Document 1wM0gwqRkaNMr2jZ3V6vqk3Z

\y % 11 ORGANIC CHEMICALS DIVISION SALES INFORMATION BULLETIN 0ATt August 9, 1957 This mr f 1 om should 1 ( UCO WITH D| )CK(T 1 ON A3 IT MA5 NOT 9 H CHC* O F Of* AC* CURACY ANO SUCH CONSIOntK' TtONJ AS TOXICITY a NO Mi f(w T con r l ( c T txce*T t ICALLY STATCP. IMCI . su.jtcT aroclor use to increase the INSECTICIDAL LIFE OF LINDANE The attached reoent publication again points out the marked influence of Aroclor to enhanoe the Insecti cidal value of Lindane. While your customers in this field probably have the Journal of Economic Entomology, we have ordered sufficient reprints 00 that you can pass copies along for your customer's convenience. It costs a good deal to Bpray trees, shrubB, etc., and the effective life of the insecticides may not be more than a few weeks. If it rains, most ordinary sprays are washed away. The attaohed article indicates what Aroclor does frit, improve this, and you can see that its use with Lindane offers considerable economic advantage. Technically, it is believed that Aroclor may do the same thing when used with other chlorinated insecticides where mutual Bolubllity prevails; in fact, the function of Aroclor resin as a ''stlckwr" seems worthy of inves tigation for every insecticide. PGB:nb Att. P. G. Benlgnus TN6S 01912 5 -....A----------------------------------------- ---------------------------- c- -- _ C-- C~ ; '~~1 /C 'V \ STLCOPCB4024860 WATER PCB-SD0000042976 Brussels, Belgium 26th January, 1967 SWEDEN, AROCLOR DW *gb G. R. Buchanan - Bt. Louis a. Benignus - 8t. Louis fi. C*n*ron - Brussels D. V* W. Hardy -- London *. JCoaaet Rally - st. Louii Steenrod - It. Louis W recently sent you a translation of a Swedish newspaper article referring to the identification in nature of polychlorinated biphenols. Because sons of the uses claimed for the materials fell in line with the uses of our own chlorinated diphenyls, we made a point, during our recent visit,to Sweden, of visiting the research institute involved and discussing their particular programme of work. To eliminate any earlier confusion that there may have been* X should like to praphasise that there is no doubt that the chemical which is the subject of the investigation and the news release, is chlorinated diphenyl l.e. Aroclor. The company that supplied the mass apectroeeter which was used in the research programme, in fact have recently put out a press release on this work. Although X am horrified by scow of the headlines in this press release, it does basically describe the research programme carried out in Sweden, and describes in clear taros how chlorinated diphenyls were identifi X therefore, enclose a copy for your files. Jensens only aim in lifs as an analytical chemist, was to idanti the substances found in his research work on the occurrence of insecticides in nature. The unfortunateiaspect of the situation is the comments which have been added to Jensens work. He showed what was present and unqualified people have made statements as to the possible effact of what he has found. . Summarising the publication position, there were original artici covering the Stockholm conference in the Swedish daily press, and these reports were picked up also by the Danish press. You will have seen from D.V.*. Hardy's seso'of the 12th January that it has also been picked up by the Shell Chemicals Labor*toj in Rent, U.R. Jensen also divulged that he had been contacted by the Swedish American press agency who intended to include information about this research work in thair monthly review The Swedish American Journal*. There is additionally the press review issued by LK2 Froductor A which I imagine to have been sent to a number of technical journals. TRAN 0566ZL STLCOPCB4024861 WATER_PCB-SD0000042977 <3. R. Buchanan St. Louis 2 26th January, 1967 &X?Ct; in foreign This matter was raised with us by svary capacitor manufacturer in Sweden that we visited, fortunately there has not been too much adverse comment as yet from plant workersiadncs they have not associated the polyahlorinated biphenols mentioned in the article with Aroclor or Pyralsne used in the Swedish factories. Jensen, however, stated that he had bean approached personally by several workers associated with chlorinated diphenyls for non-electrical uses and these workers vers quite worried as to the possible effect on their health. future Research, Arrangements sre being made in Sweden for this work to be taken over by one of the medical institutes who hope to study the toxicology of the poloychlorinated diphenyl residues at the lsvels of concsntration found by Jensen. Additionally a geographical survey is to be carried out to try end determine where the highest concentrations of rssidus are appearing and, if possible, to detect from this the method of escape so that more security precautions can be taken. We were asked by Jensen if it was possible for Honsanto to supply any samples of the pure isomers of chlorinated diphenyl eince his work indicated at the otomant that the lower chlorinated isomers are fairly easily matabolised, and the potentially more dangerous constituents are the more highly chlorinated members. If he can get hold of pure isomers, he would like to carry out some work on cowparitive rates of aotabolisation. Jansen is forwarding me copies of his mass spectrographs and details of sample preparation ao that we have ell the details of his research work. The point that I have made to Janaan is the heed for cars in any further publication of his work which is made. Be accepts that the toxicology of chlorinated diphenyls should only be discussed with detailed information about exposure coneentratioi end exposure times and that generalised statements out of context can only arouse undue public ooncsrn. If ary technical journal takes up the press release from the XJ3 Produotor Compai there is little that Monsanto could, or should do in the way of publishing rebuttals. We do not want, personally as Monsanti to get too involved in this question. I am hopeful that we ...*/ STLCOPCB4024862 WATER_PCB-SD0000042978 a. R. Buchanan St. Louis -3 26th January, 1967 night persuade Jansen himself to write a letter defining tha trus extent of his own rasearch work and placing his rasults in thair propar perspective. It would cartaiily ha helpful in gaining hi* further support if va wear* able to make available to him any small quantities of pure isomer*. Sinca v* are not alone in supplying polychlorinated diphenyls to the Scandinavian market, I have drawn this matter to the attention of tha othsr askaral manufacturers in Europe. As you will see frare the press relaasa one of the major points that is made is tha difficulty In disposing of waste chlorinated diphenyls and again I must mention that constructiv recommendations for tha safe disposal of our materials would b* most helpful* IRAN 056623 STLCOPCB4024863 WATER_PCB-SD0000042979 d>~*>~QI<50N^ST. LOUIS December 4 , 1968 Aroclor Toxicity MMJC has just issued a market plan for Santothan in Japan. In a discussion of tha competitive chlorinated biphenyl manufseturad by Kanaka (Kaneclor), tha follow ing is stated: "It was only last aonth that a serious accident happened at an edible rice-brana oil manufacturing plant in Kitakyushu, where Kaneclor in use leaked out into edible oil through j^tainless steel piping. The authorities investigated the whole plant and" fpund_out_crnks of the Kaneclor circulating stain* _le _steeJLj?..i*fC Ais many ns f2^<50O people "suffered ?rom toxication in addition to a great number of chickens fed with the oil died. The Ministry of Welfare shut down the plant. The sensation was caused. The investigation is still going on but it is certain that 5.000 to 7,000 PPM of Kaneclor contained in the food oil caused toxication. It is very unfortunate that MMJC just started market campaign when Xaneclor is giving the same market notorious Influence.** This is most distressing, and I thought you may want it for your sieeting with Calandra. We should carefully evaluate whether there Is a significant risk in selling Therminol in food applications, and what guidelines should be used. Let qR-Hofow if we can help you get further data fren Japan. u/J/A ' 6TajvASt6 T/YS 2 JCY/f A YtfA A fg#' TA P ! p YR mmAjm // &AY fAYAd fiTtfzf't- C gffjjr/t/ t&KAoA'/H'p) Y/TCS/C /ySs//Asjj>AA a/^s-jas. A/Ay YAYYCA Y/^_ ~ HEXCf/lAC Ay^Y>SM YARYY/SiS YYRz /~A<s/AA?& ASS ^ 'aY'aAAAaAA A* 7Z& sy'/ / A w )AcC TRAN 057^23 PLAINTIFFS ALEXHIBIT NO.. FrvOnR IiDvEuNiiTinIFvIC. ATION I RPTR: STLCOPCB4024864 WATER PCB-SD0000042980 t / fi-'n Monsanto Chemical Company Al st. Louis - Roberts 2 Date August 30, 1957 cc C.E. Casparl - M.O. 2 H.C. Koehler - Robts. J J.M. Magner - Robta. 2 K.E. Maxwell - 3. Clara J.W. Starrett - Robts. . M.C. Throdahl - Robts. ; To Mr. P. Q. Benlgnus Af Roberts 5 Reference PQB Sales Information Bulletin 8-27-57 OD 1149 - "Aroclors As Agricultural Subject Chemicals", 4-1-57 by JMM AROCLOR USE TO INCREASE THE INSECTICIDAL LIKE OF LINDANE It is most surprising to see that you are recommending without restriction a use for Aroclor which has not been approved by U.S.D.A.-F.D.A. For the protection of the company it appears that salesmen who may try to promote this use of Aroclor in agriculture should be fully apprised of limitations and of risks involved if promoted for use on feed and food crops. In turn they should apprise customers of the true status of the development and advise them that if they use Aroclor in insecticide formulations on food or feed crops they should first obtain government approval. You may already know that since Aroclora are toxic and, according to your attaahed reference, may extend the residual life of the pesticide, the Federal Government would require the following before selling for use on food and feed crops: (1) Proof of benefits from the application . (2) Data to show whether or not residual Aroolor is present and whether it modifies`the residual amount of Lindane or other active ingredient at harvest. (5) If Aroclor Is present or if the residual quantity of Lindane or other active ingredient has been significantly changed, tolerances for the Aroclor and for the pesticide in question must be developed. (4) If a toxic quantity of Aroclor is present at harvest in food or feed crops a tolerance cannot be established until after two year chronic toxicity feeding tests have been completed for the Aroclor. Obviously, much of the above is obviated if the Aroclor-insecticide formulation is not used on food or feed crops. Even then the label must show safe handling procedures, since Aroclor is toxic. Incidentally, the findings published by Duda, as per your attached reference, are not in accord with research findings reported In reference report OD 1149- In this report you will note that Aroclor in I hi TRAN 053674 STLCOPCB4024865 WATER PCB-SD0000042981 Mr. P. Q. Benignus 2- - Augu3t 30, 1957 contributes to longevity of insecticidal action only when combined with highly volatile compounds, and then only when applied to hard, smooth surfaces such as glass...not on agricultural plants. This ' is called to your attention because government label approval for use in agriculture also calls for proof of performance. Admittedly, your August 27 bulletin does not speoiry using Arcelor in insecticides for use on food or feed arop3 but neither does it specify' such a combination Bhould not be used on food or feed crops. Perhaps this is an over-sight which you will wish-to"call' to the attention of recipients of the bulletin. LVS/eb p.s. We repeatedly rind that users of formulations prepared for a specirio use will apply the material for other uses. In other words, even though Monsanto may encourage the use of Aroclor in pesticide formulations for non-agrieultural use you oan rest assured that some of it will be used on agricultural commodities. For these reasons alfin* It is strongly recommended that we state very specifically in any Monsanto literature, including correspondence, that Aroelors not be used on agricultural commodities. I believe our Legal Depart ment will confirm that there is an important legal aspect involved. TRAN 053675 STLCOPCB4024866 WATER_PCB-SD0000042982 Monsanto PM?* |MAM| A LOC ATI OATf Al/AVtCf m(ec*ct TO : n W. R. Richard - Research Center December 9, 1968 AROCLOR TESTING E. Wheeler - EWHEE Tucker Keller W. Johnson K. Wells P. Benienus/J R. Munch JFQ JFQ VJOHM KWELL Bryant PBRh'I JFQ The Issues on Aroclor toxicity testing are comollcated. I know you olan to issue written orogram objectives. My understanding after last meeting 12/6/68 is a3 follows: 1. Determine whether Jensen and Co. really have Aroclor or not in tissue of birds: (a) by putting Aroclor through rats and chickens and seeing if we get the same or different peaks than.found in Jensen paper. (Use mass spectrograph for check.) (b) by getting hold of tissues from nature which others say is Aroclor but which ` could be many other compounds. Use mass spectrograph to check vs, known Aroclor results. . ' 2. Determine a tolerance'level for Aroclor In feeding studies. Run a material balance on Aroclor to find out where It ends up. ', 5. Determine whether Aroclor Is an enzyme inducer . which affects steroids ana Ca metabolism. (I ' really don't know what I am saying here but you can clarify.) ` ^. Keep track of what Govt, research labs are doing In way of testing, plus interpret their results ' for Monsanto. 5. Keep track of what Govt, research labs are finding in the way of geographical location of so-called PC3 peak3, and in what species of animals. What does t-hls mean in the way of product control by Monsanto. Check with Johnson of Callandras Lab oratories.6 6. Contact Eaeyer In Germany to see if- they have taken . any action. Keep track of Japan- incident through l-i.MK, TRAN 0573^2 k. STLCOPCB4024867 WATER PCB-SD0000042983 > ' ' i'-. . l * tnr--- R. Richard Research Center December 9, 1968 ee /' DEFENSE OF AROCLOR , Ralph Munch Paul Benignua/J. Bryant J. Herber/J. Sullivan Q. Thompson/R. Weiss I } I would appreciate your thoughts. Admittedly, this 7 r. ccr is too defensive because we may find that ..roclor is safe and haa beer, misidentlfled In the environment. However, here goes on the defensive side, . 1. Toxicity Defense - Callandra to determine safe level of exposure on a long term basis in ppm by feeding studies. 2, Is chlorinated biphenyl Identified in environment? Do chicken work, and compare with what is being found and reported as FCB. 5. Find out whether PCB is an "enzyme inducer". 4. Clean, up stream and air pollution from- our Aroclor plants our customers* plants our customers* products restrict sales from specific uses 5. See if Aroclor handling facilities and oper ation of customers capacitor plants transformer plants heat transfer systems could be improved to minimize exposure. 6. Seek replacement derivatives which are differ ent, less toxic, but which use our plant*. - $$Clx -- tftfBr or GfafclFx or $$Fx ` - tftftfClx tfotfClx or GfetfClx Test toxicity, electrical properties, economics. TRAN 057681 i*< Kt STLCOPCB4024868 WATER_PCB-SD0000042984 II 7. Expand the product line to minimize efTectB of Aroclor decreases. Use hydrocarbon + (10;* invention) ' Control of DK with another reagent Control stress on plastic Control solubility of polypropylene Could control DK be by (Westlnghouse wants DK >3.0 in fluid) 8. Examine silicate esters for transformers; capaci tors If compatible with polypropylene Examine Flutec perfluoro compounds for specialty transformers and capacitors. - Examine sales of polyisobutylene - low M.Wt. thickeners for oil impregnated cable. Examine Rcfclx for toxicity, for electrical properties. R2iFx ' ` 9. Enter the business for solid insulation by buying into capital film production Thanks, ms W. R. Richard ,6S2 STLCOPCB4024869 WATER PCB-SD0000042985 (p i 5. T. Vhmeler December 23/ 11?68 Bran Oil Poisoning by Kanec lor Vour DMDO December 9, 15*68 D, A. Olson w. H. Richard* f*. C. Eeolgnua D. Boush I think the following coonenta are pertinent with regard to the recent Incident in Japan: 1. In the IT. 3. the only "hygienic regulation*' referring to chlorinated biphenyls are the Threshold Limit Values (TLV) ror Aroclor* 1242 and 125# The values are l.o mg/ cubic meter of air and 0-5 respectively. These Unit* have been set by the American Conference of Governments 1 Industrial Ryglanlate, a quasi-official group with no legal authority lor establishing federal standards. These levels are time weighted averages deemed to be safe for 8-hour daily exposures in Industry for a lifetime of work. Although they are Intended as guidelines, a number of individual states have considered the TLVs as appropriate for adoption in state codes and regulations. further, by reference,, the TLYa can be enforced by the 0. 3. Department of Labor in industrial plants subject to the Valsh-Healey contract act. .2 There, are no regulations concerning the Aroclor* In applications where there night be oral Ingestion of these materials, for example, there are no direct food additive or indirect food additive uses approved by the food and Drug Administration. To our knowledge none of Monsaato'e customers have applied for e petition for regulations permit ting such use although currently s petition.