Document DD3dELo9DZDaRq18Vk91yB2NB

H.' L. Minckler . V. B. Papageorge P. S. Park S* Pickard, Wash., B.C. J. E. Springgate. t i P. Wheeler June 30, 1970 Bon. WiIlian F. Ryan Bouse of Representatives Washington, 0. C. Bear Congressman Ryan: This vill serve to acknowledge your letter of.June 18 referring to vhat you describe as Monsanto's unwillingness to deal candidly with the chlorinated biphenyl issue. 1 believe your implications to be entirely unwarranted and based on a complete .lack of factual information. -- Firstly, I vould like to describe to you the actions vhich this company has taken and vill continue to take to ensure that the chlorinated biphenyls present the minimum possible threat to the environment. Secondly, I vill answer the individual points reised in your letter to ensure that you are fully aware of the current poriticn. ., . * At cur meeting in'your office last April, Mr. Pickard end 1 endeavored to clarify for you son* of the misconceptions on vhich ycur earlier press release ves bared. At that tine, ve .were unable to give you full details cf many of our plans and act lone as these involved several of our customers using chlorinated biphenyls and it vss necessary to discuss details vith then prior to public disclosure. Since that time, all of cur customers have been contacted both verbally and by letter end I am hov in a position to. explain our plans and actions in detail. Based on the findings of our own and many Independent scientists, ve beileve that it is necessary to rigidly control the manufacture, .use and disposal of chlorinated biphenyls to avoid build-up In the environment. Ve have, there fore, taken the position that as the manufacturer and distributor of a range of chlorinated biphenyls ve have a responsibility to ensure that they are used only in applications where their unique properties are vitally important to industry end the economy and where usage and eventual disposal can be monitored and controlled. Bov are ve fulfilling this self-imposed responsibility! 905649 1. We have taken the decision that effective from the 30th of August ve vill no lenger sell the chlorinated biphenyls to customers for use in general plasticizer applications vhere disposal of the end r< AINTIFF S EXHIB'T / s7 0 1003 146 3491 products cannot be controlled. This includes all the applications referred to in .our bulletin 0/PL-306. All of our customer! vho have used these products in the past for these applications have been advised of this decision both verbally and by formal letter Ve are vorking closely with them to recotmend suitable alternative products vhlch present no danger to the enviroiaent. .. In many of the applications vhere chlorinated biphenyls are used as hydraulic fluids, ve are not satisfied thet it is possible to control their usage and eventual disposal to ensure that there is no possibility of escape to the environment. Wo have therefore taken the decision to reformulate such fluids end ve are currently vorking vith our customers to change over to these nev formulations. A substantial part of this-program vill be completed vithin the course of the next three months and in other areas vhere performance requirements are difficult to achieve vith alternative products, ve consider it vill take until the end of 1970 to complete change-over. In areas vhere the chlorinated biphenyls are used in closed system applications, e.g. transformers, capacitors, and heat transfer fluids, ve vill continue to sell the chlorinated biphenyls as their unique, fire-resistant properties ore extremely important in ensuring maximum protection for the safety and vell-boing of the population of this country. As you should be avare, the msjer usage for the chlorinated biphenyls is as coolants in transformers vhere they heve replaced such other materials as oil end have greatly reduced tkc'rlsk of fires and explosions vhlch in the past have often had disastrous results in terms -of human lives. These closed system applications c t c such that by vorking'together vith our customers, ve can avoid emissions to the environment. Coupled vith this decision to continue selling chlorinated b.phenyls for closed system usege, ve have established a service to collect spent fluids vhlch are returned to our manufacturing sites for regeneration or destruction in a specially designed, high-tenp-urature incinerator. This incinerator breaks down the chlorinated biphenyls *lnto harmless materials, mainly hydrochloric acid vhlch is scrubbed out of the waste gas stream, neutralized and passed through our . . vaste treating facilities .. Although ve aTe confident that ve can achieve a very high degree of control in these closed system applications, ve are not completely satisfied and ve are vorking to develop modified chlorinated biphenyls vhich vill be biodegradable. This means that even if minute quantities of chlorinated biphenyl are released to the environment by accidental spills and/or leakage, it vill be possible to renmvc them from vaste vater streams in conventional secondary treatment facilities. 