oan only occur above 600C* Any tasperatura below this olniaua will rasult In vaporisation with release to tha ataoephara or woraa yet# It la potalbla to partially oxidise PCS's Into natariala which oan be highly toxic (.{. dioxins or furans)* your insineratien should bo thoroughly reviewed* X found our diaouasion and plant tour last weak vary Interesting and inforoatlve. Tour plant has excellent houaekaeping and with continued eephaaia on controlling less of PCB's to the air and sewer# X aa confident you can succeed In achieving a *bone dry* plant la mlsh tha leakage# spills# ate* are a rarity* X aa working with our F*R* Be?artcent on a suggested press release which X will send you ones* Sinearely# ***** ft 1 AmIim V* B. Papageorge, Manager Swlronaontal Control PLAINTIFF'S EXHIBIT 6BRN003404 906102 WATER PCB-SD0000072680 .1 f* see* a. BsrccDflB o, jl+ otsou July 8, ltfO Hr* f* 0* Jenkins Tic# President, Kafcerlels Sprtgue fleotrio Coepany . Horth Adame, xassachusett* 0X247 <ir hr* Jenkinst X m fortunately able to visit your Brown St* Slant on June 17 with Randall drshsa* X personally found ths discussion iafor*aative and interesting and 2 was seat favorably 1^raised with tbs concern and interest expressed by yetxr Bnagvnsut personnel* Ve diaeuaaed briefly seas Of the points raised in jour letter dated June 11. X try in this letter to be acre apccifia* Blodegyedabilltar - Biodegradation todies conducted in our rtsearcna laboratories Iin $St* Louis, Hissnurl and In Ruabcn, Vales using aedla consisting of loesl river miters or activated sludges acclimated to biphenyl give direct evidence that tbs lower chlorinated biphenyls are affected, there Is soae evidence that chlorine position on the biphenyl configuration docs influence the degree of dietraction by the aleroofgtnisms* X here encioeed a tabulation from our Xuabcu laboratory yftich attaepts to show this diffsrcaoe* Vc do not have foraal information regarding the effect of sunlight or Other natural Influences on Arcelor** Ssporienco gained ever sanr years indicates Arodors are highly stable under all known condition* present in the environment. Toxicity - fiere is ss^le evidence frun easy laboratories that certain species of birds which are at the top of ths rnrlne food chain cannot reproduce properly When 23*a are present la their diets* Hm V 3* lishetit* boratory at Oulfbrease. Florida conducted a study which indicated that Juvenile brom* ahrlop did not survive in water containing 5 parts per billion of FC3. Attached ere copies of reports ca those atudles* PLAINTIFF'S 1 ( EXHIBIT I STA CC*C &4o>i* H15____ I 14 r~\ s ^ WATER PCB-SD0000072681 -2* Monsanto haa sponsored soaa atiaiiea oo laboratory rats and docs* A suacaory of the results to dots - is attached* Slsposal - lie preferred oethod for dispose! la E^t'Spcrature incineration. 2 suspect there are several coesercicl buxtter* on tbs eerket mich will perform sell* 1 personally witnessed burning tests at the John Sink Cocpeny** unit ln^tulss, Cklahoea. Temperatures euat exceed 150Qrf to ensure that coeplete destruction la achieved* Lover temper* aturts would only vaporise the kroelor* sad create ataospherlo pollution or, wore* yet, would fora, by partial oxidation, eatcrisis which could be highly toxic (e.g. forens end dioxins). mth Incineration SCI Is ftraed Wtleh must be scrubbed frtrt the Stick gas and neutralised before disposal* We ar^ planning for an initial installation la one of our plants labor this year* As a eerrice to our cuetowers mo way not have access to other Incinerator*, ve have offered to aeeept scrap Aroelor for 1mediate storage end eventual incineration* Tentatively, soesanto will chars* 2# por pound of returned eatcrlal. ftu charge dee* not include freight or container coots and vlll be relieved when final incineration coats are established* Material which Is returned far disposal theuld be addressed to Monsanto Cewpasy, V, 0* Eruosdlch Plsat, Sauget, Ulinoia, Attentiont Supervisor Pepartaeut 246. . Solids contaminated men Aroclor* preseat a bigger challenge* As yet, we have not tested an incinerator with these aaterlal*. ttotll we get sore information the best we ean advine is safe burial in an authorised, property operated land fill located awey fjoai any " - Ve have laboratory mtk underway on other fores of dectract!ecu as yet no economically feasible oppress* has been round. Srnlgtieel Methodology X have attached copies of fieassnwHs earnyticai procedures for the determination of PCS'* in ester, soil, air and biological sa&ples* Ve ere interested in coopering our oethode with those devised by other laboratories. Any cooatnts your laboratory soy have would be Welcome and appreciated* ilk GC4CJ WATER PCB-SD0000072682 X tap* that tfe* atari Indorsation la nafal to joa, Xf l oss b od rurttar aorvioo, plaaao let too*, sinooraly. at Xr 8. ttvlt Xpra^o ZlootrL* i. *. omul V. S Ft*vtCtT aifigonantttal Control WATER PCB-SD0000072683 MITSUBISHI *v ;-'NSANTO CHEMICAL COH fROM LOCATION t Tokyo May 18, 1971 : PCB Environmental Problems TO j Mr. W. B. Papageorge St. Louis ' Messrs. D. Danna-St. Louis J. R. Dui'land-Tokyo Dear Mr. Papageorge: Thank you very much for your prompt action of sending us information arid data .about the environmental problems of PCB's, PCT's and other related products at my renuest of March 19, 1971. They are very interesting and useful to us. After a careful review of the data received and analysis of the situation facing us here, we have come to conclude that it would be difficult to promote the sale of PCB related products in Japan without establishing a systematic strategy including not only presentation to customers of data explaining that products are free from pollution but also supply of such information as to degradation and disposal. In this connection, we have decided that we would ask MC to provide us with basic data on MCS-1016, MCS-1043 and other promising substitutes for PCB referring to such points as mentioned above. We shall be very happy, if you are good enough to arrange for us to get information and data listed below: 1. On MCS-1016 An Environmentally Compatible Aroclor (Analytical Chemistry Special Study 71-2 Job No.13480 written by E. S. Tucker) NEV 026947 740202 WATER PCB-SD0000072684 MITSUBISHI MONSANTO CHKM1CAL COMPANY o ) I 1) At the middle of page 2, it reads "the fact that PCB's containing 5-8 chlorine atoms are the most refractory toward degradation as witnessed by what has and is being found in 'weathered' biological materials". We would like to have a report proving said fact and comparative data on degradation with other PCB's. 2) Degradation data by RDA exposure described on pages 4 and 5 are needed. Have further tests been done by MC on MCS-1016 itself? We would like to have such graphic data on MCS-1016 and other items as shown on A-1221(Fig, IV, V) at the end of said report. 3) Detailed data are needed on "determination of PCB Residue^ in Rats Fed A-1242, A-1254, A-1260" described on page 6. ' 4) What aro biphenyl active cultures C2 and C3 referred to on pages 3 and 4 dealing with "accumulated bacteri al degradation" and shown in PCB Environmental Problem March Status Report? Please send us detailed data on each item of PCB degradation by said materials. Are those active cultxires usable on a commercial scale? 5) We know that MC's studies have been continued on bacterial degradation, rat metabolism, etc. of MCS-1016 for the purpose of proving safety of the product. How do they progress? 2. MCS-1043 1) What is MCS-1043? 2) According to PCB Environmental Problem March Status Report, degradation rate of MCS-1043 by SCAS is twice as fast as those of A-1242 and MCS-1016. Would you inform us of degradation data such as rat metabolism? 3) What are the performance of, and fields of application for MCS-1043? 4) One gallon sample is needed. -2 NEV 02694b 740203 WATER PCB-SD0000072685 MITSUBISHI MONSANTO CP~MICAJ. COMPANY u 3 3. On Serai-Continuons Activated Sludge Tests Is the SCAS method commercially usable as a degradation process for MCS-1043, MCS-1016, A-1242, HB-40, MIPB etc.? 4, As to HB-40 and MIPB, we would also like to have such data on degradation in human bodies that prove safety of the products. We also want to have data on 90-day studies explained about on page 5 of PCB Environmental Problem February Status Report. Your assistance would be highly appreciated. Best regards. MM:ri S. Uneno Product Director Division C NEV 026949 740204 WATER PCB-SD0000072686 MITSUBISHI MONSANTO CHEMICAL COMPANY FROM LOCATION Tokyo July 8, 1971 AROCLOR REFINING Your Memo July 1, 1971 TO Mr. W. B. Papageorge St. Louis, Mo. ce` Messrs. P/ G. Benignus . S. Bergen D. Danna T. L. Gossagc T. Katayama R. E. Keller/E.S.Tuc R. H. Munch W. R. Richard S. Un eno E. P. Wheeler This will acknowledge receipt of your memo and the attached 15 reports, all relating to the biodegradability and toxicity of Aroclors. At MMK, we are under -substantial critical pressure from both national and prefectural ministries, because the available data have been insufficient to satisfy them on the improved biodegraw dation of Aroclor 1016. Even though it is obvious that the data show comparatively rapid removal of chlorinated isomers in the lower range, the presence of CI4 and higher chlorinated compounds is criticized -- even if these may be only one-tenth of the concentration in Aroclor 1242. I suppose this is a natural fear of persistence. Since the effluent from the Yokkaichi plant, where our Aroclor unit is located, discharges into a large bay which is extensively used for fishing and oyster cultivation, reduction of higher chlorinated biphenyls to an economic level in 1016 is still considered a potential (threat. We shall need any additional degradation data on Aroclor 1016 before we can introduce Aroclor 1016 as an improved product over Aroclor 1242. My congratulations also on your expanding responsibility. I am sorry we were not able to get together while I was in St. Louis. Best regards, . JRD:fu ^T. R. Durland NEV 025473 738728 WATER PCB-SD0000072687 biodegradation test program . Provide Degradation Rates of Material Submitted for Testing Business Group Product (In order of Testing Procedure Location Method of Start Up Date Estimated Completion Date ' Functional Fluids MCS 1043 I4CS 1016 Aroclor 1242 Aroclor 1254 Aroclor 5432. Aroclor 5442 Arobrom 5465 * 1. Activated Sludge St. Louis 2. River Die-Away St. Louis 3. Shake Flask Ruabon 1. Activated Sludge St. Louis 2. River Die-Away St. Louis ' St. Louis Trichloro benzene 1. Activated Sludge St. Louis * 2. River Die-Away St. Louis EC/GC EC/GC EC/GC 8-10-70 11-3-70 Underway 2-71 1-4-71 ? *? ? ? ' . Ed/GC EC/GC Holding until.further analytical method . development work is completed 10-27-70 ------- 4-71------ 11-3-70 1-4-71 0-v0| 00 zm < CO oNWii -r- Gulf 200 Bright Stock Neville Uniclor 40 1. Activated Sludge St. Louis ` FID/GC. 2. River Die-Away St. Louis FID/GC 12-1-70 12-1-70 MCS 717 MCS 762 penta-Biphenyl Isomers hexa Biphenyl Isomers Shake Flask Ruabon EC/GC Underway NC Phosphate Cresyl Diphenyl Phosphate Tributyl Phos phate Tricresyl Phos phate Diphenyl Sulfone Tolyl Xylyl Sulfone Trichloro Di phenyl Ether Monobromodichlorobenzene (Cont'd) Materials to be incorporated into program as equipment and manpower become available. 