Document 6wXkamXeM4jaXkvGm19Qvjd2o

m order* jO pro tective SUBJECT C14163 Monsanto fr FROM iname--location phone Allan M. Ford - St. Louis A2SA 4-2578 DATE August 9, 19 82 cc REFERENCE : TO : T. M. Bistline - E2ND In responding to Dr. Hryhorczuk, we are trying to limit his investigation of our facilities as much as possible. He already has grant money for his study, so I doubt if we can put a stop to it. He uses Tiernan's book, which indicates that we have made several chlorophenols, which in fact were not manufactured there. In addition, with the exception of 2,4,5-T esters, the other chlorophenols Hryhorczuk mentioned would not be expected to form 2,3,7,8-TCDD. Finally, with the case of 2,4,5-T,the part of the process likely to give off dioxincontaining waste was not operated in Illinois. We're afraid that if we don't straighten out Hryhorczuk's thinking we will be accused of something we didn't do! cot /VL* PROTECTIVE ORDER. SUBJECT TO jh enclosures - A. M. Ford 014164 /\, f)uu ALq q m Ji dbiCfttp KJiOSti ^zf A)t _ sy\ ft L QxaJ l 0^~ , h itflp u - h k h > (l Ajuv^ aJ , a u .'U - -UL, h) lAsh/^HWJl 04<UUcJ-*~. jh tu tr^ ftiL ^ hti rv AJJbCCM ? V AFT 7 August 9, 1982 Daniel Hryhorczuk, MD, MPH UNIVERSITY OF ILLINOIS SCHOOL OF PUBLIC HEALTH P.O. Box 6998 Chicago, Illinois 60680 My dear Dr. Hryhorczuk: I'm sorry for not giving a more prompt reply to your letter of June 16, but vacation schedules have intervened. In response to your proposal, the production of chlorinated benzenes likely to form chlorinated aibenzo-p-dioxins (CDD's) or chlorinated cibenzofurans at our Sauget, Illinois plant is to the best of our know ledge as reported in Tiernan's book (DIOXINS, US-EPA-600/2-80-197) , with the exception of ortho nitroanisole and 3,4-dichloroaniline which were not manufactured in the Sauget plant. In addition, 2,4,5-trichlorophenoxv acetic acid (2,4,5-T) was manufactured elswhere and esterified at the Sauget, Illinois plant. I would suggest that Dr. Tiernan at V?right State might be a good source of additional information. SUBJECT TO PROTECTIVE ORDER T i e m a n classifies most of the compounds mentioned in your letter as having a low probability for CDD formation. With the exception of the orthochlorinated phenols, the molecules do not meet the criteria of having ortho-substitution and good leaving groups. In the case of the orthochlorinated phenols mentioned, with the exception of 2,4,5- trichlorophenol, the remaining substitution on the ring suggests that the major product of coupling would not be the most toxic 2,3,7,8tetra-CDD. in any event, our process for production of ortho-, C14165 para- and 2,4-dichlorophenols, the only ones still manufactured at Daniel Hryhorczuk Page 2 August 9, 1982 - DRA. t ~ r, n Sauget, is carefully controlled to minimize formation of CDD's and predioxins. T h e '2,4,5-trichlorophenol was converted to 2,4,5-T outside of Illinois ^ n d "transferred-to'1the'Sauget plant where it was esterified to the ^-utyl-ister/riCt^siKtjeen over thirteen years since we've used 2,4,5-T as an intermediate 1at the Sauget plant, but because of the substituents 1suggesting "tha^t-'the ^ 2 , 3';77,'8-:TCDD 'iniglvt have been formed in the'2, 4,5-T process, we, along with a number of other companies, are cooperating fully in an epidemiology study being conducted by NIOSH relating to all phases of the discontinued chlorophenol processes, as well as conducting mp our own internal research. For your information,. I have.enclosed a ** ` vO process description and process chemistry for the discontinued esterifi cation process*and the discontinued pentachlorophenol process at Sauget, Illinois. We are currently involved with five other defendants in litigation involving the 2,4,5-T esters and cannot disclose further detail during the course of this litigation on advice of counsel. The pol. yc. h.lo.ri.na.te.d .bi.phenyl, s (PCB's), were manuf.acStUurBeJdECaTt TtOhePROTECTIVE ORDER. Sauget plant up. until--1977, at which "time manufacture was discontinued. We ..have-*not found; any! of the CDD's:"in*the PCB's'manufactured" by Monsanto Company nor..have we seen.any.reports..in. the -literature-of such findings. C14166 Prpduction and end use of the chemicals you mention are as described by Tiernan, eptrc.aalu,ctancdi eclosuepwlhienrge viionuitchenoltitneoramteurem.ost,Irt^odxeiacling w>i,tchJTejSeral^regulators, we have^ requested ^tha^ prp^uc.tion statistics remain- . i- secret and, on advice of counsel, cannot violate that request by dis closure to you. In the same vein, our waste disposal at the Sauget Diant Daniel Hryhorczuk Page 3 August 9, 1982 - DRAFT is involvedlin litigation with the State of Illinois. During the course of this litigation, our counsel advises us not to voluntarily disclose plant waste-related information. I hope that we've been of some help to you in your endeavor. Sincerely, PROTECTIVE ORDER. su bject to 014167