-for the use of Aroclor 5460 in adhesives for food packages is in development. Similarly there have been no applications in the pesticides field where the U. S. Department of Agriculture would have to be consulted. In the absence of prospective uses which would require such governmental clearances, there has been no incentive to undertake the extensive animal toxicity studlas which would provide data necessary for establishing a human diet tolerance. TRAN 006445 STLCOPCB4024870 WATER PCB-SD0000042986 D. A. Olaon 2- - Duceir.ber 23, 1968 3. If. there were extensive animal toxicity data available, I do not la Hove tk; food and Drug Ab.v.ir.lstrstien would s.:k r t``i.e.-.'nce level in foeon whom la: presence c-f the eh 1 'IT 'cou L. 11 y 1. ucj ai i.nd .1 *-_ :!i luskag'.: i'l*-. r.t a k_-P.t trsnr.: ur system. Such presence would result Iron leakage or other accidents 1 c on tar dnati on and would not he accepted an mlng '' necessary" or Gddlng any tiling beneficial to a Toed grade substance. CT C) I don't know of any U. S. regulations which give cither the Food and Drug Adrinintmtlon or the Do part went or Agi'icul turn approval authority for heat tranafex' material 01 vleusly, the food end drug agencies have the General, nr- to or ad ' n .ond seine rood proeuots that ara "cdul enre ted or "confcaMina.tod". It ic on Uhla baoio that the ikdlcal Department has stated that any cocking oil or other rood product con In lain-; ii.ore than .0 ppm" should te dee kroyud if tiro i.:anul;ij tui'er or processor1 of the rood product la to avoid government action. H. The data or literature concerning effects of chlorine t j :i h : ;:h '< s .:i Iv.v.'.'an rein to ml;/ to race valve vapor J.nk/Tv or a- ; rive akin exo: sui-cs. It is not possible at tkjL.; point to extrapolate fiv.;.: any or the aril:.'..il trad city human accidental exposures to a .''safe'' ingestion level for hun.a no. 5. Tii? chlorinated biphenyls are not ':pclsonc" or"drugo". There ora a number of definitions in the U. S. relating to the classification of industrial chemicals and household p --rel'.. Included am definikivna of Ike Interstate C~. Co...mission, the federal llarardous Substances labeling Act, the national Safety Council reco;r..T.sndatlcna, etc. Each of tl'irse establishes levels of tonicity and poison categories by tho results of specific aniaal teats. The chlorinated 1./.phenyls would not be classed as "poisons''1 bv any pi- ti-.ir;.? bafini tionn. They v/ould ! : considered toxic'1 1st no ;:-:-ra so than many ce:c.:.sn infra i; via 1 chccTca 13 ; and, as a rea 11 ; r vr fact, v.sny formulated produces used Ground the hcw.e. TRAN 0064^6 STLCOPCB4024871 WATER PCB-SD0000042987 V. A. ulaon -3- December 23, 1968 I don't know how much of the above will help in the . situation in Japan but I leave It to your Judgement aa to what ahould be forwarded. Elmer ?, Wheeler cs TRAN 00644- 7 STLCOPCB4024872 WATER PCB-SD0000042988 '^ON SANTO Cl IEMI(___COM PAM Y r.n ,o~~ WashlngtonT"D7~cT ^ ..* October 23, 1961 AROCLORS - PDA j*CrtCHCC ; (r.t e . i \ ( t cc p.Benignua-St .Lou. R.DavlB-St.Louis |^7fTKunt-St. Louis R.E.Kclly-St.Louis K .Welngarten-St.Louis R.S.Wobus-St .Louie K.H.Haday-St.Louiy TO rz :K, S, Bergen St. Louis, Missouri Dr. William Horwitz, of the Pood Division of PDA, la hot on the trail of a chlorinated "compound X" which is a causitive factor in chick edema. You will recall in July, I had indicated that O'Dell at the University of Oklahonia v.-ao publishing an article in the Journal of Poultry Science which seemed to indicate that Aroclor 12^2 uoed in paint for chicken coops caused chick edema. At that time, vre tranomitted a sample of 12^2 to Horwitz who was unable to find compound X in the sample. Tills seemed to give our Aroclors a clean bill of health. Horwitz is now back on the trail. Because of the use of Aroclore-aa "extenders" for insecticides against reaches etc. in the poultry field, among others, he feels the Ax-oclor lir.e should be more fully checked out. Ho called this week indicating that the FDA might like to knew all about our Ai-oclor process of manufacture, cur methods cf analysis -- Including chromatographic, our toxicity studies and anything else related to the Aroolors. Ir, addition, he Indicated that FCA might de-slre to send a nan to St. Louis to upend acme time learning the "Aroclor bUGinc ta". I calmed Horwitz down temporarily by transmitting our latert Aroclor general saleB booklet. I indicated if he did not get everything he desired from this booklet, to get in touch v;ith me and I would proceed from there. Khen Horwitz has had a chance to look over the bulletin, I will be in. touch with him again. What is our experience on the use of Aroclors as extenders in insecticides? I aw av/are that Deltovllle in *59 indicated 1 to 2p Aroclors.in.an insecticidal formulation such as Lindane for non-crop use seemed to be quite effective. Do we have any later data in this area? I will be in touch when the situation gels here. CJE/mgo C. J. Eby TRAN 012383 STLCOPCB4024873 WATER_PCB-SD0000042989 Monsanto .............. * Lw.i.0-' w. R. Richard - Research Center < M ft .-jCT |M*< March 10, 1969 NOTES ON MEETING 5/6/69 FF- Cc' , INC. TO FILE H. Bergen/D. Olson P. Benignus/J. Bryant J. Fallon/D. Roush/ S. Shaw J. Sprlngate/Schalk/ Waychoff -^JR. Keller/E. Tucker C. Payton/K. Wells B. Wild! Those present: . Joe Calandra - Pres,-Chemist PhD and M.D. + Staff Northwestern U-Pathology Otis Fancher - V. Pres.-Chemist PhD + Drug Research M. L. Keplinger-(Kep) PhD Biological evaluation Ray Kary - Air Pollution - Rad, Health Lawrence Beer- Environmental Services ' . Monitor chemical plants - Nuclear Power Plants E. Wheeler ? _ W. Richai'dj Monsanto . K. Wheeler and W, Richard reviewed background on Aroclor proper ties, recent analytical results by Scott Tucker.- history of Aroclor, . application uses, ref. to Risebrough's Dec, i960 paper in Nature; effects by public relations, legal and scientific findings on Aroclor and its products. We discussed amount of material-15,000 lb/yr, passing through Santa Clara v/arehouse, questioned whether PCB could really be present to affect wildlife as reported in Rlsebrough' paper on San Francisco Bay. . We asked for consideration of problem from public relations, DDT Wisconsin hearings, legal actions, and scientific aspects. We dis cussed problem from: _ Analytical chemistry ' Acute and chronic toxicity - animal-fishbird studies Enzyme enhancer _ calcium metabolism - thin egg shellB hormones -- human involvement Terrestial ecology The last subject, ecology, was Just mentioned because Bill Johnson, Bio-Test man in this field, v.-as at U. of Wisconsin. The name of Dr. Thomas Parks, u. of Chicago, was mentioned as a possible con sultant - may be retired. Logistics of Aroclor exposure and likeli hood of contamination not discussed enough. TRAN 005788 . i PLAINTIFFS EXHierr mo 3 tor IDENTIFICATION STLCOPCB4024874 WATER_PCB-SD0000042990 2- - The question of a grant to Newall - at Stanford, was mentioned. Possible listening post for West Coast activities. - No decision. The problem of contacting and maintaining contact with the Univer sity and Govt, people who are seeking biological Information on PCB's was discussed. Names of Bill Johnson and perhaps Lawrence Beer were mentioned. We discussed possible consultants who might be of help on this problem. , Monsanto Consultants Alan Mehler Robert Metcalf Bert Vallae * Jean Mayer Marquette U - biochem and enzymes U. of Illinols-entomologist Harvard - enzymes . Harvard - nutrition Possible Bio-Test Consultants Wayland Jack Hayes Thomas Parks Vanderbilt U. of Chicago - ecologist-Dept. of Biology Agreed to convene at earliest possible date at either Blo-Teot or Monsanto with appropriate consultants. Job of educating Monsanto consultants, and getting permission,to fall to E, Wheeler and W. Richard. (March 21 tentative date) Bio-Test consultants Job to J. Calan'dra - Otis Fancher. E, Wheeler will report on program to date: I. II. III. Rat tissue residue study and acute levels for Aroclor 1242, 1254, 1260 and 5460. Chicken tissue residue study and acute levels. ^ Fish toxicity TLM. IV. Chicken toxicity - reproductive egg and meat residue (6 months) To go ahead with study but add enzyme and hormone experiments plus calcium metabolism studies and egg shell thickness. V. Mallard Duck - (Aquatic Bird) - Same type study as for chickens. VI . VII, VIII . Three generation reproduction in rats Start now. Two year study in rate (26 months) Start now. Two year study in dogs (26 months). (18 months). ; f. | ; TRAN ' 005789 IX. Subacute Fish Study. Start immediately. Consider possibility of reproductive cycle. X. Metabolic studies - ! No decision, question on need for radio tracers. Seem inclined to do without radio tracers. STLCOPCB4024875 WATER PCB-SD0000042991 -5- Prancis T, Mayo Chief Federal Water Pollution Regional Enforcement Office San Francisco Distri r* Friend of Lawrence Beer. Discussed requirements of sampling fish and water in San Francisco Bay, location of a lot of RIsebrough's accusations vs. pcb and possible site of very low Aroclor usage. L. Beer indicated 40,000 for this kind of job. Wheeler and Richard said 4,000 plus a rowboat. Defense seems to have these elements. I. Aroclor not intended to be spread around. Used in closed systems, recycle of material, limited exposure. - most but not all Aroclor uses meet the above description. II. Aroclor identification in nature. Is It really identified? Is it a metabolic product of something else like 2-4D or 2,4,5T or chlorophenols? For example, hard to see that 15,000 lb/year could pollute San Francisco- Bay even if were all dumped in. III. Atmosphere and streams around our mfg. plants and major customers. Need to establish a norm and an acceptable standard. ' IV. Establishing a tolerable limit. Here the Wisconsin EDF type will want 0 tolerance. They will be driving on this subject as they are against DDT. Even If they fail, they will drive people from product use. This is already happening with DDT because of public relations aspect. V. Not discussed but possibly obvious. Can we find out whether product degrades In nature so that it does not accumulate? Only real way out long term. Joe Calandra again mentioned need for soil and bug experi ments so that PCB1s could be shown to degrade. If .Aroclor is an enzyme enhancer, does that mean enzymes attack It? This program is not in gear. ms Att. 1 W. R. Richard TRAN 005790 STLCOPCB4024876 WATER PCB-SD0000042992 Monsanto r.i> .*. ATt iut;(cr TO W. fl. Richard - Research Center May 13, 1969 ee AROCLOR - ANALYSIS IN PESTICIDSl- HESHSUE5 : (Visit to Prof. G. Widmark V, of Stockholm - May 5, 1969) File R. Keller E. Wheeler :.E. Tucker H. Bergen D. Olson W. Kuhn R. Kountz R. Davis P. Benlgnus/J. J. Fallon Q. Thompson R. Weiss L. Stark J. Sprlngate M. Farrar W. Waychoff C. P&ton R. Baxter - A-Lc EWHJ Res, HBER DOLS WKUH RKOU RDAV BryantPBEN JFAL.' QTH01 rwei; LSTAJ jspr: Res. WWAY( CPATC RUABC Widmark was finding . Cls and Cla chlorinated biphenyls from extraction of salmon and from extraction of waste sewage sludge. low C1t and Cl* .chlorinated biphenyl Some Clio "" No Clu and Clia " " This corresponds roughly to Clophen 50 or Aroclor 125^. The Isomers found In nature are not ttie same ratios as In either Aroclor 1254 or Clophen 50. Widmark has examined 2000 samples from the Baltic Sea. Another group of ecologists is examining the sea around Scotland. Their results are a bit different according to Widmark's knowledge. _ Widmark had been in contact with transformer manufacturers in Sweden. They reported very low loss of chlorinated biphenyls, an occasional spill. Widmark kept hitting at marine paints as a source of the product. He wanted Monsanto to restrict sale to those closed system applications. He asked If the "economic value of PCB's was worth the bad publicity which would come to Monsanto. ' ' We countered with a question. What products would he recommend as sub stitutes? What kinds of synthetic compounds are biologically acceptable? Would he help establish a safe tolerance level of synthetic compounds in wild-life? TRAN 086181 an. 11.aa STLCOPCB4024877 WATER PCB-SD0000042993 He reported that he had not isolated or found much chlorinated biphenyl with 1 through 4 cl atoms. Thi3 might be because Aroclor 1242 and below is more biodegradable; (or it could be due to the analytical Isolation and separation methods; or perhaps Aroclor 1242 is less exposed in the world.) ' Widmark is dedicated to better and more accurate analysis. He is in sympathy with most of the ecologiats demanding elimination of chlorinated pesticides. Hi3 knowledge of scientific evidence and its requirements makes him slightly hesitant in condemning Aroclor itself or demanding its total eclipse. * Keller and Wheeler should have a more complete report. Widmark reported not finding chlorinated naphthalene, chlorinated paraffin chlorinated benzene, chlorinated terphenyl. He thought he had identified ' and accounted for 80% or more of the lipid soluble extractable chlorine containing compounds. BaBed on these remarks of Widmark we might consider alternate products and actions. What is the Cla and Cl* content of Aroclor 1242? The Aroclor 1242 has 31% dichloro, 33% trichloro ' 16% tetrachloro The Cls content must be very low in *our present material. If Aroclor 1242 is indeed biodegradable we might restrict usage to minimize and control its concentration in nature to acceptable levels. .' However, the use of Aroclor 1248, 1254 and 1260 would seem to require further restrictions in exposed systems. . Scott Tucker reported that Aroclor 1242 could be destroyed by HNO3/H2SCU treatment. Widmark may or may not have been destroying Aroclor 1242 before his analysis. We could also expect that Clstf might go undetected based on Widmark'a evidence; and apparently chlorinated paraffin and chlorinated terphenyl have so far escaped detection or are ab sent in the tissues of birds or fish. Again, Keller and Wheeler should have a more complete report. W. R. Richard TRAN 086102 J' STLCOPCB4024878 water_PCB-SD0000042994 UONI'ANTO CHEMICALS LIMITED ,,*) nn 5 PRODUCT TOXICOLOGY - AROCLORS Report suraraar _3 i ng present knowl,od.g?,_c-rtcerning chlorine-containing residues in wild life and visits made to organisation implicated therewith during the veriod April 28th - May 1st, 1969. Clrculation J,W. Barrett, London. R.A. Baxter, P.uabon. H.A. Vodden, Ruibon. H.R. Newman, Newport. A.C.W. Pemberton, Newport. W.J.S. Budd, London. J. Herefousse, Brussels. D. Wood, Brussels. R.E. Keller, St . Louis. E.P. Wheeler , st . Louis R.E. Kel^y, St. Louis. W.R. Rixrhard , St . Louis ^Bergen, St. Louis. Formerly Research Services Manager, MCL, and now Consultant to MCL in the area of Product Toxicology and Safety in the Use of the Company's products. plaintiffs EXHIBrr NO TM^,RCAT1N date- Rf~,____ _ CTf\< TRAN 021762 STLCOPCB4024879 WATER PCB-SD0000042995 INTRODUCTION The wide agricultural usage of insecticides in the post World War II period and consequent effects on wild life have led in certain circles to apprehension concerning the overall effect on man. The situation has been under study for many years and Government agencies and manufacturers of insecticides have been implicated in the various aspects, particularly in the assay of such residues in many species of wild life. Fish, fish-eating birds and mammals have been subjected to wide ranging study, and it became clear that terrestrial usage of insecticides could have far reaching and hitherto unsuspected effects on wild life, part of it making an important contribution to the diet of man and domestic animals. The size of the wild life specimens and the minute con centrations of insecticides therein demanded highly sensitive methods of assay, which have been progressively refined. Gas liquid chromatography using electron-capture or microcoulometric detection has become established as the most suitable technique. It appears that the chromatograms of the residues showed not only the peaks corresponding to the insecticides and their known metabolites, but additional peaks of unknown chlorine-containing substances. Towards the end of 1965 these unknown substances were identified by SfcJren Jensen, a research worker at the Institute for Analytical Charalctry, University of Stockholm, under the direction of Gunnar widmark. Uaing a combined gas chromatograph mass spectrometer (LKB-9000) it was shown that the peaks are due to polychlorinated biphenyls (PCB's), The evidence and reasoning are available and the conclusion can hardly be in doubt . Unfortunately the announcement was coupled with sensational statements concerning the poisonous nature of the PCB's, which were calculated to cruse misgivings both to public authorities and to the general punlic. Jensen and Vidnnrk found PCB's in specimens of pike from different parts of Sweden, fish spawn, a dead eagle and in human hair, and even on fir cones'. The conclusion reached was that the PCB's originated from burning industrial wastes and were washed down by the min. Examination of feathers from museum specimens of sea biros suggested that contamination commenced in 1944 . The original work of Jensen and Widaark has been extended and generally confirood, notably by workers at the following establishments and much of the detail has been published:- TRAN 021763 STLCOPCB4024880 WATER PCB-SD0000042996 3 Great Britain 1 Labor atory of tho Government Chemist Cornwall Houua, London, S .E . _ . (Notably Mr. O'G. Tatton) .2 Freshwater Fiaher ies Laboratory, (Ministry of Faskally, Agriculture, Fisheries Pitlochry, Scotland. and Food) (Mr . A. Holden) 3. Tunstall Laboratories, Shell Research Limited, Sittingbourne, Kent. (Dr. J. Robinson and Mr. A. Richardson) 4. Monks Wood Experimental Station, Abbots Ripton, Huntingdonshire. (Dr , N . W . Moore) (^Nature Conservancy) Established by Royal Charter to (1) provide scientific advice on the conservation and control of the natural flora and fauna of Great Britain, (2) establish, maintain and manage natural reserves in Great Britain including maintenance of physical features of scientific interest, (3) develop research and scientific services related thereto. At 30th September, 1963 there were 144 scientifically qualified staff and in 1963--) there was a Government^ grant-in-aid of 701,000. Holland5 6 7 8 5. University of Utrecht (Professor H. Van Genderen) U.S.A. 6. University of California (Drs. R ,W. Riseborough, P. Rieche and S.G. Herman) 7. Cornell University (D.B, Peakall) 8. San Diego Natural History Huseum (M.N. Kirven) . TRAN 021764 STLCOPCB4024881 WATER_PCB-SD0000042997 4 This report is written following discussions with stuff from Establishments if 2 and 3 in which Dr. R.E. Keller and Dr. E.P. Wheeler (1 and 3 only) were associated. Drs. Keller and Wheeler are proceeding to visit 5, University of Stockholm, to see Jensen and Widaark. They are also visiting Bayer to ascertain its reactions aa manufacturers of PCB's (Clophens). SUMMARY1 2 3 4 1. There can be nc doubt that traces of PCB's (Aroclors) are to be found in wild life, fish and certain items of human diet. 2. There is little evidence to show how serious this minor contamination '.'ill prove to be, but what evidence there is is reassuring. 