6-71 2-2-71 7 WATER PCB-SD0000072688 t I BIODEGRADATION . AT PROGRAM Provide Degradation Ratea of Material Submitted for Testing PAGE 2 isiness Group Product (in order o Priority) Testing Procedure unctional Fluids 2,2'-dichlorodi- Cont'd) phenyl ether Cumylphenol ' Isopropylphenyl Phosphate Orthoxenyldi- phenyl Phosphate Xylyl Phosphate Ester(Fyrquel 220) lasticizers MIPB HB-40 Aroclor 5460 % mz -oc-co>oJlo < orU<ji VsJ1i Ar.oc'lor 1221 Santicizer 711M IN-425 IN-420 * 1.. .Activated , ...Sludge 2. River DieAway 1. Activated Sludge 2. River DieAway 1. Activated Sludge 2. River DieAway 1. Activated Sludge 2. River DieAway 1. Activated Sludge 2. River DieAway Location \ Method of Start Up Analysis . Date ' Estimated Completion Date ' i _ St. Louis St. Louis St. Louis St. Louis St. Louis St. Louis St. Louis St. Louis St. Louis St. Louis UV and FID/GC ? 5-27-70 8-31-70 Initial work completed; report to be ` issued Holding until further ; . analytical method develop- ment work is completed * > EC/GC EC/GC 10-27-70 11-18-70 4-71 \ 1-19-71 ' Holding until analytical ? method development ' complete Potential economic and Hold - acute toxicity problems (Cont *d) WATER PCB-SD0000072689 * f BIODEGRADATION -EST PROGRAM PAGE 3 Provide Degradation Rates of Material Submitted for Testing . 3usines9 Group Product (In order o Priority) Testing Procedure ' Location Food and Fine 3,414 *-Trichloro- 1. Activated Chemicai ls , . carbanilide Sludge 2. River Die- * Away General Chemicals. 3,3',4-Trichlorocarbanil- . ide 3,3',44'-Tetra- chlorocarbanilide Santophen I - p-Nitrochloro- benzene . o-Nitrochlorobenzene p-Chloroaniline nitrated orthene * i River Die-Away * Ft 5/ * 1* ' 1. Activated, Sludge 2. River Die- Away , St* Louis St. Louis * St. Louis St. Louis St. Louis # Method of Analysis uv uv 1. ' Estimated . Start Up Completion Date ______Date 7-27-70 8-28-70 Initial work completed; report to be issued , Initial work . completed; uv 8-28-70 report to L. issued '? . Analytical method .f * * development work to . be initiated 11-23-70* . * zin a2> oo oMU*i a WATER PCB-SD0000072690 W. B. Pnpagocrgo - Ganorel Cfficos -- E2HK Sapterher 13, 1971 W, R. Richard - T3A P* B* Ecnignus - P2CH n. . tsrc.en - B?sa T L* Gocesge - B2SL R. B. Keller - 17G0 R* B. Kunch - 17G0 C* Baton - C3SP Dr* tyon Hendalcorn, Westing/houso Research, Pittsburgh, Pennsylvania called to inquire about a foroal report describing tho relativo data cn tho biodegradability of Aroclor 1C1G and Aroclor 1242* Ea indicated ho had seen eueh a report end that eonoono in Konrrcnto had offered to send hits a copy* Xo there a report va can freely share vith cuotosara or can tho data evcilfcblo ho presented in a rwxrnar that psraits ua to do so? WBP/or tr* B* Papsgeorge r NEV 025139 738394 WATER PCB-SD0000072691 Monsanto Monsanto Company BOO N. Lindbargh Boulavard St. Louis. Missouri 63166 (314) Oxford 4-1000 January 19, 1973 Mr. Paul G. Benignus Chairman, Steering Committee American National Standards Institute Committee C-107 c/o Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 ^ear Paul: Vith the completion of the final draft of the guidelines for the proper use, handling and disposal of Askarels, it appears to me that ANSI Committee C-107 can now direct its attention to the remaining objectives, which you will recall are as follows: 1. Serve as a source for technical information and advice for Pederal, State and local authorities and for the information of all others concerned. 2. Encourage the development of suitable dis posal facilities and maintain a list of their capabilities and locations, for the information of all concerned. 3. Serve as the advisory group for U.S. particlpatlon in CEE, IEC, COPANT, SEGRA and other international organizations. I would very much appreciate the recommendations of your Steering Committee relating to the makeup of working cosnlttees assigned to the effective achievement of these objectives. Sincerely, WBP/bt cc: A. M. Salazar V. B. rapageorge Chairman ANSI Committee C-107 PLAINTIFF'S 1 EXHIBIT I ADM 007709 WATER PCB-SD0000072692 *t 1 V, V2Q/Y2 -1- FCB'S - ALLOWABLE DISCHARGE PROM PRODPSIMQ/frSIMO PLAMTS MMOTB3 OP MBBTINQ - 4/13/72 IM EPA OFFICES. WASHIMQTOM. D. C. A. Present For Monsanto K. Warren Easley - Washington Office V. B. Papageorge - O.O. A. 5.Lelsy - WOK R. M. Blowers - WOK W. C. Engman - WOK E. Scott Tucker - MIC - Research S. 2nd. P. B. Hodges - 0.0. For EPA John L. Buckley - Deputy Director - Ofc. of Research Alphonse F. Forzlatl-Chief, Measurements ft Instrumentation Branch Paul E. Des Roslers-Staff Engineer, Industrial Pollution Control Elizabeth Anderson-Staff Chemist - Ofc. of Tech. Analysis Gordon Everett - Director - Ofc. of Tech. Analysis Marllee Miller - Mo title Olenn Pratt - Chicago Region Enforcement Kathleen Schirmer- Staff Ass't. (New Toxic Div, not established) B. Background of Meeting The Task Force for PCB's, with representatives from various Federal agencies Including FDA, EPA, USDA and coordinated through the Office of Science and Technology, will soon release Its voluminous report on the PCB's problem. Monsanto has cooperated * with the involved agencies and had some insight into what would appear In the report. We agreed generally with nearly all of the report recommendations, but could not concur with two recom mendations (as we understood them)i NV 000715 716676 WATER PCB-SD0000072693 -2- V (1) Water quality standard for PCB's to be set at 0.01 ppb for rivers and lakes. (2) Zero detectable level in dischargee fro* plants producing or using PCB's. An inconsistency existed in that we understood that the 0.01 ppb water quality standard was derived from a calculation Involving 10-year low flows in the Mississippi River and a 3 lbs/day discharge from our WOK Plant (their understanding of what we were discharging to the river - the 3 lbs/day is equivalent to about 0.01 ppb in the river with no allowance for background) A meeting was requested to discuss these recommendations with ]>r. Buckley, with Intent to prepare a formal presentation for them. However, due to time pressures in SPA, the meeting was set up on 1 day's notice. Our Information and comments had, therefore, to be presented informally, with little time for preparation. The Monsanto group met to plan for the meeting on Wednesday afternoon, the various asslgnments/presentatlons were prepared that night and were reviewed on the plane to Washington, followed by another quick review In Warren Easley's office. Our objectives for the meeting were: (1) To Induce SPA to recommend a more reallatlo water quality standard than the 0.01 ppb - say, 0.1 ppb. The higher level would be more in the range of reasonable precision by the average laboratory and would recognize a small PCB background. NEV 000716 716677 WATER PCB-SD0000072694 c -3- (2) To Induce EPA to drop the "zero discharge" concept and to allow a reasonable discharge (5 lbs/dap) In terns of lbs per day - not concentration. 5 lbs/day Is con sistent with requests of the electrical Industry using PCBs. (3) To induce EPA to allow a reasonable time to attain the discharge Halt. C. Minutes of Meeting (1) Following "round-robin" introductions, W. Papageorge stated our appreciation of this first opportunity to discuss with then the problems Involved with plant discharges. He stated our desired format, which was to have various plant people discuss what we had done and were doing to control PCB discharges and to explain the problems Involved. Buckley concurred. (2) Art Lsisy spoke briefly of the complex nature of the VGK Plant, the relationship to Sauget Village and the concern within manufacturing of the envlronaental impact of wastes from the manufacturing processes. (3) Dick Blowers discussed physical growth of the plant, complexity of the sewer system, size and extent of our current program for ln-plant waste reduction and control. He pointed out that FCB's were a major one of numerous concerns where we were actively planning recycling or otherwise reducing wastes. He did not discuss the type of waste treatment Sauget Village Is contemplating. Some remarks from Glenn Pratt and others about secondary biological treatment were Ignored. NEV 000717 716678 WATER PCB-SD0000072695 V -4- V (4) Bill Bngman described the FCB containment and ln-plant reduction program (full text la attached). At the close of his talk, he stated the present level of discharge aa follows: (a) From FCB manufacturing facilities - 2 to 4 lb s/d aj. (b) Prom the Tillage waste treatment plant, 5-10 lbs/day. (5) Dr. Buckley went through his rationale for the proposed Halts: (a) FCB In water Is toxic to flBh at very low levels - under 1 ppb for some species. (b) They know from experience that FCB levels magnify greatly from water to fish - he said 75000X. With that factor and a FDA allowable limit of 5 ppm, allowable FCB concentration in water would be: 5 ppm 75000 - 0.07 ppb (approx.) With using a safety factor (7), this brought the allowable water level to 0.01 ppb. Buckley stated his Intent that the 0.01 ppb level not be imposed as a legal standard but be used as a working limit. (c) As a check on the reasonableness of that level, he had calculated the effects of our discharge of 3#/day (their figure) on the Mississippi River at 10 year low flow of 50,000 cu ft/sec. NEV 000718 716679 WATER PCB-SD0000072696 VV -5- That also equals 0.01 ppb at the low flow (or about 1/3 of that at average flow of 175,000 ou ft/see which would allow an additional safety factor). (d) They (EPA) have no actual measurements of PCB levels In the Mississippi south of Lacrosse, Sis. and don't plan to do any water measuresent work. Buckley appeared disappointed that we have no actual background level measurements in the Miss issippi River. They will plan to do monitoring by fish concentration studies - If fish PCB con centrations are under 0.75 ppm, the ambient water Is likely to be under 0.01 ppb. (6) As to allowable discharge, Buckley said they were con sidering a policy of sero "knowing discharge" (a term new to us and meaning any discharge above the absolute back ground level). This would appear to allow continuation of our background discharge plus a minimum amount from production facilities. He said that, where we were presently down to 2-4 lbs/day from our production unit, we could probably do more work and get to 1-2 lbs/day and that (plus our background) would be our "zero knowing discharge". (Mote, In a later telephone conversation with Bill Papageorge, Buckley confirmed the above and said he planned to circulate a private memo within EPA explaining what "knowing" and "non-knowing" discharges meant and that our present discharge from production facilities of 2-4 lbs/day appeared reasonable 716680 NEV 000719 WATER PCB-SD0000072697 cc -6- (7) Scott Tucker questioned ability to measure at the 0.01 ppl level. Dr. Forciatl stated that their Athens, Oa. and Cincinnati, Ohio Analytical Labs are capable of easily detecting 0.01 ppb of PCB's in environmental samples, but they would not feel