Document JNrZo8GeREMzv5qwvarBwe5M6

188 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BROOME JAMES L. and BARBARA A. FURCH, et al., Plaintiffs, Vs. . GENERAL ELECTRIC COMPANY, et al. Index No. 1370/1982 RJI No. 8 6 -110 7-M Defendants. INDEX OF PLAINTIFF'S EXHIBITS EXHIBIT NO. 400 through 416 through 432 ................... 433 .................... 434 ................... 435 ................... 405 431 PAGE MARKED .228 . 299 .364 . 3 6 5 -i .371 : .389 ` J VOLUME II DEPOSITION OF WILLIAM B. PAPAGEORGE, On behalf of Plaintiffs April 28, 1999 P.E. GATEWAY REPORTING ASSOCIATES, INC. 515 Olive Street, Suite 1506 St. Louis, MO 63101 (314) 621-2571 k'M Gateway Reporting Associates, Inc. WATER PCB-SD0000071133 189 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BROOME JAMES L. and BARBARA A. FURCH, et al., _ Plaintiffs, Vs. GENERAL ELECTRIC COMPANY, et al. Index No. 1370/1982 RJI No. 8 6 - 110 7-M Defendants. CONTINUED DEPOSITION OF WILLIAM B. PAPAGEORGE, P.E., produced, sworn and examined on behalf of the Plaintiffs, April 28, 1999,.between the hours of eight o'clock in the forenoon and six o'clock in the afternoon of that day, at the offices of Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri, before FAITH A. OLLIGES, a Registered Professional Reporter and a Notary Public within and for the State of Missouri. APPEARANCES Plaintiffs were McDonough of the law Farnetti, 117 Hawley 13902-1740 . represented by Mr. Kevin F. firm of Ball, McDonough, Artz Street, Binghamton, New York & Defendant Monsanto was represented by Mr. John C. Sabetta of the law firm of Seyfarth, Shaw, Fairweather & Geraldson, 1270 Avenue of the Americas, Suite 2500, New York, New York 10020-1801 and Mr. Timothy Peck of the law offices of Smith, Helms, Mulliss & Moore, L.L.P., Suite 1400 300 North Greene Street, Greensboro, NC 27420 . Defendant General Electric was represented by Mr. Eric E. Grondahl of the law offices of Cummings Lockwood, CityPlace I, 185 Asylum Street, Hartford, Connecticut 06103-3495. & Also present was Plaintiff James Furch. Gateway Reporting Associates, Inc. WATER PCB-SD0000071134 Gateway Reporting Associates, Inc. 190 1 WILLIAM B. PAPAGEORGE, P.E., 2 of lawful age, being produced, reminded of his oath, and 3 examined on the part of the Plaintiffs, deposes and 4 says : 5 CONTINUED DIRECT EXAMINATION 6 QUESTIONS BY MR. McDONOUGH: 7 Q. Good morning, Mr. Papageorge. 8 A. Good morning. 9 Q. I remind you you're still under oath, and 10 I'd like to ask you a few more questions if I can. 11 A. I'm ready. .. 12 Q. Would you please put that book of exhibits 13 in front of you again and open it up to tab 14, if you 14 would? 15 A. I have it. 16 Q. All right. We've placed an exhibit tag on 17 that exhibit as 392; is that correct? 18 A. Yes. 19 Q. 392 purports to be a March 3rd, 1969 20 correspondence over the typed signature of Elmer Wheeler 21 on Monsanto Company letterhead with no addressee; is 22 that correct? 23 A. That is correct. 24 Q. Have you seen this document before? 25 A. Yes, I have. Gateway Reporting Associates, Inc. WATER PCB-SD0000071135 Gateway Reporting Associates, Inc. 191 1 Q. What is it? 2 A. This is a copy of a letter composed by 3 Mr. Wheeler and sent to many customers of Monsanto's 4 PCBs . 5 Q. How did it come about that you happened to 6 see it? 7 A. During my tutorial, and I forget at what 8 point in the period, Mr. Wheeler showed me a copy. That 9 was my first exposure to it. 10 Q. And this would.be the tutorial that took 11 place in the first month or two after your employment in 12 I think you said January of 1970? 13 A. That's correct. 14 Q. And do you know whetherGeneral Electric 15 received a copy of this? 16 A. I understand they did. 17 Q. Did Monsanto ever keep a listof addressees 18 of correspondence such as this? 19 A. Normally they do. I cannot speak for this 20 particular... 21 Q. And what department or individual at 22 Monsanto would be in charge of transmittal of such 23 matters and keeping of the list? 24 A. The assignment of the subject matter to be 25 covered varies depending on what the subject is and who Gateway Reporting Associates., Inc. WATER PCB-SD0000071136 REPORTING ASSOCIATES PHONE NO. : 3142415565 Jun. 03 1999 10:40AM P2 Gateway Reporting Associates, Inc. X92 1 is in the position to know the most about it. Once that 2 person is appointed to do that assignment, it's up to 3 him or her to keep the records. 4 Q. Do you know whether Mr, Benignus might have 5 played a role in this? S A. When you say "might," that's possible. I 7 don't know. S Q. Well, do you know anybody else, any other 9 name at Monsanto that might have played a role in the 10 sending out of this document? . 11 MR. SABETTA; object to the form. 12 A. Again, when you say "might" - - 13 Q. Well, remove "might". Who probably would 14 have played a role in sending out this document? 15 A. 1 would suggest that the group that we 16 referred to earlier as the Ad Hoc PCB Committee, I think 11 we did. Nevertheless, there were some individuals 18 involved with addressing the subject of PCBs in the 19 environment. That would appear to me to be a logical 20 group to participate in the decision to send the letter 21 and what should be contained in that letter. 22 Q. Did you ever see any written practice or 23 procedure with respect to sending correspondence to 24 customers with respect to this PCB matter? 25 A. No, I have not. Gateway Reporting Associates, Inc. WATER PCB-SD0000071137 Gateway Reporting Associates, Inc. 193 1 Q. Do you know if any such practice or 2 procedure in writing exists? 3 A. I have never seen one. I do not know. 4 Q. Would you turn to tab 15 for me, please? 5 Has that exhibit been marked with a 392 exhibit tag? 6 A. Yes. 7 MR. SABETTA: 393. 8 A. I'm sorry. 9 Q. Exhibit 393 purports to be a memo from W. 10 R. Richard to E. Wheeler, dated March 6th, 1969, 11 "Aroclor Wildlife Accusations"; is that correct? That's 12 what it appears to be? 13 A. That is correct. 14 Q. Have you seen that document before? 15 A. Yes, I have. 16 Q. And how did it come about that you saw that 17 document ? 18 A. Mr. Wheeler gave me a copy in January of 19 1970 . 20 Q. Was this document in that two three-ring 21 binders that you told us about yesterday? 22 A. I don't recall it as being part of the 23 collection of documents in that binder. This most 24 likely was a separate contribution to my information 25 that I was accumulating. Gateway Reporting Associates, Inc. WATER PCB-SD0000071138 Gateway Reporting Associates, Inc. 194 1 Q. Was Exhibit 392 also most likely a separate 2 document from that two three-ring binders? 3 A. Yes. 4 Q. What was contained in the two three-ring 5 binders? Was it a particular sort of material? 6 MR. SABETTA: Objection as asked and 7 answered. You can answer it again. 8 A. It consisted primarily of what I'm going to 9 call medical-type information, toxicology reports, 10 exposure limits, that kind of subject matter. 11 Q. Were all the documents prepared by Monsanto 12 employees that you saw yesterday during our deposition 13 and these two, 392 and 393, made and kept by Monsanto in 14 the ordinary course of their business? 15 MR. SABETTA: Objection to the form. 16 A. Yes. 17 Q. If you look at the second page of Exhibit 18 392 at the bottom - 19 MR. SABETTA: You're saying 392. I think 20 you mean 393. 21 Q. I'm sorry. Yes. 393. If you look at the 22 second page of 393 at the bottom, the last entry says, 23 "Well-prepared discussions with Industrial Bio-Test, 24 Monsanto's biochemist, the Medical and Legal Departments 25 must take place now." Do you see that? Gateway Reporting Associates, Inc. WATER PCB-SD0000071139 Gateway Reporting Associates, Inc. 195 1 A. Yes, I do. 2 Q. Do you know if such discussions did take 3 place? 4 A. Certainly. Yes, they did. 5 Q. Did you participate in any discussions with 6 Industrial Bio-Test, the Monsanto chemists, the Medical 7 and Legal Departments where they were all together on 8 this PCB matter? 9 A. I don't recall a meeting in which all of 10 these that are listed here were present at the same 11 time. ^ 12 Q. How about any grouping of two or more of 13 those entit ies, Industrial Bio-Test, Monsanto's 14 biochemist, the Medical and Legal Department? Did you 15 participate in any meetings with two or more of those 16 groups? 17 A. Yes . 18 Q. How many such meetings? 19 A. I never kept score, sir. It's part of my 20 job. I did it often. . 21 Q. If we limit it to the group Medical and 22 Legal Depar tments, did you meet with them in a meeting? 23 A. Occasionally. I'm assuming you mean them 24 at the same time? 25 Q. Yes . Gateway Reporting Associates, Inc. WATER PCB-SD0000071140 Gateway Reporting Associates, Inc. 196 1 A. Occasionally. 2 Q. Was there a regularity to those meetings? 3 MR. SABETTA: Objection to form. 4 A. By regularity, you mean a certain day and 5 hour, week and so on? 6 Q. No. How did it come about that you met 7 with the Legal and Medical Department together? 8 MR. SABETTA: Object to the form. 9 A. It only happened when whoever called the 10 meeting decided that the presence of the other 11 profession would be helpful in the discussion, and 12 depended on whether the legal person called a session or 13 the medical person called the session. 14 Q. Were there agendas for these meetings in 15 writing? 16 A. No . 17 Q. Were there minutes kept of these meetings? 18 A. No. 19 Q. Who in the Legal Department did you most 20 often deal with on this PCB matter? 21 A. There again, I did not keep a score on the 22 number of times, but there were several attorneys in 23 Monsanto, and whoever was available would show up. I 24 didn't keep score. 25 Q. Aside from whether you kept score or not, Gateway Reporting Associates, Inc. WATER PCB-SD0000071141 Gateway Reporting Associates, Inc. 197 1 was there a certain attorney or more than one attorney 2 that participated in PCB matters at Monsanto? 3 MR. SABETTA: Objection to form. 4 A. There was more than one. 5 Q. Can you give me the names? 6 A. Yes. I'll try to remember them. Phocian 7 Park was one. 8 . Q. I'm sorry? 9 A. P-H-O-C-I-A-N P-A-R-K. I'm trying to 10 remember the name of the other attorney. Stapleton was 11 his surname, S-T-A-P-L-E-T-O-N. There was a third one, 12 Tom. His name doesn't come to mind. . 13 Q. Is that it? 14 A. As best I can remember, yes, sir. 15 Q. Do you know if any of these gentlemen still 16 work for Monsanto? I'm assuming they are all gentlemen. 17 Maybe I'm-- 18 A. Yes, they are males. I don't believe any 19 of them are still working for Monsanto. 20 Q. Do you know if they still are alive and 21 live in the St. Louis area? 22 A. To the best of my knowledge, yes. 23 Q. Would you turn to tab 16 for me, please? 24 We've marked as Exhibit 394 a memo on Monsanto 25 letterhead over the signature of P. G. Benignus, dated Gateway Reporting Associates, Inc. WATER PCB-SD0000071142 Gateway Reporting Associates, Inc. 198 1 March 17th, 1969, the "Regional Water Quality Control 2 Board". Let me rephrase that. We've marked as 394 a 3 letter over the signature of P. G. Benignus to H. S. 4 Bergen, B-E-R-G-E-N, on the subject of the Regional 5 Water Quality Control Board. Have you ever seen that 6 document before? 7 A. As I scan the document, it does not help me 8 recall ever seeing it before. I don't remember seeing 9 it . 10 Q. The documents that .you were provided as 11 part of your tutorial by Mr. Wheeler, did they come in 12 the form of a notebook or a file or something of that 13 sort? 14 MR . SABETTA: Objection as asked and 15 You c an answer it again. 16 MR. MCDONOUGH: Let me withdraw it. 17 MR . SABETTA: I thought he testified he got 18 two binders. 19 Q. I want to make it clear. I'm not asking 20 about them. As I understand it, you've told us that you 21 received two binders that generally had scientific and 22 medical information in them, is that correct, in the 23 course of this tutorial? 24 A. Yes, sir. 25 Q. You've also indicated you received other Gateway Reporting Associates, Inc. WATER PCB-SD0000071143 Gateway Reporting Associates, Inc. 199 1 documents during this tutorial, and I'm asking whether 2 those other documents came in the form of a notebook or 3 a file or in what fashion did they come to you? 4 A. They were individual. If it was multi 5 page, it was stapled and without a file or a folder or a 6 binder. 7 Q. They came to you loose? 8 A. Yes. They just would hand it to me across 9 the table. 10 Q. Were they in chronological order? 11 A. Not necessarily. .. 12 Q. Did they come all at onetime? 13 A. No. 14 Q. How did it happen that they came to you at 15 different times during this tutorial? 16 A. I, sir, am in no position to know how 17 Mr. Wheeler and others arrived at the decision to bring 18 along a given document. 19 Q. Well, were you talking about a particular 20 topic and then Mr. Wheeler would give you some 21 correspondence or document pertaining to that particular 22 topic? 23 MR. SABETTA: Objection to form. 24 A. At times that happened, and there are other 25 times when the presence of the document created the Gateway Reporting Associates, Inc. WATER PCB-SD0000071144 Gateway Reporting Associates, Inc. 200 1 subject of the moment. 2 Q. Did he give you the document before the 3 discussion took place? 4 MR. SABETTA: Obj ection to form. 5 A. At times. 6 Q. Was there an agenda or anything in writing 7 with respect to this tutorial as to how it was conducted 8 or to be conducted? 9 A. No, sir. ' 10 Q. Would you turn to tab 17 for me, please? 11 Has that been marked Exhibit 395? 12 A. 11 i s . 13 Q. That purports to be a memo from W. R. 14 Richard, dated April 14th, 1969, to P. Benignus on the 15 subject of disposal and incineration of Aroclor. Is 16 that what the document appears to be? 17 A. Yes. 18 Q. Have you ever seen that before? 19 A. Yes. 20 Q. Did that come to you during the course of 21 this tutorial? 22 A. When we say "this tutorial," I'm under the 23 assumption you're still referring to Mr. Wheeler's 24 discussion with me. Is that a correct assumption? 25 Q. Let me withdraw the question and begin Gateway Reporting Associates, Inc. WATER PCB-SD0000071145 Gateway Reporting Associates, Inc. 201 1 over. How many tutorials did you have after you started 2 in January of 1990 in the job assignment that you had? 3 A. _ Again, I never counted. I would suggest 4 that I had half a dozen or so. 5 Q. And those half dozen or so took place in 6 the 30 days after you started work in January of 1970? 7 A. No. In I would suggest the 90 days, 8 January, February, March period. 9 Q. How long did these half dozen tutorials 10 take? . . 11 A. Oh, again, part days. .They were not 1.2 full-day discussions. - 13 Q. So as I understand it, you had six part-day 14 discussions that you are calling a tutorial? 15 A. Well, some of these discussions were multi 16 days. Like Mr. Wheeler's lasted for six weeks of them. 17 Q. That's what I'm trying to find out, 18 Mr. Papageorge, how long these tutorials took place, 19 what period of time they occurred. ' 20 A. I have no record of dates and times. 21 Q. I didn't ask you about dates and times. As 22 I understood yesterday, you said you had tutorials, as 23 you phrased it, that lasted over a 30-day, perhaps 24 60-day time period from January 1970 forward. Do I 2 5 understand that correctly? Gateway Reporting Associates, Inc. WATER PCB-SD0000071146 Gateway Reporting Associates, Inc. 202 1 A. If you understood that to refer to 2 Mr. Wheeler's tutorials, that is correct, yes. 3 Q. That refers only to Mr. Wheeler's 4 tutorials? 5 A. That's all we were talking about. 6 Q. What particular -- Withdrawn. Who gave you 7 the two notebooks? 8 A. Mr. Wheeler. 9 Q. Did you have tutorials with anyone else in 10 the first 90 days after January 1970 other than 11 Mr. Wheeler? 12 A. We just talked about another half a dozen 13 or so people. . 14 Q. You're saying you and I just talked about 15 that ? 16 A. That was one of the questions this morning. 17 Q. Who is this half dozen or so other people? 18 A. Oh, there were two research directors of 19 the two business groups. 20 Q. Who would they be? 21 A. Dr. Richard and Dr. Ferrar. 22 Q. What was Dr. Ferrar's training? 23 A. Training? 24 Q. Yeah. 25 A. He's a Doctor of Science in Chemistry. Gateway Reporting Associates, Inc. WATER PCB-SD0000071147 Gateway Reporting Associates, Inc. 203 1 Q. Dr. Richard, I can't remember if you told 2 me yesterday what his particular field of specialty was 3 and training. 4 A. He is also a Doctor of Science in 5 Chemistry. 6 Q. Would you continue to tell me the other 7 people that you had these tutorials with in this 90-day 8 period? 9 A. I had tutorials with the marketingpeople, 10 for example, Mr. Benignus, whose name hasappeared here 11 in some of these documents, a Mr. Johnson, who is also a 12 marketing individual. 13 Q. Can you tell me what Mr. Johnson's full 14 name is, first name anyway? 15 A. Norman. Norman Johnson. 16 Q. Do you know whether he had any particular 17 area of training? . 18 A. Not really, no. 19 Q. Did Mr. Benignus 'have any field of training 20 that you're aware of? 21 A. Yes . 22 Q. What was that? 23 A. Bachelor's degree in Chemistry, 24 Q. Were there others that you participated in 25 tutorials wi th in that first 9 0 days? Gateway Reporting Associates, Inc. WATER PCB-SD0000071148 Gateway Reporting Associates, Inc. 204 1 A. Mr. Springgate and Mr. Bergen, the two 2 directors of the two business groups. I'm trying to 3 recall the name of the member of the corporate 4 engineering department. It doesn't come to mind right 5 now. Mr. Kuhn and Mr. Savage. I'm sorry. Mr. Kuhn, 6 who represented the manufacturing activity. 7 Q. Do you know whether he had a particular 8 area of training? 9 A. Yes. He had a Bachelor's degree in 10 Chemical Engineering. Dr. Keller and Dr. Tucker from 11 the analytical research group. 12 Q. Were they both toxicologists? Let me 13 withdraw that. I think you told me Dr. Keller was a 14 Ph.D. in Organic Chemistry. 15 A. Well, I don't know what type of -- a Ph.D. 16 in Chemistry. 17 Q. What about Dr. Tucker? 18 A. Dr. Tucker had -- 19 Q. What specialty did he have? 20 A. -- a Ph.D. in Analytical Chemistry. 21 ' Q. Any other people that you recall talking to 22 during your tutorial in this 90-day period? 23 A. Paul Hodges and his supervisor, Desmond 24 Hosmer, D-E-S-M-O-N-D H-O-S-M-E-R, who represented the 25 manufacturing activity. Gateway Reporting Associates, Inc. WATER PCB-SD0000071149 Gateway Reporting Associates, Inc. 205 1 Q. Do you know what his field of training was? 2 A. What? Mr. Hodges or Mr. Hosmer? 3 Q. . Mr., Hosmer. 4 A. Mr., Hosmer, a Bachelor's degree in Chemical 5 Engineering. 6 Q. What about Mr. Hodges? 7 A. The same degree. 8 Q. Anyone else that you consulted with during 9 your tutorial in this 90-day period? 10 A. I spoke with at least one attorney. I'm 11 trying to think of the others that might have been 12 involved, but I can't at the moment. 13 Q. Do you recall which attorney that was? 14 A. Mr. Park. 15 Q. Do you recall the subject of that 16 conversation? 17 A. Just general review of his understanding of 18 the issue from his position. 19 Q. Do you recall what he told you? 20 A. I don't remember the specifics. 21 Q. Do you recall the names of any other 22 attorneys, in-house attorneys I'm talking about, that 23 you met with during this 90-day period? 24 A. I don't think I met with any of the other 25 attorneys at that time. Gateway Reporting Associates, Inc. WATER PCB-SD0000071150 Gateway Reporting Associates, Inc. 206 1 Q. Do you recall speaking to anyone else in 2 this tutorial period? 3 A. _ I spoke with John Mason, who was my boss's 4 boss . 5 Q. Who was your boss? 6 A. Howard Bergen. 7 Q. What was Mr. Mason's field of training? 8 A. I don't think I ever knew. He was from 9 England, so I don't know what kind of degrees they gave 10 there. 11 Q. Did his area of specialty manifest itself 12 to you in the course of your discussions with him? - 13 A. No. 14 Q. Did you talk about the baseball team? 15 MR. SABETTA: Objection to form. 16 A. I don't understand. 17 Q. Do you recall what you talkedabout with 18 Mr. Mason? 19 A. He discussed with me his understanding of 20 the PCB environmental issue from his position and really 21 his hopes that I could kind of help, out a bit with my 22 new assignment. That kind of discussion. Sort of a 23 welcome to the team approach. 24 Q. Do you recall talking to anyone else during 25 this tutorial period? Gateway Reporting Associates, Inc. WATER PCB-SD0000071151 Gateway Reporting Associates, Inc. 207 1 A. At the moment, I can't recall any others. 2 Q. Do you recall the general purpose of why 3 you were going through this tutorial with these various 4 individuals? ' 5 A. This was my way of getting tuned into the 6 situation and getting updated on the details as much as 7 I could understand and absorb. 8 Q. And the situation would be the 9 environmental concerns with PCBs? 10 A. Yes. . 11 Q. You say "your way". Are you saying that 12 you're the one that steered your tutorial as to being 13 brought up to speed on PCBs? 14 MR. SABETTA: Objection to form. 15 A. I am the one that instituted the activity 16 and made the appointments and found the individuals to 17 talk to. 18 Q. Before you did that, did you meet with 19 people who called you into session to discuss things 20 with you? 21 A. I don't remember any such activity. 22 Q. Do I understand generally that you arrived 23 at work in your new assignment, sat down at your desk 24 and decided who you wanted to call? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071152 Gateway Reporting Associates, Inc. 208 1 Q. Did you have your three-ring or your two 2 three-ring binders at that point? 3 A. . No. 4 Q. Did you have anything at that point? 5 MR. SABETTA: Objection to form. 6 A. I had some things. 7 Q. I mean, let me ask another question. Did 8 you have anything on the topic of environmental issues 9 with PCBs at that point when you sat down at your desk 10 on that day? . 11 A. I did not. 1,2 Q. Did you ever have a discussion with anyone 13 as to why your position was created? 14 A. Yes. 15 Q. Who did you discuss that with? 16 A. Mr. Bergen and Mr. Springgate. 17 Q. Was that discussion prior to you being 18 given your new position or after? 19 A. Prior to. 20 Q. What did they tell you? 21 A. December of '69. 22 MR. SABETTA: I think he said what. 23 Q. As I understand it, you had conversations 24 in December of 1969 time period with Mr. Springer. 25 MR. SABETTA: Mr. Springgate. Gateway Reporting Associates, Inc. WATER PCB-SD0000071153 Gateway Reporting Associates, Inc. 209 1 Q. Mr. Springgate and Mr. Bergen; is that 2 correct? - 3 A. . Yes. 4 Q. Was that both of them participating in the 5 conversation, or were there separate conversations? 6 A. Separate. 7 Q. And what did Mr. Springgate tell you? 8 A. Sir, I just can't remember the details. 9 Q. Aside from the details, can you tell me 10 generally what Mr. Springgate and Mr. Bergen told you as 11 to this assignment? . ^ 12 A. It was generally the sharing with me of 13 their understanding of the findings of PCB in the 14 environment, the fact that there are two business groups 15 who were selling PCBs, and they were interested in doing 16 what was perceived to be responsible, and they were 17 trying to find someone to help with this matter. 18 Q. And that matter would be what? 19 A. PCBs in the environment. 20 Q. Did they tell you in substance what you 21 were supposed to do to help with this matter? 22 A. I don't know what you mean by in substance. 23 Do you mean in detail? 24 Q. Did they tell you what you were supposed to 25 do to help with this matter in these conversations in Gateway Reporting Associates, Inc. WATER PCB-SD0000071154 Gateway Reporting Associates, Inc. 210 1 December of 1969? 2 A. I don't recall the exact wording, but I was 3 left with the impression that a lot of activity was 4 underway, more than the usual team could handle, and 5 they wanted someone who could devote full time to 6 communicating in terms of gathering information and 7 disseminating information. 8 Q. Were you told who you were supposed to 9 disseminate information to? ' 10 A. Yes. 11 Q. Who? , 12 A. People within Monsanto whose job . 13 assignments involved PCBs. Any inquiries coming from 14 other laboratories, customers, government agencies 15 co-producers -- not co-producers, but competing 16 producers. I can't think of any other group. 17 Q- You were supposed to disseminate 18 information to competing producers of what? 19 A. PCBs is the subject we're talking about. 20 Q. Had anybody produced PCBs in the United 21 States at that time other than Monsanto? 22 A. Not to our knowledge. 23 Q. So these competing producers would be 24 located in other countries? Is that what I understand? 25 A. Yes. Gateway Reporting Associates, Inc WATER PCB-SD0000071155 Gateway Reporting Associates, Inc. 211 1 Q. Did you disseminate information to 2 government agencies? 3 A. Certainly. 4 Q. What agencies? 5 A. Well, certainly the Food and Drug 6 Administration, the Department of Agriculture, 7 Department of Interior, Department of Commerce. The 8 Office of -- I don't think I remember the name properly. 9 The Office of Science and Technology or some such 10 wording. And eventually the EPA and OSHA, O-S-H-A, the 11 Corps of Engineers, the military department, Defense 12 Department. That's all that comes to mind at the 13 present. 14 Q. Did the Office of Science and Technology 15 come directly under the President of the United States? 16 A. Sir, I'm not an expert at the government 17 organization. 18 Q. I don't think anybody proposes to be. 19 MR. SABETTA: If you don't know, you can 20 say you don't know. 21 A. I just don't know. 22 Q. You said that you were to gather 23 information, devoting full time to that as well as the 24 dissemination of information. Were you told where you 25 were supposed to gather the information from? Gateway Reporting Associates, Inc. WATER PCB-SD0000071156 Gateway Reporting Associates, Inc. 212 1 A. No. That was part of my assignment. 2 Q. Part of your assignment was to figure out 3 where you -were supposed to gather the informationfrom? 4 A. Yes. 5 Q. Did you understand you were supposed to 6 gather information from scientists? 7 A. Information from anyone. 8 Q. Up and to this point, January of 1970, had 9 you testified on behalf of Monsanto in any proceedings? 10 A. No. - 11 Q. Since January 1970, have youtestified on 12 behalf of Monsanto in proceedings? 13 A. Yes. 14 Q. About how many? 15 A. There again, I never kept a score sheet, 16 but since 1973 I would suggest that I'm approaching 40 17 or 50. This includes trial and deposition, under oath. 18 Q. Did you also make presentations to various 19 government agencies since January 1970? 20 A. On January? 21 Q. Since January of 1970. 22 MR. SABETTA: Concerning PCBs or any 23 subj ect ? 24 Q. Let's take any subject. Didyou make any 25 presentations to any government agency since January of Gateway Reporting Associates, Inc. WATER PCB-SD0000071157 Gateway Reporting Associates, Inc. 213 1 1970 on any subject other than PCBs? 2 A. Will you help me with the expression 3 "presentation"? You're talking about a formal setting 4 or a face-to-face, one-on-one discussion? 5 Q. Let's start with formal. 6 A. Yes, I have. 7 Q. And how many formal presentations? 8 A. I don't again have a score sheet. I'm 9 going to suggest that it's less than six, less than half 10 a dozen. 1 11 Q. What's a formal presentation? 12 A. I'm sorry. What formal -- 13 Q. What is a formal presentation in your mind 14 as you've answered that question for me? 15 A. It generally in my mind involves a group of 16 audience -- group of people to form the audience, is 17 generally something that is prepared in advance in terms 18 of subject matter and mode of presentation, and might 19 include charts or handouts that are shared with the 20 audience, projection of slides on a screen, and that 21 type of activity. 22 Q. You mentioned -- Withdrawn. Other than 23 formal presentations, have you made other presentations 24 to government agencies? 25 A. I had what I prefer to call discussions Gateway Reporting Associates, Inc. WATER PCB-SD0000071158 Gateway Reporting Associates, Inc, 214 1 with maybe a couple individuals from an agency or one 2 individual, or they might start off with one, and he 3 would call in others to join us, and the group kind of 4 grew as the day progressed, and the topic was free 5 ranging, depending on the interest of the group and the 6 questions they posed. 7 Q. About how many of those sort of discussions 8 did you have? 9 A. I never kept score. I don't know. 50 or 10 so. I don't know. . 11 Q. Did you meet with General Electric Company 12 from January of 1970 through the time you retired with 13 respect to PCBs? 14 A. Yes. 15 Q. About how often? 16 A. Will you help me with again -- When you say 17 General Electric, are you referring again to a group of 18 people or individuals involved with various activities 19 at a meeting somewhere? 20 Q. Do you have in your head formal 21 presentations with respect to General Electric as 22 something that you want me to include in my question? 23 MR. SABETTA: Objection to form. 24 A. Well, it would help in my mind to come up 25 with some idea of the numbers that you asked for. Gateway Reporting Associates, Inc. WATER PCB-SD0000071159 Gateway Reporting Associates, Inc. 215 1 Q. Well, how many discussions or meetings did 2 you have with General Electric or its employees or 3 consultants? 4 MR. SABETTA: Objection to form. Are you 5 including in this telephone discussions, for example? 6 Not necessarily face no face. 7 MR. MCDONOUGH: Yes. 8 MR. SABETTA: In other words, all contacts, 9 all oral contacts with GE representatives? 10 MR. MCDONOUGH:. Yes. . 11 MR. SABETTA: Not including writings, but 12 oral contacts. That's the scope of Mr. McDonough's 13 question. 14 A. Since I never kept a scoresheet on this, 15 many, many discussions. 16 Q. Hundreds? 17 A. Could be. 18 Q. Did General Electric ever come to St. Louis 19 and meet with you in the form of its employees? 20 A. I attendedmeetingsinvolving personnel 21 from General Electric in a room bigger than this at 22 which many topics were raised. One of them was the 23 environmental issue. At that point, I would actively 24 participate. 25 Q. About how many of these meetings from Gateway Reporting Associates, Inc. WATER PCB-SD0000071160 Gateway Reporting Associates, Inc. 216 1 January 1970 through January 1980? 2 MR. SABETTA: Objection to form. Again, is 3 this in St. Louis or anywhere? 4 MR. MCDONOUGH: In St. Louis. 5 MR. SABETTA: In St. Louis, okay. 6 A. I can remember two. 7 Q. Were those formal presentations? Were 8 there agendas? 9 A. Yes. 10 Q. Were there minutes .kept? 11 A. I recall there was some notes taken by a 12 participant that were distributed later. I don't know 13 if you'd call those true minutes or not. 14 Q. Who was the employer of this participant? 15 A. Monsanto. 16 Q. Who was that that took the notes? 17 A. I think it was Paul Benignus. . 18 Q. Did you ever travel to General Electric 19 facilities with respect to this PCB matter that you were 20 working on? 21 A. Yes. 22 Q. How often did you do that from January 1970 23 through January 1981? 24 A. Just once to each location. 25 Q. When you say "each location," what Gateway Reporting Associates, Inc. WATER PCB-SD0000071161 Gateway Reporting Associates, Inc. 217 1 locations are you referring to? 2 A. Well, I remember Schenectady; Pittsfield, 3 Massachusetts; Rome, Georgia; I think Glens Falls on the 4 Hudson River. That's all that comes to mind. 5 Q. Was the purpose of the meeting at Glens 6 Falls some issues that the State of New York had raised 7 with respect to PCBs? 8 A. That visit predated that. The issue had 9 not been raised by the State when I made the visit. 10 Q. Were there any agendas for these visits or 11 meetings that you just told me about? 1,2 A. I don't recall any agendas being prepared. 13 Q. Who did you meet with in Schenectady? 14 A. I don't remember the people anymore. 15 Q. Did you meet with Dr. Brown? 16 A. I don't remember the name or the face. 17 Q. Do you know who you met with in Pittsfield, 18 Massachusetts? 19 A. I remember Ed Raab, R-A-A-B. There were, 20 of course, others involved, but I don't remember their 21 names. 22 Q. Do you know what the time period of your 23 meeting in Schenectady was and Pittsfield, Mass.? 24 A. I don't remember Schenectady. I think, if 25 my memory serves me right, that the Pittsfield, Mass. Gateway Reporting Associates, Inc. WATER PCB-SD0000071162 Gateway Reporting Associates, Inc. 218 1 visit occurred the summer of 1970. 2 Q. Do you know what the purpose or topic of 3 the meeting was? 4 A. The topic of the meeting was PCBs in the 5 environment. 6 Q. Do you know if there were any minutes or 7 notes kept of that meeting? 8 A. I did not see any. I don't know. 9 Q. Did you keep any? 10 A. No. 11 Q. Did anyone from Monsanto go with you? 12 A. No. ' 13 Q. Did you go to any other meetings during the 14 course of that trip to Pittsfield, Massachusetts? 15 A. I hesitate because I have confusion with 16 other meetings. You mean with General Electric people 17 at that site? 18 Q. Did you make a swing down to Rome, Georgia 19 or a swing over to Schenectady or a swing from 20 Schenectady to Pittsfield or a swing from Pittsfield to 21 Schenectady or a swing from any of those places to Glens 22 Falls? 23 A. During the summer of 1970, I was making a 24 concerted effort to visit customers' plants. I don't 25 recall going to two General Electric locations during Gateway Reporting Associates, Inc. WATER PCB-SD0000071163 Gateway Reporting Associates, Inc. 219 1 one leg of these multiple trips that I took. I also 2 don't recall when I went to Pittsfield which plants 3 other than General Electric I visited in the 4 Massachusetts area, New England area. 5 Q. These would be other plants who might 6 employ PCBs in their processes? 7 A. That was the intent of my trip. 8 Q. Do you recall who you met with in Rome, 9 Georgia? 10 A. NNoo.. I'm having a hard time remembering. I 11 knew the man very personally, because he used to come to 12 Alabama, and I cc an't remember his name. 13 Q. He used to come to Alabama, to Anniston? 14 A. Yes . 15 Q. Was that during the time period that you 16 were general man 17 A. Yes 18 Q. And how often would he come to Anniston? 19 A. Ohh,, there again, I don't know, because I 20 wouldn't see him every time he arrived. 21 Q. How often would you see him in this time 22 period you werree >general manager? 23 A. At least a couple times. 24 Q. Do ;you know whether that was Mr. Moe, 25 M-O-E, at Rome, i Gateway Reporting Associates., Inc. WATER PCB-SD0000071164 Gateway Reporting Associates, Inc. 220 1 A. I don't know. No. I don't recall that 2 name at all 3 Q. . Do you know if it was Mr. Mayes, M-A-Y-E-S? 4 A. No. That doesn't ring any bells. 5 Q. What about R. A. Nelson? 6 A. That's a faint recollection. 7 Q. Do you recall seeing some papers written on 8 PCBs by Mr. Nelson? 9 A. I'm sorry? 10 Q. Do you recall seeing some papers written on 11 PCBs by Mr. Nelson? Call it "PCB, An Industry Problem"? 2,2 A. I don't recall that. 13 Q. What about Mr. Rogers? Would he be the man 14 from Rome, Georgia that you met with while you were at 15 Anniston? 16 A. I just don't remember. 17 Q. Do you recall who you met with at Glens 18 Falls? 19 A. No, I don't. 20 Q. Were they the same people at Glens Falls 21 that you met with at Schenectady? 22 A. Again, I don't remember. 23 Q. Do you recall telling any of these people 24 that heating of Pyranol produced dibenzofurans and 25 dioxins? Gateway Reporting Associates., Inc. WATER PCB-SD0000071165 Gateway Reporting Associates, Inc. 221 1 MR. SABETTA: Objection to form. 2 MR. GRONDAHL: Objection. 3 Q. I'll withdraw it. Do you recall telling 4 any of these GE people that you met with at the time, 5 summer of 1970, that heating of Pyranol resulted in 6 dioxins? 7 MR. SABETTA: Objection to form. 8 MR. GRONDAHL: Objection. 9 A. The word "heating" kind of disturbs me a 10 bit because it's so many ranges of temperature that 11 could be involved. I do recall discussing with the 12 audience assembled the subject of incineration of wa-ste 13 PCBs. I did not at any time refer to material by the 14 name Pyranol. I did say that the temperatures had to be 15 high enough to make certain that no other harmful 16 chemicals are formed, and I used as examples chlorinated 17 furans and chlorinated dioxins. 18 Q. When you refer to the term "waste PCBs," 19 what do you mean? 20 A. These are PCBs that no longer have the I'm 21 going to call it the purity required for the intended 22 application. 23 Q. In what way had the purity changed as you 24 refer to this fluid as waste PCBs? 25 MR. SABETTA: Objection to form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071166 Gateway Reporting Associates, Inc. 222 1 A. Well, I'd have to have the -- Under what 2 conditions? Heat transfer application? Hydraulic? 3 Q. - I'm just using your words, Mr. Papageorge, 4 not mine. 5 A. Yes. 6 Q. You said that youdesignated waste PCBs as 7 some fluid in which the purity had changed; is that 8 correct ? 9 A. Correct. 10 Q. In what way had the puritychanged? 11 MR. SABETTA: Objection to form. 12 MR. GRONDAHL: Objection. ; 13 A. When it contains material that did not 14 exist when the PCB product was introduced into a system 15 or a product. 16 Q. Was one of those materials that did not 17 exist in your opinion dibenzofurans? 18 MR. SABETTA: Objection. 19 MR. GRONDAHL: Objection. 20 A. Never. 21 Q. Did you know that dibenzofurans existed in 22 the product as manufactured by Monsanto during the 23 course of these trips in the summer of 1970? 24 A. No. 25 Q. Did you ever find that out? Gateway Reporting Associates., Inc. WATER PCB-SD0000071167 Gateway Reporting Associates, Inc. 223 1 A. Eventually, yes. 2 Q. What impurities were you referring to that 3 were encompassed in this phrase "waste PCBs"? 4 A. There again, it depends on what this PCB 5 material was exposed to. It could be a presence of 6 metals, chrome, iron, what-have-you. It could be the 7 presence sometimes of just plain water. Water itself is 8 objectionable. It could be the presence of other 9 chemicals that are present in the system in which the 10 PCB material was being used. . 11 Q. Had the scientists and-the world community 1.2 been complaining about water in the PCBs? ; 13 MR. SABETTA: Objection to form. 14 Q. At that time. 15 A. Not specifically water. They would just 16 say it doesn't meet specifications. 17 Q. Had the scientists and the world community 18 been complaining about irons, or metals or other 19 chemicals in the PCBs other than PCBs at that time? 20 MR. SABETTA: Objection to form. 21 A. Sir, scientists don't talk that way. They 22 would not complain in that fashion. 23 Q. Did Professor Jennsen raise any issues in 24 1966 with respect to water or irons or metals or other 25 chemicals -- Gateway Reporting Associates, Inc. WATER PCB-SD0000071168 Gateway Reporting Associates, Inc. 224 1 MR. SABETTA: Objection to form. 2 Q. -- in PCBs? 3 A. I'm confused by your question because 4 Dr. Jennsen reported PCBs as a contaminant in his 5 samples. 6 Q. Did Dr. Jennsen report PCBs in the hair of 7 his newborn child? 8 . A. Yes. 9 Q. Did he theorize that it came from his 10 wife's breast milk? 11 A. I don't remember that theory. 12 Q. Was one of the purposes of this or these 13 trips that you took to Schenectady, Pittsfield, Rome and 14 Glens Falls to discuss disposal of PCBs? 15 A. Yes. 16 Q. Had you done any communication on that 17 topic to these particular facilities of General Electric 18 prior to going to the trip? 19 A. Yes. 20 Q. Was thatcommunication in the form of 21 correspondence or memos, or what form did it take? 22 A. In February of 1970, a group ofGeneral 23 Electric representatives came to Monsanto in St. Louis, 24 and we had a day and a half to two day meeting. At that 25 meeting, we shared with them our thoughts regarding Gateway Reporting Associates, Inc. WATER PCB-SD0000071169 Gateway Reporting Associates, Inc. 225 1 incineration, the progress we had made to that point 2 regarding the design of a proper incinerator, and we 3 informed them that we expected to install that unit 4 later that year, 1970, and that service would be 5 available to our customers. 6 Q. Do you recall who was present at that 7 meeting from General Electric? 8 A. No, sir. 9 Q. Did you tell them that Monsanto had 10 determined that incineration of waste PCBs below 800 11 degrees centigrade could cause dioxins and furans? 12 MR. SABETTA: Objection to form 13 MR. GRONDAHL: Object to form. 14 A. I mentioned that unless the right 15 temperature was achieved you could get unknown 16 chemicals, which could include dioxins or furans. There 17 was no evidence that they would be a contaminant under 18 those conditions, but I used the word "could", only 19 because I preferred erring on the wrong side if it 20 didn't create dioxins. 21 Q. It turned out to be the right side; didn't 22 it? 23 MR. SABETTA: Objection to form. 24 MR. GRONDAHL: Objection. 25 A. The dioxin, sir, had nothing to do with Gateway Reporting Associates, Inc. WATER PCB-SD0000071170 Gateway Reporting Associates, Inc. 226 1 PCBs . 2 Q. What about Pyranol? Did dioxin have 3 something to do with Pyranol? 4 A. That was not Monsanto's product. 5 Q. Did dioxin have something to do with waste 6 PCBs? 7 MR. SABETTA: Objection to form. 8 MR. GRONDAHL: Objection. 9 A. Not as a contaminant in PCBs. 10 Q. Why do you say. Pyranol was not Monsanto's 11 product? . 12 A. Because it was specified and made according 13 to the customer's recipe. 14 Q. Who made it? 15 A. Monsanto. ' 16 MR. SABETTA: Objection to form. 17 A. Monsanto blended theagreement as 18 specified. 19 Q. Where did you get that information with 20 respect to there could be dioxins or dibenzofurans if it 21 wasn't heated to the correct temperature or words to 22 that effect? 23 A. In my own mind,knowingsomething about 24 organic chemicals, oxygen, and chlorine, I came up with 25 I'm going to call it an hypothesis, just a scientific Gateway Reporting Associates, Inc. WATER PCB-SD0000071171 Gateway Reporting Associates, Inc. 227 1 thought, and in order to make sure that the person or 2 company I was talking to would pay particular attention 3 to high temperature incineration instead of sending it 4 to the city incinerator, I chose to mention those 5 chemicals that involved the benzene ring, chlorine and 6 oxygen, as examples of what might be created in an 7 effort to get attention of the right degree. That's 8 where it came from. That's my idea. 9 Q. Did the General Electric people attending 10 the meeting appear stunned with your idea? 11 MR. SABETTA: Objection to form. 12 MR. GRONDAHL: Object. . 13 A. I did not look to see the impression that 14 was made. 15 Q. Did anyone from General Electric take issue 16 with your hypothesis that dioxins and furans could be 17 produced if the waste PCBs were not heated to the proper 18 temperature? 19 A. No. 20 Q. Do you know of any other company in the 21 world that has more Ph.D.'s and scientists than General 22 Electric Company? 23 MR. GRONDAHL: Objection. 24 A. I know nothing about their personnel. I 25 can't answer that. Gateway Reporting Associates, Inc. WATER PCB-SD0000071172 Gateway Reporting Associates, Inc. 228 1 Q. What about companies -- Withdraw it. Did 2 you communicate this information about your hypothesis 3 to General Electric in writing? 4 A. I don't recall any written document to 5 General Electric that covers that. 6 Q. Did you have a practice of communicating 7 such hypothesis to customers of Monsanto? 8 MR. SABETTA: Objection to form. 9 A. I suppose you'd call it a practice. When 10 I'd get an inquiry regarding incineration, I believe in 11 most cases I included that as an example of what might 12 happen under the wrong conditions. . 13 Q. Do you recall communicating to several 14 customers with respect to your hypothesis in the 1970 15 time period? 16 A. Yes. 17 Q. What customers do you recall communicating 18 to? 19 A. I don't remember. 20 MR. MCDONOUGH: Off the record. 21 (Whereupon, there was an off-the-record 22 discussion.) 23 (Reporter marked Plaintiff's Exhibits 400 24 through 405.) 25 Q. Mr. Papageorge, I'm showing you an exhibit Gateway Reporting Associates, Inc. WATER PCB-SD0000071173 Gateway Reporting Associates, Inc. 229 1 marked 400 for identification. It purports to be 2 correspondence over your typed signature dated July 6th, 3 1970 to Mr. Cavenaugh, C-A-V-E-N-A-U-G-H, at Espey 4 Manufacturing Company, Saratoga Springs, New York, and 5 ask you to take a look at it, please. I want to ask you 6 if that's your correspondence. 7 A. It appears to be something that I composed. 8 Q. If you look at the second page, the second 9 paragraph, second sentence of the second paragraph says, 10 "Any incineration below 800.degrees C will result in 11 vaporization, which will contaminate the atmosphere, or 12 impartial oxidation, which may yield materials which are 13 highly toxic." Do you see that? 14 A. I do. 15 Q. This reference to materials that are highly 16 toxic is with reference to that hypothesis you told us 17 about ? 18 MR. SABETTA: Objection to form. 19 Q. Withdrawn. What were you referring to when 20 you said "may yield materials which are highly toxic"? 21 A. No chemical specifically, but anything that 22 could be created with carbon, oxygen and chlorine 23 unknown at that point in time and could be highly toxic. 24 That's true of any incineration. 25 Q. May I have it back, please? Gateway Reporting Associates, Inc. WATER PCB-SD0000071174 Gateway Reporting Associates, Inc. 230 1 A. Yes. 2 Q. I'm showing you 402 for identification. It 3 purports to be correspondence over your signature dated 4 July 6th, 1970 to Mr. Wilburn, W-I-L-B-U-R-N, Manager, 5 Engineering, Westinghouse, and ask if you can look at 6 that for me, please. 7 A. I have read thedocument. 8 Q. Would you look at the second paragraph? It 9 says, "As we discussed previously, total destruction of 10 PCBs can only occur above 800 degrees C. Any 11 temperature below this minimum will result in 12 vaporization with release to the atmosphere or, worse 13 yet, it is possible to partially oxidize PCBs into 14 materials which can be highly toxic (eg., dioxins or 15 furans). Your incineration should be thoroughly 16 reviewed." Is that your correspondence? 17 A. Yes. 18 Q. Is that exhibit, which is 401, as well as 19 Exhibit 400, were they correspondence that you made and 20 kept in the regular course of your business for 21 Monsanto? 22 MR. SABETTA: I don't think you've shown 23 him 401. I don't remember seeing 401. 24 Q. What one do you have in front of you? 25 MR. SABETTA: 402. Gateway Reporting Associates, Inc. WATER PCB-SD0000071175 Gateway Reporting Associates, Inc. 231 1 A. 402. 2 Q. Are the two exhibits, Exhibit 400 and 402, 3 correspondence that you made and kept in the course of 4 your regular business with Monsanto? 5 A. Yes. 6 Q. I'm showing you 403for identification. It 7 purports to be correspondence over your typed signature 8 dated July 7, 1979 to Mr. Gene Lewis with a P. R. 9 Mallory, M-A-L-L-O-R-Y, Company in Waynesboro,' 10 Tennessee, and ask if you prepared and sent that 11 correspondence. . 12 A. I haveprepared thisdocument. 13 Q. And on the second page of that 14 correspondence, in the third paragraph, did you 15 reference, "Incineration below 800 degrees centigrade 16 will result in vaporization which will contaminate the 17 atmosphere or impartial oxidation which may yield 18 materials which are highly toxic"? Did you say that? 19 A. Yes. 20 Q. Was thatcorrespondence that you made and 21 kept in the course of your business and Monsanto's 22 business ? 23 A. Yes. 24 Q. I'm showing you Exhibit 404 for 25 identification. It purports to be a July 8th, 1970 Gateway Reporting Associates, Inc. WATER PCB-SD0000071176 Gateway Reporting Associates, Inc. 232 1 letter over your signature to Mr. F. G. Jenkins, Vice 2 President, Materials, Sprague, S-P-R-A-G-U-E, Electric 3 Company, North Adams, Mass, and ask if you prepared and 4 sent that correspondence. 5 A. It appears to be a copy of correspondence I 6 prepared. 7 Q. Was that correspondence that you made and 8 kept in the course of Monsanto's business? 9 A. Yes. 10 Q. On the second page in the first full 11 paragraph of that page, it refers to incineration and 12 uses the words "furans and dioxins"; does it not? 13 A. Yes, it does. . 14 Q. Was there a particular reason ..that you 15 recall as to why some letters referred to material that 16 was "highly toxic" and other letters referred to "furans 17 and dioxins"? 18 MR. SABETTA: Objection to the form. 19 A. I don't recall any particular reason. I 20 just -- It reflects what I dictated to the secretary on 21 that particular day. 22 Q. I'm showing you Exhibit 405 for 23 identification. It purports to be an August 17th, 1970 24 letter over your typed signature to Mr. J. M. O'Leary, 25 Technical Superintendent, Industrial Chemicals Division, Gateway Reporting Associates, Inc. WATER PCB-SD0000071177 Gateway Reporting Associates, Inc. 233 1 Hooker Chemical Company, Niagara Falls, New York, and 2 ask if you prepared and sent that correspondence. 3 A. This appears to be a copy of a document I 4 prepared at that time. 5 Q. Was that document made and kept in the 6 course of Monsanto's business? 7 A. Yes. 8 Q. In the third, I'm sorry, fourth paragraph, 9 it states, "Disposal of scrap PCB by burning can be 10 achieved if the temperature is maintained above 800 11 degrees C. Attempts to dispose at lower temperatures 12 will result in vaporization or worse if partial 13 oxidation to highly toxic furans or dioxins results." 14 Did you make that statement to Mr. O'Leary? 15 A. Yes . 16 Q. Do you recall doing letters to other 17 customers of Monsanto's on that same topic? 18 A. Yes . 19 Q. Do you recall doing one to General Electric 20 Company? 21 A. No . 22 Q. Is that because you had your meeting with 23 him and told him of your hypothetical? 24 MR. GRONDAHL: Object to the form. 25 A. Many meetings. Gateway Reporting Associates, Inc. WATER PCB-SD0000071178 Gateway Reporting Associates, Inc. 234 1 Q. Well, you mentioned a meeting here in St. 2 Louis in the summer of 1970. 3 MR. SABETTA: I think it was February of 4 1970 I believe was the testimony. 5 Q. In February of 1970 where you told them 6 your hypothesis; is that correct? 7 A. Yes. 8 Q. Was that the reason -- Let me withdraw 9 that. Do you recall whether you did or did not do any 10 correspondence to General Electric on that topic? 11 MR. SABETTA: Objection as asked and 12 answered. You can answer it again. . 13 A. I just don't recall that subject being 14 covered in a mailing. 15 Q. Does that mean that you don't recall one 16 way or the other? 17 A. I don't know how to answer that because I 18 just cannot visualize -- I don't remember, first of all, 19 sending such a document. On the other hand, my dealings 20 with General Electric were such that such a document 21 would be redundant. It would not cover a new subject. 22 So I don't recall or even consider that such a document 23 would have been appropriate. 24 Q. . Well, did you recall before I showed them 25 to you Exhibits 400, 402, 403, 404, 405? Gateway Reporting Associates, Inc. WATER PCB-SD0000071179 Gateway Reporting Associates, Inc. 235 1 MR. SABETTA: Objection to the form. 2 A. If by your question you're saying did I 3 recall the dates of the documents and the addressees as 4 well as the subject matter, I do not recall those dates. 5 I did not recall those details. 6 Q. Did you recall - 1 A. But the -8 Q. Go ahead. 9 A. But the factthat such letters were sent 10 out in response to questions from customers I did 11 recall. 12 Q. Did you discuss your hypothesis with other 13 employees at Monsanto prior to this February 1970 14 meeting with GE? 15 A. Not prior to that meeting, no. 16 Q. Did you discuss it after that meeting? 17 A. Yes. 18 Q. About what time? Let me rephrase it. Did 19 you discuss your hypothesis with employees of Monsanto 20 prior to doing this correspondence that we've marked as 21 Exhibits 400, 402, 403, 404, 405? 22 A. Yes. 23 Q. Do you know about what time you had these 24 discussions about your hypothesis? 25 A. Sometime between February and April of Gateway Reporting Associates, Inc. WATER PCB-SD0000071180 Gateway Reporting Associates, Inc. 236 1 1970 . 2 Q. Do you recall who you discussed the 3 hypothesis with? 4 A. I discussed it with Dr. Richard and 5 Dr. Tucker and Dr. Keller, chemists who were involved in 6 the project. 7 Q. Were Dr. Tucker and Dr. Keller working on 8 the incineration issue for Monsanto at that time? 9 A. They certainly had the assignment, and 10 Dr. Tucker, of course, was personally directly involved, 11 and as best as I recall, he joined me in March of 1970 12 when we visited the John Zinc Company for the 13 incinerator demonstration. 14 Q. What about Dr. Richard? Was he involved in 15 this incineration issue during that time period? 16 A. Only as an advisor in chemical matters. 17 Q. Do you recall if they said anything about 18 your hypothesis in these meetings? 19 A. Of course, I don't recall the exact 20 wording, but the impression I'm left with is that they 21 were supportive. 22 Q. Did they tell you in words or substance 23 that you were a genius to have figured out this 24 hypothesis? 25 MR. SABETTA: Objection to the form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071181 Gateway Reporting Associates, Inc. 237 1 MR. GRONDAHL: Object to the form. 2 A. No, sir. That was not the intent of my 3 inquiry. 4 Q. Did they tell you in substance that, of 5 course, your hypothesis was correct? 6 MR. SABETTA: Objection to form. 7 MR. GRONDAHL: Object to the form. 8 A. I don't recall anybody saying it was 9 correct. They implied that they would support the 10 "could happen" approach. 11 Q. Did they tell you in substance that anyone 12 could look at the molecular structure and decide if you 13 heated it in the presence of oxygen you would have 14 furans and dioxins? 15 MR. SABETTA: Objection to form. 16 MR. GRONDAHL: Object to the form. 17 A. When you said "anyone," I don't know that 18 they covered the full spectrum of... 19 Q. Good point. Did they tell you in substance 20 that any Ph.D. in organic chemistry could look at the 21 molecular structure and tell you that if you heated it 22 in the presence of oxygen the dioxins and dibenzofurans 23 could be a byproduct? 24 MR. SABETTA: Objection to form. 25 MR. GRONDAHL: Object to the form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071182 Gateway Reporting Associates, Inc. 238 1 A. We did not get in that kind of discussion. 2 Q. How are you doing? 3 A. All right. 4 Q. Can I see your book for a moment, please? 5 If you look at Exhibit 394 for me again, and look at the 6 eighth page in in the exhibit, it purports to be 7 correspondence from Elmer P. Wheeler to Howard S. 8 Bergen, which is not a good copy. I'd ask if you take a 9 look at that and tell me whether you ever saw that 10 correspondence before. 11 A. I'm having difficultyreading. 12 Q. I agree. It's not a good copy. I wanted 13 to ask you about page two more than page one, which is a 14 clearer copy. I'd ask if you have seen it before. 15 A. I'm having some difficulty in recalling 16 whether I've seen it before, primarily because I can't 17 read enough of it to help my recollection. I can't even 18 read the date. 19 Q. Okay. If you look at the last sentence on 20 page two, it says, "Where such incidents have occurred, 21 the irritation caused by the vapors from the hot 22 material," somebody appears to have written in something 23 which looks to be "(up to 600 degrees C)" "have limited 24 voluntary exposures such that systemic toxic effects are 25 rare." Do you see that? Gateway Reporting Associates, Inc. WATER PCB-SD0000071183 Gateway Reporting Associates, Inc. 239 1 A . I do. 2 Q. Do you know what systemic toxic effects 3 means as used by Mr. Wheeler in that correspondence? 4 A. I have an understanding I could share with 5 you . 6 Q. I don't think I want your understanding. 7 I'm wondering if you know what Mr. Wheeler meant when he 8 said "systemic toxic effects". 9 A. I can't speak for Mr. Wheeler, sir . 10 Q. If you turn to tab 18 for me, please, 11 marked this document Exhibit 396. It purports to be 12 Minutes of Meeting of Corporate Development Committee, 13 dated April 28, 1969, with a list of attendees. I'd ask 14 if you've ever seen that document before. 15 A. I have never seen this document. 16 Q. I note that you looked at the last page of 17 that exhibit, which is marked 292 in terms of the page 18 number. It has a heading called "Appropriation 19 Request," which includes a recommendation, "Organic 20 Division Appropriation Request No. CEA-2080 for 21 1,100,000 for solid Aroclor expansion -- Anniston." Do 22 you see that? 23 A. I do. 24 Q. Do you know what that refers to? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071184 Gateway Reporting Associates, Inc. 240 1 Q. What? 2 A. This means that thatparticular part of 3 Monsanto referred to as Organic Division, following 4 Monsanto's procedures for requesting funding, has asked 5 for 1,100,000 for the expansion of chlorinated 6 terphenyls. 7 Q. Is thatreferred to as solidAroclor? 8 A. Yes. 9 Q, Do you know whether that expansion was ever 10 undertaken? .. 11 A. Yes, it was. . 12 Q. Do you know whether this chemical was ever 13 produced pursuant to this resolution? 14 MR. SABETTA: Objection to form. 15 A. What was the word before "resolution"? 16 Q. Do you know whether that expansion ever 17 resulted in Aroclor being produced? 18 MR. SABETTA: Objection to form. 19 MR. GRONDAHL: Objection to form 20 A. Aroclors were being produced. All that 21 this' does is expand the process in terms of equipment to 22 make more, and it doesn't refer to PCBs. 23 Q. Was the equipment expanded? 24 A. Yes. 25 Q. And was that equipment -- Did it become Gateway Reporting Associates, Inc. WATER PCB-SD0000071185 Gateway Reporting Associates, Inc. 241 1 operational to make Aroclor as referred to here? 2 A. To make that type of Aroclor, yes. 3 Q. I'm showing you the next exhibit, which is 4 marked 397 for identification. It purports to be 5 minutes of the meeting of the Board of Directors, May 6 22nd, 1969. Have you ever seen that before? 7 A. I have not. 8 Q. Does that approve that expansion that was 9 referred to in the last document? 10 A. That's what I read, sir, yes. 11 Q. Did you ever make any presentations to the 12 Monsanto board with respect to PCBs? . 13 A. No. 14 Q. Did you ever make any presentations to the 15 Corporate Development Committee with respect to PCBs? 16 A. I made a presentation to a committee. I at 17 this point in time don't remember if it was referred to 18 as the Corporate Development Committee or the Corporate 19 Management Committee or the Corporate Administrative 20 Committee. The committee had name changes through the 21 period of time. 22 Q. Aside from the name changes, did you 23 understand the committee substantially did the same 24 thing? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071186 Gateway Reporting Associates, Inc. 242 1 Q. Do you know about when it was that you made 2 that presentation? 3 A. Yes. April. Early April of 1970. 4 Q. Do you know what the topic of your 5 presentation was? 6 A. PCBs in the environment. 7 Q. Did you prepare material withrespect to 8 that presentation? 9 A. Yes . ' 10 Q. Did it have a title, the material that you 11 prepared? 12 A. It had a title, but I don't remember the 13 exact wording. 14 Q. Do you know how long it was, about how many 15 pages ? 16 A. About four. 17 Q. Were minutes kept of thatmeeting? 18 A. Yes. 19 Q. Do you know who kept the meeting minutes? 20 A. I believe it was Mr. Ehlers, E-H-L-E-R-S. 21 - Q. Do you recall his first name? 22 A. I think it's James, but I'm not certain. 23 Q. If you turn to tab 20 for me, has that got 24 an exhibit number on that? Could you tell me what the 25 exhibit number is? Gateway Reporting Associates, Inc. WATER PCB-SD0000071187 Gateway Reporting Associates, Inc. 243 1 A. 398. 2 Q. Exhibit 398 purports to be minutes of 3 Aroclor "Ad Hoc" Committee, first meeting date September 4 5, 1969. Have you ever seen that document? 5 A. Yes, I have. 6 Q. When did you first see it? 7 A. Sometime in 1970. I don't recall the 8 timing any closer than that. 9 Q. Do you recall whether you were given that 10 document by Mr. Wheeler or anyone else in the course of 11 your tutorial in that 90-day period? 12 A. I don't recall that. 13 Q. Do you recall whether you have been asked 14 about this document in the course of depositions and 15 testimony you've given on the subject of PCBs? 16 A. Yes. 17 Q. How many times? 18 A. I don't remember. Several. 19 Q. If you look at page two of Exhibit 398, it 20 has a heading 5, "Toxicity Levels". It says, "Aroclors 21 have been shown to be safe for man in reasonable 22 exposure concentrations. We are testing 100 ppm in diet 23 of rats and dogs on a rule-of-thumb basis that 1/100 of 24 toxicity level is safe and one ppm is probably the upper 25 limit in total diet." Do you see that? Gateway Reporting Associates, Inc. WATER PCB-SD0000071188 Gateway Reporting Associates, Inc. 244 1 A . I do. 2 Q. Did you ever have any discussions about a 3 rule of thumb? 4 MR. SABETTA: Objection to form. 5 Q. Did you ever have any discussions with 6 anyone on rule of thumb for reasonable exposure 7 concentrations of Aroclors? 8 MR. SABETTA: Same objection. 9 A. I don't recall the wording you used, but 10 there were discussions with Dr. Kelly and with 11 Mr. Wheeler regarding how exposure limits are set and 12 what they're based on. We did get into this upper limit 13 in diet in test animals and how that translates to the 14 workplace and so on. 15 Q. Did Mr. Wheeler or Dr. Kelly use the phrase 16 "rule of thumb" as this document does? 17 A. I don't remember that. 18 Q. If you look in the third paragraph under 19 "Toxicity Levels," it says, "One problem we are facing 20 is to keep the 'safe level'(?) for shrimp from being 21 applied to, eg. Lake Michigan, where more tolerant fish 22 species probably exist. We need to show the safe level 23 in shrimp, clams, oysters, and several species of fish." 24 Do you see that? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071189 Gateway Reporting Associates, Inc. 245 1 Q. Do you know what the toxicity level for the 2 shrimp had been shown to be? 3 A. I don't recall the exact number, but there 4 was a study that indicated that juvenile shrimp were 5 very sensitive to PCBs. 6 Q. Where was that study performed? 7 A. The Commercial Fisheries Laboratory in Gulf 8 Shores, Florida. 9 Q. Was that area in the general vicinity of 10 any rivers? 11 A. When you say "general vicinity," I don't 12 know how to interpret that. 13 Q. Does the Coosa River flow inthere? 14 A. I don't know my geography that well. I 15 don't remember. 16 Q. Was the Anniston plant in the general 17 vicinity of the Coosa River? 18 A. You could see a river, yes. 19 Q. Do you know whether any chronic studies had 20 been completed with respect to PCBs up through this 21 September 5th, 1969 time period? 22 A. Chronic studies with any species, all 23 species? 24 Q. Yes. 25 A. No, there weren't any. Gateway Reporting Associates, Inc. WATER PCB-SD0000071190 Gateway Reporting Associates, Inc. 246 1 Q. If you look at the next entry under six, it 2 says "Escambia," E-S-C-A-M-B-I-A, "River Problem". Do 3 you see that? 4 A. Yes. 5 Q. There's a discussion of, "For a clearer 6 understanding of the general problem, the situation at 7 Pensacola was reviewed." Then there's a discussion of 8 quantities of chemical measured in various areas 9 downstream and in the mud; is that correct? 10 A. Are you paraphrasing the wording here, sir? 11 Q. I was paraphrasing, yes. 12 A. Well, the wording does indicate that there 13 were levels of PCBs found in water and higher level in 14 mud. 15 Q. Did you find that out in the course of your 16 tutorials with respec t to this Esc ambia River? 17 A. Yes . 18 Q. Were the re plants or customers of Monsanto 19 used PCBs in the area of the Escambia River? 20 A. Yes . 21 Q. What cus tomers would that be? 22 A. That was Monsanto its elf . 23 Q. And what plant would that be? 24 A. Pennsaco la Florida pi ant . 25 Q. Did that plant manufa cture PCBs? Gateway Reporting Associates, Inc. WATER PCB-SD0000071191 Gateway Reporting Associates, Inc. 247 1 A. No . 2 Q. How did it come about that it used PCBs? 3 Do you know? 4 A. PCBs were present in a fluid used in an air 5 compressor. 6 Q. Was that plant associated with testing of 7 wood posts that you testified to yesterday? 8 A. No. 9 Q. What plant was associated with the testing 10 of the wood posts by burying them in the ground? 11 MR. SABETTA: Objection to form. 12 A. There was no plant associated with it, with 13 that study. 14 Q. Where were the wood posts buried? 15 A. They were over in Florida associated with 16 the University of Florida as part of a scientific study 17 Q. That was a scientific study done by the 18 University of Florida? 19 A. Yes . 20 Q. Do you know whether the study was supported 21 by Monsanto? 22 MR. SABETTA: Objection to form 23 A. I do not. 24 Q. Was that on the west coast or the east 25 coast of Florida? Do you know? Gateway Reporting Associates, Inc WATER PCB-SD0000071192 Gateway Reporting Associates, Inc. 248 1 A. Gainsville. I don't know. I think it's 2 more to the east. 3 Q. If you look at page three under eight, it 4 says "Environmental Contamination By Customers". It 5 says, "Our in-plant problems are very small versus 6 problems of dealing with environmental contamination by 7 customers." Was that information brought to your 8 attention in your tutorial? 9 A. Yes. 10 Q. Was that part of your general duties to 11 travel around to Monsanto customers.to try to eliminate 12 disposal of the PCBs into the environment? . 13 MR. SABETTA: Objection to the form. 14 A. When you use the expression "travel 15 around," I'm confused in terms of -- I perceive that as 16 indicating that the only time I was involved with 17 customers was when I traveled. That was just one way to 18 do it . 19 Q. Would you turn to tab 21, please? What 20 exhibit tag is on that? 21 A. 399. 22 Q. I'm showing you Exhibit 399 for 23 identification. It's entitled "PCB Environmental 24 Pollution Abatement Plan". On the first page, it says 25 "Introduction". It appears to be a multi-page document. Gateway Reporting Associates, Inc. WATER PCB-SD0000071193 Gateway Reporting Associates, Inc. 249 1 And I'd ask if you've ever seen that document before. 2 A. I believe I have. It looks familiar. 3 Q. . Did you prepare it? 4 A. No . 5 Q. Do you know who prepared it? 6 A. I do not. 7 Q. Do you know where any of the information 8 came from that's set forth on the document? 9 MR. SABETTA: Well, it's a multi-page 10 document. He hasn't read it line by line, so I don't 11 know how he could answer that question. If you want him 12 to do that and then respond to your question, we can. 13 certainly do that. 14 Q. You can't answer that question, 15 Mr. Papageorge, without reading the document line by 16 line? Is that correct? 17 A. As I remember your question, it asked me 18 who prepared this document. 19 Q. I asked you that, and you didn't know, and 20 then I asked you if you knew where the information came 21 from within the document, and your counsel objected and 22 said that unless I had you read line by line you 23 couldn't answer it, and I'm asking you if that's true, 24 that you can't answer that without reading that line by 25 line . Gateway Reporting Associates, Inc. WATER PCB-SD0000071194 Gateway Reporting Associates, Inc. 250 1 A. I can answer that the first page refers to 2 an ad hoc committee of several individuals- They were 3 the individuals that with their understanding and 4 knowledge of the PCB issue at the time put this data 5 together. 6 Q. Have you been asked about this document by 7 other lawyers in depositions and trial? 8 A. Yes. 9 Q. If you look at the last page of the 10 document, it appears to be handwritten and has a title 11 "Profit and Liability Versus Time". Have you seen that 12 document before? 13 A. Yes, I have. 14 Q. Did you see thatduring thecourse of your 15 tutorial? 16 A. No. This came later. 17 Q. Do you know who prepared it? 18 A. Prepared this whole document again? 19 Q. Prepared this one page we're looking at, 20 the last page of the exhibit. 21 ' A. No, I don't. 22 Q. Now, to the left it says "Action," and 23 underneath it it says a heading "do nothing". Then 24 there purports to be a graph on profits against 25 liability; is that correct? Gateway Reporting Associates, Inc. WATER PCB-SD0000071195 Gateway Reporting Associates, Inc. 251 1 A. Yes. 2 Q. Does that refer to PCBs? 3 A. Yes. 4 Q. And the liability line interrupts the 5 profit line on the "do nothing" graph at a little bit 6 past mid 1971; is that correct? 7 A. Yes. 8 Q. Under the next heading, it says 9 "Discontinue Manufacture of PCB," and it has a graph 10 with profits showing a drop.to zero, again a little bit 11 past 1971. . 12 A. Yes. . 13 Q. Sometime in the 1971 time period? 14 A. Yes. 15 Q. And the last graph says "responsible 16 approach," and it graphs profits against liability; is 17 that correct? 18 A. Yes. 19 Q. And theclosest liability and profits lines 20 come appears to be in 1972? 21 A. Yes. 22 Q. Did you ever discuss these graphs with 23 anyone at Monsanto? 24 A. Yes. 25 Q. Who did you discuss them with? Gateway Reporting Associates, Inc. WATER PCB-SD0000071196 Gateway Reporting Associates, Inc. 252 1 A. Elmer Wheeler and Bill Richard. 2 Q. Did you discuss them during the time of 3 your tutorial? 4 A. No. I was not aware of this document until 5 mid 1970. ' 6 Q. How did it come about that you discussed 7 this graph with Mr. Wheeler and Mr. Richard? 8 A. I don't remember that. 9 Q. Is this one of these pieces of paper that 10 was handed over to you at the beginning of some 11 discussion? . 12 A. Yes . 13 Q. Who initiated the discussion? 14 A. I don't even know what the discussion 15 started out with. 16 Q. For example, do you recall saying to 17 Mr. Wheeler or Mr. Richard, "We ought to dump this stuff 18 and get out of the business" and they handed you this 19 piece of pap er? 20 MR. SABETTA:' Objection to form. 21 MR. GRONDAHL: Objection. 22 Q. When I said "dump this stuff," I was 23 referring to discontinuing manufacturing. 24 A. I understand. 25 MR. SABETTA: Objection to form. Do you Gateway Reporting Associates, Inc. WATER PCB-SD0000071197 Gateway Reporting Associates, Inc. 253 1 understand the question? You want her to read it back 2 perhaps as amended by Mr. McDonough? 3 MR. McDONOUGH: The witness doesn't seem to 4 be having any trouble, Mr. Sabetta. 5 MR. SABETTA: Object to the question as 6 argumentative, vague. 7 A. As I remember the question now, I've gotten 8 confused with the conversation here, but -- 9 Q. I'm just trying to find out what caused 10 this conversation that you had over this particular 11 graph. . 12 MR. SABETTA: Objection to form. . 13 Q. Do you recall what initiated the 14 discussion? 15 A. You're just concentrating on the graph? 16 Q. I'm concentrating on the graph. 17 A. Just the graph itself. 18 Q. Now, I'm going to ask you a new question. 19 Do you recall prior to receiving this graph how it was 20 that the conversation was initiated? 21 MR. SABETTA: Objection to form. 22 A. As best I recall, it came up when we were 23 as a group discussing the withdrawal of the sale of PCBs 24 to certain uses, and someone in the group, and I don't 25 recall who, brought up this graph as an example of how Gateway Reporting Associates, Inc. WATER PCB-SD0000071198 Gateway Reporting Associates, Inc. 254 1 this individual visualized the results would develop. 2 Q. The results would develop by doing what? 3 Discontinuing certain lines? 4 A. If you discontinued, you'd get this middle 5 chart. If you took what this person called the 6 responsible approach, you could end up with the bottom 7 chart. 8 Q. Do you know who this individual was? 9 A. I don't remember at the moment, no. 10 Q. Do you recall whether he was a chemist or a 11 doctor or a lawyer or an accountant? 12 A. No, I don't. v 13 Q. You mentioned discussion in a group. Was 14 there an agenda for this particular discussion? 15 A. No. 16 Q. Were minutes kept? 17 A. No . 18 Q. About how many people were there? 19 A. Oh, half a dozen or so. 20 Q. Was this the ad hoc committee on PCBs? 21 A. They were there, plus others that joined 22 us . 23 Q. And do you know about when that meeting 24 was ? 25 A. About April 1970. Gateway Reporting Associates, Inc. WATER PCB-SD0000071199 Gateway Reporting Associates, Inc. 255 1 Q. Was anyone from GE there? 2 A. No. 3 Q. Anyone from your customers there? 4 A. No. 5 Q. Was there a determination made at the end 6 of the meeting? 7 MR. SABETTA: Objection to form. 8 . A. Yes, there was. . 9 Q. What was the determination? 10 A. To recommend to higher management the 11 discontinuance of sales to what Monsanto understood to 12 be open systems and to continue the sale into systems 13 that were perceived to be closed and where the ' 14 properties of PCBs were critical. 15 Q. Were hydraulic usages of PCBs considered to 16 be open or closed systems at this meeting? 17 A. At this meeting, they were considered to be 18 closed systems. 19 Q. Do you recall whether there was a 20 discussion as to the amount of PCBs or the percentage of 21 sales that was devoted to open systems? 22 MR. SABETTA: Objection to form. 23 A. I don't remember that specific being 24 brought up at this meeting. 25 Q. Well, did anybody say, for example, "If we Gateway Reporting Associates, Inc. WATER PCB-SD0000071200 Gateway Reporting Associates, Inc. 256 1 discontinue the following open sales, we will lose X 2 percentage of business" or words to that effect? 3 MR. SABETTA: Objection to form. 4 A. No. There was -- That didn't come up. . 5 Q. Did anyone say, "If we discontinue a sale 6 on hydraulics, we'll lose X percentage of business"? 7 MR. SABETTA: Objection to form. 8 A. No. 9 Q. Do you recall whether Monsanto discontinued 10 sales of PCBs for use in hydraulics after this meeting? 11 A. At any time? 12 MR. SABETTA: Objection to form. ' 13 Q. Yes. 14 A. At any time? 15 Q. Yes. 16 A. Later, yes. 17 Q. When? 18 A. About 1971 or 12. 19 Q. Had Monsantodiscontinued sales in open 20 systems other than hydraulics prior to the 21 discontinuance of sales in hydraulics? 22 MR. SABETTA: Objection to form. 23 A. ' I think I heard you say discontinue sales 24 to open systems. 25 MR. McDONOUGH: Please read the question Gateway Reporting Associates, Inc. WATER PCB-SD0000071201 Gateway Reporting Associates, Inc. 257 1 back. 2 (Whereupon, the reporter read back the last 3 question.) 4 A. The sales to open systems were terminated 5 on August 30, 1970. 6 Q. Can you answer my question, Mr. Papageorge? 7 MR. SABETTA: Objection to the form of that 8 question. Misstates the witness's earlier testimony. 9 MR. MCDONOUGH: I'll withdraw if, my 10 comment. 11 MR. SABETTA: You mischaracterized what he 12 testified to earlier. 13 MR. McDONOUGH: That's what you say, 14 counsel. I don't agree with you obviously. Let me ask 15 another question so we don't waste time. 16 MR. SABETTA: All right. 17 Q. On August 30th, 1970, did Monsanto 18 discontinue sales of PCBs for use in hydraulic.systems? 19 A. No. 20 Q. Can you fix any better date than 1971 or 21 1972. for Monsanto's discontinuance of sales of PCBs in 22 hydraulic systems? 23 A. I cannot come up with a specific date 24 because this process was evolutionary. Different fluids 25 were replaced over a period of time. But I am certain Gateway Reporting Associates, Inc. WATER PCB-SD0000071202 Gateway Reporting Associates, Inc. 258 1 that by the end of -- let me think -- 1971 -- No. The 2 end of '72 we were out of the business. 3 Q. You were out of the business of sale of 4 hydraulic fluids? 5 A. Correct. 6 Q. What, if anything -- Withdraw that. Did 7 Monsanto continue to use the equipment that it had to 8 produce PCBs that were used in these open systems? 9 MR. SABETTA: Objection to form: As of 10 what date? As of what time? I don't think the question 11 is being answered the way it's proposed. I object to 12 the form. . 13 A. Well, when the sales to open uses were : 14 terminated, the producing units were still kept active 15 at a lower rate of production. Eventually, and I'm 16 trying to recall the date, the unit at Anniston, Alabama 17 was shut down. 18 Q. After the discontinuance of sales for open 19 units, I understood you to say that the equipment was 20 used at a lesser rate; is that correct? 21 . A. Yes. 22 Q. What was it used to make at a lesser rate? 23 A. PCBs for the continuing sales. 24 Q. Do you know about when Anniston was shut 25 down? Gateway Reporting Associates, Inc. WATER PCB-SD0000071203 Gateway Reporting Associates, Inc. 259 1 A. ' 72 , ' 73 . 2 Q. When you say Anniston was shut down, do you 3 mean the entire plant? 4 A. No . 5 Q. What do you mean? 6 A. I'm referring to the unit that produced 7 PCBs . 8 Q. What happened to the equipment in that 9 unit? Do you know? ' 10 A. It was dismantled and buried. 