3. There is littlo evidence to show how the PCB contamination arises. It tiny be by run off of wastes into rivers, or by burning of industrial wastes with consequent washing down by rain. It is remotely possible that the PCB's might arise by biochemical action on insecticides and other chlorine-containing materials which are similarly discharged into the rivers, seas and oceans. It could be that among the vast quantities of materials destroyed on land and at sen during the 1939--45 war, significant quantities of Aroclors and Aroclor-containing materials found their way into the rivers, seas, etc., and are being olowly released by corrosion, extraction, etc. (see footnote at end of report). 4. A considerable Monsanto effort will be necessary to obtain the necessary analytical and toxicological information for dealing with this threat to our commercial operations. A. Visit to Freshwater Fisheries Laboratory, Pitlochry* Monday, April Zo t h , 196 9 ! " Mr. A.V. Holden - Officer in Charge. Dr. R.E. Heller - WC Dr. D.V.N. Hardy - CL This visit was nude not so auch on account of contributions made to the subject but because Hr. Holden acts as Co-ordinator *Dr. E.P. Wheeler was prevented from taking part in this visit due to the sudden indisposition of Mrs. Wheeler. TRAN 021 765 STLCOPCB4024882 WATER PCB-SD0000042998 -5 - I for the programmes of the O.E.C.D. countries concerned with the influence of biocides on natural -nvironmenta, wild life, etc. He might therefore be expected to have a wider appreciation of the overall problem and of its assessment in terms of the hazard to man. On this latter aspect he was of the opinion that there had been a tendency to overplay the hazard to man of insecticides and PCB's, and that it was very doubtful whether the toxicities of PCB's were greater or similar to those of the insecticides. Experiments with rainbow trout in water con taining 1 part of DDT in 109 of water had shown that death occurred in six weeks after which the concentration in the fish muscle was 1 in 10. In other words there was a concentration factor of lOOO in 6 weeks: this would take place mainly by absorption in the gills. He believed that some similar experiments with Aroclors had been carried out in the Ministry's London laboratory, and phoned for confirmation but was unable to get this during our visit. I am therefore endeavouring to get the answer to this perhaps significant experiment. Mr. Holden's analytical work has been concerned largely with extracts of seals and fish taken in Scottish waters, and he has observed similar peaks to those found by Jensen and the Government Laboratory. Extracts from freshwater and seawater fish show fairly low amounts of PCB's, while seal blubber contains considerably more. Reprints of relevant papers were given to Dr. Keller and there was a discussion on analytical work, much of which was carried cut for other bodies, e.g. the Nature Conservancy. Much of tho work remains unpublished and he saw little chanco of rectifying the situation. B. Yiait to Tunatall Laboratories, Shell Research Ltd., Sit ting bourne, Tent . Tuesday, April 29th, 1969. Dr. Mr. Dr. Mr. J. Robinson - Biologist A. Richa rdson - Analyst Stevonson - In chargo of Experimental Animal Bouse. De Corsen - Laboratory Administrator. Dr. R.E. Keller - MC Dr. E.P. Wheeler - MC Dr. D.V.N. Hardy - VCL ' Shell has naturally been concerned with the problem of insecticidal residues from the outsat and the coat of the analytical effort and its interpretation must have bean very considerable. To Shell tho PCB aspect has been simply one of analytical complication, and although at times there have been suggestions from their commercial people that the focus of TRAN 021766 STLCOPCB4024883 WATER PCB-SD0000042999 6 toxicological interest night be transferred from insecticides to PCB's, there hus been no attempt to do so. In fact papers by Robinson do not rotor to PCB'a but make a very sound approach to the insecticiaas problem and to its true perspective. Nevertheless they had collected some information on possible usage of Aroclors, for example, they had noted that the Coal Board disposes of 1,000,000 gala, of high pressure lubricant each year. Did this contain Aroclor? We thought it unlikely but questions concerning safety in use of Aroclors had certainly been referred to UCL by the Coal Board and it was therefore likely that some minor uses have been developed. There might conceivably be a small content of Aroclors in the high pressure lubricant. Usage of insecticides was of a high order, and in Kent alone IOOO tons of DDT had been consumed since its Intro duction after the 1939-45 war. Reference was also made to usage of Aroclors in cutting oils; the Government Laboratory had suggested that this was a possible source of contamination. Cutting oils are normally sold as proprietary formulations and it would be difficult to estimate how much Aroclor is consumed in this form. Shell would much prefer to have a direct method for estimating insecticides. Now, owing to the stability of PCB's, it was necessary to estimate insecticides and PCB*s, then PCB's by destroying or removing the insecticides and getting the insecticides by difference. Aroclor 1254 had been fed to chicken at IOO parts per million Of the diet and no adverse effect observed aver at period of 12 months. The Nature Conservancy has carried out feeding tests on Bengalese Finches with DDT and found no adverse effects, and similar results have been with chicken and quail fed on 10 and 20 parts per million of Dieldrin. Other workers found some effect on mallards and chicken. At the Government Laboratory it has been shown that human fat (from mothers' milk) may contain PCB. Reference was also made to the work of Hr. Alabaster, Ministry of Agriculture, Fisheries and Food, on toxicological levels with fish. It was agrud that many 01 the specimens submitted for analysis were not representative of the total population, e.g. predators were heavily weighted, and of the sick and dead birds, were most frequently collected. There must be large numbers of each predator much loss contaminated than those submitted for analysis. Samples of fish oils and nargarine (supplied by Unilever) have been examined, and while I-'CB ' b can be found in the oils, they disappear curing the hardening process so that margarine is free. TRAN 021767 STLCOPCB4024884 WATER PCB-SD0000043000 8- - I C. Discussions nth Representative's of the Government Laboratory at llonsan t'o~~Tfouse Thursda y , Ma y 1st, 196 9'! Mr. J.CG. Titton Mr. G.B. Collins Laboratory of the Govornnent Mt M Chemist Dr. R.E. Keller Dr. E.P. Wheeler Dr. D.Y.N. Hardy - MC - MC - HCL Mr. Tatton said that the possible danger of Aroclors used as plasticizer (in food packaging and in lacquers for cans) had been considered quite jarly on and reference is made thereto in the Annual Report of the Government Chemist 1953-4. He will send me a photostat copy. As regards residues in wild life peaks not due to pesticides were observed in 1963-4 and this caused trouble in view of the complicating effect on insecticide determination. Attempts to identify the disturbing material failed until Jensen showed Ktheir nature. Jensen's work has been fully confirmed and I extended and PCB's have been found in eggs, predatory birds, | rarely in human food, and traces in cod liver oil. Human fat f seems to be free from PCB but there may be 2 - 12 parts/10^ of insecticide. Some PCB found in human lung samples. Work has been carried out on air and on circumstantial evidence PCB must be present. 1 part DET corapounds/lol2 parts of air has been found. The analysis U coaplicated by the presence of hydrocarbons. Tatton rill cupply references to this work which was carried out on sampleof about 1200 litres. The content of insecticides in air and water is variable, generally higher in London due to soot particles acting aa absorbent, and also dependin' on when spraying is in progress. Dr. JCroll (Water Research /:ssociation) has failed to find PCB in river waters at parts por-lO^. Many sampled are cent to ihe Government Laboratory by the Nature Conservancy, but having carried out the analysis nothing more can 3a dona as the uource and significance of the ample are known ;>nly to the Nar-.-.re Conservancy. The peaks caen in the chromatogram represent only part of those observec in commercial samples of Aroclor 1254. Probably the middle components ;-.re favoured by the analytical procedure: certainly ponkn due to higher boiling material can be obtained by raising the operating temperature of the column. Recently high PCB figures have been found on herons (several hundred parts per million in the liver), kestrels, owls TRAN 021769 STLCOPCB4024885 WATER PCB-SD0000043001 I Q and kingfiBhers. Dr. N.W. Mooru (Monkswood Experimental Station) might be prepared to diJcuas their significance and the geographical .'actor. Tnttc.: considers that Jensen's peaks are more lr. line v./ith Bayer's Clophen. He thinks that some of the bird ..amples are representative as they were taken from colonies. Tatton alsc referred to possible traces of PCB nature in occasional foed samples, e.g. ailk, mutton and beef fat. He will supply me with copies ol all relevant papers, including a report on some new detectors for VPC analysis. Dr. Keller will reciprocate by sending chromatographic curves for the various Aroclors. I referred to HCL work now starting on the biodegradation of Aroclors and suggested that cur workers should contact him on the analytical techniques. He would be most happy to do so. D, Discussion with Ropresantatr.ves of Cromer L Warner, Consultants, 140 Buckingham Palace Road, London, 5.W.1. Thursday, May 1st, 196^. ! Sir Frederick Warner - Cremer & Warner Dr. David Train Dr. R.2. Keller Dr. E.?. Wheeler Dr. D.7.N. Hardy - HC - MC - MCL This was a lunch discussion arranged to determine the possible value of this firm of .onsultanta in the assessment of the PCB problem. Cremer & Warner have contracted with the Port of London Authority (and possibly with others too) to study the effect of cortain contaminants in tho Thames. They are concerned specifically with detergents and Mr. Cremer is Chairman of the Government Committee which has been advising on the problem due to bard detergents. Cremer k Warner are also advising on atmospheric pollution due to sulphur dioxide and smoke, and on the design end interpretation of data from the recording stations. They have also acted as consultants for the new potash project in relation to the effluont disposal problem. They have advised that the effluent hould be discharged 1 mile from the shore at a minimum depv.h of 75 feet. TRAN 021770 STLCOPCB4024886 WATER PCB-SD0000043002 - 10 - 1 They were Interested broaclyin our problem and fully appreciated that after all the analytical work had been done it would be necessary to interprot the data and to correlate it to safety standards in a way which would carry conviction with the authorities. They seoaod confident that this area wav one of their strong suits, cut it is far too early to assess their ability to contribute to ho present problem. D.V.N. HARDY JTTB/HMH 6.5.69. Footnote (See p.4 - Summary, 3) Compare Jensen's Jindings chat observed prior to 1944. o contamination was TRAN 021771 STLCOPCB4024887 WATER PCB-SD0000043003 /Monsanto ' _. ' , ,.0_ . .<;.i.o~, R. H. Munch - St. Louis Organic Research - South Second Street Don Olson has asked how we should go about reaching our objective of being the world leader in the Aroclor business. Under present con ditions this question should probably be changed to: How should we go about achieving maximum profit from dielectric fluids or dielectrics in general? There are two reasons for changing the question. One is the environmental pollution problem. The other is that technological needs in the dielectrics area are changing with ever increasing rapidity. Both are compelling reasons. Attached is a copy of an outline of our current electrical fluids technical program with the items listed roughly in order of priority. We discussed pertinent parts of this with Paul Benignus, Bill Kuhn, Bob Kountz# Quentin Thompson and Don Olson. ' In the dielectrics business -area we have reached.a .situation where it is necessary to have a more and more detailed knowledge of how our fluids will be used by our customers in order to promote sale of our products. This led Don to ask. whether our capacitor technical facilities are adequate or whether equipment additions'are necessary. I agree that v/e must have a more detailed understanding of capacitor technology. To get this, we must have available: ^ .1) Capacitor winding facilities 2) Capacitor impregnation facilities 3) High voltage Schering bridge to test the resulting capacitors 4) Corona inception and sxtinction measuring equipment 5) Accelerated life test equipment $100,000 10,000 5,000 ; 10,000 10,000 We have more or less adequate equipment for items 2, 3 and 4. We have had capacitor rolls wound for us by Electric Utilities. This has enabled us to start to get the desired information. We could decide to purchase items 1 and 5. Each of the above five areas present many complex prob lems which take time and capable, experienced manpower to master. It COMPANY CONFIDENTIAL . taan oseaoo IS* IO { 11 > PLAINTIFF'S exhwrw. l<5'?//'DE^CAT10N STLCOPCB4024888 WATER PCB-SD0000043004 2- - I ia risky to assume that we can.master all five of these areas in time to achieve our objective. We certainly cannot do it without adding at least one technical and one non-technical man to our group even if we buy the equipment. ' This leads me to propose that we should try to work closely with an es-* 2 3 4 t-aparit-m. wnnfn rhir>r to take advantage of his existing equip ment and competence in the five areas mentioned. The organization chosen should be: ' 1) Highly competent technically . 