905650 3492 147 '1003 J!) In ay opinion, Congressman Ryan, these actions and plans indicate that Monsanto la taking nn-.extrcncly responsible attitude to this problem end is doing everything within its power to ensure a caxinun degree of control to prevent the possibility of the chlorinated biphenyls escaping into the environacat. I vould rcaind you that these actions ere being taken by the cccpany on a voluntary basis and without direction either by federal or state goverment authorities. I will now return to the individual questions raised in your letter. You inply that Monsanto hes not sought the opinions of oen like Dr. Robert Risebrough. This is completely untruel Surely you must remember et cur April meeting I told you that three members of Monsanto, Dr. Robert E. Keller, Manager of Applied Sciences, Mr. Uilliaa 3. Pnpagcorge, Manager, Environmental Control, and Mr. Elmer P. Uhceler, Manager, Environmental Health, Medical Department,- all traveled to California erpecielly to visit Professor Ollcott and Dr. Risebrough at the University of California in Berkeley. They reported to me that they had a cost useful exchange of ideas and opinions with.Dr.- Risebrough covering the toxicity of the chlorinated biphenyls, Monsanto*s plans to develop substitute products, detailed discussion on analytical techniques and on the work carried out by Dr. Risebrough on the effects of the chlorinated biphenyls on birds and fish. At the end of the day, Dr. Risebrough expressed appreciation of Monsanto's approach and was glad to note that the company was taking a responsible position on the chlorinated biphenyl problem. Aa you are well aware, there are cany other worker* in this particular .'field and during the last two weeks of Kay, the Individuals referred to above visited Europe to meet and exchange information and opinions with the following: ' * \* a - professor Vidmark - Sweden (As you r^y be aware, Professor Vldnsrk was the first worker in this particular field, identifying the presence of chlorinated biphenyl in birds.) - Scientists of the Food & Hygiene Depertsent of the Public Health Service Sweden Dr. Koeaon - Professor Von Gerderen (Eoth of these gentleman are froa the University of Utrecht ***"" ! Holland.) . The Government Chemist - United Kingdoa Fresh Veter and Fisheriee Laboratories * Scotlend ' Mature Conservancy Scientists - England The Laboretorles of Agriculture and Fisheries ct^Tolvorth a o l 4 - 9 3 Bumhan-on-Crouch - England 905651 148 1003 Vo In addition, a 1 advised you in ny previous letter, Monsanto has held several oaetingsvith various federal and state agencies to exchange informa tion on the chlorinated biphenyl lesue. Luring the month of July, Mr. Papageorge and Mr. ITheeler will sake further visits to a number of govern ment and state agencies to bring then u?-to-detc on the results of our latest toxicity studies on the chlorinated biphenyls and to make then avare of progress in implementing our plans to phase out of noh-contrellable applications and the development of substitute products. During these proposed discussions, ve will welcome constructive criticism, consents and recommendations and if Dr. RiEcbrough or any other individual working in this field would lihe to meet with ua, they vlll be extremely welcome. * .* You consider that our reply to your questions on possible emissions to the environment from our manufacturing operations is vague and that ve avoided responding to specific questions concerning the type of controls in use. This is not the case and the following additional information should make this quite clear. * The process for the manufacture of chlorinated biphenyls is a relatively simple, high-yield reaction with no inherently difficult emission problems. There are no stack gasses or water streams which are in contact with the product during the manufacturing process. Control of emissions is therefore concerned with prevention of leakage and spillage and safe disposal of any material which may escape in this way. The following covers the major methods ve use to control poasible'escape: 1. High priority is given to maintenance of pipes, joints,'valves and p e p s to avoid leakage. 2 Curbs and drip pans have been provided to collect any leaks from such equipment where trouble may possibly develop. 3. Continuing indoctrination of all plant personnel is practiced to be sure that they completely understand the importance of preventing losses to the environment. In our opinion, this is one of the key areas in any pollution control effort. 4 , -Ve are currently constructing catch basins in the main sever of each of our chlorinated biphenyl plants as an added safety measure to collect any material which cay pass the other safety devices. 5. Air emissions are virtually ncn-enictent as the boiling point of chlorinated biphenyl is extremely high and it can, in fact, only be distilled under high vacuum. This means that vapors are easy to control and they are returned to the system by means of condensers. 905652 3494 149 100371