11 Q. What about the particular area of the plant 12 that was used to make PCBs? Do you know what happened 13 to that area of the plant? 14 A. They cleaned up the contaminated soil and 15 backfilled it, and it's now just a gravel surface. 16 Q. Did they dismantle that area of the plant? 17 MR. SABETTA: Object to the form. 18 Q. Let me withdraw it. Was that area of the 19 plant that contained the units that manufactured PCBs 20 contained in masonry or some form of walls? 21 . A. No. These are open structures. 22 Q. Who did the cleanup at the site there in 23 Anniston after the discontinuance of operation of the 24 PCBs? 25 A. I don't know. Gateway Reporting Associates, Inc. WATER PCB-SD0000071204 Gateway Reporting Associates, Inc. 260 1 Q. Do you know if it was done in-house by 2 Monsanto, or did they retain an outside contractor? 3 A. Both. 4 Q. Did the Anniston plant become unionized at 5 some time? 6 A. Yes. 7 Q. Do you know what the union was? 8 - A. Independent Chemical Workers Union, ICWU, 9 Local 16 . ' 10 Q. Do you know if that Local 16 had its own 11 office in the Anniston area? 12 A. I don't remember a physical location. 13 Q. Do you know if the parent union had an 14 office that you were familiar with? 15 A. Theycertainly do, but I've forgotten where 16 it's located. 17 Q. Have they got one here in St. Louis? 18 A. I don't think so. 19 Q. Is that the same union that represented the 20 workers at the Krummrich plant? 21 , A. Yes. A different local. 22 Q. Thank you. You wouldn't happen to know the 23 name of that local; would you? 24 A. 12. Can we take a brief break? 25 MR. McDONOUGH: Oh, sure. I'm sorry. Gateway Reporting Associates, Inc. WATER PCB-SD0000071205 Gateway Reporting Associates, Inc. 261 1 (Whereupon, there was a brief recess.) 2 Q. Mr. Papageorge, those shrimp studies that 3 we earlier briefly discussed, do you know whether they 4 were performed with heated or vaporized PCBs? 5 A. No. PCBs were just added to the water. 6 (Reporter marked Plaintiff's Exhibits 406 7 through 415.) 8 Q. . Okay. If you look at 406 for 9 identification for me, it purports to be an October 8th, 10 1969 memo from E. V. John, Public Relations Manager, 11 Organic Chemicals Division, and Paul B. Hodges, Manager 12 of Environmental Engineering, Organic Chemicals t 13 Division, to Field Sales Offices, Plant Communicators, 14 Pollution Control Engineers and Plant Managers. Have 15 you got that in front of you? 16 A. Yes . 17 Q. Have you seen that document before? 18 A. Yes . 19 Q. Now, that document is copied to Mr. J. J. 20 Spano, S- P-A-N-O, Mr. R. W. Richard, Mr. E. P. Wheeler, 21 Mr. M. W. Ferrar, F-E- R-R-A-R, and Mr. D. B. Hosmer, 22 H-O-S-M-E-R; is that correct? 23 A. Correct. 24 Q. Mr. Spano appears to be in Japan? Is that 25 how I make out those initials after his name? Gateway Reporting Associates, Inc. WATER PCB-SD0000071206 Gateway Reporting Associates, Inc. 262 1 A. No. Those are parts of his name. The J 2 and S-P-A-N. Monsanto used that as a mail code. 3 Q. Do you know whether they were on some kind 4 of computer at that point that permitted e-mail or 5 something of that sort? 6 A. No. There were no programs like that. 7 Q. All right. Do you recall whether you saw 8 this as part of your tutorial in January of 1970? 9 A. It was part of that learning period early 10 on. It may not have occurred in the first three months, 11 but sometime in at least the first part of 1970. 12 Q. Now, this last paragraph on the first page 13 of 406 says, "This memo is to alert you to the procedure 14 for handling inquiries should you receive a request for 15 information concerning PCBs from any source (press, 16 government, university, or private citizens). Please 17 direct the inquiry to St. Louis. If the request comes 18 by telephone, take the name, address, return phone 19 number and the nature of the inquiry. By providing 20 information from one central source, we can project our 21 corporate position of cooperation and emphasize our 22 efforts in research and study being directed to 23 eliminating any possible contamination sources." Do you 24 see that? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071207 Gateway Reporting Associates, Inc. 263 1 Q. Did Monsanto employ a practice starting in 2 1969 as to having all inquiries answered by personnel in 3 St. Louis? 4 A. Initially it took that form as it related 5 to PCBs. 6 Q. Okay. Page two indicates Mr.. Elmer Wheeler 7 and Mr. Ed John were the individuals to whom inquiries 8 were to be directed; is that correct? 9 A. That is correct. 10 Q- At some point did you become the individual 11 to which inquiries were directed or were to be directed? 12 A. Well, I'm certainly one of the individuals. 13 Mr. Wheeler continued to be a contact person, and that's 14 about the way it went for a while. 15 Q. Do you know if there was any additional 16 documentation directing inquiries to be made to you 17 beyond this Exhibit 406? 18 A. Not a document, no. 19 Q. Did you handle inquiries from Monsanto 20 sales people, Monsanto plant communicators, pollution 21 control engineers and plant managers? 22 A. Certainly. 23 Q. How did they know to communicate with you? 24 MR. SABETTA: Objection to form. 25 Q. Do you know? Gateway Reporting Associates, Inc. WATER PCB-SD0000071208 Gateway Reporting Associates, Inc. 264 1 A. I don 1t know. 2 Q. If you turn to tab 25, it should be marked 3 Exhibit 407. 4 MR. SABETTA: It seems to be marked 408. 5 Q. Okay. I'm going to ask you to turn to tab 6 24. Did I give you - 7 MR. SABETTA: You said 25. 8 Q. Okay. 9 A. 408? - 10 Q. Have you turned to tab 25 -- or 24? What's 11 the exhibit number on that? 12 MR. SABETTA: 407. ' 13 Q. I'm showing you Exhibit 407 for 14 identification. It purports to be a document with Elmer 15 P. Wheeler's name at the bottom and D. S. Cameron, 16 Brussels, towards the top, January 29th, 1970 date. 17 Have you ever seen that document before? 18 A. Yes. I'm listed asa recipient. 19 Q. And along with you, Mr. Barrett or 20 Dr. Barrett in London is listed, and Mr. Bergen is 21 listed? 22 A. Yes. 23 Q. ' And the topic is "Status of Aroclor 24 Toxicological Studies"; is that right? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071209 Gateway Reporting Associates, Inc. 265 1 Q. Did you receive that document? 2 A. Yes. 3 Q. That refers to "enclosing a copy of the 4 reports from our consulting laboratory indicating the 5 status of the animal toxicity studies." Do you see 6 that ? 7 A. Yes. 8 Q. Do you know what consulting laboratory that 9 was ? ' 10 A. Industrial Bio-TestLaboratories. 11 Q. And do you know what studies that is 12 referring to as to whether they are acute studies or 13 chronic studies? ' 14 A. The attached report describes the studies 15 that were underway at the time. 16 Q. Attached to Exhibit 407 as part of it is a 17 document entitled "Status of Aroclor Studies at 18 Industrial Bio-Test"; is that correct? 19 A. Yes. 20 Q. Now, in thesecond paragraph, the first 21 page- of 407, at the end it says, "I don't see why this 22 information cannot be released with discretion in 23 Britain or Europe." Do you see that? 24 A. Yes. 25 Q. Do you know if the information was released Gateway Reporting Associates, Inc. WATER PCB-SD0000071210 Gateway Reporting Associates, Inc. 266 1 in Britain o 1 Europe? 2 A. It was. 3 Q. The next says , "Our interpretation is that 4 the PCBs are exhibiting a greater degree of toxicity in 5 this chronic study than we had anticipated." Do you see 6 that? 7 A. Yes. ' 8 Q. Did you discuss that with Mr. Wheeler? 9 A. Yes. ' 10 Q. Do you know what he was referring to? 11 A. Yes. The kinds of things that are listed 12 in the attachment, liver enlargement and so on. 13 Q. The last paragraph says, "We have 14 additional interim data which will perhaps be more 15 discouraging. We are repeating some of the experiments 16 to confirm or deny the earlier findings and are not 17 distributing the early results at this time." Do you 18 see that? 19 A. Yes. 20 Q. Did you ever see this interim data that 21 that's referring to? 22 A. I did at the time, yes. 23 Q. Were they more discouraging? 24 MR. SABETTA: Objection to form. 25 Q. Withdrawn. Did you consider the interim Gateway Reporting Associates, Inc. WATER PCB-SD0000071211 Gateway Reporting Associates, Inc. 267 1 data more discouraging than the other reports from the 2 consulting laboratory? 3 MR. SABETTA: Objection to form. 4 A. I didn't, no. 5 Q. You're not a physician; is that correct? 6 A. That's correct. 7 Q. You're not a toxicologist? 8 A. That's correct. 9 Q. Do you know if some of the experiments were 10 repeated? 11 A. Yes, they were. 12 Q. Do you know whether the results of the ' 13 repetition of the experiments were more favorable than 14 the interim data? 15 MR. SABETTA: Objection to the form. 16 Q. Withdrawn. Do you knowwhether the 17 experimental results of the repetition showed less 18 biological activity of PCBs that the interim data did? 19 MR. SABETTA: Objection to the form. 20 A. As I remember, there was no significant 21 difference. 22 Q. If you turn to tab 25, please, I believe 23 we've marked it 408; is that correct? 24 A. Yes. 25 Q. 408 purports to be correspondence on Gateway Reporting Associates, Inc. WATER PCB-SD0000071212 Gateway Reporting Associates, Inc. 268 1 Monsanto's letterhead over the signature of Donald A. 2 Olson, Director of Sales, Functional Fluids Group, with 3 the addressee blank; is that correct? 4 A. That is correct. . 5 Q. Have you seen that document before? 6 A. Yes. 7 Q. It also includes an enclosure in that 8 exhibit; isn't that correct? 9 A. Yes. - 10 Q. Did you participate in the preparation of 11 that document? 12 A. Yes. ' 13 Q. In what way? 14 A. I served as chairman of a group of Monsanto 15 individuals that were involved with the PCB 16 environmental issue, and one of the first tasks of our 17 group was to develop something to communicate to the 18 customers, and I acted as sort of a -- I'm looking for a 19 word. I pushed for this. I encouraged the development 20 of such a document. 21 . Q. Did you write this exhibit or earlier 22 drafts of this exhibit, referring to Mr. Olson's letter 23 dated February 9th, 1970? 24 A. I personally didn't write it, no. There 25 were drafts available when I joined the group, and we Gateway Reporting Associates, Inc. WATER PCB-SD0000071213 Gateway Reporting Associates, Inc. 269 1 took those pencil drafts and made a composite, and this 2 is the final result of all of that effort. 3 Q. Do you know how long this process of 4 preparing drafts took place? 5 A. Several months, but I don't know exactly 6 how many. 7 Q. You mentioned that you were chairman of 8 this group. Did it have a particular name or 9 designation in Monsanto? ' 10 A. I don't know that it ever had a name. It 11 was just a PCB environmental issue group, and anybody 12 involved with PCBs could join it. 13 Q. Was this substantially the same group ' 14 called the Ad Hoc Committee? 15 A. Some of the members of the Ad Hoc Committee 16 were members of this larger group. 17 Q. The larger group was the group that you 18 were chairman of? 19 A. Correct. 20 Q. Was Dr. Keller a member of the larger 21 group? Let me withdraw that. Do you recall the names 22 of any Monsanto employees that were members of the 23 larger group that weren't employees of the ad hoc group? 24 A. Yes. I can recall a few of them. 25 Q. Would you tell me? Gateway Reporting Associates, Inc. WATER PCB-SD0000071214 Gateway Reporting Associates, Inc. 270 1 A. Dr. Richard and Dr. Ferrar. I just can't 2 recall the individual from the Corporate Engineering 3 Department that was involved with the incinerator 4 project. He was a member of this group. Even the 5 business directors, Mr. Bergen and Mr. Springgate, were 6 members of this group, and they would drop in when they 7 could. 8 ' Q. Were there any additional names? 9 A. Yes. There was a roomful of people. I'm 10 trying to recall. Mr. Kuhn, K-U-H-N, was a member. I 11 just can't recall any more. 12 Q. How was it determined who would be a member 13 of this group? Do you know? 14 A. Anyone involved as part of his official 15 assignment with the PCBs automatically was eligible to 16 join the group. 17 Q. How was it determined that they join? Did 18 they make the determination or - - 19 A. Yeah. 20 Q. Or were they directed to? 21 A. It was an open invitation, nothing down in 22 writing anywhere, but at their group meetings they would 23 bring out the fact that this group did meet and discuss 24 PCBs in the environment, and anybody that's interested 25 can meet with them, and the next meeting is, say, next Gateway Reporting Associates, Inc. WATER PCB-SD0000071215 Gateway Reporting Associates, Inc. 271 1 week and so on. 2 Q. Were there any documents outlining the 3 duties or responsibilities or the scope of what it was 4 that this group was to do? 5 A. No. 6 Q. Were you familiar with a group at General 7 Electric called RECO? R-E-C-0? 8 A. RDCO? 9 Q. RECO. 10 A. No. - 11 Q. Were you familiar with a group at General 12 Electric known as CEIP? Although there's been some 13 disagreement on the spelling, it appears to be C-E-I-P. 14 A. I am not familiar with those groups. 15 Q. Now, as part of Exhibit 408, there's 16 another correspondence from Mr. Olson, unknown 17 addressees, dated February 18th, 1970, which appears to 18 be substantially the same as the first page, the 19 February 9th, 1970 letter; is that correct? 20 A. That is correct. 21 . Q. Did Monsanto maintain a list of the 22 customers to whom it sent these two letters and 23 enclosures? , 24 A. Yes. 25 Q. Do you know whether GE received a copy of Gateway Reporting Associates, Inc. WATER PCB-SD0000071216 Gateway Reporting Associates, Inc. 272 1 the February 9th, 1970 or the February 18th, 1970 2 letters? 3 MR. GRONDAHL: Object to the form. 4 A. They received one of them, yes. 5 ,Q. At page two of the first letter, the 6 February 9th, 1970 letter of Exhibit 408, at the top it 7 says, "We have developed and are now testing new 8 formulations to replace the Aroclor 1254 and 1260 9 components in our Pydraul products. The new 'products 10 appear to be equal- in performance and have similar 11 physical properties." Do you see that? 12 A. Yes. 13 Q. What was Pydraul used for? 14 A. Pydraul is Monsanto's trademark for its 15 industrial Hydraulic fluids. 16 Q. And looking at number one on the first page 17 of Exhibit 408, it says "products such as Pydraul," and 18 then it lists a series of numbers. "Turbinol,' 19 T-U-R-B-I-N-O-L, with a registered mark, "and 20 Therminol," T-H-E-R-M-I-N-O-L, with a registered mark, 21 "are. not formulated with Aroclor 1254 or 1260." Is that 22 correct? Is that correct it notes that on the letter? 23 A. ' Yes. 24 Q. What was Therminol used for? 25 A. That's the Monsanto registered trademark Gateway Reporting Associates, Inc. WATER PCB-SD0000071217 Gateway Reporting Associates, Inc. 273 1 for heat transfer fluids. 2 Q. And what was Turbinol used for? 3 A. Turbinol is Monsanto's trademark used for 4 fluids used in gas turbine devices that are used to . 5 move, for example, gas in transmission lines. 6 Q. Does that operation make use of heat? 7 A. No. 8 Q. WasMonsanto limiting thesales of Pydraul, 9 Turbinol, and Therminol by reason of this February 9th 10 or February 18th, 1970 communication? 11 A. They were not terminating at that time, but 12 there were studies underway to look into the replacement 13 in the Pydraul line. 14 Q. Is it a fair statement that this was 15 information that Monsanto was providing to its customers 16 at this time as to this PCB issue? 17 A. Yes. 18 Q. Did you sayanythingabout your hypothesis 19 of dibenzofurans or dioxins in this correspondence? 20 MR. SABETTA: Objection to form. 21 . A. No. 22 Q. If you look at tab26 for me,please. Have 23 we placed an exhibit number on that tab? 24 A. 409. 25 Q. We'vemarkedExhibit 409, amemo from a N. Gateway Reporting Associates, Inc. WATER PCB-SD0000071218 Gateway Reporting Associates, Inc. 274 1 T. Johnson, February 16, 1970, reference pollution 2 letter to quite a few individuals. Have you seen that 3 document before? 4 A. Yes, I have. 5 Q. Did you participate in the preparation of 6 that? 7 A. No. 8 Q. Who is N. T. Johnson? 9 A. He was a member of Monsanto'smarketing 10 group in the Functional Fluids team. 11 Q. ' Did that group sell Aroclors and PCBs? 12 A. They sold them as an ingredient in their 13 hydraulic fluid products. 14 Q. So do I understand Mr. Johnson was only 15 involved in the sales of hydraulic fluids? 16 A. Yes. 17 Q. I note it's copied to Mr.Benignus about 18 halfway down the second column of CC's. Do you see 19 that? 20 A. Yes. 21 Q. Was Mr.Benignus in charge of larger sales 22 than just hydraulic fluids? 23 A. ' No. 24 Q. Was he in charge of hydraulic fluids? 25 A. No. Gateway Reporting Associates, Inc. WATER PCB-SD0000071219 Gateway Reporting Associates, Inc. 275 1 Q. Who was in charge, if you know, of sales of 2 transformer fluids? 3 A. Mr. Benignus. 4 Q. Was Mr. Benignus in charge of overall sales 5 of fluids using PCBs? 6 A. No. 7 Q. Who was? 8 A. Olson. Mr. Olson. 9 Q. And was Mr. Olson Mr. Benignus1 s' boss? 10 A. Yes. 11 Q. Was Mr. Benignus Mr. Johnson's boss? 12 A. No. ' 13 Q. Was that a different line of reporting 14 authority? 15 A. I don't know what you mean by line. 16 Q. I'll ask you another question. Who was 17 Mr. Johnson's boss? 18 A. Mr. Olson. 19 Q. If you refer to the first page of 409, in 20 the first paragraph it says, "Attached is a list of 21 questions and answers which may be asked of you by 22 customers receiving our Aroclor-PCB letter. You can 23 give verbal answers; no answers should be given in 24 writing. If the customer asks a question you can't 25 answer or if he wants an answer in writing, then send Gateway Reporting Associates, Inc. WATER PCB-SD0000071220 Gateway Reporting Associates, Inc. 276 1 his questions to me, and we will answer it from here." 2 Do you see that? 3 A. Yes. 4 Q. Does that represent a practice of Monsanto 5 adopted at about that time of giving answers only orally 6 other than writings emanating from St. Louis? 7 MR. SABETTA:: Objection to the form. 8 A. It does not, 9 Q. Was there a practice adopted by'Monsanto of 10 answers to customers only orally? 11 MR. SABETTA:: Objection to form. 12 A. No . 13 Q. What is Mr. Johnson referring to here? ' 14 A. You' 11 have to ask Mr. Johnson that. 15 Q. Was there any correspondence from these 15 16 or 20 people telling Mr. Johnson that he had 17 misunderstood how communications with customers should 18 take place? 19 MR. SABETTA: Objection to the form. 20 A. Not that I know. 21 . Q. Is it your understanding that the list of 22 addressees on this Exhibit 409 was permitted to give 23 written answers on Aroclor PCBs? 24 MR. SABETTA: Objection to form. 25 A. That's my understanding, yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071221 Gateway Reporting Associates, Inc. 277 1 Q. Where does your understanding come from? 2 A. Just by being with Monsanto for about 20 3 years and knowing how we operated and how we 4 communicated, I arrived at that understanding. 5 Q. Was it your understanding that Mr. Johnson 6 had no authority to send such an exhibit as 409? 7 MR. SABETTA: Objection to form. 8 A. I'm not aware of anything that authorized 9 Mr. Johnson to develop that policy. ' 10 Q. Did you know Mr. Johnson? 11 A. Yes. 12 Q. Was he kind of a rogue sort of guy? 13 A. A what kind? 14 MR. SABETTA: Objection to the form. 15 A. That's so subjective. That depends on 16 who's observing. 17 Q. If you look at the second paragraph of 409, 18 it says, "We want to avoid any situation where a 19 customer wants to return fluid." Do you see that? 20 A. I do. 21 . Q. Had there been discussions among this group 22 that you were the chairman of as to avoiding situations 23 where a customer wanted to return fluid? 24 A. No. 25 Q. Were there discussions about encouraging Gateway Reporting Associates, Inc. WATER PCB-SD0000071222 Gateway Reporting Associates, Inc. 278 1 customers to return fluids? 2 A. Yes. 3 Q. When did those kind of discussions take 4 place? Maybe we can use this Exhibit 409 as a . 5 reference. This is February 16th, 1970. Do you know 6 whether those kind of discussions as to encouraging 7 customers to return fluid were before that memo? 8 A. Monsanto had for a decade or more a policy 9 of receiving fluids and arranging for a recovery of the 10 fluids to make them useful again. 11 Q. You say that policy was for a decade prior 12 to this February 1970 date? ' 13 A. At least . 14 Q. How did you become familiar with that 15 policy? 16 A. Well, some of my familiarity, of course, 17 came when I was at the Anniston, Alabama plant, and we 18 would receive these materials and run them through the 19 production system and make them usable again, and later 20 when I got this assignment in 1970, I was made aware 21 there were additional facilities in which a 22 subcontractor would clean the material. 23 Q. ' Did Monsanto make a charge to the customers 24 for receiving the returned fluids? 25 MR. SABETTA: Objection to form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071223 Gateway Reporting Associates, Inc. 279 1 A. I'm not familiar with the financial 2 arrangements. 3 Q. Do you know as to whether Monsanto ever 4 made a charge as to return of used fluids? 5 MR. SABETTA: Objection to form. 6 A. I know of the charge that was made for 7 disposal via incineration. That was eventually 8 implemented. 9 Q. Did Monsanto charge for return of PCB 10 fluids prior to getting its incinerator up and running? 11 A. Like I said earlier, I'm not aware of these 12 financial arrangements. ' 13 Q. Did Monsanto charge for taking in the used 14 fluid, cleaning it, and returning it to customers? 15 A. Well, again, I don't know what arrangements 16 were made with each customer. 17 Q. Do you know whether the material that was 18 cleaned by Monsanto was sold to customers? 19 MR. SABETTA: Objection to form. You mean 20 different customers than the ones that returned it? 21 , Q. Different customers, the same customers. 22 I'm interested in whether it was sold. 23 A. It was sold. 24 Q. Look at the second paragraph of Exhibit 409 25 towards the bottom, the next to the last paragraph. It Gateway Reporting Associates, Inc. WATER PCB-SD0000071224 Gateway Reporting Associates, Inc, 280 1 says, "We can't afford to lose one dollar of business. 2 Our attitude in discussing this subject with our 3 customers will be the deciding factor in our success or 4 failure in retaining all our present business. Good 5 luck." Do you see that? 6 A. I do. 7 Q. Did you receive a copy of this 8 communication? 9 A. No. 10 Q. How did it come about that you received it? 11 Let me withdraw that. At some point did you see it? 12 A. Yes, I did. ' 13 Q. Who gave it toyou? 14 A. I don't remember. Somebody sent me a copy. 15 Q. Do you know whether - - Was it about this 16 time, February of 1970, - 17 A. Yes. 18 Q. -- that you got a copy? 19 A. Yes. 20 Q. Did you respond to Mr. Johnson or anyone in 21 writing with respect to this Exhibit 409 after you 22 received a copy? 23 A. No. 24 Q. The third page in on Exhibit 409 is 25 entitled "Possible Customer Questions on PCBs". Do you Gateway Reporting Associates, Inc. WATER PCB-SD0000071225 Gateway Reporting Associates, Inc. 281 1 see that? 2 A. I do. 3 Q. Did you receive thatdocument aspart of 4 the communication when you received it in February of 5 1970? 6 A. I did. 7. Q. Did you review it? 8 A. Yes. 9 Q. Did you agree with the proposed questions 10 and the proposed answers? 11 MR. SABETTA: Objection to form. 12 A. I agreed with some of theanswers. I did 13 not judge the validity or the value of the questions', 14 and I found some of the responses could have been worded 15 differently. 16 Q. Did you make any form of document with 17 respect to your position in February of 1970 with 18 respect to this document entitled "Possible Customer 19 Questions on PCBs"? 20 A. I did not. 21 . Q. Why not? 22 MR. SABETTA: Objection to form. 23 A. Gee, I don't remember the -- I suspect I 24 was too darn busy. I just never got around to it. 25 Q. You also suspect that perhaps you didn't Gateway Reporting Associates, Inc. WATER PCB-SD0000071226 Gateway Reporting Associates, Inc. 282 1 disagree too much with the questions and answers? 2 MR. SABETTA: Objection to form. 3 A. That's not true. I was not in complete 4 agreement with what was in these documents. 5 Q. Did you bring that lack of complete 6 agreement with this document to anyone's attention? 7 A. Yes. 8 Q. To whose attention did you bring it? 9 A. Mr. Johnson, Mr. Olson, Mr. Bergen. 10 Q. Were there any documents created with 11 respect to your lack of complete agreement as to this 12 particular document? ' 13 A. Not to myknowledge. 14 Q. If you look at Exhibit 27 -- I'm sorry. 15 Would you turn to tab 27 for me, please? 16 A. 410. 17 (Whereupon, there was an off-the-record 18 discussion.) 19 Q. You have in front of you Exhibit 410, which 20 purports to be a March 30th, 1970 memo from W. B. 21 Papageorge to a list of individuals; is that correct? 22 A. Yes. 23 Q. ` And that document purports to attach a copy 24 of arough draft of a plan for managing the PCB problem; 25 is that correct? Gateway Reporting Associates, Inc. WATER PCB-SD0000071227 Gateway Reporting Associates, Inc. 283 1 A. Yes . 2 Q. Now, this particular communication asks 3 that each of the addressees review the draft and "plan 4 to meet jointly in conference room C303 on Thursday, 5 April 2nd, at 9:00 a.m. for a thorough discussion." Is 6 that correct? , 7 A. Yes . 8 Q. Then it says, "Our objective will be to 9 develop a finished plan which will eventually be 10 presented to the CMC by mid April." Do you see that? 11 A. Yes . 12 Q. Who's the CMC? . 13 A. The Corporate Management Committee. 14 Q. Do you know that that meeting occurred on 15 April 2nd that you refer to in this document? 16 A. Yes, it did. 17 Q. Was there a thorough discussion? 18 A. Yes . 19 Q. Were there notes made at that meeting? 20 A. Yes, there were. Marginal type notes. 21 Q. When you say marginal type notes, do you 22 mean someone wrote in the margins of your proposed 23 document ? 24 A. Well, there were several of us that did 25 that. I for one did, and there were others in the room Gateway Reporting Associates, Inc WATER PCB-SD0000071228 Gateway Reporting Associates, Inc. 284 1 Q. Did anyone else -- Withdraw that.' Do you 2 know if all of these addressees came to that meeting? 3 A. I don't recall today, no. 4 Q. The rough draft of the document is attached 5 to 410; is that correct? 6 A. I'm sorry? 7 Q. The rough draft of the management planfor 8 polychlorinated biphenyl environmental problem is 9 attached to that Exhibit 410; is that correct? 10 A. It is. 11 Q. That particular document doesn'tappear to 12 have any comments in the margin; is that correct? ' 13 A. That is correct. ' 14 Q. Are there copies that have comments in the 15 margins ? 16 MR. SABETTA: You mean that he possesses or 17 that exist somewhere in the world? Object to the form. 18 Q. Can you answer that? 19 A. I just am not aware of the presence or 20 existence of documents showing marginal notes on this 21 rough draft. 22 Q- You mentioned that you had written marginal 23 notes on the draft; is that correct? 24 A. Yes . 25 Q. Do you know whether your document with Gateway Reporting Associates, Inc. WATER PCB-SD0000071229 Gateway Reporting Associates, Inc. 285 1 marginal notes was retained by Monsanto? 2 A. I do not. 3 Q. Who else did you see writing marginal notes 4 on the draft? 5 A. I don't remember theparticular 6 individuals. They were around the table, and many of 7 them were making notes. 8 Q. Do you know if any other individuals other 9 than the addressees came to this meeting? 10 A. I do not. 11 Q. Do you know if a finished plan was 12 developed? 13 A. Yes. 14 Q. Did that finished plan bear the same title 15 as this rough draft? 16 A. As best I recall, yes, it does. 17 Q. And did you prepare that? 18 A. Yes. 19 . Q. How did you go about preparing it after 20 this meeting? 21 . A. I incorporated in the document the changes 22 that appear to have been thoroughly discussed and 23 accepted by the members of the group. 24 Q. Did you after incorporating the accepted 25 comments by the group, did you prepare a draft for Gateway Reporting Associates, Inc. WATER PCB-SD0000071230 Gateway Reporting Associates, Inc. 286 1 circulation, or did you .simply call that the final? 2 A. That was considered the final version. 3 Q. It was considered by you the final version? 4 A. Yes. 5 Q. Do you recall whether you incorporated many 6 comments in your final draft? 7 A. No, I don't. 8 Q. Do you recall whether your program as 9 referenced -- Withdraw it. Do you recall whether your 10 final draft included a program similar to what's set 11 forth on page 12 of this Exhibit 410? 12 MR. SABETTA: Objection to the form. You 13 can answer the question. . 14 A. As best as I can recall, it did. 15 Q. Would you turn the tab 28, please? What's 16 the exhibit tab that we placed on that? 17 A. 411. 18 Q. Exhibit 411 purports to be amemorandum 19 from R. Emmet Kelly, M.D., dated March 30th, 1970 to 20 yourself; is that correct? 21 A. Yes. 22 Q. Now, that communication references that "We 23 have been in communication with a Dr. Hill of the Ohio 24 State Board of Health. He has found PCB, particularly 25 Aroclor 1254, in samples of milk from at least three Gateway Reporting Associates, Inc. WATER PCB-SD0000071231 Gateway Reporting Associates, Inc. 287 1 herds in Ohio." It then goes on and discusses this; is 2 that correct? 3 A. Yes. 4 Q. In the third paragraph of that, Dr. Kelly 5 says, "All in all, this could be quite a serious problem 6 having legal and publicity overtones. This brings us to 7 a very serious point. When are we going to tell our 8 customers not to use Aroclor in any paint formulation 9 that contacts food, feed, or water for animals or 10 humans? I think it is very important that this be 11 done." Do you see that? 12 A. I do. , 13 Q. Was that done? 14 A. Yes. In fact, this is part of the open use 15 phase-out. ' 16 Q. What I'm interested to know is whether any 17 documents were prepared and sent to customers that told 18 them that Aroclors were not to be used in any paint 19 formulation that contacts food, feed, or water for 20 animals or humans. Was such a document prepared by 21 Monsanto? 22 A. There was a statement that was added to the 23 product labels that referred to this presence in food, 24 feed, and water. 25 Q. What product labels do you refer to? Gateway Reporting Associates, Inc. WATER PCB-SD0000071232 Gateway Reporting Associates, Inc. 288 1 A. These are labels that were affixed to 2 containers of materials that contained PCBs. 3 Q. Did they specifically reference not to be 4 used in any paint formulations that contacts food, feed, 5 or water for animals or humans? 6 A. It was not just limited to paint. 7 Q. Are you saying that a label was affixed to 8 all products containing PCBs that said it should not be 9 used in any formulation that contacts food, feed, or 10 water for animals or humans? 11 A. Words to that effect, yes. 12 Q. What's thewords yourecall being used when 13 you say "to that effect"? ' 14 A. I don't recall each and every word in this 15 sentence, but there is a sentence included in other ID's 16 or other precautions which refers to the use of PCBs in 17 situations that will result in contacting food, feed, or 18 water for animals or humans. 19 Q. When was that done? 20 A. 1970. 21 . Q. Were some of those products sent to General 22 Electric with those labels? 23 A. Yes. 24 Q. Do you knowwhether any ofthatinformation 25 was placed on'Material Safety Data Sheets? Gateway Reporting Associates, Inc. WATER PCB-SD0000071233 Gateway Reporting Associates, Inc. 289 1 A. Yes. 2 Q. Do you know whether any of that information 3 was placed on Material Safety Data Sheets for Aroclor 4 1254? 5 A. Yes. 6 Q. Was it? 7 A. As best Iremember. 8 Q. And when did that occur? 9 A. 1972. 10 Q. Now, you say as best you remember. You do 11 remember that this took place, what you've just told me; 12 don't you? 13 MR. SABETTA: Objection to the form. 14 A. Sir, I was one of several people that 15 developed Material Safety Data Sheets. 16 Q. Uh-huh. 17 A. I remember the process that we went 18 through, and the only hazy recall I have is the date 19 when they were completed and available and issued. 20 Q. Would that date be as late as 1987, for 21 example, in which any reference was made to food or 22 feed? 23 ' MR. SABETTA: Objection to the form. 24 A. Oh, no. No. This would have to be '71, 25 '72, or '73. Gateway Reporting Associates, Inc. WATER PCB-SD0000071234 Gateway Reporting Associates, Inc. 290 1 Q. Would you turn to tab 29, please? Off the 2 record. 3 (Whereupon, there was an off-the-record 4 discussion) 5 Q. Can we turn to tab 30, please? Is there 6 a -- 7 A. 413. 8 Q. We've marked as Exhibit 413 - 9 A. Yes. 10 Q. --a documententitled "News for Release 11 Immediately, 1970," on Monsanto paper with an E. V. John 12 at the top. Have you seen that document before? ' 13 A. Yes, I have. : 14 Q. Is this a press release that Monsanto 15 issued to the public? 16 A. Yes. 17 Q. Do you know what the date of that press 18 release was? 19 A. Yes. It's the firstline, April 10th, 20 right after the word "St. Louis". 21 Q. That would be April 10th, 1970 then? 22 A. Correct. 23 Q. ' Was anything said in that press release as 24 to dioxins or dibenzofurans? 25 A. No . Gateway Reporting Associates, Inc. WATER PCB-SD0000071235 Gateway Reporting Associates, Inc. 291 1 Q. In the second paragraph, it says, 2 "Monsanto's statement came in response to charges by 3 Congressman William P. Ryan, R-Y-A-N, (Dem.)" - 4 A. Democrat. 5 Q. -- "of New York that discovery of PCB in 6 the ecology represented a major threat." Do you see 7 that ? 8 A. Yes . 9 Q. Are you familiar with Congressman Ryan 10 introducing legislation with respect to PCBs? 11 A. Yes . 12 Q. Do you know when he did that? 13 A. 1970 or 1971. 14 Q. Do you know whether it was prior to this 15 press release referencing Congressman Ryan's charges? 16 A. I don't recall the specific timing. 17 Q. Was there eventually legislation that was 18 passed by Congress with respect to PCBs? 19 MR. SABETTA: Objection to the form. 20 A. Yes . 21 . Q. Do you know about when it was passed? 22 A. 1975 or '76. 23 Q. ' Do you know any particular reason why it 24 took five or six years to pass? 25 A. I do not. Gateway Reporting Associates, Inc. WATER PCB-SD0000071236 Gateway Reporting Associates, Inc. 292 1 Q. Did you yourself meet personally with 2 Congressman Ryan and other government officials with 3 respect to PCBs from 1970 forward? 4 A. I did not meet with Congressman Ryan. 5 Q. You did meet with other officials? 6 A. I met with other representatives of 7 agencies of the government, regulatory agencies. 8 Q. Did you meet with any Congressmen or 9 Senators? ' 10 A. No. 11 Q. Did other employees of Monsanto meet with 12 Congressmen and Senators with respect to PCB 13 legislation? 14 A. Not that I know of. 15 Q. Would you have any knowledge of that in the 16 ordinary course of what you did for Monsanto? 17 MR. SABETTA: Objection to the form. 18 A. Yes. 19 Q. What about these individuals on the 20 Corporate Development Committee? Would you have 21 knowledge as to what they did in terms of meetings with 22 Congressmen and Senators? 23 MR. SABETTA: Objection to the form. 24 A. Yes. 25 Q. How would you have knowledge of that? Gateway Reporting Associates, Inc. WATER PCB-SD0000071237 Gateway Reporting Associates, Inc. 293 1 A. The individual Monsanto employee in 2 Washington would have informed me of that type of 3 activity. 4 Q- Who was this Monsanto employee in 5 Washington that you're referring to? 6 A. I forget his first name. Mr. Easley, 7 E-A-S-L E Y. 8 Q. What was Mr. Easley's title? 9 A. As best I recall, Manager, Governments 1 10 Affairs. 11 Q. Was he a direct employee of Monsanto? 12 A. Yes. 13 Q. Did he have an office in Washington? 14 A. He worked out of an office, yes. 15 Q. Was that a Monsanto office? 16 A. Yes. . 17 Q. Did he have other employees that worked for 18 him? 19 A. Yes . 20 Q. How big an office was that in terms of 21 number of employees? Do you remember? 22 A. I'd say half a dozen. 23 Q. Was Mr. Easley a lobbyist? 24 A. No. . 25 Q. Did Monsanto employ a lobbyist about this Gateway Reporting Associates, Inc. WATER PCB-SD0000071238 Gateway Reporting Associates, Inc. 294 1 time, 1970 to 1976? 2 A. Yes . 3 Q. Who was that? 4 A. Sam Pickard, P-I-C-K-A- R-D . 5 Q. Do you know about when Mr. Pickard was 6 employed? 1 A. I do not. 8 . Q- Do you know whether he worked for Monsanto 9 as a lobbyist in 1970? 10 A. Yes . 11 Q. Did he work for them in 1971? 12 A. Yes . 13 Q. ' 72? 14 A. Yes . 15 Q. ' 73? 16 A. Yes . 17 Q. ' 74? 18 A. Yes . 19 Q. ' 75? 20 A. Yes . 21 Q. '76? 22 A. Yes. 23 Q. ' How about '77? 24 A. I don't remember when Mr. Pickard retired, 25 so I don't know beyond that. Gateway Reporting Associates, Inc. WATER PCB-SD0000071239 Gateway Reporting Associates, Inc. 295 1 Q. Do you know about when he retired? 2 A. No, I do not. 3 Q. Do you know that the Toxic Substance 4 Control Act was passed in '76? 5 A. Yes. 6 Q. Did he retire after that? 7 A. I believe so, yes. 8 Q. Do you know about how much Monsanto paid 9 him a year for his efforts? ' 10 A . I do not . 11 Q. Do you know how much Monsanto paid a year 12 for his efforts with respect to PCBs? 13 A. I do not. 14 Q. Would you turn to tab 31 for me, please? 15 Have we put an exhibit number on that? 16 A. 414. 17 Q. I'm showing 414 for identification purposes 18 to be a memo by John Mason, a report on meeting with 19 Congressman Wm. F. Ryan (Dem. 20th District - New York) 20 to the file. Have you seen that document before? 21 A. Yes. 22 . Q. A series of individuals are copied on that 23 particular document; is that correct? 24 A. Yes. 25 Q. It includes Mr. Eck, E-C-K? Gateway Reporting Associates, Inc. WATER PCB-SD0000071240 Gateway Reporting Associates, Inc. 296 1 A. Yes. 2 Q. Mr. Smith, Jr.? 3 A. Yes . 4 Q. Mr. Minkler, Mr. Smith, Mr. Kelly/E. P. 5 Wheeler, Mr. Bergen and Mr. Springgate, Mr. Papageorge 6 and Sam Pickard, Washington, D.C.; is that correct? 7 A. Yes. 8 Q. Did you get a copy of that document at or 9 about that time? ' 10 A. Yes. 11 Q. And that documents a meeting with Sam 12 Pickard and Mr. Mason with Congressman Ryan on April . 13 16th, 1970; is that correct? ' 14 A. Yes. 15 Q. Would you turn to tab 32 for me, please? 16 Has that got a tag on it? 17 A. 415. 18 Q. I've put Exhibit 415 in front of you, which 19 purports to be a letter by John Mason, Assistant General 20 Manager, to Honorable William F. Ryan, dated April 28th, 21 1970., with copies to various individuals. It showed you 22 as one of the addressees; is that correct? 23 A. Yes. 24 Q. In the second pageof that particular 25 document, at the top, first full paragraph on the page, Gateway Reporting Associates, Inc. WATER PCB-SD0000071241 Gateway Reporting Associates, Inc. 297 1 it says, "We have been investigating the relationship of 2 PCB to the environment since 1968." Do you see that? 3 A. Yes. 4 Q. Was that accurate, that statement? 5 A. Yes. 6 Q. What'syour earliest recollection from 7 reviewing the records of Monsanto as to when it began 8 investigating the relationship between PCB and the 9 environment? ' 10 A. My recollection is that as soon as Monsanto 11 heard about the study in Sweden and the possible 12 presence of PCBs, to use the word used here, 13 investigating of the matter began, which, as best as I 14 recall, was about 1967. 15 Q. I think welooked at documentsyesterday 16 showing that Ola Palm sent material to Monsanto in 17 Brussels in 1966 or thereabouts. Does that refresh your 18 recollection? 19 A. Yes. I thought that was late '66. 20 Q. And based on your knowledge with respect to 21 Monsanto records, what was the first thing that Monsanto 22 did with reference to that information being brought to 23 its attention? 24 A. The first action, as I recall, was the 25 assignment of David Wood in Brussels to contact Mr. Palm Gateway Reporting Associates, Inc. WATER PCB-SD0000071242 Gateway Reporting Associates, Inc. 298 1 in Stockholm and start the dialogue going as to what's 2 going on, what are you finding, how do you do it. 3 Q. Did Monsanto then engage in a process of 4 attempting to duplicate Dr. Jennsen's studies? 5 MR. SABETTA: Objection to form. 6 A. Yes. 7 Q. Do you know when itstarted that? 8 A. Sometime in 1967. 9 Q. And how did it start thatprocess? Can you 10 tell me? 11 A. Of course, I don't know every move that was 12 made, but the assignment was initially given to the 13 people in Monsanto who do research regarding analyzing 14 for chemicals. Monsanto got a copy of the procedure 15 used by the University of Stockholm investigators and 16 began the process of applying the procedure and learning 17 how to make it accurate and reproducible. In the 18 meantime, they ordered the latest in analytical 19 equipment, and it became a matter then of improving the 20 process. 21 . Q. If you look at the third page of Exhibit 22 415, in the first full paragraph it says, "In my 23 opinion, to release a complete list of uses for Aroclor 24 registration mark, names of products and manufacturers, 25 as you suggest, would only cause undue alarm to the Gateway Reporting Associates, Inc. WATER PCB-SD0000071243 Gateway Reporting Associates, Inc. 299 1 public and would make no contributions in this area." 2 Do you see that? 3 A. I do. 4 Q. Did Congressman Ryan ask for a list of uses 5 of Aroclors and the names of the products and the 6 manufacturers? 7 A. As I remember, he did, yes. 8 Q. Do you know if that material was ever sent 9 to him by Monsanto? . ' 10 A. It was neversent. 11 Q. If you turn to tab 33 for me, please. 12 That's not marked. 13 (Luncheon recess.) 14 (Reporter marked Plaintiff's Exhibits 416 15 through 431.) 16 Q. Do you have Exhibit 416 in front of you, 17 Mr. Papageorge? 18 A. Yes (nodded). 19 Q. Exhibit 416 appears to be a letter from 20 Elmer Wheeler to Otis Fancher, Ph.D. at Industrial 21 Bio-Test, dated May 25th, 1970. Have you seen that 22 document before? 23 A. ' Yes. 24 Q. Did you have any direct dealings with Otis 25 Fancher? Gateway Reporting Associates, Inc. WATER PCB-SD0000071244 Gateway Reporting Associates, Inc. 300 1 A. Yes. 2 Q. How did you happen to have those direct 3 dealings? 4 MR. SABETTA: Objection to form. 5 Q. Withdrawn. Tell me about these direct 6 dealings. 7 A. I met Dr. Fancher at the laboratories when 8 I joined Mr. Wheeler in a visit to those laboratories to 9 observe the testing and to be brought up to date as to 10 the status, current findings and so on. 11 Q. Do you know about when that visit was? 12 A. I think the first one occurred in the fall 13 of 1970. 14 Q. You say first one. Did you have more than 15 one? 16 A. Yes, I did. 17 Q. How many? 18 A. I think I remember four visits to 19 laboratories of Industrial Bio-Test. 20 Q. Can you give me the approximate dates of 21 the other three visits? 22 A. This is approximate now. My second visit 23 to the Northbrook laboratories was about the first 24 quarter of 1971, and then, say, mid year 1971, and the 25 latter part of 1971 I visited the Decatur, Illinois Gateway Reporting Associates, Inc. WATER PCB-SD0000071245 Gateway Reporting Associates, Inc. 301 1 laboratory. 2 Q. The first three visits you've told me about 3 were to the Northbrook laboratory? 4 A. Yes. 5 Q. What particular study, if any, was being 6 done at Decatur? 7 A. This is the study with chickens. 8 Q. Would those be leghorn chickens? . 9 A. Yes. ' 10 Q. The very chickens that are mentioned in 11 Exhibit 416? .- 12 A. I have to believe that. Yes. . 13 Q. Were these arranged visits? In other 14 words, were they scheduled prior to your arrival? 15 A. Yes. 16 Q. Did you go withanyone from Monsantoother 17 than yourself? 18 A. Elmer Wheeler was my escort. 19 Q. For all four of these visits? 20 A. Yes. 21 Q. Was there a particular purpose in each of 22 these visits? 23 A. My purpose reallywas to get familiar with 24 the way things were being done and handled, to get a 25 report where things stood. Gateway Reporting Associates, Inc. WATER PCB-SD0000071246 Gateway Reporting Associates, Inc. 302 1 Q. Had you had in your life experience any 2 prior dealings with animal laboratories prior to these 3 visits? 4 A. I did not. 5 Q. Now, in this Exhibit 416, this purports to 6 authorize Mr. Fancher to proceed with a study with 7 leghorn chickens with Aroclor 1242, to duplicate a study 8 previously done with Aroclor 1242, except in this 9 instance you have suggested using dietary levels of two, 10 four and eight ppm. Do you see that? 11 A. I do. 12 Q. The next paragraph says, "This sample of 13 Aroclor represents our current regular production which 14 involves some cleanup instituted since the previous 15 sample was made available to you." Do you know what 16 that refers to, the "some cleanup instituted"? 17 A. Yes, I do recall it. 18 Q. What does it refer to? 19 A. This refers to the sample being of the kind 20 that is sold for the electrical applications and does 21 not include any material that's been recycled from the 22 previous use and presumably cleaned up and reused. So 23 this was an attempt to test material as produced in its 24 virgin state. 25 Q. You mean that the previous sample of Gateway Reporting Associates, Inc. WATER PCB-SD0000071247 Gateway Reporting Associates, Inc. 303 1 Aroclor 1242 given to Mr. Fancher for testing was not in 2 its virgin fashion? 3 A. Not in what, sir? 4 Q. Its virgin fashion. 5 A. It implies -- There's some question. They 6 weren't certain whether it was virgin material or a 7 blended material given a lot number and then ready for 8 sales. There was apparently some question about its I'm 9 going to call it virginity. ' 10 Q. There's a lot of that in the world. Is 11 this something that was told to you by Mr. Wheeler or 12 someone else, that there was a question as to the purity 13 of the previous sample that was tested by Industrial 14 Bio-Test? 15 - A. Yes. 16 Q. What did he say? 17 A. Boy, I don't recall the exact words, but 18 the effect was that it didn't analyze as well as other 19 samples. 20 Q. Are you suggesting he told you that other 21 samples analyzed better in terms of biological effects? 22 MR. SABETTA: Objection to form. 23 A. We're not comparing biological effect. 24 Q. What areyou comparing? 25 A. Chemical analysis. Gateway Reporting Associates, Inc. WATER PCB-SD0000071248 Gateway Reporting Associates, Inc. 304 1 Q. Comparing chemical analysis -- Withdraw it. 2 Did Mr. Wheeler tell you that the prior samples given to 3 Industrial Bio-Test were not virgin as produced in the 4 factory? 5 A. He didn't use the word "virgin". He just 6 said that the analysis of that lot number from which the 7 sample was taken was not as good as a good product 8 analyses. 9 Q. Did he show you the analysis that was done 10 on that product that was sent? 11 A. No. . 12 Q. Was there a written document concerning 13 that analysis on the product that was sent to Industrial 14 Bio-Test? 15 A. Oh, there has to be. I didn't see it 16 personally, but I can't believe that the analytical 17 laboratory would not have filled out the form and 18 reported the testing results. 19 Q. Why can't you believe that? 20 A. It just isn't done . 21 Q. Withdrawn.. Why should there 22 that material after it had been submitted to Industrial 23 Bio-Test and used to do animal testing? 24 A. No. This -- I misled you. The testing 25 analytically for chemical characteristics is done before Gateway Reporting Associates, Inc. WATER PCB-SD0000071249 Gateway Reporting Associates, Inc. 305 1 the material is bottled for future sampling, and in this 2 case, as best I recall, it was at the lower end of the 3 acceptable specifications. 4 Q. Was it determined that it was at the lower 5 end of the acceptable specifications after the testing 6 by Industrial Bio-Test on that sample or before? 7 A. The chemist reported the results before the 8 sample was sent to the laboratory. When the results 9 came back from the laboratory, a reanalysis was made and 10 confirms that this particular sample, although it passed 11 the industrial specifications, didn't pass the good 12 normal Monsanto spec or characteristic. 13 Q. When you say the results came back from the 14 laboratory, meaning Industrial Bio-Test Laboratory? 15 A. No. Monsanto's analytical laboratory. 16 Q. Why was the original sample sent to 17 Industrial Bio-Test if it didn't meet Monsanto's good 18 specifications? 19 A. In the sample room, the materials are on 20 shelves, if you could picture it, and when the sample is 21 requested, the people who run the sample department 22 reach up, grab a sample, and ship it, send it on. The 23 sample is on that shelf because it passed the upper or 24 lower limits. It's within limits. It does not say that 25 it's typical of the average, nor does it say it's at the Gateway Reporting Associates, Inc. WATER PCB-SD0000071250 Gateway Reporting Associates, Inc. 306 1 low end or extra pure. 2 Q. Are you telling me what you understand, or 3 are you telling me information that you have firsthand 4 knowledge about? 5 MR. SABETTA: I'll object to the form 6 because I think he's testifying about a lot of different 7 things, but if you want to zero in on something 8 specific. 9 Q. Can you answer that? 10 A. Sir, I have difficulty with your questions 11 because you keep asking me my understanding and my 12 personal involvement. I was never in a position to- know 13 personally everything that took place. I had to take 14 other people's word, and 90 percent of my job was 15 accepting information others told me. 16 Q. That's exactly why I asked you that 17 question so we could find out what you know versus what 18 you've been told. Now, you've just told me, I guess, 19 what your understanding was as to how this sample of 20 lesser quality, if I can use that phrase, got sent to 21 Industrial Bio-Test in the first place. Is that 22 correct? You've told me your understanding? 23 A. Yes. 24 Q. Did Mr. Wheeler -tell you that that's what 25 happened? Gateway Reporting Associates, Inc. WATER PCB-SD0000071251 Gateway Reporting Associates, Inc. 307 1 A. Yes. 2 Q. Did Mr. Wheeler tell you whether he had 3 been told that by somebody else? 4 A. He didn't have to tell me. That's normal. 5 Q. Now, was the reanalysis on that sample that 6 was taken off the shelf, as you understand it to have 7 been taken, done prior to the results coming back from 8 Industrial Bio-Test? 9 A. No. 10 Q. The reanalysis was done after the results; 11 is that correct? ' 12 A. That is correct. 13 Q. Now, did someone tell you how this sample, 14 second sample of Aroclor was cleaned up as referenced in 15 this Exhibit 416? 16 A. I'm not aware of any cleanup involved. 17 Q. Well, do you know what the word "cleanup 18 instituted since the previous sample was made available" 19 refers to? 20 A. I do not . 21 Q. The next sentence says, "We would hope that 22 we might find a higher 'no effect' level with this 23 sample as compared to the previous work." Do you see 24 that? 25 A. I do. Gateway Reporting Associates, Inc. WATER PCB-SD0000071252 Gateway Reporting Associates, Inc. 308 1 Q. Was there a higher "no effect" level with 2 the second sample? 3 A. I don't remember. 4 Q. With reference to the next paragraph, it 5 says, "As soon as suitable reference standards are 6 available, the research laboratory in St. Louis will 7 more carefully characterize the two samples in terms of 8 possible minute amounts of contaminants." Do you see 9 that? ' 10 A. Yes. 11 Q. Do you know whether the St. Louis research 12 laboratory more carefully characterized the two samples? 13 A. That's what I was led to believe. 14 Q. Who led you to believe that? 15 A. Mr. Wheeler and Mr. Tucker in the 16 analytical laboratory. 17 Q. Did you ever see any documentation of the 18 characterization of the two samples in terms of possible 19 minute amounts of contaminants? 20 A. No . 21 . Q. Were you ever told that the contaminants 22 included furans? 23 A. Ever told? 24 Q. Yes. 25 A. At what point in time? Gateway Reporting Associates, Inc. WATER PCB-SD0000071253 Gateway Reporting Associates, Inc. 309 1 Q. The contaminants with respect to these 2 samples that we're talking about. 3 A. No. 4 Q. Were you ever told that the contaminants 5 contained dioxins, these samples? 6 A. No. 7 Q. Were you ever told anything as to what the 8 contaminants were if there were contaminants in these 9 two samples? 10 A. No . 11 Q. Could you turn to tab 34, please? We've 12 put an exhibit tag on that. Can you give me the number? 13 A. 417. ' 14 Q. Exhibit 417purports to be correspondence 15 from yourself to Mr. Jenkins atSprague Electric in 16 North Adams, Massachusetts, dated July 8th, 1970. It 17 appears it's the same correspondence we've already 18 marked and had testimony about as Exhibit 404; is that 19 correct ? 20 A. They appear to be similar, yes, the same. 21 . Q. Okay. Could you turn to tab 35, please? 22 What tag number do you have? 23 A. ' 418. 24 Q. I'm showing you Exhibit 418 for 25 identification. It purports to be a press release for Gateway Reporting Associates, Inc. WATER PCB-SD0000071254 Gateway Reporting Associates, Inc. 310 1 immediate release, 1970, July 16th. Have you seen that 2 document before? 3 A. Yes, I have. 4 Q. Did you participate in the preparation of 5 that? 6 A. I don't recallparticipating inthis. 7 Q. The second page of Exhibit 418 at the top 8 says, "Commenting on a recent report that PCB can induce 9 birth defects in animals, Minkler said, 'Monsanto is not 10 aware of any scientific data that indicates 11 polychlorinated biphenyls may cause birth defects.'" Do 12 you see that? 13 A. I do. 14 Q. Were you aware of any claims that PCBs 15 cause birth defects in animals? 16 A. I recall hearing of those allegations. I 17 do not recall what animals and what defects. 18 Q. Do you recall any allegations arising out 19 of the Yusho incident that the PCB oil caused birth 20 defects in humans? 21 . A. Yes. 22 Q. Do you recall when you heard those 23 allegations in terms of this press release? 24 A. I first heard of the Yusho incident in 25 early 1970. I don'tknow what else to add to that. Gateway Reporting Associates, Inc. WATER PCB-SD0000071255 Gateway Reporting Associates, Inc. 311 1 Q. Do you recall whether you heard contentions 2 that it wasn't the PCBs that caused birth defects after 3 Yusho but the dibenzofurans in the oil? 4 MR. SABETTA: Objection to the form. 5 A. I eventually heard of that, but to the best 6 of my recollection, it was later, about 1971 or so, when 7 I first was told that. 8 Q. Turn to tab 36 for me, please. What tag 9 number does it have on it? ' 10 A. 419. 11 Q. I'm showing you Exhibit 419 for 12 identification Mr. Papageorge. It purports to be a 13 memorandum between yourself and a J. R. Savage, 14 S-A-V-A-G-E, dated October 26th, 1970 with copies to 15 Mr. Bergen, Richard, Kelly, and Wheeler. Did you 16 prepare that document? 17 A. Yes. 18 Q. Now, the firstsentence says, "Recent data 19 from Dr. J. P. Mieure's, M-I-E-U-R-E-'-s, work indicates 20 the presence of naphthalene, N-A-P-H-T-H-A-L-E-N-E, in 21 biphenyl and anthracene, A-N-Y-H-R-A-C-E-N-E, or 22 phenanthrene, P-H-E-N-A-N-T-H-R-E-N-E, and dibenzofuran 23 in Santowax, S-A-N-T-O-W-A-X, R used in the manufacture 24 of Aroclors." Do you see that? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071256 Gateway Reporting Associates, Inc. 312 1 Q. Who is Dr. J. P. Mieure? 2 A. He was a Monsanto chemist working in 3 Dr. Keller's analytical chemistry group. 4 Q. And did he produce reports of his work? 5 A. Yes. 6 Q. Do you know whether those werenarrative in 7 form as opposed to simply numbers and reports of 8 quantities of chemicals? 9 MR.. SABETTA:: Objection to form.' 10 A. To me, they were narrative. 11 Q. Do you know how many such reports 12 Dr. Mieure produced? 13 MR. SABETTA: Objection to form. ' 14 A. No, I do not. 15 Q. The third paragraph says, "The 16 dibenzofurans could result from oxygen containing 17 contaminants in the benzene or, more likely, be formed 18 because of the presence of the promoter acetone, 19 A-C-E-T-O-N-E." Do you see that? 20 A. Yes. 21 Q. Where did you obtain that information from? 22 A. I don't recall thespecific individual, but 23 it came out of Dr. Richard's research group. 24 Q. The last paragraph says, "The Anniston 25 plant should design and execute a program for Gateway Reporting Associates, Inc. WATER PCB-SD0000071257 Gateway Reporting Associates, Inc. 313 1 determining the source or sources of these 2 contaminants." Is that correct? 3 A. Yes. 4 Q. Did the material that was tested by 5 Dr. Mieure or Dr. Richard's group come from Anniston? 6 A. That was the only plant that made Santowax 1 R, yes. 8 Q. Was that testing that was done part of 9 ordinary product testing for quality, or was it part of 10 a particular project - 11 MR. SABETTA: Objection to form. 12 Q. -- to review contents ofthesechemicals? 13 A. This was part of a program to develop 14 analytical procedures for those types of chemicals. 15 Q. What 1s Santowax? 16 A. That's a terphenyl, a solid,waxy material. 17 Q. Who is J. R. Savage? 18 A. He is the individual that was responsible 19 for manufacturing activities, and the Anniston plant was 20 one of his assignments. 21 Q. Was it ever determined where the 22 dibenzofurans came from? 23 A. It was, but at the moment I don't recall 24 when. 25 Q. What about the determination as to where Gateway Reporting Associates, Inc. WATER PCB-SD0000071258 Gateway Reporting Associates, Inc. 314 1 they came from? Do you recall what it was? 2 A. I don't recall, no. 3 Q. If you turn to exhibit or tag 37 for me, 4 please. We've marked a series of documents Exhibit 420 5 that purport to be Material Safety Data Sheets. Would 6 you take a look through those, please? 7 A. Would you like the number, sir? 420. 8 Q. Yes. Would you look through the documents 9 gathered together there as part of Exhibit 420 and 10 ascertain if they are all Material Safety Data Sheets 11 for Aroclor? . 12 A. These documents are a collection of 13 Material Safety Data Sheets for Aroclors, Inerteens, and 14 Pyranols. 15 Q. And I'll represent to you that all of the 16 documents entitled Material Safety Data Sheets bear a 17 date of May 1971. Can you tell me whether there were 18 earlier Material Safety Data Sheets than those prepared 19 in May of 1971 as to those chemicals? 20 A. Sir, the May '71 is the date of the OSHA 21 form- expiration. The date of these documents is, for 22 example, March 3rd, '72. 23 MR. SABETTA: February 3rd. 24 Q. Where are you referring to? 25 A. I'm sorry. At the bottom -- At the bottom Gateway Reporting Associates, Inc. WATER PCB-SD0000071259 Gateway Reporting Associates, Inc. 315 1 right-hand corner of the second page, you will see the 2 date of issue -3 Q. Okay. 4 A. -- of the Safety Data Sheets. 5 Q. Do you know whether any Material Safety 6 Data Sheets were prepared in 1970? 7 A. The OSHA forms weren't available till May 8 of '71.. 9 Q. Did Monsanto prepare similar documents with 10 respect to product safety as to these documents prior to 11 1971? 12 MR. SABETTA: Objection to form. 13 A. When you say "similar," you're talking 14 about the format or the information? 15 Q. Any documents like that. 16 MR. SABETTA: Objection to form. 17 A. There were no documents like these prior to 18 the issuance of this set. 19 Q. Were there any documents containing such 20 information that Monsanto prepared in 1970 and given to 21 either a government agency or a customer? 22 MR. SABETTA: Objection to form. 23 A. The information that is shown on these 24 Material Safety Data Sheets was included in Monsanto's 25 literature or Monsanto's product labels, not all on one Gateway Reporting Associates, Inc. WATER PCB-SD0000071260 Gateway Reporting Associates, Inc. 316 1 form. 2 Q. Did you or the group you were chairman of 3 play any role in the preparation of Material Safety Data 4 Sheets? 5 A. Yes. 6 Q. What role was that? 7 A. It depended on. the individual. I, for 8 example, sort of served as the person who looked over 9 the entire document to satisfy my interest in' the areas 10 covered. Other individuals there addressed different 11 parts of the document. 12 Q. Did you review the documentsgathered there 13 as part of Exhibit 420 prior to them being used or 14 furnished to anyone? 15 A. Yes. 16 Q. And in terms of the first document where it 17 has a Section V-lll on the second page, "Special 18 Protection Information," do you know who prepared that 19 information? 20 A. That would be a responsibility of Jack T. 21 Garrett. 22 Q. Was he part oftheMedicalDepartment? 23 A. Yes. 24 Q. Would it be the same answer with respect to 25 section Roman numeral IX, "Special Precautions"? Gateway Reporting Associates, Inc. WATER PCB-SD0000071261 Gateway Reporting Associates, Inc. 317 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Now, is thattrue with respect to each of those sections up through the document marked 1/24/72, which is Bates number 3318? A. Yes. Q. Mr. Garrett would have been supervising those operations in terms of comparing that material; is that correct? A. That is correct. Q. If you take a look for me, please, at 3319 Bates number. That's a document entitled Monsanto Material Safety Data, page one of four, and on the ' fourth page it bears a date September 15th, 1980; is that correct? A. Yes. Q. Were there otherMaterial Safety Data Sheets or Material Safety Data between January 24th, 1972, the last date at page number 3318, and this document at page number 3319? A. . Q. I don't know. Is there a particular department at Monsanto that's in charge of that? A. It's the department that is assigned this group of products. Q. At the time of the document at Bates number Gateway Reporting Associates, Inc. WATER PCB-SD0000071262 Gateway Reporting Associates, Inc. 318 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3319, September 15th, 1980, you were no longer working in the PCB area; is that correct? MR. SABETTA: You're talking about September 15, 1980; right? MR. MCDONOUGH: Yes. MR. SABETTA: As of that date, you were no longer working in the PCB area. A. I thought you mentioned a periodending in 1980. Q. ' No. At the time of this document identified as 3319, Monsanto Material Safety Data, which has a date on the fourth page of September 15th, 1980, you were no longer working in the area of PCBs; correct? A. That's correct. Q. Can you turn to tab 39 for me, please? Does that have an exhibit number on it? A. 421. Q. Exhibit 421 is entitled "Monsanto's PCB Program, W. B. Papageorge, presented at ANSI Committee, C-107, meeting September 14th, 1971". Is that correct? A. Yes. Q. Did you prepare that document? A. Yes. Q. What's the ANSI Committee C-107? A. That committee was formed under the Gateway Reporting Associates, Inc. WATER PCB-SD0000071263 Gateway Reporting Associates, Inc. 319 1 auspices of the American National Standards Institute. 2 That's what the ANSI stands for. To develop the 3 necessary information on the proper handling from 4 manufacture to use to disposal of PCBs. 5 Q. Did Monsanto have representatives on this 6 ANSI Committee C-107? 7 A. Yes. 8 Q. Who was Monsanto's representatives? 9 A. Paul Benignus and I were the Monsanto 10 representatives. 11 Q. Did General Electric have representatives 12 on this committee? 13 A. Yes. 14 Q. Do you know who its representatives were? 15 A. Yes. 16 Q. Who? 17 A. Ed Raab, R-A-A-B, and Mr. Posefski. I 18 forgot his first name. 19 Q. Do you know what his title was at General 20 Electric? 21 A. I associate him as being the key man -- one 22 of the key people in the capacitor part of GE1s 23 business. 24 Q. Was Mr. Raab with the transformer portion 25 of GE's business? Gateway Reporting Associates, Inc. WATER PCB-SD0000071264 Gateway Reporting Associates, Inc. 320 1 A. Yes. 2 Q. Did Westinghouse have representatives on 3 this committee? 4 A. Yes. 5 Q. Did other transformer and electrical 6 manufacturers have representatives on this committee? 7 A. Yes. 8 Q. How manyrepresentatives were on the 9 committee altogether? ' 10 A. I don'trecall the exact number. I would 11 say about 20 or so. 12 Q. Could you turn to tab 40 for me, please? 13 I'm sorry. 41. 14 A. 422. 15 Q. We've marked as Exhibit 422 a document 16 entitled "Status Report PCB/PCT Implementation Program," 17 which appears to be the first of three pages of what 18 we've marked Exhibit 422. Can you tell me what that is? 19 A. It's entitled "Status Report on the PCB/PCT 20 Implementation Program". 21 Q. Did you participate in the preparation of 22 that ? 23 A. I'm having difficulty recalling this 24 document. I don't think I ever saw it. 25 Q. Do you know what it was prepared for? Gateway Reporting Associates, Inc. WATER PCB-SD0000071265 Gateway Reporting Associates, Inc. 321 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I do not . Q. There appear to be various portions of the document over headings which say "certified by" and then an individual's name; is that correct? . A. I don't know that it's a heading so much as a statement about referring to the previous paragraph. Q. All right. Well, let's look at the first page. It says Roman numeral I, "Discontinue sales of PCBs for heat transfer applications. The sales of PCB heat transfer fluids in the U.S. will be terminated on December 15th, 1971 with two exceptions, both covered with hold harmless agreements." And then it goes on.' Do you see that? A. Yes. Q. That purports to becertified by T. L. Gossage, G-O-S-S-A-G-E; is that correct? A. Yes. Q. Do you know who Mr. Gossage is or Miss or Mrs. Gossage is? A. Mr. Thomas Gossage succeeded Mr. Don Olson as the Director of Marketing for the Functional Fluids business. Q. Now, the next sentence says, "We continue to supply Goodyear Tire and Rubber Company under an agreement until August 7th, 1972. We supplied fluid to Gateway Reporting Associates, Inc. WATER PCB-SD0000071266 Gateway Reporting Associates, Inc. 322 1 Bendix Corporation under an agreement, but sales were 2 terminated prior to June of 1972." Do you see that? 3 A. I do. 4 Q. What were PCBsused for byGoodyear Tire 5 and Rubber? Do you know? 6 A. Well, the wholeparagraphrefers to heat 7 transfer applications. 8 Q. Do you know what it was used for in terms 9 of what process they were employing it in? ' 10 A. I do not. 11 Q. Do you know whether they used a heat 12 transfer system to melt the rubber or make the rubber? 13 A. I don't know the process enough to know. 14 Q. Okay. Roman Numeral II, "Further sale and 15 delivery of PCBs and dielectric fluids for transformers 16 and capacitors will be made in conformance with certain 17 restrictive policies adopted by Monsanto management. 18 Sales of PCB dielectric fluids in the U.S. were 19 terminated on January 15th of 1972 except to approved 20 customers who satisfy Monsanto's special requirements." 21 Certified by T. L. Gossage. Do you see that? 22 A. I do. 23 Q. Were the sales of PCB dielectric fluids 24 terminated on January 15th, 1972 except for customers 25 who satisfied Monsanto 's special requirements? Gateway Reporting Associates, Inc. WATER PCB-SD0000071267 Gateway Reporting Associates, Inc. 323 1 A. That is correct. 2 Q. What were Monsanto's special requirements? 3 A. I don ' t remember all of the details, but 4 the requirements included understanding of the proper 5 ways to handle PCBs, an understanding of the impact they 6 could have on the environment, if mishandled, and a 7 phrase there which implied that if there is any problem 8 that the user of PCBs will be the entity responsible for 9 any harm that might result. ' 10 Q. Do you know why that requirement was 11 necessary? 12 MR. SABETTA: Objection to form. 13 Q. Do you know why the latter requirement, 14 that whoever purchased the PCBs was going to be 15 responsible for them, was employed? 16 A. Again, I have to share with you my 17 understanding as explained to me. The understanding is 18 to arrive at a position where an individual in the 19 customer's organization at a very high level in that 20 organization would sign an agreement of this kind with 21 the intent to get the right level of attention by the 22 customer's organization regarding the proper use of PCBs 23 and the availability of any resources needed by the 24 facility to handle them properly. 25 Q. And as part of that, if, in fact, they Gateway Reporting Associates, Inc. WATER PCB-SD0000071268 Gateway Reporting Associates, Inc 324 1 didn't handle them properly, if damages occurred as a 2 result of that, the customer was responsible and not 3 Monsanto; is that correct? 4 A. Yes. That's what he signed off on. 5 Q. Who explained this to you? 6 A. John Stapleton. 7 Q. John Stapleton would be an attorney 8 in-house for Monsanto? . 9 A. Yes. ' 10 Q. Was he the head of the in-house attorneys 11 for Monsanto? Do you know? 12 A. The head, no. 13 Q. Do you know who the head was in 1970, 1971? 14 A. I can't remember his name right now. 15 Q. Tom without a last name was one of the 16 attorneys you remembered earlier. Do you happen to 17 recall that last name now? 18 A. I can't recall his name either. I just 19 cannot recall the corporate attorney. 20 Q. How many attorneys did Monsanto have in 21 1970 about? Do you know? 22 A. About? A couple dozen. 23 Q. Do you know if you had any trouble with one 24 car funerals at about that time? 25 A. I'm sorry? Gateway Reporting Associates, Inc. WATER PCB-SD0000071269 Gateway Reporting Associates, Inc. 325 1 Q. I withdraw it. Looking at Exhibit 422, the 2 first page, item three, says, "Discontinue all sales of 3 PCT's, polychlorinated terphenyls, no later than June 4 30th, 1972." Do you see that? 5 A. I do. 6 Q. What are polychlorinated terphenyls? Let 7 me ask you another question. Are polychlorinated 8 terphenyls Aroclors? 9 A, Yes. The trademark applied to them as 10 well 11 Q. Are they PCB - 12 A. No . 13 Q. -- containing materials? 14 A. No. 15 Q. Why were sales with respect to 16 polychlorinated terphenyls discontinued? Do you know? 17 A. I don't know. 18 Q. Was it because of the effect on the 19 environment that was claimed? 20 MR. SABETTA: Objection to form. 21 . A. There was no such information available. 22 Q. You didn't know of any such information; is 23 that correct? 24 A. That's true. 25 Q. If you look at the fourth page in on Gateway Reporting Associates, Inc. WATER PCB-SD0000071270 Gateway Reporting Associates, Inc. 326 1 Exhibit 422, it purports to be one-page correspondence 2 on Monsanto letterhead to "Dear Sir" without the 3 addressee. Apparently the second page, which might have 4 a signature on it, is deleted from this exhibit. I 5 don't know if it is from yours or not. Is there a 6 second page to your letter? 7 MR. SABETTA: No, there's not. 8 Q. Have you seen the first page of that letter 9 before? ' 10 A. Yes . 11 Q. Did you participate in its preparation? 12 A. No. ' 13 Q. Who did? Do you know? 14 A. I do not. 15 Q. There doesn't appear to be a date on this 16 particular document, the one page anyway. Do you know 17 about when that letter was prepared? 18 A. Late 1971, early 1972. 19 Q. Did it come out of the Legal Department of 20 Monsanto? 21 . A. I do not know. 22 Q. The next page, and it's a two-page 23 document, is entitled "Special Undertaking By Purchasers 24 of Polychlorinated Biphenyls". Have you seen that 25 document before? Gateway Reporting Associates, Inc. WATER PCB-SD0000071271 Gateway Reporting Associates, Inc. 327 1 A. Yes, I have. 2 Q. Did you participate in its preparation? 3 A. No . 4 Q. And then after that two pages there appears 5 to be an article entitled "PCBs Prevalent and 6 Persistent" by Carl, with a C, Gustafson. I'll spell 7 it. G-U-S-T-A-F-S-O-N. Federal Water Quality 8 Administration, Athens, Georgia. Had you seen that 9 article before? ' 10 A. Yes, I have. 11 Q. Do you know whether that article was sent 12 to Monsanto's customers? 13 A. Yes. 14 Q. Do you know about when it was sent? 15 A. I just don't recall. 16 Q. Okay. Can we look at tab 42, please? I 17 believe we placed a tag on that. Can you give me the 18 number? 19 A. 423. 20 Q. We've marked as Exhibit 423 a series of 21 documents headed with a letter dated February 4 of 1972 22 on Monsanto letterhead from a Howard Bergen, Director of 23 Specialty Products Group, Monsanto Industrial Chemicals 24 Co. to addressees who are not indicated on the first 25 page of the letter. Have you seen that letter before? Gateway Reporting Associates, Inc. WATER PCB-SD0000071272 Gateway Reporting Associates, Inc. 328 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes, sir. Q. Was that a letter prepared to be sent to customers of Monsanto? A. Yes . Q. Did you participate in the preparation of that? A. No . Q- Do you know who did? A. No. ' Q. Do you know whether that letter was sent to anyone other than Monsanto's direct customers? A. It was sent only to direct customers. Q. Do you know whether Monsanto issued any press releases with respect to the material contained in this document? A. I don't recall apress release. Q. Now, that Exhibit 423also includes a two-page "Special Undertaking By Purchasers of Polychlorinated Biphenyls" that was part of the last exhibit, and the same article by Mr. Gustafson as the last exhibit; is that correct? A. That is correct. Q. Would you turn to tab 43 for me, please? What exhibit tag is that? A. 424. Gateway Reporting Associates, Inc. WATER PCB-SD0000071273 Gateway Reporting Associates, Inc. 329 1 Q. I'm showing you Exhibit 424 for 2 identification, which is a three-page letter from T. 3 Katayama, K-A-T-A-Y-A-M-A, Mitsubishi Monsanto Chemical 4 Company, M-I-T-S-U-B-I-S-H-I, Tokyo, March 22nd, 1972 on 5 the subject of PCB in Japan. Have you seen that 6 document before? 7 A. Yes. 8 Q. You're purported to be copied on that 9 document; is that correct? ' 10 A. That is correct. 11 Q. Did you get it at about that time? 12 A. Yes. ' 13 Q. Now, it's directed to Mr. P. G. Benignus 14 (pronouncing Ben-ing-gus); is that correct? 15 A. I'm sorry? 16 Q. It's sent to Mr. Benignus (pronouncing 17 Ben-ing-gus); is that correct? 18 A. Oh, Benignus (pronouncing Ben-ig-nus). I'm 19 sorry. 20 Q. It's also noted copy goesto a Mr. Corey, 21 Mr. Berger, a Mr. Patton and Mr.Gossage in St. Louis, 22 and W. R. Richard and Mr. Munch in St. Louis as well as 23 yourself; is that correct? 24 A. That is correct. 25 Q. Had Mr. Corey taken over the project from Gateway Reporting Associates, Inc. WATER PCB-SD0000071274 Gateway Reporting Associates, Inc. 330 1 some other employee of Monsanto that left the company or 2 retired or was reassigned? 3 A. It wasn't exactly taking over an 4 assignment. There was a reorganization in Monsanto, and 5 Mr. Corey was assigned the -- I forget the title of the 6 assignment, but it had to do with administrative 7 matters, which included environmental affairs. 8 .Q. Did Mr. Bergen and Mr. Springgate continue 9 to be involved in this PCB matter at about this time or 10 after this time? 11 A. Mr. Bergen was still involved, and he's 12 listed here. There's a misspelling there, but that's 13 who that is. 14 Q. Oh, you were referring to something that 15 says H. S. Berber? That's supposed to be Mr. Bergen? 16 A. Correct. Mr. Springgate's group as a group 17 was no longer involved, but they are represented by 18 Mr. Paton, who is listed as a recipient of a copy. 19 Q. What area of the company did he work in? 20 A. This was the group that we called the 21 Plasticizer Group. 22 Q. What area did Mr. Gossage work in? 23 A. Gossage was the marketing director for the 24 Functional Fluids Group, and Mr. Bergen was his 25 superior. Gateway Reporting Associates, Inc. WATER PCB-SD0000071275 Gateway Reporting Associates, Inc. 331 1 Q. What about Mr. Munch? Is he a new name? 2 A. That's -- I haven't seen that name in a 3 while. Mr. Munch is a research chemist working for 4 Dr. Richard in the research involved with PCBs and 5 capacitors. 6 Q. Who is Mr. Coleman at Newport? 7 A. At that time, Mr. Coleman was the 8 individua 1 at the Newport, Wales plant responsible for 9 the manuf acture of PCBs. ' 10 Q- Did Monsanto perform testing in Wales with 11 respect t o biodegradability of PCBs? 12 A. Yes . 13 Q. Was that under the supervision of a 14 particula r individual in Wales? 15 A. Yes. I'm trying to recall his name, I ' ve 16 forgotten the name of the individual. 17 Q. Were there any studies conducted by 18 Monsanto as to biomagnification? 19 A. No. 20 Q. Do you know what biomagnification is? 21 . A. I have an understanding. 22 Q. Can you tell me what your understanding is? 23 A. It refers to the increasing presence in 24 terms of amount found in living creatures as the 25 creature is identified belonging to increasing steps in Gateway Reporting Associates, Inc. WATER PCB-SD0000071276 Gateway Reporting Associates, Inc 332 1 the biological chain, such that the creature at the 2 bottom of the chain when consuming some PCBs retained 3 some of the PCBs and as it's consumed by the next level 4 of living creature, that next level exhibits an 5 increasing amount. So as you go up the chain, the food 6 chain, the amount of PCBs found increases. 7 Q. Have you seen estimates of biomagnification 8 with PCBs as high as 200,000? 