2) Trustworthy and cooperative 3) Located close to St. Louis if possible 4) One that will foster our business objectives. It would be ideal if we could work with G. E. on this basis. However, they are dedicated to a "do it yourself" policy. They are succeeding well enough at it that they probably would not be receptive. Two other possibilities would be Electric Utilities and Cornel Dubillier. Both of these would probably be receptive. I recommend that we explore the possibility of this approach to our problem. We should also have a policy on how we will use any technical advances made through this program. In the past, we have only considered giving such results to our Aroclor customers as a free present to keep them happy. We should consider whether or not there is anymore profitably way to use the results of our research. Perhaps we should have a joint manufacturing agreement with the organisation wc work with on testing our re search developments. We expect Mr. Bill Robinson of Cornel Dubillier to visit us on Decem ber 12. We need to clarify our thinking on the points raised in this memo. This is particularly true since Mr. Robinson has expressed a willingness to do testing work up through and including capacitor life tests on mater ials we recommend. We will arrange a meeting including you, Paul Benignus, Don Olson and me for early next week to discuss this situation and decide on a recom mended course of action. i- COMPANY CONFIDENTIAL R. H. Munch TRAN 058301 STLCOPCB4024889 WATER PCB-SD0000043005 X THE PCQ-POLLUTION PROBLEM January 21 and 22, 1970 St. Louis Meeting With General Electric Co. GENERAL ELECTRIC REPRESENTATIVES: " Mr. Edward L. Raab, GE Pittsfield, Mass., representing all QE locations Mr. H. CJerade, GE toxicological consultant Dr. K. Murphy, GS Schenectady, New York, Environmental Pollution Control MONSANTO REPRESENTATIVES: . H. S. Bergen, D. A. Olson, E. P. Wheeler, Dr. W. R. Richard, Dr. R. H. Munch, Dr. R. Keller, Dr. S. Tucker, W. B. Papageorge, J. 0. Bryant, P. G. Benlgnus A. Presentation and Discussion of Published Articles About Chlorinated Aromatic Hydrocarbon Insecticides, {Dtft1 etc,) and FCBa Mr. Wheeler presented to Mr. Raab a booklet containing most of the pertinent publications, to date, and indicated that additional articles will appear shortly. He mentioned that manufacturers of DDT and chlorinated aromatic hydrocarbon insecticides will tend to emphasize the finding and interference of PCBs as the Government hearings limiting or banning use of the insecticides are held. This lead GE to seek understanding of the scope, reproducibility, reliability and validity of the analytical procedures used by various investigators who reported finding PCB in concentrations as low as parts per billion. B. The Analytical Procedures Drs. Keller and Tucker presented details of Monsanto's GLC - Mass Spectrometric analytical capability and apparatus, as portrayed in Table 1. The sophistication of our analytical capability was emphasized to assure that our approach is the ultimate and is not surpassed. On this basis our views of the validity of results given in various publications are indicated in the attachments to Table 1. General Electric were impressed and completely satisfied with the scope of oar analytical capability and work. COMPANY CONFIDENTIAL TRAN 022030 J' PLAINTIFFS 11EXHIBIT NO._ FOR IDENTIFICATION as STLCOPCB4024890 WATER PCB-SD0000043006 2 C. Blodegradeablllty of PCBs Mr. Wheeler related that while Aroclor 1254 and 126o are being found, especially in aquatic environment, the lower chlorinated biphenyls are not being observed. It is anticipated that the lower ohlorinated members may be largely blodegradoable. Drs. Richard, Keller and Tucker discussed biodegradeability studies by Monsanto at Ruabon and elsewhere. These studies appear preliminary and not conclusive. Much more needs to be done in this area to allow GE to draw conclusions. Since the literature indicates that trichlorobenzene and tritetrachlorobenzene are not susceptible to biodegradation, OB are Intrigued with the absence of reports about finding these materials in the environment. The obvious implication is that since these materials are used with the higher chlorinated PCBa found -- the source of the latter is not from dielectric fluids. However, it was reasoned that chlorobenzenes may not remain duo to their relatively higher vapor pressure or may not be found to date because they have not yet been zeroed in to the analytical spectrum. D. Status of Aroclor Studies At Industrial Bio-Test. Table 2. In essence results reported by Mr. Wheeler on chronic animal toxicity tests and animal reproducibility studies underway are not as favorable as we had hoped or anticipated. Particularly alarming is evidence of effect on hatchability and production of thin egg shells regards white leghorn ahlckens. The studies Involved Aroclor 1242, 1254 and 1260. Some of the studies will be repeated to arrive at batter conclusions. E. The Location of Aakarel Transformers. Table 3. Messrs. Raab and Benignus formulated Table 3 to portray the use and locations of askarel transformers throughout Industry and our commercial and residential areas. On discussing these askarel transformer applications Mr. Raab was most Impelling and forceful about the non-replaceablllty of transformer askarel fluid and the critical or essential use and need for askarel transformers, which have safety from fire as their outstanding virtue. Without dwelling on details and Instead carried to the ultimate, the concensus is that without availability of askarel transformers large cities like New York would be shut down with no power. Certain industries that rely mainly on askarel transformers would go down with no power. Without Aroclor capacitors moat of the lights across our country would go out and motors in air conditioners and many industrial applications would not run. CCivir ANY CONFIDENTIAL TRAN 022031 nd STLCOPCB4024891 WATER PCB-SD0000043007 3 Frankly, no one could think of a suitable replacement for transformer aakarel fluid. Fortunately, Aroclor 12*12 with promise about blodegradeabillty is used in most all of the . Aroclor type capaoitors. Moreover, possible favorable isomer rearrangements are foreseen in the case of Aroclor 1242. Need to control, accumulate and properly dispose of scrap aakarels is unquestionable in light of the PCB pollution problem, and essential toward maintaining the use of askarel dielectrics. At GE alone apparatus in which askarel fluid is used represents 100 million dollars annually. About 60% la in the capacitor area and 4o^ represents transformers. GE requested and we were pleased to give Dr. Murphy their Environmental Control man, a list of all GE and other locations receiving Pyranol shipments in 19^9. This amounts to about 16 million pounds of askarel fluids with economic worth of near 2.5 million dollars. This listing Included 244 different locations of which 115 were GE plants and serviae shops scattered throughout our country. Of course in addition to dielectric use in hermetically sealed capaoitors and transformers major amounts of PCBa are used as Plasticizers, Industrial Hydraulic Fluids and Heat-Transfer media. F. Environmental Sources of PCBs From Dielectric Applications 1. Spills 2. Disposal of waste 3- Ultimate disposal of product -- for failed apparatus 4. Ventilation of operation for employe protection 5. Waste from containers 6. Field on service failures 7. Repair and return apparatus " service shops" 0. Considerations of Degradation Disposals 1. PCBs up to and Including 3 chlorine atoms appear biodegradeable in preliminary laboratory work. 2. Thus far there is no evidence that higher chlorinated biphenyls will biodegrade. COMPANY CONFIDEN l IAL TRAN 022032 J' STLCOPCB4024892 WATER PCB-SD0000043008 4 3, According to the literature TCB and TTCB biodegrade at a very slow rate. 4, Chemical, catalytic breakdown--would probably require high temperatures. 5, Incineration will require 800C. and 5 second 3ojourn time. HC1 scrubbing would be required. H. Estimated Annual Amounts of Contaminated and Scrap PCBs Prom The Electrical Industry 1. Prom The Transformer Indus try: a) In plant and field spills are small and controllable with adsorbents, which should be Incinerated. b) Near 2 million pounds a year of transformer askarels are sold to service and repair shops. These people do not manufacture new transformers, although on occasion they may fill new transformers sent into the field without fluid. As these service shops are devoted primarily to repairing faulty transformers, we can assume that as much as 1.0 million pounds annually of "scrap" is generated. Most of this has been dumped or disposed of in streams. c) We estimate that probably 150,000 pounds of this is arced beyond reworking and needs to be incinerated. The remainder may be reworkable by distillation. 2. Prom The Capacitor Industry: a) Collectable waste from normal capacitor impregnation operations amounts to about 850,000 pounds annually. Most of this should be reworkable via simple take-over distillation. b) Scrap, badly contaminated with polypropylene, epoxides, solvents, oil, grease and "Junk" is generated at not over 50,000 pounds a year. This material should be incinerated, along with the 150,000 pounds of scrap from transformers. c) Power capacitors are designed to last over 30 years. Modem motor runs may last 10 years 'and the small lighting ballast usually last not over 10 years. Eventually and cumulatively there is a large potential of field-failed capacitors. Fortunately Aroclor 1242 has been used almost exclusively since about 1950. COMPANY CONFIDENTIAL TRAN 022033 STLCOPCB4024893 WATER PCB-SD0000043009 H ^- The failed units are disposed of In Industrial dump3. In case nf ballasts the Aroclor capacitor along with the transformer imbedded in asphalt or encapsulated in epoxy resin, all encased in a metal box are discarded as a unit. Thl3 is emphasized to Indicate that incineration of such apparatus is not applicable. 3. From Containers Most askarel moves in bulk, tank cars or tank wagons, which do not present a problem. > It is questionable that drum shipments may present a problem. The drums can be used for returning scrap. I. Monsanto's Program To Handle Scrap 1. GE asked what is Monsanto's plan about reclamation of scrap PCB from aE plants, service shops, utilities, industrial users, commercial users, etc.? 2. What is our view about a "Buy-Back" arrangement? 3. What arrangements will Monsanto make for Incineration? Disposal in suitable land-fills? Reclamation by distillation at Monsanto? 4. To date Monsanto's posture is: a) We have 'taken "good quality" scrap from GE13 capacitor plant at Hudson Falls and had it reworked by simple filtration at Flndett. This Findett arrangement Is not practical nor economical. We paid GE 1 ^/lb, for this "quite good" Aroclor, plus 1.9 ^/lb. freight. Findett charged 2.1 ^ to filter this material, making our coat 5 */lb. b) 130,000 pounds of somewhat lower quality scrap from Westlnghouse capacitor plant has accumulated at Findett for lack of distillation equipment. c) Scrap from GE's Ft. Edward plant appears to need reprocessing by distillation. d) About million pounds of "bad scrap" from GE Hudson Falls, has been disposed to a land-fill in New Jersey. Monsanto paid half of the freight cost. e) A car load of scrap transformer askarel from Westlnghouse, South Boston, Virginia is being sent to W. G. Krummrich for reprocessing. COMPANY . CONFIDENTIAL TRAN 022034. STLCOPCB4024894 WATER PCB-SD0000043010 6 f) We advised Westlnghouae, Sharon to incinerate 12,000 gallons of oil contaminated askarel. g) We talked with Sangamo, Picken, S. C. and strongly . urged them to discontinue present disposal. 5. The above "take-back" arrangements have been made on an individual and experimental basis. We have no fixed "buy back" arrangement, regards answering GE's question. 6. W.e have no established process for reclaiming either capacitor or transformer scrap. 7. We have no Incinerator for disposal of totally unreclaimable material, 8. To date snd for the foreseeable future our only effective disposal is ;o a land-fill. While this Is not desireable, it is better than indiscriminate dumping. Transformer Askarel Blends Discussed With GE. Table 4. Table 4 lists the transformer askarel blends reviewed with GE, 1. GE Rome has discontinued use of Blend A due to combustibility of arc formed gas. For this same reason, as dictated by their legal people they will not use Blend B. 2. Today both GE, Pittsfield, Mass, and Rome, 0a. use Blend C (Pyranol A13B3B), which they mix themselves. 3. Blend D optimizes the Aroclor concentration in conformance with GE13 requirements for non-combustibility of the arc formed gas and with the pour point requirements. The price is in direct conformance with our previous quotation for Aroclor 1242, when GE was using this at a concentration of Q0$ by weight. TRAN 022035 COMPANY CONFIDENTIAL- fi STLCOPCB4024895 WATER PCB-SD0000043011 I 3- 6. PCB3 have been brought into hearings proposing restrictions or elimination of DOT, PCHI. 7. As manufacturer of PCHI's fight for their life, attention will be directed to PCB3. 8. To our knowledge PCBa are not being found in terrestrial birds or animals, but DOT and PCHI13 are found. 9. PCBs are not being found in the eco system without the presence of DDT or PCHI'3. 10. PCHI'3 residue are found without PCBs. 11. We have no evidence that anyone has found lower PCBs except that Dutch researchers found PCBs in roaches. 12. There is no evidence of natural sources of PCBa nor any source other than industrially produced and used. 13. PCBs in a single dose have-a low order of acute toxicity and are no aignlfioant problem to rata, dogs, chickens, fish and humans. 14. Based on six months of chronic studies in rats and dogs some PCBs are "moderately" toxic and more so than DOT, but less toxic than some of the other chlorinated hydrocarbon insecticides. 15. Some PCBs affect rat reproduction, (10 ppm. apparent no effect levels). . 16. Some.'-PCBs affect leghorn chicken reproduction (100 ppm.). PCBs have no affect level for chickens, estimated 10 ppm. 17. Some environmentalists are claiming that the PCBs 'pose a threat to humans, are so "philosophizing" In publications. 18. One published page Indicates that PCBs are a3 bad (or worse) than DOT in microsomal enzyme effect. What is algnifleant? Since many chemical compounds react similarly.' 19. Human experience In production of PCBa and their use has been favorable. Less than 20 instances of illness known to Monsanto Company since 1940-45. Proper precautions were not always followed. ' 20. CE Company's use of PCBs as dielectric fluids, has been extremely favorable without illness throughout 4o years. 21. Monsanto Company is convinced that analytical techniques and date from acme laboratories investigating PCBs are reliable and that conclusions being formulated are valid. COMPANY CONFIDENTIAL TRAN 022037 STLCOPCB4024896 WATER PCB-SD0000043012 i 9- 22, Monsanto Company has not run duplicate analysis on samples reported in the literature. L. What GE Desires 1. GE seeks that Monsanto take no precipitous reaction to the PCB problem that would result in withdrawing supply of Aroclor 1254'or 1260 to OS. ' 2. The consensus is that no suitable replacement for transformer askarel fluid is foreseen. 3. In event of development of a suitable fire-resistant fluid replacement for askarel, Mr. Raab emphasized that a minimum of 2 years testing work would be required before commercial us could be adopted. 4. In reply to Monsanto's legal question whether with continued use of Aroclor 1254 and 1260 0E would assume sole and complete liability -- Mr. Raab answered. No] To substantiate his reply, Mr. Raab oltad case examples involving OE where damages were sought and collected, even though GE was only the third party. He further stated that any arrangement seeking to delegate and confine liability to GE relative to the PCB problem would be worthless. 5. GE seeks to know the magnitude and time of Aroclor price increase that would result if Monsanto discontinues sale of Aroclor for non-electrical uses, or if pollution control expanses warrant a price Increase (as anticipated), 5. GE seeks to send a letter to their plants and service shops and major users of transformer askarel, such as the utilities giving notice of the PCB problem and guidance about the most suitable controls. 7. In the case of GE service shops scattered throughout our country it is unrealistic that these people would assume any expense to return scrap to Monsanto. The 'minimum we can expect 13 that Monsanto pay the freight charges, and reimburse for a suitable container to avoid additional and excessive contamination. , This emphasizes need for Monsanto to have an effective reclaiming process. Otherwise, the best we can expect from service shops and many other users is to continue to dump in a land-fill and stop discarding into the sewers. COMPANY CONFIDENT i A L j' TRAN 022038 STLCOPCB4024897 WATER_PCB-SD0000043013 10 8. GE realizes that Monsanto is caught between the explosiveness of arc-formed gasses problem and on the other hand the PCB pollution problem. Realizing possible unfavorable outcome of the arc-formed gaa problem, GE desires to withhold the PCB problem from involvement at NEMA, ASTM, IEEE, EEI and ASIA at this time, (making it an industry-wide problem) pending better in-depth understanding of the PCB problem. 