confident enough In their numbers to attempt enforcement at this low of a level. He went on to atate that, "they would be confident enough at the 0.1 ppb level to go to court." When presented with the results of our Internal round robin study (PC3 method accuracy and preolslon) at a level approximately 50 thousand times higher than the proposed 0.01 ppb number, he again stated their labs were achieving better results. He also Indicated that they were making quantitative PCB measurements via mass spectography at the nanogram level. (Notes from Scott Tucker - "Based upon our lab experience, I would say that Dr. Forciatl Is a little overly opti mistic with regard to the accuracy and precision of current PCB methodology. Dr. Forciatl extended an Invi tation to Monsanto to visit their facilities and It Is currently planned to contact him and arrange a visit. The objective of the visit will be to get a better feeling for their PCB analytical capabilities and to establish direct contacts with their analytical people"). (8) Paul Hodges raised the question of mixing corns. Dr. Buckley had stated that full flow In the river was used In calculating dilutions in the river because there was no aoute toxicity problem with fish around the outfall. NEV 000720 716681 WATER PCB-SD0000072698 VV -7- Hodges pointed out that, when the Federal report Is re leased, the states will move to cnaot PCB water quality standards and dlsoharge regulations. Some of then, specifically Illinois, use limited mixing cones to determine compliance with water quality standards (in Illinois the sample Is taken 600 feet downstream from the outfall). Hodges requested that the Federal report spell out the principle of using full dilution in the river. Buckley agreed. (9) As an aside after the meeting, Glenn Pratt (Surveillance, Chicago Regional EPA office) said that they were concerned about the levels of mercury being reported to Illinois since they were over 0.25#/day. He said he had written a letter saying they wanted to come to see us about mercury and about PCB's but had not sent the letter when the sub ject meeting was arranged. He would be contacting us In 2-3 weeks. Art Lelsy had, earlier in the meeting, in vited Pratt to inspect our PCB production unit and con trol facilities. P. Summary and Conclusions (1) He feel that Dr. Buckley is taking a reasonably realistic approach to eontrol with his ''knowing* and "non-knowing" discharge concept. However, we are dubious thati (a) It will hold up as the document is reviewed within higher levels and other branohes of SPA. (b) The Illinois Pollution Control Board will be as understanding as is Buckley when they move to formulate water quality standards and dlsoh*w* 716682 NEV 000721 WATER PCB-SD0000072699 i -8- 1 regulations for PCB's. We would expeot the Board to wove shortly after publication of the Federal Task Force document and announoenent of standards and regulations by the Federal BPA. (2) The 0.01 pj* water quality limitation is likely to hold up even though measurements at this level are not accurate and the Federal people have very limited data on FOB concentrations in rivers and lakes. It is also likely to become or to be used as a legal standard. (3) Apparently, Buckley moved quickly in his calculations establishing the 0.01 ppb limitation from the FDA level of 5 ppm in edible portions of fish to magnification of 75000X from water to lipid portions of fish (see C-5 above). This provides an additional safety factor to the 7X in his calculations. This was not really challenged at the meeting. <*) We don't know whether or not 0.01 ppb is exceeded either above or below our outfall in the Mississippi River. We have analyzed two large adult Mississippi River carp for FCB's. They contained apparent FOB concentrations of 1.4 ppm and $.1 calculated on the whole fish basis. Using Dr. Buckley's concentration factor of 75*000 indicates that the river could contain 0.02 - 0.07 ppb at the point where these fish were collected (this assumes that the 75,000 factor could apply to whole fish - we are uncertain about this). Further fishAater rmito**** is needed. 716683 Faul B. Hodges /ms NEV 000722 WATER PCB-SD0000072700 MONSANTO'S PCB PROGRAM W. B. PAPAGEORGE Presented at ANSI Committee C-107 Meeting - September 14, 1971 I appreciate the opportunity to share Monsanto's PC? experience with you and I hope the information I have can help"this committee plan and achieve its objectives. We at Monsanto first heard of PCB's as potential environmental contaminants in early- 19&7 when we received copies qf a talk given`in Sweden by Professors Widmark and Jensen of the University of Stockholm. In their paper they described how they were able to identify a material which had been interfering with pesticide analyses as being polychlorinated biphenyls. ,, Our laboratories began work on the development of analytical methodology to confirm that PCB's indeed were being found in the environment. During 1968 and 1969 as methodology improved the evidence continued to indicate that the higher chlorinated biphenyls were being identified in the tissues of fish and birds. During this period Monsanto mounted an extensive program aimed at acquiring more knowledge about PCB's and their effect.on the environment. We perfected our analytical methods, we Btarted' X animal toxicity studies, began biodegradation work and evaluated alternative materials for those applications we felt were con tributing substantially to contamination. N* 0*44 73 734528 WATER PCB-SD0000072701 -2- Our animal toxicity work was similar to the type we would have undertaken if we had wished to have PDA approval for food use. Chronic toxicity and reproduction studies were made on leghorn chickens. Two year chronic feeding studies were started on rats and dogs. Three generation reproduction studies were made on rats. .* The PCB's used in the tests were Monsanto`s Aroclor 1242, Aroclor 1254 and Aroclor 1260. These were selected since they represented the more commonly used PCB mixtures. The animals were fed con centrations of 1 ppm, 10 ppm and 100 ppm in.their normal diets, r* The results to date indicate that at the levels used the rats *` and dogs showed no effects with Aroclor* 1242. At 100 ppm both {_ the rate and dogs exhibited decreased weight gains and enlarged ' livers. The chickens were affected by Aroclor 1242 at the 10 ppm level. The hatchability of the eggs was significantly reduced. ' To summarize what I've said about Monsanto's sponsored animal toxicity work the.highly chlorinated polychlorinated biphenyls at 100 ppm in the animal diet doere have some effect on mammals. The lower chlorinated polychlorinated biphenyls at 10 ppm in the diet ha* some effect on leghorn chickens, and I say specifically leghorn chickens because there is mounting evidence that there X are definite species variations as determined by the Pautuxet Laboratories here in Maryland with four types of wild birds. There is a species variation noted which frustrates many scientists ` NEV Q2447<* 734529 WATER PCB-SD0000072702 I . -3- I was asked what we know about the effect on marine life. Monsanto did sponsor static fish toxicity work and we were completely frustrated because these PCB's have the tendency to plate out on surfaces. Our information was garbled because in the static testing we were really exposing the fish to PCB environments a lot less than we thought we were. The data was so distorted it was meaningless. In the meantime, we round that there are many competent laboratories looking at fish and the effects on fish that we decided that maybe this is an area that 1b best left to the experts. . - . ; . * We have been in touch with laboratories such as the. Water Quality Laboratory of Duluth, Minnesota. They have conducted studies which indicate there is some effect on some species. There has been some work done in the Columbia, Missouri Bureau of Interior Fish-Pesticide Laboratory which indicates, for example, magnifi cation about 50,000 times. By that I mean that the amount of PCB detected in the fish tissues was 50,000 times that present in the water environment in which this fish was exposed. There have been reports of fish kills and some very drastic effects attributed to PCB's. Irve tried to get evidence that these .things have occurred. I have not been.able to confirm any reported incident. ' ' We have talked with scientists at the Gulf-Breeze, Florida Commercial Fisheries Laboratory. They have conducted studies NfcV 02^75 734530 WATER PCB-SD0000072703 -u - with crab and shrimp. This is the laboratory that did detect a build-up in crab and also the lethal effect on Juvenile shrimp. Very, very low concentrations - 5 PPb in the water - do destroy Juvenile shrimp. - There is a growing thought among many of the.responsible scientists that this environmental problem is most complex and it is not really any one insult that is the demise or any particular species, but it could be the cumulative effect of all insults a creature is exposed to and usually the last Insult is the one that gets ^ blamed.. Dr. Tom Duke of Gulf-Breeze is a proponent of this theory and he is conducting studies to substantiate, this. It could *be the lack or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a cadmium or a mercury or an arsenic, and along comes a PCB and the fish dies. PCB might get blamed. This is the kind of thing that does happen in the environment. There is a growing concern that we should be considering to a greater degree chronic effects of all these materials rather than relying on the old acute studies that used to serve as a screening*' for many, many chemicals. I have sketchy data on marine life. We know that it does build up in the marine environment and ' there is, of course, the published evidence that it does affect the fish eating birds. NEV 024476 734531 WATER PCB-SD0000072704 -5- There is some indication in the Duluth studies that reproduction and survival of the frye is affected. There seems to be minimal affect on adult fish. It was suggested earlier that I might want to review the manufac ture of FCB's, the many applications in which it was used and what our present program is. To the best of my information, it was 1929 that these materials were introduced as very attractive fluids for use in transformers, and there are many in this audience that are more familiar with this development that I am. PCB's *\ were UBed in transformers as an insulating cooling .fluid because they are more resistant to breakdown, less apt to explode and burst*into flames and cause property damage and human injury. Through the years, additional uses were found for these materials because of these properties that I mentioned earlier. They gradually at first, and of course with increasing amounts, ended up in applications that Monsanto through its in-house usage referred to as plasticizer usages. That is not a very good description, but .it fit our needs for many years, and you'll find us using that expression. These are uses Buch as in paint formu lations, the specialty ink uses, the plasticizer in sealants, *' adhesives, and paper coatings of all sorts. ' There