9 A. I have seen numbers like that quoted, yes. 10 Q. Looking at Exhibit 424, - 11 A. Okay. 12 Q. -- under the first "a", it says, "No 13 electrical machinery and equipment which contains PCB 14 must be manufactured after September 1, 1972." This is 15 with reference to a Ministry of International Trade, an 16 industry notice issued in Japan; is that correct? 17 A. That is correct. 18 Q. Do you know whether these various items set 19 forth this in Exhibit 424 were all adopted as the 20 Japanese government policy with respect to PCBs? 21 . A. I have no information that says they were 22 not. 23 Q, Did you receive a copy of this letter? 24 A. Yes. 25 Q. Did you have any direct dealings with Gateway Reporting Associates, Inc. WATER PCB-SD0000071277 Gateway Reporting Associates, Inc. 333 1 Mr. Katayama? 2 A. No . 3 Q. Was this the joint venture plant that was 4 referred to yesterday to make PCBs in Japan? 5 A. Yes. 6 Q. The last page of that letter, the fourth 7 paragraph down says, "The grand funeral of PCB in Japan 8 is close at hand. What will replace PCB in the 9 dielectric markets is yet known to nobody exactly. We 10 only are aware of a number of products ranging from 11 silicone to polyisobutane, P-O-L-Y-S-O-B-U-T-A-N-E, wax 12 and DOP are competing. The strongest candidate on the 13 longer term basis seems to me entirely new systems after 14 technological innovation." 15 A. Yes. 16 Q. Did PCBget a grandfuneral in Japan that 17 you know of? 18 MR. SABETTA: Objection to the form. 19 A. That's my understanding. 20 Q. Do you know what product or number of 21 products was used to replace PCB? 22 A . I do not. 23 Q. Do you know what product or products was 24 used to replace PCBs in the United States? 25 MR. SABETTA: Objection to form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071278 Gateway Reporting Associates, Inc. 334 1 A. I do not . 2 Q. Were you involved in any research or work 3 to develop replacement products? 4 A. Well, I was prodding the research 5 department to encourage and help out wherever I could in 6 terms of getting support from upper management to 7 provide funds or people or whatever it takes to do the 8 studies, so my involvement was of that type. 9 Q. When Monsanto stopped manufacturing PCBs, 10 were replacement products used by the transformer 11 manufacturers? 12 A. Certainly, yes. 13 Q. And I think you told me you don't know what 14 replacement product was used? 15 A. That is correct. 16 Q. Would that be the same answer that you 17 don't know what replacement product was used in 18 capacitors? 19 A. Yes. 20 Q. Would you look at tab 44 for me, please? 21 . MR. MCDONOUGH: Off the record. 22 (Whereupon, there was an off-the-record 23 discussion) 24 Q. We've turned to tab 45, which we've marked 25 Exhibit 425; is that correct? Gateway Reporting Associates, Inc. WATER PCB-SD0000071279 Gateway Reporting Associates, Inc. 335 1 A. Yes. 2 Q. And Exhibit 425 -- Withdrawn. What is 3 Exhibit 425? 4 A. It 1s a collection of pages of information 5 which are minutes of a PCB Effluent Standards Meeting 6 held in February -- on February 28th, 1974. 7 Q. Where was - 8 A. And attended by a dozen or so people from 9 different users of PCBs and from associations' 10 representing electrical manufacturers. 11 Q. Was the General Electric Company 12 represented at that meeting? 13 A. Yes. 14 Q. It appears Mr. James Nelson, Mr. Stuart, 15 S-T-U-A-R-T, Richel, R-I-C-H-E-L - 16 A. Uh-huh. 17 Q. -- and Dr. Edward L. Simons, S-I-M-O-N-S, 18 were present; is that correct? 19 A. Yes. 20 Q. Did you knowany of those individuals prior 21 to that meeting? . 22 A. Now that I see their names, I do. I 23 remember a little bit about each one. 24 Q. What did Dr. Simons do for General 25 Electric? Gateway Reporting Associates, Inc. WATER PCB-SD0000071280 Gateway Reporting Associates, Inc. 336 1 A. I don't remember that kind of detail. 2 Q. Had you seen papers prepared by Dr. Simons? 3 A. I don't remember. 4 Q. What about Mr. Nelson? Do you know what he 5 did for General Electric? 6 A. No, I don't remember. 7 Q. What about Mr. Richel? Do you know what he 8 did? 9 A. If my memory is correct, Richel was an 10 attorney by training, and he became quite active in 11 representing the PCB activity as observed within GE and 12 communicating to the rest of the world, so to speak. 13 Q. Did you attend any other meetings with 14 Mr. Richel? 15 A. Well, I remember one at the University of 16 Wisconsin in Madison. 17 Q. What was the topic of that meeting? 18 A. Of course, PCBs was the main subject, and 19 it had to do, as best I remember, with the Great Lakes 20 and PCBs. 21 Q. It pertained to PCB levels in the fish in 22 the Great Lakes? 23 A. That was one of the subjects. Just the 24 lakes and PCBs and anything that was perceived to be 25 related to that. Gateway Reporting Associates, Inc. WATER PCB-SD0000071281 Gateway Reporting Associates, Inc. 337 1 Q. Was the State of Wisconsin proposing water 2 level standards with respect to PCBs? 3 A. I don't recall if that was part of the 4 topic of the meeting I had in mind. 5 Q. Was the State of Michigan proposing water 6 level standards for PCBs at about that time? 7 A. I don't remember that. 8 (Whereupon, there was an off-the-record 9 discussion) ' 10 Q. Do you know which of the three individuals 11 was most knowledgeable on PCBs? 12 MR. SABETTA: Objection to the form. 13 Q. I'll withdraw it. Did the three 14 individuals talk at the meeting? 15 A. I don't remember that detail, no. 16 Q. Who prepared these minutes or these pages, 17 I should say? 18 A. Well, I do not remember. 19 Q. Now, the first page of 425 indicates that 20 you chaired the meeting and that you were Manager of 21 Product Acceptability for Monsanto; is that correct? 22 That's what it says? 23 A. I'm sorry. I don't find that reference. 24 Q. Turn back to the first page in the tab, 25 please. Gateway Reporting Associates, Inc. WATER PCB-SD0000071282 Gateway Reporting Associates, Inc. 338 1 A. Oh! That's what it indicates, yes. 2 Q. Were you dealing with any other product 3 than PCBs at that time, February 28th, 1974? 4 A. Yes. ' 5 Q. What other products? 6 A. I can't remember them all. 7 Q. Was there more than two or three other 8 products? 9 A. Oh, yes. About a dozen. ' 10 Q. Okay. That's sufficient for my purposes if 11 counsel has no objections. Now, the objective of the 12 meeting is set forth here on Exhibit 25, the first page. 13 Did you prepare that objective? 14 A. I am the one that prepared the paragraph, 15 but the thought is a combination of many of the 16 participants that I talked to over the telephone to come 17 up with the description of the objective. 18 Q. Was there an agenda for this meeting? 19 A. I don't recall one. 20 Q. Do you recall anything prior to the meeting 21 actually taking place other than this first page? I'll 22 withdraw that. Do you recall whether anything was 23 circulated to the participants in the meeting prior to 24 it beginning? 25 A. I think I recall a sort of an invitation Gateway Reporting Associates, Inc. WATER PCB-SD0000071283 Gateway Reporting Associates, Inc. 339 1 letter announcing the date, the place, and the subject 2 matter. 3 Q. Had the EPA proposed modification of the 4 PCB Effluent Standards prior to this meeting? 5 A. Yes, they had. 6 Q. Do you know what standards the EPA 7 proposed? 8 A. I keep thinking of a number like two parts 9 per billion in water. ' 10 Q. Do you know what ultimately the Effluent 11 Standard was set in terms of that proposed modification 12 by the EPA? ' 13 A. I don't recall. 14 Q. Now, the third page in of Exhibit 425 15 purports to be minutes of the PCB Effluent Standards 16 Meeting. I may have already asked you, but I've 17 forgotten if I asked you who kept the minutes, who 18 actually took the minutes of this meeting. 19 A. I don't recall who it was. 20 Q. Was a tape of that meeting made? 21 . A. No. 22 Q. Was there aword-for-wordtranscript made 23 of that meeting? 24 A. No. 25 Q. Would you turn to tab 46 for me, please? Gateway Reporting Associates, Inc. WATER PCB-SD0000071284 Gateway Reporting Associates, Inc. 340 1 I'm sorry. Can we go back to 45, please? Tab 45, 2 Exhibit 425. 3 A. I have it. 4 Q. Did Paul Wright attend that meeting? 5 A. I don't think so. No. 6 Q. Page four refers to a Mr. Wright from 7 Monsanto. I'm asking whether that's a reference to 8 Dr. Paul L. Wright. 9 A. I don't associate the items discussed on 10 that page referring to effluent load of PCBs and 11 biomagnification -- I just don't associate that with 12 Mr. Wright. 13 Q. Did you know Dr. Wright? 14 A. Yes . 15 Q. Who was Dr. Wright? 16 A. Dr. Wright was a toxicologist. 17 Q. At some time was he head of toxicology for 18 Monsanto? 19 A. No . 20 Q. Did he work as a toxicologist for Monsanto? 21 A. Yes . 22 Q. Do you know what periods of time he worked 23 for Monsanto as a toxicologist? 24 A. The middle '70's is as close as I can get. 25 Q. Do you recall whether Dr. Wright worked for Gateway Reporting Associates, Inc. WATER PCB-SD0000071285 REPORTING ASSOCIATES PHONE NO. : 3142415565 Jun. 03 1999 02:17PM P2 Gateway Reporting Associates, Inc. 341 1 Monsanto as a toxicologist -- I'll withdraw it. Do you 2 recall if during a period of time Dr. Wright worked as a 3 toxicologist for Industrial Bio-Test? 4 A. I was told that he used to work for 5 Industrial Bio-Test. 6 Q. Were you told that he used to work for 1 Monsanto before he went to work for Industrial Bio-Test? 8 A. Yes. 9 Q. Were you told after he finished work for 10 Industrial Bio-Test he went back to work for Monsanto as 11 a toxicologist? 12 A. Yes. 13 Q. If you look at page seven of that Exhibit 14 425 it references Dr. Wright speaking and. talks about 15 biomagnification factors, things of that sort, including 16 shrimp. Do you associate those kind of statements with 17 Dr. Paul Wright? 18 A. Yes, I do. 19 q. Doesthat refresh yourrecollection that he 20 was in attendance at that meeting? 21 A- The report heredoesindicate that, but I 22 still have trouble remembering his presence. 23 Q. Were you told that Dr. Wright was indicted 24 and convicted for falsifying Industrial Bio-Test's 25 studies for Monsanto and submitting them to government Gateway Reporting Associates, Inc. WATER PCB-SD0000071286 Gateway Reporting Associates, Inc. 342 1 agencies? 2 MR. SABETTA: Objection to form. 3 A. I was left with an impression that 4 Dr. Wright was involved in some Industrial Bio-Test 5 reporting that was described as being improper. I don't 6 know any more than that. 7 Q. You don't know that he was indicted and 8 convicted in a federal criminal trial that ran for 9 months? 10 A. I read that in the local newspaper. 11 Q. Did you know that Mr. Calandra was 12 indicted? 13 A. I also read that in the local newspaper. 14 Q. Who was Mr. Calandra? 15 A. He was the principal individual with 16 Industrial Bio-Test Laboratories. 17 Q. Did you read in the local newspaper that 18 other individuals in Industrial Bio-Test.were indicted 19 and convicted for falsifying studies of materials that 20 were submitted to the federal government? 21 A. I recall other names included. 22 Q. Do you know whether Monsanto paid for 23 Dr. Wright'1 s legal bills in defending his criminal 24 charges? 25 A. Somehow I'm aware of that, but I don't Gateway Reporting Associates, Inc. WATER PCB-SD0000071287 REPORTING PSSOCIPTES PHONE NO. : 31424155G5 Jun. 03 1999 10:40014 P3 Gateway Reporting Associates, Inc. 343 1 recall how I knew that. 2 Q. Do you know whether Monsanto paid the legal 3 bills for Mr. Calandra with respect to that indictment? 4 A, I know nothing of that. 5 Q. What about any other employees of 6 Industrial Bio-Test? Do you know whether Monsanto paid 7 the expenses of their legal bills for federal 8 indictment ? 9 A. I've heard nothing on that. 10 Q. Would you turn to the next tab that we've 11 put an exhibit number, please? 12 A. 426, tab 46. 13 MR. McDONOUGH: Off the record, 14 (Whereupon, there was an off-the-record 15 discussion) 16 Q. I'm showing you Exhibit 426 for 17 identification, which purports to be a letter from 18 yourself dated March 18th, 1975 to Dan Albert, Staff 19 Supervisor, Personal Relations, Westinghouse, which 20 purports to attach responses to questions listed in your 21 letter dated February 3rd, 1975. Is that a letter that 22 you prepared? 23 A. Well, the letter in its entirety consists 24 of four pages. I prepared the first page. 25 Q. The next page starts out at the top with a Gateway Reporting Associates, Inc. WATER PCB-SD0000071288 Gateway Reporting Associates, Inc. 344 1 number one and a question. "Does Inerteen have 2 permanent effects on the human body? If so, what type 3 of permanent damage, and how long a period of time does 4 it take for this to develop? If not, explain why, if 5 possible." That's the next page. 6 A. Yes. . 7 Q. And then it has two additional pages with 8 questions and responses; is that correct? 9 A. Yes. ' 10 Q. Did you participate in thepreparation of 11 those three pages of questions and responses? 12 A. No. ' 13 Q. Who did? 14 A. Elmer Wheeler. 15 Q. Did Dr. Kelly? 16 A. I don't believe Dr. Kelly did that. 17 Q. Do you recall when Dr. Kelly left the 18 company? 19 A. About 1972. 20 Q. Do you know whether Dr. Kelly continued to 21 do any consulting work on behalf of Monsanto after he 22 left the company? 23 A. Not to my knowledge. 24 Q. Does the year 1974 refresh your 25 recollection as to when Dr. Kelly left the company? Gateway Reporting Associates, Inc. WATER PCB-SD0000071289 Gateway Reporting Associates, Inc. 345 1 MR. SABETTA: Objection to form. 2 A. No, it doesn't. 3 Q. These three pages of questions and answers 4 were sent out along with your response to Mr. Albert; is 5 that correct? 6 A. Yes. 7 Q. Did you read them at the time ~- 8 A. Yes. 9 Q. -- that you prepared theletter? Did you 10 agree with the responses? 11 A. Yes. 12 Q. Look at tab 47 for me,please. Have we ` 13 placed a deposition exhibit number on it? 14 A. 427. 15 Q. Exhibit 427 purports to becorrespondence 16 from J. C. Calandra, C-A-L-A-N-D-R-A, President of 17 Industrial Bio-Test, dated April 18th, 1975 to 18 Dr. George Roush, R-O-U-S-H, Jr., Monsanto Company, and 19 includes a several page enclosure entitled "Review of 20 PCB Meeting"; is that correct? 21 . A. Yes. 22 Q. This letter purports to be sent toyourself 23 and George'Lavinskas, L-A-V-I-N-S-K-A-S, and 24 Mr. Wheeler; is that correct? 25 A. Yes. Gateway Reporting Associates, Inc. WATER PCB-SD0000071290 Gateway Reporting Associates, Inc. 346 1 Q. Did you get this? 2 A. Yes. 3 Q. Did you attend a meeting with Mr. Calandra? 4 A. Yes. 5 Q. Was that meeting on April 18th, 1975? 6 A. Yes. 7 Q. Were any minutes of that meeting kept by 8 Monsanto? 9 A. Not to my knowledge. ' 10 Q. Did you take anynotes of thatmeeting? 11 A. No.. 12 Q. Did you seeanybody else take any notes of 13 that meeting? 14 A. No . 15 Q. The first sentence says, "I fully 16 appreciate that the meeting on PCBs today was not 17 completely satisfactory and that many nagging questions 18 remain." Did you agree that the meeting was not 19 completely satisfactory? 20 A. Yes. 21 . Q. In what regard did you feel the meeting was 22 unsatisfactory? 23 A. The reports from two studies involving rats 24 and PCBs ended up with two conclusions that did not 25 agree on the interpretation of the observations, so I as Gateway Reporting Associates, Inc. WATER PCB-SD0000071291 Gateway Reporting Associates, Inc. 347 1 an individual left the meeting frustrated, and I walked 2 out of the meeting with the feeling that this was a 3 professional disagreement between pathologists. 4 Q. Who were the pathologists who were 5 professionally disagreeing? 6 A. I forget the exact terminology, but it had 7 to do with observation of specimens taken from the test 8 animals' livers and whether or not what they observed 9 was precancerous or -- I forget all the medical terms, 10 but there was a difference in the interpretation of the 11 microscopic observations. 12 Q. Now, you mentioned the word pathologists. 13 What is a pathologist? 14 A. He's a professional in the medical field 15 who specializes in cell -- cell formation and organs 16 that developed from the proliferation of cells. 17 Q. Is such a person a medical doctor? 18 A. I believe they are listed as medical 19 people, yes. 20 Q. Do you understand a toxicologist to be 21 different than a pathologist? 22 A. Yes. 23 Q. Was there any pathologist at this meeting 24 from Monsanto or who was in Monsanto's employ? 25 A. As I remember, Dr. Calandra brought along Gateway Reporting Associates, Inc. WATER PCB-SD0000071292 Gateway Reporting Associates, Inc. 348 1 his pathologist, but my memory is not crystal clear on 2 that . 3 Q. You mentioned Dr. Calandra. What's 4 Dr. Calandra's training? Do you know? 5 A. Medical doctor is all I know. 6 Q. Did you know he was a medical doctor? 7 A. Yes. 8 Q. Was he also a toxicologist? 9 A. That I don't know. ` 10 Q. Were there any other pathologists at this 11 meeting other than this man you can't remember his name? 12 A. There was the pathologist that worked for 13 Dr. Renate Kimbrough. Oh, Dr. Squire was his name. 14 Q. Was Dr. Squire a medical doctor? 15 A. Pathologist. 16 Q. Why was Dr. Squire present? 17 A. He was the one that interpreted the 18 pathology review from Dr. Renate Kimbrough's work. 19 Q. Who is Dr. Renate Kimbrough? 20 A. As I understand it, she was interested in 21 toxicology and was in Atlanta, Georgia with the Center 22 for Disease Control, and at some point in time she 23 transferred to the Food and Drug Administration office 24 in Atlanta. I don't remember what year that was. 25 Q. Is your information based on what you were Gateway Reporting Associates, Inc. WATER PCB-SD0000071293 Gateway Reporting Associates, Inc. 349 1 told? 2 A. Yes. 3 Q. Did you ever meet with Dr. Kimbrough? 4 A. Yes. 5 Q. Do you know whether Dr.Kimbrough is a 6 medical doctor? 7 A. I wasnever left with that impression. 8' Q. Could I interpret that answer to mean you 9 don't know? ' 10 A. That's true. 11 Q. Do you know whether Dr. Kimbrough was a 12 pathologist ? 13 A. She was not a pathologist. 14 Q. Do you know whether she was atoxicologist? 15 A. That's what I suspected all along. It was 16 never brought out in discussion. 17 Q. Do you know that Dr. Kimbrough did a study 18 in 1972 in which she said, in substance, that PCBs 19 caused cancer in the liver of rats? 20 MR. SABETTA: Objection to form. 21 MR. GRONDAHL: Objection. 22 A. I'm aware of that, yes. 23 Q. ' At some time do you know whether 24 Dr. Kimbrough had her work supported by Monsanto? 25 A. Not -- Never. Gateway Reporting Associates, Inc. WATER PCB-SD0000071294 Gateway Reporting Associates, Inc. 350 1 Q. You say never. How do you know that? 2 A. I believe in the position I was in I would 3 have known almost immediately 4 Q. You referenced the position you were in up 5 until 1976? Is that what you're referring to? 6 A. Yes . 7 Q. Who paid -- Let me withdraw that. Was 8 Dr. Squires' participation in this meeting in April of 9 1975 -- Withdraw it. I forgot what my question was. 10 Was Dr. Squire paid for his attendance at this meeting 11 in April of 1975? 12 A. I do not know. 13 Q. Do you know how it came about that he 14 appeared at the meeting? 15 A. He was brought along by Dr. Kimbrough. 16 Q. Do you know why Dr. Kimbrough appeared at 17 the meeting? 18 A. As I understand it, she contacted 19 Mr. Wheeler to report to him over the telephone some 20 preliminary information regarding a recent study she had 2 1 completed and in a way asked for an audience with 22 Monsanto people. 23 Q. Was there any written documents pertaining 24 to this attendance at the meeting or communication with 25 Mr. Wheeler or an agenda for this meeting? Gateway Reporting Associates, Inc WATER PCB-SD0000071295 Gateway Reporting Associates, Inc. 351 1 A. No . 2 Q. Who arranged the meeting? 3 A. Elmer Wheeler. 4 Q. With respect to Industrial Bio-Test's work 5 that led up to this meeting, were sections from livers 6 taken by Industrial Bio-Test and sent to Monsanto? 7 A. I'm confused by your reference. The study 8 by Bio-Test led to this meeting? 9 Q. Withdrawn. You mentioned that an 10 Industrial Bio-Test pathologist came to this meeting. 11 How do you know this was Industrial Bio-Test's 12 pathologist? 13 A. Because I met the people. Dr. Gordon. 14 Q. Did Monsanto have a pathologist? 15 A. Did Monsanto employ a pathologist? 16 Q. We'll startthere. 17 A. No. 18 Q. DidMonsanto employ as a consultant a 19 pathologist about this time? 20 A. No. 21 . Q. There seems to be indications in the record 22 and I'll represent to you that tissue samples were taken 23 by Industrial Bio-Test and sent to Monsanto. Do you 24 know why? 25 MR. SABETTA: Object to the form. Gateway Reporting Associates, Inc. WATER PCB-SD0000071296 Gateway Reporting Associates, Inc. 352 1 A. I know of Monsanto's sending samples to the 2 Food and Drug Administration. 3 Q. No. I'm referring to tissue samples taken 4 by Industrial Bio-Test in the course of animal studies 5 and sent to Monsanto. Do you have any knowledge on that 6 particular subject? 7 A. The only knowledge I know is that samples 8 of the type you're describing went from Monsanto to the 9 Food and Drug Administration for the review by their 10 pathologists. 11 Q. When did that occur? 12 A. Oh, '73 or '74. ' 13 Q. This next paragraph in the letter, 427, 14 says, "Please let me know of any action that you 15 contemplate in the way of seeking additional assistance 16 in pathology or in contacting federal agencies. We will 17 be pleased to be of help in any way that you may wish." 18 Do you see that? 19 A. Yes. 20 Q. Do you know whether Monsanto sought 21 additional assistance in pathology after this letter of 22 April 18th, 1975? ' 23 MR. SABETTA: Objection to form. 24 A. Monsanto did think of discussing this w: 25 federal agencies, and I recall joining Dr. Calandra Gateway Reporting Associates, Inc. WATER PCB-SD0000071297 Gateway Reporting Associates, Inc. 353 1 Elmer Wheeler, and I forget who else. We made a trip to 2 the Washington area and called on the Food and Drug 3 Administration people and some other federal agencies. 4 I've forgotten which ones they were now. 5 Q. Would you turn to tab 48 for me, please? 6 What exhibit number do we have on that? 7 A. 428. 8 Q. You have in front of you Exhibit 428 for 9 identification. It purports to be a July 18th., 1975 10 letter from George J. Lavinskas, L-A-V-I-N-S-K-A-S, 11 Ph.D., Manager, Environmental Assessment and Toxicology, 12 with a copy to Dr. George Roush, R-O-U-S-H, to Dr. J. C. 13 Calandra at Industrial Bio-Test regarding Aroclor two 14 year rat feeding studies. Do you have that exhibit in 15 front of you? 16 A. Yes . 17 Q. Have you seen it before? 18 A. Yes . 19 Q. In the second paragraph -- Withdraw it 20 The first paragraph purports to attach a table 21 summarizing comparisons of three revised Aroclor 22 reports, 1242, 1254 and 1260. 1242 is circled for some 23 reason, and then the next paragraph says, "In two 24 instances, the previous conclusion of 'slightly 25 tumorigenic' was changed to 'does not appear to be Gateway Reporting Associates, Inc. WATER PCB-SD0000071298 REPORTING ASSOCIATES PHONE NO. : 3142415565 Jun. 03 1999 10:41AM P4 Gateway Reporting Associates, Inc. 354 1 carcinogenic'. The latter phrase is preferable. May we 2 request that the Aroclor 1254 report be amended to say 3 'does not appear to be carcinogenic'?" It says that; is 4 that correct? . 5 A. Yes. 6 Q. Was thereport amended in that fashion? 7 A. Yes. 8 Q. The nextparagraphsays, "The number of 9 hepatomas reported for Aroclors 1260 and 1242 have been 10 interchanged. This appears to have arisen from 11 confusion regarding the numbering of the animals. The 12 original report shows tumors in animals with numbers in 13 the 100 to 300 range with Aroclor 1260 and in the 500 to 14 800 range with Aroclor 1242. This leads me to conclude 15 that the numbering scheme shown in the second Set of 16 reports is correct. With Aroclor 1254 confusion is 17 compounded. The original report shows tumors in animals 18 with numbers in the units to teens, but the revised 19 reports show animal numbers ranging from 40 to 1,000. 20 Can this be straightened out?" Do you know whether that 21 topic was straightened out? 22 A. Yes, it was. 23 Q, The next paragraph goes on to say, "I was 24 unable to reconcile the differences in the animal 25 numbers between the first supplemental report and the Gateway Reporting Associates, Inc. WATER PCB-SD0000071299 REPORTING RSSOCIRTES PHONE NO. : 3142415565 Jun. 03 1999 10:41RM P5 Gateway Reporting Associates, Inc 3 55 1 original reports. I had inquired as to the changes in 2 the numbers. As I recall, I was told that the sections 3 had been renumbered when the new slides were made and 4 that a key relating to the sets of numbers would be 5 supplied. This has not been done. It may not be 6 necessary for Aroclors 1260 and 1242, but Aroclor 1254 7 remains unresolved. Insofar as I can see, the remainder B of the reports appear acceptable." Do you know if those 3 matters were straightened out? 10 MR. SABETTA: Object to the form. 11 Q. Withdrawn. 12 A. As far as -- ... 13 Q. Do you know if further changes were made in 14 the reports by Industrial Bio-Test along the lines 15 covered in this particular letter? 16 A. They were. 17 Q. As part of Exhibit 428, there appears to be 18 a letter from J, C. Calandra to Dr. Lavinskas, August 19 4th, 1975. Is that correct? It's part of the exhibit? 20 A. Yes. 21 Q. Had you seen that letter before? 22 A. Yes. 23 Q. Would you turn to tab 50 for me, please? 24 MR. GRONDAHL: When you get to a good spot, 25 I could use a five-minute break. Gateway Reporting Associates, Inc. WATER PCB-SD0000071300 Gateway Reporting Associates, Inc. 356 1 MR. MCDONOUGH: Okay. Go ahead. 2 (Whereupon, there was a brief recess.) 3 Q. I'm showing youExhibit 429 for 4 identification. It purports to be a document with a 5 date stamp of October 17th, 1975, from the United States 6 Environmental Protection Agency, Stanley W. Legro, 7 L-E-G-R-O, Assistant Administrator for Enforcement, to 8 Monsanto Industrial Chemical Company and ask if you've 9 seen that document before. ' 10 A. Yes, I have. 11 Q. Now, the first two pages appear to be a 12 letter. The next series of pages appear to be questions 13 that Monsanto is requested to answer; is that correct? 14 A. That is correct. 15 Q. Did you participate in -- Withdraw that. 16 Did you see that document at about the time, October 17 17th, 1975? 18 A. Yes . 19 Q. Didyou participate inMonsanto's response 20 to that document? 21 . A. Yes. 22 Q. Who else participated in the response? 23 A. I'm trying to recall the name of the 24 accounting individual who provided the numbers that are 25 shown as being shared with EPA. Mr. David Wood was the Gateway Reporting Associates, Inc. WATER PCB-SD0000071301 Gateway Reporting Associates, Inc. 357 1 key person to sort of edit the thing and put it all 2 together to respond to the sections of the EPA request, 3 and then there were individuals in manufacturing. I 4 think at that time James Savage reviewed the numbers to 5 see that they were accurate to the best of his knowledge 6 in terms of the products produced at the two plants that 7 he was overall supervisor. 8 Q. Under question ten. on page four of the 9 questions enclosed along with 429 is a question of a 10 description of any adverse health or environmental 11 effects which you know or believe to have, resulted from 12 the introduction of PCB compounds or mixtures into the 13 environment. Indicate any specific occasions, including 14 dates, times, locations, amounts and parties involved 15 for which such effects are known. Do you see that 16 question? 17 A. Yes. 18 Q. Do youknow whether thatquestion was 19 assigned to any particular individual to answer? 20 A. I know it was assigned to the Corporate 21 Medical Department, but I do not know whether it was 22 Mr. Wheeler or Dr. Lavinskas. 23 Q. Who did the assignment of thesequestions 24 for answer at Monsanto? 25 A. I did. Gateway Reporting Associates, Inc. WATER PCB-SD0000071302 REPORTING ASSOCIATES PHONE NO. : 3142415565 Jun. 03 1999 02:18PM P3 Gateway Reporting Associates, Inc. 358 1 Q. I appreciate that. If you look at tab 51 2 for me, please. 3 A. 430 . 4 Q. We've marked a document as Exhibit 430, 5 which purports to be bear a typed signature David Wood 6 on Monsanto letterhead directed to W. B. Papageorge, 7 October 30th, 1975, reference comments on EPA letter 8 received 10-17. Did you get that document? . 9 A. Did I get that document? 10 Q Yes . 11 A. That was the previous one we talked about. 12 MR. SABETTA: No. He's talking about 430. 13 Q I'm sorry. Did you receive a copy of 430? 14 A. Oh, yes. 15 Q- Now, can you tell me what David Wood's 16 training was? 17 A. He had some sort of degree in chemistry 18 that he obtained as best I recall in England somewhere, 19 and since I don't know their degree designations, I 20 cannot pass it on to you. 21 Q. What particular job did he have at Monsanto 22 at about this time, 1975? 23 A. At this time, he had what was left of the 24 PCB marketing effort in the industrial fluids marketing 25 group, what was left in electrical applications. There Gateway Reporting Associates, Inc. WATER PCB-SD0000071303 Gateway Reporting Associates, Inc. 359 1 wasn't anything left in hydraulic fluids or heat 2 transfer and so on. But he had the residual questions 3 that were still pouring in to answer. 4 Q. Was Mr. Benignus still involved in 5 marketing or in PCBs in 1975? 6 A No. Mr. Benignus had retired in '74. 7 Q Now, if you'll turn to the second page of 8 Exhibit 430, under what's numbered 12, it says "Q-10 - 9 none? Yusho? Chloracne years ago -- dangerous 10 question " Do you see that? 11 A Yes . 12 Q Is that with reference to the tenth 13 question that Monsanto was asked by the ERA? ' 14 A Yes . 15 Q Up to that time, had you become further 16 familiar with the Yusho incident than you had been back 17 in 1970? 18 A. Further familiar in terms of what I kept 19 hearing was consistent, and the reference to the 20 presence of chlorinated furans seemed to be gaining more 21 support by the people commenting. 22 Q Furans were gaining more support in what 23 regard? 24 A. As being the agent or ingredient that 25 caused the effects that were reported. Gateway Reporting Associates, Inc. WATER PCB-SD0000071304 Gateway Reporting Associates, Inc. 360 1 Q. Do you know whether the Monsanto medical 2 library had gathered journal articles and articles with 3 respect to the Yusho incident up through 1975? 4 MR. SABETTA: Objection to form. 5 A. They did gather, but, unfortunately, there 6 weren't too many. 7 Q. Why do you say there weren't too many? 8 A. As I recall, most of them that I saw that I 9 was privileged to see because of my request t'o the 10 medical library to keep me tuned in were not in the form 11 of a scientific paper. They were column articles that 12 appeared in, say, medical journals or chemical journals 13 and environmental journals, and they were repetitive. 14 Q. Do you know if the Monsanto medical library 15 had provisions for gathering journal articles from 16 Japan? 17 A. I don't know thatspecifically. 18 Q. Do you know whether the Monsanto medical 19 library had any provisions for translating of articles 20 from foreign languages into English? 21 . A. I don't know. 22 Q. Do you know whether Monsanto in its 23 Japanese operations translated Japanese articles for the 24 American operation? 25 A. I don't know. Gateway Reporting Associates, Inc. WATER PCB-SD0000071305 Gateway Reporting Associates, Inc. 361 1 Q. These columns you refer to, did Monsanto 2 retain a clipping service with respect to medical 3 articles? 4 A. Yes. 5 Q. What clipping service was that? 6 A. It was a service provided by entities in 7 this business to look for certain subjects in a series 8 of news magazines, newspapers, frequently issued 9 documents or journals. ' 10 Q. Did that clipping service retained by 11 Monsanto engage in reviewing scientific journals as well 12 as newspaper clippings and other materials of that sort? 13 A. Yes. 14 Q. Where was the clippingservice located? 15 A. I don't remember that. 16 Q. You mentioned, I believe, that when you 17 would request an article of the medical library they 18 would provide it to you presumably if they had it? 19 A. Yes. 20 Q. How would it come about that you'd request 21 an article? 22 MR. SABETTA: Objection to form. 23 A. There are several ways. I could go to a 24 meeting and s omeone may mention it, or I could read 25 another artic le and in the footnotes they might refer to Gateway Reporting Associates, Inc. WATER PCB-SD0000071306 Gateway Reporting Associates, Inc. 362 1 still another article. 2 Q. In this 1975 time period, or in the three 3 or four years before it, did you ever request copies of 4 all articles dealing with the Yusho incident from the 5 medical library? 6. A. Yes . 7 Q. And do you know how many articles you were 8 supplied? 9 A. That's what I indicated earlier,' there 10 weren1t many 11 Q. I'm trying to get a better handle than "not 12 many". 13 A. Half a dozen at the most. 14 Q. Do you know the names of any authors? 15 A. No. They were Japanese names that I never 16 memorized. 17 Q. How about Urabi (phonetic)? Does that name 18 ring a bell? 19 A. No . 20 Q. If you turn to the next tab, please, tab 21 52. Is there an exhibit number on that? 22 A. 431 . 23 Q. ` You're looking at Exhibit 431. That 24 purports to be an one-page letter from yourself as 25 Manager of Product Acceptability to Mr. Earl J. Gateway Reporting Associates, Inc WATER PCB-SD0000071307 Gateway Reporting Associates, Inc. 363 1 Stephanson, Director, Enforcement Division, 2 Environmental Protection Agency, dated December 11, 1975 3 enclosing a response to the questionnaire; is that 4 correct ? 5 A. Yes. 6 Q. In the second paragraph of your letter, you 7 say, "To the best of my knowledge and belief, the 8 information, contained in this response represents the 9 best information available to Monsanto." Does it say 10 that ? 11 A. Yes. 12 Q. Was that true? 13 A. Yes. 14 Q. The enclosure purports to be entitled 15 "Polychlorinated Biphenyl (PCB) Compounds or Mixtures"; 16 does it not? 17 A. Yes. 18 Q. That appears to be amulti-page document 19 including various exhibits attached; is that correct? 20 A. Yes. 21 Q. Do you recall how question ten was 22 answered? 23 A. ' Sorry? 24 Q. Do you recall how question ten as to 25 adverse health effects of PCBs was answered? Gateway Reporting Associates, Inc. WATER PCB-SD0000071308 Gateway Reporting Associates, Inc. 364 1 MR. SABETTA: Without looking at the 2 document ? 3 Q. Yes. 4 A. No, I don't. - 5 Q. Well, I'll be damned if I can find it in 6 the document. Do you see an answer to question ten in 7 that document? 8 MR. SABETTA: Note for the record, 9 Mr. McDonough, that at page with Bates number' 4541 it 10 jumps thereafter to -- The next page in the document is 11 4864, obviously demonstrating a gap in the Bates 12 numbers, which suggests to me that some pages have been 13 omitted. . 14 MR. MCDONOUGH: Off the record. 15 (Whereupon, there was an off-the-record 16 discussion) 17 (Mr. McDonough marked Plaintiff's Exhibit 18 432 . ) 19 Q. Moving right along, would you turn to tab 20 53 for me, please? We've marked as Exhibit 432 a 21 document entitled "Mortality of PCB Workers at the 22 Monsanto Plant in Sauget, S-A-U-G-E-T, Illinois," by 23 Judith Zack, Z-A-C-K, David C. Musch, M-U-S-C-H, 24 December 14th, 1979. Have you seen that before? 25 A. It does not look familiar. I don't recall Gateway Reporting Associates, Inc. WATER PCB-SD0000071309 Gateway Reporting Associates, Inc. 365 1 seeing it. 2 Q. What's the exhibit tag on that, please? 3 430? 4 A. 432 . 5 Q. Did you ever hear of any controversy 6 surrounding the methodology employed by Judith A. Zack? 7 MR. SABETTA: Objection to the form. 8 A. I don't recall any. 9 (Mr. McDonough marked Plaintiff's Exhibit 10 433 . ) 11 Q. Would you turn to tab 56 for me, please? 12 We've marked as Exhibit 433 a transcript of testimony 13 given by Phillip S. Smith on September 3rd, 1987. Did 14 you ever hear the name Phillip S. Smith? 15 A. Yes . 16 Q. Who is Phillip S. Smith? 17 A. He was at one time an employee of 18 Industrial Bio-Test Laboratories. 19 Q. Do you know what his position was? 20 A. Not really. 21 . Q. Was Mr. Smith a toxicologist there at 22 Industrial Bio-Test? 23 A. Not to my knowledge. 24 Q. Did you ever have the opportunity to review 25 this testimony as represented in this exhibit? And I'm Gateway Reporting Associates, Inc. WATER PCB-SD0000071310 Gateway Reporting Associates, Inc 366 1 not asking you to do it now. I'm just asking whether 2 you ever had a chance to review it in the past. 3 A. This is the Scott trial? That's what I'm 4 looking for. 5 Q. Yes. 6 A. I was present in the courtroom when he 7 testified. I did not read anything. 8 Q. Did Mr. Smith testify that an Industrial 9 Bio-Test study that had been done on request of Monsanto 10 contained falsified information? 11 MR. SABETTA: Object to the form. 12 A. I recall the insinuation or the implication 13 was in his testimony. I don't know that he used those 14 exact words, though. 15 Q. You call it' an implication or insinuation. 16 Is that your characterization of what Mr. Smith said as 17 to falsification of test results on a study that he had 18 signed? 19 MR. SABETTA: Objection to form. 20 A. See, I'm not aware of him signing any 21 studies. 22 Q. Did you ever go back and look to see if he 23 did sign studies? 24 A. No, I didn't. 25 Q. Do you recall Mr. Smith stating that there Gateway Reporting Associates, Inc. WATER PCB-SD0000071311 Gateway Reporting Associates, Inc. 367 1 were two Industrial Bio-Test studies that purported to 2 bear his signature? 3 A. That I don't remember. 4 Q. Do you recall Mr. Smith testifying that one 5 of those studies did bear his signature? 6 A. I did not remember that. 7 Q. Do you recall Mr. Smith testifying that the 8 other study that purported to bear his signature did not 9 bear his signature and his name on the study was a 10 forgery? 11 A. I don't remember that either. 12 Q. Do you recall him insinuating or implying 13 that? 14 A. No . 15 Q. Did you testify in that Scott trial? 16 A. Yes. 17 Q. Do you recall testimony of Dr. Paul Wright 18 being read at that trial? 19 A. I do not. 20 Q. Do you recall statements and summaries 21 being made at that trial as to Dr. Wright being asked 22 numerous questions on falsification of Aroclor studies 23 and taking the Fifth Amendment as opposed to responding? 24 MR. SABETTA: Objection to the form. 25 A. I do not recall that at all. Gateway Reporting Associates, Inc. WATER PCB-SD0000071312 Gateway Reporting Associates, Inc. 368 1 Q. How long were you at that trial? 2 A. I've forgotten. 3 Q. Did you stay throughout it? 4 A. Throughout it? 5 Q. Throughout the trial. 6 MR. SABETTA: Objection to form. You mean 7 was he present in the courtroom, or was he in the 8 vicinity? 9 Q. Well, I meant were you present in the 10 courtroom during that trial? 11 A. A couple, three days. I didn't keep a 12 record of it, sir. I came and went. 13 Q. Were you there for Mr. Smith's testimony? 14 A. I recall I was there for some of his 15 testimony. I don't know how often he or how long he was 16 in the witness chair. 17 Q. I didn't ask you how long he was there. 18 Were you present during Mr. Smith's testimony. 19 MR. SABETTA: Objection to form. 20 A. For some of it is the best I can tell you, 21 because I don't know how long he was there. 22 Q. Since your counsel has objected to the form 23 of the question, I have to ask some more questions. 24 Were you present during the time that Mr. Smith 25 testified in that trial? Gateway Reporting Associates, Inc. WATER PCB-SD0000071313 Gateway Reporting Associates, Inc. 369 1 MR. SABETTA: Objection to form. I think 2 the confusion is whether he was present for the entirety 3 of the testimony or only a portion of it. Maybe we can 4 get at it that way. But I object to -- 5 Q. What I'm asking you is whether you were 6 present during the entire portion of Mr. Smith's 7 testimony. 8 A. I don't know. 9 Q. Can you think of any reason why you would 10 have gotten up and left during the course of Mr. Smith's 11 testimony? 12 MR. SABETTA: Objection to form. 13 A. Telephone call or restroom or some other 14 business I had to attend to. 15 Q. Were you told that Mr. Smith had testified 16 that test results were falsified and his name was 17 forged? 18 A. I don't recall a discussion like that. 19 Q. After that trial, did you come back to 20 Monsanto here in St. Louis and do any form of 21 investigation into those Industrial Bio-Test studies? 22 A. No. 23 Q. Why? 24 MR. SABETTA: Objection to the form. 25 A. Because my personal observations and Gateway Reporting Associates, Inc. WATER PCB-SD0000071314 Gateway Reporting Associates, Inc. 370 1 experience led me to visualize a totally different 2 situation than what you just described. 3 Q. Well, as I understand your testimony, you 4 have no recollection of what I just described; is that 5 correct? 6 MR. SABETTA: Objection to the form. 7 A. That is true. 8 Q. Now, were you in the courtroom at the time 9 that a video was played of Wright's testimony? 10 A. There were videos shown, but I just don't 11 remember any scene with Dr. Wright in it. I don't 12 remember, no. 13 Q. You knew who Dr. Wright was at the time of 14 this trial; did you not? 15 A. Oh, yes. 16 Q. Dr. Wright had been a co-worker of yours at 17 Monsanto; is that correct? 18 A. At this time, yes. 19 Q. Was he a co-worker of yours at Monsanto at 20 the time of the trial? 21 . A. That's what I meant. At that time. 22 Q. Did you hear statements made that 23 Dr. Wright was taking the Fifth Amendment rather than 24 answer any questions? 25 A. I don't remember that at all. Gateway Reporting Associates, Inc. WATER PCB-SD0000071315 Gateway Reporting Associates, Inc. 371 1 Q. Was that reported in the newspapers? 2 A. Are you talking about the Scott trial, sir? 3 Q. I'm talking about Dr. Wright taking the 4 Fifth Amendment in the course of testifying as to the 5 Aroclor tests that were done by Industrial Bio-Test. 6 Was that reported in the newspapers that you saw? 7 A. No . 8 (Mr. McDonough marked Plaintiff's Exhibit 9 434 . ) ' 10 Q. If you'll turn to tab 60 for me, please. 11 We've identified as Exhibit 434 a document entitled 12 "Minutes of Meeting of the Corporate Development 13 Committee, November 17th, 1968." Present Messrs. E. J. 14 Bock, Chairman; H. H. Bible, B-I-B-L-E; J. R. Eck, 15 E-C-K; J. L. Gillis, two L's; E. J. Putzell, 16 P-U-T-Z-E-L-L, E. H. Sommer, S-O-M-M-E-R; J. N. Ehlers, 17 E-H-L-E-R-S, Secretary. Have you ever seen those 18 minutes before? 19 A. I have seenportions of them. 20 Q. When did you see portions of them? 21 . A. Early 1970. 22 Q. Were they given to you, these portions of 23 them, by anyone? 24 A. Yes. 25 Q. Who were they given to you by? Gateway Reporting Associates, Inc. WATER PCB-SD0000071316 Gateway Reporting Associates, Inc. 372 1 A. Elmer Wheeler. 2 Q. Was this part of your tutorial that you 3 told us about in the first 90 days? 4 A. Yes. 5 Q. In the course of your work from January 6 1970 up through the time that you didn't work in the 7 area of PCBs anymore, did you have any discussions or 8 conversations with any of these gentlemen identified in 9 these minutes with respect to PCBs? ' 10 A. Yes. 11 Q. Which ones? 12 A. Mr. Putzell, P-U-T-Z-E-L-L. ' 13 Q. What role did Mr. Putzell play in the 14 company? 15 A. Mr. Putzell was the general counsel of 16 Monsanto. 17 Q. When did you have discussions with 18 Mr. Putzell? 19 A. As I recall, it had to do with the subject 20 21 MR. SABETTA: He's asking for the date. 22 THE WITNESS: Oh, he asked me when? 23 MR. SABETTA: When. When did you have such 24 discussions? 25 THE WITNESS: When did I have the Gateway Reporting Associates, Inc. WATER PCB-SD0000071317 Gateway Reporting Associates, Inc. 373 1 discussions? 2 MR. SABETTA: With Mr. Putzell? 3 Q. Yes. 4 A. The letter from the EPA requesting all that 5 information is dated October 17, 1975. Somehow 6 Mr. Putzell heard that we had received a copy of that, 7 and he called me to sit down with him and discuss it. 8 Q. And did you sit down and discuss it with 9 him sometime after October 17th, 1975? ' 10 A. Yeah. Within a week, yes. 11 Q. Was there anybody else present? 12 A. No. 13 Q. What did you discuss? 14 MR. SABETTA: Well, just a second. I think 15 we're trenching on the attorney-client privilege now, 16 and before I let my client answer any of these questions 17 I would want to have discussion with him outside the 18 presence of other counsel to see whether the privilege 19 should be asserted here, and I should direct him not to 20 answer any questions directed to the content of those 21 discussions. If you intend to ask him what they said to 22 each other at the meeting, I'm going to have that 23 discussion with him. I may instruct him not to answer. 24 If you're intending to do something other than that, 25 then I won't have to do that. Gateway Reporting Associates, Inc. WATER PCB-SD0000071318 Gateway Reporting Associates, Inc. 374 1 MR. McDONOUGH: I intend to ask him those 2 questions, and I cannot understand how the 3 attorney-client privilege would apply, but would you 4 like us to leave the room? 5 MR. SABETTA: No. I'll step outside with 6 the witness and with Mr. Peck, and we can discuss that. 7 MR. McDONOUGH: By the way, could I ask a 8 few more questions off that particular topic before you 9 leave? ' 10 MR. SABETTA: Sure. 11 Q. Did youhavediscussions with any of these 12 other gentlemen - 13 A. No. 14 Q. -- other than Mr. Putzell? 15 A. No. 16 Q. And that goes from January 1970 through 17 1986 when you left the PCB area? 18 A. ' 76 . 19 Q. ' 76, I'm sorry. 20 A. That is correct. 21 . MR. McDONOUGH: Okay. Thank you 22 (Whereupon, there was a brief recess 23 MR. McDONOUGH: Are you going to permit the 24 witness to answer the question what did he di scuss with 25 Mr. Putzell? Gateway Reporting Associates, Inc. WATER PCB-SD0000071319 Gateway Reporting Associates, Inc. 375 1 MR. SABETTA: I'll permit the witness to 2 answer only the subject matter that they discussed on 3 that occasion. I will not permit him to give any 4 testimony about what either he or Mr. Putzell said on 5 that occasion. I'm instructing him not to answer that 6 question because I've satisfied myself that that 7 information is privileged, protected, confidential by 8 reason of the attorney-client privilege. Mr. Putzell 9 was the attorney -- general counsel, rather, of the 10 company, and he was acting as such in connection with 11 this meeting with this witness. 12 Q. What subject matter did you discuss on that 13 occasion? 14 A. The letter that Monsanto received from the 15 EPA requesting information. 16 Q. Did you discuss the subject of the answer 17 to question ten? 18 MR. SABETTA: I'm going to object and 19 instruct him not to answer that question. 20 Q. Just so the record's clear, I disagree with 21 that, but we'll proceed. You have in front of you 22 Exhibit -- What is the tag number on that? 23 A. 434. 24 Q. And that's the minutes of this meeting 25 November 17, 1969. If you'll turn to the document Gateway Reporting Associates, Inc. WATER PCB-SD0000071320 Gateway Reporting Associates, Inc. 376 1 portion that has Bates number 3937 on it, it has a 2 heading "Organic Division, Law and Medical Departments 3 Report on Polychlorinated Biphenyls". Have you seen 4 that portion of the exhibit before? 5 A. Yes. 6 Q. Was this a report -- Withdraw that. Was 7 this a joint report by the Organic Division and the Law 8 Department and the Medical Department? 9 A. You mean this document is a report, or do 10 you mean the presentation, the meeting? 11 Q. Was there a presentation made at the 12 meeting that was a joint presentation by the Organic 13 Division, the Law Department, and the Medical 14 Department ? 15 A. Yes . 16 Q. Now, this indicates present Messrs. 17 J. Mason, T. K. Smith, H. S . Bergen, J. E 18 Springgate, R. E. Kelly, E. P. Wheeler, Rodney Harris, 19 Jr., D. W. Miller, W. C. Robinson; does it not? 20 A. Yes. 21 , Q. Are any of those gentlemen attorneys? 22 A. No. 23 Q. Who is C. J. Smith? 24 A. C. J. Smith was an Assistant General 25 Manager of the Organic Division at that time. Gateway Reporting Associates, Inc. WATER PCB-SD0000071321 Gateway Reporting Associates, Inc. 377 1 Q. Who is T. K. Smith? 2 A. T. K. Smith was the vice president to whom 3 the Organic Division reported. 4 Q. Do you know what T. K. Smith's training 5 was ? 6 A. No, I don't. 7 Q. Did you ever deal with him in this 1970 8 through 1976 time period? 9 A. Occasionally. 10 Q. Do you know what training C. J. Smith had? 11 A. He was a Bachelor's degree in Chemical 12 Engineering. 13 Q. The reference to R. E. Kelly would be 14 Dr. Kelly? 15 A. Yes . 16 Q. Who is Rodney Harris, Jr.? 17 A. He's a chemist in Monsanto's Research 18 Department in the Organic Division. 19 Q. Who's D. W. Miller? 20 A. He also is a chemist. 21 Q. Do you know whether they were Ph.D.'s, 22 Mr. Harris and Mr. Miller? 23 A. I know Mr. Miller was. I do not know about 24 Mr. Harris. 25 Q. Who is W. C. Robinson? Gateway Reporting Associates, Inc. WATER PCB-SD0000071322 Gateway Reporting Associates, Inc. 378 1 A. He's another research chemist. 2 Q. Do you know if he's a Ph.D.? 3 A. I do not. 4 Q. Do you know if any of these gentlemen are 5 still alive? 6 A. To the best of my knowledge, Mr. C. J. 7 Smith is, Mr. Mason, Mr. T. K. Smith, Mr. Springgate, 8 Rodney Harris, D. W. Miller, and W. C. Robinson. 9 Q. Do you know any of those gentlemen who 10 still are employed by Monsanto? 11 A. No . 12 Q. Do you know whether the ones that are alive 13 still live in the St. Louis area from your knowledge? 14 A. Mr. C. J. Smith is not. Mr. Springgate is 15 not . 16 Q. Where does Mr. C. J. Smith live? 17 A. I am not up to date on these. Ibelieve 18 he's in Naples, Florida. 19 Q. Where does Mr. Springgate live to the best 20 of your knowledge? 21 A. Mr. Springgate is in California near the 22 Sacramento area. That's the best I know. It's not 23 necessarily accurate. 24 Q. If you look at the page Bates number 3938 25 under Environmental Aspects, E. P. Wheeler, there Gateway Reporting Associates, Inc. WATER PCB-SD0000071323 Gateway Reporting Associates, Inc. 379 1 appears to be an area in the middle of the page that has 2 no printing. Do you see that? 3 A. I do. 4 Q. Do you know whether material has been 5 redacted from that page? 6 A. I am told that. I have never seen the 7 material. 8 Q. Do you know what that material says? 9 A. Not having seen it, I don't know what it 10 said. 11 Q. Has anybody told you what it said? 12 A. No. ' 13 Q. Does it involve a report by attorneys? 14 A. I understand that it was entitled "Legal" 15 with an underline under it. 16 Q. Do you know whether an attorney was 17 identified in terms of giving the report at that portion 18 of the document? 19 A. No, I don 1t. 20 Q. The next heading down says "Plan of Action, 21 H. S.. Bergen and J. E. Springgate". Do you see that? 22 A. Yes. 23 Q. Had you seen this pagebefore today? 24 A. Yes. 25 Q. Did you see it at the time of your Gateway Reporting Associates, Inc. WATER PCB-SD0000071324 Gateway Reporting Associates, Inc. 380 1 tutorial? 2 A. Yes. 3 Q. Was the legal portion whited out when it 4 was shown to you? 5 A. Yes. 6 Q. Now, if you look at the next page, page 7 number 3939, it purports to be page 79 of this document, 8 there's a list of items 1 through 12; is that correct? 9 A. Yes. ' 10 Q. Item 1 says, "Appoint aproject manager - 11 responsible for the overall management of the Aroclor 12 pollution problem. He would be assisted by a Task Force 13 from members of each business group plus Medical, Law, 14 Engineering, and Manufacturing." Do you see that? 15 A. Yes. 16 Q. Would you be thatproject manager? 17 A. Yes. 18 Q. And your task force never had aname? 19 A. Not officially. 20 Q. Item 2 was "Notify all Aroclor customers of 21 PCB problem." Was that part of your assignment? 22 A. Yes. 23 Q. Item 5 was "Develop andimplement new 24 packaging systems for Aroclor 1254/1260." Was that part 25 of your assignment? Gateway Reporting Associates, Inc. WATER PCB-SD0000071325 Gateway Reporting Associates, Inc. 381 1 A. Yes. 2 Q. What does that mean, "new packaging 3 systems"? . 4 A. It's an attempt to describe a system for 5 filling pails or drums with the 1254 and 1260 that was 6 more up to date and resulted in less spillage, and, 7 therefore, reduce the contamination at that drumming 8 spot. , 9 Q. Would that new packaging system'include 10 methods of packaging that would reduce vapors from the 11 shipping containers? 12 MR. SABETTA: Objection to form. 13 A. There were no visible vapors. The material 14 wasn't that hot to create vapors. 15 Q. Did you participate and perform item 5? 16 A. No. It was well underway when I finally 17 got around to addressing it. 18 Q. Who had it underway? 19 A. The Anniston plant. 20 Q. Item 6, "Introduce to market replacement 21 products for Aroclor 1254/1260," did you do that? 22 A. We attempted it, but it did not succeed. . 23 Q. When you say it did not succeed, do you 24 mean up until the time you left the PCB area in 1976? 25 A. Well, even up to the time Monsanto stopped Gateway Reporting Associates, Inc. WATER PCB-SD0000071326 Gateway Reporting Associates, Inc. 382 1 producing PCBs of all kinds for anything. 2 Q. When did Monsanto stop producing PCBs of 3 all kinds for anything? 4 A. The summer of '77. 5 Q. What was the reason for that? 6 MR. SABETTA: Objection to the form. 7 Q. Do you know why Monsanto stopped producing 8 PCBs of all kinds for anything? 9 A. Well, the Toxic Substances Control Act 10 mandated that it be terminated in '79. Monsanto 11 received word from its few remaining customers that they 12 had alternative materials, and it was agreed by both 13 Monsanto and its customers that July 'll was achievable. 14 Q. Who was Monsanto's last customer of PCBs? 15 A. I do not know. 16 Q. Was GE one of its few remaining customers 17 in 1976? 18 MR. SABETTA: Objection to form. 19 A. Yes. 20 Q. Who else was a customer in 1976? 21 A. I don't propose tomemorize them all. 22 Q. Do you recall any? 23 A. Of course, Westinghouse and Sprague 24 Electric and Cornell Dubilier. Might have been a half a 25 dozen more. I just don't remember the whole list. Gateway Reporting Associates, Inc WATER PCB-SD0000071327 Gateway Reporting Associates, Inc. 383 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you recall from your studies who Monsanto's first customer was with respect to PCBs? A. Yes. Q. Who was it? A. Well, when I said yes, I had in mind Swann Chemical Company. General Electric was the first customer. Q. Item 7, "Continue and expand biodedegradation test program with Aroclor series, particularly 1242, 1248 and 1254." Were you able to do that during the course of your work? A. Yes. Q. What was this test program? A. It consisted of activities in Ruabon, Wales and in St. Louis in which bacteria that were taken from a municipal waste treatment plant were introduced into solutions containing these three Aroclors mentioned at different concentrations, and they bubbled air through them just like the municipal treatment does, and to analyze over given periods of time to see what was happening to the Aroclors that were introduced into the system. Q. Item 9 says, "Accelerate present analytical test program." Did you understand there was an analytical test program in place at that time, at the Gateway Reporting Associates, Inc. WATER PCB-SD0000071328 Gateway Reporting Associates, Inc. 384 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 time of this meeting? A. There was a -Q. November of '69. A. -- test program, yes. Q. Was that the test program you told us with respect to Dr. Keller and his group? A. Yes. Q. Ten was "Determine feasibility and cost of eliminating 5/6 chlorines in Aroclor 1242 and'1248." Do you know whether that was done? A. Yes . Q. What was the cost of that? Do you know? A. I do not. Q. 11, "Study incineration products," do you see - A. Q. Yes. Was that study done? A. Yes. Q. Who did that? A. Well, the laboratory work was done by Dr. Richard's people, and the materials, the gases that resulted from that test, were analyzed by Dr. Keller's group, and the incineration products from the John Zinc test were also studied by Dr. Keller's group. Q. Did you discuss this study, incineration Gateway Reporting Associates, Inc. WATER PCB-SD0000071329 Gateway Reporting Associates, Inc. 385 1 products portion, with Dr. Kelly or Mr. Wheeler in the 2 course of your tutorial? 3 A. Yes. 4 Q. Was there concern about the incineration 5 products from PCB oil at that time? 6 MR. SABETTA: Objection to form. 7 A. The concern expressed involved the degree 8 or the temperature to which the operation was taken, and 9 they were supporting the high temperature approach. 10 Q. Did that concern include concern for a 11 hypothesis that furans and dioxins might be produced if 12 a high enough temperature was not used for incineration? 13 MR. SABETTA: Objection to the form. 14 MR. GRONDAHL: Object to the form. 15 A. Well, they supported that hypothesis, but 16 they were relying on the chemists to confirm that 17 hypothesis. 18 Q. Did they support that hypothesis at the 19 time of your tutorials in January 1970? 20 MR. SABETTA: Objection to form. 21 . Q. "They" referring to Mr. Wheeler or 22 Dr. Kelly. 23 A. I would suggest that that came a topic of 24 more discussion really than the early three months in 25 1970. It kept coming up throughout 1970. By the time Gateway Reporting Associates, Inc. WATER PCB-SD0000071330 Gateway Reporting Associates, Inc. 386 1 the incinerator test was made, it was receiving much 2 more attention. So that would be the fall of 1970. 3 Q. So as I understand your answer, the 4 hypothesis was discussed in your tutorial in June of 5 1970 or was not? 6 A. I have a problem with the use of the word, 7 "tutorial" beyond the first three months. That doesn't 8 mean we stopped talking and exchanging information. 9 Q. I was asking about the month of January 10 1970. Was the hypothetical that dioxins and 11 dibenzofurans could be released from PCBs if the 12 temperature for incineration was not high enough 13 discussed? 14 A. It did not come up. 15 Q. When did it first come up? 16 A. About the middle of 1970 was about the time 17 it started coming up. 18 Q. The next-to-last paragraph on 3939 says, 19 "Conclusion. In light of the recent and developing 20 evidence of a possible threat to certain species of bird 21 and aquatic life, we should plan to discontinue the 22 manufacture of Aroclors 1254 and 1260. The Division is 23 instructed to develop a program to discontinue these 24 products and report this to the committee." Do you see 25 that ? Gateway Reporting Associates, Inc. WATER PCB-SD0000071331 Gateway Reporting Associates, Inc. 387 1 A. I do . 2 Q. Was that conclusion reported to Monsanto's 3 customers? 4 A. Yes . 5 Q. Was it reported at that time? 6 A. At what time? In '69? 7 Q. Yes. On or about November of 1969 or 8 December of 1969. 9 A. No. It was reported starting in about 10 April of 1970. 11 Q. You're telling us that it was reported 12 starting about April of 1970 that Monsanto was going to 13 discontinue the manufacture of Aroclors 1254 and 1260? 14 A. That we were planning to. We hadn't 15 arrived at the definite decision. 16 Q. Your testimony is that Monsanto told its 17 customers that it was planning to discontinue the 18 manufacture of Aroclors 1254 and 1260 starting in April 19 of 1970? 20 A. Yes. 21 Q. And were any documents employed to 22 communicate that plan? 23 A. Not to my knowledge. 24 Q. How was the communication made? 25 A. Well, we made it through our marketing Gateway Reporting Associates, Inc. WATER PCB-SD0000071332 Gateway Reporting Associates, Inc. 388 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 people. I recall at least one document that proposed eliminating Aroclor 1260 and that was acceptable to the customer. Q. I'm talking about April of 1970 when you tell me that a plan to discontinue the manufacture of Aroclors 1254 and 1260 was communicated to customers, were there any documents that Monsanto produced with respect to that plan other than this particular exhibit that we're looking at? ' A. When I mentioned April, that was the beginning of a period at which this information was shared with our customers. It was not done in a mass mailing. It was done in a face-to-face kind of discussion. Q. And you're telling me there were no written documents with respect to these face-to-face discussions or directions to your marketing people to have these face-to-face discussions? A. That is true. Q. Everything was done orally? . A. Yes. Q. Did you, meaningMonsanto, communicate to the public that you were planning to discontinue the manufacture of Aroclors 1254 and 1260 on or about November 1969 or December 1969 or January or February or Gateway Reporting Associates, Inc. WATER PCB-SD0000071333 Gateway Reporting Associates, Inc. 389 1 March or April of 1970? 2 MR. SABETTA: Objection to the form of the 3 question. 4 Q. Withdrawn. Did Monsanto ever communicate 5 to the ultimate customers its plan to discontinue the 6 manufacture of Aroclors 1254 and 1260? 7 MR. SABETTA: Objection to the form. Asked 8 and answered. 9 A. The customers who were buying Aroclor 1260 10 were informed of the discontinuance of that product and 11 they accepted it. There was no need to go any further 12 with 1260 . 13 Q. What about the public? Did Monsanto 14 communicate its plan to discontinue the manufacture of 15 Aroclor 1254 and 1260 to the public? 16 A. No . 17 Q. Did it communicate this plan to any of the 18 purchasers o f transformers? 19 MR. SABETTA: Objection to the form. 20 A. No. 21 . (Mr. McDonough marked Plaintiff's Exhibit 22 435 . ) 23 Q. Did it communicate this plan to any -- I 24 withdraw that. If you turn to the next document, I've 25 had it marked. We've marked as Exhibit 435 a document Gateway Reporting Associates, Inc. WATER PCB-SD0000071334 Gateway Reporting Associates, Inc. 390 1 that purports to be a letter over the signature of or 2 the typed signature of Elmer Wheeler, dated October 3 23rd, 1959, to Mr. Wilbur Speicher S-P-E-I-C-H-E-R, 4 Administrator, Industrial Hygiene, Westinghouse, East 5 Pittsburgh, Pennsylvania. Have you ever seen that 6 document before? . 7 A. I recall it, yes. 8 Q. When did you first see that? 9 A. Part of my discussions with Mr. Wheeler. 10 Q. Was that part of this three-month tutorial 11 we've been talking about? 12 A. Yes. 13 Q. Did he give you the document? 14 A. Oh, he handed me a copy. I read it right 15 there in the room and returned it. I did not keep it, 16 no . 17 Q. Did you ever put any of these loose 18 documents that Mr. Wheeler gave you to keep in a 19 particular binder or file? 20 A. Some of them. 21 . Q. Did you have a name for that finder or 22 file? 23 A. Oh, I had several names depending on the 24 subject matter. 25 Q. Do you know whether those files or binders Gateway Reporting Associates, Inc. WATER PCB-SD0000071335 Gateway Reporting Associates, Inc. 391 1 still existed when you left employment in this PCB area? 2 A. They did. 3 Q. What would you do with the others that you 4 didn't keep? 5 A. Destroy them, as long as I knew that they 6 were copies of some permanent file. 7 Q. You felt that you didn't need the documents 8 in your own files? 9 A. That 1s right. ' 10 Q. These files or binders that you did keep, 11 were they files or binders or both? . 12 A. Are you referring to the three-ring 13 notebooks? 14 Q. I'm referring to whatever files or binders 15 you kept this material that Mr. Wheeler gave you, not 16 the two three-ring binders that you've earlier 17 identified. 18 A. Those were placed in files according to 19 subject matter as I defined it so that I could retrieve 20 them. They would be under "Toxicity - 1242" or 21 "Toxicity - Miscellaneous Aroclors". It varied. 22 Q. Were these files -- Did these files bear 23 your name in any fashion or any designation that they 24 were your files? 25 A. They were in my cabinets. Gateway Reporting Associates, Inc. WATER PCB-SD0000071336 Gateway Reporting Associates, Inc. 392 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MCDONOUGH: That's all I have. MR. GRONDAHL: I don't have anything. MR. SABETTA: Okay. I guess we're done. WILLIAM B. PAPAGEORGE, P.E. Subscribed and sworn before me this ________ day of , 1999. My commission expires: Notary Public FAO/Furch, et al. vs. General Electric Company, et al. Gateway Reporting Associates, Inc. WATER PCB-SD0000071337 Gateway Reporting Associates, Inc. 393 NOTARIAL CERTIFICATE STATE OF MISSOURI CITY OF ST. LOUIS ) ) .1, FAITH A. OLLIGES, a Registered Professional Reporter and a duly commissioned Notary Public within and for the State of Missouri, do hereby certify that there came before me at the offices of Husch & Eppenberger, 100 North Broadway, St. Louis, Missouri, WILLIAM B. PAPAGEORGE, P.E., who was by me first duly sworn to testify to the truth and nothing but the truth of all knowledge touching and concerning the matters in controversy in this -cause; that the witness was thereupon examined under oath and said examination was reduced to writing; that the signature of the witness was not waived by agreement of all parties, and this transcript is a true and correct record of the testimony given by the'witness. I further certify that I am neither attorney nor counsel for nor related nor employed by any of the parties to the action in which this deposition is taken; further, that I am not a relative or employee of any attorney or counsel employed by the parties hereto or financially interested in this action. IN WITNESS WHEREOF, hand and seal on May 3, 1999. I have hereunto set my My commission expires March 21, 2001. Notary Public Gateway Reporting Associates, Inc. WATER PCB-SD0000071338 - ' ECCs P. G. EElttGiruS ' , D. A. OLGGH July 6, 10JO hr. I>. 13. Csvcnaugh h .7.7 ' .7 k/-f \ ; 3cpey KsnuCaotus'-lns Company .. -7 V *'*/ ' l\ 0. r-ox fii? . ,' Saratoga Springs,; 2,Tcw Yoi'Ic 1PC66 `Vi-s- a: . 7,/...frV - / " , .Jtear I*ir.' Cavonauglis. f ;..7 7. ''Last mor.th when Randy Graham and-I .violted your ' plant to dis onset the ?CB problem, e did not intend . ;' to cause? undu-* alarm or create cr.j panic concerning: the use and handling, of polychlorinated biphenyls. . ' .7 t'e were pri airily interested in sharing our current . . Jnicwledgc of the situation with you and offered to v help 'wherever wo could. . ..... . .-,.... . . ' All studies that we'are aware of indicate that fOS's, . ' vdileli are present in Mens an to* s Aroclors,' are not .. . acute poisons to humans and other na^.-rr.is, but do ' . effect cose species of liras and murine life, lion ever, . since they are chlorinated hydrocarbons, personnel working with these .materials rnould be protected- ' from prolonged breathing of the runes and frees skin ; ' . contact with the liquid. Ventilation should bo provided to keep the concontx*afelon in tlv; working ` area below 0.3 - 1.0 ciilligraa per cubic meter of '. air. ^ . .. .'. ... To provent the escape of PCB's.to the environment . calls for a level of control and housekeeping many . of us have.never been asked to achieve in the past. . Every effort :rusfc be moo to prevent Xsa'msc ana spillage. Maintenance r.ust bo kept at a very high ctarfar-d. Her those arena whore leaJra.ee and spills \ will occasionally occur, catch pans must bo provided. Tivesa pons must drain to a. collecting basin or be ' .. emptied by rcsponaiblo employees ou a scheduled - . ' basis. . . . . ... . -... .' .- ' ' FUR 001911 WATER PCB-SD0000071339 T-Uzins of Arc dors with waste water stream should ' be avoided since senaraticn of fCM'e fre.u water can bo costly.. XT inirciug cannot to avoided, a catch basin a:id settling ?ona should be provided to separata . the heavy Arcelor frenn the water. . . . .: Unusable eontaninr.tcd Aroclor should be diopocd-cl by incineration wivlch nocurcs earpiece destruction to CO?. Y.pp, end MCI. -Any Ineincz'atiPn below b03C vail! result in vaporisation which rill corkucinate the at:cospnei'C cr in partial oxidation which nay yield rjatcrialo vihich are highly fccsoLc. - To help our* customers with their liquid disposal problems, t:o have offered.to access for lutr.ro in cineration ncron- II.'raid Aroelovs shipped to Monsanto ... Company, !!.. 0. hruciarich- fieri,- Case.;et, "Illinois, Attention Supervisor, Impart;iont 2s i. The choree for t.'iin disposal'Is 3> par peund cl' natc-rial, tills charge is tentative ponding a complete cs-valuation of incineration costs and does net include freight or concoiner. costs.; ;-;3 -. ' .. .. . . ; . Contamination of the'atsiocphsre roust; also be elimi nated, a 11 handling aystcry, raust be closed- wherever possible. .. l"u::ss exhausted iron a tank, vessel, or "worldrun area, .vest be trapped and collected using . condensers nr.d eetrcd-ivacnt separators. ... . -- iolids contaslruifcsd tilth ?CB*s pose a grenter challenge. Until a proper incinerator Is designed wo are sv averting that aispenel be asade in an authorised- properly operated land fill av.vy frc'.t any water nysCerc;. Thane solids include treati'ont clays, abac-rains :'a.toriole, v.aec to contain spills, rag3, windings"und containers. . -y In cuusary, control of ?0">fc can bn achieved with . cquipxcut engincer-ei to prc-ver.it losses cud u-ain- tainccl properly coupled with good .manufacturing practices -which result in a high aeonJoru of iiouse- 3;ccpir:g." : - " . .-... Prea. the interest nni. concern thick you have cr.r.-reased I on certain that you will do .all you can to r-iduso the escape of Pul's from .your operation, ihen all or us sue cued in this cb4active, i an certain that no . reculr.tcry agency trill be compelled to ta'.re precipitous - action regarding the vr.c of rj.1 s or. vital- uppilco-ticno. os; d.-'..drehnu Sincerely,3'v; .1; - . i fur 001912 t.'. a, r>:-P;,ggj7.gy( yoiir.gcr ' Mivitxjmpntiil Con trol WATER PCB-SD0000071340 BCCs P. G. BMIGNUS D. A. OLSON July 6, 1970 Mr, Darlington Wilburn Manager, Engineering Vestinghouse Electric Corporation South Boston, Virginia Dear Gary* X have read your Process Specification 8914001 "Disposition of Scrap Xnerteen end Inerteen Contaminated Materials" and I found It an excellent document which reflects Weatinghouse's concern about the PGB problem and Is a major step forward toward Improved control, I do have one concern that I would like to pass on to you. The suggestion to burn solvent or oil contaminated with Inerteen does not refer to any minimum combustion temperature. As we discussed previously, tot ad destruction of PCB'a can only occur above 800C. Any temperature below this minimum will result in vaporization with release to the atmosphere or worse yet, It is possible to partially oxidize PCB'a Into materials which can be highly toxic (e.g. dioxins or furans). Your Incineration should be thoroughly reviewed. I found our discussion and plant tour last week very Interesting and Informative, Your plant has excellent housekeeping and with continued emphasis on controlling loss of PCB'a to the air end sewer, X am confident you can succeed In achieving a "bone dry" plant In tfilch the leakage, spills, etc. are a rarity, X am working with our P.R* Department on a suggested press release which X will send you soon. Sincerely, rr, n W fjr*nbn'n FUR 001908 W. B. Fapageorge, Manager Environmental Control rlPLAINTlFr^EPOSmON| " EXHIBIT I WATER PCB-SD0000071341 BCC: P. G. BENIGNUS D. A. OLSON July 7, 1970 Mr* Gene Lewis P, R, Mallory Company Waynesboro, Tennessee Dear Genei I apologise for the delay, but after further travel and a long holiday weekend 1 am finally sending you my comments regarding the control and disposal of Aroclors. I appreciated the time you and your colleagues were able to spend with Randy Graham and me and 1 was pleased I had the opportunity to tour your plant, since this gave me a better understanding of your overall problem. Gene, of all the plants I personally toured, yours had the biggest challenge to reach the objectives we are striving for. I tell you this not to embarass you but, hopefully, to give you soma feel for the magnitude of the problem. First, let us consider the welfare of your employees. Aroclors, being chlorinated hydrocarbons, should not be permitted to exceed 0.5 to 1.0 milligram per cubic foot of air in the work area. In your operation, in spite of an operating ventilation Bystem, the presence of Arodor was noticeable by the blue haze present and insensitive as I have become, the amount was high enough to cause eye irritation which persisted for several hours, after the expoair e. Another area of employee exposure is direct skin contact with the liquid Arealor. Contact should be eliminated by operating changes or by providing protective gloves and clothing. FUR 001905 WATER PCB-SD0000071342 2- To prevent the escape of PCS'a to the environment calls for a level of control and housekeeping taany of us have never been asked to achieve In the past. Every effort oust be as.de to prevent leakage and spillage. Mainte nance oust be kept at a very high standard. For those areas here leakage and spills will occasionally occur, catch pans crust be provided. These pans oust drain to a collecting basin or be emptied by responsible employees on a scheduled basis. Mixing of Aroclors with waste water stress* should be avoided since separation of PCS'a from water can be costly. If nixing cannot be avoided, & catch basin and settling pond should be provided to separate the heavy Aroclor from the water. Unusable contaminated Aroclor should be disposed by Incineration which assures complete destruction to COg, Ugp, and HC1. Any incineration below 800C will result In vaporization which will contaminate the atmosphere or In partial oxidation which nay yield oatcrisis which are highly toxic. To help our customers with their liquid disposal pro blems, we have offered to accept for future incineration scrap liquid Aroclors shipped to Monsanto Company, V/. 