9. GE strongly seeks to continue manufacture of askarel type transformers, because in many applications this apparatus cannot be replaced with mineral oil nor open dry, nor seal gas dry type units. Mineral oil burns. Open dry accumulates dust, lint, moisture and can then fall with explosion and burning. Sealed gas dry types are very expensive, space consuming and very difficult to maintain sealed. Transformer design and application la governed by National Electric Code, by local building codes, Pire Underwriters, NEMA, IEEE, ASTM, IEC, ASA, Insurance companies and others. Because of the diversity of organizations involved a directive to discontinue askarel transformer manufacture would assume highly complex proportions. ' P. G. Benignus January 26, 1970 COMPANY CONFIDENTIAL J- TRAN 022039 STLCOPCB4024898 WATER PCB-SD0000043014 ! THE PCS-POLLUTION PROBLEM SUMMARY OP JANUARY 21 AND 22, 1970 ST. LOUIS MEETING WITH GENERAL ELECTRIC COMPANY I. Monsanto has highly sophisticated capability, not surpassed by others to detect PCBs in the parts per billion range. II. Aroclor 1254 and 1250 are being found, especially in aquatic environment. Aroclor 1242 and lower chlorinated PCBs are not being observed. III. Studies are underway to better define the possible biodegradeability of lower chlorinated PCBs. IV. Literature citations indicate that tri and tetra chlorobenzene do not biodegrade, however, they are not being identified in the environment. V.PCBs have been brought into hearings proposing restrictions or elimination of DDT and other chlorinated hydrocarbon insecticides. PCBs are incriminated by association subject to rechecking. VI. Due to combustibility of arc-formed gas, GE will not use Aroclor 1242 nor any blend with less than near a 1 to T ratio of chlorine to hydrogen, for transformers. This Judgement la baaed on GE legal people citations of precedent court actions assigning liability against GE for transformer accidents. VII. As no suitable replacement for ClE'a transformer Pyranol blends are foreseen, GE seeks that Monsanto take no precipitous reaction to the PCB problem that would.result in withdrawing supply of Aroclor 1254 or 1260 to GB. VIII. In reply to Monsanto's legal question whether with continued use of Aroclor 1254 and 1260, GE would assume sole and complete liability -- their spokesman answered Noi He cited legal case examples to substantiate his response. IX. GE strongly seeks to continue manufacture of askarel type tranaformrs because in many applications this apparatus cannot be replaced.with mineral oil types, nor with open or sealed dry types. COMPANY ' CONFIDENTIAL TRAN 022023 2 X- GE urges control of the PCB problem through accumulation and proper disposal of "scrap". Incineration, distillation, catalytic and bio breakdown are to be investigated by Monsanto. XI. At the present time, land-fills continue as our sole disposal for arced or "poor quality" transformer askarels. P. a. Benlgnus COMPANY CONFIDENT'A'. J" tran 022029 I STLCOPCB4024900 WATER_PCB-SD0000043016 DISTRIBUTION LIST - FUNCTIONAL FLUIDS ARGENTINA - G. S. Corley J. C. Pando BARBADOS - J.A.K. Archer BOLIVIA - E. Zblnden BRAZIL - J. F. Valente A. Oraovay CHILE - J. Brelt G. Johann3en COLOMBIA - V. Zaret3ky D. Hernandez C. Iregui CENTRAL AMERICA - M. Caceres ^PANAMA - R. Miro S.A, COSTA RICA - M. Silesky *HONDURAS - 0. Benavides ^NICARAGUA - C. Rivas MEXICO - Mexico City L. Ysasl H. Bravo G. Silva M. Medina (c&B) Monterrey A. G. Villareal PARAGUAY - S.A.C. Manuel Ferreira PERU - H. Pantigoso B. Gonzales PUERTO RICO - Dr. R. P. Fernandez SURINAM - H. J. de Vries TRINIDAD - C. A. Rodriquez URUGUAY - B. Bemat Send their copies via M. Caceres. VENEZUELA - H. H. Schlaubitz J. Navarro DOMINICAN REPUDLIC - J. Roque ECUADOR - Guayaquil A. Speck R. Arosemana NEW YORK - M. Maglnnis Quito E. Lucio EL SALVADOR - II. Mendoza GUATEMALA - J. Mansylla HAITI - V. Wynn JAMAICA - E. Perez, Puerto Rico TNGS 008493 PLAINTIFF'S EXHlBrr NO.. FOR IDENTIFICATION q-ik-qs DATE: RPTR: STLCOPCB4024901 WATER PCB-SD0000043017 F.J. Cumargo/C. Paton-St. Louis j# E< Tuckcr-St. Louis October 1, 1971 N. J. Knmper-St. Louis bcc : W. B. Papageore-82SK J.J. Roder-B2SQ POLYCHLORINATED BIPHENYL PRODUCTS See Diutributlon List P.Q. Benignus-D2SH D. R. Pogue~B2SJ W. S. Clark-B3NE T. L. Gossage-B2SL The public concern over environmental pollution due to PCBs continues In U.S.A. and Europe. The public and Governmental agencies arc becoming increasingly ooncered with the levels or PCD found in fish, eggs and poultry. In fact there have been several seizures of eggs and turkeyo made by U.S.D.A. in the past Beveral months. Hero io a status report by country1 1, U.S.A. and Canada Monsanto hot voluntarily banned sales of PCD for all applications except dielectrics and a few restricted heat transfer ays terns. 2. UiC_ # Monsanto follows the same voluntary ban as in U.S.A. 3. Sweden - The Swedish Government has banned the import of all PC3s and PCJi-containing products excopt for the dielectric industry, 4. Holland Ad. the attached news item shows Holland is actively considering a ban on TCBs. ` 5. Germany Monsanto will attend a meeting on PCDs at the German ?'lin.t3try of Public Health in September. TNCS 008494 STLCOPCB4024902 WATER_PCB-SD0000043018 -4 - Please note tnat no Arcelor produat show.'.'! be used in any oynter.i processing or handling food or related products, food wrapping or container materials, pharmaceuticals, animal feed stuffs or .-.otable v.vater systems. Labels to thin effect will appeu on all f-roclor drums. You may wonder where tills places us with regard to competition. We think we are In a stronger position than Prodelcc or Bayer, eto. Why? 1. You have had replacements for plasticizer PCBs In your hands for over a year. There la no sign that Prodelec ox' Bayer have any yet. 2. Our PCB competitors cannot claim this is solely a Monsanto problem. Bans in U.K. and Sweden and a proponed ban In Holland mean European producers have a problem too. In Japan there la a clamor for a ban. A customer will gain little Insurance by switching suppliers. 3. U.N. restrictions on PCBs is a real possibility at their meeting which is only about six months away, Monsanto 13 genuinely interested in preventing ecological problemn from lt3 products. We would rather restrict our sales on a voluntary bnnia and help our customers use replacements than be suddenly legislated out of buslncaa. We want to adopt a responsible attitude towards all ' countries, peoples and communities where v/e operate. We want no violations of our policies on PCDs anywhere. The PCB situation has engaged a lot of the time of higher Monsanto management, e.g. John R. Eck of our main Board of Director* and John Mason (former Assistant General Manager of Orgartlo Divlcion and now a Group Director in Monsanto Industrial Chemicals Company.) We, therefore, ask your active co-operation In putting these policies'into offeot without delay. If you have any questions, please contact Frank Camargo, Thank you. F, J. Camargo TNCS 008497 FJC/CP C. Paton STLCOPCB4024903 WATER PCB-SD0000043019 .A ' X. T. Johnson Of. Louis February 16, 1970 __ P. J. A. Mar si'. - Bi R.A. Damiani - Chicago G.F. Fague - Detroit R. A. Garcia - Akron R. Garnsworthy - Melbourne J. A. .Heilala - Akron R. Irwin - Houston J. S. Pullman - New York J.J. Roder - Chicago R. Giles - Melbourne D. E. Roush J. R. ]'alien D. A. Hall D. R. Pogue D. F. Smith D. A. Olson Attached is a list of questions and answers which may be asked of you by customers receiving our Aroclor-PCD letter. You can give verbal answers; no answers should be given, in writing. If the customer asks a question you can't answer or if he wants an . answer in writing, then send his questions to me and we will answer from.here. ' / We want to avoid any situation where a customer wants to return fluid. The new reformulated products will be available within a month. We would prefer that the customer use up his current inventory and purchase Pydraul 625A, Pydraul ACA, Pydraul ACA Winter Grade and Pydraul 540A when available. He will then top off with the new,fluid and eventually all Aroclor 1254 and Aroclor 12 60 will be out of his^system. We don't want to take fluid back. Sell him the replacement. We must be very positive in our approach with each customer relative ro our decision to eliminate the use of Aroclor 1254 and Arocl<>r 1260 in our Pydraul products. V/e (your customer and Monsanto) are not interested in using a product which may present a problem to our environm.ent, We certainly have no reason to be defensive or apologetic about making this change. The decision to change makes good sense and our customers should commend us, not c riticize our actions. No ai e has forced u3 to make this TftGS 008683 STLCOPCB4024904 WATER PCB-SD0000043020 change. We have done it to keep our customers out of possible trouble. yhey should appreciate our effort, and may with us as a custom/r on the reformulated Pydrauls. To make this change has cosh us re search monies and time. Fortunately, we possess the technical skills to make a change in our formulations without affecting the performance of products. Be positive. Take the offense. Don't let a customer or competitor intimidate you. I doubt if our competitors know whether their product could present a problem to our environment. You might ask your customer if he has ever asked Houghton or Stauffer, Carbine, etc. about the effects of their products. We should also recognize (point this out to your customer) we must clean-up. The Chemical Week article gives him an idea of laws in effect in his state. Read this yourself. Be familiar with the data on each staLa in which your customers are located. Use this in your discussions. We have no replacement products for Aroclor 1254 and Aroclor 1260, We will continue to make these products; however, customers will have to use their own judgement on continued use. Wc can't afford to lose one dollar of business. Our attitude in discussing this subject with our customer will be the deciding factor in our success or failure in retaining all our present business. Good luck. (We have also attached a copy of the letter sent to transformer cus tome r s . ) N. T. Johnson lb TNCS 008684 STLCOPCB4024905 WATER PCB-SD0000043021 POSSIBLE CUSTOMER QUESTIONS ON PCBs Question 1 PUBLICIT Y / Will you send me copies ? // An.-iwc r: In the U.S., newspaper articles have appeared in the San. r raucisco Chronicle on Feb. 3-1, 1969, tlu: San Francisco Examiner on Feb. Z5, 1969l and the Hartford Times on Aug. 3, 1969. Numerous articles we^-e generated by che Wisconsin. "DDT Hearings" in May, 19(617. At the hearings, witnesses discussed (lie problem, of PCDs as "interfering substances" in their search for DDT in the environment. PCBs, they said, produced peaks on a gas chromatograph similar to the peaks produced by DDT. In no case was PC13 indicted at the Wisconsin hearings. Copies of the articles will be made available on reeptest. Regional managers should contact E. V. John, Public Relations Manager Organic Chemicals Division, in St. Louis and copies will bo for warded to the customer through the regional manager's office. in addition to the newspaper articles mentioned liIjovc, there have bee:', radio broadcasts. At the time of the San Francisco Chronicle and Examiner articles, radios m Lite San Francisco area also carried the story. in August, the sports editor of the Ha rtfc rd Time a syndicated a radio broadcast on the subject of PCBs, ana in Dec., 1969, the Canadian Broadcasting Co. (radio) carried ar. interview they taped with a mo rubor of our rrc rLcai department. Giio s tion d Were Monsnato's Aroclors specifically mentioned in these article s ? If so, which ones? TNGS 008685 STLCOPCB4024906 WATER_PCB-SD0000043022 ,\n s'i' r Monsanto1 s Aroclors were mo :u:ono ci in some 01 the articles ;-,u; only in Clio San Francisco Chronicle story in Fob. , l?i9, was Aroclor 1Z6Z specifically rr.eruioued by number. In several of tbc articles, Monsanto was also identified as the sole LI. 5. producer of polychlorinated biphenyls, marketed under the tradename of Aroclo i*. Question 3* V/haL did the articles on Lhc PCD problem say? An Li wc .- Since the outset of the "PCB problem", when the first article appeared in the U.S. press in Fob. , 19G0, Lhc whole question has Ixicn closely interwoven with Llie question of DDT as a possible environmental contaminant. . The Sin Francisco Chronicle article carried a headline, Menacing New Pollutant. 11 'In rather sensational styLe, it identified PCB as a threat to birds,and humans, highly toxic in a gaseous state and related to known cancer-causers. PCB presence in the environment is rising swiftly, the article stated. i The Examiner article called PCB a "plastic pollutant in l!ic Bay cad Mothers1 Milky*' This article called PCB an "alarming" new chemical pol/futant that is playing a role in the declining peregrine falcon population, has hen found in mothers' milk, anc: is the addition to a Growing list of chemicals in the ocean-------- the newest symptom Gi/man's chemical invasion of the ocean. " Tire sc two articles quoted Dr. Robert Rise brougk, a researcher at the Institute of Marine Resources in the University of CMifo rma1 o Department of Nutritional Scientists, on the detrimental effects of PCBs. Eater Dr. Risebrough said he had bean misquoted in some r.ewsoaoer stories. Tin: I-la rtfo rd Tirne a uory < mi*;': -'l ; .. .' Bess sensniioual laan Llie ban J- rnucisuo article.Lne Tir:.n:. g.V'e u.a '.erount of PCBs being found in. Lhc environment and the studies :.:de r w^y to determine their biological effects. This article, -*VJ Dr. Rise Itrough, tends to clear PCB of blame. TNCS 008686 STLCOPCB4024907 WATER PCB-SD0000043023 Article:* generated Ijy tee Whsccn Sir. DDT hoare-.^j gem-, r discussed PCD as an ir.ie me ring substance discovered in seter.-...- _1 sc:arcii for DDT in the c a v trout no nr. Dr. Rise brougn said at t::c hearings that there w_s no proof at the iron:;-::: that PCD r.lcr.e can cause thin eggshells, one of the phenomenon that he had discovered in studying the declining population of the peregrine falcon. - / / / / LEGISLATION Question 1 Arc there any Fndo ral/Slalo/local laws mule r wlm-li the use or/ discharge of Aroclors could he prohibited? Answer _ No existing Federal, Slate, or local laws prohibit the discharge of Aroclors. However, in a number of states the basic water pollution control legislation is so broad that state agencies can prohibit chemicals, deemed necessary, from being discharged. Question 2 Is the DDT and the PCB problem related? An swr r We arc not a manufacturer of DDT or outer chlorinated hyd rocari.on pesticide and, therefore, have no knowledge of the sc riousne ss of the charges against DDT other than what has been so widely publicized on TV, in the press and in technical journals. To 1 lie extent that both DDT and PCB are chlorinated hydrocarbons, then there is a similarity. They are sufficiently different in their chemical structure ^ ; however, that it would be entirely wrong to assume tnat both behave in the same way in the environment. There is another and more obvious cl iffc r"c nee . DDT and other chloriuaLvd dlij r-Jt.irbo.i pesticides were specifically designed fer a job that obviously leads to their bcing scattered in wide spread fashion across the countryside. Rain, birds, wind, insecls further scatter these pe sricide s -n u:t unc ent Tollable manner. PC3s are not used in this ` i ashion and TNCS 1/ i Il 008687 STLCOPCB4024908 WATER PCB-SD0000043024 Ivio.usnnlo has never sou^u to promote this. This, we be!;_ v_, an important distinction that should act be overLeoxed if DDT ar PCB arc linked as a common pollutant, of the ei.virnitmc.-.L. To our knowledge PCBs have never beer, identified in the absence 01 DiDT or other chlorinated hydrocarbon pesticide:.. Que s tion 3 Could it be PCD that's causing the environmental problems and not DDT ? An swe r: We believe that present-day GDC and mass spcclromctric techniques arc sufficiently accurate to be able to differentiate lietwccr. DDT, related pesticides, Uicir metabolites and PCD. Question 4 What authority do SLaLe and lucal governments have in banning/ controlling the use of PCBs. ' ' A.n awe r: They do iiavc authority to ban or control use of any substances they consider harmful. Quo s tion 1 EFFLUENT AND ITS CONTROL P.ow do 1 dispose of Aroclor lZb-1/1260, etc. effluent from my plant ? An swe r: V/e would suggest collecting n?I process effluent, equipment washings, tank or drum washings and then regularly taking to the nearest toxic materials dump. You may also be able to use a sanitary land fill if permits arc issued for this in your locality. We dotv't recommend feeding this material to local sewage treatment plants o r taking out to sea in drums for dumping. These methods do not ` / // TN&S 008688 STLCOPCB4024909 WATER PCB-SD0000043025 solve Lhe problem of contamination. V/c uro .-kin a cn ' - disposal of these material:. by incir-.e vuiior. r..-. Our work in these areas has not yet reached -in stage V.\v: v j wc can offer practical suggestions. I: is of in:--rc-&t to r.c:_, however, that research is underway fo find caL. lyses to DDT self-destructive. The possibility exists Lhut \vc could find catalysts that would destroy PCBs in Settling tanks con structed to catch all your effluents. , Question 2 Can I test my effluent to see if my effluent has no Aroclor ld5-l, . etc. ? Answer: Yes. Analytical c r. i i i^rr^i available that can do this "if"Che proper technique is used. The basis of the method is GDC or gas liquid chromatography. Arc you or anyone in your company familiar with this? Do you have GLC equipment? LC you do, we can send you a description of a method that could identify PC3. If not, there may be a good analytical testing laboratory in the vicinity where you could send samples and rely on the results if you want to test your effluent. Question 3 What is a "safe" PCD level for effluent leaving my plant? A ns we r: As our letLer points out, parts per million (ppm) and parts per billion (ppb) have been mentioned in the published articles. There is still a lot of doubt as to how absolute any quoted values are. To bring this into the realms of reality, this definition-of ppm and ppb may help clarify things. To give you a practical example, the escape <?f one-two gallons STLCOPCB4024910 WATER PCB-SD0000043026 ' ^ Qui.'buon -1 You must have quite a uon'./ol problem a; yov.r oi__ would think Monsanto1 s Aroclor plants are A.. :.ia or polluters--how ore you handling control? Answc r: The Aroclor products wo make to sell at a profit, dictate maximum housekeeping, minimum josca. process is a. "dry process" or closed system. so ccor.o.v.ics T .'