waB a use that was a real thorn in our side and you'll see at least some of the earlier articles on PCB.'s referring to pesticide use. There were some studies conducted by the Department of Agriculture in which PCB's were used to extend the effect of NEV 0Z4477 734532 WATER PCB-SD0000072705 -6 - life of pesticides such as lindane. It was never intended for broadcasting as we visualize DDT was on food crops, cotton crops, or orchards. The only widespread use that I could find was a m limited trial to help prevent or curtail the dutch elm disease, and that proved to be a failure. The other uses were extremely small in private formulations that were used to spray or coat hard surfaces - shelving, comers of floors and all for the typical crawling type insects such as the roach and silverfish. In fact it was so small that.Monsanto did not market directly \ to pesticide formulators; we gave this business to our dlstrl* butors. On the other hand, this use did cause considerable emotion and was used by some to explain the presence of PCB's *, in remote'areas. We wrote to the Department of Agriculture suggesting that during 1970 when pesticides were being re registered that PCB's not be approved. .Finally in October they did put out a notice to that effect. We have had questions raised, "Is it in my shower curtains at home?' Is it in the draperies? In the Carpeting?" The answers to those is "not very likely". And I use those words because we really don*t know. If It was put into these applications, it was so small we, Monsanto, were not aware of It. It was not used in automobile tires; it was not used in brake linings. F/ Other major uses include the use in hydraulic fluids which are fire resistant. Monsanto marketed these fluids under its trademark Pydraul. I am sure some of you remember the Livonia, 734533 WATER PCB-SD0000072706 I Michigan Tire? This was a disastrous fire in terms of property damage and was really a high mark in terms of convincing Industry that there was a need for fire resistant hydraulic fluids. But the application is not the type that is maintained to a degree where everything is leakproof. Many of these connections leak, hoses burst, and the tendency 1b to keep producing by adding more fluid. So it is conceivable that many of these hydraulic fluids ended up in the sewer. I do not intend to criticize the customers of our products. From the knowledge that we had at. that time of the material the practice was considered acceptable, ^ , ,* ^T Another fairly widespread application of PCB's is the use of these ifluids as a heat transfer media to achieve high temperatures, have a fire resistant transfer fluid, and avoid the installation of high pressure equipment. These materials were ideally suited for this application. We thought at one time that these were adaptable to close control and proper maintenance where we could logically call them closed systems. Some recent evidence indi cated 'that we were wrong and I'll get into that when I discuss * our present applications. * One. application that was a fairly significant one and one that in our thinking is associated with coatings is the use in car bonless reproduction paper.Vlth the emphasis on recycling paper.^ wastes and with the persistance of PCB's there is a problem developing in that PCB's are being found in many paper products and many of these paper products end up in food packaging. NEV 024479 . 734534 WATER PCB-SD0000072707 -8- Initially the evidence we were getting seemed to point to the higher chlorinated materials as environmental pollutants. As soon as we were aware of this, we. sent a letter to all of our customers telling them that what little we knew indicated that these materials could be an environmental problem, and care should be exercised in handling. When the results came in on our chicken toxicity studies they indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that we better place some restrictions *x on these materials because there were to us some uses that '^ deserved to be kept in spite of the problems that we saw facing us. 1 * * We decided that we've got to get out of those applications where we felt there was no earthly chance or it was beyond our ability to control the introduction into the environment, so we got out of all the so-called plasticizer applications, August 30, 1970 was the targeted effective date. . We then went into-a very active program of reformulating the hydraulic fluids. There! again, it required a lot of testing. We had to run these new materials through the Underwriters Laboratories for approval on fire resistance. They had to be compatible with the machinery then in use. This is not easily X done, but it was done. ' We decided that we could and must continue to supply the trans former manufacturer, the capacitor manufacturer, and at that NfcV 0244S0 734535 WATER PCB-SD0000072708 -9- time closed heat transfer systems based primarily on our concept that fire resistance was important in heat transfer. To pick up the point that was raised earlier about foreign im ports, we are to the best of our ability trying to monitor imports. To this day, we have no information that any.have arrived in this country. On the other hand, we are getting some reports that some of our former customers have made inquiries of the foreign producers. I am also told by some Canadian provincial agency people that they had heard and were going to,further investigate that PCB's were entering Canada.and from there .r moved.into the United States. I have talked to representatives of the Japanese producer, the Kanegafuchi Company, and I am led to believe that they are most reluctant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering the U.S. market. I have talked to representatives of the French companies. They assure me that they don't want any part of this business. . ,, In May, 1970 Congressman William Fitz Ryan Introduced a proposed bill which would in essence place into law the very things that Monsanto had proposed doing on a voluntary basis. The bill provided that PCB's be banned except for those situations where the Secretary of HEW would give special permission or license. ^ We went through the latter part of '70 and early part of this year feeling, however, that we were still walking on thin ice. nev 734536 WATER PCB-SD0000072709 10 - But we thought that we had made some tremendous strides In the right direction to preserve those uses which we thought were essential while eliminating those uses which were grossly con taminating the environment. This summer our hopes of control in the heat transfer business vanished when we found that a user of PCB did not appreciate the problem, did not maintain his equipment and created the recent chicken, egg, fishmeal problem. Because of this incident. Congressman Ryan withdrew the first bill that was submitted and has now placed before the same com mittee a bill which totally bans PCB and does not provide for any use whatever. And there are, of course, penalties for the marketing, manufacture, or use of PCB in this country. A very drastic measure which does cause or can cause a lot of concern among.those of us who feel that PCB has a place in our society under proper conditions. As a result of this incident, we were forced to re-evaluate our position. We decided that,although heat transfer systems could be closed units, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the. situation where even a pinhole leak can create tremendous pro blems before it can be discovered. So we have taken, again, ' an arbitrary position and informed all of our customers in the food (whether it's animal or human food)j packaging business, and the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. . NEV 0444d4* * 734537 WATER PCB-SD0000072710 11 In addition, we will no longer market to any new heat transfer applications. Our efforts will be concentrated on reducing those that we market today. This business should decrease as time goes on. ' To get back to legislation ... as many of you probably know, there is before Senator Phillip Hart's committee a bill referred to as the Toxic Substances Act of 1971. The purpose of this bill is to prevent the Introduction into our society of hazardous materials. It also provides'for the review of materials now in our society and the curtailment of the use of the more hazardous ones.. Initial hearings were held in August, to which a select few individuals were invited to testify. PCB was brought out as an example of a material introduced into society and thought at one time to be -most valuable, but is now considered a serious threat to all of us. The meetings will be resumed in October; I do not know the exact date as yet, and I'm led to believe that this would be the opportunity for industry to speak up in its behalf. .1 am assuming that since PCB's were brought up as an example of the type of substance this bill is supposed to prevent that Monsanto as sole producer in this country will be either invited or we may choose to ask to be invited (we don't know at this point Just / what is the proper approach here) to speak on the merits of retaining PCB's in transformers, capacitors and fire resistant heat transfer systems, non-food applications. NEV 734538 WATER PCB-SD0000072711 12 I mention this bill because it is our opinion, and we could be wrong, that rather than act on Congressman Ryan's bill, which is specific toward PCB's, we suspect that the Toxic Substances Act will have in it provisions which will refer to such materials as PCB's. We feel we have good technical data to Justify our staying in the business for limited applications. But we cannot overlook the emotions that have set in. And believe me there are many and they are deep. It is difficult to combat emotions, as you know, and the references in the popular press to hazardous #* poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we talk about per sistant versions of PCB and degradable versions of PCB I sus pect, and this is -a personal opinion, that there would be many who Just discount* this kind of information. This is a very real problem; in my opinion it is a difficult problem. As a little more background let me describe what I understood from a meeting we. held last week with representatives of the Food and Drug Administration. It is my personal opinion that the Food and Drug people are as conscientious as can be in trying to cope with the PCB problem. They are objective people trying to work with a minimum of data. I suspect they are as frustrated as any group of people can be as to what is the right way to go. There are tremendous pressures on the Food and Drug people today as well as the Department of Agriculture brought about by critics. NEV 734539 WATER PCB-SD0000072712 - 13 - .Theae agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. . The FDA people really don't at this point in time have much infor mation that will lead them to a regulation as to how much PCB should be tolerated in food. They have established some guide lines based on what little information they have from their own laboratories and the information that Monsanto