0. Kruaarich Plant, Sauget, Illinois, Attention* Supervisor, Department 246. The charge for this dis posal Is 3$ per pound of material. This charge Is tentative pending a complete evaluation of incineration coats and does not include freight or container costs. Contamination of the atmosphere must also be eliminated. All handling systems must be closed wherever possible. Fumes exhausted from a tank, vessel, or working area oust bo trapped and colloctcd using condensers and entrainment separators. Solids contaminated with PCS's pose a greater challenge. Until a proper Incinerator is designed, we are auggoa ting that disposal be made in an authorized, properly operated land fill away from any water systems. These solids Include treatment clays, absorbing materials used to contain pills, rags, windings end containers. In summary, control of PCBfs can be achieved with equipment engineered to prevent losses and maintained properly coupled with good manufacturing practices Khlch result In a high standard of housekeeping. FUR 001906 WATER PCB-SD0000071343 3- Frota the Interest and concern which you have expressed, I aa certain that you will do all you can to reduce the escape of PCE'a from your operation* Wien all of vs succeed In this objective, I aa confident that no regulatory agency will be compelled to take precipitous action regarding the use of PCB'o in vital applications. Sincerely, not cot Hr. H, B. Vaught P. R. Kalloxy Coapanor Kr. Cecil Harrod P. R. Hal lory Company Q. R. Crahaa Vf. B. Papegeorge Manager Environmental Control FUR 001907 WATER PCB-SD0000071344 BCC: P. 0. BmCSNUS D. A, OLSON July 8, 1970 Hr. P. 0. Jenkina Vic President, Material Sprague Electric Company North Adams, Massachusetts 01247 Bear Hr. Jenkinsj : Z was fortunately able to visit your Brown St. Plant on June 17 with Randall Graham. I personally found the discussion informative and interesting and I was most favorably Impressed with the concern end interest expressed by your management personnel. We diocussed briefly son of the points raised in your letter dated Jun 11. I will try in this letter to be more specific. Biodegradability - Biodegradation studies conducted in our research laboratories in St. Louis, Missouri and in Ruabon, Wales using media consisting of local river waters or activated sludges acclimated to biphenyl give direct evidence that the lower chlorinated biphenyls are affected. There is some evidence that chlorine position on the biphenyl configuration does influence the degree of dietruotion by the microorganisms. I have enclosed a tabulation from our Ruabon laboratory which attempts to chow this difference. We do not have formal information regarding the effect of sunlight or other natural influences on Arodors. Experience gained over many years Indicates Aroclors ar highly stable under all known conditions present in the environment. Toxielty - There is ample evidence from many laboratories that certain species of birds Which are at the top of the marine food chain cannot reproduce properly when PCB'a are present in their diets. The U. S. Fisheries laboratory at Gulfbreese, Florida conducted a study which indicated that Juvenile brown shrimp did not survive in water containing 5 parts per billion of PCB. Attached are copies of reports on these studies. FUR 001902 WATER PCB-SD0000071345 2 Monsanto haa sponsored come studies on laboratory rats and dogs. A summary of the results to date Is attached. Disposal - The preferred method for disposal la high temperature Incineration. I suspect there are several commercial burners on the market which will perform well. X personally witnessed burning tests at the John Zink Company's unit !n_Tulsa, Oklahooa. Temperatures oust exceed 1600 P to assure that complete destruction Is achieved. Lower temper atures would only vaporize the Aroclors and create atmospheric pollution or, worse yet, would form, by partial oxidation, materials which could be highly toxic (e.g. furana and dioxins). With Incineration HC1 Is. forced which must be scrubbed from the stack gas and neutralized before disposal. We are planning for an Initial Installation In one of our plants later this year. As a service to our cus toners who may not have access to other Incinerators, we have offered to accept scrap Arcelor for immediate storage and eventual Incineration. Tentatively, Monsanto will charge 3^ per pound of returned material. This charge does not include freight or container costs and will be reviewed when final Incineration costs are established. Material which Is returned for disposal should be addressed to Monsanto company, W. 0, Krummrich Plant, Sauget, Illinois, Attention! Supervisor Department 246. . Solids contaminated with Aroclors present a bigger challenge. As yet, we have not tested an Incinerator with these materials. Until we get more Information the best we can advice Is safe burial In an authorized, properly operated land fill located away from any water lysteas. We have laboratory work underway on other forma of destruction. As yet no economically feasible approach has been found. Analytical Methodology - I have attached copies of Monsanto's analyticaTprocedures for the determination of PCB1a in water, soil, air and biological samples. Ve are Interested In comparing our methods with those devised ty other laboratories. Any comments your laboratory may have would be welcome and appreciated. FUR 001903 WATER PCB-SD0000071346 3 I hope that the above Information la useful to you If I can be of further service, please let me know Sincerely, ms cos Mr. B. Davis Sprague Electrlo 0. R. GUrahaa V. B. Papageorge Manager Environmental Control FUR 00190^ WATER PCB-SD0000071347 BCCj D. E. ROUSH August 17, 1970 Mr. J. M. O'Leary Technical Superintendent Industrial Chemicals Division Hooker Chemical Company Niagara Palls, New York 1^302 Dear Mr. O' Leary1 Monsanto's Don Roush informed me of your interest In receiving more information regarding polychlori nated biphenyls. I am enclosing summaries of Monsanto's position concerning the selective markets we will supply and the Btatus of biodegradability and chronic toxicity studies, I have also included copies of our analytical methodology for the detection of PCB's in water, sediment, biological specimens and gases. We would appreciate any comments your laboratory may have to offer concerning these procedures. Disposal of scrap PCB by burning can be achieved if the temperature is maintained above 800C. Attempts to dispose at lower temperatures will result in vaporization or worse if partial oxidation to highly toxic furans or dioxins results. Stack gases from complete destruction must be scrubbed and neutralized to properly dispose of the resulting HC1 gas which is formed. We have been working with the John Zlno Company, Tulsa, Oklahoma, on the dedgn of an Incineration scrubbing unit for installation in one of our plants within the next bIx months. 1 PLAINTIFF'S DEPOSITION ' EXHIBIT FUR 001900 WATER PCB-SD0000071348 -2- You may be Interested In the disposal service offered by Rollins-Purle, Inc., Wilmington, Delaware, James J. Mclaughlin, Director of Marketing, 302-478-5150. They have an operating unit at Gloucester, New Jersey capable of incinerating chlorinated hydrocarbons. I hope you find this information helpful. If I can be of further service, please let me know. Sincerely, W. B. Papageorge Manager Environmental Control ma aiclosures Sent the following: PCB's - Control of Escape to the Environment PCB's - Biodegradation Studies Summary - Interim Status Chronic Toxicity w/Aroclors Analysis of Water & Sediment for PCB Analysis of Biological Materials for PCB A tentative procedure for the determination of airborne PCB Identification of PCB by gas chromatography/mass spectrometry FUR 001901' WATER PCB-SD0000071349 Monsanto r,o ,.-c. loc.tiom E. V. John - St. Louis October 8, 1969 riRCHCi TO : Field Sales Offices Plant Communicators .Pollution Control Engineers ' Plant Managers Mr. J. J. Spano - JSPAN Mr. W. R. Richard - WRICH Mr. E. P. Wheeler - EWHEE Mr. M. W4 Farrar - St. Louis Mr. D. B. Hosmer - DHOSM CONFIDENTIAL You are probably aware that for the past seven months there has been considerable interest in the possible environmental contamination by polychlorinated biphenyls (PCB). The subject, first came up in the U.S. in connection with a research study done by a Dr. Robert Risebrough of the University of California. ; Dr. Risebrough was investigating the possibility of environmental contamination by DDT when he discovered an "interfering substance" which later was identified as PCB. The San Francisco Chronicle published a story based on these findings. Further DDT investigations by government, state and university laboratories have substantiated that PCB's are showing up in the environment, generally in the parts-per-billion range, but occasionally, in the parts-per-million range. PCB's are manufactured by Monsanto and marketed under the trade name Aroclor. (There are other producers in Europe and Japan). '.We have received numerous inquiries from the press and private j governmental and university laboratories for information about PCB. In some cases, requests have been made for samples of our Aroclor products. Monsanto's position is one of complete cooperation. A position statement has been prepared and is furnished to news media on request. To date no major national publicity has appeared. The company recently has appointed a task force to gather information and to make recommendations for future actions to protect our position in the manufacturing, marketing and customer use of Aroclor products. This memo is to alert you to the .procedure for handling inquiries. Should you receive a request for information concerning PCB's from any source (press, government, university or private citizen) please direct the inquiry to St. Louis. If the request cones by telephone, take the name, address, return phone number and the nature of the inquiry. . By providing information from one central source, we can project our corporate position of cooperation, and emphasize our efforts in research and study being directed to eliminating any possible contamination sources. . i PLAINTIFF'S DEPOSITION * EXHIBIT FUR 003338 I - WU y. WATER PCB-SD0000071350 Field Sales Offices Plant .Communicators Pollution Control Engineers . .Plant Managers . 2 October 8, 1969 Following are the individuals in St. Louis to whom inquiries may be directed for prompt action: Mr. Elmer P. Wheeler, Medical Dept., Sta. 2196 Mr. Ed John, Public Relations Dept., Sta. 2891 Your cooperation in handling inquiries on PCB's and Aroclors as suggested will be appreciated, and hopefully will result in greater control over the flow of information. . E. V. John Public Relations Manager Organic Chemicals Division Paul B. Hodges Manager of Environmental Engineering Organic Chemicals Division EVJ-PBH/stw . ' ' ' P. S. Attached are newspaper clippings which may provide some background on the present controversy. . 003339 I WATER PCB-SD0000071351 S. F. Chronicl* Fb. 24, 1969 A Menacing New Pollutant Brf?W firtww The peregrine falcon, a highly pataca--t. sod chemi bird of prey that once' cals closely related to ft are abounded all over Amerl-: known caocer-canaert. j ct. Is bearing a bitter* Ln California tbe pollutant* seaming to man: is widespread; la tbe San I . A newly-Wentl/led cheml- * Fraoclaco Bay Area, where- cal pollutant has arisen oo many industries use many our planet: It threatent not varieties of tbe compound.' 0*1y the existence of falcons' the chemicals have concen and countless other birds, but trated heavily. llj.molecules are already en tering the bodies of humans. The new pollution threat It a class of organic chemicals Its* long-term hazards at called polychlorinated bi low levels to the human spe phenyls. Few laymen have, cies are wholly unknown -- ever heard of them, yet they although In concentrated gas eous form the cncmical is See Back Pape 20 |ngratae* Cfrreaade Won., Feh. 2A, lf69 SHJ FAuC.t$>Co ClExiicLC FS3o<3<l, iRfeS Bay Scientist's Pollutant. Warning From Page 1 The Berkeley scientist is* he came upon It. chemical pollutant. Eight) ently starts coocentratlng In leagues point out that all the not survive as a species In an!cause they remain localised,* ep>tInrvtjraysiucnx:uxeilsatashft,eoojmixyrrssmtae-apjaaorielnruathdnkuebtissoirceoucdsnbha.mbnee1dme6lmericcmeaattpikdrrloieiuncxssigasy-,l^TDrMpSetacrcasirseretimMRnnatoerifescbntRhseotee.,rfotsr*fo^CuNratchRleuiefslostimeInrnbisttrattoihi'otuieugnteUhDa.noeial-f * resins. , Dr. Rlsebrough and a team . i of colleagues from Davis. The tale Is an Ironic one. percent of California's breed- the lowest links of the ma chlorinated hydrocarbons, environment altered by Dr. Rlsebrough says, are* for It all started with the per- ing peregrine falcons. Dr. rine "food chain" -- the ml-1 like DDT. cause enzyme man's new chemicals. "misleading, irrelevant and egrlne falcon. That bird. Rlsebrough estimate!, hive croacoplc oceanic plants and ch.nt hi animal liver, and And wh,, ,,( ^ 0, won*." . once described by an end- now been destroyed, animals -- and becomes that three new-formed en- biphenyl compounds In How the PCB compound* \ neat ornithologist is "the H was barely two years more and more concentrated rymes break down many vi- humans? The compounds1 may affect human food up- embodiment of noble rapid- ago that Dr. Rlsebrough. on as tiny fish eat plankton, big tal hormones. Including already been found, ip^et and human lives are! ty and lonely freedom." I* an expedition to Baja Callfor*. ger flah oat small fish, and hormones. In laboratory ex- >mino^y, in the milk of1 l ues* for future re- now extinct as a breedfng'nia. found an unhatched * bird) eat bigger fish. perimenta with pigeons. us- roolb<T1 by Dr. J.' rearch. The one certainty Despite their widespread San Diego and Cornell Uni species In the eastern United* abandoned egg of a peregrine Peregrines preying on Pa Ing a biphenyl compound ^ Endorsee aod Dr. F. A. now 1* that they can be found' use. in America they are made only by Monsanto versity la New York, have Stales and southern Canada. /falcon! He analyzed the egg's. cific sea birds have now vir been alerting ecologists to- Its rapid population declln ' conlerrtf, found DDT In it. tually vanished Dr. Rlse called Arodor 102. made by ^ Monsanto, Dr. Riaebrough's. ^ College ' everywhere, that they have Rlaebrough Is now:lovded the food-producing Chemical Co., which markets , the hitherto unsuspected during the years right aftei and also found it contained brough reporU. But small In pup has found that PCB la * hoph,f ^ test for their pres- * of the oceans, and that many forms of the com prevalence of the bvphenyl. Work! War !1 --* when DDT,another unidentified cheml- land colonies of California five times more powerful Burxin. mothers I Uelr presence is rising swirt- pounds under the trade name compounds and to their inva was first introduced as a nil- - cat. . falcons. wHch prey mostly than DDT In Its hormone-! ^>efT * *- ul Aroclors. sion of man's environment, They apparently enter tl>e utman's environment atmosphere and marine er.vi-. moment by vaporizing, vent- ' FALCON 1 Ing from factory stacks, by Tber have published their jor pesticide -- first served * pg \ on doves and songbirds, still to alert ecologists that a new-r'. .... .. , , poUon mixht be dim,*tnr U pr ">*' tbe environment. E: fond In the ft of Eurt>- appear to normally. be . reproducing pean birds and Swedish- In hundreds of analyses of PDT .scientists Identified It as a birds and their eggs Dr. Rlse destroying activity. Tbe ex hormones, * | As Dr. accord-.written: .. Rlsebraaghhas "They are highly Officials co.mp.an.y of tiie Monsanto In St. Lo.uts w_ere tag to Dr. Rlsebrough. play I toxic to man when Inhaled as! "f*1 .for cor?rTenl 00 ,Drt an Important role In ciWum - vapors, and the more heavily jR1 * e b.r u ** s rTPn u*| metabolism, and at a retult;chlorinated components have!***'* After tbrre **** of waste discharge Inta water-! Rodinas in the British sci Investigations showed the!polychlorinated biphenyl.- brough and his colleagues ways and eVen sive wearing of by the abra tires oo free-j ence yotmial Nature, American counterpart inSIctsi' fparlecyoinngwoansbisrduscctuhmatbihnogd by!which was to gain iu in-| title notoriety as PCB. scien- have found only about a tenth as much PCB as DDT of the pollution by PCB and:greater toxicity. No tote^-.<*ufrte, m001?**0* .P?*,"* DDT the e**i of bird, like:L limit, h.vi been t for^*" TM]A ,h*> ,,0'' Wcnn, we now fir thinner. humin food jupplle, and Moni.nl. lenlU,,ndle, ways. ence. and have Their chemical structure Is at conferences very similar to that of DDT,' mental poisons. discussed ll oRnlseebnrvoiruognh--,' gested targe quantities of j Dr. Risebrough and his colDDT. a'chemical that con--leagues then began an ex centrales in animal fats. So.haustive hunt for PCB In the potent and long-lasting will be presenting more evi the falcon, in a sense, was birds and fish along the West among birds from relatively unconlamlnated areas. But In birds from the Farallon Is lands the PCB quantities are md more fn*ile thin tuedlobe. fn*wAKft Hi.'MANb theyiiheir cincer-ciujin* proper-: wrr' -ludyl^t n. tin remilo to be deter- Dr. HlKbrou^Y f e 11 o *- -mined" rne.rcher, .lucking the PCB pollution problem in- insecticide. Both DDT and dence on the problem at a La man's first messenger to car-! Coast. They are itiU at it higher -- between a fifth and j The calcium-deficient eggs FOOD -elude Dr. I). U Peakull ol the biphenyls are known as Jolla scientific meeting on ry the warning that DDT was They have found, for ex- a half the DDT. break prematurely and fail Dr. Rlsebrough and hit col- Cornell: Steven G. Herman, chlorinated hydrocarbons, the "Chemical invasion and in the words of a Berke the Ocean." .. of befouling the world. And juit as Spartan kings ample that PCB is present m almost all hir;-s of prey. In birds ` and their eggs to produce hatchltags. Thus Irom polluted San Francisco `the decline of the falcon -- leagues have found evidence that the biphenyls, like DDT. a zcxitoglst at Davis: Dr Monte N. Klrven at the San ley researcher they are now In an Interview with The Mew their messengers who but its quantities aie largest Hay -- falcons, gulls, terns the end of its evolutionary are carried widely across the Ptrgo Natural Mirim v -the moil abundant synthet Chronicle recently. Dr. Rise- bore bad news, so tbe falcon in iho>e birds that feed <-n and night herons -- there Is road. It had adapted. over joceans b> *mds and wjut Musnim. and Pan! Heiche m ic pollutants present In the brottgh described the new lx being Mam today ns it car- fish or fi?r,-rating bird*. The often more 1MI thin DDT. million* of years to it* nau- currenM Arguments that the marine resources lab at ` global environment." pollution menace, and huw ties itie news | the new material, like DDT. appar Dr Risehrough amt his col- . ral environment but it could they can be used safely be- Berkeley, WATER PCB-SD0000071352 FUR 003340 I .A'AUKbb fcUftimuL ' MILWAUKEE, WiSC. , D. lGO.Oll. } ' MAY 13 1969 Some Bird Species ;3 Called DDT Victims | By QUINCY DADISMAN drocarbon compounds widely- Sentinel Staff Writer used In industry. PCB's show* -Madison, WIs. -- A Califor up in some test equipment Iti a . nia biochemist testified Mon way triRt makes separation of day that his studies have con .DDT in analysis much more vinced him- that DDT and not difficult. '. -- another commonly found con taminant is the cause of thin Only Few Found ' eggshells which he believes Risebrough said that while will wipe out certain predatory PtB's are' found In large bird species. mounts In many marine birds, he had.found only a few in Robert Rischrough, Berkc- which there _wcje mo[e.PCJB's, Icy, Calif.", was.colled as an ad {Hart ~BD`rVr" its metabolitics verse witness by Out attorney (forms into which it changes In' defending f h c pesticide at a passing through living tissue), natural fcsourco department hearing on a petition calling Ho said that tests with eggs, for banning DDT in Wisconsin. containing up to one part per , Testified Earlier million (p.p.m.) of PCB's and up to six p.p.m. of DDT in all . . Rischrough h.ad testified in Deeemher for the petitioners forms showed mathematically, -- Cilizrns' Natural Resource by correlation with eggshell assiicialion and thC Wisconsin thickness that DDE and riot chapter 'of the Izank Walton PCB's, were to blame. The' league -- about DDK, a form tests were made mathematical Into which DDT changes In liv ly, ho said, with a .statistical ing bodies and his conviction accuracy of 99.9%. ' | that DDK causes a metabolic He said that damage to '' disturbance in birds which eggshells from DDT can ''e leads to thin eggshells. , traced not only to the DDE In, j . The thin shell cracks' easily, I the bird's body fat, but also to causing the death of the cm- the amount present in.the food bryo inside the egg. It cats. '. Risebrough w A a called by "DDT may be comparatively Willard S. Stafford. Madison Inactive in.the body fat," he ' attorney who is conducting the concluded, explaining that per- | : defense of DDT for the Nation cgrlne falcons from Arctic ; al Agricultural Chemicals asso areas seem to be sustaining 1 ciation. ' their numbers better than , Stafford questioned Rise- those from more temperate ell; . hrough about work he has mates because the food they.j done wilh polychlorinated bi eat while rearing second phenyls (PCB), a gbiip of hy* clutch of eggs is "clean." j / i . A FUR 003341 WATER PCB-SD0000071353 Posed THE HARTFORD TIMES, Sunday, Augirrt.3,.1%9 by PCB Pollution ;>' Polychlorinated blphcnals ' (PCB) are -causing a con troversial -puzzle that raises many unanswered questions. By Bill CledeAnd the finger of accusation. may be pointing prematurely, j . PCB'g .have been found by . chemists testing fish and! wMlfe samples for residues! of pesticides such as DDT. ! ``It Is simply astounding' that the anvxrrrts of PCB being reported'codd posslWy t be- present In our- ok vlfonment,1' said Tom C. ','Tbrd of Monsanto, only com-; \vmercial producer of PCB in !".'the United States. . ' ' He explained that there just . isn't the opportunity for PCB's to be Introduced Into, ' nature. : Polychlorinated blphenals are a class of hydrocarbon chemicals with many indus trial uses. .They are used prl- . marily. as. inpulatb\g fluids In electrical. transformers and] capacitors. They are added to | a polymer. to make certain | plastics and adhesives or surf-. ace coatings. ' ' ; Although PCB's are similar to DDT, dieldrln and other chlorinated hydrocarbon In Industrial uses, PCB's . Since Monsanto Is the sole are s e 1 f-contained. The U.S. producer of PCB, the transformer Is sealed. In' company has launched heat-transfer applications, the. research programs .hoping to PCB fluid functions in a clos-. answer new questions raised ed system. . by chemists. ' In- plastics, .they become .- One Is seeking to Identify, part-' of - the solid material '; the compounds reported to itself'., . . .......... - , .the .PCB's. This Involves ~ \ Biit "plastic*" Is a. broad' . analysis o f environmental 'term.' .. .. - . - -: ; samples of air, water, soil and- ' "Now food-storage bags are wildlife. '- virtually ' all made o f Also underway are studies polyethylene which contains . no' PCB's' at all," Ford ; reassured us. "There .Is no , to determine the.blologkal-effects'of deliberate dosage df PCB's on fish, birds and mam- V requirement of clearance' ' with the Food and Drug Administration." " - .rnals. ' ''' . But -.neither . '., Is -complete ... .The Unking of. PCB with' enough- yet to draw conclu- ! DDT first happened about " slons. One 'chemist has done j : three years ago. Scientists 5,000 test samples but will not 'analyzing pesticide, residues ' assume any facts until he has In wildlife, found unidentified s "interfering" srfjsfcances In 'the. same range as DDT on 'finished 10,000, ,! Dr. Robert Rheborough, a marine biologist at t h e test equipment. University of California at y Professor Gunnar Wldmark Berkeley, tends to clear PCB and Soren Jensen, of the Stockholm University Institu- 'Hon of Analytical Chemistry identified the interference as of blame. . Testifying at the Wisconsin's ` Natural ^Recourses Department hear-, PCB. It shows up a peaks on,; tags on pesticides In May, Dr. the-. graph of a gas'- Riseborough even suggested- chromatograph very near the that DDT has been wrongly peaks caused, by. DDT. ......... blamed for producing thin . Ooniputer analysis, he "said, .showed "no significant statistical relationship" between. PCB content. .1 n .. . pelican' eggs and the-, thickness of their shells. But . as DDE contamination in creased, "the shells became -thinner" in both pelican and d o u b le-crested cormorant . While' PCB's are found hi 1 large amounts In many! marine birds, RLseborough' has found only a few in which there were more PCB's than ' DDT or its forms changed by passing through living tissue. But It is now a question whether the similarity of PCB's might have confused 1 earlier -tests for DDT. According to Brainerd T. ; Peck of the State Board of ' Pesticide Control, tests made prior to 1968 may not have " taken PCB interference into consideration. . . Keirstead of the Connecticut Agriculture Experiment Sta tion says it Is not likely that . . tests within the past couple of years would be confused. But li's an even bigger . question that if. these findings of -PCB's in fish and wildlife ;.are .accurate, where is. it coming from? . . Chemists have theorized - Uat the source must be in dustrial wastes. Yet industry spokesmen' know of no pro cess that would-release these ' chemicals: Monsanto has car ried out a program for several years . for ' the reclamation of used PCB's for re-use. The only .definite statement .anyone will, make is that these Questions will surely ex . pand tne scope of- research -- but there- won't be any quick and ready answers. pesticides, they have n o eggshells in some birds. With the advent of the gas agricultural use. :. "The gas chromatograph is "DDE (a breakdown pro chromatog raph, Lloyd ; 'TCB's would make lousy ' pesticides," Ford explained: 'It takes" 120 milligrams of DDT per kilogram of. animal weight to kill a rat. It would take 5,000 to 10,000 sensitive," Ford said, "but -you really, can't make positive Identification without a mdss spectrometer. We have learned that the Swedes did use one." duct of DDT) appears to-be the environemtntol pollutant most responsible for thin eggshells despite Ihe presence of PCB In some DDE-con taminated birds. ." . miftitrrarrv; of PCB." ' Ft!R nmoso WATER PCB-SD0000071354 Elmer P. Wheeler, Medical Department January 29, 1970' Status of Aroclor Toxicol- logical Studies ! J. S. Barrett, London grrTTErgrFKT-- W. B. Papageorge, WPAPA D. S. Cameron Brussels Enclosed Is a copy of the reports from our consulting laboratory indicating the status of the animal toxicity studies. I have summarized the pertinent findings separately and as indicated- in the table. We have given copies of these data to one U. S. custo mer, the U. S. FDA and-one or two other state agen cies. I don't see why this information cannot be released with discretion in Britain or Europe. Our interpretation is that the PCB's are exhibiting a greater degree of toxicity in this chronic study than we had anticipated. Secondly, although there are variations depending on species of animals, the PCB's are about the same as DDT in mammals. We have additional interim data which will perhaps be more discouraging. We are repeating some of the experiments to confirm or deny the earlier findings and are not distributing the early results at this time. EPW:ju Enclosure Elmer P. Wheeler : PLAINTIFF'S DEPOSITION EXHIBIT | ^77 FUR 003343 WATER PCB-SD0000071355 o Auary 15j 1970 2 year rat at 1, 10 and 100 ppm: At 90 days--possible liver enlargement. Males at 100 ppm. Histology O.K. Others O.K. Blood., urine. 2 year dog at 1, 10 and 100 ppm': At 6 months--0.K. body weight, food consumption, reactions, mortality, hematology,- blood chemistry and urine. ' 3 generation rat reproduction at 1, 10 and 100 ppm: 100 ppm--effect, on survival--difficult to obtain pups for maturing and mating, egg production. Chickens-r-egg production, hatchability, survival, etc.at 1, 10 and 100 ppm: 10 and 100 ppm levels effect hatchability. 1 ppm O.K. Aroclor 1254 2 year rat at 1, 10 and 100 ppm: At 90 days possible liver enlargement in males at 100 ppm. Histology O.K. Other levels O.K. 2 year dog at 1, 10 and 100 ppm: J At six months body weight effected at 100 ppm. Possibly less food consumption? Other levels O.K. Same parameters as 1242. FUR 003344 WATER PCB-SD0000071356 -2- i Aroclor 1254 (Continued) ' 3 generation rat study at 1, 10 and 100 ppm: 100 ppm--effect on survival same as 1242. Chicken--egg production, hatchabillty, survival, etc, at 1, 10 and 100 ppm: 10 ppm O.K. but 100 effects hatchabillty. Aroclor 1260 2 year rat at 1, 10 and 100 ppm: At 90 days--possible liver enlargement in males and females at 100 ppm. Other levels O.K. ' 2 year dogs at 1, 10 and 100 ppm: At six months, body weight effect at 100 ppm, possibly at 10 ppm. One male and one female dled--refused to eat. No other obvious reason for fatalities by gross examination. . . 3 generation rat study at 1, 10 and 100 ppm: No adverse effects. Chlcken--egg production, hatchabillty, survival, etc, at 1, 10 and 100 ppm: No effect. FUR 003345 WATER PCB-SD0000071357 2-year rat chronic At 1, 10, 100 ppm Status 90 days 2-year dog chronic Status--6 months 3 generation rat reproduction Chicken--Egg Production, Hatchability, Survival, etc. 1242 12^4 1260 100 ppm Liver enl.- Males 10 ppm O.K. 100 ppm Liver enl. Males 10 ppm O.K. 100 ppm Liver enl. M&F 10 ppm O.K. . 100 ppm O.K. 100 ppm affects survival 10 ppm O.K. 10 ppm affects hatch. 1 ppm O.K. 100 ppm Body wt. dec. 10 ppm O.K. 100 ppm affects survival 10 ppm O.K. 100 ppm affects hatch. 10 ppm O.K. 100 ppm 1M-1F died refused food- no other gross abn. 10 ppm Possible body wt. effect 100 ppm O.K. 100 ppm O.K. p}R'005146 WATER PCB-SD0000071358 Monsanto Monsanto Company 800 N. Lindbergh Boultvird St. Loult, Missouri 63166 Phono: DM) 684-1000 February 9, 1970 OROAHtC CMLH1CAJ.S DM Dear Sirt . Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (PCBs) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the partB per million and parts per billion categories. It is claimed that .the PCBs found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. Products which are sold by Monsanto under the trade names of Aroclor 1254 and 1260 do contain chlorinated biphenyls. In addition to Aroclor 1254 and 1260, Monsanto sells certain functional fluids containing Aroclor 1254. These include Pydraul 625, Pydraul AC, Pydraul AC - Winter Grade, Pydraul 540, Therminol FR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Aroclor 1254 and 1260 and formulated products containing 1254, we wish to alert you to the potential problem of environmental contamination as referred to in the newspaper and magazine articles. . We would like to point out the following additional facts. 1. Products such as Pydraul 90, 135, 230, 312, A-200, F-9, 150 and 60, Turbinol 153 and Therminol FR-1 and FR-2 are not formulated with Aroclor 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not . been found in the environment and appear to present no potential problem to the environment. FUR 004024 WATER PCB-SD0000071359 2 We have developed^ and are now testing, new formulations to - . replace the Aroclor 1254 and 1260 components in our Pydraul products. The new products appear to be equal in performance and to have similar physical properties. - We feel that all possible care Bhould be taken in the applica tion, processing and effluent disposal of these products to prevent them becoming environmental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969 regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good manu facturing practice in the future may require that no products used by any company should find their way into waterways. Sincerely yours, nlc Attachment /C. t*t< Donald A. Olson Director of Sales Functional Fluids Group FUR 004025 WATER PCB-SD0000071360 CHEMICAL WEEK / OCTOBER E9, 1969 _ Environment technology data for sulfur oxides and particulate matter, will follow with similar studies for other pollutants. Once criteria and control data have been issued for a pollu Tnc huge water requirements of the chemical industry- tant and control regions have been designated, a complicated now the nation's third largest user-make water quality and process involving standards, hearings and implementation availability increasingly important factors for site selectors. and enforcement plans will be initialed that can take over a Legislation enacted in recent years has forced planners to pay year to produce standards. close attention to pollution control standards. So far. no firm sulfur oxide or particulate standards have All 50 slates have had their water quality standards ap emerged. But NAPCA's criteria for selling the standards sug proved entirely or in part by the Federal Water Pollution gest they'll be lough. The oxide criteria report, for example, Control Administration (FWPCA). Recently a slale-by-state emphasizes that there arc deleterious effects to man at con summary of key standards was put together for the first time. centrations as low as 0.04 ppm. "" Surprisingly, it was not the FWPCA that did the job. Instead NAPCA's control data reports present detailed appraisals it was handled by an American Public Health Assn. (APHA) of various methods and equipment, along with estimated subcommittee headed byTVA Health Director F. E. Gartrell, costs. As in the case of water, the costs will be high, although assisted by the APHA Engineering and Sanitation Section. A some pollutants-mainly sulfur dioxide-will have recovery portion of the study, covering standards for surface industrial values. NAPCA is sponsoring a number of research projects water, is summarized in the tables starting on p. 80. to improve technology. Pollution control is being spurred by Contrary to widely held opinions, there is considerable financial assistance programs (mandated by state law) now variation in slate standards. Take the dissolved oxygen (DO) operative in the following 28 states: standard, for example. Minimum allowable DO (as milli Arizona, Arkansas. California; Connecticut, Florida. grams per liter or percent saturation) is the single most impor Georgia, Idaho, Illinois, Indiana, Maine, Massachusetts, tant standard to chemical site evaluators. As a rough rule of Michigan, Missouri, New Hampshire, New Jersey. New York, thumb, a 2-mg./l. standard is considered to be one industry North Carolina, Ohio, Oklahoma, Oregon, Rhode Island. can live with comfortably, while a 6.0 mg./l. value is pegged South Carolina, Tennessee, Vermont, Virginia, Washington. `'extremely tough." Wisconsin and West Virginia. California, Wyoming and Washington have set the stan In addition. Pennsylvania oilers financial aid sanctioned by dard at 6 mg./l. or higher. But a few states such as Con administrative regulation. Several stales, including Utah and necticut, Maine, Illinois, Indiana, Massachusetts, Virginia and Maryland have legislative studies under way. Wisconsin require 2 mg./l. or lower. ; The incentives take a variety of forms. Most common arc Other standards-notably turbidity, taste, odor, color and exemption from personal property taxes (e.g., Arkansas), fast solids-niay also be important, depending upon the nature of depreciation (Arizona), exemption from ad valorem equip the chemical plant's waste effluents. These standards also ex ment and structures taxes (Connecticut), exemption from lo hibit state-by-state differences. Moreover, they are generally cal taxes for staled period of time (New Hampshire), less specific than the straight numerical DO standards. operating loss deductions (New York); credit against state in Although chemical plant site experts see little point in come tax (Oregon), "running from tough standards," the criteria do make a Quantify: The large chemical complexes now in vogue difference: Plans for two nonferrous metals plants in Puerto make watcr-and lots of it-a major site criterion. The cooler Rico are now on the shelf, because of standards that call for a the water is, the better, for it can reduce the investment in 4.5 mg./l. DO. no wastes that interfere with the esthetics of heat-exchange equipment. Occasionally, plants can manage the waters and other specifications. on ground water, but usually surface water is required. That No compilation of ground water standards has yet been means location on or near the big. drought-resistant rivers. published. Ground water standards may prove important in There are less than 200 rivers in the U. S. with minimum the future as companies arc forced to use costly deep-well dis flows over 50 cu. ft. per sreond (OF Oct. S, '68, pp. P4-P.V- posal for wastes. Availability of ocean waste disposal services For companies whose plant needs at least 100 cu. ft/second, is also looming more important. the list numbers only 150 (excluding Alaska). Sea water is Waste Cost.: The price tag for pollution control is high. A generally avoided because of high equipment corrosion costs. recent FWPCA study on the organic chemicals industry esti Piping water in is expensive. Duval, now opening a 1.5 mil mated thul water waste-treatment facilities can increase in lion tons/year sulfur mine in the arid Northwest area, was stalled capital equipment costs 40% or more. Between '69-73, forced to install a 36-in., 38-milc-long water line and a 40- the organic chemical industry would have to shell out $182.5 million-gal. reservoir. Cost of the water supply system hasn't million to remove 10% of its biological and chemical oxygen been disclosed, but it is estimated that the tab was at least sev demand waste and 65% of its suspended solids. Removal lev eral million dollars. els of 83% 13% and 71%, respectively, for biologic oxygen de The adequacy of domestic water resources in the year 2000 mand, chemical oxygen demand and suspended solids would has recently been evaluated by the Geological Survey. Na require $242.6 million, while 98%, 30% and 89%, respectively, tionally. projected demand will be 173% of potentially as would up the ante to $608 million. sured supply. Only in three regions, New England. Ohio, and Cleaner Air: Establishment of air quality standards is not the South Atlantic Eastern Gulf, will future water require nearly as far advanced as are water standards. The National ments be easily met. Economic growth may be handicapped Air Pollution Control Administration (NAPCA) is still desig in nine regions: Eastern Great Lakes. Lower Mississippi. Up nating regional air control regions. At last count, 16 regions per Missouri-Hudson Bay. Lower Missouri, Western Gulf- had been formally designated and another 41 had been pro Rio Grande, Pecos, Colorado. Great Basin, and Central and posed. NAPCA has issued air quality criteria and control South Pacific. FUR 004026 79 WATER PCB-SD0000071361 For the first time, a summary of water quality standards set by all 50 states. pH Allowable Tmpr#tun* (*F) allowable Increase Range Deviation Minimum above ambient DI*k> oxygen (minimum. mg./l. or %) Other RequIrefTnmts Alabama 6.0-8.5 1.0 90* (24 hrs.) 93*(ny6 hr*.) 93* (cooling water) 10% 2.0 at 6 ft or Radio activity, Color, Taste and Odor, Texlc &ub*tances: Only In -- _ mlddapth IT lata amount* that would not render water* unaultabU for Industrial ___ ^vianlOft cooling and proceti-water supply purpota*. Solid*: Free from waata malarial* that cauaa unalghtty or putraacant condition* or Intarfara dlractly or Indlractly with Indutlrlal uia. Alaska 7.0-6.0 o.B 70* 5.0 Radioactivity: Not to exceed limit* of PHS Drinking WaUr Standard*. Turbidity: No Impoaad valua* that would Intarfara with established laval* of traatmant. Colon Trua color leis than SO color unit*. Tests and Odon Shall not unraaaonably Impair esthetic consideration*. Solid*: No dissolved solldi above na tural conditions causing corrosion or scaling problam*. No visible evidence of othar hotting solid* or aludga deposits. No Impoaad a+dimant loede that, would UUrfara with aatabllahad traatmant laval*. Texk BubrUnce*: Chamlcal constituents should ba balow concentrations found to ba of public hathh algnlhcanea.* Arizona 6.6-8.6 0.5 S3* 6* -- fUdlMeHvltar; Not to *.! 1/30 of lh MPC- vtlu. e'**" for continuous occupational exposure In NM Handbook 69. Turbidity; * 50 JCU (straama); 25 JCU (lakes). Colon Free from waata mata- rials In amounts sufficient to change existing color enough to Interfara with Industrial ut or to create a nuisance. Tart* and Odort Free from wait** In amounts sufficient to produce enough taste and odor to create e nuisance or Interfere with Industrie! um, Solids: Free from waste* that would be unsightly, putrescent, odorous or In amounts that would Intarfara with Industrial use. Toxic feibaUneae: Free from waste* toxic to human, animal, plant or aquatic life or In amounts that would interfere with Industrial use. Arkansas 6.0-9.0 1.0 (24 hr*-) 95* S* 4.0 (average Radioactivity: "Rulet and Regulations for the Control of lonlilng for any cross Radiation," Arkansas Board of Health, apply. Turbidity: No die- . taction) tlnctly visible (nereis** due to wastes. Color: Shall not be In creased to tha extant that It Interferes with Industrial use, presant or future. Taste and Oder Must not cause offensive odors or otherwise Interfere with InduttrUi use. Solids: No dis tinctly visible persistent solids, bottom deposits or eludge banks due to wastes. Texlc Substance*: Must not ba present In amounts toxic to human, animal, plant or aquatic Ilf*. California 6.6-8.6 7.0-8.6 (Coastal waters) 7l.6**(freh water) Non# that would cause ecological change or harm aquatic life (coastal waters)4 6,0 Coastal water: 5.0 (unless naturally lower) Radioactivity: Shall not axcaad 1/10 of tha MRC valua* given for continuous occupational axposurs In NBS Handbook 69. Turbidity: Fret from wastes that could altsr water's existing turbidity. Color: Free from substances attributable to waetas that produce detrimental color. Taste and Odor: No substances that Impart foreign last* or odor. Solids: Dissolved solids In fresh water must not exceed 300 mg./I. at any time; annual mean: 275 mg./l. Settieabie solids must not ba able to change nature of stream bottom or harm aquatic environment. Toxic Substance*: At all times free from concentrations harmful to humans, aquatic !He or wild or domsstlc animal*. Colorado 5.0-9.0 -- 93* -- 3,0 Radioactivity; Not to exceed 1/30 of the 168-hr,-w*ek values In NBS Handbook 69. Turbidity: Must not Interfere with estab lished levels of treatment. Color. Waste* present must not cause appracleble change In color or Interfere with Industrie! use. Testa and Odor: Free from wastes that causa odor or ap preciable change In teste. Bofld*: Free from wastes that are unsightly, putrescent or odorous or would Interfere with use. Taxk Substance*: Free from wastes In concentrations or com- binatJons sufficient to harm human or animal life. Connecticut 6,0-9.0 Dtltwir* 6.5-8,5 None unless It does not exceed re commended Hmfts for In dustrial use 2.0 5 50%4 or 4.0 * Radkectivtty: Umha to be approved by appropriate elate agency. Turbidity, Color, Tatte and Odon None In such quanti ties that would Impair industrial uss. Solids: Limited to small amounts that may result from dischargs of appropriately treeted wastes. Teidc Substances: Free from chamlcal constitu ents In concentrations or combinations harmful to human, animal or aquatic life. Radio activity: Alpha emitter* limited to 3 pc/l.j bet* emitters, to 1,000 pc/2. Color, Taste and Odor: None in concentrations that cause color, taste or odor. Solids: Free from unsightly and malodorous nuisance* due to floating solids or sludge de posits. Toxic Substances! None In concentrations harmful (synargiaUcalty or otherwise) to humans, fish, shellfish, wildlife or aqustic life, Fkxldl 6.0-8.6 1.0 -- -- 4.0 fUdUUort: Grow bt--1,000 pc/1. (In .bi.nc. of Sr-90 n<, alphs amltteri). Turbidity: 50 JCU. Color; Must not render water unfit for Industrial-cooling or process-water supply purposes. Tatte: Must not render water unfit for Industrial use; phenols 0.001 maximum. Solids: Dlstolvad solids must not exceed 1,000 mg./l.; monthly average: 600 mg./l- Must be free from floating wastes that are unsightly or deleterious or other wastes that settle to form putrescent or objectionable sludge deposits. Toxic Substances: Fres from wastes harmful to human, animal or aquatic life. Cu, O.S mg./lj In, 1.0: Cr, 0.05; Vb, 0.05; Fe, 0.3: As, 0.05; F, 10.0; Cn, none detectable. FUR 004027 eo WATER PCB-SD0000071362 '*' l'- .:. ' '" '''pH/Ulpwibia Tamparatur* (*F) aliowabla UCTMM Haiti* Oatlatioa Warimuat bova amblefH DiuohrH xygan (mlnlsmw m*./l,ar*) Other Requirement* &KKJ .oi* . -- , . 93.T r ,'-r; ICTfebovt intake) ' ' 2.6 llafioactfvtty. Must conform to rtsts sUtulss. TwrbWTty, Oo^or, . 8^0 (daRy veT* Taft* and Odor Fraa from waste* that esuts obfacttonebt* eon '**/ : dttwts CX lntri*ns Wtth industrial ut. *fW^ Fra* from wssUi thft ar unsightly, putresoant or otherwlM objedlonsbls or would Intsrfsrs wfth industrial um. Taidk Subatanctuc ho wartat In oonoantratlon* that would pravent fHh aunrival or tntwfsr* wtth Induftrtal um. v.4tf V ;vft*4W*tMbrt ^ Mtea*d of tha valuaa given by MBS .-V - H'*;;':!"'^HandbodK W. TurWdftrt Fres front toll particles from acoalon ; caused lay land development or aaricuttural um. Test* orvd Odor; *. , Wartav attar dilution and mixture, must not JnUrter* wtth In- imji tubftanoac tFvra**a from tuubbiitta*nnceee* iIn aon- . , ' P.fJ -jSrfi-v-, wtffiifl ufntnafuvlftlabtoie ffwormIanadu-asntriimalant,u-o.r-marina Ufa or that r.OftVW gjuMFT V.\' ' Indians BXbtj) ~ . ,V*B- gF-i? .' >' -: ' i:j -' i' ` "V'V'. - ,' J> X'\-f ` i si. :y',: low* -- V. < m--: K* f`l*' **.*1V.,"' -J0 * -- #0* p*tVi.r' NNAS r^JJ- . hv . ' : r- * *iCi; " ; V'1.-. ' . SVhr lOvcUy W.:\- >: h.: -r e,o-o,o -- 06.- . . o>* \ :&r* kVi-'yrM'y(** f-;: . 8,4' i7o9r%iit &(a>t a*4-JtafieiactfotYyiuHrboidt htyo: afxtcowaodbfBamctHlo*naobfl*'62turPbUidBityDrtihnkaitng"caWn atbear r ^rRced kj'.i.Pdnt touroa. Sotkki No floating or aubmirgad mat* ' ! *' ' a', i *w iludoe'deposits that eouid advariaV affact Induatrial i--v S J^NuTaak JWbfUhaaa: Ho wmIh of othar than natural Origin f x.Oanddfttrrtlona ot public haafth ilgnlhcanca or that oould . . ,|Mv*fWtyjdffagt Indurtrtal u*a. tS/# ` Color, Tt and Odon Fraa from wastaa that produca odor, P* CfOf lj hr*, odor or taata In such a dsgraa aa to craata a nuisanca. IsUc *a-nr. fnxn florllng waatas that Mttia and form unslghtty. dalo- . # r ' tagout Of.putraacant dapoalt*. Torfc lubatancea: Fraa from ' ' wiata* In ponoantrations ar combinations harmful to human, j **;//.qutte w*. yarma) * Os4*r, Taabs and Odoc Fraa from waatss that produca color, tarts or odor In auch a dagraa as to craata a nulsanca. 9o*d: phrtohrad aollds mutt not axcaad 1,000 mg./l4 monthly avar.pga. 760 mg,/l. Mutt ba froa from unsightly, putrascant, data- _ ' tariovt or otharwfta ob|actiontbl wtttat. Tatic tubttancca: ' 'Tros from wastat In ooncantratlona or combinations harmful to human, animal, plant oc aguatk Ifta. Wk, T.*bl and Odor Fc from w.iUi th.t product color, t.rU or odor tn tudi d*fcn to b* d.trlov.rrt.1 to IndurtrUI in,. tUd>l FrM from fto4tlng wi*(m In cmounU ttial would b* ' urtrlsfrHy of d*tt1oui or othr wut.i tht c*l, to form .. putPMCorit ,dr 'obJwSJotHibl. iludpo d*Do*lti. Tdc Mntww Ho wtttot Vi ooooKltnthru *r oOfnWn.tlor\i d.lrlmonUI to humcn, nlrmil of oqu.Uo lift or to Vdurtrl.l um. 4.0* Turtodfty;' No IncrMM tod ciuh, cubtUntlal vl.lW. corrtr.rt wtth rwluml pfMirir>c or tot It dtlrlmtnltl to Indurtrttl uat. Color: Dltehtrp.1 ol oolor-produeino tubdnc llmttod to corvMrrtntkmt not ddrlm.ru.I to Induttritl um. T.tt. and Odor: CoomoIration. Ilmltod to tooM that would not rwauh In nottc*abta oflanatva odor, or otharwlM Int.rt.r. with Indu.trial uta. ' VotWc'frw*'.from'noaUng dabrit or matarial In amounta that .would b unalphtly or d.trimantal to Inductrlal um. Toric ftuh* atsncoc Follutional aubatancaa mutt ba mtlnlalnad balow cart oon(ration. datrimantal for Indudrial uta. Color, Tatt* and Odod Wtttat mutt not craata a nulttnca. oJWc tMaaolvad aollda mutt not axcaad 1,000 mt)./I.! monthly avarapa: 740 mp-/X. No ftoatlnfl waataa In unalohtly or daw. tarioua amounta; no othar wartaa that Mttia to form putraacant or cbjactkxiaMi aludpaa. Taric tubabuwaai No wa.taa In coniooritratlona of oomblnatlotw harmful to human, animal, plant or aquatic Ufa. . 90% Radtoatttdtyi Spactoc limit, aat for all radloactlva laotopaa ra . iatMd a. aratta. oft4c Nona that would produca ftoatlnc ' maitaa, aludpa banha or badt on bottom, altbar organic or In organic, Toalc fojbatoncaa; No waataa In oncantrationa or oombln.ttona barmfut to animal or plant Ilf*. 2.0* FUdtoactfvftyt Not to axcaad *42 PH3 Drinking Watar Standard., Turbidity, Color, Taata and Odart Fraa from wa.tai that Impart turbidity, ookw, taata or odor or Impair (ndualrial um. Sohd.; Fraa from oludga dapoalta, aoiid rafuM and Boating aollda. Taric Jubatanoaat No chamlcal oonatltuanta from waata wurcta harmful to humana or that advtraoly affact Induttrlal um. 4.0 (unit at Caior, Taata and Odon Fraa from waata matariala that changa oxl.ting color or produca tarta and odor to auch a dagraa a. to Croat, a nulMnca or Intariara with Inductrlal uaa. Solldat Fraa from waataa that float aattla to form dapoalta. craata a nulMnca or Intariara wtth Indurtrial um and art unalghtly, putraacant or odoroua. ToxJc Sobatanoaa: FrM from toxic waataa that Intartara with Induttrlal um or that ara harmful to human, plant, animal or aquatio Ilf*. ItadloactJvttyt Nona In conoantration. harmful to human, animal or aquatic Ufal Turtrfdftr, Calaf, Taato and Odart Non# In ccncontratJona that would Impair induttrlal uaa. Saitdat Nona al lowed axcapt that which may rtautt from tha dl.ch.rga from waita-troatmant fadlltloa providing appropriata iraatmant. Toxic Bobatanoooj Non# In conoontrationa or oomblnatlona harmful to human, animal or aquatic Ufa. FUR 004028 WATER PCB-SD0000071363 620fr00 and -tftsi |t)Jinpu| J|r^uj| pjnoM law tuofitt/tq .ujoo u| jo auojo buon ,`t+MJrjaq/vf o^ioi o; tjqrinqjj) -j puo jq)|A XftpaaJ *j }*%# rypodp aflpn! >o *po *jqo .a|U *o 0UJ1O^ H ^*n |*ljq*npu| JO* afqninaun j]im IU0n*i)iqUX>3 UJ JO HiOfO )tq) MqiM pOJOfOO &N w'p'2 oSeuoab) ,g .98 -- 9-ar-0'9 `t|*uj)u *q*y, '*uujnq 0| o|*cq nunouj* on ;aoo*)>q>>s pproj. 'Ujouoq jo aajpadoJd jaya AyutoyiuBja )iq) )uauj|paa puo jpgap Jo ipjfoa 0unou }qtuo|p^qo on `anopouqo jo iquo|p*(qo X||tO|Ym* aja jaq) 'uj&po jun)*u p uq) jaqio *uopo on uopo *1X `uoiVlpPoa |q*Jj*opun Uf ]oo pincxts *aou*/*4ddf |tJn)ni ipp* >aJ> ooo *|qj|A jff)ur)*qna atnaa )ou jjrys yCupfqjnx *69 ^ooqpuaH SflN U| *nj*A *jq-ay jo Qt/t w4l J*4*Jfl H>N ^t*rPnpM rpiq opanba o) tnuaiupiap *q jo futtumj pay* Pt^oM )ttfj *uon :**our)*qns :>f*X *rp|q 5j)*nb o) |t)uaujfJ)p jo tuovunq ) BAjsutyo ui )y) buon ;>opo a->*x `*1+0 *aJoqa Ouojo papaodap JO J)M U| *iqaaoj>ou auN PiK>tt 'X^pjqJr>X tUO}pru|qujoo jo Buopajiutotioo opro) u| *uon .***9ur)Aqnf oprox `Dunovua {qauopoafqo uf aytodap adpnjB JO tpjjoa 0U|iu ON ap|)03 t)unouj ^qtuo|p4(qo u| uon uopo P^* *)*X 'AWVnX uofyiHOd anro pjnoM )i# puaiuap ua/C#o ou an im x> Jfr)tM 4ui jo a;jr>uo4 )0U )nw (.X#oj dn).g / 'a l)MPin*wjo#jna*j)*n)tiu4#i aojou( on 9-8-9-9 P3|XM MM Gcjniw ;un),X8 -- (lunnu **un) 9'8-9 9 XM-Wf A)J (jwmiu trofun) . 9*8~Q*9 Jm>iluitHM*H `an iryunpui 411* *j*pi}u| jvi jo am Ofjanb* jo ;ua)d 'j*uj|ua 'uaujnq oj o\no\ auotiaufqweo jo tu0f)tj>u9ooo uj f\9WM ujoj) uj ^ouv}qn$ 3P*ox 'nn jjnvnpo| mjM ajp)U| jo OJopo jo /|iqB)tun q p|nOA nunouit Uf moqap jo a^futq aflpnii uuo| cq *\M** )tq) uiiim J*M)0 JO Bujjtoy ujoj| mjj :apnof `jiiM *41 u| jopo jo ttn oonpoJd o\ jo 'nn {fjl*npu| q>|M *j*^>*)Uf jo K>uMjnu a i)tJ3 ay qfinoma jojco jo Xypjqjn) 0u))t)xa afiuaqo o% jutpiyna r>unouja uj tuoj) *+ii uopo pua nax 'J*tO *4lPI4*U `tS ^>oqpuH S0N --ny$A Ji**M-`j4-t9i q> >o oi/l <>l P*K^H lAfAfpojprj| Qdos^unr q*9 0*9 Onu)M) (jaujvun*) jyu S*9-VZ ;uafpauj j*nuuy 9`8-9*9 ptA*N >*o japuftpuf jo# *K}nin -un J*)tM japuw pinoM lql auoi)vufqujoq jo uo}iaj>uaouoa uj uon m^ur)qns opol rn |t^nnpui oj >r>opii*p jb jo qoq l*odp yujjfrd )m ipijo* *i*m on '*oJno >Ufod XU tUOJ$ (T/'fiuj 001 IfiiJfO *J3Uf SOZ wrql fcjouj *I/`0uj oOfi't poooar# y>u >nuj p|fO* paAjoatja `I/'Puj 100*0 !n |pinpu| jo| iiitaftb j)*m apufiap piooj* ;rqq cpjnoujt um **q uopQ puo qi| `tuopipooo aour*|nu **i**j3 }if) jW*uj p *3u*pp.* on {JOt0 '1*^1 iruxjoii *Aoq jooj %oi uvq| #jouj oM s/jpfV'U *>5. *r^jq*N l* *>*1S *Cl>* *V*I) **><> jnDay MU*H |*^BojO|p*y uuojuop i*n^ *jty*{ptotpm XtauaAp* k*j lamu >u*jd thidouiy ^ou`Hriflqn|B^i>oiapni*pXu| pyo )uuj)vji py pul *p/|Of *tq4{4* jo rjufrujjpoa ou >n jap) tnpuj a% nopi)p a-iuroiuv uj vyvodap *0pr>| put tpne* 0uf qaoy on `ijKua >o \\\0\* #o *nia 04 Aiuyo )ou uofpp uoo U| pouiiu|ui q )|*qi j}m u&PO puo ivx 'JO^oo *iu4jj jaw) )o j*a| p*4*rt<?P jou inM ^upfqjnx pjpor)9 JiM Bupiupa SHd Z3, <H K>H . C) 9 r06 0*1 O*0-9`9 o^fWjqtN Suiip uAp on fl'O 9`5-S'9 U10dM t I ; Tiy `H1PU* 1Jli *u<urH| .,, t"1-.'- ' o* afioi jo Mn |p^npo| o) i*>uuiyip yxi 0(i4uouog' ;T r'~ ' ofiox r>un<nu *no|j*|>tip jo /|)i{0|iun oi *ift*inui''.' ,/< Bun*otf jo ||od*p S(Ufljou| jo S|ufijo |()*one>o Ofj P00* " ' ' ". nn i*|jjnpu| iflj* J*p)U| MpoHpo jo uopo *Aj*ujo |q . . . -oiijJ u| |iJ *xi ptnoM Infl uoflj|usuoo o p*fluifj - ' ' pu* 1 `on |tpiuipu| qflM j*p>p)| jo >o puji*<m* .' ;:: junioil ifl|M |*Jfl/00 nq|(A |flunjqn unto >ou l*nut W^M ' 1 , , 1 U0JO3 T/sd C :9ZZ-r* p|0*ia T/l 01 (*|UJ* .' - ; .. pu ofrJS jo *ou*? uj) 'j/od 000'I :rj*q wjo -tAB0*oiMl'. ' . (uoaoos oj9 jo SJ*A)^8 0'6~9'9 ptVHt|W ifll ofltnbo js ifiujut 'Uiumfl cq jnpjjjtti looitnjjqujoo jo woflffluKjuoo uj mjim ojq rtou>)tq)ri op*/ iljiodtp |uMj)jid jo *fqauoflo*{qo 'u>op)tp 'XflqJRMjjo UJJO) oq |UH >nfl )I1M Oufltoy uxu| jj a min 'i/'Pii Oil dJ* Xnfluoui fl/'Bui Oort pnn Jod' lmu PU0*,' pA|0*Ja nppot >ou>>inu oqtmjo oq n tqono lifjgM; jo jojoo ooopojd qrvfl M|u uxu; mjj qJopQ poe ' -----" ` ' 'ohooW"'flii.'^-VpoJqrtS' SIfi!/-/ PUP* p*pu*dtn MrwntunooVqol'uHon|HJ0*|0oUK|pUJ >puo Bufliou qur>i;iu6)q **>Ppo j*0j*>JJ)hu.tptnofipo'jo*p`atuoJXflJjpoool*Ioo*jojirKoj; - ;< J1. ;U V^'|VV* '\4**./V .S8 O'X J'W9 JV O'fr-Q'9 rvMouu||M ***n 6* ad^jnfl)! * \ ` au>oo^q j jo *j )m) Moy) r*i *uonJVrtoo> 0^ *- '. *vi*|';.;, .'*** paiiuin :wxj4qr>f H*x `"n |tp)inpu| ifljM auaptuq pinoM *'* . . ** 1*4) uijutnb u| cytodap *fquo4c>fqo jo fp[jo* flunky erf^ *[/`0UJ 009 *0*j*a* X;Lf}UCUJ f x/'Oui paaoxa )ou jsfHU *p||oa * p*A|oa|Q ;*pp^f 'an {>yisnpu| cq ooijnfu) auiooaq Xwu jo j i4) ^*A*| uopo 1X >n |tinr>po| qyja ajapajuj ., cq majo^na aamjuanb u| jotoo jo Xyptqjn) jjmauun Ofqmofi..!' .*. .rv- . on >ai3 `AjPtqjnx tpaya nrpa)aiap uo ajqaj|A t| aourqnu )Uoa7 ` ' ' ` " ' ucHVruuo>ijf u*4M paqtnqnfo *q cq ipjrpuiqg jCUaffoaofpaN '*i<3 H*nourj ' ,,Q| -- . ' 9*0 fl'O-fl'B ~' ~~ (9&A'T/*fua ia|qujaaAO^a uimupiaM uj)ai**fl o#u)# _ Ru^ujBjjnboy jon>0 . . . ' uAxo oiqpjROji* Q.) 6Jn;eJ0<iuJ0X ' :,> - spjBpuBjs Xpienb * < *: , ' 1 , : ; .i . WATER PCB-SD0000071364 Water quality standards !1'7\ . ..-.f Ly.' - . C*Y'' r.' ' ' ' pH WlowM T.mpr*tur,{T)HowbU tncr**a Jterrfe Caviatlon Maximum above ambient hwlh Csrbflri* Normal v * lor area, & .TV- f'- 5jTn" 96-* 7* oxygsn (minimum) mj./l,or%) 3.0 Other Requirement* Calec Mutt not render weter unfit for industrial cooling. SeiJot; Muit net fl.r dilution and mlxtura, m.k. w.Ur unfit (or Indui trial coollno. Tokle Subtt.ncet Mutt not m.k. watar unfit (or tnduatrial cooling. >: swamp* ; Horth DkoU 6.0-9.o 0.6 93* .% v,\- ; ' /- 5 10* 3.0 Radloacttvttjn No dltchtrg* allowad unl.it malarial, an-raadlly 6.0 (lor 16 hr*J<i*yy . tolubla or dltpanlbla and of awntHJa. tccapUbla to atata haatth dapartmant. Color, Taata *nd Odori No waataa that color watar or raautt In obfactlonabla odor* to * dagraa that Impair* Widu*- trlal u*a. Soltda: No unalghtly floating waataa (hat would ad. varaaty aflaet Induatrial uaa or waataa that aattla to form pu- tnacant or objactionabta dapotlU. "Totk Subatancw No eon- oantntkma or eomblnatlona harmful to human, animal or guatic Rfa. OhV# B.o-9,0 I'l;" r^' .OlrUhOBM 6.6-6J5 95* / 98* iiS (dafW flvsrsge; 6* 4.0 ,. Or*pofl 6.6-9.0 V.- rinnorfmnl* e.o-9.0 . lv 2* (wily H w.t.r 70* or Ur**) 6.0 93- r/hr. 4.0 b.O (da By svarags; Color, Tait, and Odor Frat from waataa that produca color or odor to a dagroa that craata* nulaanca. toHdar (Xciolwd aollda mutt not axcaod 1,000 mg./l4 monthly avtraga: 760 mg./l. Muat ba Irw from floating or othar waalaa that aattla .to form putn^ant Or objactfonabla dapoalta or that ara urialghtty or dalatarloua. Totk iubitanoaa: No wait.. In corvcantnatlon. or eomblnatlona harmful to human, animal or aquatic 8fa. R4loictivftyt Average concentration at point* of controlled relaasa shall not exceed State Board of Health Radiation Pro tection Regulation*. Turbidity: None that cause* visible c*ntra*t with future! condition*. Colon Non* that H persistent In con centrations detrimental to Industrial use. Teete and Odor: No concentration* that would cause offensive odor* In vicinity of water or otherwise Interfere wtth Industrial use. tollds: Free from floating debris, bottom deposit* or other materials. Toxic Bubstancas: None In quantities tnat maka watar toxic to human, animal, plant or aquatic Ilf*. Radlatien: Shall not post external hazard. Turbldlty:5dCU above natural. Color, Tette and Odor: No objectionable discoloration or conditions asthatlcally offensive to human sente* of taste or mall. Sofld*: No floating solids, organic or Inorganic deposits Injurious to industry. Toxic Substances: No condition* Injurious to public health. Color, Taste and Odor: No wastes that produce colors, tastes or odor* in amount* harmful to Industrial use. Solids: Dissolved solids must not exceed 750.mg./l.,* monthly average: 600 mg./l. No floating wastes or substances that settle to form sludge In amount* harmful to Industrial use. Toxic Substances: None In amount* harmful to Industrial use. ' f&KJ-d. Itland 6.O-6.8 *-- I?.-;' ..V 4* 3,0* Radioactivity, Toxic Subatance*: No concentration* or combine* 6.04 (16 hrtf/ tlon* harmful to human, animal or aquatic Ufa. Turbidity, Taste day) and Odon None In concentrations that would Impair Industrial us*. Solid*: No solid refuse, floating solid* or tludge deposits. South C*ro1ki g,o-j -- : ' (tw.mp.) f' V ' ` 93jr* itti Dftkvta l.o -- 10** |r'r. ; T*nnm# 6.0-9.0 l.o (24 hfO rv. > \ :. . m* HSU: *7hr. J.O* Z.6(*wmp) Turbidity, Color, Taste and Odor: Free from wastes that change the existing turbldhy or color or that produca taste or odor to i*ch a degree as to causa nuisance or Interfere with Industrie! use. Solids: None from wista sources in amount* that ara un* slQhtiy, pulrascant, odorous or that ciuu a nuisance or Interfere with Industrial um. Tonic Substance*: Free from watts* Harmful to human, animal, plant or aquatic Ufa or that Interfere direct!/ or Indirectly wtth Industrial use. -- * FU die activity: Nona permitted In water unless raadlly soluble or dispersible and In quantities allowed by federal or atate agencies, Color, Taste and Odor. No wsstes that product mate rial dlsodorition or undesirable odori. Boltd*: Dissolved aotlds mutt not exceed 1,000 mg./1. No waste* producing floating solids, *Judge dapotlU or othar oflenslva aftacta, Tdc Bub* stances: Nona In concentration* toxic to human, animal or aquatic Iff*. * Enough to pro- RadlaectJWtyi Nona that could adversely offact Industrie! uaa. vant oHan.Hre TurbidHy, Color: Nona In amount* or concentration* that could condition* fKrt be reduced to accaptabla level* by conventional traatmant. Taste and Odor; Nona that would result In UlH or Odor that would prevent u*a for Industrial processing. Solid*: Olsaolvad aollds mutt not exceed 500 mg./I. No distinctly visible solid*, bottom deposit* or sludge bank* that could be detrimental to Industrial use. Toxic Substances: Nona that produces toxic condition* that would adversely affect water for Industrial use. 4.0 %; - _ ' . Radloectivtty: Regulated by Taxaa Radletlon Control Act and Tax** Roultiona for Control of Radletlon. Turbhrtty: No subatantiel IncreaM due to watte*. Colon No ubUnttat visible contract wtth natural appearance of receiving water* after weatet receive bett practice! treatment Taart* and Oden No concentration* that produce offensive odor*. Betide: Dissolved solid* mutt not exceed 1,000 mg./l,, unit** water used only for ooollog. Must be eesentielly free from floating or 4rttl*aWe suspended solid* that would adversely affect Industrial uee. Toioc Subetancee: 6hall not show scut* or chronic toxicity to humane, animal* or equatic Ufa to such an extent iu to Inter* fare with Industrie! use. BA FUR 004030 WATER PCB-SD0000071365 Water quality standards pH AHowibla Tempflrtur*('f)t!fowabl r* IncreaM R.ng. Deviation Maximum abova ambient Dissolved oxygen (minimum mg./l. or %) Other Raqulramant* Utah .6-0.0 -- -- -- -- Radioactivity: Shall not excaad 1/30 of MPC values for con tinuous occupational exposure In NBS Handbook 69. Turbidity, Colon No wastes In amounts that would change existing turbidity or color enough to cnat public pultanca or inlrfr with industrial use. Taste and Odor: No wastes In amount! that would produce Last* or odor. Solids: No floating wuUi that era un* tightly* or fhet Interfare with Industrial uaa; rvj watUa that tattle to form unsightly or odorout Kludge or bottom deposits. Toxic Substances; No waatac (h concentration! or comblnaliona toxic to human, animal, plant or aquatic life or that would Interfere with Induitrlal um. Vermont 6.0-8.8 -- Ij.TO* d.tf <16 hra.y Radioactivity: To b-* approved by appropriate ataU aganey. Turbidity, Color, Taita and Odor: Nona in concentration! that would impair Induitrlal uaa. Solids: No floatIno soiida, eludge deposit* or solid rafus*. Toxic ftubatanceel No chamlcal con* atUuent* In concentrations or comblnatlona harmful to human,' animal or aquatic Ilia. ' Virginia 6.0-9.0 (swamps as low si 4J) -- 95* (unless naturally higher) ' i.rNo audden , change* that 2.0* (dally ooulaharm aweragel aquatic IH Colgr, Taite and Odon No waitea that changia axlttlng color or produce odor to such a dagree at to create a nuisance or interfere with Industrial uaa. Sotlda: No floating waates that ere unsightly or create a nuisance or other waste* that tattle to form unsightly, putrescant or odorous deposits. Toak Bubfiance#: No wastes fn concantratlon* or combinations that would Interfere directly or Indirectly with Industrial use. W*lhllflton 6.6-S.6 0.6 70* t - 110/ 6.5 or 70% Radioactivity, Toxic Substances: Below concentrations that could (T-15 adversely affect Industrial use. Turbidity: Lets than 10 JCU over natural conditions. Color, Taste and Odor, Solids: Dissolved, suspended, floating or submerged matter shell not reduce esthetic values so as to effect Industrial use. Wait Virginia Proem water: 6.5-4.0 Coo)In* t*n r.0-9.0 Wltcontln 6.0-9.0 -- Cooling walar; 6* Rata; ST/hr. (Dc.-AprJ Proce*e water moat parmH flh paaaaga 0.5 69* 21..00 (daily average) 1.0 2.0 (d.lhr avaragej l Color: Nona that it objactionabl*. Tart* and Odon No objection* able odors in vicinity of the water. Solids: No distinctly visible floating, aettleable or suspended solids of unreasonable kind or quantity. No objactionabl* bottom deposits or sludge banks. Toxic Substances: No concentrations of metadata poisonous to human, animal or ft*h life. Color, Teste and Odor: No materials producing color, lasts or odor In amounts that would create a nuisance. Solid*: Die* solved solids must not exceed 1,000 mg./I.; dally average: 780 mg./I. No floating or submerged debris or waste substances that would ceuso objectionable deposits In amounts to create a nuisance. Toxk Substances: None In concentrations or com* blnations toxic to humans or of public health significance. Wyoming 6.S-8.6 -- -- 4* 2* (for atreeme where temp, not over 70*) 6.0 Radioactivity: Not to excaed 1/50 of N8S Handbook 69 values. Turbidity: No more then 15 JCU above natural (when turbidity il 150 JCU or lets): otherwise, no more then 1054 above natural. Colon Essentially free of wastes that visibly alter natural color of water or impart color to vessels or structures. Taste end Odor: Essentially free from subtleness that would produce detectable odor at site of use. Solldst Essentially free from floating or Batlleeble solids that are unsightly or settle to form sludge, bank or bottom deposits. Toxic Substances: Free from toxic fubatances in concentrations or combinations toxic to human, animat or aquatic life. 6Undard rmrv.d from F.d.r.l W.I.r Pollution Control Admlnlatr.llon approval. , , ,_ 11- total cumulatlv. heat addition allow.d (rom unnatural wait* eource*, at any point throughout tha glvon atr.om ra.ch. T ' highest Cfib[fraviatlona"'pHS^-PubiIc Halffh Sarvtee*N&?^NatlonaTBureau of Standard*; JCU-J.ck,on C.ndl. Unit.; pc/t.-plcocurl par lltar. Source: Water OuaWy SUndard, ol the United Statai, Territory*, and tha DUtrlct ol Columbia, Am.rlcan Public H.alth Aa.n., Subcom- mKtaa oti Water Quality Control, and Engineering and Sanitation Section. .,, , u ,,, Note: Specific limit* for collform*. biologic oxygon damand, plant nutrlanta, oil, graata, acum, bottom depo*tta, peillclde*. tpeclllc eon- ducunca, carbon chloroform extract, eynthetlc detergent. not Includad. Borne autaa mat aUnd.rda for ..ch tr..m r..ch or rlv.r b.aln; In auch catai, table Ihowi least atrlngant requirement This reprint is an excerpt from the "Plant Sites, '69" report that appeared in the October 29, 1969 issue of CHEMICAL WEEK Coprriphl 1969 Mi (irmv-llill, Inc., New York, N.Y. This article may not hr rr/ra/mn/ tritlunil permission. FUR 004031 56 WATER PCB-SD0000071366 Monsanto Monsanto Company 600 N. Lindbarph ftoutavard St. Louis. Missouri 63106 Phona: I3M) 694-1000 ) ORGANIC CHCMICALS OM February 18, 1970' Dear Sir: Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (PCBs) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the parts per million and parts per billion categories. It is claimed that the PCBs found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. Products which are sold by Monsanto under the trade names of Arocloi 1254 and 1260 do contain chlorinated biphenyls. In addition to Arocloi 1254 and 1260, Monsanto sells certain functional fluids containing Arocloi 1254. These include Pydraaf 625, Pydraul AC, Pydraul AC - Winter Grade, Pydraul 540, Therminof FR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Arocloi 1254 and 1260 and formulated products containing 1254, we "wish to alert you to the potential problem of environ mental contamination as referred to in the newspaper and magazine arti cles. We would like to point out the following additional facts: 1. Products such as PydrauB> 90,135, 230, 312, A-200, F-9, 150, and 60, Turbinol 153 agd Therminol FR-1 and FR-2 are not formulated with Aroclor 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not been found in the environment and appear to present no potential problem to the environment. FUR 004032 WATER PCB-SD0000071367 -2- We have developed, and are now testing, new formulations to replace the Aroclor1254 and 1260 components in our PydrauP products. The new products appear to be equal in performance and to have similar physical properties. '_ We feel that all possible care should be taken in the application, processing and effluent disposal of these products to prevent them becoming environ mental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969, regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good manufacturing practice in the future may require that no product used by any company ' should find their way into waterways. We realize that you have marketed or may now market transformers and other electrical equipment containing dielectric fluids which include Aroclor 1254 and 1260. Although these fluids are sealed into such equip ment it is recognized that occasionally the fluid may be lost through leaks resulting from equipment misuse or equipment repair necessitating replace ment of the fluid. Since the dielectric fluid contained in this equipment is only an incidental part of the over-all unit manufactured by you, we are not notifying the purchasers of such equipment of the potential environmental contamination problem described in this letter. We do recommend, however, that you notify such equipment users of this problem. Sincerely yours, lb Attachment Donald A. Olson Director of Sales Functional Fluids Group FUR 004033 WATER PCB-SD0000071368 nin WEEK / OCTOBER SS, 1969 Environment technology data for sulfur oxides and particulate matter, will follow with similar studies for other pollutants. Once criteria and control data have been issued for a pollu- Thc huge water requirements of the chemical industry- tarn and control regions have been designated, a complicated now the nation's third largest user-make water quality and process involving standards, hearings and implementation availability increasingly important factors for site selectors. and enforcement plans will be initiated that can lake over a Legislation enacted in recent years has forced planners to pay year to produce standards. -. close attention to pollution control standards. So for, no firm sulfur oxide or particulate standards have All 50 slates have had ihcir water quality standards ap emerged. But NAPCA's criteria for setting the standards sug proved entirely or in part by the Federal Water Pollution gest they'll be lough. The oxide criteria report, for example, Control Administration (FWPCA). Recently a statc-by-slatc emphasizes that there arc deleterious effects to man at con summary of key standards was pul together for the first time. centrations as low as 0.04 ppm. Surprisingly, it was not the FWPCA that did the job. Instead NAPCA's control data reports present detailed appraisals it was handled by an American Public Health Assn. (APHA) of various methods and equipment, along with estimated subcommittee headed by TVA Health Director F. E. Garirell, costs. As in the case of water, the costs will be high, although assisted by the APHA Engineering and Sanitation Section. A some pollutants-mainly sulfur dioxide-will have recovery portion of the study, covering standards for surface industrial values. NAPCA is sponsoring a number of research projects water, is summarized in the tables starting on p. 80. to improve technology. Pollution control is being spurred hy Contrary to widely held opinions, (here is considerable financial assistance programs (mandated by stale law) now variation in state standards. Take the dissolved oxygen (DO) operative in the following 28 stales: standard, for example. Minimum allowable DO (as milli Arizona, Arkansas, California, Connecticut, Florida. grams per liter or percent saturation) is the single most impor Georgia, Idaho, Illinois, Indiana, Maine, Massachusetts. tant standard to chemical site evaluators. As a rough rule of Michigan, Missouri. New Hampshire, New Jersey, New Yolk. thumb, a 2-mg./l. standard is considered to be one industry North Carolina. Ohio, Oklahoma, Oregon, Rhode Island, can live with comfortably, while a 6.0 mg./l. value is pegged South Carolina, Tennessee, Vermont, Virginia, Washington. "extremely tough." Wisconsin and West Virginia. California. Wyoming and Washington have set the stan In addition, Pennsylvania offers financial aid sanctioned by dard at 6 ntg./l. or higher. But a few states such as Con administrative regulation. Several states, including Utah and necticut, Maine, Illinois, Indiana, Massachusetts, Virginia and Maryland have legislative studies under way. Wisconsin require 2 mg./l. or lower. The incentives take a variety of forms. Most common arc Other standards-notabiy turbidity, taste, odor, color and exemption from personal property taxes (c.g.. Arkansas), fast solids-may also be important, depending upon the nature of depreciation (Arizona), exemption from ad valorem equip the chemical plant's waste effluents. These standards also ex ment and structures taxes (Connecticut), exemption from lo hibit slalc-by-statc differences. Moreover, they are generally cal taxes for stated period of time (New Hampshire), less specific than the straight numerical DO standards. operating loss deductions (New York); credit against stale in Although chemical plant site experts see little point in come tax (Oregon). "running front tough standards," the criteria do make a Quantity: The large chemical complexes now in vogue difference: Plans for two nonferrous metals plants in Puerto make water-and lots of it--a major site criterion. The cooler Rico are now on the shelf, because of standards that call for a the water is, the heller, for it can reduce the investment in 4.5 mg./l. DO, no wastes that interfere with the esthetics of heat-exchange equipment. Occasionally, plants can manage the waters and olher specifications. on ground water, but usually surface water is required. That No compilation of ground water standards has yet been means location on or near the big. drought-resistant rivers. published. Ground water standards may prove important in There are less than 200 rivers in the U. S. with miirfmuni the future as companies are forced to use costly decp-well-dis- flows over 50 cu. ft. per second (CIV Oct. 5, '68, pp. 94-95). posal for wastes. Availability of ocean waste disposal services For companies whose plant needs at least 100 cu. fl/sceond. is also looming more important. the list numbers only 150 (excluding Alaska). Sea water is Waste Cost,: The price tag for pollution control is high. A generally avoided because of high equipment corrosion costs. recent FWPCA study on the organic chemicals industry esti Piping water in is expensive. Duval, now opening a 1.5 mil mated that water wastc-trcatmcnl facilities can increase in lion tons/ycar sulfur mine in the arid Northwest area, was stalled capital equipment costs 40% or more. Between '69-'73, forced to install a 36-in,, 38-mile-long water line and a 40- (lie organic chemical industry would have to shell out $182.5 million-gal. reservoir. Cost of the water supply system hasn't million to remove 10% of its biological and chemical oxygen been disclosed, but it is estimated that the tab was at least sev demand waste and 65% of its suspended solids. Removal lev eral million dollars. els of 8.1%, ) 3% and 71%, respectively, for biologic oxygen de The adequacy of domestic water resources in the year 2000 mand, chemical oxygen demand and suspended solids would has recently been evaluated by the Geological Survey. Na require S242.6 million, while 98%. 30%, and 89%, respectively, tionally. projected demand will be 173% of potentially as would up the ante to $608 million. sured supply. Only in three regions, New England. Ohio, and Cleaner Air: Establishment of air quality standards is not the South Atlantic Eastern Gulf, will future water require nearly as far advanced as are water standards. The National ments be easily met. Economic growth may be handicapped Air Pollution Control Administration (NAPCA) is still desig in nine regions: Eastern Great Lakes, Lower Mississippi. Up nating regional air control regions. At last count, 16 regions per Missouri-Hudson Bay, Lower Missouri. Western Gulf- had been formally designated and another 41 had been pro Rio Grande, Pecos, Colorado, Great Basin, and Central and posed. NAPCA has issued air quality criteria and control South Pacific. < FUR 004034 79 WATER PCB-SD0000071369 Water quality standards I I pH Allowable Tmpritur CF)llowbl |^ Range Deviation Maximum abovInecaremabsieent | Utah 6.5-9.0 -- -- -- Vrmont 6.0-8.6 Dissolved oxypn (minimum "ifl./l. of %) Other Requirements Radioactivity: Shall not exceed 1/30 of MPC* veluss for con linuous occupational exposure (n MBS Handbook 69. Turbidity. Color: No wastes In amount! that would change existing lurhiriity or color anouQh to crsele public nuisance or interlace *><H\ induatrlal uaa. Taata and Odor: No wastes in amount! that would produca taata or odor, tolldt: No floating waatat that e/ un lightly or that Intarfara with Induitrial use; no wastes**thAt lattla to form umightly or odoroui iludga or bottom deposits Taale Subatarvcaai No waataa In concentration* or combination! loxlc to Human, animal, plant or aquatic Ufa or that would intarfara with Induitrial uie. . 5 0* (16 hr* / approved by appropriate stale agency. ' *' Turbidity, Color, Taita and Odor: Nona in concanlralions that would impair Induitrial use. Solldi: No floating solid*. sUidijc dapoilti or solid refuse. Toxic Subttancai: No chemical con stituents In continuations or combination! harmful to human, animat or aquatic Ufa. Virginia 5.0 -9.0 (swamps at low as 4.3; -- 95** (unless naturally higher) No sudden change* that couldharm aquatic IHc 1.0* 2.0* (dally average') ertateCotar, Testa and Odor: No wastes that change existing .-col-jr or produce odor to such a degree at to a ->r Interfere with Industrial use. Solids: No floating wastes that a/e unsightly or create e nuisance or other wastes that settle lo form unsightly, putrescent or odurous deposits. Toxic Sub Stances: No wactec In concentrations or combinations that would Interfere directly or Indirectly with Industrial use. Washington 6.5-8.5 0.5 70' 1-110/ 6.5 or 70% Radioactivity, Toxic Substances: Below concentretlons that could CM5)f adversely affect industrial use. Turbidity: Lass than 10 JCU over natural conditions. Color. Taete and Odor, Solids: Dissolved, suspended, floating or submerged matter ahall not raducr esthetic values so as to affect Industrial use. Wait Virginia Procass water: 5.5-9.0 Cooling water: 6,0-9.0 Cooling water: 93* (May. NOV.) 73* (Dec.* AP'.) Process water mutt permit fish peiioge 5* Rate: 2*/hr. (Ooc.'Apr.) 1.0 2.0 (daily average) Wisconsin 6.0-9.0 0.5 89" t i 2.0 (daily average) I i Wyoming 6.5-A.5 i i 4* 2" (for stream! where temp, not over 70") 6.0 Color: None that is objectionable. Taste end Odon No objection able odors In vicinity of the water. Solids: No distinctly visible floating, settleable or suspended solids of unreasonable kind or quantity. No objectionable bottom deposits or sludge banks Toxic Substances: No concentrations of malarial* pnlspnrm*. to human, animal or fish life. Color. Taete and Odor: No metarials producing color. Inslc or odor in amounts that would create a nuisance. Solids: DIs solved solids must not exceed 1,000 mg./l.: daily average: 7M) mg./I. No floating or submerged dtbris or waste ubslncn that would causo objectionable deposits in amounts to create a nuisance. Toxic Substances: None In concentrations or com binations toxic to hument or of public health significance. Radioactivity: Not to exceed 1/30 of NBS Handbook G9 value*. Turbidity: No more than 15 JCU above natural (when tiubidMy is 150 JCU or tan); otherwise, no more then )0% above natural. Color: essentially fret of wastes that visibly alter natural color of water or impart color to vasseis or structures. Taste and Odor: Essentially free from substances that would produce delectable odor at site of use. Solids: Essentially free from floating or eettleabie solids (hat are unsightly or settle lo form sludge, bank or bottom deposits. Toxic Substances: Free from toxic substances in concentrations or combinations toxic tu human, animal or aquatic Ufa. Standard reserved from Federal Water Pollution Control Administration approval. ,, . ,, ... f t - total cumulative heat addition allowed from unnatural watte sources, at any point throughout the given stream reach. T - highest occurring temperature lor a given period, In a specific stream reach. .. , . ... Abbreviations: phS--Public Health Service; NBS--National Bureau of Standards; JCU--Jackson Candle Units; pe/l.--plcocuresper liter. Source: Water Quality Standards of the UnHed States, Territories, and lha District of Columbia, American Public Health Assn., Subcom mittee on Water Quetlfy Control, and Engineering and Sanitation Section. . , , ... Note- Soec!f(c limit* for colllorms, biologic oxygen demand, plant nutrients, oil. grease, scum, bottom deposits, pesticides, specific con ductance, carbon chloroform extract, synthetic detergents not Included. Soma states set standards for each stream reach or river basin; in such cases, table shows least stringent requirement. This reprint is an excerpt from the "Plant Sites, '69" report that appeared in the October 29, 1969 issue of CHEMICAL WEEK 7 V69 Mtdrun- l/ill, htc., Nr if Yurt.. A'.)'