.a C. Question 5 --- . , 1 low does Monsanto think Aroclors can pet into the c nvi ror.rru. .a-, and cause so much pollution? ' Answe r: Disposal, leakage from systems using it, spills, etc. Question 6 . II I analyse my effluent stream and find pub there, how do I ` know it didn't come from air-borne contamination or was present, in Live process water that I pump from the XYZ river into my plant? Answc r: . Analyze water entering your plant and compare. Tcere is a method available for sampling air. ' Que stion 7 You seem to think from the tone of your letter that the source of pollution, is from effluent disposal into streams. Ir. my process, Aroclor 125-1, 1260, ate. vapors escaiia. XIV.at pre cautions can I take to prevent (a) employee problems and (b) escape at vapors into tin- at in os pi u-ru ?, TNGS i 008690 STLCOPCB4024911 WATER PCB-SD0000043027 Question 2:-' What's the diffc re nee between a chlorinated hi ,kyl ;_-.b a tcrphenyl? Ar.sv/ii r: A Lcrphenyl has three benzenes linked together and bicker.y! only wo. They arc, the re lore, similar but dAforor.t, just as Naphthalene is diffcrent from benzene. Que s tie ri 3 Why should PCS be an environmcntal contaminant and chlorinated lerphenyls not? Answer: 1 don't think there is any positive answer on this and I can't give you any theories. However, 1 would emphasize teat not all PCBs appear to be contaminants. Those such as Aroclor let2:1, 1232, and 1242 haven't been identified in marine, aquatic and wildlife environments. Chlorinated tcrphenyls - at least those made by Monsanto - have not been identified in the environment c-iute Que stion 4 Since you sell other PCBs beside Aroclor 1Z54 and 12SQ, why arc they not found in the environment? , / / / An swe r: One reason could be that they biodegrade and hence .never butid UD to a level where they can. be labelled persistent contaminants. Therefore, although you would find it in an effluent stream if you analyzed it just after you peered PCB into it, its absence when a river, for example, is analyzed downstream at a later date would indicaLe degradation by bade rial.-organisms. Wo are actively working on this aspect of biodegradability in our laboratories at this Lime. Results of this type cf work won't come to hand quickly but our preliminary work on PCBs of less than 54% chlorine looks promising. TNGS 008692 STLCOPCB4024912 WATER_PCB-SD0000043028 Cue slioi, H Is the reason lor no: resu .;v.iLaiia4 yuur 10 "r for approvn.1 of Arcelor r-A: 0 due to true PCs oa slici" / ? . No. Question 9 V/cat's t-Ue problem .lion? Anwe r: V*c arc brinuiue a now solid Aroc.lov plahL oii-;; ireum in the* next Lwo-tiiree months. iVe u t.U lo m.mc sure it prci.'si.^. j the sonic quality Aroc^u:' u-loO we usee: in our jnecixr.t; studies for Lite FDA. Once we're sure tout's 0. K.-- and we feel it will be - - the n .,jt the petition moving ajaiu but F DA clearances do tx-i.o Dine. Question 10 Dues tr.is PC3 publierty mcun met FDA ttirov.u 01 Arcelor 5-160 is /tot ^om.; in be obtained? / v-.-'o nave no reason to china the ewe- tally; s arc refuted. . mGclor A r.oc clientictill/ a PCD. Tuc delay resulted front me ace<.; to set up certain analytical e.otlioA to sm-ofy FDA. 'Jr.iinvolved analytical inatrunu.: luetic;; and is no in;* cempte ted. .;m . It is my uncle r standing '*' plan to rejubm.tL our petition o__' 0. I personally don't know >.la. exact date. . '. CON'i v. s: * r> .me ev.ys at G.: l r-.u v. iz.tr v.'jx.n; x -e w.tn me v. TNGS 008694 STLCOPCB4024913 WATER_PCB-SD0000043029 o . .r..-;v.*c 7 \ j i', 1 lius ivoi: io o'v.Ui'. Q; ta- ::on bkcaid 1 look Ter replacement icr Arcelor 1 /dr- 1 /'_ 11A3, etc. Answer: ' I think cnly you can decide this. How easy v<oulc- this; he ter you? Do you. have any other repiucernervt product ir. mine ? Question o:-: Does ivionsunto have rtipla.eeincut produces tor Aroclor Id5-1 and 1160? Ans-e r: As you know, wo have over oimiy plastic Z C 1 a O Li r*t c.aci t.tore's quite a 'art of product ir.tcro.iuy so iL is possible LhCil there is anom.er product ir. our line that a 1 tj ijtutt ..u4.4, V/h.at rosin do you use? l-'er'eaps wa coni. ; look c v ches. L U 1... / s.lu A lie a i - - ullt.t tJ ii - L.-*; C<_ :.: cl ire LIuc A.\ou.>.. $ I've Ofjc: it witr me. olsdUO ;* i' hCoil ;: I* Wl on s-aiiuo orlcing ers vc: ;:-i ^conr.c rves: **or Aroclor i-:-r F-'.id 1160? . These- research Tallows tire always busy on tluuqs like -.tat. To some people Aroclor Ids-- :. d 1260 h; vi- i .'a 6 -- quite- apart Trent pro sC-m. p.: .ic.ity c-.: hCO. .\rot hf 1_ r - is .'airly volatile. /. r c.lor 12.60 L very vn.Cs.e. . ; d.i.hhuid. to handle. 'For poly .> u.l .'Lie sealants, lor on:. i: pi. . ;iw u-c hr.: cal people in o.. Louis cave jurt sc.il us du... o:i p.-:-u--..c.s t.ir.t w._.. b.;rc\n eerier train Aroclor 1-.6-1 in poly ~-rd :.k: .--i-. .s. h-uybo there's something here Ter yo.. tc lee:, t.t. .Let's TN6S 008696 STLCOPCB4024914 WATER PCB-SD0000043030 BCCr P. 0. BENIQNU3 D. A. OLSON July 7* 1970 Mr. (Jane Lewis ?. R. Mallory Company Kayneaboro, Tennessee Dear (tenet X apologize for the delay, but after further travel end a Ions holiday weekend X aoi finally sending you my comments regarding the oontrol and disposal of Aroolor*. X appreciated the time you and your oolleaguea were able to spend with Kandy Oraham and me and X was pleased X had the opportunity to tour your plant, slnoe this gave me a better understanding of your overall problem* Gtene, of all the plants Z personally toured, yours had the biggest challenge to reach the objectives we are striving for. I tell you this not to embarsss you but, hopefully, to give you some feel for the magnitude of the problem* Plrst, let us consider the welfare of your employees. Aroolors, being chlorinated hydrocarbons, should not be permitted to exoeed 0*5 to 1.0 milligram per oublo foot of air In the work area. In your operation. In spite of an operating ventilation system, the presence of Aroolor was noticeable by the blue hare present and Insensitive as .2 have become, the amount was high enough to cause eye irritation which persisted for several hours, after the exposure. Another area of employee exposure Is dlreot skin oontaot with the liquid Aroolor. Contaot should be eliminated by operating changes or by providing protective gloves and clothing. . COMPANY CONFIDENTIAL TRAN 061672 STLCOPCB4024915 WATER PCB-SD0000043031 -2- To prevent tha escape of PCE'fl to the envlroocaant call* for a level of control and housekeeping many of us hara never been asked to achieve In the past. Every effort oust be made to prevent leakage and spillage. Mainte nance must be kept at a very high standard, for those areas Wiere leakage end spills will occasionally occur, catch pans stunt be provided. These pons oust drain to - a collecting basin or be emptied tgr responsible employees on a scheduled basis. Mixing of Aroclore with waste water atreams should be avoided since separation of PCS'a rrew water can be costly. If airing cannot be avoided, a catch basin end settling pond ehould be provided to separate the heavy Aroclor froa the water. Unusable contaminated Aroclor should be disposed by incineration which assures complete destruction to COo, BpO, and HOI. Any Incineration below 800C will result in vaporisation Which will contaminate the atnosphore or in partial oxidation tAilch sftj yield oatorlals which are highly toxic. . To help our cuetoners with their liquid disposal pro blems, we have offered to accept for future Incineration scrap liquid Arcelor* shipped to Floassnto Coapany, W. 0. Kruaarleh Plant, Saugst, minds, Attentlcoi Supervisor, Deportamt 246. The chars# for this dis posal is 34 per pound of Material. Balt charge is tentative pending a complete evaluation of Incineration costs and does not include freight or container coats. Contamination of the ataoapbere oust also be elininated. All handling 07cteas suet be closed wherever possible. Fiasco exhausted free a tank, vessel, or working area oust be trapped and collected using condensers and entrainment separator*. Solids contaminated with fCB's pose a greater ohallsngs. Until a proper Incinerator la designed, we are suggesting that disposal be wade In an authorized, properly operated land fill away froa any water systsas. These solids include treatment cloys, absorbing tateriala used to contain spills, rags, windings end containers. In sunmary, control of ?CBr* can be achieved with equipment engineered to prevont losses and maintained proparly coupled with good manufacturing practices which result In a high standard of housekeeping. ' COMPANY CONFIDENTIAL T01N otl,, STLCOPCB4024916 WATER PCB-SD0000043032 a. munch - JTQ A. OLSON - DOLSO MonsantoI B. PAPACECRCE - VPAPA Mamanto Company 800 N. Llndbarph Boulavard St. Louis. Missouri 03100 Phona: (314} 884-1000 OITOAHIC CHOJICAU OH August 6, 1970 MCS 1016 Since environmental probes for FCB's reflect the presence of the more highly chlorinated biphenyl compounds, Monsanto prepared an experi mental amount of Aroclor 1242 from which a significant portion of the more highly chlorinated compounds have been removed. This experimental material Is called MCS 1016. The amount you requested for- your capacitor itudlet Is nrout Co your* *CtenCion, delivered at no charge. Attached Li our comprehensive analysis. Indicating the properties typical for MCS 1016. The enclosed list of Aroclor 1242 properties is for your convenience in comparing these two materials. The comparison reflects what one would expect after removing a signifi cant amount of the more highly chlorinated biphenyl compounds from Aroclor 1242. The excellent resistivity and power factor values given for MCS 1016 do not reflect a decimal point in the wrong place. However, it is not to be misconstrued that the electrical values of MCS 1016 are intrinsically superior to those obtainable with Aroclor 1242. Both,materials attain these excellent electrical value* when highly refined by adsorbent#. PLAINTIFFS EXHIBIT NO.__S_\ FOR IDENTIFICATION 9-in -^s DATE. RPTR: <3, TRAN 092667 STLCOPCB4024917 WATER_PCB-SD0000043033 Page 2 August 6, 1970 The electrical -viluej given for MCS 1016 are not baaed on a aaraple from the atorage tank. Instead, they are-baaed on individual analyaia of about ten samples removed from the drums in which th* material was pack aged. To account for the good results, we wish to indicate that handling, sampling, and analytical work on thia experimental material was auperviaed by Dr. Ralph Munch in our Research Laboratories. He employed hit recently-developed procedure which encompasses special care required for the proper analysis of the power factor and resistivity of highly refined Aroclor. In light of this careful handling and testing at our end, and the vide aimultaneoua distribution of this material to the capacitor makers, ve have good opportunity for a "round-robin'* teat of power factor and re sistivity. We will appreciate it if you will sample your shipment prompt ly and give us your readings of power factor and resistivity. In any event, the prime purpose of sending the HCS 1016 is to give you an _ opportunity to run capacitor life tests. Looking ahead, it appears likely chat we will need to convert to the HCS 1016 type material aa a step in the direction of helping on the PCB pollution problem. Thank you for your assistance. Very truly yours PCB:PH Attach raui DCUJ-&UU9 Market Manager Dielectric Fluids TRAN 092663 STLCOPCB4024918 WATER PCB-SD0000043034 Recipient* of ?. G. Benignus lettr dated August 6, 1970 are a* follow*: Hr. Abe Kalstein AER0V0X CORPORATION 740 Belleville Avenue New Bedford, Massachusetts Hr. Kurt Lopes CORNELL-DUBILIER 1605 Rodney French Boulevard New Bedford, Haaaachuaett* Hr, Ray Clark ELECTRONIC COMPONENTS, INC.' 902 Crescent Avenue Bridgeport 8, Connecticut Mr. Robert E. Abbe CENERAL ELECTRIC CCMPANY Capacitor Department John Street Hudson Falla, New York Mr. Howard Brown HERCULES, INC; P. O. Box 5038 Terre Haute, Indiana Mr. Ralph Meyers HC CRAW EDISON IND,' Line Materials Company South Milwaukee, Wisconain - Hr. H. B. Vaught P. R. MALLORY Waynesboro, Tennessee Hr. T. Katasaraa MITSUBISHI MONSANTO CHEMICAL COMPANY C. ?. 0. Box 879 Tokyo, JAPAN Mr. C. R. Coleman MONSANTO CHEMICALS, LTD.' Runbon Denbighshire North Wales, UNITED KINGDOM Hr. Boyce Whitman SANCAMO ELECTRIC COKPANY Pickena, South Carolina Mr. Howard Davia SPRACUE ELECTRIC COKPANY North Adana, Massachusetts Mr. Donald L. HcClain VEST INCHOUSE ELECTRIC CORPORATION P. 0. Box 341 Bloomington, Indiana Dr. L. Handelcorn WESTINGH0USE RESEARCH Beulah Road Churchill Borough Pittsburgh, Pennsylvania TRAN 092669 STLCOPCB4024919 WATER PCB-SD0000043035 AROCLOR I Z4Z (Trichlorobiphenyl) Specification Properties - September 27, I96Z PROPERTY TYPICAL Viac. at 37, 8 *C. (ASTMD88-56) - Spec if ic Grav ity at 25/l5.5*C. (ASTM D1810) Color, APHA Cond ition Acidity, mg. KOH/g. {ASTM D974, D664) Pour Point, *C. (ASTM D97-57) Inorganic Chlorides {ASTM D1821) Refractive Index at 25'C. (ASTM D1807) Distillation Range (ASTM D20-56) *C. corrected for stem and barometric pressure Water content (ASTM D1533-60) Resistivity, 100*C. 500 volts DC at 0. 1 inch gap. (ASTM D1169) DPlc.ctric constant, 100*C. at 1,000 cycles (ASTM D924-49) Flash Point, Cleve. open cup (ASTM D92-57)* Fire Point * Sulfates (ASTM D117-31)* Fixed Chlorine Content (Carius)* Specific Heat at 25*C.* 82 - 92 seconds Saybolt Universal 1.381 - 1.392 50 max. Clear 0.01 max. -14 or lower 0. 05 ppm. max. 1.6Z'.0 - 1.6260 10% 325 min. 90% 360 max. 35 ppm. max 500 X 10? ohm-cm. min. 4.7 to 4. 9 170* to 200"C. None to boiling point None 43+0. 5% 0.29 , Evaporation at 100'C. for 6 hrs.* Dielectric strength (ASTM D877-49) at 25 *C. KV min.* Hydrolyzable Chlorine Compounds, (aSTM D1 820-61) ppm. chlorides, max. Thermal Stability (ASTM D1936) ppm. chlorides, max. Coefficient of Thermal Expansion* (ASTM Dl 903) 0. 4% max. 35 0.5 0. 4 0.00068 cc./cc./'C. *Not determined unless by special request. TRAN 092671 STLCOPCB4024920 WATER_PCB-SD0000043036 bcc: P. Benignus 0. R. Graham Ootober 1, 1970 Mr. F. R. Vlland Senior Buyer . Purchasing Department Transformer Division Westinghouse Corporation 469 Sharpavllle Avenue Sharon, Pennsylvania 16146 - Dear Fred, I apologize for not responding sooner but I was waiting for some laboratory data which I hoped would be helpful in resolving the solid material disposal problem with your state agency. I telephoned Dr. Loughry on August 18 and found him to be very opinionated regarding the types of waste he would tolerate in a land fill. He insisted he had to have research data on the behavior of askarels on the various Pennsylvania soils over long periods of time. I, therefore, did not succeed in convincing him that disposal in a landfill was.safe since I could only refer to generalities. He did soften his position somewhat by stating that he understood you wished to dispose of liquid waste rather than solid waste. I assured him this was not your in tent. Perhaps you can pursue this opportunity. The laboratory information I was waiting for relates to a study made by Monsanto in the Gainesville, Florida area in 1938* Aroclor 1242 was one of several materials applied to soil in holes 15" in diameter and 16" deep. The walls were sprayed with a solution of Aroclor 1242 and the soil was replaced with each layer sprayed with additional Aroclor 1242. When the hole was completely filled, the remaining solution was poured on top. A total of 4 ounces of Aroclor was applied. Wo have STLCOPCB4024921 WATER PCB-SD0000043037 ti- Mr. F. R. Viland . -2- October l, 1970 estimated that the Aroclor content was about 2200 ppm. In 1969, wo secured samples from the Aroclor 1242 hole at 6 , 6-16" and 16-26" from the top. Aroclor was pres ent in these quantities: - Probe Depth _ ppm Aroclor 1242 6" 6"-l6" l6n-26" 2820 510 26 This data would indicate that after 30 years the Aroalor has not migrated to any significant degree. I have not shared this information with Dr. Loughry since he seemed to indicate that studies with soils from other states would not be indicative of what would happen in Pennsylvania. It is my opinion that only a soil chemist familiar with Pennsylvania will bo able to communicate with Dr. Loughry. aary Wilburn was considering approaching a consultant at VPI. Perhaps ho could help. I am sorry I was not able to help. Apparently ve do not have anyone within the Monsanto organization who can talk Dr. Loughry*a language. Yory truly youra, WBP ms W* B. Papageorge Manager ' Environmental Control NEV 003896 STLCOPCB4024922 WATER PCB-SD0000043038 P. 0. Beclgnus - St. Louis January 25, 1971 H. S. Bergen - HBERO T. L. 00*8*5* - TO OSS C. R. Coleman - RUABON h. Munch - OOTEKKT J. R. Fallon - JFALL P.J.A. KARSH BRUSSELS Dear Peter: You will recall that at the IEC-10B aseting In Brussels Pierre Jay of Prodelec fclndly gave me hla detailed analysis reflecting Prodelec*s view* that they are not the source of PCB pollution in Sweden, as result of their sale of Pyralene 1*199 to Llljeholaena, the sole user of aekarel In Sweden. I have two reeaona for pursuing thla thing: 1. Monsanto haa not achieved lta Marketing goals at LI 1JehoIrena. It la mj Impression that Prodelec have been supplying most of Llljehol- men's annual requirement of A00 tons of Aro- clor 1242. 