has shared . with them. The FDA will permit fish at 5 ppm on tha market- place;* milk at .2 ppm or less; eggs .5 ppm; pountry (they have a double standard) 5 ppm in the fatty tissue and 5 ppm in the muscld tissue. Another problem that is disturbing to the FDA, is the recycle paper problem. The cereal boxes, the cracker boxes, all of these boxes that are made from what is known as chipboard, are made from recycle paper. Fairly high levels of PCB's are being.found in this recycle board. It probably comes from about three or four different sources. It may come from some ink application in the past, some adhesive application, some coating application, as well as the carbonless reproduction paper appll- *' cation. There have been some pilot studies made by the American Paper Institute to isolate the carbonless reproduction paper' X from the recycle batch. They still found PCB's in that batch. They are probably looking at maybe the second or third genera tion of recycle. And with the emphasis on recycle, I cannot see any way out of this dilema except that there will be more and more PCB's in these cartons. NEV 024485 734540 WATER PCB-SD0000072713 - 14 A thought we must all keep In mind, too, is that we've got to live with the PCB's we introduced into the environment for the past 40 years. They have not disappeared overnight; they will not disappear overnight". We do not have any tests that tell us how long it will take. We can only made an educated guess and we might say they will be out there for another .'generation, 25 to 30 years yet. Hopefully, it will be a decreasing amount as time goes on. Monsanto has conducted.biodegradation tests on its products. We have three programs that are now active. One program we are conducting in our laboratories in Ruabon, Wales in- which we are making what I would refer to as scientifically basic studies in terms of which isomers are most degradable and with what type of microbe. -This is a little bit on the impractical side at this point in time. We have as a consultant. Professor Charles Evans of Bangor University in South Wales, who is a noted authority worldwide in this kind of activity. He has isolated at least three microbes.that seem to thrive on polychlorinated biphenyls. These microbes he developed from soil that he obtained from his garden. What this tells us is that there are microbes out there in the environment that will eventually destroy these materials. In the St. Louis area, we have two types of tests going. One x is the use of river water with its normal biota in it, in which we introduced theee polychlorinated biphenyls and look for the disappearance rate. It is a very quick and rather unsophisticated type of study. The other type of test 1b the one that simulates new 0244flt> 734541 WATER PCB-SD0000072714 - 15 - those conditions which are apt to be found in a normal municipal sewage treatment plant. It's an aerobic test using an activated sludge from a St. LouIb waste treatment plant. As a standard, we use a soft detergent'because it .Is well known to other laboratories. What we are doing, really is using our expertize that we. established * back in the days when the hard versus soft detergent controversy was quite common. And we are using these soft detergents that do degrade as our controls and comparing the PCB's to these con trols. The studies so far show that there are isomers within each of these mixtures-that do degrade. The lower the chlorine level/ the faster they disappear, the higher the chlorine level the more resistant they are. Which only confirms vihat many of 1. us had suspected. We were not too surprised by this data. . t I will attempt to summarize ... I think we can conclude that PCB's.are in the environment. There is no question about it. Many of these PCB's are manmade and were introduced to the environ ment because of our lack of understanding of what these materials can d6 to the environment. In this country Monsanto, as sole *. producer, has attempted to Improve the situation by limiting the applications to which these materials are used. Studies today would indicate that these PCB's are not. and cannot be ti classified as highly toxic. There is still a lot of information that is needed to help us determine the long term effect on human beings. We feel that the properties of these materials make them, at least as of today, the most suitable material for use in trans formers, capacitors and heat transfer systems. We also believe that under proper conditions we can control the amount of these 734542 NEV 044407 WATER PCB-SD0000072715 wS 44 ;; - 16 - * that do enter the environment to the point where the adverse , effects are not great and that the benefits we derive far out- i' : weigh the minor adverse effects that we might notice. Now there I 5 are many of us in the transformer and capacitor application that have made tremendous strides In controling these materials. # *' j. I suspect our objective Is to further improve our ability to ' control this material. In my personal opinion the emotion r that is now prevailing regarding PCB's is something that we must contend with. Whether we believe in it or not, there ` are many people that Sincerely believe PCB's should:be totally : banned. * f ' 734543 WATER PCB-SD0000072716 PCB YEARLY SALES TOTALS WESTINGHOUSE - ALL LOCATIONS ALL PCB PRODUCTS 1954 - 1977 1954 4,631,644 lbs 1955 4,346,780 lbs 1956 7,083,144 lbs 1957 8,367,139 lbs 1958 4,562,464 lbs 1959 5,648,271 lbs AS6-G- -'ri 8,294,977 lbs 1961 6,591,368 lbs 1962 5,843,134 lbs 1963 7,517,688 lbs PLAINTIFF'S EXHIBIT (S*> f'n<\r>,| iron AOM CCb97l 256 WATER PCB-SD0000072717 1964 7,492,896 lbs 1965 9,271,259 lbs 1966 8,027,542 lbs 1967 10,856,219 lbs 1968 10,316,063 lbs 1969 8,038,072 lbs 1970 9,071,230 lbs 1971 6,851,689 lbs 1972 --i. s* -gy 7,4r0V^0'4' 1973 7,951,141 lbs 1974 9,080,243 lbs 1975 7,754,663 lbs 1976 5,456,521 lbs 2 r,-_, - - ^,,.. >-- . AC* C08973 cmmm 257 WATER PCB-SD0000072718 1977 693,993 lbs 3 Total All Years: 170,539,344 lbs --a "-* >. y.A A* CCfi97^ 258 C0Wte31 WATER PCB-SD0000072719 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS' STATE OF MISSOURI GLENN 3ROWN, et al. Plaintiffs, vs. MONSANTO COMPANY, Defendant. ) ) ) ) ) Cause No. 862-00694 ) ) ) ) . AFFIDAVIT IN SUPPORT OF MOTION TO SEVER ` THOMAS M. BISTLINE, being first duly sworn, on his oath states: 1. I'am Litigation Counsel for Monsanto Company. I make this Affidavit in support of Monsanto Company's Motion to Sever. 2. The information set forth in this Affidavit was compiled at my direction from historical sales summaries of Monsanto Company which were prepared annually in the ordinary 6ourse>o4S44oi*santo^<3inpaY-:^:busaihs^-~--~The* jna4r-trs--s et r.forth^----- .r herein are true to the best of my knowledge, information, and belief. . 3. Monsanto Company sold the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Bloomington, Indiana: 1957-1967 Aroclor Aroclor Aroclor ' 1242 .. 1286 (Less than 6,000 lb./yr.) 1254 (Less than 100 lb./yr.) . rowspv . 259 C ' " *. mu* WATER PCB-SD0000072720 1968-1970 Aroclor 1242 Aroclor 1232 (Less than 1,500 lb./yr.) Aroclor 1254 (Less than 200 lb./yr.) Transformer Inerteen PPO (Less than 1,000 lb./yr.) 1971-1977 Aroclor 1242 Aroclor 1016 Inerteen 54201 CF Inerteen 54201 A9 Inerteen 54201 KJ Capacitor 21 Capacitor Aroclor 1489 (Less than 100 lb.) 4. Monsanto Company sold.the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Muncie, Indiana: _ 1964-1970 Therminol FP.-2 1971 Therminol FR-1 1972-1977 -S'*-"'3 V-VT-..S5-.sa les. _-3 ,*.v - r w*s-21 5. Monsanto Company sold the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Cincinnati, Ohio: 1959-1968 Transformer Inerteen PPO 1969-1972 Transformer Inerteen PPO Transformer Inerteen 100-42 (Less than 1,000 lb./yr-) cnon&.ri3 260 WATER PCB-SD0000072721 1973-1976 Inerteen 70-30 COUNTY OF ST. LOUIS ) ) STATE OF MISSOURI ) ss. Subscribed and sworn to before me, a Notary Public, this day of March, 1987. /38 dJlvJh Nota SHiHLSt j. s-mO.y.-'Y'g NOTARY PU2UC. STATE Or Ml.il'URI MY COMMISSION EXPIRES 7/24,7. ST. LOU'S COUNTY ra. 'ki HUSCH, EPPENBERGER, DONOHUE, CORNFELD & JENKINS . y Charles E. Merrill - *27238 100 North Broadway-14th Floor St. Louis, MO 63102 (314) 421-4800 . Attorneys for Defendant Monsanto Company 261 WATER PCB-SD0000072722  ... to help you be sure your Askarel liquid insulation is tip-top and to keep it in the best of operating health 663^0. ; i WATER_PCB-SD0000072723 WATER PCB-SD0000072724 OILS -- that can burn There are quite a number of these. They are sold by oil companies; and these mineral oils are used in transformers where, if they catch fire, no great harm 'besides the transformer itself' comes from the burning oil. If water gets into an oil-niled transformer, it tends to settle through the oil to the bottom. There are certain ways to check on the health of mineral oil insulation, too, but the "Check points" are somewhat different than for askarel. AS KARELS -- that cannot burn Although there are TWO types of askarel fluids supplied under a number of brand names), actually they all have just one and the same ba&c ingredient: Monsanto's Aroclor* 1260. If you want to know, Aroclor 1260 is hexachlorobiphenyli. And THIS is one of the world's best liquid insulations! ' AOM COC9%2 WATER PCB-SD0000072725 don't worry about "different kinds" So, what are the two types? What's the difference? Simpiv this: they have different pour points and -- the tiny amount of `scavenger" chemical added to each is different. The Pyranol 1470 General. Electric' type has the lower pour point: it will still pour at 47' below F.i zero. The Inerteen PPO Westmghouse type will pour down to 26e below . F. zero. These two types eacn contain a tiny amount of a different additive: both additives are good ar.d do their job. Hbwever. the additive in Pyranol type askarei can crystallize out a bit at 14s above 'F.i zero. It does no harm: the crystals disappear after a while when the transformer warms up. Other brand names, like Chlorextol Allis Chalmers': Noflamol Wagner Electric ; Asbestol Amertran Corp. : Saf-T-Kunl Kuhlman Electric - are either one type or the other. Some manu facturers simply call their fluid by the common descriptive name: askarei. But, transformer manufacturers who supply askarei fluids have sound reasons for favoring their own type. So, it's nest to stay with your particular brand. However, since basically askarei is askarei, there will be no difference in the operation of your transformer if IN EMERGENCY you would interchange or even mix the two types! But askarei is NOT oil -- cannot, should not. must not be mixed with ordinary transformer oil. For one reason: the inside core materials used with mineral oil filled units get gooey with askarei. For another reason -- over of mineral oil mixed into askarei "clobbers" its fire resistance. For another reason -- never mind! Don't mix or interchange askarei and oil. "Askarei" liquid insulation is a very carefully-manufactured, highly pure, chemically made fluid. It does not vary in composition uke the range of oils. AND . . . askarei is heavier than water. If water gets into askarei