. This nrtirlr may nut hr rrfrmhit nl iritlinnr !>n nn.\\I< 'll FUR 004039 06 WATER PCB-SD0000071370 N. T. Johnson 5:. Doui; tMO riCV I G. F. Fague - Detroit R.A. Garcia - Akron R. C-arnsworthy - Melbourne J. A.-.Heilala - Akron R. Irwin - Houston J. S. Pullman - New York J. J. Roder - Chicago R. Giles - Melbourne . J. R. r alien D. A. nT Ta_ 1i1l 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-PCB 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 situatioh where a customer wants to return fluid. The new reformulated products will be available within a month. We would prefer that the customer use m 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 1260 will be out of hi? 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 to our decision to eliminate the use of Aroclor 1254 and Aroclqr 126'0 in our Pydraul products. V/e (your customer and Monsanto) are not interested in using a product which may present a problem to our environment. 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 criticize our actions. No cne has forced us to make this fur 004010 WATER PCB-SD0000071371 2 change. We have done it to keep our customers out of possible trouble. . They should appreciate our effort, and stay with us as a customer on the reformulated Pydrauls. To make this change has coscus 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 e-e-uld 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 state in which your customers are locatedUse 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.' We 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. (Y/e have also attached a copy of the letter sent to transformer customers. ) N. T. Johnson lb fur 004011 / WATER PCB-SD0000071372 POSSIBLE CUSTOMER QUESTIONS ON PCBs PUBLICITY / /' Question 1 / ' ' ,// / What'articles have appeared 'on the PC3 problem? Will you send me cojne,s ? / Answer: In the U. S., newspaper articles have appeared in the San Francisco Chronicle on Fob. .24, 1969. the San Francisco Examiner on Feb. 25, 196^1 and the Hartford Times on Aug. 3, 1969. Numerous articles ware generated by the Wisconsin "DDT Hearings" in May, 19691 At the hearings, witnesses discussed the problem of PCBs as "interfering substances" in their search for DDT in the environment. PCBs, they said, produced peaks on a gas chromatograph'similar to the pea.ks produced by DDT. In r.o case was PC3 indicted at the Wisconsin hearings. Copies of the articles will be made available on request. Regional managers should contact E. V. John, Public Relations Manager Organic Chemicals Division, in St. Louis and copies will be for warded to the customer through the regional manager's office. in addition to the newspaper articles.mentioned al;ov<;, there have been, radio broadcasts. At the time of the San Francisco Chronicle a:u` Lxamine r articles, radios in the San Francisco area also carried the story. In Angusl,--the sports editor of the Hartford Times syndicated a radio broadcast on the subject of PCBs, and in Dec., 1969, the Canadian Broadcasting Co. (radio) carried an interview they taped with a member of our me dica'l department. Question 2 Were Ivlonsnato's Aroclors specifically mentioned in these ar-;i cle s ? If so, which ones? FUR 004012 WATER PCB-SD0000071373 Monsanto's Aroclors were mentioned in seme of the artici only in the San Francisco Chronicle story in Feb. , 19b?, W h. i Aroclor 1262 specifically mentioned by number. In several of the articles, Monsanto was also identified as the sole U. 5. ci-ofucer of polychlorinated biphenyls, marketed under the tradename of Aroclor. : Question 3 . - What did the articles on the PCD problem say? Answcr Since the outset of the "PCD problem", when the first article appeared in the U. S. press in Fe b. , 1969, the whole question has been closely interwoven with the question of DDT as a possible environmental contaminant. , The San Frar.ci's'co' Chronicle article carried a headline, "A Menacing New Pollutant. "/In rather sensational style, it i.oer.rified 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. The. Examiner article called PCB a "plastic pollutant in the Bay and Ivlothers1 Milk/" This article called PCB an "alarming" new chemical pollutant that is playing a role in the declining peregr re ' falcon population*, has teen found in mothers' milk, and is the "late t addition, to a growing list of chemicals ir. the ocean------- the newest symptom oLman's chemical invasion of the ocean. " * ' /' Those two articles quoted Dr. Robert Risebrough, a researcher at the Institute of Marine Resources in the University of California's Department of Nutritional Scientists, on the detrimental effects of PCBs. Later Dr. Risebrough said he had beer, misquoted insome r.ewsoaoer stories. The Hartford Times story onljed PCD poll..'Jon a " Dess sensational than the San ! rancisco articles, t/.e Time;, guve cU account of PCBs being found in thci environment and the studies under way to determine their biological effects. This article, -s Dr. Risebrough, tends to clear PCB of blame. FUR 004013 WATER PCB-SD0000071374 Articles generated by the Wisconsin DDT hearing; generally discussed PCB as an interfering substance disco-re red in. sciertAts 1 search for DDT in the environment. Dr. Risebroach said at the hearings that there was no proof at the moment that PCB alone can cause thin .e ggshells, one of the phenomenon ' that he had discovered in studying the declining population of the peregrine falcon. __ , /' / ' LEGISLATION '/ Question I / /' Arc there any Fcdoral/Statc/local laws under which the use or/ discharge of Aroclors could be prohibited? Answer ; No existing Federal State, cr local laws prohibit the discharge cf Aroclors. However, in a number of states the basic water pollution control legislation is so broad that state agencies cart prohibit chemicals, deemed necessary, from being discharged. Question 2 Is the DDT and the PCB problem related? Arts v.'o r; We arc not a manufacturer of DDT or other chlorinated hydrocarbon pesticide and, therefore, have no knowledge of the seriousness of the charges against DDT other than what has been so widely publicised on TV, in the press and in technical journals. To the extent that both DDT and PCB are chlorinated hydrocarbons, then there is a similarity. They are sufficiently different in their chemical structures ; however, that it would be entirely wrong to assume that both behave in the same way in the environment. There is another and more obvious difference. DDT and oilier chlorinated hydrocar bon pesticides wore specifically designed for a job that obviously leads to their being scattered in wide spread fashion across the countryside. Rain, birds, wind, insects further scatter these pesticides in an uncontrollable manner. PCBs arc not used in this-fashion and FUR 004014 II Ii WATER PCB-SD0000071375 IvIor.sa.rito has never sought to promote this. This, we believe, A an. important distinction that should net be overlooked it DDT and PCB are linked as a common pollutant of the environment. To our knowledge PCBs have never beer, identified in the absence of D&T or other chlorinated hydrocarbon pesticides. Question 3 Could it be PCB that's causing the environmental problems and not DDT ? Answer: We believe that present-day GDC and mass spectrometrie techniques are sufficiently accurate to be able to differentiate between DDT, related pesticides, their metabolites and PCB. Question 4 What authority do State and local governments have in banning/ controlling the use of PC3s. ' Answer: They do have authority to ban or control use of any substances they consider harmful. EFFLUEN AND ITS CONTROL Question 1 Row do I dispose of Aroclor 1254/1260, etc. effluent from my plant ? Vvre would suggest collecting all 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 are issued for this in your locality. Wc don't recommend feeding this material to local sewage treatment plants or taking out to sea in drums for dumping. These methods do not '/ FUR 004015 WATER PCB-SD0000071376 solve the problem of co::;mir_a: :o. Y.'e arc vorkin r c;. ;; disposal of these materials by ir.cineraricr. ar.f biederraration. Our work in these areas has no: yet reached the scas-c where we can offer practical sugge srior.s. I: is of ir.serest to note, however, that research is underway fo find cataivsss to make DDT self-destructive. The possibility exists that we could * find catalysts that would destroy PCBs in settling tanks con structed to catch all your effluents. , __ . . Question 2 Can 1 test my effluent to see if my effluent has no Aroclor 12 54, . etc. ? Answer: Yes. Analytical can do this ------ - ' IrTrui'propertechnique is used. The basis of the method is GLC or gas liquid chromatography. Are you or anyone in your company familiar with this? Do you have GLC equipment? if you do, v/e 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 rest your effluent. Question 3 ` What is a "safe" PCB level for effluent leaving my plant? answer: As our letter 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. '. / WATER PCB-SD0000071377 Question -4 You n'.usi have quite a control problem a: vour oi would think Monsanto's Aroclcr plants are t'.-.e rr. polluters--how are you handling control? Answc: The Aroclor products we make to sell at a profit, . so. economics dictate maximum housekeeping, minimum lose s. The Arcelor process is a "dry process" or closed system. Question 5 .. How does Monsanto think A.roclors can get into the environment and cause so much pollution? ' Arts we; Disposal, leakage from systems using it, spills, etc. Question 6 If I analyze my effluent stream and find ppb there, how do I know it didn't come from air-borne contamination or was present in the process water that I pump from the XYZ river into my plant? Ar.swer; Analyze water entering your plant and compare. .There is a method available for sampling air. ! Question 7 You seem to think from the tone of your letter that the source of pollution is from effluent disposal into streams. In my process, Aroclor 1254, 1260, etc. vapors escape. Y/hai pre cautions can I take to prevent (a) employee problems and (b) escape of vapors into tlu: atmosphere? FUR 004017 WATER PCB-SD0000071378 Articles on PC3 interference wish oesticides analvsis l-.-'/c mentioned the possibility of loss to the atm. osohcre from vaporization when Aroclors are heated. V/e find this hard to believe and it warrants considerable investigation. TOXICITY flues tlon 1 ' I PCE is'a danger to fish and birds, how about humans? Answer: / ; The amounts being found in the environment/are not considered a danger to humans or fish. The whole question on chlorinated pesticides relates to birds. / I Question 2 . / Are Arocior 1254/1260, etc. more toxic than other Aroclors ? Why ? . There is a differencejmAn^heaty^depending on degree of TnTsis not to say that higher chlorination is more toxic than,lower chlorination. The alleged PCB problem is not really related to degree of toxicity. DIFFERENCES El :n aroclors Question 1* ' .' In your letter, you state that Arocior " o060,'* 5-S--.2 and 5460 arc not PCEs. What arc they? Answer; They are chlorinated te'-phenyls. FUR 004018 WATER PCB-SD0000071379 Question 1 What's the difference between a chlorinated biuhenyl a terphenyl? Answer: : A terphen.yl has three benzenes linked together and-Binher.yl ' only two. They are, therefore, similar but different, just as naphthalene is different from benzene. Question 3* Why should PCB be an environmental contaminant and chlorinated terphenyls not? . Answer: I don't think there is any positive answer on this and I can't give you any theories. However, I would emphasize that net all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1242 haven't been identified in marine, aquatic and wildlife environments. Chlorinated terphenyls - at least those made by Monsanto - have not beer, identified in the environment either. Since you sell other PCBs beside Arcelor 1254 and 1260, why are they not found in the environment? Answer: 4 // One reason could be that they biodegrade and hence never build up 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 poured PCB into it, its absence when a river, for example, is analyzed downstream at a later date would indicate degradation by bacterial organisms. We are actively working on this aspect of biodegradability in our laboratories at this time. Results of this type c: work won't come to hand quickly but our preliminary work on PCBs of less than 54% chlorine looks promising. FUR 004019 WATER PCB-SD0000071380 Question 5 In your iettcr, you make no mention of Arcelor 1262 and 1268. .What-is their status? Answer: . / ' // * ~ It could-be that their semi-solid/solid water insoluble nature means they are'/far, far less likely to become "mobile" contaminants..yit could be that their structural differences from Aroclor/1254 and 1260 are responsible for the apparent lack of a prpDlem. In any event, they have not been identified by scientist's in the environment and--believe me-- a lot of scientists seem to be looking for PC3s. Question 6yf Both Amoclor 5460 and 1260 contain 60% chlorine. Why is one a problem (1260) and apparently not the other (5460)? . Answeri A terphenyl has three benzenes linked together and biphenyl only two. They are, therefore, similar but different, just as naphthalene is different from benzene. 1 would emphasize that not all PC3s appear to be contaminants. Those such as Aroclor 1221, 1232, and 1342 haven't been identified in marine, aquatic and wildlife environments. Ch-iorinated terphenyis--at least those made by lAonsanto-have not been identified in the environment either. Du-.;.-: this PC3 problem mean that you have discontinued efforts to get Aroclor 5460 approved by FDA? FUR 004020 WATER PCB-SD0000071381 LJ u C r i. 2 O! i O '* is the reason for nor re submit' :cr approval of Arcelor 5-160 i Ar.iwc r: No. Question 9 V/hat's the problem then? An swe r: V/e are bringing a .now solid Arocior plant on-stream in the next two-throe months. We want to make sure it pro; the same quality A.roclor 5-160 we used in our feeding studies for the FDA. Once we're sure that's O. K. -- and we feel it will be--then v/e'll get the v. FDA clearances do take time. Question 10 tms ?--uOitcity mean sunt _ i A."i c- 3*2 2'O V*clJ. 02 not going to be cbtair /; 9 / Vvre have no reason to think t! ie two things are related. Amo to: is not chemically a PCD. Ti; ,c delay resulted from the need to sot up certain analytical vr: ethods to satisfy FDA. This involved analytical instrumor.nation and is being completed n It is my unde r standing v.v pi a n to resubmit our petition althc I personally don't know the c: cact date. CON ,\ . Tlv\T ;"l- ii>\ 2C) ;,,*CO OllVla ii 2V2 'J 21SGC 11" O C _ C Y Cj 2".'.i22 r W12.'. 02.2 2*2*10 .22-Yl.'. 0 FUR 004021 WATER PCB-SD0000071382 uostion -KjVl L/ What should 1 do? Should I ell Jcc Doc ? thorn back cr oav me 53. 30 L di t S ir.5AV r: Don't have an answer at this time. V,re just Gerdt knew. APPLICATIONS ;ive / oro-uct Tell your customer--'.? e want to advise you of a possible c: mental problem. Without knowing what your customer does with product X, this is hard to answer. (Vie would say that it would not seem wise to use Aroclor 125-i or 1260 for keep dust down on the roads, for use in dental sealing compound or as carriers for pesticides. )* !':Only if you suspect cr are told this is what the abdication is. lio 3` Does Ivlonsanto intend to continue manufacture of Aroclor 133-1/ 1260, etc. ? FUR 004022 WATER PCB-SD0000071383 r I have beer, giver, no indication otherwise. Question 4* Should 1 look for replacement for Arocior 1254/1260, etc. ? Ar.swn r- ............ '/ I think only you can decide this. How easy would this be for you? Do you have any other replacement product ir. mind? .y / .. ... Question 5' ., /' Does Monsanto have replacement produces for Arocior 1254 and 1260 ? , An s'ye r: As you know, we have over eighty plasticisers in our line and there's quite a bit of product interplay so it is possible that there is another product ir. our line that mi give replace them. Y/hai resin, do you use? Perhaps we could look at these re sin/piasticise r Ss iS ctcr Charts in the back cf the Blue Book. I've get it with me. Question c* Is Monsanto working or. replacements for Arocior 12 54 and 1260? '' . .msver: These research fellows are always busy on things like that. To some people Arcelor 1254 and 1260 have draw-hacks- quite apart from present publicity on PCB. Arocior 1254 is fairly volatile. Arcelor 1260 is very viscous at..;' difficult to handle. 'For poly sulfide sealants, lor exam ole., the technical people in St. Louis have just sent us data on propacts that will behave cotter than Arocior 1254 in poly sulfide sealants. Maybe there!s something here for you to loch at. .' Let's ilO C-`V2." it. . i i / r ! i pUR 004023 WATER PCB-SD0000071384 Monsanto W. B. PAPA GEORGE - ST. LOUIS MARCH 30, 1970 cc TO H. S. BERGEN M. W. FARRAR - SECOND STREET E. V. JOHN R. E. KELLER D. A. OLSON P. S. PARK C. PATON W. R. RICHARD . J. E. SPRINGGATE : E. P. WHEELER Attached is a copy of a rough draft of a plan for managing the PCB problem. I realize much of the information is known to you, but I hope to consolidate in one document a summary of all of our activities. I also recognize that I have probably missed some important activities or approaches. Will each of you review this draft and plan to meet Jointly in Conference Room C-303 on Thursday, April 2, at 9: A,M. for a. thorough discussion. Our objective will be to develop a finished plan which will.eventually be presented to the CMC by mid-April. ms . .Attachment W. B. PAPAGEORGE fur 003347 WATER PCB-SD0000071385 ROUGH DRAFT MANAGEMENT PLAN POLYCHLORINATED BIPHENYL ENVIRONMENTAL PROBLEM I. THE PROBLEM The presence of materials identified as polychlorinated biphenyl (PCB) In marine environments was first noted by Professors G. Widmark and S. Jensen of the Institute of Analytical Chemistry, Stockholm,'Sweden and reported in November, 1966. Since then and with increasing frequency, other investigators have identified PCB in marine and animal life. Increasing evidence has been noted that indicates PCB in ubiquitously present in the environment and is resulting in damage to the ecological system. Monsanto is a major producer of PCB (Aroclors) worldwide and has been mentioned in many of the reports. II. BASIC STRATEGY With the growing evidence of the presence of PCB and , the apparent damage it can do to the world environment, Monsanto njust respond as a responsible member of the business world genuinely concerned with the welfare of our environment, yet not take premature action which would compromise its responsibilities to its customers, shareholders or employees. Finding ourselves on the FUR 003348 WATER PCB-SD0000071386 -2- defensive, lacking considerable information to help' .in arriving at :sound business decisions and with no real influence regarding the timing of any precipitous action by the press, competitors, public or governmental agency, we are forced to commit our limited resources in several directions. Some of our efforts are being expended seeking Information to help better understand and control the problem and some effort is being expended to find alternate products which we may or may not require as Indicated by new research data or other developments. Early reports had indicated that the polychlorinated biphenyls with 5 and 6 chlorines were being identified in environmental samples. From this information it was surmised that the lower chlorinated biphenyls were being degraded and probably were not a problem. Conse quently, a decision was made to plan to discontinue the manufacture of Aroclors 125^ and 1260. Recent data, although still very preliminary, indicates that not enough information is available to justify this action. It appears that :ln those uses where control of spillage and disposal can be rigidly exercised and the Aroclors are in sealed containers; e.g. transformers, the manufacture, of Aroclor 125^ and 1260 should be continued. The advantages of using these Aroclors, particularly where safety is a prime consideration, far outweigh FUR 003349 WATER PCB-SD0000071387 -3the potential threat to the environment. III. OBJECTIVES The overall objective of this plan is to manage the PCB pollution problem to prevent It from adversely affecting the established Return-on-Investment objectives of the Functional Fluids and Plasticizers Groups, while main taining the corporate image of Monsanto as a responsible and respected member of industry worldwide. Objectives supporting the overall objective are as - follows: 1. Reduce and effectively control the PCB content of all effluent from Monsanto plants. 2. _ Inform customers of the PCB problem and the importance of preventing environmental pollution both at their plants or by their products. 3. Develop products to replace Aroolors for those uses in v/hlch Aroclors have been demonstrated to be harmful to the environment and cannot be prevented from escaping into the environment. FUR 003350 WATER PCB-SD0000071388 Develop reliable analytical procedures for determining PCB content of liquids, gases, or solids. 5. Develop methods for effective disposal of wastes containing P'CB without contaminating the environment. 6. Develop methods for reclaiming and reusing off-grade fluids containing PCB. 7. Determine effects of PCB's on birds, aquatic life, animals and humans. 8. Establish and maintain favorable relationships with the press, governmental agencies, the public and the universities. ACTION PLAN 1. Objective - Reduce and effectively control the PCB content of all effluent from Monsanto plants. Status - A tentative target of 10 ppb of PCB in / plant liquid effluent has been established. Plants at Anniston, Alabama, Newport, Wales and Sauget, Illinois 'have monitored plant effluents and taken action to lower PCB's In the effluent. Target of 10 ppb not yet achieved. FUR 003351 WATER PCB-SD0000071389 -5- Action - All plants to continue emphasis on control to achieve .target of 10 ppb In effluent. Responsibility - Manufacturing Manager Date - By September 1, 1970 2. Objective - Inform customers of the PCB problem and the Importance of preventing environmental pollution both at their plants or by their products. Status - All Functional Fluid and Plasticizer customers In the U.S. have been informed. Customers in Canada, lj. K., South America and Continental Europe have not . been informed. Action - Inform customers in Canada and U.K, Customers In Europe will not be Informed until concensus is reached by all PCB producers in Europe. Notification of South American customers to follow. t Responsibility - Sales Directors - Functional Fluids and Plasticizer Groups ' Date - Canada and U.K. by May 1, 1970 Europe and South America - as Indicated. FUR 003352 WATER PCB-SD0000071390 -6- 3- Objective - Develop products to replace Aroclors for those uses in which Aroclors have been demonstrated to be harmful to the environment and cannot be pre vented from escaping to the environment. Status - Work on product substitutes has been directed primarily at Industrial Fluids applications, and NCR Paper coating. Water-glycol mixtures, bromlnated Aroclors, bromlnated biphenyl, silicates, blends using chlorinated terphenyls with lower chlorinated biphenyls, terphenyls with phosphate esters, phenyl ether with biphenyl, chlorinated paraffins, and fractionated Aroclor 1242 are all under study for Functional Fluids application, Alkylated biphenyls and KB-40 (hydrogenated terphenyls) appear promising for NCR Paper applications. . Action - Accelerate efforts to develop acceptable substitute products. Responsibility - Managers, Research and Development, Functional Fluids and Plasticizer Groups. y Date Major needs by year end. FUR 003353 WATER PCB-SD0000071391 -7- Objective - Develop relalble analytical procedures for determining PCB content of liquids, gases and solids. Status - Procedures have been developed. Copies have been offered to university and governmental laboratories. Comments regarding our procedures and comparison of results with other procedures have been solicited. Arrangements have been made for exchange of samples to verify analytical results. Action - Continue to refine methodology until we reach a level of competence which will provide data whose accuracy will not be challenged. Responsibility - Section Manager, Applied Sciences Date - July 1, 1970 ' ( 5- Objective - Develop methods for effective disposal of wastes containing PCE without contaminating the environment. t Status - Studies are being conducted on biodegrad ability, incineration and removal from water solutions. FUR 003354 WATER PCB-SD0000071392 -8- Blodegradabllity studies with aclimatized micro organisms are being conducted at Ruabon. Data to date indicates that the monochlor and some of the diand trlchlor biphenyls degrade; remaining PCB's are highly resistant. Studies in St. Louis in river water Indicate high resistance to degradation. Incineration tests of 1242, 1260 and Inerteen PPO Indicate combustion can be sustained with minimum fuel requirements. Stack gas samples were taken for analysis to determine degree of destruction. Recovery of Aroclors from dilute v/ater solutions is being studied at Anniston and by MRC at Dayton. At Anniston, adsorption on carbon is being evaluated. At Dayton, the use of acid clays is being studied. At the W. G, Krummrich plant, the removal of Aroclors from HC1 gas streams by high temperature cracking are being studied. Action - Continue biodegradation work at both Ruabon i ~~ and St. Louis to establish degree of degradation possible and optimum conditions required. Responsibility - Manager, Research and Development- Functional Fluids Group Date - October 1. 1970 FUR 003355 WATER PCB-SD0000071393 -9- Actlon - Evaluate alternate methods of disposal by incineration - Monsanto operated vs. contract. Responsibility - Engineering Manager, Functional Fluids, CED . Date - July 1, 1970 Action - Continue the work at Anniston, Krummrich and Dayton on the removal of PCS from water streams. Responsibility - Manager, Research and Development Functional Hulds Group Date - September 1, 1970 6. Objective - Develop methods for reclaiming and re using off-grade fluids containing PCB. Status - Limited reclaiming has been achieved by Flndett, Inc. Arrangements have been made for the reworking of a tank car of material at W. G. Krummrich plant. Initial efforts will be concentrated on returned material from large electrical customers. Meanwhile, customers are holding material for further instructions or are dumping in authorized FUR 003356 WATER PCB-SD0000071394 -10- land fills. Action - Develop procedure for processing of re turned material. Responsibility - Manager, Research and Development Functional Fluids Group. Date - May 1, 1970 Action - Select and modify as necessary, the required equipment at the W. G. Krumrnrich plant. Responsibility - Manufacturing Manager Date - September 1,1970 FUR 003357 7' Objective - Determine effects of PCB's on birds, aquatic life, animals and humans. Status - Toxicity studies are being made for Monsanto by Industrial Bio-Test Laboratories. Studies include two year oral toxicity on rats, three generation reproduction study on rats, two year oral toxicity on dogs and studies on egg production, hatchability . and survival on chickens. The Aroclors used in these studies are Aroo'1 r<r IpUP. Aror.l or and Aroclor 1?60. WATER PCB-SD0000071395 -11- Results to date Indicate the following: Liver enlargement'in male rats at 100 ppm; body weight loss in dogs by higher chlorinated Aroclors; rat reproduction effected by 100 ppm Aroclor 12^2 or Aroclor 125^; chicken reproduction effected by lower chlorinated Aroclors. Studies on fish were attempted, but were discontinued when cross contamination was discovered. These studies will be resumed. Action - Continue studies now underway. Evaluate need for extending studies. Resume fish toxicity studies. Responsibility - Medical Department Date - .Complete by m:Ld-1971. 8. Objective - Establish and maintain favorable relationships with the press, governmental agencies, the public and the universities. Status - Relationships are excellent. We have expressed interest.in studying the problem and indicated that we wish to cooperate to help identify ' and solve it. Pressure to divulge more information WATER PCB-SD0000071396 FUR 003358 -12- wlll continue to increase. Action - Appropriate Monsanto personnel will continue to participate in activities related to the PCB problem in a manner which will maintain our excellent relationship. Responsibility - All personnel Date - Continuing V. COSTS Costs for the program for 1970 have been budgeted as follows: Program Develop Analytical Procedures Toxicity Studies Plant Effluent Studies Blodegradabllity Studies Develop disposal methods Reclaiming Systems design Substitute Products Overall Administration Budget $M $ 80 100 105 40 ' 50 30 150 115 $670 FUR 003359 WATER PCB-SD0000071397 -M^'3nto - fRCM St.ILOCATIONI Louis DATE ; March 30, 1970 SUBJECT : REFERENCE ; TO : V7. B. Papageorge WPAPA ee. H. S. Bergen - HBEP.G ' H. L. Minckler - HMIh'C- P. S. Park - PPAP.K J. E. Springgate - JSPRI We have been in communication with a Dr. Hill of the Ohio State Board of Health. Ke has found PCD, particularly Aroclor 1254, in samples of milk from at least three herds in Ohio. He has traced this contamination back to silage from three different silos. Dr. Hill reported concentrations *t>f 0.2 ppm of PCB in the silage in the center of the silo and up to 20 ppm in the material next to the walls. He also stated that concentrations in the milk were between 0.1 ppm and 0.6 ppm and that some of.the milk had been destroyed. The silos are concrete silos whose interior surfaces ware painted in 1967 using a formulation that contained 1254. I don't know if there was any other Aroclor in the formulation nor do we know the coating manufacturer; although, this could be found out if important. The presence of PCB in the silage came from flaking off cf the material and possibly from leaching out during the silage storage. At present they will have to destroy about 150 tons of silage which is valued at about $30 per ton. As a rough guess, they consider there may be 50 other silos involved in Ohio that -were painted with the same formulation. .They are also looking into the.fat con tamination of the cows themselves. A.11 in all, this could be quite a serious problem, having legal and publicity overtones. - This brings us to a very serious point. When are we going to tell our customers not to use any Aroclor in any paint formulation that contacts food, feed, or water for animals or humans? I tliink.it is very important that this be dene. It may be that some of the customers will assure themselves on the basis of non-extractability that a particular formulation. might be safe but I think we should make a blanket recom mendation against these uses. . WATER PCB-SD0000071398 NEWS F R R ELE As ^ IMMEDIATELY. 1970 Monsanto E. V. John (314) 694-2891 ' PUBLIC RELATIONS DEPARTMENT MonttMO Company *00 N. Lfftdbfoh Boufvr<f St. LovU, MUioufi 63)66 MONSANTO REPLIES TO CHARGE THAT PCB THREATENS ENVIRONMENT ST. LOUIS, April 10 -- Monsanto Company said today it . was well aware of the concern over possible environmental ' contamination by polychlorinated biphenyl (PCB), an industrial chemical made by the company. The company began a six-point program in 1968 to properly identify and measure PCB in the ..^-environment. Steps have been-.taken to strictly control use of the chemical and replace those grades of PCB which linger in nature. - .' Monsanto's statement came in response to charges by Congressman William F. Ryan (Dem.) of New York that the discovery of PCB in the ecology represented a major threat. Howard L. Minckler, Monsanto vice president and general manager of its Organic Chemicals Division, saiti, "We have and will continue to cooperate fully with governmental agencies investigating this problem. We also have been in close contact with our customers. Monsanto has spent over $1 million to verify or correct scientific reports, monitor the use of PCB and search for substitute products where needed. This program will be successfully concluded this year. Jniore- FUR003367 WATER PCB-SD0000071399 MONSANTO: REPLY TO PCB CHARGE xxx year. "It is unfortunate that Congressman Ryan evidently did not have all this information at his disposal. Just last month we participated in a U.S. Department of the Interior _ . meeting where we-exchanged ideas with some 40 scientists and told them of our findings and actions," Minckler said. The Monsanto executive also noted that the use of PCB is misunderstood by some investigators.. "For example, we do not know of any current use of PCB -in insecticides. Even so, we' are asking the U.S. Department of Agriculture to reject any . .... ...insecticide which "has PCB as an inert carrier," Minckler said. "PCB is not a household product, as some have suggested," Minckler continued. "To our knowledge,' it is net used in plastic food wraps, house paints, cellophane, asphalt or tires. The principal market is electrical applications where the chemical performs a vital function as an insulating fluid. In this use, PCB is completely sealed in a metal container. Other major markets employ similar closed systems." - .. . 4 t. ' Monsanto* s. PCB program was initially directed at proper identification of chlorinated hydrocarbons appearing in the r.environment. This,.research, confirmed by .otherB, found only the higher chlorinated materials. At the same time, Monsanto undertook animal feeding studies which show PCB is not a highly toxic material. , . FUR 003368 -more- WATER PCB-SD0000071400 MONSANTO: REPLY TO PCB CHARGE xxx material. The second part of Monsanto's invastigation was " _- , coordination with all customers anda rigid critique of its PCB manufacturing units. Although.loss of PCB during manufacturing .va.s. negligible, production.-techniques were further modernized and new pollution abatement devices are continually being upgraded. Monsanto has concentrated its further research on , those few PCB compounds which degrade slowly. Alternate products for theBe grades, which retain the_functional properties of PCB and present no potential threat, will be introduced later this year. ' Minckler concluded, 'Monsanto is seeking the best solution to this potential environmental problem. Action not based on reason and scientific facts can only result in greater problems. For example, we have been advised by one electrical equipment manufacturer that an immediate ban on PCB would result in major power failures throughout the world. This is not the answer. Proper use of this vital chemical and substitution, where appropriate, is the answer." ** .. -0O0- FUR 003369 WATER PCB-SD0000071401 Monsanto ' i*Et\.:c<tios st. Louis - General Offices -r.Kt.E-d TO : April 21, 1970 PC_B.' s PILE . " J. R. Eck T. K. Smith, Jr. H. L. Minckler C. J. Smith R. E. Kelly/E. P. Wheeler H. S. Bergen - J. E. Springgate W. B. Papageorge Sam Pickard, Wash., D.C. REPORT ON MEETING WITH CONGRESSMAN WM. F. RYAN (DEM.) 20th DISTRICT - NEW YORK... _ Washington, D.C., April 16, 1970 . Sam Pickard and I met with Congressman Ryan this afternoon. We told Mr. Ryan that the purpose of our visit was to enable him to raise any questions he might have in relation to Monsanto's involvement in the manufacture of PCB's and also we hoped that he would give us an opportunity to clarify some of the points which he had made during his press conference. He explained that he was extremely short of time but he was quite willing to discuss the situation with us,' emphasizing that he hoped that he would still receive a formal response to his letter to Mr. Bock. We assured him that this would be replied to in due course. ' We were impressed with Ryan's apparent understanding of the problem although he disclaimed any abilities in the scientific area. His questions led us to the conclusion that at his press conference he was not simply reading something that someone else had written for him. He assured us that on at least two occasions that his total interest in the matter was to safeguard the health of the public and we confirmed that we also had a similar concern. The following is my recollection of the issues that were raised by Ryan and ourselves. 1. Referring to his press release, we explored the question of the toxicity of Aroclors in more detail. We indicated to him that we were extremely concerned that the stories in the press would cause undue concern in the public mind. He was advised that based on the work we have done on toxicity of the Aroclors we believe these materials are only mildly toxic and compare favorably with many other industrial chemicals. We pointed out that the information he had given to the press obviously came from one of our technical bulletins and was extracted from a standard warning issued to operatives processing Aroclors in large quantities and usually at high temperatures. We indicated that any PCB's currently being found in the environment were at extremely low levels and there was absolutely no danger to the health of the public. Ryan 2 PLAINTIFF'S DEPOSITION S- EXHIBIT HL FUR 003364 WATER PCB-SD0000071402 Memo to File Subject: PCB's -3- April 21, 1970 industry primarily in transformers where the material was operating in closed systems. We made the point that the use of Aroclors for this type of application was extremely important to the nation as a whole in view of-their fire resistant properties and the fact that Aroclor-containing transformers are much smaller in size than transformers using other forms of coolant which made them particularly suitable for use in heavily built up areas such as New York. 5. Ryan raised the use of PCB's as pesticide carriers and we advised him we had already written to the USDA requesting that they refuse registration of pesticide formulations containing Aroclors. He was advised that current usage in this application was extremely small and like many recommendations made in our old bulletins no real market had developed. 6. Emissions from our manufacturing plants were queried by Ryan and we made it clear that it had been Monsanto's practice for many years to control such emissions from all of our manufacturing operations. We also advised him that in view of the current concern over PCB's in the environment we had made significant improvements and had a program in hand which would ensure that any such emissions were completely controlled. Congressman Ryan's time was somewhat limited and the meeting was terminated after about 30 minutes. However, he expressed himself as being interested in a more detailed discussion with Monsanto emphasizing that he would like to have a scientist present with him and also underlining once again that his real interest here was in protecting the safety of the public. We gained the impression that Ryan was genuinely concerned that some of the statements he had made to the press were not strictly accurate and he appeared to be a man who wants to be certain that any statement he makes is true and factual. We recommend that Mr. Bock reply to Congressman Ryan's letter giving definite answers to the questions raised, and also mentioning our willingness to hold further discussions at a suitable time. gl FUR 00336S WATER PCB-SD0000071403 April 23, 1970 Hon. William P. Ryan House of Representatives Washington, D. C. . ' . ' . lear Congressman Ryam . .' Mr.- Bock has asked me to respond to your letter of April 9 concerning FCB.'s. Flease accept my sincere apoligies for the delay in responding. Mr, Sara Pickard and myself are extremely grateful for the opportunity of meeting with you' to discuss this matter and I hope that we were able to convey to you Monsanto Company's deep concern about the environment and responsible actions we are taking towards pollution, abatement, I can assure you that our commitment to pollution abatement'has not been generated by recent public interest in this subject. Cur record shows we have always attempted to conduct our opera tions in a manner consistent with the best interest of the public. We implemented positive pollution control programs long before the word ecology became fashionable, . In view of our activity in total pollution control programs and the cpecial measures we have taken and are continuing to take to regulate PCB, we feel any accusation or implication of irresponsible action by Monsanto is unjustified. As you know,- only recently tremendous strides in science and technology have perfected analytical techniques which make it possible to detect and measure extremely minute quantities of .an item in other substances. Our own scientists have made a' significant contribution in these developments and we are constantly working to utilize these techniques to further the degree of control exercised by our plants and those of our customers, Monsanto Company fully recognizes its responsibility and will continue to develop and produce products which contribute to the publio well being, but at the same time we . WATER PCB-SD0000071404 Hon, 'William F. P<i April 26, 1970 Page 2 \ will take every precaution to protect the environment in which we all live. - ' We have been investigating the relationship of PCB to the environment since 1963, V/e can only assume that the other manufacturers of PCB materials are doing likewise. We have contacted scientists and agencies around the world. Most recently, we attended'a U. S. Department of the Interior meet ing where some 40 scientistsfrom throughout the country gathered to exchange Information on PCB's and recommend actions. On April 29, we are participating in a meeting of the Office of Science and Technology of the Executive Office of the President to discuss the toxicity of PCB's. When we first became aware of the possible threat to the environment by PCB, our immediate action was to cooperate fully with scientists and government agencies to properly Identify and measure PCB in the environment. Since then, we have taken other major steps directed tov;ard strictly monitoring the manufacture, use and disposal of PCB- containing products which could possibly build up in the ecological system, ' . It' should be emphasized that the apparent PCB problem relates only to the possible effects on some species of birds. Manu facturing and use experience for thirty years, earlier animal toxicity studies, and the Interim reports on current extensive toxicological studies with various species of animals indicate that there is no threat to the public health, ` You will recall that during our meeting with you we discussed the very important distinction between various Aroclor0 products and the fact that not all Aroclors0 are PCB's, Scientific evidence indicates that only the higher chlorinated biphenyls-- those containing more than 5^ percent chlorine--are being found in the environment. These materials appear to be presenting a possible threat to certain species of birds. As we also dis cussed, Monsanto manufactures several products under the trade name Aroclor which are not polychlorinated biphenyls and which pose no threat to the environment. References to-the toxicity of the Aroclors made in your press, release were of course extracted from our safety instructions directed tov/ards the protection of the health and safety of workers using large quantities of these materials in industrial processes, often at elevated temperatures. As you will appreciate, there are many chemicals which require careful handling during processing operations, and such instructions and definitions of possible hazards are standard practice in the chemical and allied industries. V/hen used in other products the Aroclors are usually present in only very small quantities or when used FUR 003361 WATER PCB-SD0000071405 Hon. Y.'illlam'F. April 28, 1970 Page 3 an alone they are normally in closed systems and consequently represent no hazard to human health. It is therefore incorrect to assume that the PCB's presently being found in the environ ment in parts per billion or parts per million represent a health hazard to the public. ...... ' ' . In my opinion; to release a complete list of uses for Aroclor, names of products and manufacturers, as you suggest, would only cause undue alarm to the public and would make no contribu tions in this area. ' ' We have repeatedly stressed .the major markets for PCB-containing products are in electrical applications, where the fluid is sealed into an electrical component, and .in closed system heat- transfer usages. In the early stages of market development for the Aroclors^ we recommended many usages for these products based on their chemical properties. Not all of these proposed applications proved satisfactory, hov;ever. . In addition, we ' ' have become much more selective in recommending usages for these products bearing in mind the' additional information now ' available to us due to the recent developments in analytical techniques and technology. ' Recently it came to our attention that PCB was being used as an inert carrier by two small Insecticide formulators. We have notified our distributors to discontinue all sales of our products for this usage and we have also requested the U. S. Department of Agriculture to refuse to register any insecticide formulation containing PCB as a component. In a related action,, we have already alerted our customers to the possible environmental problem and are assisting them in switching from P'CB-containing compounds to other Monsanto products in applications where we believe that the chemical could be a threat to the environment. " With regard to our manufacturing operations, we have stated clearly our total commitment to pollution abatement. Production of polychlorinated biphenyls came under even stricter scrutiny when it appeared as a possible environmental hazard. We have improved production techniques and are continually upgrading pollution abatement devices in our plants. In the very near .future all of our PCB-containlng products will carry a new shipping label stressing the possible environmental hazard. . Finally, Congressman Ryan, I am sure you are aware that Monsanto's production and sales figures are confidential information, as they are in most companies. We are ready to cooperate fully . FUR 003362 WATER PCB-SD0000071406 Ken. VIilliam F. Ryan April 28, 1970 rage 4 with you or any responsible government agency v;hen we receive assurance that these z'igures will be kept confidential. ' I hope you will consider this letter a responsive reply to your questions. In my opinion, Monsanto Company is taking a responsible position and is using corrective action in dealing with 4-W -u situation. ' . Sincerely, JM/gd bcc: Messrs 2 # <J . j! R. E. V. John . VI. B. Papageorge P. S. Pa rk s! Pickard *r-\ . . J; Putzell, F.- C. Rehfeld Jr E. P. VineePer H. S. Bergen . J. E. Sprihggate- John Mason Assistant General Manager ' FUR 003363 WATER PCB-SD0000071407 Majr 25, 1970 Otis E. Fancher, Ph.D. Director ' Industrial Bio-Teat Laboratories, I8l0 Frontage Road Northbrook, Illinois 60062 Inc. - Dear Otis: This letter will authorize you to proceed with a study with the leghorn chickens with the Aroclor 1242, lot number AL-55. Thia should duplicate the study you did previously with Aroclor 1242, lot number AK-255# except in thia instance you have suggested using dietary levels of 2, 4, and 8 ppm. . This sample of Aroclor represents our. current regu lar production which involves aome clean-up insti tuted since the previous sample was made available to you,. We would hope that we might find a higher "no effect" level with this sample as compared to the previous work.. . As soon as suitable reference standards are available, the research laboratory in St. Louis will more care fully characterize the two samples in terms of possi ble minute amounts of contaminants. Best personal'regards. Sincerely, EPWiJu Elmer P. Wheeler Manager, Environmental Health FUR 004040 WATER PCB-SD0000071408 BCCt P. 0. BENIGNTJS D. A. OLSON July 8, 1970 Hr. F, Q. Jenkins Vice President, Materials Sprague Electric Company North Adams, Massachusetts 012t7 Dear Hr* Jenkinsj . I was fortunately able to visit your Brora St* Plant on June 17 with Randall Graham. I personally found the discussion informative and interesting and I was moat favorably impressed with the concern and interest expressed by your management personnel* We discussed briefly some of the points raised In your letter dated June 11* I will try in this letter to be more specific. Blode&radablllty - Biodegradation studies conducted in our rcsearon'laboratories in St. Louis* Missouri and in Ruabon, Wales using media consisting of local river waters or activated sludges acclimated to biphenyl give direct evidence that the lower chlorinated biphenyls ore affected. There is some evidence that chlorine position on the biphenyl configuration docs influence the degree of distraction by the microorganisms. I have enclosed a tabulation from our Ruabon laboratory which attests to show this difference. Wo do not have formal information regarding the effect of sunlight or other natural influences on Aroclora. Experience gained over many years indicates Aroclora art highly stable under all known conditions present in the environment* Toxicity - There ia ample evidence from many laboratories That certain species of birds which are at the top of the marine food chain cannot reproduce properly when RGB* a arc precent In their diets. The U. fl. Fieherie laboratory at Oulfbreese* Florida conducted a study which indicated that Juvenile brawn shrimp did not Burvivo in water containing 5 parts per billion of PCS. Attached arc copies of reports on these etudics FUR 004041 WATER PCB-SD0000071409 2 Monsanto has sponsored come studies on laboratory rata and dogs. A summary of tho results to data is attached* . Disposal - The preferred method for disposal la high temperature incineration. X suspect there are several commercial burners on the market which ' will perform well. X personally witnessed burning tests at the John 2ink Company** unit inTulsa, Oklahoma* Temperatures must exceed l6O0np to assure that collate destruction is achieved. lower temper atures would only vaporiae tho Aroclors and crest# atmospheric pollution or, worsa yet, would fora, by partial oxidation, materiala Which could be highly toxic (o.g* furana and dioxins). With incineration HC1 is. formed which must be scrubbed from tho stack gas and neutralized before disposal. We are planning , for an initial installation in one of our plants ... later this year* As a service to our customers who may not have access to other incinerators, we have offered to accept scrap Aroclor for immediate storage and eventual incineration. Tentatively, Monsanto will oharge 3# per pound of returned material. This . charge does not inoludo freight or container cofits and will be reviewed when final incineration costs are established. Material which is returned for disposal should bo addressed to Monsanto Company, ^ K. a, Krummrich Plant, Sauget, Illinois, Attention* " .. .Supervisor Department 246. .. Solids contaminated with Aroclors present a bigger challenge. As yet, wa have not tested an incinerator with these materials. Until we get more information the best we can ad vino is eafe burial in an authorise<3, properly operated land fill located away from any water qystema. We have laboratory work underway on other forma of deotruotlon. As yet no economically feasible approach has been found. Analytical Methodology - I have attached copies of Konaanto * a analytical pros edureo for the determination of PCB'a in water, soil, air and biological samples. We are interested in oomparlng our methods with those devined ty other laboratories. Any coomonts your laboratory may have would be welcomo and appreciated. FUR 004042 WATER PCB-SD0000071410 3- I hope that the above Information is useful to you. If I can be of further ervice, please let me kno^. Sincerely, me cel Mr, H, Davis Sprague Electric 0, R* Qraham V, B. Papageorgt Manager Environmental Control FUR 004043 WATER PCB-SD0000071411 NEWS __ FOR RELEASE 'IMMEDIATELY 1970 Monsanto E. V. John (314) 694-2891 PUBLIC RELATIONS DEPAP1MENT Monunto Company BOO N.LIndbarph BouUvatd SI. Louli] Mitsouii 63166 MONSANTO CITES ACTIONS TAKEN ON ENVIRONMENTAL ISSUE ST. LOUIS, July 16 -- Monsanto Company, sole U.S. producer of an industrial chemical called polychlorinated biphenyl (PCB), today Baid recent political charges and sensational headlines about the chemical causing "e major ecological crisis" completely ignore voluntary actions the company has taken to restrict use of the material. . "Our program began back in 1968 with the proper ' identification and measurement of PCB in the environment and will conclude this year by our unilateral action to restrict its use," Howard L. Minckler, company vice president and general manager of its Organic Chemicals Division, said. He added that Monsanto had not been pressured into action by any legislation or organized group. "We have taken decisive action based on evidence that PCB is a persistent chemical which builds up in the environment." -more- FUR 003384 WATER PCB-SD0000071412 --2 MONSANTO: MINCKLER'S REPLY TO PCB CHARGES xxx environment." Commenting on a recent report that PCB can induce birth defects in animals, Minckler said, "Monsanto is not aware of any scientific data that indicates polychlorinated biphenyls may cause birth defects.- The results of comprehensive toxicity studies, sponsored by Monsanto and using the usual species of laboratory animals, have failed to produce such effects. "Scare tactics and sensational reporting do not serve the public interest nor solve ecological problems," he said.. "Only a few reports have stated why PCBs were ever developed and why they are used today. Nor have the consequences of not using PCB been explained. "What should be emphasized," Minckler continued, "is that PCB was developed over 40 years ago primarily for use as a coolant in electrical transformers and capacitors. It is also used in commercial heating and cooling systems. It is not a 'household' item. . "Anyone who lives in a large city is familiar with power failures. During-periods of peak power needs, air-conditioning " : and refrigeration fail, lights go out and commuters are stranded. If power companies were to remove PCB from equipment, we have been told that major blackouts would occur throughout the world. -more- . FUR 003385 WATER PCB-SD0000071413 --3 MONSANTO: MINCKLER'S REPLY -TO PCB CHARGES xxx world, "PCB is used in electrical equipment as a safety fluid. It has replaced combustible oil products which have, on .many occasions, exploded and burned, causing deaths and injury to human life. Today ..state and local laws all over the ^.country require the use of non-flammable fluids in certain electrical equipment as a safety feature. At the moment, there are no substitutes available which equal the safety performance of PCB." Monsanto said it intends to continue selling PCB for ''closed-system" uses such as electrical components and heat-transfer systems. "With rigid control over where the product goes, how it is handled and disposed of, we believe the safety functions of the product can continue to serve society and the environment can be protected," Minckler said. "We are discontinuing sales into 'open systems' -- adhesives, sealants, chlorinated rubber, specialty paints, etc. "For other uses, such as fire-resistant hydraulic fluids, where PCB cannot be strictly controlled, we have reformulated some fluids and they are on the market. The new products cohtain other fire-resistant ingredients. We will continue to develop alternate formulations which do not contain persistent PCB. We will hot abandon hydraulic fluid users," Minckler commented, "as has been reported." -more- FUR 003386 WATER PCB-SD0000071414 . --4 - MONSANTO: MINCKLER'S REPLY TO PCB CHARGE xxx reported." Monsanto has also established a new system for disposal or recycle of spent PCB. A special high-temperature incinerator will break down PCB into harmless materials. The company also regenerates spent fluids for reuse. The incinerator will be offered to customers'who cannot otherwise destroy or regenerate their old fluids. "Although loss of PCB from our manufacturing plants has been negligible, we have further tightened up our production techniques and installed new pollution abatement devices the . Monsanto executive said. ' "I repeat," Minckler concluded, "our program was initiated and conducted by Monsanto alone. It will be concluded this year. We believe it is a position any responsible company would take." < f - - . " f -oOo*-'" ~ ' FUR 003387 WATER PCB-SD0000071415 W. B. PAPAGEOEQK October 26, 1970 T R. Savage H. S. Bergen V* R. Hichard R. E. Keller E. P. Kheeler Recent data from Dr. J. P. Hieuro's work Indicates the presence of naphthalene In biphenyl and anthracene or phenanthrone and dibenzofuran In Santouax R usdd In the manufacture of Aroclors. The naphthalene, anthracene or phenanthrene could be present In the benzene used In the diphenyl unit or could be co-produced with the biphenyl, terphenyl and quaterphenyl. The dibenzofuran could result from oxygen contain ing contaminants In the benzene or, more likely, be formed because of the presence of the promoter, acetone. . Tha Anniston Plant should design and execute a program for determining the source or sources of these contaminants. W. B. PAPAaEORQS 1 PLAINTIFF'S DEPOSITION 1 s EXHIBIT I FUR 004044 WATER PCB-SD0000071416 forr.v Aiiproved O.'o no. ''i-m ?;-y _ Approval Exp lies: Only 30, 1972 u .u. ...j_; v.; C..................... . .. \i\ I'. '7 *[.>: r j; O !\ '* n.',> n >m, ti7U\ bvii'M Torm !> . -Q"I Moy, 197 1 21iii I SECTIOiM i [ U A ill-' * Aw IpliLl") N A Mf *TTmm;c h c v . ll & o 4i i no. !.,,MQJr.v'7SK TO .COMPANY._________________________________ |. l'*or"i(i i\ (KutnOf-t. M'ow. City. SiM,r.mi 7/V Coa>J ' * , 77 I 800 North LindberRh Boulevard, St. Louib, Missouri G31ob " _ ................... "* f. ''C;;'/ ; '.AML- ` no kmo^.iii L_ _yl-}--'JL____ rI Rcclail motl Aroclor_ 7IlKToTmTC:! Vh'dTtN,-~i"vu cKiorinaVed Aromatic !.................... .... _____________ _____ f ......................... ............._r.PC.Tip; J. Ij Jl.V'lf'-T'WH.IR.Tir:i_p_p_-_n,niMr.'xiTaTRrr.%\v.Tai..-Tun:-.Ti'a paihts, rntsc svaiivu, a solvehts % TLV (Unitil ALLOYS AIIO METALLIC COATINGS PlGM(MIS fcASt l/ T AL C AT A( YS1 ' AUOVS * vtHic.tr j SOlVtUU | intiiiivis . ' meiasuc coatiiigs FPIlUllSlftCOMA-TTAINlG OR CO*5 FLUX OTntns "iLV 1 (oi<> ; "! 1 . i: | o:kT7.4 | hazardous mixtures of other liquids, solids, on oases i' r. "(Lt'lnyln) i1 1 1 .. .... i aswuscaaas urs -isz tv j. SECTION III po.uNrpO.*Y>r.iafc ,,0 mm 20 )-l|00C j VA^OA entssuxt |m K(,| at 20C <1 mm l VAPOR DtNSlTT 4AIM-tl j j tOtU.1U,T,g06VneRlip;lble N< >t Avail <0.0? . ..... PHYSICAL DATA " IC cYav.it WjOr.iy ^ UvRGvEoNtuT uVtOIhAuTUC EVAPORATION RATE * JauAc___=w "oq") 11 f `-r-Ki .... r ,.-tj .vrr^i ^_ "n!a^ | o1 --1 -JaU'. SECTION IV FIRE AND EXPLOSION HAZARD DATA 1 * irr,v..\ -vTarr.:;r'ji3.^uaz.^AS--iMuiuiucrr.'icxr:.'a~r.v.'`~rrv'rr.' ttx7:~z z:7'rmsv. `Vlasm fOWt h'.rihoa uuoi I LAI ^J UAl 1 ( X 1 I N 0 WI S H1 S' G N*.E c ` A I s`lclTie&bi^'i''^&r^ct^ro^ection vrhen fight.'inf; fires v;here exposure to ~Vhlj'0'}''S_'dT''pos"sihlo.. -- >) J^^^^^h^Tcl.loridos and chlorine) cor be evolved in......... fl res* *of" this product. ~c Ar~ 4 FUR 003275 "h PLAINTIFF'S Dtmu.ON ' EXHIBIT WATER PCB-SD0000071417 Rec T aimed Aroclor Mi;\ o'1 in i o iTui: vaiue*' SECTION V HEALTH HAZARD DATA |fil(CI5 Of OV(KCX/'OSUk( __ Slcln irr.station In the form of chioraehne, systematic_in- toxicc'.tioii leads to nausea, vomiting, loss"of weight, edema arid p i.'t n;.i NC. v Al/O I I!-I AIU HUJCUH'niS ~ abda. uLinaJ--p.aan.^ JjfGitio_vc: from exposure .__ Remove contaminated -iclothiing. Wash !_ contacted area v/ith_lai'ge amounts of water and soap. liefer to I 'physician'...............` ~ ! SUCTION VI REACTIVITY DATA ! V UNST AOU conoiiTonS io Xvoi'o . STARl F X UK 0APA1 AfUUl T (Mdtrttoii In e\`Oi<f) iu?w*noys of composition i_______________ rr.oouci,to, COp, |>t,\2AIUJOUS I'OOMtllW Al ION MAT OCCUR wiu not occun smoke, soot, chlorides conditions io avoio X and chlorine r.er --aero;: or: rasr/ix SECTION VII SPILL OR LEAK PROCEDURES T'u I f Vo Vi YaV( Vficam"m'aninii'ii'^ntu as tooW t Cu o Absorb on clav. sawdust or other absorbant material. Place in____ drums, Bury in approved chemical landfill in accordance with local and state regulations, wash chsi'OSai method Burn In an approved incinerator in accordance with local and state regulations. s samzrCT2^^T^^mI^ga.Tfcx^^Tca^7Inl,^ma :rr.T77^z<ms*^ h VtspiAAionr VfNIIlATION SECTION VIII SPECIAL PROTECTION INFORMATION rr.sTTTz:: Hines approved respirator for organic vapors.[ lOCAl CXHAUSt ^ Yes - for vapors SPECIAt MECHANIC AS OTHER pnoiccnvE gioves Rubber 1EVE AAQIEC ION Che]fflical gOggleS OtHfA PKOUCUVC IQUIPMENI rr^.?-.rr.' * SECTION IX SPECIAL PRECAUTIONS i-fitc a`01 IONS 10 Dl TAKEN 'lN^H A NO i'ING^ANo' s' r O'AiNO'C" r.',-jerr'3r:-..'rvr;.tc-.. Avoid skin and eye contact, avoid inhalation of vapors "oiHi'a pistca"oiTons _Ji While the information and recommendations set forth herein are believed to be accurate as cf the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY .FROM RELIANCE THEREON . JAC : 1 iOH : JTG ;Y!)3P FUR 003276 2/3/7 2 WATER PCB-SD0000071418 i-o cm Approved utfti Ho. 44-RU67 Approval Expires : u.o, uui"U11.;i:l Ur LMJIK( Form No. OS; Hay, 1971 July 30, 1972 MATERIAL SAFETY BATA SHEET 7~T"\r"?`Tr"T *\ ' l, ' , 1 --> - j ' SECTION 1 - ] MIS1.1* i( 1 w(k'l tM{AC(NCT KU^hOmC HO. 1 MONSANTO COMPANY . HIM 6cN_T000 1 4:8i0M0| tNl oSwrm<h^i, LJhinmci, bCcurr.ciniinijb0o.1m/.<eVvCair^an , St. Louis, Missouri 63166 - 1 * k.V -- ( ** 4 S * M (. I'NOllUt 1 A*OC v, u(, mo ImOmul Mixture_________________________________________ Aroc lor 1016. KCS 1015 ;"v~'c*Chlorinated aronatic Mixture 1 SECTION' II HA7ar'7r.!IS HihTI, t i[;tunvu, t lotvtxn J * igu| sr I CJLt *lfT % 1 UV AllOTl AKD KITALUC COATIHCJ Al[ UdAl. AUOU VI h 1C L C : oiv(Mj J iDDItivn 1 WJTAUIC COAIlNGJ _ 1______ nnuujnCvOiAtAimi c C* COt HUX OtKttl I' I KtrAlDOUl Kit TUI K 1 or OTkE* LIQulOl, WU6!, 0* CkiES j i * UY % fU7L-iYw ) J` SECTION III to^o>o^o,l6b r_ . 325C VfOt'MttUM "* ">( lRC5_XPSCl 3 run ; V**0 D( K Jit r lAlft- U ] H it Avail ; ,OlU.tl,n,r.^0c nepllE.lble <C.01$ *i*u>.c(*no:o colorless oil PHYSICAL DATA. I'lC'iic c*ivm *M* CvoI*wTwViO<lA\iTiu ( VJCU(I0N A At ( i .JTuAo..., :n ^ 25/15,5C) slirht aromatic odor 1 .3^7 M.A. <1 1 1 ; SECTION IV FIRE AND EXPLOSION HAZARD |U*j** VM(I C # 0 . C^^Xb 0 C j llALaUAlLl LUJltJ iiiHGuijHm'o liiou Water, To an, CO2 or dry chemical DATA sparseicEcrra; .il r._ JU- 1'tCfA.l. I*1 <iGntiKG MOClOutli Rr qpl ra t-n-y r o*- * r>.~\ Vh"n ri^hHnr f<rr'; \-:rnv exposure to vapors or gases is possible. UJiUSUil /!( AKO Il'lOS'C* N4JAOS P I rp V1 r *>> c f inf1 evolved in fires of this nrccuct. ^hvn'i'T.... m i-fv^-rrP'T'"'--" nT'* ^v.^JTx.i.xr^tV^--..tgr^T^gjT^v^j^.^>~rr^.^t-.-.f^-TT^-irTrTTT1-rT, 0o^77 fUR WATER PCB-SD0000071419 SECTION V HEALTH HAZARD DATA / v .*-1 t v;vl "" "" " ' 'xm c`=v=^r'7:'1~ - 0-rri,VVt*t.ion in the form of chlorac.nc, systematic | leaas to nausea, vomiting, j .......................------------------------------- --______ ~ (U|C|NC' H0 MAS! AID rsoci UKK1S loss 01 PeTgnt, ---------- - . c-aema add intoxication auc.orr.i.nai pair. " a --iJ-- fjUIUMl, UN51AIU SECTION VI REACTIVITY DATA -j- C-grTT*. Z.VET | v.uNic'f'WsdO AVL>>|) l T A lit iWC D'-'T AT Aimir 4<*i4J ' JKl/AAOOuS OCCOufOSiTlO* AKOOUC1S CO, *PAO.JOA*UOlAOUuSAtiO* i ...... WAT OCCU* HOT OCCU* CO? , ---------1 " - --- -- ------ --" '- " 1 ' smoke, soot, chlorides and chlorine COHOUIOHS TO AVOID . X 'r'ATr^-- 1 SECTION VII SPILL OR LEAK Ux,uiyiXtr^cjo^''ffixu.,i:j,rgasrxcayTto.r33aw^ji^iy:^':iArr^ \ i't *> C * 1 t*4S . S w*>t V A J< fc. A * i v - %i I* 5 Absorb on clay, sawdust or otr.er absorbent j .arums. Bury in approved chemical ianafili PROCEDURES material. Place in in accorear.ee witn local and state regulations. **"' :n5.os.*i uumoo gurn n approved incinerator in accordance vlth local and state regulations * . i " < ! fJj f i VIKIILATIOH j SECTION VIII SPECIAL PROTECTION INFORMATION j. u./..-it,*. 1 iZLJg.-iLi-iltu* 'J:r* r-- Mines approved respirator for organic vapors . YeslOCM. lAHAUlI ,, - f_or vapors jaeciai. l*|CHAA<ICAl (CnerntJ othu ^ i 1 ; 1 'ftOMCIIv'C ClOvtJ 1 rubber | OtKt* '*OUC * IV( lOUIAtHT -1`-I -.' IT n- TT-T-- -- - ~ ______ ______ ___________ .... . - ITl RAOHCTIQH chemical goggles (--------------------------------------------------------------------------------------------------------------------------------- ------------ ! SECTION IX SPECIAL PRECAUTIONS } I | i'MCAl/TlOM 10 11 IA4(N th *NOLINO AND 3 \ Avoid skin i OtH<a rMC AUMONi L_ and eye contact. Avoid inhalation of vapors. FUR 003278 i:argg.rrnr rai-jgKrTOcturrrw * >m. i w t. hh-tyt ---. ------------- t I --j While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY HAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JA0:H0H:JTG':W3P 1/25/72 WATER PCB-SD0000071420 Form Approved 0MB No. 41-R1387 Approval Expires: July 30 , 1 972 U.S. DEPAETliEtlT OF UG03 MATERIAL SAFETY DATA SHEET Form No. OSl May, 19 71 SECTION I ( MONSANTO COMPANY ' J :ri *i A, Lily, Z/P Co(i ' 800 North Linabcrgh Boulevard, ^ - l c * - ** * ** C *h UnOntuI 1 5 `Chio*rinated Aromatic St. Louis, Missouri (utnoiNCr UuIAhOnc ko. Ml M Ao'i-ioro . 63166 TRAOC NAWC *NO iTNONYWl Aroclor 1221 fO*UutA Mixture` section it hazardous ir-'C^oj 5gavcrgrtT-;rr .> rU- hints. f n t 'A fi VA TV S. c. SOLVENTS . ^ j UV ! (u.ii ALLOTS AHO METALLIC COATIMGS Cw{ MS A.SC UCfAl c a! Aort AUOrS vt hic11 SOivtMS OO'I'VI S UTAUlC COATINGS HUH U(TAl PIUS COMING OA CCH( KUX OTHIAS Cl~tAS H A Z A ft OOU S MIX! U* IS OF OTHER LIQUIDS, 50LIC5. C2 CiirS T LV TLv #1 i-1 .. V SECTION III PHYSICAL DATA &M3X73a&xxj3ys*sE*i'ana. >> u-r-t j r'-' 7 60 mm i viommui i st ___ mn^ i v**oo(nsmt i*.i- *i | 27,5-320 > .OOF .. NO . Avail. i'CCinc C*vilr iMjO-1^ pn/T r, m*TacVtOnI tUUv|oi(Matiu C va?o*/Uion * AM !;.VIAc . =11 i !2lu,ll"un^"C neFllrible <0.01* H A^( AlANCt AND OOO* colorless oil aromatic odor FC) rtxxCTca? 1. \- U. A. <1 SECTIOM IV FIRE AND EXPLOSION HAZARD DATA (j^u^sTFVoi*! iihi tni Mot Avail -a ftrrsggg&geiT 'txirt I IA>-UAIU llUltPlot A.val[l--. -- |j `'.'a^yr^dSn, C0?> or dry chemical .Respiratory0 projection when flrbtinr fires where exposure to b vapors or oases Ts possible.. : xrz'. '*'. p Y!':'Hr.l3o^.^0^s7.Af*l'tpbblorides and chlorine) can be evolved in < fires of this product. FUR 003279 WATER PCB-SD0000071421 Aroclor 1221 SECTION V HEALTH HAZARD DATA "u.i v/ii-jt ;.j0t Available b ",Skin0irrita'tio.n in the form of chloracne, systematic Intoxication _leads to nausea^ vomiting, loss or v.'eigriVJ LMema and abdominal pa: n I u|f.l S( > *N1> MRSI *10 mojioums _ Remove from exposure; Remove contaminated clothing. contacted area with large amounts of water and soap. ,, , Wash Refer- to physician. _ UNS1 Aftlf . SECTION VI REACTIVITY DATA xcasc: AvOlO S1A#U j.NC OW' A 1 A H1L t 1 V fVfllfMo/ f (O 1*0 / D(COM'OSl!lON POOUCTS | vU j 1mA/AACOuS *Ol Ptf At IOH MAY OCCUR will NOT OCCUH . U Jp 1 smoke, soot, chlorides and chlorine CONDITIONS TO AVOIO ' X | SECTION VII SPILL OR LEAK PROCEDURES " 3-- i drums. Bury in approved chemical landfill in accordance with u------- local and state regulations. j *S A ,'l-.urri!sVn`K'nu approved incinerator in accordance with local and < J state regulations. 1 --------1 fr ii - ij ii SECTION VIII SPECIAL PROTECTION INFORMATION ...... ;"lc"OM'l"n''ff(ireau of Mines approved i VI N 1 ll A t ION ,0C*. I.H*OS, yes _ for Vapors | UJCnaNICAI + respirator OTHIW for organic v apoi'TTt j * * (C v Cl OvlS rubber F:-l 'OUCUvl (OulfutNl l Y C TAOltCTiON chemical goggles ; SECTION IX J2VKY3 /> ( C. A I ' i.* S ' O It U>|N *N HANOl'Nu A*0 Avoid shin and eve contact. Avoid inhalation of vapors 01 H( A 9 *1 C AUl lONS SPECIAL PRECAUTIONS FUR 003280 While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANT WITH RESPECT THEPETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. . 1 :n: . t'tp . uo r> WATER PCB-SD0000071422 form Approved OMB No. A 4 - R13 8 7 Approval Expires : July. 30, 1 97 2 U.S. DEPARTMENT OFIAOOE Form No. OSH; Hay, 1971 MiML SAFETY DATA SHEET' WATER PCB-SD0000071423 Aroclor 1232 SECTION V tieasnn^n i,.,v.:ub i'wi: va.ui j'ot available. HEALTH HAZARD DATA USUUU lead: in the form of chloracne, systematic intoxication , vomiting, loss of weight, edema nno abdominal pa ini 'osure. Remove contaminated clothing. contacted arcc. with large amounts 61 v;Ater ana soap. ""t o' phy's 1 c T ariT )ni wnri"ii""iiiiii Wash Hliter ~--; SECTION VI REACTIVITY DATA a. x b u i UN51 ABl[ staklc INC Ok"*l ACM. IT r IHaltutll lo Hi.i^DousD(coM,osu.oNoDuci^0t C02> smoke> soot, chlorides and chlorine *A/A*00uS *0l * *lj i.1 iO* UAYOCCU* Wilt HOT OCCUX toCOKOmOHS AVOID X ' rex ?nf _______ " " W r IU|N SECTION VII urwsm I *`.l *>o SPILL OR LEAK PROCEDURES 'kjxxtk immrfLr*rri*rZMX gx.'m^f-wtrr n r-i ____ ._________ i____ ,vv. < ~ i LJr^rr m a ^ i t\ drums. Bury in approved chemical land) ill In aCdorUumiC*1 wl lh local. And 1irrsTtr I' U |J U hi* U i 1 * j*4S''Burri` linVMS?> acoroved incinerator in accordance with local and state regulations. i -------{ H i _____f H i SECTION VIII UMtvatni < G| l *mo!{ c 1 'r'fih i*,-'' SPECIAL PROTECTION INFORMATION V t H m A t ION . u.cAi lAMAusi yes - for vapors iriciAL UlCHAfvICAl (CfyftmU or h( n ; 'noneMv/i Ciovii rubber l ft mOtlCTIO* chemical goggles foTTTT r.uouc nvl lOUl^lNT Ihc-i jwguejayracagym v~. a-qfea -- araigtjjtwxvjti r'raLg.uc^orr.: *1xr7crk.u?i vircanHc SECTION IX SPECIAL PRECAUTIONS ( ! KCTc3^nsr*Brcc3E&rs^a^rr^ntfjwrw-* tare i.w^ircow u/.yv.1o.'i,d;vnaIk1;in''' 1,n1 r.d eve contact.____________________ awnwa1 *"C7^u*\-autr'' I, Avoid inhalation of vap.ors FUR 003282 01 A r M c AUllONi While the information and recommendations set forth herein ere believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THERLOU- 1 /> r. wnu . t'po . vo o WATER PCB-SD0000071424 Form Approved OMB No. 4 4 - P. 1 3 8 7 Approval Expires: July 30, 1972 U.S. BEP/iBTEEtil Of LOCOS Form Ho . - 0S1IA -2 Hay, 1971 MATERIAL SAFETY BATA SHEET' ! SECTION I M A MU* + C tO* l '* NiUf MONSANTO COMPANY D(>nf 1 fA'umbtr. Cn t`. /IP Cod*} 800 North Lindbergh noulcvnrn, . * i m ; * i mut *no itnohyui ill x,time. C M t Ml C *1 f iUI). * Chlorinated Aromatic St. (MCnClNCY MO. Wl) .S^l-IOQQ___ Louis, Missouri 63166 fo Amuw* TAADt N<U( ANO IVNONTUI - Aron lor 12^? Mixture ICWI NTS cai Ann VIHICU JOlVlNTS ADOITIVl J OIlS narsorg.'>^lurwrii>MarTL<3- SECTION If IIA7;i:'!00HS Ij'.'P^Oj'EfllS TLV (Ulu) ALLOYS AMD METALLIC COAT INCS . A S( MtlAL ALLOYS UITAIUC COATING* FULL UITAl FLUS COATING MCMI TlUt OTMMl HAZARDOUS MIXTURES OF OTHER LIQUIDS. SOLIDS, OR CASES TLV )> (Ur.li.) k TLV (U.u.) SECTION III PHYSICAL DATA iouinc to.ni ft.> 760 mm 3a 5-360C i*{C me C*Vif r IM.O' It * _ , ,, ..... 3 (2R/?RCl ] . ?R0 [ va*o* t*su( i-tii.i( 155-195C) Vi.*0 DfNtlTf 4AIA-U 3 mm *CCfM VOLATIU VOl<JU< tVI >t Avail l VA FOAAnO* AATC (. Bu4r = u N.A. | <1 J *OLu.a.u,N.A,^ooc ne^lKlble. iMlL AFF(ARANC( AND 0004 colorless oil slight aromatic odor SECTION IY FIRE AND EXPLOSION HAZARD DATA 3, K A>m fQiN T 1 ***!* C.O.C. 180C Flauma.lI LIUITI ,,T,NGu,Ah,NO u,Q,a Water> fQam^ CQ? or dry chomlcal JMCUL IIM TI&HtING F*OC(OU( Respiratory protection when. HghMng fires where exposure to vapors or gases is possible: TOAVv^roVrc^VcT^rchlorldes and chlorine) can be evolved In fires of this product. FUR 003283 WATER PCB-SD0000071425 Aroclor 124: SECTION V HEALTH HAZARD DAT, _TUTff________________________________ . ,, _1.0 mp./mi of air. UK Ct s oi ovi Rf i^osii( Skin irritation in the form of chloracne, systematic intoxicatl on leads to nausea, vomiting, loss of weight, edema and abdominal --------------------------------------------------------;------------T------------------------------------------------------------------------------..-..-..-.-..-..-..-..-..-..-.-...-...-.-.-..-..-..-..-..-.-..-..-..-..-..-..-..-.-..-..-..-..-..-..-..-.-..-..-..-..-..-..-.-..-..-..-..-..-..-.-..-.. pUOa.i1nI,I,.., (Uiir.l *C `NO I IRS I AID R*OClOufl(S Remove from exposure. Remove contaminated clothinp,. Wash contacted area with large amounts of water and soap. Refer to --rpuhTy/s.vi:cian--.------------------------------------------------------------------------------------------------------------------------------------------------------------ r>--wirii. SECTION VI REACTIVITY DATA riNCOJUT Aftsuit lo iwajardous decomposition prooucts !wA*AAOOuS AOLTW( Ai/ATION MAYOCCUR Witt HOT OCCUR C ONDITlONS TO AVOIO X ' SECTION VII SPILL OR LEAK PROCEDURES >0 fit Ia<|h iN CASE UAUMUl IS MUtASeU OR S'llUO 'Absorb on clav, sawdust or other ahsorbant.I l l/i-l VJ i. w W11 v^-1-fiT f HLLHUUU m w x wwAik.A t j,.j-l xa.-w *. i.,. i.* * i Place In drums.i xuul. ajx. ..Lt i_mim Maarzn and bury In approved chemical landfill in accordance with local and state regulations. ' ---- ! WAJ!| ^uWrnITHHOOfn an approved incinerator in accordance with local and state laws. SECTION VIII SPECIAL PROTECTION INFORMATION I1HAI0T fROUClIOH ISftuIr ttrrl VENTILATION iocai ikhaust U(CMANIC At MOTtC'IVt ClOV<S Rubber OTHER PROHClIVC lOUl^fNT Yes -- for vapors *PtC*AL OTHIR |rt PROTECTION Chemical goggles - mmmefi | jfflfta. tuff ^4 | .: ; . SECTION IX SPECIAL PRECAUTIONS ECAUTIONi ro M Ta|H in HANOtlHO AKO SI0"n6 ____Avoid.skin and eve contact . avoid inhalation of vapors. OIHCA PA(C AUTlOMS 0032&A fur 1 While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY HAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROH RELIANCE THEREON. JAG :HOH: JTG.-WBP . 1/24/72 WATER PCB-SD0000071426 Form Approved 0MB ::o. W" R13U7 Approve! L r, p i r e s : July 30, 1573 D.3.%. 'J ;io;,w.vt1i,:,, v| ,,., U. .: >, c V,/n ij, '. Vi for'.:'. Co. CRM May, 1971 nwn n(Vikf.' i`&\fs niL, M<?s ip'ptivvr ? ib.y or. firi. cbbpn-j?l'-:iakt 2> / 0 2- SECT!0:j I I ' > r i u'm n* MONSANTO COMPANY I' * :m h. f.VuM'-pf. Su C`11), Si.in., rtr cc s>) 000 Nov In Mimlocrgh Boulevard, St. | V* * \ M l* 4 1. NU't * K'O S rii'Cl(YWi 1 Mi j: i.uro | [ -ii imC * i r * i/iv. ' } Clilori.natcd aromatic r' Te(w3c t1. .cA{'.)h c v f c <L c ^ how e" ,v o * " Ac.;i.,.i_pon.............. ~ ~~Z ' J.,ouis, Missouri 63166 ronuvi, a. Tr\4L.C N*W AHO ll'NOliri',1 Aroclor 3 ?( B Mj xture i .....................^sncTiorj n j paihts, n r c sc rva fiv: s, . solvcmts j r u,Ll( h l i | CA1AIYJ1 1_______________________________ VOUCH j SOlVO.TS I ADOitIVIS OTwihS T LV (Unit * ) alloys ano metallic coatings 6A$ ut Tal ALLOYS UtTAUIC COATINGS fIUU UHAL PLUS COATING QK COft HUT. OTHERS H A 2AHDOUS HlXTUftEJ OF OTHER LIQUIDS, SOLIDS, OR GASES r T LV (Uiu) TLV li (11 r. i* | I I L_ SECTION III r^r-inm.'u rm PHYSICAL DATA irraTaim'xrera rtfZJia^cc; POKING PONl f/.l 7 6 0 mm 3jj,,|-3,8,5.i. VAf'OR PACSSURC I"YTV Wo.I I6f3-210C 3 mm SMClMC GRAVITY 1IM 0 " \\ 25/35C) flACCNT VOLATILE BY VCHUVE (M 1. t)IIQ 11 jljlJ VAfO* OINSITY iAlA- I lv*ron*TiON bail Npt.. Avail i Bn An. =u <1 f SOLUBILITY IfLWAJIB _. . J _______ 20b negligible <L,,mX- Q`.TAj'i--yrn.nAattiLACHVct.'ia^ahgoTJcgoJBoAn^Y/rT^rTKa'JScvSoCBloaari^lJe^ssxJsL^esvtso.'^-Tyitive\rll^o:w-~-so3?Si4ljaicrijxixra/',-uz:a<--rcoj2ml>.ni.tcinm..1...it. SECTION IV FIRE AND _VoirvJ.ccr.xrrp*A,T5T;^i,r3`' tj.'-.TTcrrivzrinv>.t^jq. fc^cv^ci>xigssjLrr j HASia POINT |U*ihoJ ui<J) Q Q c 196C (Xllfvr.UISMI'YO IOI * EXPLOSION HAZARD DATA /LAL^IA0L LIMITS | Ll ( Ue I ____b3IE=IiIiLI shciai. f ip.t iiCiHiino faocioonis __ -pc.cp-'i vnhr-.v*y pvohppf.'l on '.'lipn___fig'iti-Lnfi--f 11~6 --WllfUlfi--S-TUIP.5tlTO--k9-- vapor or gaoes is possible^; r y^iVvM^oxyc0nasV4ATohlorldeR f "Ti ros*~of tiVi s p"roduct. -- ^; - J L- vj 1..- ^ and chlorine) can be evolved in____ ^ ^narcT.^Lraa---ie.^"TS-atST.--.: : FUR 003285 WATER PCB-SD0000071427 Aroelor 12^8 ", :'K( sViciTimii vmaJC SECTION V HEALTH HAZARD DATA li < cII i i oi CmmiuxxpnoossuuRrii j_rr|tation in the for:", of c.hloracne. Oyster at ic i I', t O X i cTiTTon-"!caus to- naus ca~ v'oTiii c m r } los a OT" weigh ttnitfi. TS -----------------------------------------------------------------------------------------------------------------and pbriorMnnl________r.alrU- Remove from exposure. Rsniove contaminated clothing. Wash "contacted" area with large amounts dT"v7aIrL:r aTRr'iToap. "F\t! fOT 'to physician".' ............ I ' jl M A OKI I 1 v., p ; r,,. UNST A DU 51 Atu { Hi'COMPaT AhHHY fMolMiob io<u-oirf/ SECTION VI REACTIVITY DATA CONOI TlONb to AVOIU X , smoke,ka; arocus orcoufosmoN.iooyc^s ImPOat2\AMf.lOMOi;uASl (ON MAY OCCUR WU.l NOT OCCUR soot, chlorides and chlor j ne , CONDIIIOMS 10 AVOID X J i ____'I , x'luvj .`jtoJL'T SjHx-yrr;t--:tsscxl-ciiaznc^y^i rrxr vsi'.crjsmsu'STizrrm tz ires- SECTION VI I____S_PILL OR LEAK P_R_OCEDURES ', si'ii'f' ri 7 Vs o'a hi' 'llfRV UAJUi'OR'siMtuo' io` n'iW caTCma'ii'm'aT fif lease oS simileo .X--A- t1 -J-rr-Tj: i Absorb on clav. sawdust or other absorbent material. S1\L. ..