2. Mr. Jay's contention that Pyralene 1499 con tains no hexa and not over 1% of pentachloro- blphenyl was disturbing as our Aroclor 1242 has sbout seven tlstes this mount of higher PCB*. Consequently we analysed all the Materials given in the at tached list. Without giving the exact detail findings, for all prectloal purposes the higher PCB contents are about the same for all. The only exception Is our proposed MCS-1016 where we have gone to great means to remove the higher PCBa. Thus we found pyralene 1499-1500 and 1500S quite similar t ) Aroclor 1242 regarding higher PCB. Without burdening the reader with *11 of Mr. Jay's calcula tions of the pollution situation In Sweden, the following will suffice. Be concluded Introducing 90 pounds of higher PCB per year into the Swedish environment. However, based on our analysis of Pyralene 1499 we conclude that tha amount is 1,040 lbs, per year, from Liljeholwens capacitor operation. Put into terras of ecological conaidarationa and particularly see eagles in the case of Sweden, this level of higher PCB would oontasrinate one trillion pounds of water to a level of ona part par billion. . TRAN STLCOPCB4024923 WATER PCB-SD0000043039 o as -2- Our MCS 1016 would result in a lower level of contamination by a faetor of 7. While Hr. Jay's analysis of tha PCB pollution situation la comprehensive in terms of tha pollution generated In a given year by LilJeholmena opsrntion and while ha mantionad that of tha eapaoitors arecexported# we feel that tha follow ing point must not be overlooked as given tine It la .the most Important consideration. Given 10 yeara or 20 or 30 years# most all of the capacitors produced will have failed or become obaolete and In any event returned to mother earth. Thla Is what the pollution prob lem Is all about - not Just one year's operation of Liljeholmen's plant. The purpose of all of thla is to get your views as to whether you feel that you can uae the merit of MCS 1016 effectively at Liljeholmens in effort to obtain a significantly larger portion of their ilroclor requirements In competition against Fyralene 1-499. I am mindful of not attaching our detailed Isomer analysis of all the competitive materials. It may be a little early to release these data into commercial circles as wc can then expect it to come to our competitors. This will happen# eventually. Best regards# F. 0. Benignus cs TRAN 037341 STLCOPCB4024924 WATER PCB-SD0000043040 MUM' .`U 1-0 B2SH Cumning Paton October 14, 1971 Status of PCBs TO : 1070 H. R. FORD 1010 R. A. GARCIA 1800 D. R. HANSEN 1650 P. L. SLAYTON "B2SL B2NK B2SJ W4A B2SH B2SH B2SH T. L. Gossage W. B. Papageorge N. T. Johnson P. S. Park P. G. Benignus D. E. Roush/j. j. R Oder D. R. Pogue CONFIDENTIAL The following are the notes I used In the PCD "presentation" that must have held you enthralled at midnight after a 17hour day.1 Dielectrics 1. Product Changes rOF1 TlfH- Aroclor 1242 for capacitors changed to more bio degradable 1016. U- S. j CA^A-b A- o*Jey . (5^- 0_-L A S j'v Aroclor 1221 renamed Capacitor 21. oD' In transformers no major changes planned. Research under way on PCB replacements, (Don't expect results in under 3-5 years.)----- Co^ R1 TD>tSaJ7"//"h_ 2, Customers , 11 <- y-Y 8*u> -L" * f Lri. (a) (b) OM ^ yr\ fc) (d) Effective October 4, dielectric fluids must be ap proved prior to order entry by P. G. Benignus or C. Paton and W. B. Papageorge or T. L. Ooosage. To prevent the need to approve all orders, a list of approved customers in both capacitors and trans formers has been compiled and will be circulated by October 18. . Field sales should scrutinize MIP runs re customers and order size. Follow up on doubtful ones and alert Product Group and COP. Regional managers to add one line to their monthly report: Unapproved Fluid Sales: (No or Yes) If yes/ a separate report should be sent on this. Customer Notification fjCT / <f) A letter on the pollution aspects of PCBs will be sent to cus tomers. This is being cleared with the Legal Department. ANSI ft An S.I.B, has been written on the formation of Committee 0107 STLCOPCB4024925 WATER PCB-SD0000043041 2- - of ANSI. This committee will address itself to the problems PCBs pose for the dielectric Industry. Pollution Control We are addressing ourselves to the pollution control or lack of it related to "service centers" for transformers or transformer users who buy only replacement fluid from Monsanto. Heat Transfer Fluids1 2 3 4 5 1. Conversions . Conversion of direct food-related users: completed. Conversion of curtain costers ('*' 80< complete). Conversion of film and foil producers D. E. Roush prepar- Conversion of adhesive manufacturers ing list of tai-get Conversion of resin manufacturers for accounts for conver- paints and coatings. sion. 2. Restrictions No PR fluid sales for new applications will be strictly en forced. This will include hospitals and off-shore gas plat forms, , 3. Customers ( = (a) 1 All orders are being approved by two people prior to order entry. (b) A list of approved PR users (top-up only) is being prepared and will be circulated by Octobex* 25. (c) Field sales scrutiny of MIP runs is requested (as per dielectrics), (d) Regional managers should report on unapproved fluid sales (as per dielectrics). . (e) We still need field sales help in completing surveys on the applications of FR customers. 4. Customer Notification A moiling to all customers is planned. This will Include: warning on PCBs; alternates to FR; non-fire' retardance of T-55> oS and 77; conversion offer and procedure; positive approach to non-FR fluids; tighter maintenance guide for all fluids. 5. Labels New labels are being printed. This will includo a stronger statement on food and food-related uses. It will also THUS 008481 STLCOPCB4024926 WATER PCB-SD0000043042 -3- cover the return of used fluid for incineration. Process Fluids 1. Carbonless Carbon Paper No salo3 of chlorinated bl- or terphenyls. 2. Dye Carriers Aroclor 1221 replaced by Aroclor 1221B. (Aroclor 122IB is monochloroblpheny1 whereas Aroclor 1221 did contain up to 25$ PCB. We should make no big issue out of this with any customer. Currently Ciba-Geigy is the only customer affected and this has been handled. Therefore any request for Aroclor 1221 will be filled w_i_t_h__A__ro__e_l_r_o_r without comment.) c<r6i C*^*~ni* 1 '4 _ 3. No customer notification of Process Fluids Is planned as a general mailing. Individual customer situations have been and will be handled separately. In addition to the above, the following situations have arisen. 1. Requests by paper companies for information, help on PCBs 'in recycled p.;per'. We should refer companies to The American Paper Institute which is active in thl3 area or to W. B. Papageorge. If any paper company wants methods for detecting FCB, Bill has a "Methodology Packet" that can be sent. 2. Requests from Monsanto customers that we write letters stating whether or not the products supplied by any of cur Divisions are PCB-free. Specialty Product Group preducts: All products (except dielectric Aruclor/Inerteen/Pyranol; Aroclor 5^00 and 6000 8eriae; Aroclor 1221B; Santovac 1 and 2; Pydrauls; Therninol fr series; and Turblnol 153) the regional manager should write the customer assuring him of the absence of PCBs. On product exceptions -- contact W. B. Papageorge. Products from other groups: Pass request to your counter part in the region for handling. 3. Pollution Control Procedures for Customers' Plants A draft of a bulletin on this subject has been written and is being revised. an TNCS 008482 STLCOPCB4024927 WATER PCB-SD0000043043 o I have been impressed by the efforts many of your men have put Into turning this difficult situation around. If they have any suggestions where we can improve on our procedures and policies or problems we are Ignoring we'll be only glad to hear from them. If they need spacific help from anyone In St. Louis please let us know. I'll try to keep you a3 up to date as I can on future developments, . Cummlng Paton os TNCS 006483 STLCOPCB4024928 WATER PCB-SD0000043044 Monsanto ^sh p. g, Benlgnm 1460 J. 0. Prederikaen B2SH C. Paton B2SJ N. T.. Johnson Dear Ray, Please refer to John Frederlksen's memo to Cumming Paton ootober 13, 1971 indioating that ha haa notioad a distressing amount of indeciaion on tha part of aavaral dlalaotrlo fluid aooounts re garding tha propar dlapoaal of aorap askarel. Would you pleaaa Hat who theaa aooounta are? Our PCS ineinarator i in full oparation at W. 0, Krummrioh and to tha baat of my knowledge communications were aant to all of our ouatomara indicating that thay ahould aand acrap fluid to us at Sauget, Illinois for incinaration at 3^/lb. This maaaaga is also baing lndioatad on tha labals of our drums. An example ralatlva to Aroalor 1016 is attachad. Soma of our othar packages carry tha small separate waste disposal lcbol. Also it was my undarstanding that thia sama briaf message uas to ba put on all invoioes. However, notwithstandir all our afforta I supposa that communi cation remains tha world's maabar ona problem. Therefore, If lndeedfj. $5 Pr^eriksenTis ancountaring our own ouatomara not fully informed plaasa write to them or carry thla message to then. As this entire PCS thing has now baan widely publicized wa readily understand that customers of someone like Kuhlman Xlectrio may ba asking then this Question about waste disposal. As wa oannot cover thia thing for Kuhlnan's customers and tha endless number of others out in the field please advise Kuhlman and our other oustoaers to do all they can to pass along tha sassage. sing that tha electrical manufacturers themselves oannot ot all these people wa have formed oomlttfes at ANSI .gh which organisation wa hope to have available channels ora widely distributing this massage to individual., usars. program is In formative stages. ; ' '' ' Best regards^ os im.is Mv 1-41 0883^7 PLAINTIFFS 05 EXHIBIT NO v--' FOR JDE^IF?CATION DATE: RPTR: 3TvS STLCOPCB4024929 WATER PCB-SD0000043045 826.12-01101/53 6316$, U.SA i TRAN 0883*8 STLCOPCB4024930 WATER PCB-SD0000043046 Used polychlorinated biphenyl fluids may be returned freight prepaid for proper incineration at 3* per pound. Ship to: Supervisor Dept. A-246 MONSANTO COMPANY SAUGET. ILLINOIS 62201 1143/S3 TRAN 088349 STLCOPCB4024931 WATER PCB-SD0000043047 t1 OfCTATE IN SEQUENCE:" ' 1. HEADING INFORMATION 2. NAMES OF ADDRESSEES 3. NAMES OF CARBONEES i. IMMEDIATE ACTION NEEDED 5. REPORT ON CALL " w V uI CU5IOMU NAME OA.lt Of CAU OAfE Jtcccrvco 6-16-72 oaIe /ypto BAYTOWN, TEXAS 6-19-72 6-21-72 CUSTOMER MAILING LIST CHANGE5 - SERVICE CENTER USE ONLY name and hue 'sr MP Mac Category codes REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED REGION SOUTHERN SERVICE CEN1ER HOUSTON SALESMAN D. W. STEGEN/s j_ TO CUMMING. UTON - ST. LOUIS CC JERRY DAVIDSON - STL. PAUL CRASKA - PITTSBURG E. L. SHIMLEY - AKRON DOUG HANSEN - S. C. BOB BEVACQUA - L. A. CALL MADE WITH J RODER. PERSONNEL CONTACTED: Bob Peterson - Maint. Supt. John Rowland jpslr -ptxr CP?-- XTT R^ttss , Date Ree`d PYDRAUL 230 C;^ Peterson had received a call from his counter-part in the Torrance, CaTif. operation of U. S. Steel, indicating that Torrance was in trouble as a result of polychlorinated biphenyl pollution. Peterson is of the opinion that Torrance has already changed their system with the assistance of Monsanto from PCB to non-PCB fluids and has flushed the system to remove all residual* PCB's.' We discussed the entire PCB situatio with Peterson and Rowland and now I feel they have a reasoned)ly good under standing of the problem. Peterson recognizes he will not get to -0- PCB's, even if he drabs and flushes his system. We did provide him with the name of the lab's which we would be willing to recommend for analytical work .on PCB ' s. I also suggested to Peterson that he sample his affluent to determine If he has a PCB problem at this time. Peterson is agreeable to this, however, he did ask if the State of Texas had established any toleran leeels on PCB in affluent. I indicated I would have Bill Pappageorge conta him in order to clarify this point. 5-J3I ptCY. 132*9) 1 - CENTRAL OFFICE COPY TNCS 007355 plaintiffs exhibit no. for IDENTIFICATION DATE; STLCOPCB4024932 WATER PCB-SD0000043048 I B2SC P. 0. Bc-r.ignus January 20, 1972 Askarel Dielectrics B2SL B2SL B2SL B2SC B2SL W. R, Corey H. S. Bergen T. L. Ooaaage C. Paton J. R. Savage B2NK W. B. PAPAaECRaB When (Tea ling with historical production and sales figures for dieleotrics it becomes quite important for all concerned to put them into proper perspective, especially from the atand point of tha higher PCB (Aroclor 1254 and Aroclor 12f>0) con tent relative to the PCB pollution problem. Product changes took place. For example in the capacitor in dustry: Approx. Higher PCB Prime Product Prime Product Content 5 Cl and higher Uae Period Aroolor 1254 Aroolor 1242 Aroclor 1016 76% 7% 0.3 To about 1952 1952-1970 1971 1970 was the historical high year for pounds of capacitor Aro olor use in the USA at near 26 lbs. We do not expect thla level to be exceeded for some years to ooroe. Now to reflect the elimination of higher PCBa from capacitor Aroclor Jtaking in account product changes and usng,.il97A'.aales as basis for comparison we have: 1970 Baals for Comparison Product Higher PCB Involvement Pounds Aroclor 1254 26 R x 76% l9,7b6,000 Aroclor 12^2 26 H x 1% 1,820,000 Aroclor 1016 2b Pf x 0.3# 78,000 1. If Aroolor 1254 had continued in use the higher PC invtflVemcnt ~.?ould have been near 20 S pounds. 2. In 1970 Aroclor 1242 was the prims product and the higher PCB involvement was 1.82 S' pounds. 3. Now Aroclor 1016 is used exclusively and the higher PCB involvement based on 1970 sales would have been 78,000 pounds. COMPANY CONFIDENTIAL TRAN 021185 STLCOPCB4024933 WATER_PCB-SD0000043049 2- - Conclualon At this time anc for the foruneeable future the involvement with the acknovr_ . dged non-biodegnadabl 5 chlorine and higher PCBs from the or; ..ire USA capacitor industry dooe not appear to exceed about .0,000 pounao annually. P. 0, Benignue 08 COMPANY CONFIDENTIAL ' TRAN 021186 STLCOPCB4024934 WATER PCB-SD0000043050 :-fx > Monsanto HAI M( * C) ! s. Tucker - RtD Labs ' May 19, 1969 AROCLOR SAMPLES FROM WGK (flRINCl TO : Michael A. Pierle TSD - WGK 1700 So. 2nd ~ St. Louis cc' ft. E. Keller - So. 2nd ' C. F. Buckley - WGK W. R. Richard - GO E. P. Wheeler - GO P. B. Hodges - GO i 3 Analysis of the WGK sample by EC/GC produced the following results. Aroclor 1242 Found Sludge from Sauget Village Waste Treatment Plant 0.8G + 0.02% Waste Water from Village Effluent Sludge from Mississippi River 300' downstream of Plant> Outfall Waste Water from Aroclor Production Department Interference* 16.4 +0.3 ppm** . 