insulation, only a smidgeon 125 ppm dissolves -- the rest floats on top. Askarei is one of the most flre-resistaht, chemically-inert, hat-stable liquids erer dereioped! You can be sure of this: askarei does not deteriorate when exposed to air, heat, hot metal: it does not break down over long use to form conducting or corrosive chemicals: it does not sludge or oxidize. Askarei will remain perfectly stable year after year after year unless broken down by exposure to severe arcing -- the kind that could set an oil transformer afire. The onlV real "enemy" of askarei is: contamination by water. WATER PCB-SD0000072726 NOW LETS TALK *year to year operation! One of the most brain-y electrical engineers in the business once said: "The best `maintenance' for askarel transformers is KEEP 'EM DRY, and leave them alone!" This business of "keep 'em dry," however, whether your trans former is EITHER an oil-type or an askarel type, is the watchword! It takes some care. In fact, anything MECHANICALLY you can do to stop moist air breathing and condensation will be the best health insurance for your liquid filled transformer. Here are some of the questions that come up when you want to "keep 'em dry." Is your transformer a welded shell or a gasket top? (even the tightest gaskets can "breathe!") Does your transformer run, stop: run. stop: run. stop? (This hot-to-cold temperature cycling makes the breathing faster and harder!) Is air around it mostly cold and dry or hot and moist? (Wouldn't it be great for automobiles and transformers if there wasn't any such thing as condensation!) When you have "breathing" and high humidity -- you can cut back on check-ups if you fit the transformer with a drying device (all transformer makers offer these) or you can bleed dry nitrogen into the shell. Any mechanical steps you take to stop inside con densation will be double insurance on trouble-free operation. Of course, if you are ordering a brand new transformer -- either ofl or askarel type -- you can "design* out" most of the moistureentry points. Basically, you call for all-welded construction, in cluding fins, pipes, and instrument connections AND a recessed gasket for the hand holes. (If you or your electrical equipment supplier would like more complete details on tips to keep innards dry, we can send you a copy of: "Design Details For Moisture Protection of Liquid In itiation Transformers.") $ So -- you'll be happy to learn that preventing moisture contamina tion is the only major health insurance you need provide for your askarel insulation. ACP CCC WATER PCB-SD0000072727 CHECKING THE CHECKPOINTS Now you are well on your way to beinf an "expert." Since you know that keeping tabs on MOISTURE is the major checkpoint on your askarel transformer, let's ask: How do you keep tabs on moisture? . You do this by a periodic test of the askarel's dielectric strength. Do not bother to check -- or if you do -- do not be misled or dis turbed by relatively high power factor... or even a drop in volume resistivity. (If you want to know why, you can read the fine print on the following page.) ' The DIELECTRIC STRENGTH of the askarel is your major clue to the "health" (i.e. dryness) of your askarel transformer. Besides taking a good look at a sample of your askarel -- dielectric strength is the only "test" you need actually run! Here's why: the dielectric strength of askarel is sensitive to moisture; not sensitive to other ordinary contaminants (like metal dust, salts, dirt, etc.). The dielectric strength is also hurt by severe arcing, but you'll know that arcing is the culprit if the askarel has gotten noticeably black or has particles of sooty carbon floating in it. Unless you've had severe arcing (lightning, accidental overload, back surge, etc.), the dielectric strength is your "moisture indicator." New askarel has a minimum dielectric strength of 35 KV at 25*C.; a maximum moisture content of 30 ppm. If you check the dielectric strength periodically, find that it is rapidly decreasing -- this is your "clue" to moisture pick-up, arcing, or both. When the moisture content rises to 100-120 ppm (or oven -- the dielectric strength will drop to 20 KV or less. That's your due! INSPECT POP WATER CONDENSATION IN THE SHELL, AND "REFINE" THE ASKAREL. As the operator, you will have to judge hone often you want to check up on your askarel insulation. Steadily running, well-sealed askarel transformers have run as long as 25 years on the initial charge of askarel -- and the dielectric strength still checked out at above 30 KV. HOWEVER, if the dielectric strength drifts down ward to 25-20 KV at 25C. -- then it is time to "clean-up" the liquid insulation and to get rid of any water accumulation in the shell, too. . This askarel clean up is relatively simple; the askarel need NOT be discarded. BUT MOST IMPORTANT . . . if the dielectric strength drops rapidly over a short period of time, this shows rapid pick-up of water (or arcing). . When you take your sample for check-up -- k sure to take it carefully (so it represents the surface) and handle the sample properly (so It doesn't pick up moisture in the sampling). ACM C C C 9 5 WATER_PCB-SD0000072728 6: j P k I ccc**4*0 \ WATER PCB-SD0000072729 o checktest your a; You'll be able to "take the pulse" of your askarel insulation with the following five simple rapid tests. Three are simply "mspectionby-eye!"' You can do these check-ups yourseif or have the tests run by a local transformer service shop. COLOR by inspection' -- N'ew askarel is a clear, faintyellow liquid. After long-term use. the color will gradually 1 intensify to brown. Any color change, such as taking on a green, red or blue cast, indicates extraction. If you find a distinct change in cnU,r, the complete range of electrical characteristics should be checked to learn if the extracted color is the tell-tale for contamination. r 4_ l * CLARITY by inspection1 - S-w askarel is clear and should remain clear in service. Deve--pment of turbidity or cloudi 2 ness indicates contamination from water, insulation partides. metallic dust or dirt. Cloudiness or turbidity calls for a complete analysis. The exception to this would be cloudiness in a cold sample of PYRASOL 11.70. This type askarel contains a scavenger additive which will "come out" of solution when cold around 15:F. and cause white turbidity and perhaps show salt-like deposits on the trans former shell. If this is noticed, heat the askarel sample to 150-2003F. for several hours and agitate. Upon heating, the Pyranol's additive will redissolve, as it wiil in a warm transformer. t BLACK COLOR AND SMALL CARBON PARTICLES by in spection -- If the color of the sample is black, and especially 3 if suspended carbon particles can be 3een, this snows that the askarel has arced and should be discarded. You can also detect exposure to strong arcing chemically, wit.n indicator paper. Simply dip a piece of moist blue litmus paper into the askarel. If the blue litmus turns red. there is excess acidity from arcing beyond the limit absorbed by the "scavenger" additive. AC* 0005*1 C 1 WATER PCB-SD0000072730 >a 4 DIELECTRIC STRENGTH by ASTM D901. D877- The aielectric strength is the most important; and it is a simple test to make. The dielectric strength of new asuarei :s 35 KV at 23:C. minimum. This value should not be allowed to fail below 25-20 KV. Contaminants wr..eh may nave pronounced effect on the power factor and volume re>:.-tivity 'isii&'ij -\o not fo-i't r Reduced dielectric strength almost always snows exposure to strong arcing or moisture contamination. 5 MOISTURE - The moisture content of new askarel is :3d parts per million maximum. The moisture >'itnr-:imn level is about 125 ppm at ordinary temperatures. When the moisture content approaches 125 ppm saturation lev*! , the dielectric strength goes down. The moisture content of askarei should not be allowed to rise over 70 ppm; it snouid be r.eid as near as possible to du ppm. NOTE: It your sample shows :J0-35 KV dielectric strengtn. >"U n**d n->t check for moisture. However, if y.-u do cr.eck moisture, use tr.e Karl Fisner Met nod. AsTM D-15.-J3. IF ANY OF THESE FIVE CHECK-UPS APPEAR ABNORMAL CON TACT YOUR TRANSFORMER MANUFACTURER FOR COMPLETE ANALYSIS. These simple tests will show you the or.dition of your .iak-r-1 insulation, but only md;rcci!'j the condition of your trar.sivrm-rr. They can be relied upon when the sample is carefully tak.-r. as not to "miss" water globules ffoating on the surface or a i.-.er.ru to the shell in the air space over the insulation . So. if you have : .iKen meer.anical precautions against moisture entry into your us^rr'i transformers and can "Keep 'em dry!" tr.ese tests wi.i he \vur assurance that, between cr.ecks, you can "F.cget 'em." The American institute of Electrical Engineers has OuCiisned a compre-e-S'-e and informative guide titled 'Proposed Guide for Maintenance at Transform' Askarel." AIEE No. '6 Decemoer 1953 Tn.s guide descnaes properves to =e inspected ana me ASTM metnod to oe used. Monsanto camoieteiy analyzes each production lot of transformer asva'ei c/ these methods prior to shipment. However, tnese orf'Ciai tests are NOT ES SENTIAL to the user Of asarei transformers. When a complete analyse s re quired in a special case, me user snouid request it `rom me transformer mj*er wno in turn can can on Monsanto if neeoed. ` V\ DK CCC4-6 3*-- IK#r'( WATER PCB-SD0000072731 GROOMING ASKAREL FOR RE-USE If strong arcing has blackened aakarel, throw it away: it coats less to replace arceo insulation than to reclaim it. If there's been no arcing, but a low dielectric teat shows moisture contamination, you'll find it is quite easy to refine the askarel back to good operating dielectric strength. Simply run the insulation through a dry, ab sorbent filter. ` Most operators prefer a portable refining apparatus, such as a plate press, fitted with a dolly, available from Sparkler, Mundelein, 111.); or the earthen cartridge filter type, < available from Industrial Filter Corp., Lebanon. Ind.i. Filter paper liners for the plate press are available from Carl Schleicher & Schuell Co., Keane, N'.H. Any flexible hoses and gaskets on the refining equipment should be lined with or made of materials that will not be softened by contact with askarel fluid. vSilicone or Teflon materials are suitable:. If you use a filter press, before refining it is advisable to oven dry the filter paper at 1008C. for a half hour to remove all moisture. If the askarel to be refined contains excessive moisture, circulate it hot (55-60C.i through the filter fitted with the paper liners only first. Then, rent press with dry paper and load it with the absorbent earth. The earth refining process is simple: 1. SPREAD DRY EARTH EVENLY OVER THE . EILTE9 SURFACE. Fme-mesh Attapulgus clay or Fullers earth, dried and activated by heating for 12 hours at 250aC. immediately prior to use. is highly efficient. The amount of earth used should be 0.1 to 0.2 per cent by weignt of the asKarel (asxarel weighs about 13 pounds per gallon). To deposit the earth evenly, stir one-third of the earth with a small portion of askarel in a clean container. ?jmp the mixture through the filter and follow with two more one-third portions. 