- Place in ' drurns. Bury in approved chemical landfill In accordance with| local and state regulations.. j v,AS1ku'r'n5,'j.nt1an1 approved Incinerator In accordance with local and state regulations, riTirn7am3v^Jttgcxv.'^^x"<g^TCyc:^T7s rr.'.r SECTION VIII SPECIAL PROTECTION INFORMATION ,\TRZlJS,TiMJJMZAJ'IOZLRZt7ZfRnrOXZUXStlTluOZtrNt^TJe(S2apurc`ifVy tix^^'tMines approved snasrarjccarr: wu tztzj^. r;zox^sixc*r--:.`rz.r ur-/. respirator for organic vapors.___ | VfNTUAllON 10CAI EXHAUST ,, ^ Yes - for vapors MICHANICAL (Ctntratl SPECIAL OTHER 1 rnou< iW. GiOVCS ^ ., Rubber OIHIR PAOUCTIVC EQUIPMENT T PROTECTION Chemical pcofi;p;les SECTION IX SPECIAL PRECAUTIONS 'r_H_C_C_AlA'TnIOvvN:o*sitidnvzietcs:"UIk'aAin|VNn lINiaTn^HAAdTTCoHelIVNyNGeGAM^cOviorSfTinbOiHt?IaN7^Cc,t, r^r.is^crapgsgrrA'S"acgg.a. rx-"bc':t?jpr.c avoid Inhalation of,, vapors, :r oTm! hTa( C auT ions r .'XCTi.r-- :.-*ca:.htkv.>tl: .tw.z y.-agatja-aa; - .'.vrx,,-;..xnocressxr.zrB: J While the information and recommendations set forth herein are believed to be accurate as of the date hereof. MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. J AG : HOIi: JTG : W B P . FUR 003286 l/2*;/7 2 WATER PCB-SD0000071428 form Approved OMB Ho. 44-R1387 ^pprovdl txpircs: O U.S. OEI'/iilTLiEiil Of IfiDBil Form No. oS1 Kay, \S7] O Q WATER PCB-SD0000071429 f&sv.SKr j> l v. i * u \ ir ij ~f:/-5``or'air ** * 'J' PA^AKO UA i A "' 1 ~ " *--* * ---- - -- -- . ~ 1 o; j SR in irritation in the form of chlcracne, systematic Intoxicati on : leads to nausea, vomiting, loss ol v.-eigne, cue.pa ana asocmina 1 pal iiuinoi^-c* a**.', HAW AID r*OC(Cn,M5 Remove from exoor.ure. "* Hcmove contaminated c]otv^nr. j contacted area with lai'gc amounts of water-anc soap. V/n c h Refer to |i physician* -an i Vrrrna tiil'AIU.It SECTION VI REACTIVITY l u \mx:zzr.~r^trzzjzciz rc,rit.r3;::-'*c;rr.'rr7^7.^"-v^.ir^r I UNSTABU I ^W.^O.UAVW DATA STaiK INCOM^At Xftll 11 T (V4trn*tl (0 4VO\4) HA.JABOOUS OlCOurOSlIiO* r*OOuCJS CO. CO?, smoke. soot. chlorides and chlorine HU AADOVS *CHVU( AUAHOW U4T OCCU Will KOI OCCUB COKOniOUS TO A-VOiO X -rrn rrra -nv.^xr^3ijriJ7grn= r , , \.f/....... , -.n----- [ t 1 1 . SECTION1 VII SPILL OP. LEAK PROCEDURES _ kb s orb'on^clav'y sp.v.-aust``or *ochcr absorbart material. Place in drums. Bury in approved chemical landfill In accordance with O local and state regulations. *AUtBurh^ln" an approved incinerator in accordance with local and state regulations. itUrWJCT.rrO*' SECTION VIII SPECIAL PROTECTION INFORMATION 3 fr^DCVCLTI rtXU^-T^VXVW,ttl^TEjTTTV-tl 4*ms%lixrtzx<u VI N til A 1 ION tOCA.1 I IHAUSl Yes - for vapors U|CHMCl (Ctuttll tdoncuvi i,iovii Rubber j tu fftOUCtlON mm fMn r c i ivt coi/i'Mixi irlc,Al vapors. OlHl A Chemical goggles SECTION IX SPECIAL PRECAUTIONS jAr:xarnjjvTTrCTfr^i^xTJxTrt^ninj''ijT'y^TVi^Ta.rr<r.'fXcrrrgi^ttr^^a^jjj>^^'CTA4ca.'rr-vx=r^=c_________ "tc*W'oid's k/l'n `anaSJc-ve* c*oV.Va'ct, avoid inhalation of vapors OlHU 'MCAvliOfcl FUR 003288 :warsflevKT o While the information and recommendations sot forth heroin are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS' ALL LIABILITY FROM RELIANCE THEREON. .JAC:HOH:JTC:WDP 1/25/7 2 WATER PCB-SD0000071430 Form' Approved OHO no. AA-nnu? Approval Expires: July 30, 1972 HQ nW'tOTl Ar V^viV0 'Ir.JvK*-!rvifb' f!K l Ww s\/tl mm mm ifliA mm Fon.i tic. OSnr May, 1971 8)) o SHCTlOiJ I ( UAKl/l ACU'HCfl'J W * M r tML^CuNCV TELCPHOUe KO. i__a,,c_M_C_'pOK_:_*t!_s*_.(_SA_uA_.f._fitvi'_rr,_cS_)i_ft_Crf.,,OCtM(y,PA,NYnd T._U_' _C_o_de_)_____________________________ (RiA) 6Q/I-1QQO! . 'i BOO North Luidbcrgh Boulevard, St. '.Louis, Missouri 63166 | 0J.A*:< At l|*M[ A IV D iYHClVYMS ! Mixture onn aromatic ITrtADC K * mFX77d a r no n V Ml "j Js.rohior i?6ni FOftUUL A Mixture r.Mrrsm'jcce^sr.T _^>c___ SECTION J.L. WWv?-^- t paints, r q t se rva t * v e s, a solvents tlv <U*lu) ALLOTS AMO METALLIC COATIIICS TLV (Unll , ) p ic.wi vi$ cat MYjn BASE METAL 'ALLOTS J VlHIClt Insolvents ADDIKVTS METALLIC COATINGS FILLER MET At coneplus coating or E LUX OTHERS HAZARDOUS MIXTURES OF OTHl-fl LIQUIDS, SOLIDS, OH OASES TLV (LMii) t,i.raxi;regn3g*irp.ffi^^ SECTION III PHYSICAL DATA 1 sjrrrpJ: TT&scEXJtsJ. 7^0 mmDOKINC POINT fl.l l-A20oC SPECITIC ORaviiv IH^Op T1 ( 2tj/2tbc,C) 1.620 VAPOR PRESSURE |m H0. ^.95-2^5C VAPOR 01 NSITT IAIR = 11 .3 mm Nbt Avail PERCENT VOLATILE ST VOLUME IM EVAPORATION RATE <-Billie-------=n -N--A<1 20CSOI UOIUTY IN WATIA neKllRible! <0.01s i APP AflANC AND OOOA V-w-.T yellow ` soft resin slight riais." CTruuco: arom*'a**',t1 Tic^Vr^Vopdt/woI.r SECTION IV FIRE AND EXPLOSION HAZARD DATA t | 'zrzrrtt. c.*vTiKvx2C jxnuctirsluscjxi.i P* l A$H pOnWT iNLU'od used) lt None I flAMMAJl.6 UMITJ CKMNCUlSHtNO Mf DlA zrzsz. Ek. ll I Ut*l ( ftrfr.--f--itr/r-- "1 ! ""special fins fiOHEiNC procedures Respiratory protection vfhp.n_Ci.gi3 vapors or gases is possible/ <chlorides and chlorine) can be ' evolved~in fires ol' this product. ft , 'll l! FUR 003289 WATER PCB-SD0000071431 Aroclor 1R6o SECTION V HEALTH HAZARD DATA | 1 I */;(. Sl'Ol (> I IMI) V A { ul Not avail I'il-'Vn t\r,r!ff.a?!:f!bn in the form of chloracne, systematic intoxication j (Tends "to "nailsea,~~vo;nTifiiT[f7 11 >7fs~~oT~ we'!'ifIT, UuTTi'iia~TIIfd <iT>cIoTnTTuTI paTh~i! |i l.'l IUM N( V A Mil I ll'.M AIO rflOl'tOlilitS _ , 'Remove from exposure. : Remove contaminated clothing, icoiitactoii * aVliiTlTi'tlT"TarT^`'aTirourfvr^TiT~wiiTeT~ai'Ri i_.............................................................. .............. . fsoajV, Ho f or to ' physician"............. . ~ , . ' Wash i Jl 1 I i 1 i SECTION VI ' REACTIVITY DATA .... , UNS1 AUU .. .... " CoN'dnio'iTs'ui Avoid'........ .................................. .... staku. . INC OM.nAl ADU n v (WaUiioh tonv^td) X HA/Anoous orc ovposnion products CO, COp, smoke, soot chlorides & chlorine. HA?AAOOUS |POlV/fHi?ATlON MAY OCCUP. wu wot occun COWOITIOWS TO AVOIO -jccc.ttu jv:c-r ! __ SECTION _V_I_I__ s:rzz _SPILL 0R LEAK procedures j drums. Bury in approved chemical landfill in accordance with local and state regulations WASH !)V1'Q&*ai I/ITHOO Burn in approved incinerator in accordance with local and state regulations. ' vr crj:--t:icu BrK7tc`i7Umr^3ssnM3?xicuacff3crir,i3 *'.Tc.:r . . SECTION VIII SPECIAL PROTECTION INFORMATION TispiraIORT PHOncflON (Sf 'rr^i IrptJ UIie.au,,aT--Iilne.6-.afiprx?y.&d .rftsnlrahnr VI NtllATJON l OCAL CXHAUS1 Yes - for vapors SPECIAL MECHANICAL (Crnttul) OTHER for. nrpnn 1 r. vapors RHOUCTIVL CLOVES OTHtR rnOTCCTlvE IOUIPMENT -'jrsxjrfz.' rubber EVE PROTECTION cheJnlcal Co0r,leS . i^xsrssxt:; SECTION IX SPECIAL zxrs.9 ,r.nr,ttj:\'st w r.-ttrrjrx*; .VT^^.T.Trr* ,r:rj?:jx:rair.n;re :.r 'PftLf ALMJUNji TO fj. TAf.(N IN HANDLING A NO STORING Avoid skin contact and eye contact. Avoid inhalation of vapors. PRECAUTIONS ;'xz.zz^jcz.ts:zrrtET.'t 7i~7rc.!rr"^rrc^:.'rrr.'.J' ~j oThcIiTTTcauTions ' IE mi^ mr.c-r r.i While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AiiD DISCLAIMS lALL LIABILITY FROM RELIANCE THEREON . J AG : HOH : JTG : Y/13P FUR 003290 l/?b/7? WATER PCB-SD0000071432 Forn Approved 0MB No. A 4 -R13 87 ( pprovdl Expires: July 30, 1972 tl.S. DEPliilTLlEilT Of LABOR Forn No. OSKAHay, 1971 MATERIAL SAFETY BATA SHEET' WATER PCB-SD0000071433 Arcelor 125- SECTION V HEALTH HAZARD DATA 0.5 ng/m- of air I l I | C "S 01 Ovl ( ii"OS^i Skin Irritation In the form of ehloracne, systematic leads to nausea"^ vomiting, loss of wei-gnt, eaeg.a and mi a Cl *C *'<0 MAS I AID PSOC(Ou*t$ He-ove from exposure. Remove contaminated cloth!nr. R contacted area with large amounts of water and soap. Tlintoxlcarion aocorr.ir.aj.. t Wash Refer t< physiclan, 1 A P i . \ U^STT A8l t SECTION VI REACTIVITY DATA tO'ip-nuN) /U'U }(J&flESBAABiCS3i^JC3SE2 STabU NCO^fAl AjUllV /^Oittiolt (oai-oidW *A?AfDOuS OtCOWfOSmON ^OOUCTS H H A 2 A ADOUS *0l YUl R2 At lON UAr OCCUA vriiA >*OT OCCUA CONDITIONS TO AVOID X ll ) I'S rl A Cil '1 ki.U:[0 C* j*u.O Absorb on clay, sawoust or other ah.sorb ant material.____________ drums. Bury in approved chemical landfill in accordance with jj local and state regulations. f! *`sl|Rur'n`jnnan approved Incinerator in accordance with local ana state regulations SECTION VIII SPECIAL PROTECTION INFORMATION t a 1 c*' #fcOitCTiCs / .'prfj/t iyrr * | VI NIIUUION iocai umaust Yes - for vapors i,lclAl- nTTl vapors. 1 MICMANICAl ICrnttall OTHtA i pHoifc'wi Clovis Rubber * ttf roiCTioN Chemical goggles fc GTm|* 'POMCHvC iQuIPUtNT irx^sTT3X7*r SECTION IX SPECIAL PRECAUTIONS fi Avoia bsi Kin l#al nHaVOei(v'ev A.c*,ioWnvt^ai'hci t, avoid inn. a_lati.cn of vanors OlHtA M(CauIiONS FUR 003292 ii- nrTrrmmej While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAXES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAG: 5iOH : JTG : VBP 1/25/72 WATER PCB-SD0000071434 Tori"- Appro vac' OKI; M o . A '< !< 1 3 i) 7 Ap|)i evul f.>. p'l i es : 0 u 1 y 3 0, 1972 .1.-i!' r; e rr:........ v r ; c > L;.o. UMf U.j... I ; Li........ ; For it. i-o. 0S,L'.; Mcy ,197! ' ;, [ . i.m r nn"i:,V -.! biv:- r L v l./i 3 y it k Xj/07 . N !<:)>/ N TO C O'-1 V`A NY -/. Slict. i-iiy. Sf*n, end >:/. C.cr-VJ 11 LOO ' N"ourrih Lindhc:rgn noulcvrurd, j *.- C * v u m |. * ntj i r MC,' v i I _________________ j_ Cii 1 or_J r;ated nro;natlc SKCi'K.I I Iem.b : . v 7ki c t cl c`*ko~i ;*mo "" ' 7 ' / St. J.,ou5.:;, Missouri 63166 ................ 1TAikDr. NAM l AMO I Y % P MV*/; I Aroclor 120? Mixture . _ t ________ _ ... .......... .............................................................. . ^______________ _____ _________ _______ ,,....______ ___ (________________ -.......... M , ................... ......................SnCTIO:}f.;- - - -npi K'r-'nnriTS.................................................... _ _ ,ll ................................ ' ....................... ' '- ............ i r atrds, purse nva 11vlt, r- solvents * i- tC,w. s I 5 \ | C / I * t \ $' . . j VlMlClf ! : civi k:s | ArouivtS | (Tm(HS ` % TLV (Uni..) ALLOYS AKO METALLIC CO.MIIICS Cl ASt l. i IAC ' r TLV 1 (u-H.) j1 AllOVS .1 UCIAUIC COATINGS Mtu j;-TAC nus COATING 0^ com KUX oihccis I1 . I HA7.AP.DQUS UIXTUI5EJ OF OTHUE LIQUIDS, SOLIDS, Oil CASES 1 ii . TLV 1. (Ur.lll) i i __ _ . '; v* r.srtr.v T~r vrsi~Zi\ r.rrvx: rT^KT^ctLtr:^ j SECTI ON III PHYSICAL DATA \v..\v v*\w; j/vr.n.T.:. :uv;/*\r-ir.-:ru^-xaejcss. i 60:i''.c poiai mi L. (bO min - ?0-I|25C '3 S-'CCUIC CRAVIIT ljO=U( z^/S^oc) j VA''Ol( FAI SMJI't W K(,l >t avail PUCCNT VOV ATUt nr voi uw i%j 1 vatG* OINMTy |Alft= II 1 lf CVAI ORATION ftATF N at avai .1 . i_8p__Acl_ =u j so.usKi.t.uivA.i. 20oc neciicibl J TJi cue i. 1 N. A. 1 o l! O. Vo __ 0) SECTION IV FIRE AND EXPLOSION HAZARD DATA /TsmToi.T YkV.II<`ul.lf' *. ' ' j~ fLAUMAPU ll.-MTi UMN\.UISH|NC V.UA * $. if. I/.T l im f lOHTIN(i Pi'ioc lO'.JAfS Respiratory protection v.'hen f.1 r.htlJin- fires v.'horo exposure to vapors or canes is possible. . *hloride s and chlorine) can be evolved Jn fires of this product.___ _ ___ _ _ FUR 003293 f. ) WATER PCB-SD0000071435 Arocioi SECTION V HEALTH HAZARD DATA ____n_< _S_.H_0v_o__{ _IM_U___V_A_l _u_t __ Hot available JnTicisoi ovi.kjo-oiuni ", ' ' ' ' 'j| H ,....Skin irritation in the: form of_ chloracnc, syr.tcmat ic J n Lori cat x cjj j ii leeaaddss to nausea, vvcomiting, rVH' AT('rr<it A76~i:nbc(.o^'s __ loss of weight, 7 ' .j edema and : 7T~: aCdT^rfrrrrrp.'VITrn Ii --.----------------- j Remove from exposure.. Remove contaminnted clothjng. Wash j contacted area with large a mounts" "of" wa t er"and s oapi ire.fer~To" j phy r.iciai:. " ' \*T M"i l\ * UNS1 AOU SECTION VI REACTIVITY DATA . z..*-C *"COnouV6'nVi'o"av6Vo'*" '' ' smut i/vC OV.f'Al aOU 11 V fUairtinti to avoidl X * hazardous (HCOMPOsiTioN mooucis CO, CO?, smoke, soot, chlorides & chlorine___ ha; AiiCOoS rCjUUUMZ At 'ON MAY OCOUK v/iu not occun CONDITIONS TO AVOtO zs:r:\ r. : r ~ ji.v zzi-'LXir -r.-j-rrjzTZ zz.'L'ry- if rzvxz:#zrr*:v SECTION VII SPILL OR LEAK PROCEDURES ----. -z.~:rivrr""7:n,.:',.:rr (Vu's 10 B{ JAtlN IN CAEi MATfRiAl IS niUASCO Oft SMlUO I Ahrorh on ?i?.y,sfjiv/flu&.t.Qr._p.tbgr...,..a.b,s.Qr^..arLt_materl.al. P3a.ce In j drums. Dury in approved chemical landfill in accordance with local and state regulations. ' }*tk)'r:n''TrV an"aDnroved incinerator in accordance with local "" and state regulations ;thx J!_i \ SECTION VIII 2 tkztsjic xittxzzr. SPECIAL PROTECTION INFORMATION nisi'ir.AioKrPftoucnoN^^^y'r^^ ^^_ne5 approved respirator for organic vapors i-'i V(NTlt Allow l OC AL f KH AU$1 yes for vapors Sf'CCUl. MtCXANIC AL (Crtyttal) OIHf R rAOli r nvt ciovts Rubber 01 1MIH -iOUCllVI tOUICWINT tn Pn0Uci|0NChemiCaT gKE1g ' s4.t" "-vflr.T.Trj-.si,c^raagu^^^ac3a^x^na^fiCT^rr.^^v'^T^^.~^^rr?7~~jLrr.zrir. n::-:;T.,r;:zr>'a''r-V-T-;:'T--'v SECTION IX SPECIAL PRECAUTIONS i'iiic'AiW'iovi Tow ''mTii/in'MANlj'u'/G''XNd"Tcwiito::'xrfi',` 'r~' '* *" i__ Ayoiq__skin and eye contact, avoid inhalation of vanors lOl.ltll ir.iCAUllOHS While the information and recommendations set forth herein arc believed to be accurate as of the date, hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAG : 1101 i : JTG :WDP 1/2U/72 FUR 003294 WATER PCB-SD0000071436 Form Approved 0MB Ho. 44-R1387 Approval Expires: July 30, 1972 U.S. BEPft3TC8!T OF Ll'cna <v = Form lio. OSHA-pr . ; Hay, 1971- ~ % 2. (o t O - >^1 (^<^-4. I I C 4p ^ fiWESCL SSfHT 8jKA SKJ _ r i.n.-: oT-j unu* *C iDMcrrj Nmr MON MAT-'TO COMPANY *ydH(H ;.'wT/ji, CifK. *nt/ Z/F Co^fl BOO Norih Lonoberrih iSoulcvard, VHCMl(lt l|iM[ ANO irHOSTUl C Lm-C A u r A Cl.;. % Chlorinated Aromatic SECTION I CuCACCHCr TClCPmqhC no. HIM 6^-ior>o . St. Louis, Missouri 63166 T*AR* N * l- f AND PWONTMI Capacitor 21 Mixture' Jl SECT I CM II j-jp.yp p.'*-c't F AIK T S, MIUKVAlivn. A SOLVENT} f IGMINIS TLV <U., 1 ALLOTS AMD METALLIC COATIMCJ ASl UEIAL CATAUJT ALLOTS V( MIC It SOLVt NTS ADOlUvtS OlHUS UlTALLIC COATINGS f ILLCA UtTAl costFLOS COATINC o.t flUI HAZARDOUS MIXTURES OF OTHER LIOUIOS, SOLIDS, OR CASES T L V ;.i --J- uv . (IJ.e.l I j.sjj-uai.a.i;i'Arnrnic SECTION III PHYSICAL DATA u --P II t i| J SOHIHO FOiNl Cl.1 ?6o nrn . 27 5h3.20 j VAFOfSSUM iM0.lsf._ lnn0p VAfOA 0(WSlT> IAIA- >1 J 1> .005 .. . N05 Avail. /\ O o J-4 j r.er.lir.ible b AAf(AhAKC( AND OOOF colorless `frjjagxxsBTgsSoiapaL^ oi: [j SECTION IV FIRE AND SMCIMC GAAV.1Y IMjO-.J. 25/15. ^0C) '(C!WT VOl A T M, ( CY VO(LVt| IXI naT( 1.167 1 >! A 1 <1 s i' nx ^...cvv-j.0 i/Wv nzriznrxL EXPLOSION HAZARD ragn-Mujrr yra^s^r- %. t DATA jl i 1 1/1041_ SJHW<7VSZttf;M j f a$h bOl,i uwmoo Mot Avail i..p.ci c^--Tk.. * fl 1U< APU UMlTA j a .r il U'M Mot Avaitf: u 1 (/a C'e 1MH1'ciln, CO?, or dry chemical, Recp.1 rat o r y protection when fir-htlnr. Circs where exposure to I vapors or pjasos is posrioxe (l 1 lii'ii!d']yni Ooa l e'l :aVi^AVc h lor i d c a and chlorine) can be evolved in rives of this product. FUR 003295 WATER PCB-SD0000071437 Capacitor 21 Ttrrr. x^a s m v. x h 1 Mt,l >iC'i.U i'UiJ v*u SECTION V Available HEALTH HAZARD DATA rra c ich.^ato {j1"(^klC!nj rriuallon in the form of c h 1 o r a enc, systemat ic intoxic a tier, leads to nausea"] vomiting, ' loss or v;eignt, edema and abacmir.al pa UW(CG('.C> `Idlinsi AID f#DClOU*[S ,, I Remove from exposure. Remove contaminated clothing. j contacted area with large amounts oi water ana soap. | to physician. Y -- --------------------------------------' ~ TTrw ---- -Wrrw*erjr-rrr-tr -rmr-i-nr ,, , Wash Refer UNST A6U 51ABU JINCOMrATABUITT tKattnall in foid) SECTION VI REACTIVITY DATA __ 5 r: zrprz^x a cmTKMnazxz. ajrrararTr.'Tyw/v^ r 1 . UNGi lio.s a I 0 /. vOiO :ytr?g.cirvM | i! CO,jHAJA/inOUS DtCOMPOSUlON PRODUCTS ,' jrtAfAAOOUS . jpOVYWCAt* Al ION MAY OCCUR Will NOT OCCUR COp, smoke, soot, c,h-lorid. .es CONDITIONS TO AVOID X and, c.h,lori,ne / SECTION VII SPILL ^nrmfgTirprAffTt *tlt-t:-\y^r^^irrrfSTCCArnz^ i(i5 :o ut ia*.(n in c /:* KAi(fcAv. ($ niw.Aio o*< s'klcO nuDuiu drums. Bury in approved chemical OR LEAK PROCEDURES landfill in accordance with local and state regulations. j burn 1 n',lanaDproved incinerator in accordance with local and state regulations. i! H u H 4uizrv SECTION VIII SPECIAL PROTECTION IN FORMAT ION TZI.TSTLmrZ'Z.TT. ''v*rrx7%zzTsrrL-r.! `6Weau of Mines^CS^ifiAlont PRO I ten ON f.'pteti approved respirator for organic VtNmAllON lOCAl fK*US! yec. _ for vapors SPECIAL vapors, j WtCHUNICAl. (Cmrrtll OTHER L PAOUCHVI CiOV'tS rubber ; oth** rHoncnvf iouipuint tvt PROTtCHON chemical goggles \< l mZJTTZ jancEC-r-w .* \ [Lsr.Tr xt-o SECTION IX 5xr^r^r.ry- Tr^rr^r-'-A 't* .w " u;* 'zrr-LrrTTrjrrn PfltCAUTlOsS ;0 Ol W.mS IN hANulK'O ANO irU.'-NG t Avoid 51-:in_ancLev_e__c_entdet^ Avoid inhalation of vapors. pOTHtft rtctCAUllONS SPECIAL PRECAUTIONS TOerssai=a.TC45k?wo cagrrrraiva^xvsja&nzizrcrjrr^- i] 1! While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY'MAKES NO W ARRA '.* 7 Y WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON J AG : 11011: JTG :YJBP V1V72 WATER PCB-SD0000071438 For..'! Approved O'/A lio . 4-r1387 Approval Ex pir c s : July 30, 1972 Mc f r'iv-'";ny r\ i nr",:) U.U. L'i;w l S U LiW.I SECTION I foriu iio . OSi!A May. 1971 8ioU WATER PCB-SD0000071439 Inerteen PPO SECT 1 OP V HEALTH HA'/ARD DATA \v Vabi^ InlMulnll&soori oL'VvLtRRttxJPpOoSsUuRrEe ^__ Skin irr-M'RHnn In the form of chloric);?, systematic ,1.n`;oxlcat' on j leads to nausea, vomiting, loss of '..eight, edema and abdominal paTrf Twr'iC.rLTv-XTTi riRsi Ai'oTnocToTics : ~' i _Pk'i:io.v.cuJ'rpat.oximsilce_,__ Remove contaminated clothing.____ Wash_______ J contacted area with 'large amounts of "water and soap. FcTer- " to physician. SECTION VI REACTIVITY DATA ' f$\A t) 11 H \ UNS1 ABLE "C'O'fib'i 1 f"ON$"fTavoid k * "" SI AOL t iNCOVf'ATAfuui* (Unlctiah (o avotdi HAJAftOOuS DECOMPOSITION PRODUCTS CO. HA? AROOUi* POLYMffU? M ION WAY OCCUR WILL HOT OCCUR CO?, smoke, soot, chlorides and chlorine CONDITIONS TO A VOIO X 3stc.^vax2:?;wiTt^r:.r2rs r.zTrz&JT'jrzz agasgflrr xctxc SECTION VII SPILL OR LEAK PROCEDURES <r/rr.^r*.T.iT* i * ~v~ ~~*1T*-*LL~-~C11 *. - > lITf* IT-- SA wUL. f. r, JALm . d yU'l*/*. uLi*ivLi. JjJJKVrrt [ThASb1 so'pHiro1A<CoNnin CcAlSat WyA, UHsIAaI wIS dREuLEsAtSEDoOrR SoPILtLhEDer absorb. an,t ma. ter. ia-l. ,,P.lace i.n drums. Bury in approved chemical landfill in accordance with local and state regulations. WAfjnrn0ynMan0aDoroved incinerator in accordance with local and state regulations. LjYvna.1 SECTION VIII SPECIAL PROTECTION INFORMATION an? aszs t^.aaagex-TarA'vawBjjx'a; jLaamjBUW^tnaas^fM3jgjsaagig amaj ixiraLCT^zccss TOn^m: ~--'zrrr.r-: ' respirator* protection of Mines approved respirator for organic vaporr Vf N THAT ION LOCAL EXHAUST Yes - for vapors MECHANICAL (Ctntrat) SPECIAL OTHER 1 protective cloves t______________ j OTHlA PROTECTIVE EQUIPMENT * r- *- rubber EYE PROTECTION chemical goggles aayraJMASJ? as 'ar.ajagsrrxmyr ct c:A^u.xyjcrn: SECTION IX SPECIAL PRECAUTIONS TV.":zJ^i^Fr::-:c.:rm-r.':.T.-va.rr3ar.i^Fri3r.3rr^-;:TLSFXRotrcg--^^^ j HR C A LIT ION S TO Ot TAAEN IN HANDLING AND STORING i______Avnid ski n_and , eyft. contact,..--------------------:---------------------------------------- --- Aoid inhalation of vapors. OlKLR PRECAUTIONS ,Lii rjji-:...vj.l.tt.v.-ok While the Information and recommendations.set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY pROM RELIANCE THEREON . JAG :HOil: JTG :WDP 1/26/72 f u r nna?9R WATER PCB-SD0000071440 Form Approved 0MB Ho. 4 4 - Rl387 Approval Expires : July 30, 1972 U.S. CEPSSTCSIiT Gf IK3S Form No. 0 S H4 . May, 197 1' cf -LCjL MATERIAL SfJETYMA SIE?- Z \ \ ! O'- 2- f"? SECTION u*Nuf uiwwcn'i hamt MONSANTO COMPANY AQOHltt (.Sk.r-l-ft, Cilr. *(*". ntf /</' CodJ 800 N or In Linobcrpn Roulevard, St. CntWlCiL N*MC *Nt SthOhtuI r. cC H Ml * V A Ml t * Chlorinated aromatic Louis, Missouri tucncr.NCY tcupiionc no. (31.41 604-1000 ' 63166 1AAOC Nl^ AH 0 iruONYUf Inert^fan FOAuul4 Mixture . nu 1 ,I \ IJ PAIHU, POCif V*tlV!l, . SOlVENTi f lGU(Nf$ j ^ | (JV*, ALLOYS AND METALLIC COaTIMGI AH W( TAV TLV .1 (I'llllll ; CaI Al tJT auoyS V( MJCU SOLVlNtS Aoomvt $ OlMlftS UETAUIC COATINGS man uc-tai nus coiTiuc on com uux OtKCHS .11 KAUfcDOUS MIXTURCS OF OTKtn LIQUIDS. SOLIDS, OR C AS* $ TLV DU L OM.ING O'Nf ff.i 7Co mm ICCKUS^UR.'. SECTION III PHYSICAL DATA cro*ajjanrfltfW/\Lrr4.vctiwma5CLKs=M3ca7JTv;3:rxCTiVL i 3b5-3C0C| *,(C',IC c**vltT IH;`" ( 25/25C) 1.380 VAAOPAMS4UAI H*n> Wo,l( VAfOH OIKSHT IAIH- l| w *oivmiTrihHAii20oc At-PEAPAUCl AKO ODO* ZlXZrSTDCGS 3 ir.m) M*C(U1 VOIATIU er vot UM( IM II. A. negligible <0,02? (V/.fOAATlON HU{ <1 coToTTe JijoTI aromatic odo: =zar3Hirflir.naqjEagCT;i3 r^i/iJxw/n^:es-JiKsr.-xr^niivsr:tJZj-raK.'> :* SECTION IV FIRE AMD EXPLOSION HAZARD DATA 7rmTtrmrii Hash to-H< iia*im>.i ui.ai C.O.C. 180 C CVTJCVKV. EL KAMMAILt LIMITS l L'< I !T-.Sr,-----IMt -------- miNGuiSHiMo vcoia v/ater foam, CO2 or dry chemical 11 Special n il 1 iGiin-'.C rnociOt..' ES RcsM ratn"V protection v;'-,pp f < r'-it.-* nr GIkap..u^hcr.p_cv-prLriiLrp. . 1: to vapors or gases is possible f-r3 and ^lorinc) can be evolved in fii'es of this product ifrt:JVZ'i: 'I r~`fUiUtZASUL;VkJXXtt'Jr:.V~TLi^-2Ttx-_<--tr^CZrZX.riBU-TC~ citcj'?-vy:lu=~ FUR 003299 WATER PCB-SD0000071441 merteen 54201 CM SECTION V HEALTH HAZARD DATA _ r*:grrgiyxflirr~r_jzxzr?rvrryr slxgztc VAtH Not avallable. (IMCtS 01 OV(K( HOSUAC 'U Skin < ~rl f.nfrlon In the form of chlorac.ne, systematic Intoxication I , leads to nausea, vomiting, loss of weight, edema and abdominal i! Tin RC.i XO A*v[i I il.SI AID rOCtOuli(S __ _ __ --f j Remove from exposure. . Remove contaminated clothing. V/ash contacted area with large amounts of water and soap. Hefer to physician. '3--T n^tesaraxsa-'; ~~~ '' la^rmB-nirr-nraaCTnr^reimjsmrif.lauji u xi nr?i--nrr cr'-rrv,.r- i SECTION VI REACTIVITY DATA TTTCTTncHir.i starrxia I O AVOlO STAftU IWCOUI'AIABIIITV (Uaitiioll ro ovotdl HA2AAOOUS OCCO'APOSITION PK00UC1S HA/AROOUS 1*00 UCMf A1IQN WAY OCCUR Will NOT OCCUR conoinons to avoid X 7 i :1 II snm vxzccu^tr^ri: ]j SECTION VII SPILL OR LEAK PROCEDURES T2?prC'TTl ji'ja' Z.iX.J0." SI{Hi 10 i`t lAM* IN CASl MAU^lAl l>cllAb(D lM b^lt-LfO ___ Absorb on elav, sawdust or other absorbant material. Place in drums. Bury in approved chemical landfill in accordance with local and state regulations '.wash msfosii winBouorn in an approved Incinerator in accordance with local and'state regulations 1 !` SECTION VIII SPECIAL PROTECTION III FORMAT I ON is -..r_acr xzrjtxzn Lr^r^^w'T^^-u^KTirrg.? rrux"/ ftcspi^ATOKY i-houction (St-teiir '^fou^o-au of Mines approved respirator Tor organic i< VCNIlutllON ' lOCAl (KMAUS1 Yes -- for vapors S('C(Al * vapors. MECHANICAL ICtnr'tll oimeu | I'ROTtCllvt GlOVCS rubber YE PftOTCCIION 'chemical goggles rJ~u-~rsuL^aT-t \c< %vrr3miiyeago<ioTxrg*zar,ocrc^^ SECTION IX _ . .. .. .............. INlC/.UliO'.b IC. n. lAMli .h MANJUUO A,\0 SiOmPt. I Avoid skin nnd eve contact. i 01 HtA PiitC Al>< lO'.'S SPECIAL PRECAUTIONS --j.'sma rz -amass: r. .wrE7XW'5SRMGSnc5?^^ , , , , .^ ^ ^ r ,,or.^vnr. Avoid inhalation of vaoors While the information and recommendations set forth herein are believed to he accurate as of the date hereof, MONSANTO COMPANY MAKES NO WAR FA -T Y WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE TI'.IIREON. JAG: IIOII :JTG:WBP l/26/'/2 FUR 003300 WATER PCB-SD0000071442 Form Approved-OHB No. 4 4 - R128 7 Approval Expires: July 30, 1972 U.S. BEMfiTL'EElT Of IfiKSB Form No. OSUAHay, 1971 haibbal safety data mx SECTION I UANaMCtUAEI'l Niwf CUCMCtNCY TSUenMONC llO. 1 MONSANTO COMPANY m4l 6q4-iooo A O Of< C 4 V (ALTi/f. Sir* (. C Ur, $(4i9.*t\d IIP Ca<tl _ ,, , m , . 800 North Lmaberph Boulevard, St. Louis, Missouri 63166 f ( ChLUiUl KlUC AMO ItnONYUI T n A D C Niuf AMO IYNONTM1 C m Lii C A t, PiM.1,1 Chlorinated aromatic ' Inerfce^n ^OflMVLA Mixture rw_LArocln . . section it kPAIHTS. PQfiC*VATiVJ, SOLVENTS t iCWfNfS CA1AIYST F'.v'-1 tlv \(Unit i;y: lacfaTTCS; ALLOYS AMO METALLIC COATIHGS 9 AS( Ut T AL Alters VIHICll Aoomvis MCTAIHC COATINGS FILCEA UfTAL PIU5 COATIKG OR r.Of flU* OTHU5 OIKUS HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS, OP. CAS*?$ "i-T &LfL-^Z-T?21 Vi. tlv (Unit.) TLV f l * i * 111) SECTION III PHYSICAL DATA ^ ^ .Oll.NOPO.NirM 750 mj71 (2r)/25C)25-3C0od S^CCIMC CKAVHr iKjO-ll ll. 3 0 0 VAfOR HUSSUM |nrn Hg.l^ VAPOR OlNSITY IAIN- \ | soiuou.nr in wAttR2 0C Atff Ar.ANCI AKO 000" cj _-J ) 3 mm PCBCIHT VOl MU bY VQUA`( (M I VAPO* ATION 9 JLTt _U3lliL&.--111- <1 negligible <0.025: colorless------------------------------- -----o------i--l- "aromatic-- ------------------------ o-----d---o-- *r ( T^erBcgn^Tii=gw?x2rig;Tyy.PwiS3 CTiarenjre irg-.T^s^w^utcrs^a^: ?-> /-m me;c SECTION IY FIRE AND EXPLOSION HAZARD DATA 1X?75T3^C.T7rjrrXTKEWCT^PH'-r.ArtC2t77tlX3 uCrtTLUItLIX~ j'Jm1LL7/ET^V&l^-nTL.-.JJ ^EiWT -HIa t.vr A-- HASH rcwi lU.ihon KA.OI c.o.c. iGoc 1 KAlXV>CwC LMSTS 1*1 Vl I rtlTTr:-----------------hfr -- uHNcuiSHino'.-tDiA V/ater foam, CO2 or dry chemical smcu.i fiat nr.HiiNC taocloukes Hcr)nirp.tr'"V protection V/hen flrhi-.-inr flro*: v.'hnrp evnA<-.ii^A to vapors or gases is possible. u,iyjyMv TovFras^f5?chlorl:ior and chlorine) can be evolved in fires of this product. FUR 003301 WATER PCB-SD0000071443 inerteen 54201 CM . SECTION V HEALTH HAZARD DATA a "" i'CTi" 1 HA^HOlU l (Mil VALUt Not available, jtHIC'S 01 0 VI Rf irOSl'M . i Skin irritation in the form of chloracne, systematic intoxication 1 leads to nausea, vomiting, loss of weight, edema and abdominal itwuiCINCv and unsi aio rnoccouncs Remove from exposure. Remove contaminated clothing. Wash contacted area with large amounts of water and soap. Refer to ) 1 i ' ; physician. j SECTION VI $1 ABttn Y UNSTABLE STABLE iNCOMPAT ABILITY (Uatfiialt to ovoid) HAZARDOUS DECOMPOSITION PROOUCTS HAZARDOUS P0LYWEAI2A1I0N MAY OCCUB WILL NOT OCCUR X REACTIVITY DATA COfVOniONS TO A vote SECTION VII SPILL OR LEAK PROCEDURES S'U^S ro 1*1 lAiiN IN C'ASt WAliHul, IS Ntl t A SE O 0-4 S^ILLfO ' Absorb on clay, sawdust or other absorbent material Place in drums. Bury in approved chemical landfill in accordance iith local and state regulations, WASH DISPOSAL MC-IWBOuD rn i,n an approved, i,nci.nerat. o,,r i.n accordJance w.it.h. local and state regulations. ^ SECTION VIII SPECIAL PROTECTION INFORMATION !--r--u--n---n---A-- io--nv no.t.c.cuoNDT..j3. ure.au of j>]iricf approved respirator-------------------------------------------------------------------------------------7 3 forixxji orignoaiancii2c=cv w ! VtlOILAl'OH i oc*i ir.'iAusi Yce ,, fo), vapor3 scfci/,i vapors. MICMAWC AL (CtWlI OTHER f'AOTECUvE CLOVIS rubber OTMIK PMOTCCTIVt 10UIPMIWT in PHOTtCTlOK chemical goggles i SECTION IX SPECIAL PRECAUTIONS rNnTi*c*/v.u;1f1iYo?i..xs^WiCTi -;tiv.? Tuvrmr n m h.mjoiii.C and >.^ JlSiZ ITT?H!av-erttttj^ttXlznrrrrF: mr".r~r-i ,,x-P | Avoid skin and eve contact. Avoidinhalation of vapors .I /01 HfcR PJitCAUI IONS i jj I'-r.-zz tjtx:r.^nusit FUR 003302 .'-.tiDwvj '^-jorviax-v-no:xxtjxz VT.LJ Whi 1e the information and recommendsti ons set forth herein are believed to be accvi rate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPE CT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. J A G : 11 OH : JTG : W13P 1/2C/Y 2 WATER PCB-SD0000071444 t- o ! nppro^o uiib -P.1387 Approval Expires: U.b. UU'Uti l ,.;H I Ur LfWjij! Form Ho. OSHAHay, 1971 July 30 , 1 97 2 M111TfitFI LOi vilA.. le* U?.PtXil ?L. VS t' Rt-J f"\:; Td ^*^ UWP-(LbT' rzr. SECTION 1 MONSANTO COMPANY . i rr"rn . 4 Cay, *n* ZIP C m*0l 1 bOO North Lindberpn Boulevard, St. j v'-tv ANC IrNONlUl 1 ..................... Louis, t w t A O C.H c Y TILlfHONl HO. ' niU... l^ ' 6Q4-inoo Missouri 63166 ' < T.h*OC H A U C A H O IYNOHYUI _____Inerteen 7 0-30__________________ Mixture SECTION II R PAINTS, r Of if KVaTiVES, l SOLVENTS . f lOMI MS cai Ai>ri R.W.frOOUS INCHED TLV (UniliJ alloys aho metallic COATINGS ASC MITAL alloys vehicle SOLVENTS ADOITivtS O'HLAJ METALLIC COATINGS FILLEA METAL YyLIS COATING &> CW ELUt OTHtAS HAZARDOUS HIX7U5ES Of OTKES USUJDS. SOLIDS, C5 CiiSS TLV (Un.) TLV (U.-.lMi P. IOU.ING FQiNT ff.l SECTION III ^jLjriifc:a^'axwtxJW 760 mm 206-R00C V`*OA YAlSSuK lrTrn ML.' UAYOA DtNSltr IAIA - 11 Not: Avail . Nop Avail. SOlUHLUY IN Ml( 20c nepilipiiblb <0.01% AFflAAANCt AND OOOA COlOTieSS Oi 1 PHYSICAL DATA ^mazoe^xocwoscs^ SMOMC 0uv,mHi0M,(15<5/15[5Oc AT(VCOLNUTMVEOL(%AT| IVC 1 11 1I VA*0AtlOM A ATI R ar =j 1.523 M. A <Jl aromatic odor "^waaxRwoa^oLPiJccgeoj., suirLLXLSLiwa3<o*iLuejecogcYgg'J SECTION IV FIRE AND EXPLOSION HAZARD DATA llASKfOiNl l`Winoo w.*0 I LTlNGUI JING M | OIA None ILAWJAtLt LIMITS Ul I U.l mx TTir |i SMC I al I lt * iGHtiNG f AOCIOUAES n Respiratory protection when firrhtinr fires where exposure to " vapor' s or gases JIs p. o_sJsVi. bT l-ei Up UmNUSrUAhLl;M."M tA.NnDrtlrM.OSrIOaNsH".A-Z;AUDfSoh,lnrldes a^nd Lchlorine). can .be evo.lved. i.n fir6S Lhls^product. .......... FUR 003303 WATER PCB-SD0000071445 , Inerteen 70-30 SECTION V HEALTH HAZARD DATA . If^AlWOvO IIWH* VAIUI VH1 o*t_ available. ^ l!"l'l<I)n0vi.rr^a!tion in the form of chloracr.e, systematic intoxication j ^ leads to nausea, vomiting, loss of weight, edema and abdominal pair jl Ml ftf.( '.c * AKD no ST AID PAOCl OUP.IS _ . ] Remove from exposure. Remove contaminated clothing. V/ash 5 contacted area with large amounts of water and soap. Refer f | to physician. ,st Adl'l T SECTION VI REACTIVITY PyMCTMPTTlQi'gOpW TgXSQJOgS -tt yr? unstable DATA. * u i-r~r * STABU . INCOUPAT ABILITY EWalfliol, lo cuoidl X CO, CO ,nAJAHDOUS DECOMPOSITION PRODUCTS 2 HAZARDOUS POLYUCAlZ ATION UAY OCCUR WILL NOT OCCUft smoke, soot, chlorides CONDITIONS TO AVOID X and chlorine /nM [| i-to T 0 fc|U t N tS j Ahsnrh nn.. i in drums. SECTION V 11 SPILL OR'LEAK PROCEDURES k&aaszxaxrirvsiv mamur away^nr nstfkvr v a 1 (ft i a t IS ftlUA&(0 Oft SMiUO cpur.imt nr nrnnr shsnrwnr. nnrr>-l il u > drq Bury in approved chemical landfill in accordance ........ with ; .local and state regulations . j hash d<>os*i. withod gurn in an approved incinerator in accordance with | local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION is''iato<'poitcTioN <>r'gureau 0 Mines approved respirator for organic ^ VENTILATION LOCAL UHAUST Yes l tofA vapors SPECIAL vapors, MECHANICAL tCrimll OTHCA 1 ^OlfCTWt GLOVES rubber Y|t rAOTtCTION chemic al goggles OThU PROJECTIVE lOUIPWE NT SECTION IX SPECIAL PRECAUTIONS ' ........................... . imii 1 mum 111M11 punir 1 mi i,\ rrrmnrn---prrrtrTTriTT^YTrn-- Xvoid skin and eve^icau'iOnS *0 61 r aMn n handling and sioa-No contact. Avoid inhajl-%ation . of va. pors. OlMlft *MC AVTiONS dEaXpaaceoastaca While the information and recommendations set forth herein are believ to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARR^ WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREC JAG :HOH; JTG :WBP ' FUR 003304 1/25/72 WATER PCB-SD0000071446 1 Foi u> AD,n)'0/c-cJ 0.:: No. '.<!-!<! 3!i7 f: p.'"r t:` 'V [r. :p V> For si , os:: May, 19 7 r I I WATER PCB-SD0000071447 Inert car, lGQ-'i2 SECT I 0 i( V HEALTH HAZARD DATA f: '''i 'itoi D :.".M vai c{ Not available. HHClSOl Ov'.lUt.'OiunC ,S^-in irritation In t he for m_o f _c hi or a one , systemat i c .1 ntor. lent 1 On leads to nausea, vomiting, lose of weight, edema and abdominal r -I l Ml net NC ' AMO imsi AIO MOC t IH'iU S ' ' L Remove from e_.cxdosur Removc contaminated clothli\r . V,'anb_ ! contacted area with large amount's-of water'and so dp'. Refer "to" nhysic.i au, SECTION VI REACTIVITY DATA cou'OiiiUNi: io AvC'iu STABU F OWPATAimn* /UotrM'jJj to avoid} CO,HAZARDOUS lUCOWPOStUON f'AOOUCIS CO^, smoke, soot, chlorides A chlorine 1-------------------------- IkAZ AHOOUS rOlYVURl? AllON WAY OCCUR WIU NOT OCCUR CONDITIONS TO AVOIO -RTTr.r SECTION VII SPILL OR LEAK PROCEDURES \(> ijf'l AfttViNCAM l/Al t HI t i- 15 REWASC-O OH sTllUO s-saca.r:avsj.^ Ahsorb on clnvf sawdust or other absorbant material. Place Tn dz~ums. Bury in approved chemical landfill in accordance vrith local and state regulations. Irt/.sii :>i^po!>ai Mtm]3oourn In an approved incinerator in accordance with loca.l and state regulations, L_ \^v. /.v ,;r j.`s - -niarr TJ^osn-t'.w irjscaxflNfrOTsstsarj'xrar.'a amar-s SECTION VIII SPECIAL PROTECTION INFORMATION "I! nisHi/iAiodi rHOHciio^o'f't'ri '"'bureau of Mines approved respirator for organic jj Vf nihauon LOCAL IXHAUST Yes - for vapors SPCCIAL vapors. | MSCHANICAL fCmrtai} rrouci ivi ClOvls 'rubber Y PAOTCCTION OtHCR chemical goggle; 1 i OiHlfi paouctivc (QUIPWCNT .r iLdiTXJ' jtx { { ;r/xjiTr-canr; SECTION IX xuzztjxT^siysiiarCTiccssrrJ.r-'-r r.cr. SPECIAL PRECAUTIONS iiTiTcauI ion's to'w'TAifN wTANOUNCf ANdTj cn'i'HCi !___ Av.qJ.1 ' ' ' eve con'ta' "ct. Avoid inhalation of vapors otmu rn-CALmoNS L i While the information and recommend ations.set forth herein aro believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAG:non:JTG:WBP FUR 003306 1/20/7 2 WATER PCB-SD0000071448 rm Approved O0MMB . 44 -P. 1387 proval Expires: U.S. DEPf,iii:.;E!!! C'f (ADOS r\' Form No . '0Si:4 - ? May, 1971 , 3 -tJU WATER PCB-SD0000071449 Inertcen 54201 KA SECTION V r^-j. _ JcaHBCT?tr.sitJ=y3 "'wl"OlDl"',"v^1 Not available HEALTH HAZARD DATA Jt,,l'!<n0virrfixation in the form of chloracne, systematic intoxication leads to nausea, vomiting, loss of v;eight, edema and abdominal paii (umClNCt ANU j Remove lifrr.soimi,Ue0xCp1OoUs'.(uS re.. _ Remove , contaminated clothing. Wash | contacted area with large amounts of water and soap. Refer ' I to physician. imccmrry irnn -ygus UNST ABLC SECTION VI REACTIVITY DATA jvr:j^ri.~s;s' v3i^rw3^Mx^c:Tgtfagr,n^,T^ lJiCuiG'o to avu.j nc*' i stabic INCOMPAT AOUttr /Wotffa/i 10 avoid/ CO, CO ,WhaJAHDOuS OlCOWPOSlUON PROOUCIS 2 WA7AAO0U.S PQl TW{ Al J AT ton WAY OCCUR WIU NOT OCCUR smoke, soot, chlorides CONDITIONS TO AVOtO X and chlorine . jg5/^< yirror---xacru'nc-A\caixzczxxxz&zxx-- ils uEarjx'uttxrrzz -.-^r-r -r\yn^ur*TM^riL,rT7C*Ty'\rTXLA3Tr jcr_r i SECTION VII SPILL OR LEAK PROCEDURES . FL ijwUMrTS-irTvO'r*bl'l~stNnIN C~Sl WAtlftiAi ($,wtttAS-DrOR SPtLllOwrir: IIAha nrh nn r1ny_ snwdii--J;--or..ctbim--ahs.orhanf:--mater-lp-dU------PA-TrC-o---------------------- H in drums. Bury in approved c.hemlcal landfill in accordance with local and state regulations J wash DISPOSAL MClHOU Burn in an aooroved incinerator in accordance with `local and state regulations. SECTION VIII SPECIAL PROTECTION I fi FORMAT I OH /y^irrj ^.t7t Mi^LTlrr^ri.7T^` RtscmAioK> pRouctit th'oh ,jf'ureau of Mines approved respirator for )n ViNTlUATlON iocai tiKAust Yes - for vapors . SPtCIAb 1; rwr < H 11 < u n ' < organic Vapord. MECHANICAL (Ctnrrall OTHtR ] PflOUCIIvt ClOVIS rubber tvt fuoucnoN chenueai goggles j OIH( rRO'.tC'IVf COulPMtNI 'iBTO^iw'4..r^flJK*^JiasrranBXEW/C3Kiraw3scraa yr. f-J *tr~w4 v 'itT.TV'1 SECTION IX SPECIAL PRECAUTIONS -.vkwc Trzr.} >.vTTirr:--<i.r7r/r'/r:rn^.t7rri^~'r wj32sre.v=rr:. ^zz^vc^zz&tr--zzrrrr:*^. r^o. ivc: f'^CC AAUTviCo'vb^aJO sUc k iCnK(H aINnmdai.OeUyneG AcNOobn> tact. Avoid inhalation of vapors, jOTHlK PMCC.AUTIC IW.*.-.: -.2 ^sav<:$c While the information and recommendations set forth herein are belie vf'd to be accurate as of the date hereof, MONSANTO COMPANY HAKES NO NAP.P. ANT'' WITH RESPECT THERETO -AND DISCLAIMS ALL LIABILITY FROM RELIANCE THERE OH JAG : IIOH : JTG :V/BP 1/25/72 WATER PCB-SD0000071450 Form Approved 0MB Ho. 4*-R1307 Approval Expires: u.s. ofmhzuui im Form Ho. OSHA-2 Hay, 1S 7 f July 30, 1972 MiM s/m m r7 SECT id:.1 I | I'AII'jF / C 1 U'M'i'.'l K* Ml* 1 ..MONo AN TO. COMPANY : '><''< *<!'>tuCur. Strto. W 11f Cod -/ | COO North Lindbergh Boulevard, St, 'jvi'LU't A IPMC *NC iVKOWVWi - i Mixture |CH|Mlf A'. 1 AWILV Chlorinated Aromatic FV-SRCKNCy TCLCVHywl HC-. , ' . nPt) 6q1i-tooo........... Louib, Missouri 63166 TPAOF. N*.U AND lYNOMYMl FOflMULA Inerteon MI201 KJ mixture f ^............. ^.. T.sjicjicw jl. (i^^'.onusj^r^orirjTS ^ < .rajaKSsu-ar: I'AINTS, PPCJCftYATiv:^ #. SOtVIHT* TLV (UnHr) ALLOYS AH0 METALLIC COATINGS J nOMlNIS ASl UllAl TLV IL'aIii) C A 1 A l V S" I rviHiciE !~SOI Vt NTS I a.oohil es I ________ |~0'H[AS METALLIC COATINGS f IUIA MTAL reus COATING OA COAt ELUX OTHERS --1 HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS, OR CASES TLV (U.lu) ! VH'.r.vr. vrKL'CTWC-aoaEinrnas'SCFJS Xi.LrABBammYT-cL.u SECTION III PHYSICAL DATA I ^r^uaoaaisrr.raascjRX FOILING FOIN1 Cl.I 760 mm " 2dO-35QC S'ECIHC CAAVItT IHjO" 25/15 5C) `'ZZVSASZJZTJr! 1.333 0VA AMSSLI'E invn Mg.) * VAf)fl 0(NSI I IAI ft \ | Nd t Nd t Avail Avail MACINT VOLATILE tr ypyum <X) EVAAOAIION RATE X-RuJUl------ EJX NTA , <1 ll J- SOLLIPIL II r IK WATER 29C.negligible AAftANC l AND OOOft colorless xxrrra oil aromatic odor aceeras jTttosaac ettVA'x SECTION IV FIRE AND EXPLOSION HAZARD l ---r .--j- ;-.trr~rTCC3^,gassRegtaT Mar:xmrj^Trsorsircs s <ZZZT,'_12ZIS:,.TJ\UVJJi-t-STE 1 u/.sn Acini iiuthoo ut^ai . None ELAMMADLE limits ^TTtingl/ismii.-c media DATA SKS NT7TT Utl irnr Y~SUCIAl IIAE 1IGHTIIIU mocLOUSES Respiratory protection whpn fip;ht.ip.g; f.1 pp.r -Ji'ha...r-P--ex pnsnne-----to vapors or p.ases is possible.. . WftlVlty'-'V.hlorldes" and chlorine) can be evolved in : Fires of this product.. : - -"Taia.TiLsa-TiT--.vrj\iji-oimrf.Tr~rmT'.,T' FUR 003309 WATER PCB-SD0000071451 lncrtcen '^I|2CI KJ SECTION V HEALTH HAZARD DATA I imhismolo VAIUL Not available. j'^'l^Vn0' .(rri'E'a'lTion in the form cf chlorachne, systematic intoxication, j TcncT's to nauseF~"vonTTtlng, -a.T.,ci~'a'c-'uTOri:i:rrl"p'a':n 'lylH.INCV /.(J I IRS I AID PROCCOvlUS Remove contaminated clothing. V/ash contacted fj_area_. _ JTemove froM_ exposure Wa.sh with large amounts of water and I, soap. Refer to physician. . : 'j 5t AOIl ll t UNSTABLE SECTION VI REACTIVITY DATA , r..;.vl `'Cb'i'ohToii's t 6" avoid" --------------- ------------------------------------------ ------------------- - SI AblE INCOMPATIBILITY (Hattnult to ovoid/ X CO, CO?,(hazardous DECOMPOSITION PRODUCTS WA2 AACOUS poo m:ri<: at ion MAY OCCUR Wilt NOT OCCUR smoke, soot, chlorides CONDITIONS TO AVOlO and, chlori, ne. LT.V.V-K7^i 2T XTT.TZTJ^ TC-TJT.. TTT7L SECTION VII SPILL OR LEAK PROCEDURES - asr/zigfig.'a ac 11; Lisrxir^ z. ;rnxar.x"*. v A* $T[wW$S TO f`i TAXfN IN CASE MAUfHAl IS RELEASED OR S/PMILILICEO bsorb on clay, sawdust or other absorbant material, PJace in drums. Bury i"n approved chemical 1 andfi 11 in accovdance v;I~t>/ local and state regulations. WAST| niSI'OSAl METHOD Burn in an approved incinerator in accordance with iO:ocal and state regulations T'SKsrascr wo^=iinr.:jwci^4WixuooaiJBas*iii**aK^ SECTION VIII Jracsrcr.TsEsa'S AESRIRAIOR' PROTECTION (Sptct/y Irp'J SPECIAL PROTECTION INFORMATION ventilation YesLOCAL fXHAUST ,, - f-or vapors SPECIAL RROUC-I.E COVES MECHANICAL (Ccnticl) Rubber eve protection OTHER chemical goggles 1 i OTHER PROUCtlvt EQUIPMENT . rXZ-2CTXJ sc i:kimmaaamar-j SECTION IX . . yll'/VctXA iblj, miTA. l- 2s. ,^1^77 SPECIAL PRECAUTIONS 2xmi3cxzfr n-'ec ci M[ C AUTION S^To'e'i 1 ARM?^"^(TnoTrrn2^GW^AJN3p!"^'!T;:O.TRrINsG^^''1'"'* '` ;*il.UCJT . _____________i iAv'oy'dIN.sf<Tn'Nan^) `eye^contact, avoid inhalation of vapors._| j While the information and recommendstions.set forth herein arc believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THERLON. J AG : H0!i: JTG : WBP FUR 003310 1/26/72 WATER PCB-SD0000071452 fcf.'T Approved OHB II o . 4 4 R 1 3 8 7 "oproval Expires: July 30, 1972 U.S. CEPiflUIFilT OF UBOB Form Ho. DSHAHay, 1971 MATERIAL SAFETY DATA SHEET SECTION 1 1 MONSANTO COMPANY ' i *rri U N i If CII r. nd Z// Cod S00 North Lindbergh Boulevard, St. 4 <- c a w C HnON<m| ? Fixture - lMtH5lsCt UUkMOK( WO. . , 1. 3 1_M . .' 6Qh-IOOQ Louie, Missouri 63166 . TKi O C M A W E AWO iTWONTMl .. Pvranol A1753R \ ' " THl orlnated aromatic Mixture .. rjiHTI, * it, i j fl C*tAtrri k v(hicu | SOlv1N t S 1 ADOUiVtS U Ol-1 ns SECTION II HAZ/HOOUS INC"-OI-r-'TS Wivuii % 1 ,,!LV, ; ( UmI 1 ) ALLOYS ANO utTUUC COATIHCS ftASl WTAL ALtOrS MITAUIC COATING! rm(n w(tai Hut COatihC O* CO*f KUI OIH(S |* Hv IUm'.) . NaZaUDOUS mIXTUUCS Or 0 T H [ K LIQUIDS. SOLIDS, 0* GAJM T LV -- tjw >m n ............................ - _ gasmen iodise * O'* y ft SECTION III PHYSICAL DATA 760 mm 2llo-^00C 1 MCI,,C f'**vl,T IH>'11 (15.5/15.5C|) 1.567 t1v* 0 Siu( <"y" w,l No' Avail VA*C* Ci NSi'i IAI = <1 Noti Avail 20CSClUlUin IN NA1I neliibl<F !"C(N1 VOlAlUt ' voujui im f VAP0*AT0* Ipl! Ah r i| N.A Al. P*I AAANCl ANO 00 OA colorless oil aromatic odor '' lari'TmtOLMmucrmnw TmmmLnr!rrL.\xrrTr*2MKXj^-K^ *ri*T*r*n-vTri*r*ur^\-o*^JiXB-Zjr3r*/ SECTION IV FIRE AND EXPLOSION HAZARD DATA iaSh AO'Nl iu.ii\oo ,,>ai UMNCUIShINC W*0'A None I l AUWAIL, lIUlTS . | I.' JLUZ SMCiH Mr *ftOClOU*{S nc-sri ratorv rrotecti on when f1rhtinr flrp^ v.'h^rf nunnr.iirp to vapors or gases is possible. I I n^'?"'-Mv*lT`d?.iJc?lCi'iii&tFATc4hlorides and chlorine) can be p evolved in fires of this product. '.t:/r>iicv>ig3r3ECP8au: FUR 003311 u.' - WATER PCB-SD0000071453 vranol - A1333B SECTION V *yj mt-ga? i ;;ot available. HEALTH HAZARD DATA 1 `: 1 :rynj n v'l r'rT'ba 11 c n in the form of chloracne , systematic intoxication l*eads to nausea^ vomiting, -loss oi weight, Suem.a' iWKior.mai .pain remove from exposure, .remove contaminated clothing. Wash contacted area" with large amounts oi' water and soap. Hel'er to "p'hys'ician. :' USJUBLl SECTION VI i, REACTIVITY DATA. )0 avO'D ST A|l( S C ^aTaIHITt f *< "** *0 awei 4) *.:*DOui oicoMfosmoN rxoouci^Q ^ c62, smoke, soot, chlorides and chlorine * DA.J%Av*t0f0tUij S*1 on UAYOCCU Wtu NOT OCCU" ' CONDITIONS TO AVOID X , SECTION VII .* :: n i**l S . S C A'.l Mi H Hi A, MK *UO l#*t * V> f* p, ^ n n rhnv, sawdust or SPILL OR LEAK PROCEDURES `Ft ,mrfcc<m ctfraan j\ other absorbant -material,a..... Place In ____l | drums. Bury in approved chemical landfill in accordance with l-- local and state regulations. F ___ ( H* * A i W|1hOO ^ Burn in aooroved incinerator in accordance with local and state regulations. i ----- ! PQBgWX^CiMUL3 BIW MB 111 W IH Iff H Hut IP, SECTION VIII SPECIAL PROTECTION INFORMATION \ ( MIUIION ioc*i Yes - for vapors. UfCHANIC (Cttiinli . j 'suc'ivi ciovts rubber tre fRotfcnoH inciAi vapors . OIHM chemical nogr.io.n li f SECTION IX f j.TSgCT'jcam wn wgannva&AiJ 1 . **' lO'*\ *0 H 'fiN.S man:,; n > A NO s: Avoid akin and eye contact, SPECIAL PRECAUTIONS v. avoid inhalation of vanors. __ ______________________________________________ (* PAIC AUtiONS FUR 003312 Wnile the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANT) WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON.' JAC :UOH : JTG :V.'BP ' . 1/26/72 WATER PCB-SD0000071454 form AO'Ov0 Iwd^l So. 44.*138? Apofov^i Co<>i AjtX-fl#XiKX July 30, ,, U.S. DEPARTMENT OF LABOR 1^7(?rkplace standards administration Bureau o< Labor Standards MATERIAL SAFETY DATA SHEET &02: Form No. OSRAMay, .1971 SECTION I UANUTAC TU^M'S NA'nJ MONSANTO COMPANY ApLpt_SS St'ert, City, r*J ZIP Cod*) " " North Lindbergh Boulevard, CHEMICAL NAME ANO SrNONVMS Mixture CHEMICAL fAMILT Chlorinated aromatic e^erge^y rjufHONE nc. " " 1000 St. Louis, Missouri 63166 TflAOt NAME ANO SYNONvMS Pyranol A13BTB-2 FORMULA Mixture . SECTION II PAINTS, PRESERVATIVES, 4 SOLVENTS % ' PIGMENTS HAZARDOUS INGREDIENTS TLV (Unit,) ALLOTS ANO METALLIC CQATINCS ase metal * CATALYST ALLOTS vtMtcte SOLVENTS ADDITIVES METALLIC COATINGS FILLER METAL PLUS COATING OR CORE FLUX others OTHERS HAZARDOUS MIXTURES OP OTHER UOUIDS, SOLIDS, OR GASES % TLV (Unit.) - TLV % (Ut.lt.) ' - ?: \ SECTION Jit PHYSICAL DATA .. OILING POINT (*P.) 7g0 ^ 21, D - 400 3,Ptc,r,cc4AvlTv,Haog,^/l5 c VAPOR PRESSURE |mm H9.| ; Avail PYERVCOELNUTMVEOLINAaTl ILE VAPOR OENSITY IAIR= 1) EVAPORATION RATE No : Avail 1 =n SOLUS.UTY IN WATERS neKllKlble ' . .. 1>(.3 S-1.529 N. A. Cl APPEARANCE ANO OOOA nolorle5S pH aromatic.odor SECTION IV FIRE AND EXPLOSION HAZARD DATA f LBASuH rPnOINT iM._lh_o_d_u__d_l _ None to _Bo. l,li.ng EXTINGUISHING MEOIA Self FLAMMABLE LIMITS Lf Ui ...n:a . ~TTTSZ SPECIAL EIRE FIGHTING PROCEDURES Rpymlratorv protection when fighting fires where exposure to vapors or p;ases is possible. UNUSUAL f IRE ANO EXPLOSION HAZARDS can be evolved. Highly toxlo gases (hydrogen chloride) :h:**:r -- FUR 003313 \ WATER PCB-SD0000071455 FI SECTION V HEALTH HAZARD DATA NotTHRESHOLD LIMIT VALUE aval labJL.fi. ITPECTS Of OVEREXPOSURE -Skin--Irritation--In_fcilfi--form nr r.h1nrapnpt qyqt-.pmat-^ p _ Intoxication leads to nausea, vomiting;, loss of weight, edema and ah. EMERGENCY ANO HAST AIO PROCEDURES Remove from exposure -Remove enntaml na terl clothing domlnal pain. Wash contacted area with large amounts of water and soap. Refer to physician.----------- ----------------- --------------------------------------------- i: SECTION VI REACTIVITY DATA STAB (LIT Y UNSTABLE CONDITIONS TO AVOIO STABLE X INCOMP AT ABILITY (Materials to avoid) ' HAZARDOUS DECOMPOSITION PROOUCTS : co,____coo,___ smoke, soot. i HAZARDOUS POLYMERIZATION MAY OCCUR WILL NOT OCCUR i; hydro,pen chloride CONDITIONS TO AVOID X . * SECTION VII SPILL OR LEAK PROCEDURES STEM TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Abaorb on clay, sawdust or other absorbant material. Place In drums. Bury In approved chemical landfill In accordance with local and state regulations.-. BurnWASTE DISPOSAL METHOO In approved Incinerator in accordance with local and state regulations, ----------- ------------------' - .............. .... ............... - SECTION VIII SPECIAL PROTECTION INFORMATION RESPIRATORT PROTECTION (Sptcify lypW Bureau of_ .M..ines approvi;d respirator for organic VENTILATION LOCAL E*^USsT - fOr vapors. SPtClAL vapors. MECHANICAL (C4n<rmt} PROTECTIVE CLOVES rubber . OTHER PROTECTIVE EQUIPMENT EYE PROTECTION chemical goggles ;' I . SECTION IX SPECIAL PRECAUTIONS ' ' _______ ) PRECAUTIONS TO 8E TAKEN IN HANDLING AND STORING h ;____________:---------------------------------------------------------------------------------------------------------------------------------i--------------- |; Avoid skin and eye contact, avoid inhalation of vapors. f OTHER PRECAUTIONS ~ While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES MO WARRANT* WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE thERP'^' . FUR 003314 WATER PCB-SD0000071456 Form Approved 0MB No. 4<i-P13?7 Approve:! Expires.: July 30, 1972 Mv | ' ' v [ I--' r, U \j . . I l l 4 i I I I J L 1 U - *J Sj \ ] !' 0 li'.i i v o . O' May. 197) r fXr\ r n r r\ r ,p.; (*-, fi A Anfif.j':' | n\i: r. i : :l!i v I: j, w ; /. V?:--*, ;j Lure I; v'!j L li li J u ?J J O SECTlui'J i I M.'uyi *CU;r.tH'* m. Ml' '___MQh\r.AN2:O^OMl^NY_ I CBO/l'iO'i. | Nl (oftwrtrihjf'if JSjtiinff-a/,b(*ctcr>g, T3{ia/ff,cAondmZIct- vCaoer/*a) r St, | 0<1 W'C K SAM( ANC ( YNOs ' WJ * I ti.*nn o f.Tr.v "t ?. i_ 7- mVon* ^ `no' ** |J Lou.is, Mi. srour-_.jJ_6.U3^ 1H6. 6,i). ............ ...j! in*Dt NAUC AMO OYf.OKYMO jl `LTiiorinated aromatic j^'0,'"ULA Mixture !l i! j P/.l/.ti, r R E S ft V A M V S, A SOLVENTS j r icui i, i s j CAT Al^St '' % TlV (UaiI ) ALLOTS AND /.(ET/.LLIC COATINGS IASI UCTAL AU.OVS % TL V j VlKtCl E j SOIVIN1S j AODIlls'tS J O'MtflS METAlUC COATINGS riUEHUETAt PLUS COATING GA COnc flUX OTHEftS -- ` " 1 HAZARDOUS HIXTURCS 0T OTHER LIQUIDS, SOLIDS, OR GASES . S', VIA- On;) i' i . ................................................... . .................. ............ i ::d :rr.:rTv. rrrz.: lttn.^c-. _-ir--.c/ato--------------: i-rcaras'cas rrsKx^/aaazacivr.; '.xzixzi.xxizr.^ a.IT. | SECTI on m PHYSICAL DATA -r^v\T.'7.L-v;>j.LLv'jA-^s-.nMW:;ev;^iKzTi?'^iHTTir --zn~-zzi :a 'L :iz-3isxz&"*cr3-iac. . v. j sou.nc ro.M r-., 760 mm 2 -0-360C s-tcnc caaviit 1.1,0=11 (2S/15.5C) i1 JlNO j va'Ok riussuiie im ho.i ] VATOA DCNSIU IA1A- II i . >t N 5t Avail Avail ^(flCENT VOtAHU 1 f VOLUME (SI i VACATION ATC iiiuA-C-------- ='i A v" 1 ( 1 tOlW5U.IT,NWATE20oC neRllp.jble <o.oi acanA^c^j>w oooa __co 1or1ess^ 1 iqu.1 d SECTION IV '7:Iih To'iki' `j).;Tho<i'un<:T None j" m' INCUISmllG 'wTmVriT ."XT FIRE AND EXPLOSION HAZARD `"3'*.............................'iriAVLJAjicLuiirs' DATA Ll ZEE Uol iX._ I sr(rtAL inu riCHin.'G rnodouM 5 on..iibr-a-f-Lght. 1 r p... f'i-re.a-vxlinrx-------------------------------- j__ exposure to vapors or Eases- is possible.________________ _ _ I, Yl'-S: r-hVv** (Fc& '0Ea s oAJAI're~h I or Id e s and chlorine) can be evolved in _ | fires of tills product. FUR 003315 WATER PCB-SD0000071457 FH - Low'f ei.ip. SECTION V HEALTH HAZARD DATA .'ni'tsAoioViMif'vXiui Not' Avail ^'hle'; .......................... ............ Jim cis Of ovir:xposure i .Skip -1 uvVtrition In the form of chloracr.e, systematic intox i cat Ion___ | j Toads to nausea, vomiting, loss of weight, edema, and nbdomminai~pain . jif.;|-^;lTrcV7V7E7TTst aid r,-jocf"olmi$ Remov.cf.i:oif>-_o./vno.':jiwi_. Remove conLaminated cJLothing_. V/ash I contacted area with large amounts of water and'soap. 'Here f to physician. UUST ADIC SECTION VI REACTIVITY DATA Cotio I \ ibivV t oTvoicT S7APU t(ii.'COMBAl AI1IUIV (Kalrnel Ie> ax'Oid) ; ; * ouha ak ous otcouposmo.w products , IwArABOOuS jl'Ol VMlftl? MlCHV MAY OCCUR WILL K'OT OCCUR i\ooj | ........................... _ 1 smoke, soot, chlorides and chlorine COUDUIOIIS TO AVOID X' : S.2X77C. r SECTION VII SPILL OR LEAK PROCEDURES TVi'i's'Td'rfHxnTVtTclsi'uiil hialTs huASEo"bR's>ilud" Absorb on cTav. sawdust or other absorbant material. Place In drums. Bury in approved chemical landfill in accordance v/ith '"local~~and state regulations i wxsn oii'-xosAi Kiiiioo ,. , ., ,, . I Burn in an approved incinerator in accordance with local and state regulations. | | 1 j SECTION VIII SPECIAL PROTECTION INFORMATION j msfidAioM fnoHcuoNAVffi7> i)'/'^uroau of. Mines approved respirator for organic j Vf NTH AT 1 ON local exhaust Yes _ for vapor5 1spec al vapors . MECHANICAL (Ctntttl) .(rnoifciivt oiovis rubber j~OUUB rBOTtCtlVE COLIIRMENT rr.'zxrjTzr.r. ccmrsa. jssaixj^v^.'ei'i'i u',j.wBamgmgy OTHER eve fnoiccnoN chemical goggles rj.TTxnxa7T.r.rr.`- SECTION IX SPECIAL PRECAUTIONS jztjxIfBECAuilOfis i'o fjf iTxEfTiN HANOLING'/Nt> SrOKifflj TT'*"*' , . '""S" ..b.e^s: :.trsrocr:n Avoid skin and eve contact. Avoid inhalation of vapors. [oTAeii I'Ve cautions" While the information and recommondations.set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAG : BOH : J'J'G :WBF FUR 003316 1/26/72 WATER PCB-SD0000071458 Perm Approved OMC lio. 4 4 - R1 3 0 7 Approve 1 Expires: July 30, 1972 U.S. bii'T:!.'L..d.:r 17 %Vm S/MV DATA SBSI Form Ho. OSh'AHay, 1971' I SECTION I , W A Nyf l C T un Llt'S wA.Mr L __M QNSANTO _C O.MPA NY...... ao:mj;u (iVi-nEif, '****'(*<:/). r.ntf i.ir CoL'pl " ' " L l^ndbcrh 13oi'.lc^ard# St. Loui e, jc * L C * L NlMf, AMU lrhOSMl !_____ Mixture__________ C * C mi < * L * fcu V Chlorinated Ar omatic I EWCNGINC Y mCF'HO^: HO. , ImiNi) 6qU-ioooI Missouri 63166 VHAOC MAUt; AMO IVWONVMI Therminol FR-0 Mixture T.T.l I cjiqelji .j^^ous. ir!Pr so.nri.ts ...... v | PAINTS, P SC SE R Va tiVE S, A SOLVENTS TLV (Uxlul ALLOTS AND METALLIC COATINGS ^ IC.uf MS l___________ ) C AT Al YS1 IASC MfTAL AUOYS V( HlCU 7StVINIS J AOOtUvfJ OThips UUALUC COATINGS IIIUR WtTAL HUS COATING O* C0:>F FLUX OTKftS L._ HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS, OR CASES TLV (L'sliij TLV (U rvll I) x27ruurzLza2ia'u=DErL`aa3a.jz^^;xEi^^a:rc=oicxuTzrxc^jaiLso,-a3aaE^Airasac3vsrTiarsxEr:aa i SECTION III PHYSICAL DATA .oiungpoin, Cf.i 760 mm 5 70-615 vapoa rnsssuRt i"> up.) 200P 1.35 SPECIFIC GRAVITY IHj0r., (?^/x^ MACCNT VOIATIU r VOU.'M I%l VAPO* OtNSlTr IAIA- U Not Avail . - (Y/^QnATlON RATI i [JU.AC. =11 KHumiumwAT^ so^CneRliciblE AAPfANANci and ooor colorless oil aromatic ~ ; 'X -~x&rzi^nmmx*Lnj3oar:liltnrriatz-n-nrT'Tnvyi--r n-ray- tt/tj .-r.-ym-T.T pt.-t-tvi! r>0 r) odor r-np N.A. <1 SECTION IV FIRE ANO EXPLOSION HAZARD DATA i.r-U-rr.LLT."--rr. r=rrrirTr.rsrrrirmiTaRs:3=cr HASH POINT lUiihod v.odl None *5crci .--orj;~r.72 r?-tlatjrsazyggr-zero~ivec,;d.",'rr~ FiAU.MASLE LIMITS | Lot Lit I_____ I I__________________________________ EXTINGUISHING MEDIA N. A. SPECIAL flP-E FIGII1ING PAOCLOUII5S Respiratory prot.cr.tinn wher- _fji.hiiin.g--fhL us__Dhexne- exposure to vapors or cases .is possible. (chlorides l chlorine) can bo evolved In ~ fires" of this "product^ FUR 003317 WATER PCB-SD0000071459 heri;'inol':,'n-0 SECTION V HEALTH HAZARD DATA t" avaXifig! 'iincis oi ovmufosuRt -. L.S_ki n..-Irritation In the form of. chloracne, systematic j leads to nausea, vomiting, loss of neight, edema and >TiAT:F.rt<CT aToTTTuTAmo fr.octc-Cir.Ti ~ r~ ! Hernovc from exposure. Bemove contaminated clothing. i contacted area "with-large amounts o f~w aCcr-ahcTTTdapl intoxication abdominal pain1 A Wash ReTcr i to_ phy rl cl an . _ ____^ UNST ADU SECTION VI REACTIVITY DATA ir:X"c'i*D`mo;>is to'Avoro' ........ iNCOWRA.tAtm.lTr (Uairnali In oiniJl ,kamrdous orc.ov.PosniON product: CO?, smoke, soot, chlorides and chlorine HAZARDOUS MAY OCCt/fl CONDITIONS TO AVOID '01VMRIZ AllON c X4 WILL NOT OCCUR ^^isa^.^,T;.'Kx~l.,iXu.'mc^.itffs.:.u^-aiJw,:vAii/rrg'r;rry-aTcrgiity.7ss-r:aTi!g.i.-a3r=t?=3r ` , SECTION VII SPILL OR LEAK PROCEDURES !- .ic -?e7Z^. z.\.~ rl.1.jzztc: -tn-gjzx^tiTxnc .-.r-Tjrr^J. I'Titl'STO H 1AN IN C.ASl MAURIAL IS REU ASEO OR SPILLED I Absorb on clay , sawdust or othei ~ v-s'tim.'CEra uexcr^rvrxm_______________ ________ ______ . . ,,,, 4. - rl,.,, 4n absorbent material# Place In|j ft~ drums. Bury in approved chemical landfill in accordance with local-and state regulations. _. .U WA?lurn't^n"an0approved incinerator in accordance with local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION ^yjv^zzxrLzzzjLuyj^, zrrsocTT^rrj; zrzrcc: zlwz *lil'thWa{?B?uW'i!ife'&h H'^roved respirator for organic vapors. VCNTIlAllON local ixhaust yes _ for vapors SPECIAL . MECHANICAL fGtntral} , OTHEH PAOHClIVE-GlOVlS OTHCft PROTECTIVE fOUl^MENT r.vnAn-P rubber ,cye fRottctiON chemical goggles SECTION IX |l`R(C AUT IONS 10 DC TAKEN IN KANOUNG ANO STOKING --Ayqld-S-kln. and-.y.e contact,- Avoid inhalation of vapors ofmr fmeauhons SPECIAL PRECAUTIONS While the information and recommendations set forth herein are believed to be accurate as of the date hereof, MONSANTO COMPANY MAKES NO WARRANTY WITH RESPFCT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON- J AG : IIOII: JTG : Wli P FUR003318 l/P.H/12 WATER PCB-SD0000071460 PAGE 1 OF 4 Monsanto material safety data NOTE: NO REPRESENTATION IS MADE AS TO THE ACCURACY OF THE INFORMATION AND RECOMMENDATIONS HEREIN. SEE PAGE 4 FOR CONDITIONS UNDER WHICH DATA ARE FURNISHED. MONSANTO PRODUCT NAME POLYCHLORINATED BIPHENYLS--PCB's* Sea page 4 for definition and notes MONSANTO COMPANY 800 N. LINDBERGH BLVD. ST. LOUIS, MO. 63166 EMERGENCY PHONE NO. (CALL COLLECT) (314)634-1000 9 PRODUCT IDENTIFICATION Synonyms Trade Names (Commonly used Monsanto products) PCB's Chlorodiphenyl (_% Cl) Chlorinated biphenyl Polychlorinated biphenyl Chlorinated biphenyl* (approx. _% Cl) Askarel** Aroclor*' Series 1016, 1221, 1232,1242,1248, 1254, 1260 Pyranot** Series Inerteen*1 Series Therminol*'' FR Series See page 4 for notes CAS No. 001336363, 053469219, 021672296, 01109769, 011096825 and others WARNING STATEMENTS Federal regulations under the Toxic Substances Control Act require PCB's and PCB items to be marked. (Check regulations for details.*) CACUOKTTWIWON PCBs Hi 1 II J -.-i -! - - 1-1 tFfPWWwi UpWeT"* A lM< ^>VArVTX<MO< (mefTWXX'! of *100*0* * oaoxXKxr wHt* ul *Otf<(OA At***** PfW-^wOtorx* <OCnu*t to> Oteotof Wew-e' (OMOO lh* U l C A O<f N\ (Ol* ** Ul Cmu (* *0> tfvf Vipor* C 00-474 4*07 A>WO Co^AXI .... _ _ _ *0____________ ._ s* .. THIS EQUIPMENT CONTAINS PCB (Po*ycModrj<*d 0Mwry*l CAPACITORCS) | CAUTION - COHlAWS PCB* fOA r*0A OBWMt IHfOAMATION CMTiCT US [KYKOMttXUi hwtkjkh Astxcr J EMERGENCY AND FIRST AID PROCEDURES Ingestion--Consult a physician. Do not induce vomiting or give any oily laxatives. NOTE TO PHYSICIAN--If large amounts ingested, gastric lavage is suggested. Skin--If liquid or solid PCB's are splashed or spilled on skin, contaminated clothing should be removed and the skin washed thoroughly with soap 8nd water. NOTE TO PHYSICIAN--Hot PCB's may cause thermal burns. Eyes--Eyes should be irrigated immediately with copious quantities of running water forat least 15 minutes if liquid or solid PCB's get into them. A petrolatum-based ophthalmic ointment may be applied to the eye to relieve the irritating effects of PCB's. Inhalation--Remove to fresh air. If skin rash or respiratory irritation persists, consult a physician. NOTE TO PHYSICIAN--If electrical equipment arcs over, PCB's or other chlorinated hydrocarbon dielectric fluids my decompose to produce HCI, hydrochloric acid, a respiratory irritant. , FUR 003319 G 4048 Monsanto material safety data WATER PCB-SD0000071461 @ Monsanto material safety data PAGE 2 OF 4 OCCUPATIONAL CONTROL PROCEDURES Inhalation--Workplace exposure should be maintainted below the OSHA eight-hour, time-weighted aver age Threshold Limit Value (TLV). At room temperatures, the hazard of inhalation is considered slight or absent. Chemical cartridge respirators or gas masks approved for protection against organic vapors are recommended in the event of spills or leaks of hot fluids. These will provide good protection up to the concentrations shown on the approval labels and the odor will give ample warning if it comes through the de\[ice. Self-contained breathing apparatus should be worn when PCB's are encountered in an enclosed space. Threshold Limit Value (TLV)--Chlorodiphenyl (42% chlorine) 1.0 mg/cu.m. Chlorodiphenyl (54% chlorine) 0.5 mg/cu.m. Skin Contact--Avoid prolonged or repeated skin contact. Where employees may come into direct contact with PCB's, protective clothing impervious to PCB's should be worn. Gloves, boots, overshoes and bib-type aprons that cover the boot tops should be used when necessary. This protective equipment should be regularly inspected for defects and to ensure that it is in clean and satisfactory working condition. Contami nated clothing, gloves, etc., should be disposed of as prescribed by regulations. . Eye Contact--Eye protection should ba used where there is a possibility of liquid splashes. Ingestion--Ingestion of these materials is generally not a problem in industry. PHYSIOLOGICAL EFFECTS SUMMARY: Skin Contact--Can be absorbed through intact skin. Local action on skin is similar to that of common organic solvents where contact leads to removal of natural fats and oils with subsequent drying and cracking of the skin. A potential exists for the contracting of chloracne. Eye Contact--The liquid products and their vapors are moderately irritating to eye tissues. Ingestion--The acute oral toxicities of the undiluted compounds are: LDM rats--8.65 gm/kg for 42% chlori nated, and 11,9 gm/kg for 54% chlorinated--"slightly toxic." Inhalation--Animal experiments of varying duration and at different air concentrations show that for similar exposure conditions, the 54% chlorinated material produces more liver injury than the 42% chlorinated material. Other--There are literature reports that PCB's can impair reproduction function in monkeys. A study reported in the literature with female rats using Aroclor* 1260 stated that Aroclor 1260 caused liver cancers. Monsanto sponsored animal feeding studies of Aroclor 1242,1254 and 1260. These compounds, fed to both sexes of rats, did not produce cancers.The National Cancer Institute performed a study in 1977 using Aroclor 1254 with both sexes of rats. NCI stated that the PCB, Aroclor 1254 was not carcinogenic under the conditions of their bioassay. The consistent finding In animal studies with PC8's is that they produce liver injury following prolonged and repeated exposure by any route, if the exposure is of sufficient degree and duration. Liver injury is produced first, and by exposures that are less than that alleged to cause cancer in rodents. Therefore, exposure by all routes should be kept sufficiently low to prevent liver injury. FIRE PROTECTION INFORMATION Fire and Explosion--Chlorodiphenyl# are essentially non-combustible compounds. They may decompose to form CO, C02, HCI, phenolic6 and aldehydes under severe conditions such as exposure to flame or hot surfaces. No phosgene is formed. puR Q0332Q MATERIAL SAFETY DATA Monsanto WATER PCB-SD0000071462 PAGE 3 OF 4 Monsanto material safety data _ @ Standard fire fighting wearing apparel and self-contained breathing apparatus should be worn when fighting fires that involve possible exposure to chlorodiphenyls. Fire fighting equipment must be thoroughly cleaned and decontaminated after use. . m PHYSICAL DATA TABLE I--Properties of Selected Aroclors Property Colir (APHA) Physical state 1016 -- mobile oil Stability inert Density , (Ib/gal 25C) Specific gravity x/15.5'C 11.40 1.36-1.37 x-25 Distillation range PC) 323-356 Acidity mg KOH/g, maximum Fire point CC) none to boiling point Viscosity (100F) 71-81 .... I........... I........ ............. REACTIVITY DATA 1221 100 mobile oil inert 9.85 1.18-1.19 x-25 275-320 .014 176 38-41 1232 100 mobile oil inert 10.55 1.27-1.28 x-25 290-325 .014 238 44-51 1242 100 mobile oil inert 11.50 1.30-1.39 x-25 325-366 .015 none to boiling point 82-92 1248 100 mobile oil inert 12.04 1.40-1.41 x-65 340-375 .010 none to boiling point 185-240 1254 100 viscous liquid inert 12.82 1.49-1.50 x-65 365-390 .010 none to boiling point 1400-2500 1260 150 sticky resin inert 13.50 1.55-1.56 x-90 385-420 .014 none to boiling* point -- PCB's are very stable, fire-resistant compounds. Monsanto m a t e r i a l s a f e t y d a t a SPILL, LEAK & DISPOSAL INFORMATION If PCB's leak or are spilled, the following steps should be taken immediately: All non-essential.personnel should leave the leak or spill area. . The area should be adequately ventilated to prevent the accumulation of vapors. The spill/leak should be contained. Loss to sewer systems, navigable waterways and streams should be prevented. Spllls/leaks should be removed promptly by means of absorptive material, such as sawdust, vermiculite, dry sand, clay, dirt or other similar materials, or trapped and removed by pumping or other suitable means (traps, drip-pans, trays, etc.). Personnel entering the spill or leak area should be furnished with appropriate personal protective equip ment and clothing as needed. Personnel trained in the emergency procedures and protected against the attendant hazards should shut off sources of PCB's, clean up spills, control and repair leaks and fight fires in PCB areas. All wastes and residues containing PCB's (e.g., wiping cloths, absorbent material, used disposable pro tective gloves, clothing, etc.) should be collected, placed in proper containters, marked and disposed of in the manner prescribed by EPA regulations (40 CFR 761). Various federal and state regulations may require reporting of PCB spills. Consult your attorney or appropriate regulatory officials for information relating to spill reporting. FUR 003321 WATER PCB-SD0000071463  Monsanto material safety data PAGE 4 OF 4 ^ NOTE: ALTHOUGH THE INFORMATION AND RECOMMENDATIONS SET FORTH IN THIS SHEET ARE BELIEVED TO A BE CORRECT AS OF THE DATE HEREOF, MONSANTO COMPANY MAKES NO REPRESENTATION AS TO THE " COMPLETENESS OR ACCURACY OF SUCH INFORMATION AND RECOMMENDATIONS. MONSANTO COM A PANY SHALL IN NO EVENT BE RESPONSIBLE FOR ANY DAMAGES OF WHATSOVER NATURE DIRECTLY OR INDIRECTLY RESULTING FROM THE PUBLICATION OR USE OF OR RELIANCE UPON SUCH INFORMATION AND RECOMMENDATIONS. ^ ... NO WARRANTY, EITHER EXPRESS OR IMPLIED, OR MERCHANTABILITY OR FITNESS OR OF ANY OTHER NAtURE WITH RESPECT TO THE PRODUCT OR TO THE INFORMATION AND RECOMMENDATIONS HEREIN # IS MADE HEREUNDER. This form has been approved by the Occupational Safety and Health Administration as "equivalent to" OSHA Form 20. MATERIAL SAFETY DATA Monsanto * POLYCHLORINATED BIPHENYLS . For regulatory purposes, under the Toxic Substances Control Act the term "PCB's" refers to a chemical substance limited to the biphenyl molecule that has bean chlorinated to varying degrees or any combination of substances which contain 50 ppm (on a dry weight basis) or greater of such substance (40 CFR 761). Chemically, however, PCB's are defined as a series of technical mixtures, consisting of many isomers and compounds that vary from mobile oily liquids to white crystalline solids and hard non-crystalline resins. Technical products vary in composition, in the degree of chlorination and possibly according to batch. The mixture generally used contains an average of 3 atoms chlorine per molecule (42% chlorine) to 5 atoms of chlorine per molecule (54% chlorine). They are used as dielectric fluids in transformers and capacitors. Prior to 1972, PCS applications included heat transfer media, hydraulic and other industrial fluids, plasticizers, carbon less paper, paints, inks and adhesives. "Federal regulations now specify that non-totally enclosed PCB ac tivities are permitted only if specifically exempted or authorized." (40 CFR 761 see FEDERAL REGISTER, Vol. 44, P.31514, May, 31, 1979) CAS No. 001336363: For general class of compounds TRADE NAMES 'ASKAREL--Generic name for a broad class of fire-resistant synthetic chlorinated hydrocarbons used as dielectric fluids. ' Registered trademark of Monsanto Company > Registered trademark of General Electric Company 5 Registered trademark of Westinghouse Electric Corporation This list of trade names is representative of several commonly used Monsanto products (or formulated with Monsanto products). Many other trademarked products were marketed by Monsanto and other chemical manufacturers. PCB's were also manufactured and sold by several European and Japanese producers. Con tact the manufacturer of the trademarked product directly, if not in this listing, to determine if the formulation contained PCB's. DATE September 15, I960 REVISED X SUPERCEDES All prior to 9/15/80 FOR ADDITIONAL NON-EMERGENCY INFORMATION, CONTACT: 80-010 John H. Craddock, Manager, Product & Environmental Safety Monsanto Industrial Chem. Co. 800 North Lindbergh Boulevard St. Louis, Missouri 63166 (314) 694-4764 FUR 003322 WATER PCB-SD0000071464 MONSANTO'S PCB PROGRAM W. B. PAPAGEORGE Presented at ANSI Committee C-107 Meeting - September 1^, 1971 I appreciate the opportunity to share Monsanto's PCB experience with you and I hope the information I have can help'this committee plan and achieve Its objectives. We at Monsanto first heard of PCB's as potential environmental contaminants.In early- 19^7 when we received copies of a talk given `in Sweden by Professors Widmark and Jensen of the University oB Stockholm. In their paper they described how they were able to identify a material which had been interfering with pesticide .analyses as being polychlorinated biphenyls. Our laboratories began work on the development of analytical "methodology- to confirm that PCB's indeed were being found in the environment. During 1968'and 19^9 as methodology improved the evidence continued to indicate that the higher chlorinated biphenyls were being identified in the tissues of fish and birds. During this period Monsanto mounted an extensive program aimed at'acquiring more knowledge about PCB's and their effect.on the environment. We perfected our analytical methods, we Btarted' animal toxicity studies, began biodegradation work 8nd evaluated alternative materials for those applications we felt were con tributing substantially to contamination. 2 PLAINTIFF'S DEPOSITION EXHIBIT I i/JJ ... FUR 004045 WATER PCB-SD0000071465 2 Our animal toxicity work was similar to the type we would have undertaken if we had wished to have FDA approval for food use. . Chronic toxicity and reproduction studies were made on leghorn _ chickens. Two year chronic feeding studies were started on rats and dogs. Three generation reproduction studies were made on rats. - The PCB1 s used in the tests were Monsanto's Aroclor 12*12, Aroclor 1254,and Aroclor 1260. These were selected since they represented the more, commonly used PCB mixtures. The animals were fed con centrations of 1 ppm, 10 ppm and 100 ppm in.their normal diets, The,results to date indicate that at the levels used the rats and dogs showed no effects with Aroclor 12*12. At 100 ppm both i the'rats, and dogs exhibited decreased weight gains and enlarged ' livers. The chickens were affected by Aroclor 1242 at the 10 ppm level. The hatchability of the eggs was significantly reduced. ` To,summarize what I've said about Monsanto's sponsored animal toxicity work the-highly chlorinated polychlorinated biphenyls at 100 ppm in the animal diet does have some effect on mammals. The lower chlorinated polychlorinated biphenyls at 10 ppm in the ,-e. diet ha^- some effect on leghorn chickens, and I say specifically ie'ghorn chickens because there is mounting evidence that there X are definite species variations as determined by the Pautuxet Laboratories here In Maryland with four types of wild birds. There is a species variation noted which frustrates many scientists FUR 004046 WATER PCB-SD0000071466 -3- I was asked what we know about the effect on marine life. Monsanto did sponsor Btatic fish toxicity work and we were completely frustrated because these PCB's have the tendency to plate out ,on surfaces. Our information was garbled because in the static testing we were really exposing the fish to PCB environments a ' lot less than we thought we were. The data was so distorted it was meaningless. In the meantime, we found that there are .. . .. many competent laboratories looking at fish and the effects on fish that we decided that maybe this is an area that is best left to the experts, . - ; We have been in touch with laboratories such as the. Water Quality Laboratory of Duluth, Minnesota. They have conducted studies which Indicate there is some effect on some species. There haB been some work done in the Columbia, Missouri Bureau of Interior Fish-Pesticide Laboratory which indicates, for example, magnifi cation about 50<000 times. By that I mean that the amount of PCB detected in the fish tissues was 50,000 times that present in the water environment in which this fish was exposed. There have been reports of fish kills and some very drastic effects attributed to PCB's. I've tried to get evidence that these .things have occurred. I have not been able to confirm any reported Incident. ' *' We have talked with scientists at the Gulf-Breeze, Florida Commercial Fisheries Laboratory. They have conducted studies FUR 004047 WATER PCB-SD0000071467 . -4 - with crab and shrimp. ThiB 1b the laboratory that did detect a build-up in crab and also the lethal effect on juvenile shrimp. Very, very low concentrations - 5 ppb in the water - do destroy - . Juvenile shrimp. - There is a growing thought among many of the.responsible scientists -that,-this environmental problem is most complex and`it is not , really'any one insult that is the demise of any particular Bpecles, 'but it could be the cumulative effect of all insults a creature is exposed to and usually the last .insult is the one that gets blamed.. Dr. Tom Duke of Gulf-Breeze is a proponent- of this the.ory. and he is conducting studies to substantiate, this. It could ibe the lack .or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a cadmium or a mercury or an arsenic, and along comes a PCB and the fish dies. PCB might get blamed. This is the kind of thing-that does happen in the environment. .There is a growing concern that we should be considering to a greater degree chronic effects of all these materials rather than relying on the old acute studies that used to serve as a screening'' for many, many chemicals. I have sketchy data on marine life. . We know that it does build up in the marine environment and ' there 1s, of course, the published evidence that It does affect the fish eating birds. FUR 004048 WATER PCB-SD0000071468 _5- There 1b some indication in the Duluth studies that reproduction and survival of the frye is affected. There seems to be minimal affect on adult fish. . ' It was suggested earlier that I might want to review .the-.manufacture -of PCB's, the many applications in which it was used and what our" present program Is. To the best of my information, it ...was 1929 that these materials were Introduced as very attractive fluidB for use in transformers, and there are many in this audience that are more familiar with this development that I am. PCB's were pBed in transformers as an insulating cooling ..fluid because they are more resistant to breakdown, less apt to explode and burst'.into flames and cause property damage and human injury. Through the years, additional uses were found for these materials because of these properties that I mentioned earlier. They .gradually at first, and of course with increasing amounts, ended'up In applications that Monsanto through its in-house usage referred to.as plasticizer usages. That Is not a very good description, but -it fit our needs for many years, and you'll find us .using.that expression. These are uses such as in paint formu lations, the specialty ink uses, the plasticizer In sealants, adhesives, and paper coatings of all sorts. There was a use that was a real thorn in our side and you'll see at least some of the earlier articles on PCB.'s referring to pesticide use. There were some studies conducted by the Department of Agriculture in which PCB's were used to extend the effect of - fur 004049 WATER PCB-SD0000071469 6- - life of pesticides such as lindane. It wses never Intended for broadcasting as we. visualize DDT was on food crops, cotton crop3, or orchards. The only widespread use that I could find was a limited trial to help prevent or curtail the dutch elm'disease, ' and that proved to be a failure. The other uses were extremely Bmall in private formulations that were used to spray or coat . hard surfaces - shelving, corners of floors and all for the typicalcrawling type insects such as the roach and silverfish. In fact-it was so small that.Monsanto did not market directly to pesticide formulators; we gave this business to Our distri butors. On the other hand, this use did cause considerable emotion and was used by some to explain thepresence of PCB's In remote areas. We wrote to the Department of Agriculture suggesting that during 197 when pesticides were being re registered that PCB's not be approved. .Finally in October they .did put out a notice to that effect. We have had questions raised, "is It in my shower curtains at home?' Is it in the draperies? In the Carpeting?" The answers to those is "not very likely". And I use those words because we really don't know. If it was put into these applications, It was so small we, Monsanto, were not aware of It. It was not 'Used in automobile tires; it was not used in brake linings. Other major uses include the use in hydraulic fluids which are fire resistant. Monsanto marketed these fluids under its trademark Pydraul. I am sure some of you remember the Llvonie, FUR 004050 WATER PCB-SD0000071470 7 Michigan fire? This was a disastrous fire in terms of property damage 'and was really a. high mark in terms of convincing Industry that there was a need for fire resistant hydraulic fluids. But the application is not the type that is maintained to-a-degree where everything is leakproof. Many of, these connections leak, hoses burst, and the tendency is to keep producing by adding more fluid. So it is conceivable that many, of these hydraulic fluids ended up in the sewer. X do not intend to criticize the-customers of our products. From the knowledge that we had at. that time of the material the practice was considered acceptable. 