1.20 + 0.05 ppb Aroclor 1242 present but the background was so intense a quantitative estimate could not be made. Probably slightly less than solubility limit ^--'10-100 ppb, **Peaks with longer retention times indicated the presence of Aroclor 1254 so the number shown is slightly high for Aroclor 1242. Content slightly low for the total Aroclor content. GC/Mass analysis confirmed the presence of mono, di, tri and tetra polychlorinated biphenyls in the Sauget sludge sample. I I I db E. S. Tucker MV. II. TRAN 00756+ STLCOPCB4024935 WATER PCB-SD0000043051 I / r /i-Ciwt t-u <t N_--V ^ r- . UNITED STATES " DEPARTMENT OF THE INTERIOR FISH AND WILDLIFE SERVICE BUREAU OF SPORT FISHERIES AND WILDLIFE BUILDING I*. DENVER FCDCRAL CENTER DENVER. COLORADO 0OZ25 January 16, 1968 * r'tl it r' WRes Moncanto Chemical Company 800 N. Lindbergh Boulevard St. Louis, Missouri . ' Gentlemen: . It has boon brought to our attention that presumptive evidence of chlorinated biphenyl and chlorinated polyphenyl coupounda have been found in avion and animal tissues. We arc in the process of further investigation of compounds of this scrico and would appreciate your sending us samples of your ArochLor compounds numbers 1242, 1254, 1260, 1268 and any others which might be extensively used. Sincerely yours. Richard A. Wilsonf--Sr. Research Chemist (Biochemistry) I. TRAN 007565 STLCOPCB4024936 WATER PCB-SD0000043052 AjocXor sCerien evne/ahv P.G. Benignus, St. Lauda G.E. Buchanan, St. Louis D.S. Cameron, Brussels Dr. R. Eknmet Kelly, St. Louis G.R. Graham, Now York R.A. Steenrod, St. Louis X). Wood, Brussels J.A. Evans, London R.A. Baxter, Ruabon !JAN 1 6 1961 On 2nd January 1<?67 Hr. A. Richardson of Shell Chemicals' Tunstall Laboratory, Sittingboume, Kent talked with me over the telephone concerning the Swedish Press report relating to the identification of "Polyclilorinated Biphenola" &e traoe contaminant in sea birds, fish etc. Richardson haa been working for some yearn on the similar problem with insecticides such as DDT, which are known to have wide distribution in traoe quantities* He had already found that the chlorine-containing residue contained substances more stable than BUT. and just as S8ren Jensen reports he has obtained spectrographic evidence that these are very Bimilax if not identical with Aroclor8. He has obtained samples of Aroolors 1242, 1254, 1262 and 54&0 from ua,' and would now like to have small samples of any chemically pure Aroclor constituents which ve may be able to supply. Milligram quantities would suffice for hie purpose* Mr. Richardson was quite sure that the compounds reported to be "polychlorinated biphenols" are really meant to be polychlorinated biphenylb and as support he has sent me a copy of the synopsis of a paper entitled "Pesticide Analysis! Presence of Polyohlorlnated Biphenyls at Residue Analysis of Biologioal Samples" by SBren Jensen and Gunner Vidmark (photooopy attached). I discussed with Richardson the soundness of Jenserfs claims, and was assured that his work and findings are sound. Jensen is on the staff of the Institute of Analytical Bhamistry, University of Stockholm. A note on the staff and work of the Institute is attached. From this you will see that Jenaan is wholly concerned with the analysis of chlorinated pesticides and with the work of stations for routine analysis. I would be glad if Dr. Baxter and Itr. Buchanan would arrange to send me milligram samples of any pure Aroolor constituents that may be available at Ruabon and St. Louis respectively. COMPANY CONFIDENTIAL N- -4 007566 STLCOPCB4024937 WATER PCB-SD0000043053 Mon-santo * vOf ' 0*1 l V ft *tc T V (("C V TO David Wood-St. Louis-B2SC July 18, 1974 DIELECTRICS SEMINAR SEPTEMBER, 1974 MEETING 17TH JULY PROGRAM COMMITTEE P. G. Benignus T. L. Gossaga ' W. B. Papageorg* 1) Definition of Environmental Problems Surrounding PCBsj 2) Indepth Review of the Defense of PCB Continued Use j 3) Conclusion that Use of PCB Can Be Continued. Wc with the program to allow customer participation and to reflect a balance between capacitor and transformer manufacturers, and large and small manufacturers. Ideally, there should also be soma contribution from the limited number of overseas manufacturers who may attend. On the above basis, the following program evolved} 1) Statue report on environmental issues concerning PCB around the world. No guest speakers would be involved in this section since we wish to concisely define the problem before the seminar without getting into over much discussions of different corporate viewpoints. U.S.A. and Canada would be presented by Bill Papageorge, the European situation by A1 Vodden, and other world areas by David Wood. 2) Effect of PCBs in the Environment. We believe that this heading should cover biodegradation, isomer differentiation, and test procedures to satisfy the capacitor industry pro blems, and secondly, migration of PCBs in soil to reflect the rather different situation of transformer manufacturers. We suggest that this is handled by Scott Tucker and A! Vodden without guest speakers. TRAN 028069 . 10 BCV >'72 PLAINTIFFS FOR IDENTIFICATION STLCOPCB4024938 WATER PCB-SD0000043054 2- - 3) Methods of testing PCB in effluent streams. This topic should be divided into four sections: A) Presentation by Ed Stewart on clean-up of our own PC3 facility? B) CED Department - Monsanto ideas for controlling PCB at customer locations; C) Capacitor industry comments, preferably by Mr. Hydrick of Sangamo; D) Transformer customer comment by Mr. Shepherd of Westinghouse. 4) Disposal of waste Aroclor. We suggest that this be handled by a panel comprising Jim Savage, Bill Papageorge, and Earl Potter, and should aim to cover incineration, transportation, cleaning and disposal of drums, damage to bulk containers in transit. We anticipate that at the end of Item 4 would form a breakpoint for lunch. 5) New Fluids. Under t;his heading, we would cover work cr> Aroclor 1016, Aroclor "10*3, and non-PCBs with emphasis being low on non-PCBs; however,as we hope the EPA standards support the continued use of PCBs. We propose that this section be handled by R. Munch and J. G. Bryant. 6) Transformer Fluids. We seek a presentation by G. E. Rome, Jim Kinney covering the search for alter native fire resistant transformer dielectrics to be followed by a presentation by Bill Richard in dicating that Monsanto has not neglected transformer fluids in its Research program, but that new major developments have not yet evolved. We shall seek in this presentation to ventilate the Monsanto pro duction problem if there is a general move from higher chlorinated isomers and explore the concept of a transformer fluid based on Aroclor 1248. Items 2 through 6 are designed to indicate the number of areas in which a defense of continued PCB use can be mounted. TRAN 028070 STLCOPCB4024939 WATER PCB-SD0000043055 7) Economic influence of askarel use on U. s. economy. Here we seek a presentation by Ed Raab of General Electric of the economic data presented- in Washington. We hope to set a positive note with this presentation to support continued use of PCBs. 8) Consumer attitudes. Under this heading, we would seek positive presentations on askarel transformers and askarel capacitors. Our first choice for transformers is Niagara with Ferranti Packard as reserve. Our first choice on capacitors is Jard with Mallory as reserve. It was suggested that after each section, we should allow a 15-minute period for questions from the floor and that as a last stage, the committee should consider whether there were any specific organizations and ques tions we wished to introduce into the program. Would you please let me know if the above fairly re flects the conclusions of the meeting and whether you. have any further additional comments to make before we seek final approval of this format. ' / dab David Wood TRAN 028071 STLCOPCB4024940 WATER PCB-SD0000043056 Monsanto C) ) r9M |MM( * VOCATIO^I n ^ __ , _ __ __ E. S. Tucker - RfcD Labs - 1700 So. 2nd - St. Louis ' May 19, 19 69 AROCLOR SAMPLES FROM WGK MUKINCt i TO : Michael A. Pierle TSD - WGK co R. E- Keller - So. 2nd ' C. F. Buckley - WGK W. R. Richard - GO E. P. Wheeler - GO P. B. Hodges - GO Analysis of the WGK sample by EC/GC produced the following results. Sludge from Sauget Village Waste Treatment Plant Waste Water from Village Effluent Sludge from Mississippi River 300' downstream of Plant Outfall Waste Water from Aroclor Production Department Aroclor 1242 Found 0.86+ 0.02% Interference* 16.4 + 0.3 ppm** . 1.20 0.05 ppb *Aroclor 1242 present but the background was so Intense a quantitative estimate could not be made. Probably slightly less than solubility limit "--'10-100 ppb. **Peaks with longer retention times indicated the presence of Aroclor 1254 so the number shown is slightly high for Aroclor 1242. Content slightly low for the total Aroclor content. GC/Mass analysis confirmed the presence of mono, di, tri and tetra polychlorinated biphenyls in the Sauget 3ludge sample. db e fltv. tl # E. S. Tucker TRAN 00756+ STLCOPCB4024941 WATER PCB-SD0000043057 jjTQcIor _ Sweden JNm/iSM ' P.G. Benignus, St. Louie G.R* Buohanan, St. Louie L.S. Cameron, Brussels Lr. R. finmet Kelly, St. Louis G.R. Graham, Haw York R.A. Steenrod, St. Louis . L, Wood, Brussels J.A. Evans, London R.A. Baxter, Ruabon 'JAN : 6 1961 On 2nd January 19^7 Hr. A. Richardson of Shell Chemicals' Tunstall Laboratory, Sittingboume, Kent talked with me over the telephone concerning the Swedish Press report relating to the identification of "Polychlorinated Biphenola" as traoe contaminant in sea birds, fish etc. Richardson has been working for aomo years on the similar problem with inseotioidea such as LOT, which are known to have wide distribution in traoe quantities. He had already found that the chlorine-oontaintng residue contained substances more stable than LOT. and just as SBren Jensen reports he has obtained spectrogxaphic evidence that these are very Bimilax if not identioal with Aroclors. He has obtained samples of Aroolors 1242, 1254, 1262 and 54^0 from ua,' and would now like to have small samples of any chemically pure Aroclor constituents which we may be able to supply* Milligram quantities would suffice for his purpobe* Mr. Richardson was quite sure that the compounds reported to be "polychlorinated biphenols" are really meant to be polychlorinated biphenyls and as support he has Bant me a copy of the synopsis of & paper entitled "Pesticide Analysist Presence of Polyohlorinated Biphenyls at Residue Anal^CyBie of Biological Samples" by SBren Jensen and Gunner Vidmark (photooopy attached). I discussed with Richardson the soundness of Jenserfs claims, and was assured that his work and findings are sound. Jensen is on the Btaff of the Institute of Analytical Chemistry, University of Stockholm. A note on the staff and work of the Institute is attached. From thia you will eeo that Jensen is wholly concerned with the analysis of chlorinated pesticides and with the work of Btaticns for routine analysis. I would be glad if Ur. Baxter and Lr. Buchanan would arrange to send me milligram samplsB of any pure Aroolor constituents that may be available at Ruabon. and St. ^ouis respectively. COMPANY CONFIDENTIAL HARDY TRAN 007566 STLCOPCB4024942 WATER PCB-SD0000043058 Monsanto C) mOM (NAMC LOCATION* E- S. Tucker RfiD Labs May 19, 1969 AROCLOR SAMPLES FROM WGK CMMIMCI TO : Michael A. Pierle TSD - WGK ). 1700 So. 2nd - St. Louis CC* R. E. Keller - So. 2nd C. F. Buckley - WGK W. R. Richard - GO E. P. Wheeler - GO P. B. Hodges - GO Analysis of the WGK sample by EC/GC produced the following reaulto. Sludge from Sauget Village Waste Treatment Plant Waste Water from Village Effluent Sludge from Mississippi River 300' downstream of Plant> Outfall Aroclor 1242 Found 0.86 + 0.02% Interference* 16.4 + 0.3 ppm** . Waste Water from Aroclor Production Department 1.20 + 0.05 ppb *Aroclor 1242 present but the background was so intense a quantitative estimate could not be made. Probably slightly less than solubility limit *--'10-100 ppb. **Peaks with longer retention times indicated the presence of Aroclor 1254 so the number shown is slightly high for Aroclor 1242. Content slightly low for the total Aroclor content. GC/Mass analysis confirmed the presence of mono, di, tri and tetra polychlorinated biphenyls in the Sauget sludge sample. db ** MV, 11 -SI E. S. Tucker TRAN 007564 STLCOPCB4024943 WATER PCB-SD0000043059 | i'r ,I*/' ' / /T i~v Ay i14 * i () rr - . UNITED STATES " rij ! (r f / DEPARTMENT OF THE INTERIOR FISH AND WILDLIFE SERVICE bureau of sport fisheries and wildlife WRefl UILDINO ie. DENVER FEDERAL CENTER OCNVCR. COLORADO 00225 January 16, 1968 Moncanto Chemical Company BOO N. Lindbergh Boulevard St. Louis, Missouri Contlemen: . . It haa been brought to our attention that presumptive evidence of chlorinated biphenyl and chlorinated polyphenyl coupounds have been found in avion and animal tissues. We arc in the process of further investigation of compounds of this series and vould appreciate your sending us samples of your Arochlor compounds numberc 12*i2, 125*1, 1260, 1268 and any others which might be extensively used. Sincerely yours. diehard A. WilsonJ-'Sr. Research Chemist (Biochemistry) <. TRAN 007565 STLCOPCB4024944 WATER PCB-SD0000043060 vMonsarU mi* <i o |f* f I HI I /1 | 10 D.Y.H. Hardy, London 12"th January, I967 ArqoXor - sCedan imm/mi ^ P.G. Benigmis, St. Louis G.R. Buchanan, St* Louis D.S. Cameron, Brussels Dr. R. Sterne t Kelly, St. Louis G.R. Graham, Hew York R.A. Steenrod, St. Louis . D. Wood, Brussels J.A. LVans, London R.A. Baxter, Ruabon 'JAN : 6 1967. On 2nd January 1967 Hr. A. Richardson of Shell Chemicals' Tunstall Laboratory, Sittingboume, Kent talked with me over the telephone concerning the Swedish Press report relating to the identification of "Polychlorinated Biphenols" as traoe oontaminant in sea birds, fiBh etc. Richardson has been working for somo years on the similar problem with insectioides such aa EDI, wliich are known to have wide distribution in traoe quantities. He had already found that the chlorine-oontaining residue oontained substances more stable than BET. and juat as SBren Jensen reports he has obtained spectrographic evidence that these are very Bimilar if not identical with Aroclors. H* has obtained samples of Aroolora 1242. 1254* 1262 and 54&0 from us,' and would now like to have small samples of any chemically pure Aroclor conatituenta which we may be able to supply. Milligram quantities would suffice for hia purpobe. Mr. Richardson was quite sure that the compounds reported to be "polychlorinated biphenols" are really meant to be polychlorinated biphenylb and as support he has Bant me a copy of the synopsis of a paper entitled "Pesticide Analysis! PreBenoe of Polyohlorinated Biphenyls at Residue Analysis of Biological Samples" by Sflren JenBen and Gunner Vidmark (photocopy attached). I discussed with Richardson tho soundness of Jenserfs claims, and was assured that his work and findings are sound. Jensen 1b on the etaff of tho Institute of Analytical Bhamistiy, University of Stockholm. A note on the staff and work of the Institute is attached. From tills you will nee that Jensen is wholly ooncomed with the analysis of chlorinated pesticides snd with the work of stations for routine analysis.I I would be glad if Dr. Baxter and Dr. Buchanan would arrange to send ms milligram samples of any pure Aroolor constituents that cay be available at Ruabon and St. I^ouis respectively. COMPANY CONFIDENTIAL B.Yfff. HARDY TRAN 007566 STLCOPCB4024945 WATER PCB-SD0000043061 > Monsanto % O ) rOM IHI.MI ft \.0<ATJOH| E. S. Tucker - RtD Labs 1700 So. 2nd -- St. Louis May 19, 1969 AROCLOR SAMPLES FROM WGK *crincMCi TO : Michael A. Pierle TSD - WGK cc` R. E. Keller - So. 2nd ' C. F. Buckley - WGK W. R. Richard - GO E. P. Wheeler - GO P. B. Hodges - GO Analysis of the WGK sample by EC/GC produced the following results. Sludge from Sauget Village Waste Treatment Plant Waste Water from Village Effluent Sludge from Mississippi River 300' downstream of Planb Outfall Waste Water from Aroclor Production Department Aroclor 1242 Found 0.86 + 0.02% Interference* 16.4 + 0.3 ppm** . 1.20 + 0.05 ppb *Aroclor 1242 present but the background was so intense a quantitative estimate could not be made. Probably slightly less than solubility limit "'-'10-100 ppb. **Peaks with longer retention times indicated the presence of Aroclor 1254 so the number shown is slightly high for Aroclor 1242. Content slightly low for the total Aroclor content. GC/Mass analysis confirmed the presence of mono, di, tri and tetra polychlorinated biphenyls in the Sauget sludge sample. E. S. Tucker db TRAN 007564 STLCOPCB4024946 WATER PCB-SD0000043062 J l')`- / /r . UNITED STATE department of the interior FISH AND WILDLIFE SERVICE BUREAU or sport fisheries and wildlife UILDING I*. DENVER FEDERAL CENTER OtNVtff.COLORADO 60225 January 16, 1968 WRcs Mon can"to Chemical Company 600 N. Lindbergh Boulevard St. Louie, MiBoouri . ` Gentlemen: _ It has been brought to our attention that presumptive evidence of chlorinated biphenyl and chlorinated polyphenyl compounds have been found in avian and animal tiaaues. We arc in the process of further investigation of compounds of this series and would appreciate your sending us samples of your Arochlor compounds numbers 12h2, 125h, 1260, 126Q and any others which might be extensively used. Sincerely yours. Richard A. Wilson}--Sr. ' Research Chemist (Biochemistry) TRAN 007565 931 STLCOPCB4024947 WATER PCB-SD0000043063 $ ............. B.Y.N. Hardy, London 12"th January, 1967 Afpclor - 8Cedan lynh/ahv ' P.G. 3enignus, St. Louis G.R. Buohanan, St. Louis DS. Cameron, Brussels Ltr. R. Hnmet Kelly, St. Louis G. R. Graham, New York R.A. Stsenrod, St. Louis . B. Vood, Brussels J.A. LYans, London H. A. Baxter, Ruabon 'JAN 1 S 1967. Cta 2nd January 1967 Mr. 1. Richardson of Shell Chemicals1 Tuns tall Laboratory, Sittingboumo, Kent talked with me over the telephone concerning the Swedish Press report relating to the identification of "Polychlorinated Biphanola" os traoe contaminant in sea birds, fish etc. Richardson has been working for somo years on the similar problem with insecticides such as LET, which axe known to have wide distribution in trace quantities* He had already found that the chlorine-containing residue contained substances more Btable than EDI. and iuat aa Sttren Jensen reports he has obtained Bpectrographic evidence that these are very similar if not identical with Aroclors. He haa obtained samples of JLroolors 1242, 1254. 1262 and 54&0 from us,' and would now like to have small samples of any chemically pure Aroclor constituents which we may be able to supply. Milligram quantities would suffice for his purpobe. Mr. Richardson was quite euro that the compounds reported to be "polychlorinated biphenola" are really meant to be polychlorinated biphenyls and aa support he has sent me a copy of the synopsis of a paper entitled "Pesticide Analysis PrsBenoe of Polyohlorinated Biphenyls at Residue Anal^ysis of Biological Samples" by SBren Jensen and Gunner Vidmaxk (photocopy attached). "V.. I discussed with Richardson the soundness of Jenserfs claims, and was assured that his work and findings are sound. Jensen is on the staff of ths Institute of Analytical Chemistry, University of Stockholm. A note on the staff and work of the Institute is attached. From this you will see that Jenaan is wholly concerned with the analysis of chlorinated pesticides and with the work of Btatians for routine analysis. I would be glad if Dr. Baxter and Hr. Buchanan would arrange to send mo milligram samples of any pure Aroolor constituents that maybe available at Ruabon and St. J,ouis respectively. COMPANY CONFIDENTIAL TRAN 007566 STLCOPCB4024948 WATER PCB-SD0000043064