2. PUMP THE HEATED ASKAREL FROM TRANSFORMER THROUGH FILTER. Circulate askarel taken from near the top of the transformer, oass it hot (55-60JC.) through the filter and feed back through the oottom transformer outlet. 3. CONTINUE CIRCULATING THROUGH THE FILTER UNTIL ASKAREL IS CLEAR. When the askarel is clear use the simple tests described earlier to check for restored dielectric strength. 4. CHECK THE TRANSFORMER AFTER REFINING. After refining the askarel, the overall power factor and insulation resistance should closely approximate the values it would snow with new askarel fluid. If the overall power factor is more than 30-35 per cent iat 20C. and 60 cycles) it is considered POOR and it is advisable to run a complete analysis of the entire insulation system. o t-------- v\ ADM 0G C 949 WATER PCB-SD0000072732 ! CMJ * POWER FACTOR & VOLUME RESISTIVITY High power factor and low volume resistivity in transformer mineral oils are commonly regarded as "danger sigr.ais" t-at the oil has deteriorated and broken down chemically. This is NOT true of askarel liquid insulation. New, unused askarel shows these electrical values: Power Factor: 0.05-0.2% <5 80 cycles 20aC. about 1-2.0% <n 80 cycles 100C. Volume Resistivity: 100-1000 x 10 ohm-cm : lO'j-'C.. 500V., DC.. 0.1" gap Used askarel from SATISFACTORILY OPERATING TRANS FORMERS normally and frequently snows Power Factor: 20 to 30% y 60 cycles 100'C. Volume Resistivity: about 25 x 10 ohm-cm 100*0.. 30" V.. DC.. 0.1" gap This relatively high power factor and relatively low volume re sistivity of used askarel ARE TO BE EXPECTED. Even at these levels, the askarel's dielectric strength is STILL in tne 30-05 KV range. The reason is simple: askarel. unlike "oil." is a relatively polar liquid. The volume resistivity is sensitive to traces of conductive contaminants. However, even in the presence of large amounts f contaminants, the volume resistivity does not seem to fali neiow 10 x 10 ohm-cm'. Yet the dielectric strength remains h:gn. oecause intrinsically askarel remains a r.on-conductor. To quote from Insulation Magazine, December 1961 DIELECTRIC LOSS YARDSTICKS by John C. Botts. Manager Insulation Development Section, and Graham Lee Moses, Manager Services Engineering, Wesr.nghouse Electric Corp.. East Pittsburgh, Pa. "Dielectric loss is a good comparative evaluation for some characteristics of insulation. It may be usea for comparing similar samples of the same material. It may not be used as an overall evaluation for com paring different materials." .i.e. "oiis" and aska.-eis Power factor is not an important criteria of askarel .r.su.atior. efficiency IN A PROPERLY CONSTRUCTED TRANSFORMER. However -- if improper construction materials or unpredictable foreign contaminants enter the system -- high power factor in the absence of moisture in the shell can indicate improper construction. V ACM uu095C t A tL. ( i WATER PCB-SD0000072733 sampling your aS NOW . . . since you know that the DIELECTRIC STRENGTH is the most important checkpoint, and that .except for arcing MOISTURE is the villain that saps dielectric strength you want to make sure that your SAMPLE truly represents your askarel insulation. ' TAKE YOUR SAMPLE AS CLOSE TO THE TOP OF THE LIQUID SURFACE AS POSSIBLE! Many large askarel transformers have a built-in sampling tube near the surface for convenient sam pling. If additional sampling tube connections are contrived on to valves for easier sampling, make tne tubes of clean glass, stainless steel, aluminum or tin for rigid types; and silicone or Terion tubing for riextbie types. Water .'foals on askarel. If there is any water in your transformer, it may collect in little puddles ON TOP of the askarel. AND, therefore, more water will probabiy be dissolved in tne askarel near the top, where it contacts any collected condensation. If you find low dielectric strength and high moisture in the as\arel. you will probably want to thoroughly dry out the shell and take some mechanical steps to keep it dry. When you take your askarel sample for testing, take tne same precautions but no more that you take when sampling mineral 1. Select a dry day. Do not samoie "suiation on a warm, moist day when humidity exceeds 75T. ana 2. Make sure that the askarel is at least as warm as the sur rounding air. (Cold liquids can condense moisture from humid air.) 3. NEW containers for fluid samoie Your sample container should tse a new and previously unused small mouth pint glass bottle f.tted with a 3a*e- :e screw cap fitted with an aluminum or tin pottle cao '."er Make sure that the new bottle does not stand arouna open to collect dust or moisture. Rmse the sample oottle a"d cao lining two or three times with askarel from the transformer; then fill it. When sample will be tested promptly, a clear glass bottle can be used. If sample >s to be stored indefin itely. use an amoer glass bottle or wrap clear glass wit" aluminum foil. Whenever a sample is to be shipped to the transformer manufacturer (or to Monsanto) for complete analysis. t"e contairer must be a 5-pint amoer glass bottle. For your convene'ce. various transformer manufacturers a~d Monsa~*c will send you the sample bottle filled with new askar^f. ;u simply empty out the new askarel and re-fill bottle w - /our sample. A&K CGw5l. I 6 l WATER PCB-SD0000072734 / / D'electnc St'e"gtrv 30-35 KV Mcistj'e Content 30-50 30m 4 Dielectric Strengtn: 25-20 KV or less Moisture Content: 125 DDm \ Au* CCC*** WATER PCB-SD0000072735 THAT'S THE STORY keep 'em dry... let 'em alone! But you might want these storage and handling "tips" to.make you a complete transformer askarel expert. STORE NEW ASKAREL IN A CLEAN DRY PLACE Keep the 5. 30. or 55 gallon drums dry; turn them over on their sides to keep water oil the drum head. It can be sucked in by the drum "breathing." i CLEAN UP SPILLAGE Askarel can. if left standing, attack paint, rubber, or plastics. Absorb it from floors with sawdust, sweep, and then wipe dry. Use a rag wet with mineral spirits if you want to make sure it s all cleaned away. TAKE ORDINARY PERSONAL CARE Transformer askarel has been made, handled and used for over 30 years without causing toxic or other ill effects. Askarel can be handled in the same manner as insulating mineral oil. As with mineral oil. there may be some peopie allergic to askarel. so pro longed skin contact should be avoided where possible. When accidentally spilled or splashed on the skin, askarel does not present an acute hazard nor will it cause serious skin irritation. Simply wash it off with soap and water. If work clothes become impregnated with askarel, they should be removed and washed. Eye contact may cause temporarily painful irritation but NO PERMANENT DAMAGE to the tissues or sight. Flush the eye with large amounts of water. A drop of castor oil may be put in the eye. As with all eye first-aid. refer to a physician who will treat the eye with an ointment. Ordinary*, infrequent exposure to askarel vapors will not cause any ill effects. However, prolonged exposure to strong vapors should be avoided. If hot fluid is to be handled in a closed or confined area, provide ordinary exhaust ventilation. Harmful concentrations of askarel vapors are easily detectable by the smarting of the nose or eyes. Should hot askarel 'above 100C.) have to be handled in the open in a confined,\unventilated area -- it is advisable to wear organic canister-type masks as supplied by Mine Safety 'rsburgh. Pa. 1 i9l *0* Co$ 9 WATER PCB-SD0000072736 (AS FAR AS tUUir'MCNi cmh oc/ best friend! Since "askarel" type transformers were first made in 1930, few pieces of electrical equipment have equalled these "juice controllers" in trouble-free service. The name "askarel" applies to the liquid insulation that fills askarel type transformers. And "askarel" is a general name for a unique kind of chemical classified as a halogenated hydrocarbon. But, don't let this chemical jargon bother you one bit. After you read this little pamphlet, you'll be an EXPERT on operating askarel transformers; you'll know all about this wonder ful liquid -- askarel insulation -- because it's all very simple. however! Since many engineers and maintenance operators work with BOTH askarel and transformer "oils," you will want to remember that askarel is different from mineral oil . . . and you'll want to know the simple ways to "check up" on the health of your askarel transformer. That's the reason for this pamphlet. First, to tell you that your askarel transformer, in addition to being FIRESAFE, can be the most trouble-free piece of equipment you operate. Second, to give you the few simple facts that will make you an expert on the "whys" and "wherefores" of the easy maintenance. Knowing the facta given on the following pages, you will keep your askarel (and transformer) operating at trouble-free, top performance, year, after year, after year.* *Wa own onm that has boon operating as faithfutiy as a haart boat for 28 years! T \ ACM WATER PCB-SD0000072737 Monsanto also supplies:' Pydraut AC All synthetic fire-resistant compressor lubricant. Pydraul All synthetic fire-resistant hydraulic fluids. Thermal Fluid Fire resistant, non-vaporizing heat transfer fluid. Coolanol Dielectric coolants for high power electronic circuits. Fluid OS-59 Dielectric for high frequency power transformers. MONSANTO CHEMICAL COMPANY Aviation and Special fl-.as Department Organic Cnemicais Division St. Louis 66. Missouri Askarel transformer fluids can be ordered directly from any one of these Monsant^ sales service centers Atlanta Boston Chicago C.ncmnati Cieveiano Detroit Houston Los Ange'es Minneapolis New York Pittsburgh St. Louis San Francisco Seattle Syracuse Wilmington f r.-T" i. V : 9 * - * WATER PCB-SD0000072738 WATER PCB-SD0000072739 Sometimes a "must" ...but often preferred by electrical engineers who know! . .3 Askarel-type tr-.-.sformers have served industry, insti tutions, comir.=-dal housing, the military, electric utility companies and electric railroads safely, reliably, economically ... for over 30 years.