'Another fairly widespread application of PCB's is the use of 'these .fluids as a heat transfer media to achieve high temperatures, have a fire resistant transfer fluid, and avoid the installation of high pressure equipment. These materials were Ideally suited Tor this application. We thought at one time that these were adaptable to close control and proper maintenance where we could -logically call them closed systems. Some recent evidence indi cated `that we were wrong and I'll get into that when I discuss our present applications. One. application that was a fairly significant one and one that in our thinking is associated with coatings is the use in car bonless reproduction paper,'with the emphasis on recycling paper X wastes and with the persistance of PCB's there is a problem developing in that PCB's are being found in many paper products and many of these paper products end up in food packaging. FUR 004051 WATER PCB-SD0000071471 8 Initially the evidence we were getting seemed to point to the higher chlorinated materials as environmental pollutantB. As soon as we were aware of this, we sent a letter to all of our customers telling them that what little we knew indicates?., that . these materials could be an environmental problem, and care should be exercised in handling. When the results came in on our chicken toxicity studies they indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that we better place some restrictions on these materials because there were to us some uses that deserved to be kept in spite of the problems that wb saw facing 'us. ` l. - ' * We decided that we've got to get out- of those applications where we felt there was no earthly chance or it was beyond our ability to control the introduction into the environment, so we got put of all the so-called plasticizer applications, August 30, 1970 was the targeted effective date. We- then went into-a very active program of reformulating the .hydraulic fluids. There! again, it required a lot of testing. :We had to run these new materials through the Underwriters Laboratories for approval on fire resistance. They had to be compatible with the machinery then in use. This is not easily X done., but it was done. ` We decided that we could and must continue to supply the trans former manufacturer, the capacitor manufacturer, and at that ' , FUR 004052 WATER PCB-SD0000071472 9 time closed heat transfer systems based primarily on our concept that fire resistance was important in heat transfer. To pick up the point that was raised earlier about foreign im ports, we are to the best of our ability trying to monitor imports. To this day, we have no Information that any.have arrived in this country. On the other hand, we are getting some reports that some of our former customers have made .inquiries of the foreign producers. I am also told by some Canadian provincial agency people that thpy had heard and were going to further investigate that PCB's were entering Canada.and from there ' .V moved .into the United States. I have talked to representatives of the Japanese producer, the Kanegafuchi Company., and I am led to believe that they are most reluctant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering the U.S. market. I have talked to representatives of the French companies. They assure me that they don't want any part of this business. -In-May, 1970 Congressman William Fltz Ryan introduced a proposed bill which would in essence place into law the very things that Monsanto had proposed doing on a voluntary basis. The bill v provided that PCB's be banned except for those situations where the Secretary of HEW would give special permission or license. We :.went through the latter part of '70 and early part of this year feeling, however, that we were still walking on thin ice. ' FUR 004053 WATER PCB-SD0000071473 10 But we thought that we had made some tremendous strides in the right direction to preserve those uses which we thought were essential while eliminating those uses which were grossly con taminating the environment. ThiB summer our hopes Of .control .. in the heat transfer business vanished when we found that a user of PCB did not appreciate the problem, did not 'maintain his" equipment and created the recent chicken, egg, fishmeal problem, Because of this incident, Congressman Ryan withdrew the first ' bill.that was submitted .and has now placed before the same com mittee a bill which totally bans PCB and does not .provide for any use whatever. And there are, of course, penalties for the marketing, manufacture, or use of PCB in this country. A very drastic measure which does cause or can cause a lot of concern among.those of us who feel that PCB has a place in our society Under proper conditions. As a result of .this Incident, we were forced to re-evaluate our position. We decided that, although heat transfer systems could be-closed units, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the. situation where even a pinhole leak can create tremendous pro blems before it can be discovered. So we have taken, again, ' .an arbitrary position and Informed all of our customers in the food (whether, it's animal or human food)j packaging business, emd the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. -- - FUR 004054 WATER PCB-SD0000071474 11 In addition, we will no longer market to any new heat transfer applications. Our efforts will be concentrated on reducing those that we market today. ThiB business should decrease as time goes on. - \..To get back to legislation ... as many of you probably know, . 'there is before Senator Phillip Hart's committee a bill referred- - to as the Toxic Substances Act of 1971- The purpose of this bill is to prevent the Introduction into our society of hazardous materials. It also provides"for the review of materials now in our society and the curtailment of the use of the more hazardous ones,. Initial hearings were held in August, to which a select few individuals were invited to testify. PCB was brought out as an example of a material introduced into society and thought at one time to be most valuable, but is now considered a serious threat to all of us. The meetings.will be resumed in October; I do not know the exact date as.yet, and I'm led to believe that this would be the opportunity for Industry to speak up in its behalf. .1 am assuming that since PCB's were brought up as an example of the type ' of-..substance this bill is supposed to prevent that Monsanto as . '.sole producer in this country will be either invited or we may choose to ask-to be Invited (we don't know at this point Just what is the proper approach here) to speak on the merits of retaining PCB's in transformers, capacitors and fire resistant heat transfer -systems, non-food applications. FUR 004055 WATER PCB-SD0000071475 12 I mention this bill because it is our opinion, and we could be wrong, that rather than act on Congressman Ryan's bill, which Is specific toward PCB's, we suspect that the Toxic Substances * ..Act will have in it provisions which will refer to such materials as PCB's. We feel we have good technical data to justify our staying in the business for limited applications. But we cannot overlook the emotions that have set in. And believe me there are many and they are deep. It is difficult to combat emotions, as you "know, and the references in the popular press to hazardous -poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we talk about per sistant versions' of PCB and degradable versions of PCB I sus pect, and this is a personal opinion, that there would be many who just discount" this kind of Information. This is a very real problem; in my opinion it is a difficult problem. As a little more background let me describe what I understood 'from a meeting we, held last week with representatives of the Food and Drug Administration. It is my personal opinion that the Food and Drug people are as conscientious as can be in trying ' to..cope with the PCB problem. They are objective people trying to work with a minimum of data. I suspect they are as frustrated as any group of people can be as to what is the right way to go. There; are tremendous pressures on the Food and Drug people today as well as the Department of Agriculture brought about by critics. pUR 004056 WATER PCB-SD0000071476 13 - These agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. . The PDA people really don't at this point in time have much infor mation that will lead them to a regulation as to how much PCB should be tolerated in food. They have established some guide- . `lines based on what little information they have from their own laboratories and the information that Monsanto has shared 'With them. The FDA will permit fish at 5 ppm on the market- place;- milk at .2 ppm' or less; eggs .5 ppm; -pountry- (they have "a .double standard) 5 ppm in the fatty tissue and 5.-PPm in the muscle tissue. ' ' Another problem that is disturbing to the FDA, is the recycle -paper problem. The cereal boxes, the cracker boxes, all of ""these boxes that are made from what is known as chipboard, are made from recycle .paper. . Fairly high levels of PCB's are being.found in this recycle board. It probably comes from about three or four different sources. It may come from some ink application in the past, some adhesive application, some coating application, as well as the carbonless reproduction paper appli cation. . There have been some pilot studies made by the American Paper Institute to isolate the carbonless reproduction paper' X from the recycle batch. They still found PCB's In that batch. They are probably looking at maybe the second or third genera tion of recycle. And with the emphasis on recycle, I cannot see any way out of this dilema except that there will be more and more PCB's in these cartons. FUR 004057 WATER PCB-SD0000071477 14 A thought we must all keep in mind, too. Is that we've got to live with the PCB's we introduced into the environment for the past 40 years. They have not disappeared overnight; they will not -disappear overnight. We do not have any tests-that--tell us how long it will take. We can only made an educated guess and we might say they will be out there for another .'generation, 25 to 30 years yet. Hopefully, it will be a decreasing amount 'as time goes on. . Monsanto has conducted.biodegradation tests on its products. We have three programs that are now active.- One program we are conducting in our laboratories in Ruabon, Wales in- which we .are making what I would refer to as scientifically basic studies In terms of which isomers are most degradable and with what .type of microbe. This is a little bit on the Impractical side at this point in time. We have as a consultant. Professor Charles Evans of'Bangor University in South Wales, who is a noted authority worldwide in this kind of activity. He has isolated at least three microbes that seem to thrive on polychlorinated biphenyls. These microbes he developed from soil that he obtained from his garden. What this tells us is that there are microbes out there in the environment that will eventually destroy these materials. In the St, Louis area, we have two types of tests going. One x is the use of river water with its normal biota in it, in which we-introduced t-he^e polychlorinated biphenyls and look for the disappearance rate. It is a very quick and rather unsophisticated type of study. The other type of test is the one that simulates FUR 004058 WATER PCB-SD0000071478 - 15 - ' those conditions which are apt to be found in a normal municipal sewage treatment plant. It's an aerobic test using an activated sludge from a St. Louis waste treatment plant. As a standard, ' we use a soft detergent'because it .is well known to ot.h.e-r-. laboratories. What we are doing, really is using our expertise that we established back in the days when the hard versus soft detergent controversy was quite common. And we are using 'these soft detergents that "do degrade as our controls and comparing the PCB's to these con trols, The studies so far show that there are isomers within each of these mixtures-that do degrade. The lower the chlorine level,*-the faster they disappear, the higher the chlorine level 'the more resistant they are. Which only confirms what many of us had'suspected. We were not too surprised by this data. . 1-will attempt-to summarize ... I think we can conclude that rPCB 's ...are in.'the environment. There is no question about it. Many.of these PCB's are manmade and were Introduced to the environ ment because of our lack of understanding of what these materials can d6 to the environment. In this country Monsanto, as sole producer, has attempted to improve the 'situation by limiting - the applica tions . to which these. materials are used. Studies 'tp'day would Indicate that these PCB's are not. and cannot be #* .classified as highly toxic. There is still a lot of information \ " " . ' . . '/ that Is needed to help us determine the long term effect on human beings. We feel that the properties of these materials make them, at'least as of tpday, the most suitable material for use in trans formers, capacitors and heat transfer systems. We also believe that under proper conditions we can control the amount of these ^ FUR 004059 WATER PCB-SD0000071479 - 16 - that do enter the environment to the point where the adverse effects are not great and that the benefits we derive far out weigh the minor adverse effects that we might notice. Now there -are many of us in the transformer and capacitor application that have made tremendous strides in controling these materials. I suspect our objective is to further Improve our ability to control this .material. In my. personal opinion the emotion that is now prevailing regarding PCB's is something that we -must contend with. Whether we believe in it or not, there are many people that sincerely believe PCB-'b should-be totally 'banned.' ' * FV)R4060 WATER PCB-SD0000071480 STATUS REPORT PCB/PCT IMPLEMENTATION PROGRAM U. S t DOMESTIC PROGRAM .. I. Discontinue sales of PCBs for heat transfer applications '" The sales of PCB heat transfer fluids In the U.S. were terminated on December 15, 1971 with two exceptions, both covered with hold harmless agreements. We continue to supply Goodyear Tire and Rubber Company under an agreement until August 7, 1972. We supplied fluid to Bendix Corporation under an agreement but sales were terminated prior to June 1972. '. Certified by T. L. Gossage II. Further sale and delivery of PCBs as dielectric fluids for transformers and capacitors will be made in conformance with certain restrictive policies adopted by Monsanto management. Sales of PCB dielectric fluids in the U.S. were terminated . * . ..on January 15, 1972 except to approved customers who ' satisfy Monsanto'b special requirements. Certified by T. L. Gossage III. -'Discontinue all sales of PCTs (polychlorinated terphenyls) ... no later than June 30, 1972. The program calls for 75# of - such sales to be terminated by March 31, 1972, with the remainder to be terminated during the Becond quarter of 1972. ' With two exceptions, sales of plasticizers containing PCTs were terminated on March 31, 1972, exclusive of a few customers who had signed hold harmless agreements. The two exceptions occurred in early April, Sales to customers who had Bigned hold harmless agreements were terminated prior to June 30, 1972. Certified by W. S. Clark SaleB of PCT industrial fluids were terminated on June 30, 1972. Certified by T. L. Gossage WATER PCB-SD0000071481 2 U.S. EXPORT PROGRAM I....- Discontinue all saleB of PCBs for all uses other than as di electric fluids In transformers and capacitors no later than January 31> 1972. Effective date of discontinuance shall be date of letter giving formal notification. .. SaleB of PCBs for all uses other than dielectric fluids . : in transformers and capacitors were terminated by ' January 31> 1972. Certified by E. Greene D. Goodwlllle W. S. Clark J.I; Further sale and delivery of PCBs as dielectric fluids for ... . transformers and capacitors will be made in conformance with the restrictive policies adopted by Monsanto management. "... In Canada sales of PCBs to dielectric applications were terminated on January 31> 1972 except to approved customers who satisfy Monsanto's special requirements. Certified by D, Goodwlllle .... -Remaining export sales of PCB dielectric fluids were terminated on March 31> 1972 except to approved customers who setisfy Monsanto 1 s special requirements. Certified by E. Greene III, Discontinue all sales of PCTs no later than June 30, 1972, .. The program calls for 75% of such saleB to be terminated by March 31, 1972 with the remainder to be terminated during the second quarter of 1972. All sales of plasticisers containing PCTs were terminated on March 31, 1972 except for thoBe customers who signed special agreements. These were terminated by June 30, 1972. Certified by W. S. Clark P. J. Marsh D, Goodwlllle E. Greene Sales of industrial fluids containing PCTs were terminated on June 30, 1972. Certified by D. Goodwlllle P. J. Marsh E. Greene FUR 004148 WATER PCB-SD0000071482 -3- MONSANTO EUROPE PROGRAM I. Discontinue all sales of PCBb for other than dielectric uses by January 31. 1972. _ ' ' _' Sales of all PCB products other than hydraulic fluids for the German mining industry and dielectric fluids were terminated on January 31* 1972. Program calls for ter miration of sales to the German mines by November 30* 1972. ~ ' Certified by P. J. Marsh -II, Further sales and delivery of PCBs for dielectric UBes for ' transformers and capacitors will be subject to the same re " " strictlve policies adopted for U.S. domestic and U.S. export f sales and the effective date of implementation will be ' . March 31* 1972. . ^ Sales of PCB dielectric fluids were terminated on March 31* 1972 except to approved customers who satisfy .Monsanto's special requirements and to Eastern European .customers to whom we continue to sell wlthovdr~ree-tr4c^ons . ' Certified by P, J. Marsh MMK PROGRAM - ~ ' ' Mitsubishi Monsanto discontinued the exporting of PCBb except for dielectric purposes on January 31* 1972. Manufacture of PCBs was discontinued entirely on March 17* 1972 and all sales were discontinued shortly thereafter. Certified by E. Greene FUR 004149 WATER PCB-SD0000071483 Monsanto MONSANTO INDUSTRIAL CHEMICALS CO. 600 N. Lindbargh Boulavtrd St. Louis, Missouri 63166 Phona: (314) 694-1000 Dear Sir: We are writing to advise you that Monsanto has adopted certain restrictive policies with respect to its further sale and delivery of all polychlorinated biphenyl (PCB's) products used as dielectric fluids in transformers and capacitors including but not limited to^those sold unde^r tradenames such as AroclordP, Inerteen(5>, and Pyranol(fi), and under the generic term askarel. Effective 15 January 1972 Monsanto will sell and deliver these products only to manufacturers of transformers or capacitors who have entered into agreement to indemnify and hold harmless Monsanto in the use of these products. The two copies of such an agreement are attached. The acceptance by Monsanto of such an agreement is subject to receipt of financial and other information from you (such as evidence of adequate insurance protection) which, in Monsanto's opinion, makes the agreement meaningful. As we have previously advised you, studies indicate PCB's may be accumulating in the environment. In some instances, PCB's have been found in food or in the food chain. For your information, attached is an article by Carl G. Gustafson of the' Federal Water Quality Administration appearing in "Environmental Science & Technology" which deals with this subject. Because of Monsanto's concern over this problem, we are discontinuing sales of'PCB's in any applications except as dielectric fluids for use in transformers and capacitors. FUR 004150 a unit o( Monsanto Company WATER PCB-SD0000071484 Monsanto MONSANTO INOUSTRIAL CHEMICALS CO. 800 N. Lindbergh Boulevard St. Louis. Missouri 63168 Phona: (3U) 694-1000 SPECIAL UNDERTAKING BY PURCHASERS OF POLYCHLORINATED BIPHENYLS Monsanto Company ("Monsanto") manufactures certain poly chlorinated biphenyl products ("PCB's") which ______________ ("Buyer") desires to purchase. While Buyer desires to purchase PCB's because of certain desirable flame resistant and insulator properties. Buyer acknowledges that it is aware and has been advised by Monsanto that PCB's tend to persist in the environment; that care is required in their handling, possession, use and disposition; that tolerance limits have been or are being established for PCB's in various food products. Monsanto has therefore adopted certain restrictive policies with respect to its further production, sale and delivery of PCB's, including the receipt of undertakings from its customers as set forth below, and Buyer is willing to agree to such undertakings with respect to sales and/or deliveries of PCB's by Monsanto to Buyer. Accordingly, Buyer hereby covenants and agrees that, with respect to any and all PCB's sold or delivered by or on behalf of Monsanto to Buyer on or after the date hereof and in consideration of any such sale or delivery, Buyer shall defend, indemnify and hold harmless Monsanto, its present, past and future directors, officers, employes and agents, from and against any and all liabilities, claims, damages, penalties, actions, suits, losses, costs and expenses arising out of or in connection with the receipt, purchase, possession, handling, use, sale or disposition of such PCB's by, through or under Buyer, whether alone or in combination with other substances, including, without implied limitation, any contamination of or adverse effect on humans, marine and wildlife, food, animal feed or the environment by reason of such PCB's. unit of Monsanto Company FUR 004151 WATER PCB-SD0000071485 2- - A11 existing contracts for the sale of PCB's by Monsanto .. to Buyer are hereby amended to contain the provisions set forth above. Nothing herein shall create or imply any duty or obligation of Monsanto to Bell or deliver any PCB's to Buyer. No condi tions, understandings or agreements purporting to modify or vary the terms hereof shall be binding unless hereafter made in writing specifically'referring to this agreement and signed by the party to be bound and no modification or variance of the above undertaking shall be effected by the acknowledgment or acceptance of any sale document, purchase order, shipping instruction or other forms containing terms or conditions at variance herewith. BY: TITLE: DATE: ________________________ (Buyer) MONSANTO COMPANY BY: FUR 004152 WATER PCB-SD0000071486 feature andhpersistent Intensified research is needed to minimize their dangers Carl Q. Gustafson. Federal Water Quality Administrationt Athens, Ga. r> J_during (he past three years, a special class of compounds, called polychlorinated biphenyls (pcb's), has claimed the attention of ecologists and pesticide analysts in this country. These compounds were not discovered in the environment until 1966 in Swe den and 1967 in the U.S., despite the tact that they have been available com mercially for 40 years. Interest in pcs'* has arisen because they are frequeftly found in fish, bird, water, sediment, and other environmental samples when such samples arc examined for chlori nated pesticide residues. That a wide variety of samples containing pcb's has been collected from England, Scandi navia, The Netherlands, Antarctica, Central America, and many different p.:U of the 15.S. makes them truly ubiquitous pollutants. Polychlorobiphenyls are made by substituting chlorine atoms for one or more of the hydrogen atoms at the The Monsanto Co. stated recently In a letter to Congressman William F. Ryan of New York that as of August SO, It would no longer sell fee's to t customers for use in general plasticizer operations where disposal of the endproducts cannot be controlled. Alter some lag period--the time It takes to eventually dispose ol the products made from fee's and currently in processor's Inventories--the quantity of fee's getting into the environment may be substantially reduced. If Monsanto's former customers look for PCB substitutes, rather than purchasing, fee's from manufacturers in Japan and Europe, the projected decrease could become a reality~ > ' Carl G. Gustafson numbered positions of the biphenyl structure. ' In the process of replacing hydrogen atoms with chlorine atoms, a large number of substitution combinations arise. For example, three monochlorobipheny! isomers are possible, 12 dichlorobiphenyl isomers, 21 trichlorobiphenyl isomers, and so on. Theoreti cally, 210 compounds can be prepared by this substitution process; a typical example would be 2,4,6,2`4-pcntachlorobiphenyi. Whenever arortjatic hydrocarbons such as biphenyls are chlorinated, the product is a mixture of compounds, in cluding isomers. It is quite difficult, to synthesize single, specific chlorobiphcnyl compounds in the laboratory unless involved procedures are em ployed. Consequently few of the indi vidual compounds have been prepared in the pure form for study. In the commercial process for pcs manufacture, biphenyl is chlorinated with anhydrous chlorine in tali cy lindrical towers with either iron filings or ferric chloride as the catalyst. The by-product is hydrogen chloride; the product is a mixture of several pea's. The degree of chlorination is deter mined by measuring the specific gravity of Che mixture or, when the product h more viscous, the ball-nnd-ring soft ening-point test is used. The whole pro cess takes from 12 to 36 hours. . In the U.S., the sole manufacturer of pcb's is the Monsanto Co., which markets them under the trade name Aroclor. pcb's are also manufactured in Europe and Japan, under trade names such as Pbenochlor and Clophen. The various Aroclors are dif ferentiated by a four-digit number, with the last two-digits indicating the percentage of chlorine in the mixture. Proparti** The three most important physical properties of the pea's are low vapor pressures (they have high boiling points), low water solubility, and high dielectric constants. They are mis cible with most organic solvents and compatible with many types of poly mers. Although some individual poly- chlorobiphenyl compounds are crys talline, the Aroclor mixtures are either liquids or resins. The chemical properties that make pcb's desirable industrial materials are their excellent thermal stability, their strong resistance to both acidic and basic hydrolysis,`and their general in ertness. They are quite resistant to oxidation. Monsanto reports, in a tech nical bulletin on PCB's, that they can be heated to 140 C, under 260 p.s.i. of oxygen pressure "without showing any evidence of oxidation as judged by de velopment of acidity or. formation of sludge." ' The physiological properties of the pea's .make them potentially significant contaminants of the environment. For any pollutant, two factors arc involved: acute toxicity, which is immediately evident because of a high death rate or other maiming effect; and chronic tox icity, which it the result of a slow ac cumulation of the poison in the body and is a sublelhal effect. Whenever acute toxicity is high, a pollutant will be readily recognized and appropriate remedial actions will be introduced. If, on the other hand, acute toxicity is low. *14 Enrtrwimrcla! Scirr> ti Ttcfinotogy FUR 004153 WATER PCB-SD0000071487 the physiological effects will go un noticed until the chronic effect! make themselves evident. When this happens, the problem may have advanced be yond immediate or euy correction. fUuU texlelty All studies of rca's in animals indi cate that acute toxicity is not a signifi cant factor. Their acute toxicides are on the order of those of other chlori'nated aromatic compounds. Monsanto has sponsored two investigations of the acute toxicilies of Aroclor mix tures. In the first, at the Kettering Laboratory at the University of Cin cinnati, Dr. J. F. Treon and his coworkert investigated the toxicity of Aroclor vapors for guinea pigs, mice, rabbits, and rats. All animals survived a 24-day exposure to 0.83 p.p.ra. of Aroclor 1242 for 7 houn per day on 17 of those days. Even after more pro longed tests, there were no severe ef fects from Aroclor 1242. In the second Investigation, still in process, three groups of besgles are fed Aroclor 1242, 1254, and 1260, respectively, at a rate of 100 p.p.m. in their diets. After three months no significant abnormalities have been noted. Similar studies on fish have been per formed in severs! laboratories. Dr. Richard Schoettger of the Sport Fish eries and Wildlife Fish-Pesticide Re search Laboratory in Columbia, Mo., reports that 96 hour-TLt0 toxicitiea of the Aroclors to trout range from 1.17 to 60 p.p.m. Compared to dot, whose 96 hour-TLjn toxicity it 0.002 to 0.009 p.p.m. for trout, the rca's have a rela tively low acute toxicity. With the more sensitive bluegill, the 96 hour-n.l() for Aroclor 1248 is 0.278 p.p.m., while that of cdt is 0.008 p.p.m, Aroclor toxlcitles appear to be inversely propor tional to the chlorine content of the mixture. Shellfish, oysters, and shrimp are" more sensitive to rca's. Dr. Tom Duke, at the Bureau of Commercial Fisheries Pesticide Field Station, re ports 1009s mortality of juvenile pink shrimp exposed to 0.10 p.p.m. of Aro clor 1254 in water for 48 houn. This concentration of Aroclor 1254 will cause a 100% decrease in shell growth of oysters after 96 houn. To achieve the same effects with dot In these ex.periments, only 0.0006 p.p.m. and 0.01 p.p.m., respectively, were required. There is very little evidence that Tea's are toxic to insects. Studies to date show that they are lest toxic than dieldrin or dot. As with fish, their tox icity appears to be Inversely propor tional to the chlorine content of the mixture. Based on the above data, it is un derstandable why the polychlorobiphenyls, commercially available for 40 yean, have only recently attracted attention as toxic environmental con* Lamia ants. Chr*nl taxlelty . The chronic toxicilies of rca's pre sent a more disturbing situation; several chronic effects have been observed. It was discovered, quite by accident, that pea's have a toxic effect on chickens. Professor E. L McCune and his coworken at the Univenity of Missouri found their chickens dying after they were placed in a feeding house, parts of which hsd been freshly psinted with an epoxy paint. Careful Investigstion revealed that the toxic factor was Aro clor 1242, a binder in the paint When Aroclor 1242 was fed to the chicks it produced the same characteristic effects, as chick edema factor. McCune re ported: "dross pathology included hy dropericardium, hydroperitonium, en larged heart, liver, and kidneys, and hemorrhage of Internal organs. Mi r . va. croscopically the kidneys showed marked tubulir dilation and numerous casts." Another chronic effect of rca's fa related in wildfowl. The accumulation of high concentrations of chlorinsled hydrocarbons in birds resulted in dis ruption of normal breeding behavior and in the formation of thin-shelled eggs. A dramatic example of this efft hu been observed in the esse of the brown pelican. On the Anacapa Islands off the California coast, no young were hatched last year from 300 pairs of nesting birds. The shells of moat eggs laid were so thin that a dent occurred when the egg was picked up. There are two possible causes for. the laying of thin-shelled eggs by wild fowl. One is a low calcium' reserve in the bird; the other is the inability of the bird to deliver the needed calcium to Its oviduct, where tbe eggshell is forming. The calcium level in the avian biosystem and the calcium reserve in the secondary bone structure or medul lary bone, found only in female birds when they are breeding, are controlled by the hormone estrogen. A high es trogen level Is associated with the for mation of this calcium reserve. Chlo rinated hydrocarbons, such m dot, Volume 10, October 1970 SIS FUR 004154 WATER PCB-SD0000071488 chlordtne, dieldrin, and pcb's, activate enzymes in the liver which transform estrogen into a more water-soluble compound that is readily eliminated from the bird's body. This means that when estrogen levels are low, calcium reserves will also be low, and there fore very little calcium will be avail able for strong eggshell production, Dieldrin and pcb's are more effective than dot in this type of entyme-induction activity. Aroclor 1262 has an es tradiol degrading potential four to five times that of p,p'-doe or technical grade dot. The ability of the female bird to deliver calcium to her oviduct during the last 20 hours, when the eggshell is being formed, is related to the func tioning of the enzyme carbonic anhydrase. When birds that have ex hibited the ability to lay normal eggs are injected with a metabolite of ddt (doe) just prior to the formation of the eggshell, they will lay thin-shelled eggs. This indicates that dot also In hibits the activity of carbonic anhydrasc, the enzyme (hat controls the flow of calcium from the blood stream of the bird into its oviduct. Since dieldrin seems to have no effect on carbonic anhydrase, we may assume that neither do the pcb's. How ever, these compounds delay breeding time significantly. Many ornithologists feel that late breeding has a stronger Influence on the reduction of bird populations than does the laying of thin-shelled eggs. If this is true, pcb's are a more potent threat than dot to our declining bird populations, es pecially for predatory birds that ac cumulate fairly high levels of pcb's be cause they eat smaller animals that al ready have concentrated pcb's in their own tissues. Other investigators have .produced evidence to show that pcb's are simi lar to ddt in their activity. Dr. Joseph Street at Utah State University has ahown that when pcb's accumulate in the liver, they induce microsomal en zyme activity by bringing about more rapid metabolism of drugs, insecticides, and other foreign compounds. He fed rats a diet containing 50 p.p.m. of Aroclor 1254 or Aroclor 1260. After 10 days on this diet, the test animals were administered hexobarbitol at a dose of 100 p.p.m. to induce sleep. In comparison with a control group, the sleeping time for these rats was reduced by 65 to 80%. Street also found that Aroclor, when fed at (be same level, will reduce dieldrin. stor age in adipose tissue by 90 to 95%; in crease aniline oxidation by 200 to 300%; and increase epn detoxication by 430 to 470%. In addition, the pcb's cause activation of organothiophosphate compounds, which adversely af fect the system. This latter effect coun terbalances the detoxification of diel drin. Normally, when a substrate activates an enzyme, it is converted to a wateraoluble form that will be eliminated from the system; however, this is not the case with pcb's. Because they re main in the system for prolonged pe riods of time, their enzyme induction activity is always present. In this way the norma! concentration of important body chemicals may be lowered to the point df bringing about malfunctions in the system. For exampte, Street be lieves that the pcb's bring about steroid degradation, which can lead to altered endocrine relationships. The chronic toxicity to man is as follows: Like the chlorinated naphthalenes, the chlorinated diphenyls have two distinct actions on the body, namely, a akin effect and a toxic action on the liver. The lesion produced in the liver is an acute yellow atrophy. This hepato-toxic action of the chlorinated di phenyls appears to be increased if there is exposure to carbon tetrachloride at the same time. The higher the chlorine content of the diphenyl compound, the more loxtc it is liable to be. Oxides of chlorinated diphenyls are more tltf Entlroofn^nUl Scfrtv* A TVchnoloo* FUR 004155 WATER PCB-SD0000071489 tonic than the unoxidircd ma terials. ` The skin lesion is known aa chlotacnr, and consists of small pimples and dark pigmentation of the exposed areas, initially. Later, comedones and pustules develop. Jn persons who have suffered systemic intoxication, the usual signs and symptoms are nausea, ' vomiting, loss of weight, jaundice, edema, and abdominal pain. Where the liver damage has been severe, the patient may pass into coma and die. Sax. N. /rvin/t, "Dangerous Properlirs a] Industrial Materials." 3rd ed.. Van Nostrand-Reinhold, New York. 196/1. The ubiquity of pcb's is related to the wide spectrum of applications that Have been found for them. The largest single use of pcb's is related to their electrical properties--as coolant-insu lation fluids in transformers. For (his purpose the Aroclors arc nlso sold under such trade names as Chloroxtol (Allis-Chalmcrs Mfg. Co.), Dykanol (Federal Pacific Electric Co.). Incrtcen (Westinghouse Electric Co.), Noflamol (Wagner Electric Co.). Pyranol (General Electric Co,), and Thcrminol (Monsanto to.). Other uses of pcb's include formula tion into ballasts for fluorescent fix tures: impregnation of cotton and as bestos for hr.uded insulation of elec trical wiring: a plasticizer in wire and cahle coatings: capacitors and nskuroltype transformers; and plasticizers of sinyl ch'oridc polymer films. Because of their thermal stability and fire re sistance. the ptb's also find application in high-pressure hydraulic fluids, spe cialized lubricants and gasket scalers, heal transfer agents, and machine tool cutting oils. Miscellaneous uses in clude: formulation into some epoxy paints; protective coatings for wood, metal, and concrete: adhesives; and in carbonless reproducing paper. One of the primary manufacturers of carbon less reproducing paper also sells Aro clors in an encapsulated form. Generally the kinds of applications described above mean that the pcb's will be in many types of products that eventually find their way to the domes tic market. When used io manufacture of ballasts for fluorescent fixtures they will be found in kitchens, baihrooms, stores, and offices throughout the coun try. Wherever office forms arc used that do not use carbon paper, one may find pcb's formulated into the micro capsules of dye that comprise the re Aroclor 1254 H approximately 10 time* tho*e of the pesticide* in A, hence It is un derstandable why PCB'* were not readily recognized In pesticide chromatograms. Ga* chromatograph (Packard 7620) conditions: gas flow 80 ml./min. nitrogen; tem peratures--oven. 210* C., inlet. 230* C.. detector, 218* C.: Nl" electron capture detector; 5` x Vi" glass column packed with 8SE-30 on Chromosorb Q 80-90 mesh. producing layer of the business form. fee's have also been found on the transparent receipts used in credit card charge forms. A* plasticizers they can be expected to appear in many con sumer plastics. . Since the chronic toxicides are. so significant, it becomes important to know just how extensively the' pcb's are distributed in the ecosystem, and just how they find their way into the environment. Rainwater in En gland, brown seals off the coast of Scotland, white-tailed eagles in Swe den, cod in the Baltic Sea, mussels in The Netherlands, adelie penguin eggs in the Antarctica, brown pelican eggs in Panama. Arctic terns, shrimp in Florida, river water in Japan, waters in the Great Lakes, human hair, and human adipose tissue--samples of all these have been found to contain pcb'i. Volumt 4*NumWr 10, OeioWf 1^10 FUR 004156 WATER PCB-SD0000071490 thus making them a cln of widely diiperscd pollutants. Readily abeecbed The properties of PC*'* that make them industrially useful are the aame propertie* that caute them to persist in the environment. These in clude thermal stability, resistance to oxidation and bydrolyrir, solubility in a wide range of organic solvents, water Insolubility, high dielectric constant, and compatibility with many type* of macromolecule*. Their resistance to oxidation and hydrolysis alto make* pcb's more itible and persistent than DOT. Consequently, they could even tually accumulate to a higher concen tration than ddt, especially if the use of dot is sharply curtailed in the U.S. The solubility of pcb's in nonpolar solvenlt explains why they arc readily absorbed into fatty tissue and into the liver. Their resistance to oxidation or other types of chemical degradation explains their persislencc in the en vironment and accumulation in animal tissue. The latter effect is enhanced both by their insolubility In water and solubility in organic solvents. Their chemical inertness and resistance to metabolism account for their low acute toxicity. But as they slowly build up in a living system their con centration approaches toxicity levels, at which point chronic effects make themselves evident. Jt has been established (hat ilsh-eating birds will accumulate large concenOations of pcb's, as in the case of the white-tailed eagle, which ha* been found to have as much as 14,000 p.p.m. of pcb's. Peregrine falcons, taken off the coast of California, were found to have as much as 2000 p.p.m. in their lipid tissue. When shrimp were exposed to 10 p.p.b. of Aroclor 1254 for 48 hours, they accumulated 1300 p.p.b. of pea's, which represents a 130-fold con centration in a very short time. Oysters, exposed to an identical concentration of Aroclor 1254 for 96 hours and then plaoed in pea-free water for four days, still had a concentration of 33,000 p.p.b. of pcb's, which constitutes a 3300-fold concentration. This'mean* that even though the concentration* of pcb's are In the parts-per-bitlion range in the environment, their high lipid solubility causes them to collect in fatty tissue* of lower animals and marine life. Therefore, species at the top of a food chain will also accumulate pcb's In their bodies, particularly in their lipid litsue and liver, in much the same way a* they accumulate dot and other chlorinated pesticides. Because of (he low solubility of pcb's in water, when a solution or dispersion of them is discharged into a river or lake, they will accumulate on the sedi ment in relatively high concentration*. Subsequently, they will redissolve very slowly in the water as conditions change. Therefore, it will usually take a long time to flush out a contaminated area. Accidental occurrence The reason that pcb's have not been found In the ecosystem as extensively as dot, and are not present in environ mental samples at as high a concen tration as ddt, is that pcb's find their way into the environment accidentally. dot is deliberately spread because this is the only way its insecticidal propertie* can be utilized, pcb'* are not in tended to get into the environment, but they do because their unique chemical propertica prevent them from being de stroyed by our usual waste disposal methods. Thu*, they inadvertently e*capc and become widely dispersed. In Sweden, where the use of dot has been banned, and where the main power source is hydroelectric, investi gators find that the concentration of pen's in the environment is as high as that of ddt. There are several ways by which pcb's get Into the ecosystem. One of these is by incineration. Products con taining pcb's, such as carbonless re producing paper in business forms, plastics (especially polymer film and sheeting that contain Pco's as plasti cizers), spent ballasts from fluorescent light fixtures, and objects coated with PCB-formulated coatings, all find their way to the city dump or incinerator for burning. The rca's do not bum but are vaporized. They are then carried into the atmosphere, where they collect on particulate matter and are subse quently returned to the surface of tbe earth, into the riven, lakes, and ocean*. In this way they become widely dis- . tributed throughout the global environ ment. Another source is probably land run-off from industrial wastes and dumps. A third source is the point of manufacture and tbe plants where rcn'i are processed into other products. They can escape through the plant ven tilation and exhaust system* into the atmosphere and through its waste treat ment system into sewers or directly into waterways. . SIS EmiroonrenUl Science A Ttchnoioff FUR 004157 WATER PCB-SD0000071491 It it interesting to note that the inci dence of fcb'i in environmental sam- plei is highest in industrialized and ur banized areas. Birdt whose primary habitat is the San Francisco Bay area have a larger concentration of PCB'a per unit of body weight than those lo cated in Baja, Calif., which it com pletely rural. Aquatic life in the Archi pelago of Stockholm, the most indus trialized area of Sweden, were found to have a higher concentration of pcb's than fish tamplea taken from the west ern coast of Sweden, a less developed area. Sediment samples taken from louthem portions of Lake Michigan have a higher concentration of pcb's than those from other parts of the lake. Monsanto state* that until a recent change in marketing policy (see inset, page 814), sales of Aroclors were in creasing at the rate of 8% per year. While this increase does not seem sig nificant, it may be important if the in creased consumption was in consumer product* and thus would find their way inlo our normal solid wasic disposal systems. Such an occurrence would mean a definite increase of pcb residues in the environment, and therefore a marked increase in their chronic tox icity effects. ' Detection pcb's were not discovered in environ mental samples until very recently for several reasons. First, as indicated above, they have not been deliberately distributed about the ecosystem. Sec ondly, because of their relatively low acute toxicities, their presence was not immediately evident. Finally, they are difficult to detect analytically. The pcb's were first detected as in terfering peaks in the gas chromato graphic analysis (oc) of environmental samples being analyzed for chlorinated pesticide residues. When pcb's are pres ent in a sample they give a pattern of several cc peaks, whose retention timesare similar to those of dieldrin, ddt, doe, aidrin, and hcptachlor oxide. Be cause the peaks were not large or aharp, investigators tended to ignore them until S, Jensen, In Sweden, and R. Ritcbrough, at the University, of California at Berkeley, identified them as corresponding to common constitu ents of environmental samples being analyzed for persistent pesticides. The problem of the interferences of pcb'i with the analysis of other chlori nated pesticides has been largely over come by prior treatment of the sam ple. Several investigators have used column chromatography to separate pcb'i from chlorinated pesticide*. At a recent meeting, iponsored by the rwQA's National Water Quality Lab oratory, Duluth, Minn., a general pro cedure was .recommended for separa tion of pcb's from pesticides. In this procedure for biosamples, the sample is extracted with hexane as in regular pesticide analysis. It is then partitioned with acetonitrile to remove fats, the cleaned-up extract is passed through a Fluorisil column and then through a silicic acid column. Finally, the sample is analyzed by gas chromatography, with a chloride-specific detector. In this way the pesticides are retained on the silicic acid column for later elution and identification. - ' Research need* To assess fully the significance of pcb'* as environmental pollutants, ad ditional research is needed. No one really knows the extent of the chronic effects of these chlorinated hydrocar bons. Some problems that need to be considered are: ' Although pcb's are known to ac cumulate in human organs we do not know at what concentration they will begin to exhibit toxic effects. Will these chronic effects be similar to those shown in animal*--microsomal en zyme activity, calcium metabolism in hibition, and to on? What are other possible chronic effects? Which of the many pcb com pounds in the commercially available mixtures are responsible for their tox icity? Can commercial pcb mixtures be modified to eliminate the toxic com ponents? Pure samples are required to answer these questions. At the present time work is continuing at the fwqa's Southeast Water Laboratory to sep arate each of the Aroclor mixtures into its many components, and to identify each component. We need to know all the uses for the pcb's. What is the annual produc tion of pcb's? Our knowledge of these facts it limited and needs to be ex panded. These fact* should be known if we are to accurately determine how they get into the environment, and take steps to prevent further environmental contamination by them. In view of the complexify of the isolation and accurate quantitative analysis of pea's in chlorinated resi dues, a straightforward, unambiguous measurement of them needs to be de veloped. What it the fate of pcb's In nat ural waters? More needs to be known of their partition coefficients between bottom sediments and water. This it vital if we are to estimate how long it will take for a river bed to clean itself of contamination. It will also be useful when assessing the effects of pcb's on marine life that feed on the bottoms of lakes, rivers, and estuaries. We should also learn more about pcb solubility in water of various ionic strengths. Are present waste treatment sys tems adequate to handle pcb's? Do spe cial measure* need to be taken when pcb's. are part of the waste effluent be ing treated? ' By trying to get some of these an swers now, we may find that we arc in' a position .to control the escape of pcb's into the environment before ad ditional damage is done. So frequently, action is taken only after it is evident that massive damage has resulted from a particular pollutant. In the cue of the pcb's wc may have an opportunity to resolve the aituation before that happens. Additional Reading Hubbard. H. L. "Chlorinated Biphenyl and Related Compounds," Encyclo pedia of Chemical Technology, 2nd ed., 5, Interscience Publ., New York, N.Y., 1964. pp. 289-298. Reynolds, l. M,, Bull. Environ. Contain. rox/co/. 4, 128(1969). Ritebrough, R. N., et. a/.. Nature 220 (1968). Carl 'G. Gustafson, chairman of the Department of Chemistry of King's College, Brlarcliff Manor, N.Y., re ceived a Ph.D. in organic chemistry from the University of Delaware In 1957. During the ! 969-70 academic year, he was on leave at the fwqa Southeast Water Laboratory in Athens, Ga., where he studied trace organic analysis in waste effluents. As a mem ber of the National Water Contami nants Characterization Research Pro gram, he worked with pcb's and pulp and paper mill effluents. Volun* A. Numbtr lO.OrtoUr 1970 l WATER PCB-SD0000071492 Monsanto MONSAhfTO INDU8TKIAL CHEMICALS CO. 000 N. Undbsrgh Boultvard St. Loula, Missouri 63106 Phon#: DU) 664-1000 February 4, 1972 It - . Dear Sir: . We are writing to advise you that Monsanto has adopted certain policies with respect to its further sale and delivery of all polychlorinated biphenyl (PCB) products used as dielectric fluids including^mt not limited to those sold under tradenames such as AroclorvS^ Inerteen, and PyranolCE), and under the generic term askarel. Effective immediately Monsanto will sell and deliver these prod ucts only to manufacturers of electrical equipment or components who utilize the products as dielectric fluids and who have entered into agreement to indemnify and hold harmless Monsanto in the use of these products. The two copies of such an agreement are at tached. The acceptance by Monsanto of such an agreement is sub ject to receipt of financial and other information from you (such as evidence of adequate insurance protection) which, in Monsanto's opinion, makes the agreement meaningful. As you are undoubtedly aware, studies indicate PCBs may be accumu lating in the environment. In some instances, PGBs have been found in food or in the food chain. For your information, attached is an article by Carl G. Gustafson of the Federal Water Quality Administration appearing in "Environmental Science & Technology" which deals with this subject. Because of Monsanto's concern over this problem, we -have discontinued sales of PCBs except for use as dielectric fluids in electrical equipment and components. If you desire to continue purchase of these products from Monsanto, please have the attached copies of agreement signed by an authorized officer on behalf of your company and forward a fully signed copy, together with your most recent audited financial statement and any other information which you feel will assist Monsanto in its evalua tion. WATER PCB-SD0000071493 Page 2 If you have any questions please telephone (314) 694-2455 or write directly to Hr. H,S, Bergen, Monsanto Company, P.O, Box 14617, St. Louis, Missouri 63178. We .sincerely regret any hardships that this decision may cause you but it is taken in an effort to continue to make -available these products for these important electrical applications. Very truly yours /bi Enclosures Howard Bergen, Director Specialty Products Group Monsanto Industrial Chemicals Co FUR 004160 WATER PCB-SD0000071494 Monsanto MONSANTO INDUSTRIAL CHEMK3A1S CO- 800 N. Lindbergh Boulevard : St. Louie, Miteouri 63168 Phone: (314) 694-1000 SPECIAL UNDERTAKING BY PURCHASERS OF POLYCHLORINATED BIPHENYLS Monsanto Company ("Monsanto") manufactures certain poly chlorinated biphenyl products ("PCB's") which _ ("Buyer") desires to purchase. While Buyer desires to purchase PCB's because of certain desirable flame resistant and insulator properties. Buyer acknowledges that it is aware and has been advised by Monsanto that PCB's tend to persist in the environment; that care is required in their handling, possession, use and disposition; that tolerance limits have been or are being established for PCB's in various food products. Monsanto has therefore adopted certain restrictive policies with respect to its further production, sale and delivery of PCB's, including the receipt of undertakings from its customers as set forth below, and Buyer is willing to agree to such undertakings with respect to sales and/or deliveries of PCB's by Monsanto to Buyer. Accordingly, Buyer hereby covenants and agrees that, with respect to any and all PCB's sold or delivered by or on behalf of Monsanto to Buyer on or after the date hereof and in consideration of`any such sale or delivery, Buyer shall defend, indemnify and hold harmless Monsanto, its present, past and future directors, officers, employes and agents, from and against any and all liabilities, claims, damages, penalties, actions, suits, losses, costs and expenses arising out of or in connection with the receipt, purchase, possession, handling, use, sale or disposition of such PCB's by, through or under Buyer, whether alone or in combination with other substances, including, without implied limitation, any contamination of or adverse effect on humans, marine and wildlife, food, animal feed or the environment by reason of such PCB's. unil ol Mont into Company FUR 004161 WATER PCB-SD0000071495 All existing contracts for the sale of PCB's by Monsanto to Buyer are hereby amended to contain the provisions set forth above. ; Nothing herein shall create or imply any duty or'obligation of Monsanto to sell or deliver any PCB's to Buyer. No condi tions, understandings or agreements purporting to modify or vary the terms hereof shall be binding unless hereafter made in writing specifically referring to this agreement and " " signed by the party to be bound and no modification or variance of the above undertaking shall be effected by the acknowledgment or acceptance of any sale document, purchase order, shipping instruction or other forms containing terms or conditions at variance herewith. BY: TITLE: DATE: __________________ (Buyer) MONSANTO COMPANY BY: FUR 004162 WATER PCB-SD0000071496 feature PCB's-prevalerit and persistent r Intensified research is needed to minimize their dangers Curl Q. Qustafson, Federal Water Quality Administration, Athens, Ca. T) I during the pa$l three years, a special class of compounds, called polychlorinated biphenyls (pcb's), has claimed the atlention of ecologists and pesticide analysts in this country. These compounds were not discovered in the environment until 1966 in Swe den and 1967 in the U.S., despile the fact that they have been available com mercially for 40 years. Interest in pcb's has arisen because they are frequently found in fish, bird, water, sediment, and other environmental samples when such samples are examined for chlori nated pesticide residues. That a wide varieiy of samples containing pcb's has been collected from England, Scandi navia, The Netherlands, Antarctica, CiMttr.i1 4mericii. and many different of tlio U.S. makes them truly ubiouitmis pollutanls. Polychlorohiphenyls are made by subsisting chlorine atoms for one or more of the hydrogen atoms at the The Monsanto Co. staled recently in a letter to Congressman William F. Ryan of New York that as of August 30, it would no longer sell pen's to 1 customers for use In general plasticiser operations where disposal of the endproduets cannot he eontroUed. After , some lag period--the lime It takes to eventually dispose of (he produets made from pen's and currently in processor's Inventories--the quantity of Pen's getting Into the environment may he substantially reduced. If Monsanto's former customers look for PCS substitutes, rather than purchasing Pen's from manufacturers In Japan and Europe, the projected decrease could become a reality. Carl G. Gustafson numbered positions of the biphenyl structure. Aroclor. pcb's arc also manufactured in Europe and Japan, under trade names such as Pbcnochlor and Clophen, The various Aroclors are dif ferentiated by a four-digit number, with the last two digits indicating the percentage of chlorine in Ihe mixture. In the process of replacing hydrogen atoms with chlorine atoms, a Urge number of substitution combinations arise. For example, three monochlorobipheny! isomers are possible, 12 dichlorobiphenyl isomen, 21 trichlorobiphcnyl isomers, and ao on. Theoreti cally, 210 compounds can be prepared by this substitution process; a typical example would be 2.4,h,2 4 pema- chlorobiphenyl. Whenever aromatic hydrocarbons such as biphenyls are chlorinated, the product is a mixture of compounds, In cluding isomers. It is quite difficult to synthesize single, specific chloro biphenyl compounds in the laboratory unless involved procedures are em ployed. Consequently few of ihe indi vidual compounds have been prepared in the pure form for study. In (he commercial process for pcb manufacture, biphenyl is chlorinated with anhydrous chlorine in tall cy lindrical towers with either iron filings or ferric chloride as the catalyst. The by-product b hydrogen chloride; the product is a mixture of several pcb's. The degree of chlorination Is deter mined by measuring the specific gravity of the mixture or, when the product is more viscous, the ball-and-ring soft ening-point test is used. The whole pro cess takes from 12 to 36 hours. In the U.S,, the sole manufacturer of pcb's is the Monsanto Co., which markets them under the trade name Properties The three most important physical properties of the pcb's are low vapor pressures (they have high boiling points), low water solubility, and high dielectric constants. They are mis cible with most organic solvents and compatible with many types of poly mers. Although some individual polychlorobiphenyl compounds are crys talline, Ihe Aroclor mixtures are either liquids or resins. The chemical properties that make pcs'i desirable industrial materials are their excellent thermal slability, their strong resistance to both acidic and basic hydrolysis, and their general In ertness. They are quite resistant to oxidation. Monsanto reports, in a tech nical bulletin on PCB'a, that they can be heated to 140 C. under 260 p.s.i. of oxygen pressure "without showing any evidence of oxidation u judged by de velopment of acidity or formation of aludge." The physiological properties of the rce'i make (hem potentially significant contaminants of the environment. For any pollutant, two factors are involved: acute toxicity, which si immediately evident because of a high death rate or other maiming effect; and chronic tox icity, which is the result of a slow ac cumulation of the poisoa in the body and is a subletha! effect. Whenever acute toxicity is high, a pollutant will be readily recognized and appropriate remedial actions will be introduced. If, on the other hand, acute toxicity is low, 114 Ertflroruncr-Ul S<kocr A Tt<ivK>bty . FUR 004163 WATER PCB-SD0000071497 the physiological effect* will go un noticed until the chronic effect! make themvelvet evident. When this happens, tbc problem may b*ve advanced be yond immediate or eaiy correction. Aetna teilclty All itudiet of fee's in aoimali indi cate that acute toxicity is not a lignificnt factor. Their acute toxicides are on the order of those of other chlori nated aromatic compounds. Monsanto has sponsored two investigations of the acute (oxicitica of Aroclor mix tures. In the first, at the Kettering Laboratory at the University of Cin cinnati, Dr. J. F. Treon and his co workers investigated the toxicity of Aroclor vapors for guinea pigi, mice, rabbits, and rats. All animals aurvived a 24-day expt^ure to 0.83 p.p.m. of Aroclor 1242 for 7 hours per day on 17 of thoae days. Even after more pro longed teals, there were no severe ef fects from Aroclor 1242. In (he second investigation, atill in process, three groups of beagles are fed Aroclor 1242, 1234, and 1260, respectively, at a rate of IOO p.p.m, in their diets. After three months no significant abnormalities . have been noted. Similar studies on fish have been per formed in several laboratories. Dr. Richard Schoettger of the Sport Fish eries and Wildlife Fish-Pesticide Re search Laboratory in Columbia. Mo., reports that 96 hour-TLs() toxicities of the Aroclors to trout range from 1.17 to 60 p.p.m. Compared to DDT, whose 96 hour-TLj,, toxicity is 0.002 to 0.009 p.p.m. for trout, the rca's have a rela tively low acute toxicity. With the more aensitive bluegill, the 96 hour-TL|0 for Aroclor 1248 is 0.278 p.p.m., while that of oor is 0.008 p.p.m, Aroclor tox-_ icities appear to be inversely propor tional to the chlorine content of the mixture. Shellfish, oysters, and shrimp are more sensitive to pea's. Dr. Tom Duke, at the Bureau of Commercial Fisheries Pesticide Field Station, re ports 100% mortality of juvenile pink shrimp exposed to 0,10 p.p.m. of Aro clor 1254 in water for 48 hours, This concentration of Aroclor 1254 will cause a 100% decrease In shell growth of oysters after 96 hours. To achieve the same effects with dot in these ex periments, only 0.0006 p.p.m. and 0.01 p.p.m., respectively, were required. There is very little evidence that pci's art toxic to insects. Studies to date show that they are less toxic than dieldrin or dot. Aj with fish, their tox icity appears to be Inversely propor tional to the chlorine content of the mixture. Based on the above data, it is un derstandable why the polychiorobiphenyls, commercially available for 40 yean, have only recently attracted attention as toxic environmental con taminant!. CHrente taxlelty The chronic toxicides of pci's pre sent i more disturbing situation; several chronic effects have been observed. It was discovered, quite by accident, that pci'i have a toxic effect on chickens. Professor E. L'. McCune and his co workers at the University of Missouri found their chickens dying after they were placed in a feeding house, parts of which had been freshly painted with an epoxy paint. Careful Investigation revealed that the toxic factor wax Aro clor 1242, a binder in the paint. When Aroclor 1242 was fed to the chicks it produced the tame characteristic effects as chick edema factor. McCune re ported: "Gross pathology included hydroperictrdium, hydroperitoaium, en larged heart, liver, and kidneys, and hemorrhage of internal organs. Mi croscopically the kidneys shenrad marked tubular dilation and curnerot* casts." Another chronic effect of pea's h related in wildfowl. The accumulation of high concentrations of chlorinated hydrocarbons in birds resulted in dis ruption of normal breeding behavior and in the formation of tbin-iLeiled eggs. A dramatic example of this effect hu been observed in the case of the brown pelican. On the Anacapa Islands off the California coast, no young were hatched last year from 300 pairs of nesting birds. The shells of moat eggs laid were so thin that a dent occurred when the egg was picked up. . There are two possible causes for the laying of thin-shelled eggs by wild fowl, One is a low calcium reserve in the bird; the other is the inability of the bird to deliver the needed calcium to iu oviduct, where tbe eggshell is forming. The calcium level in the avian biosyitem and the calcium reserve in the aecondary bone structure or medul lary bone, found only In female birda when they are breeding, are controlled by the hormone estrogen. A high es trogen level it associated with the for mation cf thia calcium reserve. Chlo rinated hydrocarbons, *uch as dot. WATER PCB-SD0000071498 chlordane, dieldrin, and rca's, activate enzyme* in the liver which tramform estrogen into a more water-soluble compound that it readily eliminated from the bird's body. This means that when estrogen levels are low, calcium reserves will also be low, and there fore very little calcium will be avail able for strong eggshell production. Dieldrin and pea's are more effective than dot in this type of enzyme-induc tion activity. Aroclor'1262 has an es tradiol degrading potential four to five times that of p,p'-doe or technical grade ddt. The ability of the female bird to deliver calcium to her oviduct during the last 20 hours, when the eggshell is being formed, is related to the func tioning of the enzyme carbonic an- hydrasc. When birds that have ex hibited the ability to lay normal eggs are injected with a metabolite of dot (tinr.) just prior to the formation of the eggshell, they will lay thin-shellcd eggs. This Indicates that ddt also in hibits the activity of carbonic anhy- drase, the enzyme that controls the flow of calcium from the blood stream of the bird into its oviduct. Since dieldrin seems to have no effect on carbonic anhydrase, we may assume that neither do the pcb's. How ever, these compounds delay breeding time significantly. Many ornithologists feel Ih.'it late breeding has a stronger influence on the reduction of bird populations than does the laying of thin-shellcd eggs. If this is true, pcb's arc a more potent threat than dot to our declining bird populations, es pecially for predatory birds that ac cumulate fairly high levels of pcb's be cause they eat smaller animals that al ready have concentrated pcb's in their own tissues. Other investigator* have .produced evidence to show that pcb's are simi lar to dot in their activity. Dr. Joseph Street at Utah State University- has thown that when pcb's accumulate in the liver, they induce microsomal en zyme activity by bringing about more rapid metabolism of drugs, insecticides, and other foreign compounds. He fed rats a diet containing 50 p.p.m. of Aroclor 1254 or Aroclor 1260. After 10 days on this diet, the test animals w?re administered hexobarbitol at a dose of 100 p.p.m. to induce sleep. In comparison with a control group, the sleeping time for these rats was reduced by 65 to 80%. Street also found that Aroclor, when fed at the same level, will reduce dieldrin stor age in adipose tissue by 90 to 95%; in crease aniline oxidation by 200 to 300%; and increase epn detoxication by 430 to 470%. In addition, the pcb's cause activation of organothiophosphate compounds, which adversely af fect the system. This latter effect coun terbalances the detoxification of diel drin. Normally, when a substrate activates an enzyme, it is converted to a watersoluble form that will be eliminated from the system; however, this is not the case with pcb's. Because they re main in the system for prolonged pe riods of time, their enzyme induction activity it always present. In this way the normal concentration of Important body chemicals may be lowered to the point of bringing about malfunctions in the system. For example, Street be lieves that the pcb's bring about steroid degradation, which can lead to altered endocrine relationships. The chronic toxicity to man is m follows: Like the chlorinated naphthalenes, the chlorinated diphenyls have two distinct action* on the body, .namely, a skin effect and a toxic action on the liver. Tbe lesion produced In the liver is an acute yellow atrophy. This hepalo-toxic action of the chlorinated di phenyls appean to be increased if there Is exposure to carbon tetrachloride at the same time. The higher the chlorine content of the diphenyl compound, the more toxic it is liable to be. Oxides of Chlorinated diphenyls are more 114 EJirtrocmwnUl Sdoe* A Tachoolojy FUR 004165 WATER PCB-SD0000071499 toxic than the unoxidized ma terials. The skin lesion is known as chloracne, and consists of small pimples and dark pigmentation of the exposed areas, initially. Later, comedones and pustules develop. In persons who have suffered systemic intoxication, the usual signs and symptoms arc nausea, vomiting, loss of weight, jaundice, edema, and abdominal pain. Where the liver damage has been severe, the patient may pass into com,i and die. Sn\. S'. Irving. "Dangerous Prop erties of Industrial Materials," 3rd cd.. I 'tin Noslrnnd-fteinhold, New York. I96K, 1 he ubiquity of rcVs is rclaled to the wide speclrum of applications that have been found for them. The largest single use of pen's is related to their electrical properties--as coolanl-insulotion fluids in transformers. For this purpose the Aroclors arc also sold under such trade names as Chlorcxlo! (Allis-Chalmcrs Mfg. Co.). Dykanol (Federal Pacific Electric Co.), Incrtcen (Wcslinghouse Electric Co.), Nofiamoi (Wagner Electric C'o.). Pyranol (General Electric Co.), and Thcrmi, nol (Monsanto Co.). Other uses of pen's include formula tion into ballasts for fluorescent fix tures: impregnation of cotton and as bestos fur braided Insulation of clec- tneal wiring; a plasticizer in wire and cable coatings; capacitors and askarelt\pe transformers: and plasticizers of \inyl ch'oridc polymer films. Because of Iheir thermal stability and fire resistanee. the pea's also find application in high-pressure hydraulic fluids, spe cialized luhricanls and gaskcl scalers, heal transfer agents, and machine tool culling oils. Miscellaneous uses in clude: formulation into some epoxy paints: prolcclivc coatings for wood, metal, and concrete; adhesives: and in carbonless reproducing piper. One of the primary manufacturers of carbon less reproducing paper also sells Aro clors in an encapsulated form. Generally (he kinds of applications described above mean that the pen's will he in many types of products that eventually find their way to the domes tic market. When used in manufacture of ballasts for fluorescent fixtures (hey w-ill be found in kitchens, bathrooms, stores; and offices throughout the coun try. Wherever office forms arc used (hat do not use carbon paper, one may find pen's formulated into the micro capsules of dye that comprise the re Cat chromatogram A is of a standard pesliclde mixture, G it typical of Aroclor 1254, and A + B Is the chromatogram of a 50 : 50 mixture of both. The concentration of Aroclor 1254'ls approximately 10 times those of the petticldet In A, hence It It un derstandable why PCB'a were not readily recognized In pesticide chromatograms. Gat chromatograph (Packard 7620) conditions: gis flow 60 ml./mln. nitrogen; tem peratures--oven, 210* C., inlet. 230* C., detector. 218* C.: Nr electron capture detector; 5' x glass column packed with 8'i SE-30 on Chromotorb Q 80-90 mesh. ' producing layer of the business form, pen's have also been found on the transparent receipts used in credit card charge forms. As plasticizers they can be expected to appear in many con sumer plastics. Since Che chronic lo.xiciiics are so significant, it becomes important to know just how extensively the pea's are distributed in the ecosystem, and just how they find their woy into the environment. Rainwater in En gland, brown seals off (he coast of Scotland, white-tailed eagles in Swe den, cod in the Bailie Sea, mussels in The Netherlands, adelie penguin eggs in the Antarctica, brown pelican eggs in Panama, Arctic terns, shrimp in Florida, river water in Japan, waters in the Great Lakes, human hair, and human adipose tissue--samples of a' these have been found to contain Pen':.. Vetimw 4 10, OtloWr 1970 117 I WATER PCB-SD0000071500 thus making them a else of widely dispersed pollutants. RMdlly ebsarfead The properties of rcs's that make (hem induitrially uaeful are the tame properties that cauae them to persist in the environment. These in clude thermal stability, resistance to oxidation and hydrolysis, solubility in a wide range of organic solvents, water insolubility, high dielectric constant, and compatibility with many types of macromoleculei. Their resistance to oxidation and hydrolysis also makes pcb's more stable and persistent than dot. Consequently, they could even tually accumulate to a higher concen tration than ddt, especially if the use of dot is sharply curtailed in the U.S. The solubility of fee's in nonpolar solvents explains why they are readily absorbed into fatty tissue and into the liver. Their resistance to oxidation or other types of chemical degradation explains their persistence in the en vironment and accumulation in animal tissue. The latter effect is enhanced both by their insolubility in water and solubility in organic solvents. Their chemical inertness and resistance to metabolism account for their low acute toxicity. But as they slowly build up in a living system their con centration approaches toxicity levels, at which point chronic effects make themselves evident. It has been established that fish-eat ing birds will accumulate large concern tiations of pen's, as in the case of the white-tailed eagle, which hat been way as they accumulate dot and other chlorinated pesticides. Because of the low solubility of pcb's in water, when a solution or dispersion of them is discharged into a river or lake, they will accumulate on the sedi ment in relatively high concentrations. Subsequently, they will redissolve very found to have as much as 14,000 p.p.m. of pcr'i. Peregrine falcons, taken off the coast of California, were found to have as much as 2000 p.p.m. in their lipid tissue. When shrimp were exposed to 10 p.p.b. of Aroclor 1254 for 48 slowly in the water as conditions change. Therefore, It will usually take a long time to flush out a contaminated area. Accidental occurrence hours, they accumulated 1300 p.p.b. of The reason that pcb's have not been pcb's, which represents a 130-fold con found In the ecosystem as extensively centration Jn a very short time. Oytlers, as ddt, and are not present in environ exposed to an identical concentration mental samples at as high a concen of Aroclor 1254 for 96 hours and then tration as dot, Is that pcb's find their placed in PCB-free water for four days, way into the environment accidentally. still had a concentration of 33,000 dot is deliberately spread because this p.p.b. of pcb's, which constitutes a is the only way its insecticidal proper 3300-fold concentration. This means ties can be utilized, pcb's are not in that even though the concentrations of tended to get into the environment, but pcb's are in the ptrU-pcr-blllion range they do because their unique chemical in the environment, their high lipid properties prevent them from being de solubility causes them to collect in fatty stroyed by our usual waste dhpottl tissues of lower animals and marine methods. Thus, they inadvertently es life. Therefore, species at the top of a cape and become widely dispersed. food chain will also accumulate pcb's In Sweden, where the use of dot In their bodies, particularly in their has been'banned, and where the main lipid tissue and liver, in much the same power source is hydroelectric, investi gators find that the concentration of pen's in the environment is as high as that of ddt. There are several ways by which pcb's get into the ecosystem. One of these is by incineration. Products con taining pcb's, such as carbonless re producing paper in business forms, plastics (especially polymer film and sheeting that contain pcb's as plasti cizers), spent ballasts from fluorescent light fixtures, and objects coated with pci-formulated coatings, all find their way to the city dump or incinerator for burning. The pcb's do not bum but are vaporized, They are then carried inlo the atmosphere, where they collect on particulate matter and are subse quently returned to the surface of the earth, into the rivers, lakes, and oceans. In this way they become widely dis tributed throughout the global environ ment. Another source Is probably land run-off from industrial wastes and dumps. A third source is the point of manufacture and the plants where pea's are processed inlo other products. They can escape through the plant ven tilation and exhaust systems into the atmosphere and through its waste treat ment system into sewers or directly into wsterwayt. Ill Earlrewaanlal Sdaoc* A Taebootosy FUR 004167 WATER PCB-SD0000071501 j( it inleretting lo note that the inci dence of pcb's in environmental sam ples b highest in industrialized and ur column chromatography to separate rcB'i from chlorinated pesticides. At a recent meeting, sponsored by the What ia the fate of pcb's in ural waters? More needs to be kn of their partition coefficients" bciv banized areas. Birda whose primary habitat is the San Francisco Bay area Pvvqa's National Water Quality Lab oratory, Duluth, Minn., a general pro bottom sediments and water. Thi vital if we are to estimate bow loc have a larger concentration of pcb's cedure was recommended for separa will lake for a river bed to clean it per uni! of body weight than those lo tion of pcb'i from pesticides. In this of contamination. It will also be us. cated in Baja, Calif., which is com procedure for biosamples, the sample when assessing the effects of pcb's pletely rural. Aquatic life in the Archi is extracted with hexane as in regular marine life that feed on the bottomr pelago of Stockholm, the most indus pesticide analysis. It is then partitioned lakes, riven, and estuaries. We tho trialized area of Sweden, were found with acetonitrile to remove fats, the also learn more about pcb solubility to have a higher concentration of PCS'* cleaned-up extract is passed through a water of various ionic strengths. than fish samples taken from the west Fluoritil column and then through a Are present waste treatment i ern const of Sweden, a less developed silicic acid column. Finally, the sample terns adequate to handle pcb's? Do sj area. Sediment samples taken from is analyzed by gas chromatography, cial measures need to be taken wh southern portions of Lake Michigan with a chloride-specific detector. In this pcb's are part of the waste effluent 1 have n higher concentration of pcb's way the pesticides are retained on the ing treated? than those from other parts of (he lake. silicic acid column for later elution and By trying to get some of these a Monsanto states that until a recent identification.. swers now, we may find that we are change in marketing policy (see inset, a position to control the escape > page 8 5 4), sales of Aroclors were in creasing ut the rate of 8% per year. Research nsaefs pcb's into the environment before at ditional damage it done. So frequent!' While this increase docs not seem sig To assess fully the significance of action js taken only after it is evidet nificant, it may be important if the in pcb's as environmental pollutants, ad that massive damage has resulted frot creased consumption was in consumer ditional research is needed. No one a particular pollutant. In the case c products and thus would find their way really knows the extent of the chronic the pcb's we may have an opportune into our normal solid waste disposal effects of these chlorinated hydrocar to resolve the situation before tha systems. Such an occurrence would bons, Some problems (hat need to be happens. mean a definite increase of pen residues in Ihe environment, and therefore a considered are: Although pcb's are known to ac , Additional Reading marked increase in their chronic tox icity effects. CMaction ! rrn's were not discovered in environ mental samples until very recently for cumulate in human organs we do not know at wbal concentration they will begin to exhibit toxic effects. Will these chronic effects be similar to those shown in animals--microsomal en zyme activity, calcium melabolism in Hubbard. H. L., "Chlorinated Biphenyt and Related Compounds," Encyclo pedia of Chemical Technology, 2nd ed,, 5, tntersclence Publ., Now York, N.Y.. 1964, pp. 289-298. Reynolds, L. M,, Bull. Environ. Confam. Toxicol. 