* They are supplied -- built to exact specification -- by all major electri cal manufacturers. But only a relatively few engineers and electrical architects have dug into chemistry to learn WHY the askarel transformer is so fire safe, so reliable in operation, requires so little maintenance. Not too many electro-technologists know that askarel transformers (even when they cost a little more compared KV for KV with mineral oil transformers] can actually save money on the installation as a whole, and save money over years of use! Askarel transformers are quite unique. And the "tradesecret" is the fluid. If you would like to join the "inner circle" of astute electrical architects and engineers who for the past 30 years have known just how, where, and why an askarel transformer should be installed . . . just check the facts (and factors) in the following few pages. Monsanto hoi manufactured and tuopltod askarel fluids since tna V eskarei-tyoe transformer was first introducsd. Asesrei-type trens- ' formats wars first mads by General Electric m 1930. The askarel fluid insulation was supplied under tna trade mare Pyranol. Other electrical manufacturers soon developed askarel units using various trade marks for tna asearai fluid, suen as inertean (Westmgnouse); Chlorestol (Allis-Chaimars); Noflamol (Wegner Electric): Asosstol (Amertran Corp.); Saf-T-Kuni (Kuntman Electric). Many manufac turers, howover, simply usa tna ganartc name, askarei. ADM 0C0927 WATER PCB-SD0000072740 TRANSFORMERS K YOUR BEST INVESTMENT/ Mineral-oil transformers can catch fire. Dry, open- type transformers can start a fire. Gas sealed trans formers require pressure and their cost is high! But askarel transformers quietly handle their load, under surge and drop, delivering a steady power flow year after year. The secret of this quiet, fire safe service is the askarel fluid . . . the finest liquid insulation that chemistry has developed. , Askarel fluid cannot be ignited by a blow torch! In ad dition, this dielectric liquid will not oxidize or sludge; will not attack or corrode metals; remains chemically stable when subjected indefinitely to temperatures at least as high as 150 C. The unique values of the askarel-type transformers all stem from the chemical, electrical, and physical proper ties of the askarel fluids. AOM C0C928 WATER PCB-SD0000072741 CHECKPOINTS 5 FOR CHOOSING ASKAREL-TYPE TRANSFORMERS economy dependability easy maintenance low noise leve FIRE SAFETY Askarel fluids, unlike mineral oil, cannot be ignited . . . even by the heaviest arc, such as might accidentally be caused by lightning. Equally important, askarel transformers cannot carry or add burning oil hazards to fires that may start from other causes. The fluid does not deteriorate when exposed to heat, hot metal, nor does it decompose over long use to ac cumulate electrically unstable contaminants. Since askarel v fluid won't burn, and gases formed by arcing do not support ' combustion, the use of askarel transformers eliminates the possibility of fire and secondary explosion. Fire safe askarel transformers are the choice of far-sighted engineers for hospitals, hotels, schools, institutions, under ground networks, military bases, mines, shopping centers, electrical railroad systems, rocket sites. AOM 000929 i WATER PCB-SD0000072742 ECONOMY Askarel type transformers coet about the same or very slightly more than open dry types, cost much less than sealed dry. (gas) transformers. While askarel units cost up to 15% more than equal-capacity mineral oil units, this initial cost is only part of the economic picture: askarel transformers can usu ally be installed without the costly vaults, fire walls, or sprink ler systems required by safety codes for mineral oil units. Further savings accrue in the design of the power transmis sion system. Since askarel units can be placed in congested, closed areas without danger to workers, askarel units can be dose to the point of power usage. .'See Performance Compari son Tablet In addition, fire insurance rates are usually lower when askarel units are used. DEPENDABILITY A properly designed and installed askarel transformer will give trouble-free service for a minimum of 30 years. Since their introduction in 1930, the manufacturers report finding the overall failure rate to be less than Q.5% for all units under test and service conditions. The Edison Electric Insti tute's last report (1956-1958) on their member utilities pub lishes the failure rate for askarel transformers as 0.13 per hundred banks per year! Even these rare reported failures are found to be due to improper sealing that allowed moisture to enter. Modern design requirements for askarel transformer seals eliminates possible failure. EASY MAINTENANCE Askarel transformers are ea*>>st to maintain! Most of the askarel transformers in serv today have received little or no maintenance in decades : operation. Even the accumu lation of relatively large am- ..its of non-ionic contaminants has little effect upon askar%. j excellent dielectric strength. The only contamination that seriously affects the askarel's dielectric strength is water. Proper sealing banishes this source of contamination. Five simple periodic tests (three of them, visual) will check out the askarel insulation. Monsanto and the transformer manufacturers furnish guidance literature on this easy-to-follow maintenance. Unlike oil type trans formers, with askarel units there is no chance of fluid oxi dation or sludge formation, and therefore, less need for replacing the fluid. LOW NOISE LEVEL Askarel transformers operate quietly! Where open dry type transformers in office buildings, hospitals, schools and insti tutions require a sound suppressing room or locating far from point of use, askarel units are so quiet that no sound problem arises. Wherever a fire safe transformer is warranted, the askarel type unit operates at a significantly lower noise level than dry types and offers a significantly superior impulse rating over the dry type. Askarel-Type Transformers Offer Five Important Advantages Over Other Type Transformers Eliminate Fire Hazard More Economical to Install and Operate Proven Dependability Less Maintenance. Easier Upkeep More Quiet Operation ADM 000930 y i f t \ % 9 t *tf WATER PCB-SD0000072743 ! WATER PCB-SD0000072744 1ST & ADDITIONAL EXPENSE COMPARISON Unit additional installation cost BUT: original unit cost is Mignar tnan any other typa. Little or no additional installation cost no additional measures naadad for fira and Uttla additional installation cost BUT: cannot be usad where tltara is excessive atmospnenc dust. dirt, moistura. or wnara high noisa (aval anil causa interference. WATER_PCB-SD0000072745 SAFETYI Freedom from fire and sec ondary explosion. USE FLEXIBILITY! Tightly sealed askarel trans formers can be used in at mospheres contaminated with dust, lint, corrosive vapors and moisture. DEPENDABILITY! Askarel fluid does not oxi dize or sludge. LOW NOISE LEVELI Askarel transformers can be installed close to power sup ply outlets without causing objectionable noise. FOUR IMPORTANT ADVANTAGES FOR INDOOR USE, AND FOR OUTDOOR INSTALLATIONS, TOO! RANGE OF ASKAREL TRANSFORMERS Askarel transformers are available in all capacities, in size ratings exceeding 15,000 KVA. Most askarel transformers in use to day fail .n the 25 to 2,000 KVA rfmge, the majority ranging between 100 and 1,000 KVA. The following transformer comparison chart is ievised to show the economics of askarel n tr.e 25 to 2.000 KVA range, which .ire used primarily for their superior safety features. 000933 WATER PCB-SD0000072746 J * FAIt -- cm caua POOt -- on cum i initial ignition intf ' tnonpliin mBSEm..'. i^iV-- AuM oCCS3<t WATER PCB-SD0000072747 4 Ha HERE'S WHERE AN ASKAREL TRANSFORMER IS YOUR BEST CHOICE INDUSTRIAL LOAD CENTERS In factory areas where maximum safe ty from fire is required ar.d atmos phere contamination may prevail. UTILITY NETWORKS Where location underground or above the surface requires protection from water and other elements, and where maximum safety against fire is needed. INSTITUTIONS AND OFFICE BUILDINGS In schools, hospitals, government buildings, hotels, airports, shopping centers, sport stadiums, etc., where maximum safety and lowest noise levels are quired. WATER FRONTS AND BOAT DOCKS Where fire and weather resistance are the prime requirements. ELECTRIC RAILROAD SYSTEMS Transformers in electric trains and throughout the system require maxi mum safety features ar.d assurance against faulty operation due to weath er exposure. MISSILE SITES Where surface and underground struc tures demand reliable performance and complete protection from weatner, fire and explosion. CONGESTED OUTDOOR INSTALLATIONS Where safety from fire and explosion are required for crews working tl.se to transformer units. \ U CCC935 AuK WATER PCB-SD0000072748 Some engineers who have had no opportunity to acou.re actual operating experience with askarel transformers ana wr.o have received little information about them sometimes harbor mis taken opinions tr.at are contrary to the facts. Here are the three misconceptions that, however infrequent, have been occasionally encountered : "Askarel fluids are 'poisonous.' " The facts: askarel fluids have been manufactured, handled, and used for over 30 years without encounters._ - >xic or ill-effects. It is :! accepted by transformer rr.a.-. - and utilities that askarr; du.ds are not hazardous when ..-.died under standards of - irmal g: - i housekeeping and : ordinary personal precautions used witn other inert md- *-:ai materials. "Askarel transformers can explode." The facts: there s no instance, in the wnoie use history of askarei units. of sec ondary explosion because gases formed by arcing are .non explosive and r.or.-combus::bie ! Even under str.r.g a.-c.r.g, tne possibility of primary explosion in a proper:;.- :es:gr.ei and escape-ver.ted askarei transformer :s very --m.:?. M oorrn design features, sucn as :aoie connection --a.i. .-.np.ete..." protect askarel transformers from pcssioie exp.os.cn. "Askarel fluids run a high power factor." T.ie facts: En gineers experienced w;tr. askarel transformers knew tr.at .: is norma! for an askarei transformer to sr.ow a r.-.gnr power factor than a mmerai oil unit. It is technically unsound to compare the insulating efficiency of oil and askarel by simply measuring power factor. A high power factor in mineral oil :s cause for alarm: BUT ,t is normal for askarei to sr.ow a power factor asir.igh as do to 50 per cent at 100'C. 60 cycles d-5' ' at dOsC w::n absolute ly no danger of efficiency loss or .mpairing norma! operation. NOTE: The most significant and reliable measurement of transformer askarel is its DIELECTRIC pTRENC-TH. As karel -aill maintain its high dielectric strer.gtr. un.ess :--:t .s sigr.iScar.t moisture contamination or brea.;jwr. .: -. d'ucu from an unusually severe exposure to arc. ACP CCC93c WATER PCB-SD0000072749 Askarel fluids both Ir.erteen and Pyranol typei are manufactured by Monsanto ar.d shipped promptly to users anywnere m tr.e world. Askarel transformer fluids, unlike naturally formed oils, are manufactured and quality-checked for consistency and shipped with aa extrema care that is given to few industrial materials. This means askarel fluids can be depended upon to be uniform and provide the optimum service of any liquid insulation. Operating with askarel units is the safest, easiest, often lowest cost way to distribute electrical power. Monsanto will be happy to send you a copy of the pamphlet "Care and Grooming of Askarel Transformer Fluid" or request a copy from the transformer manufacturer of your choice. And if you do . . . ASK KIM to check the (acta on askarel transformers deeeribed on the pre ceding pagan. MCVSAMTO CHEMICAL COMPANY A. ; ;n and Soectal Fluids Oeoartment C'52* c Chamicais Oiviaion St. -i-m 66. Missoun Askarel transformer fluids sen be ordered directly from any ono of thoso Monsanto solos sorvico contort Atlanta Boston Chicago Cincinnati Clovoiand Ostroit Houston LOS Angelos Minnotoons Now York PitttDurgn St. Louis San Francisco Saattla . Syracuta Wilmington ACM CCC937 l WATER PCB-SD0000072750