4, 128 (1969). Risebrough, R. N., ef. af., Nature 220 several reasons. First, as indicated hibition, and o on? What arc other (1968). above, they have nol been deliberately possible chronic effects? distributed about the ecosystem. Sec Which of the many res com ondly, because of their relatively low pounds in the commercially available aculc toxicitics, their presence was not mixtures are responsible for their tox immediately evident. Finally, they are icity? Can commercial pcb mixtures be difficult to detect analytically. modified to eliminate the toxic com The Pelt's were first delected as in ponents? Pure samples are required to terfering peaks in the gas chromato answer these questions, At the present graphic analysis (gc) of environmental time work is continuing at the fwqa's samples being analyzed for chlorinated - Southeast Water Laboratory to sep pesticide residues. When pcb's arc pres arate each of (he Aroclor mixtures Into ent in a sample they give a pattern of its many components, and to identify several cc peaks, whose retention limes each component. arc similar lo those of dieldrin, ddt, We need lo know all the uses for twn, aldrin, and hcptachlor oxide. Be cause the peaks were nol large or sharp, investigators tended to ignore them until S. Jensen, in Sweden, and R. Rischrough, at the University of California at Berkeley, identified them as corresponding to common constitu ents of environmental samples being the pcb's. What is the annual produc tion of pcb's? Our knowledge of these facts is limited and needs to be ex panded. These facts should be known if we are to accurately determine how they get into the environment, and take steps to prevent further environmental contamination by them. Carl G. Gustafson, chairman ot the Department o! Chemistry o/ King's College, Brlarcliff Manor, N.Y., re ceived a Ph.D. In organic chemistry from the University of Delaware In 19S7. During the 1969-70 academic year, he war on leave at the fwqa Southeast Water Laboratory In Athens, analysed for persistent pesticides. In view of the complexity of the Ca,, where he studied trace organic The problem of the interferences of isolation and accurate quantitative analysis In waste effluents. As a mem pen's with (he analysis of other chlori analysis of pcb's in chlorinated resi ber of the National Water Contami nated pesticides has been largely over dues, a straightforward, unambiguous nants Characterization Research Pro come by prior treatment of the sam ple. Several investigators have used measurement of them needs to be de veloped. gram, he worked with pcb's and pulp and paper mill effluents. * VotumA S.TNaniWr 10, Octobw 1970 814 r WATER PCB-SD0000071502 MITSUBISHI MONSANTO CHRMICAI. COMPANY FhOM LOCATION 1 Tokyo OAT t SU<JCCT 'March 22, 1972 1 PCB IN JAPAN hcfikcncc l TO ! Mr. P. G. Benignus St. Louis (B2SC) ce- Messrs. J. R. Durland - Tokyo W. R. Corey - St. Louis H. S. Berger - " T, L. Gossage - " C. Baton -" J. Mason - Brussels P. J. A. Marsh - " W. R. Richard - St. Louis R. H. Munch... - . " W. B. Papageorge- " C. R. Coleman - Newport Dear Paul: I am pleased to answer your, questions in your letter of March 20, 1972. The Ministry of International Trade and Industry (MITI) issued notice yesterday to almost every industrial association concerned, as summarized in the following: a. No electrical machinery and equipment which . contain PCB must be manufactured after Sep. 1, 1972. b. No heat exchange equipment must be produced after July 1, 1972 which use PCB as a transfer medium. c. Exceptions to the above are those which are sold to the specific users and which can be returned after use to the producers or manu facturers for PCB disposal. They must periodically report to the ministry how PCB Is used, shipped, stored, recovered, returned and disposed, including machinery, in addition to the quantity dealt with and so and so forth. Every user of PCB-containing machinery and equipment will have to be recorded and registered in the official list to insure strict supervision in the future. d. Import of such machinery and equipment will be possible only if permission is granted by the Government, after September 1, 1972. e. PCB containing machinery and equipment already in use must be identified and reported to the authorities so that the disposal of PCB is to be made complete. '' FUR 004169 WATER PCB-SD0000071503 MITSUBISHI MONSANTO C1IKM1CAI. COMPANY You will understand that the above action is not the total ban of PCB usage. However, who can meet such stringent regulatory requirements to continue using PCB, other than non-civil organisations? __ We called the MITI yesterday to learn the following: 1. The MITI foresee by the action taken-yesterday the use of PCB fluid will be limited in the near future to the transformers used by the Japan National Railroad and certain electronic parts in missiles belonging to the Defense Ministry, in addition to the high voltage electro-furnace ^.capacitors as a ' ' possibility. 2. Thermal transfer systems with PCB will sooner or later undergo change in fluid or the whole line will have to discontinue operation. 3. Kaneka agreed to follow the recommendation by the MITI to discontinue the production of PCB, probably after September of this year. 4. Those who are able and obliged to use PCB will have to import PCB, possibly from Bayer, with permission from the Government. You rightly pointed out that the actions being taken by the Japanese Government appear out of line from the rest of the world today. I can agree to Mr. Terasaki's statement in this respect that the folks go all the way when they decide to do something in this country. I think the latest happening sensationally moved the Government to this direction - the analysis of mothers' milk in Osaka showed PCB level of 0.7 to 0.1 PPM, as against the FDA's 0.2 maximum level for cows' milk. In the Diet committee the.JVelf are Minister was at a loss when asked if or not babies can drink milk with 0.7 PPM PCB without any danger to their healthy growth. You might recall Yodo River flows from Lake Biwa to Osaka Bay. Two capacitor plants are located by the Lake-Nichicon's and Nisshin Electric's. Samples of the soil were taken from the vicinity of Nichicon to run analysis of PCB with an unfortunate result showing 1,000 PPM PCBI FUR 004170 WATER PCB-SD0000071504 MITSUIllSl 11 MONSANTO CHliMICAI. COMI'ANV People associated the contamination of the soil with the mothers' milk case. Thus Niehicon was forced to announce last week that they plan to discontinue production of PCB capacitors, after coming September. _ Today the world seems to be ruled by feeling and not reason. The pressure against PCB usage is far from logical. It is quite emotional and at the same time political, It was this pressure that led Kaneka to the discontinuation. . It has not been 100% confirmed but I think you may rest , assured Kaneka will not go after overseas markets after the fall of this year, although they are exporting substantially today. . The grand funeral of PCB in Japan is close at hand. What will replace.PCB in the dielectric markets is yet known to nobody exactly. We only are aware a number of products ranging from silicone to poly isobutane, wax and DOP are .competing. The strongest candidate on the longer term basis seems to me entirely new systems after technological innovation. I wish you good luck. TK/ym T. Katayama P.S. .. Just before I had this letter typed, Kaneka announced that they decided to discontinue the production of Kaneclor by the end of June, which was confirmed by myself today with Kaneka. Also Nichikon was forced to terminate their production of PCB capacitors at the end of April. FUR 004171 WATER PCB-SD0000071505 r. * Chairman: Mr. W. B. Papageorge Manager, Product Acceptability Monsanto Industrial Chemicals Co Objective; The purpose of the meeting was to share information, experiences and impressions to help each of the participating companies in taking appropriate actions which are mutually supportive and effective in persuading the Administration of EPA to modify the proposed PCB Effluent Standard, fur 004497 WATER PCB-SD0000071506 PARTICIPANTS PCB STANDARDS MEETING February 28, 1974 CERTIFIED BALLAST MANUFACTURERS Mr. N. R. Clark Universal Manufacturing Co E.I.A Mr.. Arnold S. Doty Dr. E. M. Moore Mr. Rudy Carlson P. R. Mallory & Co., Inc Electrical Utilities Co. Electrical Utilities Co. GENERAL ELECTRIC COMPANY Mr. James S. Nelson Mr. Stuart Richel Dr. Edward L. Simons 'JARD COMPANY, INC. . Mr. Richard Rollins ( s NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION (NEMA) Mr; A. M. Salazar WESTINGHOUSE CORPORATION Mr. H. Sheppard Mr. N. H. Smith fur 004498 WATER PCB-SD0000071507 MINUTES OF PCB EFFLUENT STANDARDS MEETING 1. Mr, Howard S. Bergen, Jr., Director, Specialty Products Business Group of Monsanto Industrial Chemicals Company, welcomed the participants. ' 2. Introduction - W. B. Papageorge ' Mr.. Papageorge summarized the timetable past and future on toxic pollutants: July 6, 1973 - Toxic Pollutants list published September 7, 1973 - Final toxic pollutants list pub . lished including PCBs and 8 other . chemical classes (e.g. cyanide, mercury, DDT, cadmium, etc.) December 27, 1973 - Proposed Effluent Standards published January 18, 1974 - Filing date for status as participant at proposed EPA Hear ing on Standards January 25, 1974 - (i) Prehearing Conference with EPA (il) NEMA, Monsanto, O.E. and Westinghouse recognized as participants. (ill) A total of 38 objector^ ex pressed an interest. They represented industry or trade associations with the exception of the Michigan Water Research Commission and two powerful environmental groups (Environmental Defense Fund and National Resources Defense Council). (iv) Presiding officer made it clear that Hearings will be strictly for cross-examination ot participants1 testimonies in affidavit form only. FUR 004501 WATER PCB-SD0000071508 -2- March 15, 1974 Written testimony by 38 objectors to be submitted In affidavit form. April 8, 1974 . - Hearings open for cross-examination and rebuttal evidence. CH~/Cd/Hg - : first three. PCBs are 7th (third from last). Mid-May, 1974 - Hearings completed. (Evenings/week ends may be UBed.) June 25, 1974 Final standards published - effective In one year. "It should be noted that others who are affected by these standards can still comment by March 25 to: : . ', .. Dr. C. Hugh Thompson, Chairman-Hazardous and Toxic Substances Regulation Task Force Office of Water Protection Agency* ' Environmental Protection Agency Washington D. C. 20460 ..Industry representatives still wishing to comment and who need more background information can contact any of the industry -..participants (see attached list) or Mr. W. B. Papageorge of Monsanto (314-694-4051). -.'Mr, Rlchel (G.E.): 1' (i) ' Made'a plea for greater Industry participation. Comments can still be made up to March 25 with sound excuse for tardiness. (il) EPA at January 25 prehearing Conference were reluctant to expose themselves to cross-examinationDr. Hugh Thompson to be available for cross-examination at Hearings. (ill) Many objectors had common interest (e.g. environmentalists). EPA suggested a common counsel for this group. (iv) On each of first 3 pollutants, EPA would offer 2 witnesses. Mr. Doty (P.R. Mallory) aBked about bearing of economic factors on standards. Mr, Rlchel (O.E.) stated: (1) Law,is clear-economic factors are not relevant in establishing standards. (ll) EPA is somewhat of a split personality on this. The FUR 004502 WATER PCB-SD0000071509 -4- "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which Is chlorinated and which have been Bhown to persist and rapidly bioaccumulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gaB chromatographic retention times greater than 54, relative to p, p-DDE r 100, under the standard con-..---ditionB recommended in the EPA PCB test method." Mr. Sheppard (WeBtlnghouse) said Monsanto's proposed definition was relevant to persistence but was it relevant for standards directed toward toxic materials? Are persistent materials non toxic? Mr. Wright (Monsanto) stated the proposed effluent standard had two.parts: : (i) acute limits directed to toxicity of materials . and specifically limits PCB concentrations on that basis. . (ii) daily load in effluent - based solely on bio . magnification (relevant to persistence). .Dr. Simons (G.E.) pointed out that section 307-A of the proposed standard refers to persistence as being a critical factor to be considered.. . Dr. Tucker (Monsanto) stated we were badly hurt if all PCBs are regarded as persistent and if biomagnification factors of 200,000are used. Researchers other than Monsanto have found bacterial degradation of PCBs and that PCBs have been found to undergo metabolism in both aviarian and mammalian animals. * s Mr, Nelson (Q.E.) aBked if proposed PCB definition would exclude Aroclor 1016. Dr. Tucker (Monsanto) Aroclor 1016 would be excluded for the most part (9B.9^> is lower than pentachloroblphenyl). Aroclor 1242 would be excluded to 65^ or better. Aroclor 1254 however would not be excluded, Mri Papageorge (Monsanto) pointed out that of the factors listed as being critical, in determining which pollutants made the EPA list of 9/7/73 only biomagnification appeared relevant to PCBs. Dr. Simons (Q.E.) agreed. FUR 004504 WATER PCB-SD0000071510 -5- Mr. Wright (Monsanto) Btated that an acute toxicological level is defined in the EPA Basie Sr-Burpose document as ^ 10 ppm (96 hour LC-50). He also believes that differences in toxicity among PCBs are minor until chlorinated as high as Aroclor 1260. Mr. NelBon (q.E.) stated that words should be used in a diecourse on definition to properly screen us on acute toxicity. '' In reference to a comment that Aroclor 1254 would not be excluded by the proposed definition. Dr. Tucker (Monsanto) offered the opinion that transformer fluids were easier to re cover than capacitors. (b) Analytical Methodology Dr. Tucker (Monsanto) stated the EPA's proposed method for PCB analysis was being submitted to ASTM. He thought the method was well written and capable of detection to ppt (parts per trillion) but It was untried and the quantitative accuracy is in question. The method waB not submitted for round-robin testing before EPA adopted it. Monsanto has found that by spiking distilled water with 500,000 ppt or 500 ppb of PCBs we get values for PCB that vary by dt 55^* The EPA, however, claims a capability of detecting absolute values at 50 ppt. The EPA method ignores interfering substances. Mr. Clark (Universal Manufacturing) said that with a proposed upper limit for PCB discharge of 0.0648 lb./day the sensitivity of the analytical method would vary "all over the lot" depending on the size of the water "reservoir" into which the PCBs dis charge . Mr. Sheppard (Westlnghouse) commented that if the analytical techniques on determining PCB levels are so difficult, how valid are the determination of toxic values for PCBs. 1 Mr. Clark (Universal Manufacturing) asked if analytical techniques differentiate between different chlorine levels. Dr. Tucker (Monsanto) said it would depend on the PCB mixture'll Aroclor 1242 could probably be identified quantitatively in a mixture with Aroclor 1260 but addition of Aroclor 1254 to the mixture would prevent identification because Aroclor 1254 contains PCB homologs that overlap both Aroclor 12^2 and 1260. Dr. Munch (Monsanto)said that the proposed EPA method does not use high resolution and hence handicaps identification of individual peaks. Dr. Simons (Q.E.) mentioned that after EPA Bet automotive emission standards (NIOX) the analytical methodology was found faulty and the standards were delayed. In this case, EPA is not- setting the effluent standard on analytical methodology but FUR 004505 WATER PCB-SD0000071511 6- - ; - on factors such as toxicity and persistence. The methodology is relevant In enforcement and monitoring. This then leads to the possible argument that the effluent standard Is correct and justified on the baBis of toxicology et al, but 1b not enforceable due to lack of an accurate method for absolute value deter- - mination of PCB discharge. T" Mr. Rlchel (Q.E.) pointed out that EPA won't buy an answer to that argument which seeks to raiBe the effluent standard to a level that can be accurately measured. Mr. Savage (Monsanto) felt Btrongly, however, that this dilemma needed to be in the record. Others agreed. . Dr. Tucker (Monsanto) said ASTM would hold a round-robin on the . EPA method and that Monsanto would participate. He will send ... the name of the ASTM contact to the participants so that they can decide if they want to Join the round-robin test. Mr. Sheppard (Westinghouse) said he was not prepared to accept that the proposed EPA.method for determining quantities and types ' of PCB in samples and animals was accurate enough so that toxic v limits could be defined on the basis of PCB levels of question . able accuracy. Toxicity . > ' " v Mr. Hosmer (Monsanto) stated that the original EPA publication on Water Quality Criteria came from a publication by McKee and 'Wolfe for the State of California. The McKee/Wolfe volume was well.done and EPA did not change much of it. There is now a new 2-volume EPA edition extracted from the work of 10 committees of the National Academy of Sciences. The. toxicity of PCBs is related to salmon egg studies and Monsanto doubtB the validity of this. Monsanto has made their ^feelings known to Dr. Thompson of EPA but he thought the : - - criteria were sound. Since then Russell Train`has been sued .. . T* ^ by NRDC and other groups on the grounds that the toxio pollutants list is hot long enough and the proposed standards are too len ient. .. ' ,. Mr. Wright (Monsanto) went through the rationale used by EPA in arriving at a PCB discharge maximum of 0.0648 lb./day. He also showed how the standard could be changed and yet be consistent with published data on PCBs. Details follow. - (a) FDA set arbritary proposed tolerances: 5 ppm in fish for human consumption 5 ppm in components for animal feed ' 0.5 ppm in complete animal feed FUR 004506 WATER PCB-SD0000071512 -7- (b) Monsanto would not disagree with these tolerances. (c) PDA has presented - acute toxicity limits (point sources) . - chronic toxicity limits (dally . load) Acute toxicity limits: 96 hour LC-50 studies for PCBs show: ' ". '~'280 ppb in fresh water (bluegill) .^10 ppb in coastal or seawater (pink shrimp/oysters) Published data based on materials leaving an outlet and going into a'body of water. Acute limltB have no direct relation to chronic limits. Chronic toxicity limits: The EPA equation is: Chronic limit X water flow rate X safety factor * gm/day ,, discharge In Marine organisms the chronic limit is set as " 3S^lr = O'016? w* In fresh water the chronic limit has been determined by using `0.5 ppm as toxic limit for salmon eggs and a 200,000 bio"magnification factor. This gives a chronic limit of : " . 200,000 = Q---PPb > The blomagnification level of 200,000 is based -on unpublished ..data from Stalling & Meyer (Pish Pesticide Lab, U. S. Dept, of Interior, Colombia,^Mo.). Dr. Simons Said that in response to repeated requests by G.E. to the Columbia Lab the only reference they have been given is a Stalling & Meyer paper presented in Carolina in 1971 and which contains no mention of a 200,000 factor. Mr. Wright (Monsanto) stated he has seen only one literature reference to an accumulation factor of~200,000 and that was in the hepato pancreas of a pink shrimp. If the PCB level was calculated on the basis of the total shrimp then the accumulation factor was only 22,000. Other references give accumulation factors of 1000-75,000 for whole tissues of various fresh water organisms. Accordingly, Mr, Wright proposes that a blomagnification factor of 30.000 and not 2O0,O0Q be used. He also proposes""that we retain the chronic limit of 0.5 ppm wftfi- out debating the salmon egg issue. ^ FUR 004507 WATER PCB-SD0000071513 -8- This would lead to a discharge level for PCBs: g;5 ' 30.000 X 10,000 x (flow rate) . 0.5 X (safety factor) ' 5.4 = 0.459 lb./day (conversion Into lb./ day) - -V- ThlB compares to the proposed standard of 0.0648 lb./day,., , The safety factor comes from the EPA's Basis and Purpose document supporting the proposed effluent standards. It is supposed to take account of non-point sources of PCBs and 1b the same as 6 of the 9 toxic pollutants proposed for EPA standards. Monsanto's Medical Department feels this safety factor is arbitrary and confers no real toxicological benefit. If deleted, the revised Wright PCB discharge level would be 0.918 lb./day. ' One of the most critical parts of the discharge equation is the water flow rateT A significant number of dielectric PCB manufacturers have plants on rivers where the flow rate is under 100 cfs or 1$ of the EPA cut-off flow of 10,000 cfs. Several ..plants discharge into sewage plants which in turn have treated liquid flowing into rivers or streams with very low 'flow rates. For a river with 100 cfs flow the EPA maximum discharge would drop to 0.000648 lb./day or 0.162 lb. in a 250 :work-day year. Even a revised standard of O.9I8 lb./day at 10.000 cfs would only be O.OO918 lb./day at 100 cfs or 2.3 lb. 'per 250 work-day year. Clearly this is a staggering target to "nave, to meet. Mr. Doty (Mallory) pointed out that in the present language of the EPA standards municipal sewage Bystems are not considered point Bources. Mr..Richel (Q.E,) was of the opinion that where a plaht dis charged into a sewage system without treatment and hence into navigable waters the plant could have to comply" with effluent standards on toxic pollutants. . Mr. Papageorge (Monsanto) felt we should not be complacent and regard discharge'to sewage plants being the answer to problems. Mr. Hosmer (Monsanto) stated that 10,000 cfs represents the largest flow the EPA will consider on the grounds that all Industry would move to the lhrgeBt river. The opposite of that argument is that it .encourages Bmall plants on every Btreara in the country. Mri Sheppard (Westinghouse) raised the issue of sedimentation. Since it appears that all the experiments to establish toxic values were run without sediment effects being considered, the real-life values were questioned. PCBs attach themselves to sediment. Furthermore the sediment moves down river and so PCB would be dispersed from the point source. It was pointed out by Dr. Richard (Monsanto) that Aroclor 1254 is soluble In water up to 50 ppb ana that in time partitioning between sediment and FUR 004508 WATER PCB-SD0000071514 -9- water could take place. Mr. Wright (Monsanto) agreed that the discharge limits were extreme cases' In the absence of Bedlment considerations and this was worth study and Incorporation into arguments against the proposed leveIs~T : Dr. Simons (O.E.) queried whether we were correct in concen t rating our attacks on the criterion of toxic effects of mammals eating fish and ignoring the possible argument that fish per se must be protected. Mr. Wright (Monsanto) said the proposed standard says both. In salt water, standards are proposed that would protect the Bpecies that eat organisms containing PCB. In freBh water, if 0.5 ppm in salmon eggs correlates with <5 ppm in salmon then we are protecting salmon. He also said that the . 'chronic limits and biomagnification limits he was proposing would protect the species themselves. We should, however, beware of arguing for higher levels in fish because we could draw EPA and FDA into conflict. The FDA levels In food, fish etc., are temporary tolerances and any arguments against their validity could lead to a reduction In these tolerances. Mr. Savage (Monsanto) queried whether raising the level in organisms could cause possible danger to predators. Dr. Simons (G.E.) quoted from page 39 of the Basis & Purposes document which states that the body burdenB of birds and mammals should not increase over present levels. Page 51 of the same document cites a Nat. Acad. Scl. report which gives 2.0 ppm PCB a'B tolerable level in flesh of whole fish. 2.0 =0.1 ppm PCB ... 200,060 is given as tolerable level in water divided by a safety factor of 5 to give a maximum PCB concentration in water of 0.002 ppm. Thus EPA accepted 2 ppm PCB level in fish but got to water concentration of 0.002 ppm by using a high level of 200,000 for biomagnification and an arbitrary factor of 5. ** 1 If we. were to revise the proposed EPA standard by: .' N (i) using 2.0 ppm as chronic limit in fresh water species instead of 0.5 ppm; . (ii) substituting 30,000 instead of 200,000 for b.lomagnificatlon factor; and . (iii) ignoring safety factor of 0.5 then the maximum permissible discharge in lb. PCB per day would be: 2.0 -v 10,000 v 5.4 3.6 lb. FUR 004509 WATER PCB-SD0000071515 -10- For the plant situation on a river with a flow of only 100 cfs the discharge would be O.O36 Ib/day or 9*0 lb. per 250 work-day year. These levels are still far below the 5 lb./day given in A7IST~C-107. It is therefore apparent that other aspects of PCBs must be highlighted in order to get away from PCB discharge levels as low as even our "revised'' proposals. . Aspects to concentrate on are: (l) Definition of PCBs that.excludes biodegradable homologs. This could exclude 9C$ or better of Aroclor 1016 and 65^ " or better of Aroclor 1242. On that basis, discharge levels would be as follows: Stream Discharge TthTPcF e quivalent/day) PCB Type . Flow (cfs) . EPA Wright - Simons/Wright Any PCB Any .PCB Aroclor 161b Aroclor 1016 Aroclor 1246 Aroclor 1242 10,000 . 100 10,000 . 100 10,000 100 0.0648 0.000648 0.64B 0.00648 0.1/4 0.0019 O.918 0.00918 ~97TB 0.0918 2.75 0.027 3.6 O.O36 36.0 0.36 TO 0.10 (2) Try to change stream flows from the present value of the flow rate in cubic feet per second (cfs) expressed - as the probable low rate occurring during a~7 consecutive day period once in 10 years at UKe effluent ..point, : . If the average flow rate over a period of time (to be - agreed on) was used, the lowest, flow rate in the ' equation could conceivably be raised by a factor of 10 . from 100 to 1000. In the Simons/Wright version for a standard the Aroclor 1016 discharge could be raised to 3.6 lb./day at 1000 cfs flow and Aroclor 1242 to 1.0 lb./ day at 1000 cfB flow. (3) Magnitude of PCB Point-Sources It is possible that EPA and environmentalists are totally misinformed on the number of plants still using PCBs. " In the U.S. today there are: FUR 004510 WATER PCB-SD0000071516 -12- Proposed Effluent Standards Dr. Simona (q.E.) summarized the points he felt had to be dealt with in trying to change the proposed standard! 1. Higher persistence of higher PCBs versus alleged lower acute toxicity ' 2. Background levels of PCBs - - 3. Written testimony of participants and correlation -Toxicity EPA Basis & Purpose document (page 50) states that 96 hour LC-50 to fish cannot adequately measure toxicity of PCB. Where is time demarcation between acute and chronic. Chronic effects can be either lethal or non-lethal. Why are `PCBs on the list on toxic grounds? LD-50 for PCB is such that it is not considered toxic to humans. For protection of aquatic life the Hat. Aca. Sci. set a 96 hour LC-50 of 10 ppm or less. In proposing a definition for PCBs, Dr. Simons (Q.E.) felt we should .stress: (a) . lack of persistence of homologs below tetra' chlorobiphenyl. (b) chronic toxicity does not arise for the lower homologs because they are non-persistent. (c) ignore acute toxicity - no real differences between Aroclor 1016, 1242 and 1254.N Participants need to consider: Do we have the best definition? In the tentative EPA analytical method we should take note that in the table on p.3-22, the percentage of PCB was not controlled. -Mr. Carlson (E.U.C.) pointed out that in its present form the standard could saddle present PCB userB with all other dis continued uses. Dr. Richard (Monsanto) pointed out that FDA and Boxboard Manufacturer's Association had agreed on a protocol that protected recycle paper users from Just such a situation. Mr. Bergen (Monsanto) asked that copies be circulated to participants. FUR 004512 WATER PCB-SD0000071517 -13- We need to word our definitions to exclude residuals. Participants should exchange proposed drafts on wording re garding residuals by March 7 0. E. stated we should not approach the hearing on the basis 'that things can't be done. Rather hake the proposed standard and polnt^out what it means in real life. In G.E.1 s case they use X M lb./year and yet can't lost 0.5 drops per day. Stream flow rates make the matter worse. This is a point on which ,.Dr. Thompson should be cross-examined. Of the participants present, 5 plants discharge into sewers with outlets into rivers (very small except in 2 cases). Three plants discharge into small rivers. No one at the meeting could cope with the EPA standard as it is proposed^ Only Jard expressed an opinion.on what level they could live with. (Jard stated 27 lb. Aroclor 1016 per day. This would be 2.7 lb. PCB by our proposed definition.) -- FUR 004513 WATER PCB-SD0000071518 Monsanto SnCC-ULTYfi PPOCCSS CHCUICALS ClUSlOH MONSANTO INDUSTRIAL CHCMICAL8 CO. BOO N. Lindbergh Boulevard St. Louis. Missouri 63168 Phone: (314) 694-1000 March 18, 1975. .... Mr. Dan A. Albert Staff Supervisor Personnel Relations Westinghouse Electric Corporation Highway 58 West South Boston, Virginia 2^592 . Dear Mr. Albert: Attached are responses to the questions listed In your letter dated February 3s 1975. In addition to the industrial hygiene practices described in our responses to your questions, I cannot overemphasize the need to properly control the use and handling of Inerteens to prevent thelr. escape into the environment. Also, in discussing this information with your employees, I strongly recommend that the perspective gained from over 40 years of experience in which no human harm has resulted, be emphasized. In summary, the proper handling of Inerteens should pose no environmental or human health problems, permitting society's continued use of a very valuable ma terial. I hope the above information is useful to you. If I can be of further service please let me know. Sincerely, WBP:pd W. B, Papageorge Manager, Product Acceptability Specialty & Process Chemicals I PLAINTIFF'S DEPOSITION , EXHIBIT unit of Moniohto Comoenv FUR 004516 WATER PCB-SD0000071519 1. Question: Does Inerteen have permanent effects on the human body? If so, what type of permanent damage and how long a period of time does it take for this to develop? If not, explain why, if possible. ' The polychlorinated biphenyls in Inerteen can have permanent effects on the human body. The length of time or period of exposure necessary to develop symptoms depends on the degree or amount of exposure. In general, a single exposure for a few minutes to atmospheric .concentrations that cause irritation to the eyes and/or respiratory tract would not'be expected to cause either the skin eruptions or demonstrable liver injury. The problem arises from repeated and prolonged exposure to atmospheric concentrations in excess of the accepted Threshold Limit Levels or repeated and prolonged skin contact.~ " The polychlorinated biphenyls have not been recognized as skin "Irritants" in the same sense that caustic materials or many v.organic chemicals are irritants. Because of their "solvent" . action in removing the natural fats and oils from the skin, T leaching, drying and chapping, repeated and prolonged Ekln contact should be avoided. When the polychlorinated biphenyls are mixed with other chlori nated hydrocarbons, the mixture may be classified as a skin irritant. The potential toxic effects in humans from excessive exposure to polychlorinated biphenyls include injury to the liver and 'chloracne. In animals, the liver effect is demonstrated by increased liver weights and injury to cellular tissue. Although chloracne is difficult to evaluate in animals, in humans, this take the form of comedones (large blackheads with typical acute pustules) and may be an external symptom of over exposure pre ceding serious liver injury. . Animal data and human experience indicate that the toxic effects are similar whether exposure results from ingestion, inhalation of vapors, or absorption of the liquid material through the unbroken skin, (See AIHA Hygienic Guide Series - "Chlorodiphenyls" attached.) 2. Question: Several hourly employees have mentioned recently that many chemicals such as Inerteen cause sterilization after prolonged-use. Is this true? There is no evidence that polychlorinated biphenyls cause , "sterilization" in humans. </ FUR 004517 WATER PCB-SD0000071520 ) Question: Since Inerteen effects birds and other animals, ' If there is no real effects to human beings, how do you explain it to employees in such a way that they will understand why it can kill a bird and not a human? There is a potential real effect to humans - including death as discussed in the answer to Question 1. Due to differences in metabolism of food (and food contami nants) in birds and humans (and particularly the difference . in the reproduction process in birds and mammals - inelu ding humans), birds are particualrly sensitive to many chlorinated hydrocarbons including polychlorinated biphenyls. Question: If an employee spills Inerteen on his clothing and later takes the clothing home to be wa ed with other . clothes, will this have any effect on he or his family and should be carry his clothes home to be washed? There should not be any effect on an employee or his family from home laundering of work clothing. If washed with other clothing, there may be residual odor of the chlorinated hydrocarbons in the clothing. Question: Employees carry Inerteen home on the soles of their shoes and complain quite a bit about the effect Inerteen has on wearing out their shoes. Is this a -serious problem? Will Inerteen in the soles and leather of shoes, over a ' long period of time, have an effect on the feet and skin . ' since the shoe is the only protective equipment we wear on our feet and the Inerteen penetrates through the leather. There should not be polychlorinated biphenyl on the floor for workmen to contaminate their shoes to carry home. The plas ticiser or solvent action will destroy or shorten the life of the shoes. More importantly, the wearing of contaminated shoes could lead to absorption of the liquid through the soles of the feet as through any other unbroken skin surface. ' Question: There is one employee in our plant who had no pro blem whatsoever with Inerteen years ago. After six years . of using, now when he works in Inerteen (which is a part of his Job) he develops a swelling on the inner bicep of his left arm, only in one location. Could this be from Inerteen or not? It goes away as soon as he gets out of the Inerteen. It is similar to the swelling after taking an injection. . FUR 004518 WATER PCB-SD0000071521 We do not believe there can be any association between "a swelling on the inner bicep" of the arm and exposure to polychlorinated biphenyls. Question: Are there hand cleaning solvent materials that we should be using when working in Inerteen to coat our skin before working in it and to wash it off--after we finish working in it? Please give your recommendation. Our employees working in Inerteen are not able to use gloves since it is an assembly area. Even if they could., the Inerteen would destroy the protective glove.- ' ' We assume the question refers to the use of "Barrier Creams" rather than a "hand cleaning solvent". There are a number of barrier creams available to protect workers against water Insoluble solvents. Probably the most effective include silicone" "to provide an impenetrable shield". A problem with such creams Is that they may offer a false sense of security. Proper use includes a discipline which requires liberal appli cation at the beginning of a work shift and after each washing of the hands during the work day. FUR 004519 WATER PCB-SD0000071522 TOXICOLOGY ENVIRONMENTAL SCIENCES CH EMI STRY PLANT SCIENCES MEOICAL SCIENCES 9nduAt/dal BIO -TEST JlalxyojJ/yi&A', Snc. 1610 FRONTAGE ROAQ NORTHBROOK', ILLINOIS 60062 AREA CODE 312 TELEPHONE 272-303 Dr. George Roush, Jr. Monsanto Company- 800 North Lindbergh Boulevard St. Louis, Missouri 63166 . Dear George: I fully appreciate that the meeting on PCB's today was not completely satisfactory and that many nagging questions remain. The enclosed is a brief summary of my personal views and I would appreciate any open and frank comments that you all may have. Please let me know of any action that you contemplate in the way of seeking additional assistance in pathology or in contacting federal agencies. We will be pleased to be of help in any way that you may wish. It is my feeling that we need to get together again within the next few weeks to continue our discussions. Very truly yours, JCC: AR J. C. Calandra President cc - Dr. George Levinskas FUR 004520 WATER PCB-SD0000071523 DnduiiAial B l O - l b b t Xaluyiabyuei-, Unc. REVIEW OF PCB MEETING The central issue in question is whether the PCB's are carcinogens or not. The long term studies conducted at BIO-TEST indicate that the answer is no. Drs. Ward Richter and Donovan-- Gordon are of this opinion which is shared by M. L. Keplinger and J. C. Calandra. On the other hand, a study conducted by Dr. Renata Kimbrough presents evidence- that in female rats of the Sherman strain, liver carcinomas were found. This is the only study in which this finding is reported in rats. BIO-TEST has no basis for refuting the findings of Kimbrough except to take exception to the design of the experiment that used only female rats and to point out that to our knowledge no one else has reported similar results in rats. It should be noted that the earlier allegation by Kimbrough that bladder cancers developed, in female rats fed PCB was successfully counteracted by BIO-TEST and Monsanto personnel. Kimura* worked with Kanechlor-400, a commercial brand of PCB and in a rat study of 400 days' duration concluded that "PCB1 s induced a benign neoplastic change, though it seemed to be still short of malignancy, and that the change appeared exclusively in the females. " The author expressed concern that the benign nodules in the liver may progress to carcinomas if "specific or non-specific stimuli are introduced into the animal. " ' FuR 004S21 WATER PCB-SD0000071524 jInduAt'Ual BIO-TEST J.ali&iatiyu&i, 2 Ito conducted a study in mice and found "hyperplastic nodules and well-differentiated hepatocellular carcinomas" at a dose level of 500 ppm of Kanechlor 500. Hepatocellular carcinomas were not in- ' duced by Kanechlor 300 and Kanechlor 400. - -- -- ' The evidence to date indicates that male rats are more resistant than'females to the formation of nodular hyperplasia as well as hepato-' cellular carcinoma. Rats also are more resistant to the induction of these lesions than mice. To return to the BIO-TEST studies on PCB, it should be noted that the liver sections which were read by the pathologists and reported. ' in IBT No. 641-06672 and dated March 24, 1975, were not the same slides or sections as those reported bn originally. The preserved livers were reprocessed by taking 4 "cuts" from different areas to obtain as large a representative sample as possible. It is not surprising that under these circumstances a different tabulation of the various primary liver lesions was found. Studies on thyroid hyperplasia and by Richter's associate. Dr. Stanley Vesselinovitch, have shown that this procedure generally results in a different qualitative and quantitative line-up of lesions that are reported by the same pathologist. Ideally one would like to be able to reaffirm the original findings by this procedure, but this is not always possible because of the additional variables introduced. Serial sections of the liver would FUR 004522 . WATER PCB-SD0000071525 SndtuUlai B I O - T E S T labyiaiouei, Snc, 3 eliminate some of the covariants. The important point in the most recent study of the sections is the fact that no hepatocellular carcinomas were found which is'in agreement with the earlier findings. It must be'" emphasized that the diagnosis of "hepatoma" by Gordon and-Richter - connotes a benign process and must not be confused with the classical definition of the term by "human" pathologists. Further, Dr. Squires reviewed a number of the same slides on Aroclor 1260 with Drs. Gordon, Levinskas, Kimbrough and Richter and agreed with the BIO-TEST pathologists that liver carcinomas were not present in the slides. In addition, the original slides have been in the possession of FDA since June, 1973 and to date we have not been informed of any disagreement with BIO-TEST findings. Dr. Squires has stated in a letter to Dr. Kimbrough dated November 12, 1974, that "I define 'discrete nodules' and 'trabecular (basophilic) hyperplasia' as precancerous lesions and thus indicative of carcinogenic response. " This reflects a viewpoint which is not shared by all pathologists and there is nothing that BIO-TEST can do to change this definition except for its pathologists to accept or reject the view. Drs. Richter and Gordon do not accept Dr. Squire's definition. Workers in the field have published extensively on the pathogenesis of hepatocellular carcinoma in recent years and the concepts have undergone considerable changes since the preparation fur 004523 WATER PCB-SD0000071526 $ndiUtAial B l O - T E S T jal&iatMle, 9nc. 4 of the final BIO-TEST report on chronic oral toxicity studies. One must note that Popper in his studies on Aramite in i960 postulated that hyperplastic nodules were transformed into hepatocellular cancer; however, this concept was not generally accepted by the scientific . community. -. An excellent paper which describes "the highlights of some . newer developments in our under standing of liver carcinogenesis" 4. has been published by Farber. If the concepts presented in this paper as well as those of Squires, Saffiotti and others are accepted, a number of substances would have to be reclassified as liver carcinogens. Carried to extreme, we could argue that any substance that results in stimulation of liver microsomal enzymes or possesses hepatocytoxic properties to any degree is a potential liver carcinogen. BIO-TEST is unwilling to accept these concepts. The lesions seen in the livers of the rats in its PCB studies for Monsanto do not show vascular invasion, metasteses or anaplasia - all classical features of carcinoma. We continue to view the lesions seen to be benign. Several additional things need to be done by BIO-TEST and these include: (a) Re-examine the original liver slides. (b) Cut new sections at different levels from original paraffin blocks and read slides, (c) Tabulate liver findings separately in female and male rats. (d) If possible, develop information on-the reversibility of the liver changes. FUR 004524 WATER PCB-SD0000071527 ShcUuuaIzI B I O - T E S T laliOUiioAieA, 9no. 5 It is important to point out the following: 1. The BIO-TEST position was and remains that the PCB's were not shown to be liver carcinogens in its studies. This conclusion is the opinion of its resident pathologists as well as its independent consultant. 2. The BIO-TEST results show that a no-effect level for the development of hyperplastic nodules was found in each of its studies. 3. . BIO-TEST has no means at its disposal to dispute the findings of Kimbrough that Aroclor 1260 in female Sherman rats is a liver carcinogen except on the basis of experimental design. 4. BIO-TEST is not in agreement with the classification by Squires et al. that considers hyperplastic liver nodules to be pre- cancerous. ' 5. BIO-TEST studies on PCB's meet the scientific standards of Toxicology and Pathology and we are prepared to assist Monsanto in any adversary situation in or out of government. _ J. C. Calandra April 18, 1975 ' References 1 Kimura, N.T. Gann 64:105 (1973). . 2 Ito, N. J. Nat. Cancer Inst. 51:1637 (1973).- . 3 Popper, H. Cancer 13:1035 (i960). 4 Farber, E. Arch. Path. 9jhl45 (1974). FUR 004525 WATER PCB-SD0000071528 July 18, 1975 Dr. J.C. Calanara Industrial BIO-TEST Laboratories 1810 Frontage Rd. Northbrook, 111. 60062 \ A / Oa y \ re: AROCLOR 2-year Rat Feeding Studies Dear Joe: The attached table^utmvmarizes a comparison of the 3 revised AROCLOR reports ((1242^ 1254, 1260). In 2 instances, the previous conclusion of "slightly tumorigenic" was changed to "does not appear to be carcinogenic". The latter phrase is preferable. May we request that the AROCLOR 1254 report be amended to say "does not appear to be carcinogenic". The number of hepatomas reported for AROCLORS 1260 and 1242 have been interchanged. This appears to have arisen from con fusion regarding the numbering of the animals. The original reports show tumors in animals with numbers in the 100-300 range for AROCLOR 1260 and in the 500 to 800 range for AROCLOR 1242. This leads me to conclude that the numbering scheme shown in the second set of reports is correct. With AROCLOR 1254 confusion is compounded. The original report showed tumors in animals with numbers in the units to teens, but the revised report: shows animal numbers ranging from 4o to 1000. Can this be straightened out? I was unable to reconcile the differences in the animal numbers between the first supplemental report and the original reports, I had inquired as to the changes in the numbers. As I recall', I was told that the sections had been renumbered when the new slides were made and that a key relating to the sets of numbers FUR 004526 WATER PCB-SD0000071529 Dr. J.C. Calandra July 18, 1975 Page - 2 - would be supplied. This has not been done, it may not be necessary for AROCLORS 1260 and 12^2, but AROCLOR 12^4 remains unresolved. - Insofar as I can see, the remainder of the reports appear acceptable. Kindest personal regards. Sincerely, George J. Levinskas, PhD Mgr., Environmental Assessment and Toxicology /bkp att, ' cc; Dr, ueorge Roush, Jr., M.D. FUR 004527 WATER PCB-SD0000071530 Product Supplemental Report #1 (mailed) AROCLOR 1260 conclusion slightly tumorigenic hepatomas 3 range of p. 9 p. 10 p. 11 p. 12 p. 13 p. 14 test animal nos: 600 to 800 1000 series 70 to 100 500 to 600 600 to 700 700 series Supplemental Report #2 (JCC delivered does not appear carcinogenic -_ .100 to 300 800 to 000 lotto 4o 80 to 200 200 to 300 200 to 300 AROCLOR 1254 conclusion hepatomas slightly , tumorigenic 6 slightly tumorigenic 6 AROCLOR 1242 conclusion slightly tumorigenic does not appear carcinogenic hepatomas range of test animal nos,- 7 3 as in report #2 as in report #1 for AROCLOR 1260 AROCLOR 1260 fur 004528 WATER PCB-SD0000071531 TOXICOLOGY ENV'RONMENTAi. SCIENCES CH CM : STR Y PLANT SCIENCES MEDICAL SCIENCES 9w$mt/UoM B10 - T E S T 1810 FRONTAGE ROAD NORTHBROOK, ILLINOIS 60062 . August 4, 1975 3m. AREA CODE 312 TELEPHONE 272-3030 Dr. George J. Levinskas, Manager Environmental Assessment and Toxicology Monsanto Company 800 North Lindbergh Boulevard ' St. Louis, Missouri 63166 Dear George: \ \ . Re: Aroclor - 2 Year Rat Studies J ' In regard to the comments and questions covered in your letter dated July 18, 1975, pertaining to the above, please note the following: 1. We will amend our statement in the last paragraph on page 2 of the Aroclor 1254 report to read, "does not appear to be carcinogenic" in place of "slightly tumorigenic" as requested. 2. In regard to the animal numbers in the Aroclor 1242 and 1260 reports, they are correct in our final revised report. In the original reports, the Aroclor titles for these two materials were reversed. 3. The animal identification numbers appearing in the reports on evaluation of additional liver sections are the same as those in our original report. The animals were not renumbered. 4. We cannot find any discrepancy in animal identification numbers in the reports (original, re-evaluation, final revision) on Aroclor 1254. However, in the report on re-evaluation of additional liver sections dated March 24, 1975, there was a typo graphical error on page 1 which referred to Aroclor 1260 instead of 1254. Perhaps this is the basis of your confusion. I hope that this will serve to further clarify the situation. Thank you for your assistance and cooperation. Sincerely yours, rrr. a p J. C. Calandra President fur 004529 WATER PCB-SD0000071532 S'* l/ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHING YON, D.C.' 20460 . OCT 17 1975 . _ OFFICE OF ENFOnCEMENT ' Monsanto Industrial Chemicals Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63166 Gentlemen: OCT 221915 Recent governmental sampling data indicate the presence of Polychlorinated Biphenyls (PCBs) and comparable chemical substances ' in the air, in water bodies, and in fish in several areas of the .country. In order to determine the nature and extent of the possible . adverse effects resulting from the presence of PCB compounds in the environment, the Environmental Protection Agency (EPA), In cooperation with other federal and State agencies, is attempting to determine the sources and amounts of PCBs entering the environment. It is important that this effort be carried out without delay. It is our understanding that your company handles PCB compounds or mixtures.or comparable chemical substances in its operations. I am therefore requesting, pursuant to the authority provided by Section 308 of the Federal Water Pollution Control Act, as amended, 33 U.S.C. 1318, and Section 114 of the Clean Air Act, as amended, . ^ 42 U.S.C. 1857c-9, that your company furnish EPA with information pertaining to your use-and handling of PCBs and comparable chemical substances. In addition to a general description, which should include _ information as to sources, quantities, U6es,.and ultimate disposition, . V .you should respond in detail to the enclosed questions. If any question ' .is not applicable to your company or operations, please so indicate by / responding "not applicable." The information requested herein must be provided notwithstanding its possible characterization as confidential information or trade secrets. Should you so request, however, any information (other than ' effluent or emission data) which the Administrator of this Agency . determines to constitute methods or processes entitled to protection as trade secrets.will be maintained as confidential, pursuant to procedures specified in 40 CFR Part 2. . -i PLAINTIFFS DEPOSITION ! EXHIBIT i FUR 004530 WATER PCB-SD0000071533 2 Within 14 days of receipt of this letter, your company must provide all information concerning your current status and activities and covering the twelve month period immediately preceding receipt of this letter. _ Within 30 days following receipt of this letter, your company must provide all information for all of the prior years indicated. The information required herein should be sent directly to the address indicated below. If you have-any questions you may call the person indicated below or Mr. Blake A. Biles of our office at (202) 755-8731. . ' We appreciate your prompt cooperation in this matter. Sincerely yaurs, Stanley wZ'Legro Assistant Ac^inistrator for Enforcement Enclosure Regional Contact: Mr. Earl J. Stephenson Director, Enforcement Division Environmental Protection Agency 1735 Baltimore Kansas City, Missouri 64108 Telephone: (816) 374-2576 ' WATER PCB-SD0000071534 POLYCHLORINATED BIPHENYL (PCB) COMPOUNDS OR MIXTURES Within 14 days of receipt of this letter, your company must provide all information concerning your current status and activities and covering the twelve month period immediately preceding- receipt of this .letter. Within 30 days following receipt of this letter, your company must provide all information for all of the prior years Indicated. FOR PURPOSES OF THIS LETTER, THE PHRASE "PCB COMPOUND OR MIXTURE".INCLUDES ALL CHEMICAL SUBSTANCES KNOWN OR BELIEVED BY YOU TO BE PCB COMPOUNDS OR MIXTURES OR OF A SIMILAR CHEMICAL ` .NATURE,.-IRRESPECTIVE OF TRADE NAME, AND SPECIFICALLY INCLUDING CHLORINATED TERPHENYLS. . -' 1. For each PCB compound or mixture produced or imported by your company, for each company facility7~during each year of 1971, 1972, 1973, 1974, and the first two quarters of 1975: a. The total amount of each PCB compound or mixture produced or Imported. b. ' ' The name and address of each of your company's facilities which handle PCB compounds or mixtures- (including production facilities and wholesale and retail outlets), and the amount of each PCB compound or mixture distributed through each facility. c. The name and address of each customer of each PCB compound or mixture, the amount of each PCB compound or mixture . obtained by each customer from- each facility, and each customer's delivery point(s) for the receipt of each PCB compound or mixture. ;' 2. For each PCB compound or mixture incorporated by your company into its products, for each company facility, during each year:of 1971, 1972, 1973, 1974, and the first two quarters of 1975: . a. A description of each product. b. For each product the total amount incorporated of each PCB compound or mixture. pUR 004532 WATER PCB-SD0000071535 2 (continued) ' c. For each product the name and address of each source from which your company obtained each PCB compound or mixture", and the amount of each PCB compound or mixture obtained from each Eource. . d. The name and address of each of your company's facilities which handle such products (including production facilities and wholesale and retail outlets) , and the amount of each product distributed through each facility. ,. e. The name and address of each customer of each product, and the amount of each product obtained by each customer from each facility. For consumer products list only the total production of each product at each facility and the total number of customers. Do not provide the name and address of each customer of consumer products. For each PCB compound or mixture used by your company in its operations other than for incorporation into its products, for eactucompany facility, during each year of 1971, 1972, 1973, ..197m, and the first.two quarters of 1975: a. A description of each use. b. For each use the total amount of each PCB compound or mixture. c. For each use the name and address of each source from which your company obtained each PCB compound or mixture, and the amount of each PCB compound or mixture obtained from each source. For each PCB compound or mixture reclaimed^by your company, for each company facility, during each year of 1971, 1972, 1973, 1974, and the fir6t two quarters of 1975: a. A description of each method of reclamation. b. For each method of reclamation, the total amount of each PCB compound or mixture reclaimed. c. The total amount of each PCB compound or mixture reclaimed. FUR 004533 WATER PCB-SD0000071536 h b. . The flow nnd/or composition of any discharges or emissions by the company (into waters of the United States or Publicly Owned Treatment Works, or into the air) which contain PCB compounds or mixtures. '' c. ' Concentrations of PCB compounds or mixtures in receiving Waters (both upstream and downstream) of any discharges by the company which contain PCB compounds or mixtures and concentrations of PCB compounds or mixtures in the air in the area of the company. 8. . The methods by which PCB compounds or mixtures are transported to, by, and/or from your company, including: a. A description of each method of transportation, and the form in which PCB compounds or mixtures are trans ported by each method. Where different methods of trans portation are used at different facilities specify which 1 transportation method is used at each facility. b. The'names and addresses of all known transporters of PCB compounds or mixtures. 9. All occasions (including spills) of which you are aware oh which PCB compounds or mixtures have or may have been introduced into the environment. In particular, describe such occasions insofar " as 'they involved PCB compounds or mixtures in their liquid state, as incorporated into closed systems, or as incorporated into open systems. For each occasion, indicate name and address of party involved; dates, time, and location of the discharge or spill; and the amounts involved. -10. A description of any adverse health or environmental effects which you know or believe to have resulted from the introduction of PCB compounds or mixtures into the environment. Indicate any specific occasions including dates, times, locations, amounts, and parties involved for which such effects are known. 11. Any and all other information which you possess concerning: a. The-piroduction, importation, reclamation, use, distribution, ' and disposal of PCB compounds or mixtures. pUR 004535 WATER PCB-SD0000071537 5 b. The discharge of PCB compounds or mixtures into the environment. . In addition to the above, EPA would appreciate receiving any-other information which you possess concerning the distribution and discharge of PCB compounds or mixtures by sources other than your company, including your company's customers and sources. FUR 004536 WATER PCB-SD0000071538 Monsanto jhami ft locaiioni David Wood--St . 31/0X3is~ B2SO October 30, 1975 ' f-EPA *U0JCC1 ftttlHtftiCl ..COMMENTS ON EPA LETTER REC'D 10-17 TO : W. B. Papageorge B2SK . 1. Bill, this seems to be a new version. - 2. .Page 1. Cl. Terphenyls specifically mentioned. 3.a) Production records answer 1(a). b) Remember we warehoused PCBs for short period 1974 ahead of labor contract renewal. c) Question lc raises a problem that has been at back of my mind. #2 report is supposed to show "ship to" address, but if this is case, why do 3rd party w/GE . shipments appear under "bill to" locations. 4. Q2 a) No problem b) No problem c) No problem d) No problem e) Policy - Hanley level? 5. Q3-No problem except 71/72 6. Q4-No reclamation. .7. Q5-a) No problem b) Difficult. Can split Dielec/HT/Pydraul But some returns mixtures of oil/PCB, etc. c) Can do. d) Difficult e) Difficult 8. Q6 - Available 9. Q7 - a) Guess we have b) Guess we have c) Guess we have pUR 004537 10. Q8 - a) Bulk Rail Bulk R - 3 accounts Drum - Specify drum construction b) E. M, Potter WATER PCB-SD0000071539 11. Q9 - Should answer from our activity? -.12. QlO - None? Yusho? Cloracne-years ago - Dangerous-guestion. 13. Qll - a) Might get HUB again? b) Should write this one very carefully - can make some positive points in this section. /deb David Wood FUR 004538 WATER PCB-SD0000071540 6 MONSANTO INDUSTRIAL CHEMICALS CO. BOO N. LindUtrgh Bjulivird 3t. Loud, Miuouri 93C8 Rhon: 0141 994-1000 December 11, 1975 -/ ^<3 Mr. Earl J. Stephenson Director, Enforcement Division Environmental Protection Agency 1735 Baltimore Kansas City, Missouri 64108 ' Dear Mr. Stephenson: Attached is a response to the questionnaire which accompanied Mr. Stanley Legro's letter dated October 17, 1975. To the best of my knowledge and belief, the information contained in this response represents the best information available to Monsanto. If I can be of further assistance, please let mo know. Sincerely Manager, Product Acceptability Process Chemicals Division ajt Attachment CCi Mr. Stanley V.'. Logro' US Environmental Protection Agency 40).' "M" Street, SW Washing tun, D.C. 20460 FUR 004539 WATER PCB-SD0000071541 Mortality of PCB Worktr* at tha Monsanto Plant in Saugat, Illinois Judith A. Ztck and David C. Musch . Dacambar 14, 1979 fur 003370 WATER_PCB-SD0000071542 Scott Trial Testimony September 3, 1987 1 PHILLIP S. SMITH, 2 HAVING BEEN DULY CAUTIONED AND SWORN TO TELL THE 3 TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE TRUTH, 4 TESTIFIED AS FOLLOWS: 5 6 7 DIRECT EXAMINATION 8 BY MR. POHL: 9 Q Would you state your full name? 10 A Phillip, middle initial "S", Smith-. 11 Q And where do you live? 12 A Barrington, Illinois. " 13 Q Are you a former employee of Industrial 14 Biotest Laboratories, Inc.? 15 A Yes, I am. 16 Q Now, prior to your testimony here before the 17 Court today, have you visited .with anyone from 18 Monsanto -In your home in recent months? 19 A Yes, I have. 20 Q Who was that? 21 A A Mr.Tim Peck. " 22 Q And, very, very briefly, what was the 23 substance of that visit and the nature of the 24 visit? 25 A Mr. Peck wanted to discuss Aroclor compounds PENGAD'Bayonne. N. i . WATER PCB-SD0000071543 75 . MINUTES OF MEETING OF THE CORPORATE DEVELOPMENT COMMITTEE Nov emb e r 17, 1969 Present: Messrs. E. J. H. H. J. R. J. L. E. J. C . H. J. N. Bock , Cha I rman Bible Eck . Gi I I is Pu tze 1 1 S omme r Ehlers, Secretary ____ CHEMICAL MEETING The President reported that a chemical meeting Is to be held in Washington on Wednesday, November 19, with Secretary Stans and officials In the Shultz Committee. It.was decided that Mr. Reese should attend on behalf of Monsanto and also Mr. Bible, if Indicated. TV SPECIALS The President advised the meeting that the rash of complaints about the most recent TV special Indicated a need to re-examine our position on them. It was the consensus that the most recent specials were not satisfactory and did not portray a desirable Image of the company to the viewing public. The balance of the TV specials should be examined with the view of canceling them or If firm commitments exist, to dispose of them. Also, that the advertising firm In charge of them should be replaced, with public announcement of the change. He requested Mr. Gillls to look into this matter and to recommend a course of action on It. .ADVANCED MATERIALS AND COMPOSITES REVIEW - NEW ENTERPRISE DIVISION Present: Mes s r s . S. Gordon, L~. E~. iO e 1 n , T . L . G o s s a g e Ce rex Production from the Mark II machine Is meeting our commitment and will produce nearly double the sales commitment In November. The plant construction Is completed, the machines are being Installed, and the testing program will commence December 15* - Total capacity of the four machines will be 2 M lbs. with sales of approximately $9 M annually. 1970 forecast Is for sales of $5_M and after-tax loss of $.8 M^ This reflects a $3.1 M SARE, an Increase of $1.1 M over 1969. The Increase is to cover development of new stretch materials and other products which has been delayed six months due to the pressure of production commitments. FUR 003935 WATER PCB-SD0000071544 - Future plans include U.K. production with an appropriation request to be submitted in m 1 d - I 9 7 0 . This is being , deferred until the star t - u p of the Mark III production Is complete and an assessment of this operation can be made. Decision: The Division should present to the CDC a review of the start-up operations of the Hark III machine in mid-February when this is comp Ie t ed. Hetal Fibers Program . This program is running approximately 6-12 months ahead of its . R D plan. - 60 hours continuous run of 6 mil aluminum wire has been demons trated. - Steel technology is 6 - 10 months ahead of schedule. Can reproduclbly spin 3 mil steel wire. - Aim to develop In-line takeup of steel wire within six months. - Steel represents the greatest opportunity to Honsanto, although development programs are being conducted with both aluminum and copper. Conclusions: The President complimented the Division on the real accomplishment that they have made In this program which Is an exciting one. The Division Is requested to develop a business plan for this field for consideration by the Committee. Graphite Fiber Program Graphite fiber Is the stiffest and strongest material per unit weight commercially feasible today. The market for this material Is .dependent upon the ultimate price. At $300 per pound a limited market of $3 - $ ! 5_H is foreseen. At. $20 per pound the market would exceed $200 H annually. Laboratory evaluations indicate a $20/lb. price Is commercially feasible.- This reflects an $8.25/ib. cost of manufacture at a 1 H 1b.' product 1 on level, and a $2.00/lb. cost of special aery I Ic precursor. Honsanto franchises In this field consist of strong technical strength in fibers and their treatment. - Properties of the finished graphite fiber are completely dependent on the properties of the precursor. A high quality acrylic precursor Is a necessity. - Possibility of patent shelters exist in process steps but not in the material itself. FUR 003936 WATER PCB-SD0000071545 77 . Research Objectives - Develop defect-free, high tenacity precursor. - Reduction of precursor manufacturing cost. - Increased rate of throughput in pre-treatment and graphitizatI on steps. - Increased volume of throughput with greater numbers of fibers. Brake Disk and Turbine Blade Programs .Progress In the development stage Is very satisfactory. Several companies have expressed an Interest In an arrangement to obtain the benefit of our technical strengths In these prod.uct lines. Business Plan Monsanto technology extends through sub-components level. Main issue Is. to develop the business plan for components such as brake discs and turbine blades. The division recommends continued approval of' the June 9 recommendations - 1. Proceed with development of raw material, sub-component and finished parts technology with projected A. T. losses of $1.25 M In 1969 and 1970, and $1 H In 1971. 2. Explore, without commitment, possible acquisition candidates during the next six to twelve months. Conclusions: The President expressed the Interest of the Committee In the technical accomplishments of this program and concluded that It should be pursued further. The business plan as proposed by the Division Is not accepted at this time but may be operated under as an Interim deve1opment_p1 an. The proJeted potential for the business of $13 " $35 H with $1 - $2.5 M net Income by 197^ Is not acceptable to warrant continuation of the program. The Division Is requested to develop a full business plan with strategies to make the project a commercial success in the shortest possible time. The .Division Is Instructed to present the business plan for the Comm I ttee *1 2s' rev Iew In June 1 970. (Excerpt to Dri R. S. Cordon.) ORGANIC DIVISION, LAW AND MEDICAL DEPARTMENTS -- REPORT ON P0LY- CHLORINATED BIPHENYLS ____________________________________________________ Present: Messrs. C. J. Smith,J. Mason, T. K. Smith, H. S. Bergen, . J. E. Sprlnggate, R. E. Kelly, E. P. Wheeler, Rodney Harris, Jr., D. W. Miller, W. C. Robinson Monsanto's worldwide Aroclor bu s I nes s__amoun t s to 10^ M Ibs./yr., 70M used In funtlonal fluids and 3^ M In plasticizers. This represents. $22 H In sales. Products range from monoch1orobIpheny1 FUR 003937 WATER PCB-SD0000071546 78. to decach1orob I pheny1 , terphenyls, and chlorinated terphenyls. Production locations are at Anniston, Alabama, Sauget, Illinois, Newport, U,.K. and Yokkalchi, Japan. ' Environmental Aspects - E. P. Wheeler The 5 and 6 chlorinated biphenyls (Aroclor 125^ and 1260) have been found at limited locations in water, In birds and some forms of aquatic life. Recent indications are that such b i-p-freny 1 s ' may affect reproduction'of fowl life and may be toxic to shrimp. These products are not toxic from the acute standpoint to man or fish but there Is some evidence of ecological buildup in certain' water deposits,, in fish and ultimately In bird life. - Aroclors 12^8 and lower In number are believed to be biodegradable but this has not been conclusively establ Ished as yet. Plan of Action - H. S. Bergen and J. E. Sprlnggate The availability of alternate products to satisfy customer requirements was reviewed. Main problems are that no replacement product Is available for capacitors and replacement products for other uses pose a pollution problem. In plasticizer uses, evidence Is not available as to whether Aroclors- escape from end products, either through leeching or by dispersal In burning. The recommended plan of for each business group assure that the loss of minimal. action Is to establish a tailored program and each customer market situation to PCB's In the environment, If any, Is FUR 003938 WATER PCB-SD0000071547 79. 1. Appoint a Project Manager - responsible for the overall management of the Aroclor pollution problem. He would be assisted by a Task Force from members of each business group plus Medical, Law, Engineering and Manufacturing. , 2. Notify all Aroclor customers of PCB problem. 3. Reduce and effectively control PCB effluents from Monsanto plants. 4. Educate customers on need to reduce and effectively control PCB effluents at their plants. 5. Develop and Implement new packaging systems for Aroclor 12 5V12 60. ' 6. Introduce to market, replacement products for Aroclor - 1 25V 1 260. . . 7 Continue and expand biodegradation test program with Aroclor series, particularly 12V, 1.248 and 1254. 8. Continue toxicological test program. 9. Accelerate present analytical test program. 10. Determine feasibility and cost of eliminating 5/6 Cl In Aroclors 1242 and 1248. * 11. Study incineration products. 12. Develop business plan to offer: - Monsanto Fluid Reclamation and Recovery with Enviro Chem. (Reclamation already under way at Flndett.) Cost of this program Is estimated at approximately $400M SARE and $700M capital to change equipment. Conclusions: In light of the recent and developing evidence of a possible threat to certain species of bird and aquatic life, we should plan to discontinue the manufacture of Aroclors 1254 and 1260. The Division Is Instructed to develop a program to discontinue these products and report this to the Committee. The status of Aroclor 1242 should continue to be tested to determine whether It contributes to this problem. Other products which might be Involved should also be examined. (Excerpt to Messrs. H. L. Mlnckler, Rodney Harris, Jr., R. E. Kelly, T. K. Smith.) FUR 003939 WATER PCB-SD0000071548 8o. DONATION OF LAND TO MONSANTO FUND The President advised he would recommend to the Board of Directors the donation of the following parcels of land to the Monsanto Fund : Nitro-- 122 acres Revere Beach - 16 acres Seattle - 20 acres . The Treasury Department Is requested to prepare a memorandum for submission to the Board of Directors at the December meeting. . (Excerpt to Messrs. C. P. Cunningham, P. J. Dowd, Rodney Harris, Jr., J. D. Mahoney, H. L. Mlnckler, Finis Morgan, T. M. Rasmussen, - - T. K. Smlth.) APPROPRIATION REQUESTS AND RETIREMENT REQUESTS Action was deferred on the following retirement requests: Organic Division No. 0D-2000- Retire phthallc anhydride _ plant - Chocolate Bayou Organic Division No. 0D-3182 - Retire phthalic anhydride plant - J. F. Queeny Plant The President advised that he would approve - Organic Division AR ^CEA 2109/2172 - Denora Chlorine Cell Conversion - Krummrich Plant - $590,000; and Retirement of 22 DeNora Chlorine Cells - $595262 grossassetvalue. MISD Appropriation Request No. 23 ~ IBM System 360 Model k0 to replace IBM 77^0 Switching System and supply additional capacity - basic annual lease $13^,200. OTHER BUSINESS Mr. Putzell advised the Committee of the pendency of a proposed arbitration proceeding against Scientific Design under the contract for design and construction of the MAL Phenol Plant. Mr. Putzell and Mr. Sommer will review with Mr. Throdahl the value of our continuing relationship with Scientific Design as may be affected 'by Instituting the arbitration proceedings, following which the matter will be reconsidered by the Committee. A review of the Packaging Division operations Is to be scheduled In the near future. J. N. Eh 1e r s Secretary FUR 003940 WATER PCB-SD0000071549 "\ E'OJ Paul Eenignus-GO October 23, 1959 AIR KAIL Mr. H, Wilbur Speisher Administrator, Industrial Hygiene Westinghouse Slectrie Corporation East Pittsburgh, Pennsylvania Bear Wilburi thank you for your letter of October 21 inquiring about the safe use of triehlorodiphenyl and a mixture of 40j fcriohlaro- bensene and 60 hexaohlorodiphenyl. We market triehlorodiphenyl Aroclor 1242"^ The cotnblna- tion of hexaohlorodiphenyl andv tri(^los*obnxene is known aa Inert'ecn PR~O'"". The diphenyl s combination is our "Aroecllowr lSWV The physical and chemical properties of the Arcelor* mentioned are shown oa the table on pageB 4 and 5 of the enclosed Aroclor bulletin* Inclosed also is a reprint indicating the results of chronic toxicity studies with Aroclorsfi4c arid 1254, The following coasasnts answering your questions serially are based on information contained in these bulletins. I believe prolonged and repeated skin contact with any of the Aroclor should be avoided for two reasons. In the first !elanctes, otlhveenltesssfocr holoilrsinaatneddfaptrsodiunctstheareskliinquaisdswealnldasareotheexrcel- organic materials. Secondly, it is possible that prolonged or repeated akin contact oould lead to chlorecne, I know of only two cases whore such experience has developed during the long history of production and use of the Aroclors* In one case, an Aroclor was being used as a heat transfer Mdlua in a system that allowed vapors to escape when the material was heated to 60Cr>y, Several workmen developed "blackheads" which were found by an industrial physician but which in his words were so in significant that the men were not aware of them near weuld a general practitioner notice them, This indicates to me, however. WATER PCB-SD0000071550 Hr. H. Wilbur Speioher--Page 2--October 23* 1959 that sufficient exposure, whether by inhalation of vapors or skin contact* can result in chloraane which I think we oust assume could be an indication of more serious systemic injury if the exposure was allowed to continue. ^ ' A second case of mild chloracne about which we have any knowledge resulted from workmen dipping their hands in the liquid Aroolor as if it were mineral oil or vegetable oil. In addition* their clothing sooner or later became impregnated with the material and thus exposure was magnified. You asked at what temperature local exhaust ventilation should be provided. Although the distillation range for Aroclor 1242 is 325-360C. and 365-420C. for Aroolor 1260* I feel that good practice dictates that local exhaust ventilation be provided when any of the Aroclora are heated above 150F. in open tanks or in any systems where the material is not in a completely enclosed system (vapor-proof tanks* kettles* pumps* piping, etc.}. This may be ultra conservative because as the distil lation ranges and vapor pressure curves (page 12 of the Aroclor bulletin) indicate* the loss of vapors at 150P, should not be significant except in any work area where general ventilation or air changes do not exist. Your next question related again to possible skin and systemic effects and I believe it is answered above. In connection with the 40j trlchlorobenzena-60^ Aroclor 1260 eceabinatlon* I believe the thoughts expressed above also apply. 1 I understand that the trichlorobenzene which is used is a mixture of the 1*2*3-* 1*2*4-, and 1,3,5-isomera which will i begin to distill at 205C, Again* I believe this indicates t a low vapor pressure for the solvent at room temperatures, The only reference we have to trichlorobenzene toxicity is con tained in the Public Health Service Publication No. 414 entitled "The Kalogcnated Hydrocarbons Toxicity and potential Dangers" by Dr. W. F. von Oettingen* U.S, Qovermant Printing Office, 1955 (page* 297-296). Dr. von Oettingen refers to some work . done in 1937 which indicated that the trichlorobenzene was less : toxic than mono or dichlorobenzene. In my opinion* a reasonable MAC for this material would be 100 parts per million. The enclosed publication on the toxicity of Aroolor 1242 and 1254 suggests an MAC for 1242 of 2 milligrams per cubic meter which is twice that recommended by the ACOIH for a chlorinated di phenyl of unstated chlorine content. In the case of 1254, the publication suggests that the MAC of 1 milligram per cubic meter "recommended tentatively for safe industrial practice by the American Conference of Governmental Industrial Hygienists" is reasonable. On the other hand* reference to Henry Smyth's Cusssinga Memorial Lecture of 1956 in which he discussed the basis for the then existing "hygienic standards" indicates that FUR 003942 WATER PCB-SD0000071551 Kr. H. Wilbur Speishar--?aga 3--October 23, 1959 Henry agrees that MACs of 1 mg/cu.s, for Aroslor 1242 and 0.5 g/ciu for Arcelor 1254 are acre realistic, In the ab sence of any thnanle toxicity data on Aroelcxr 1260, we suggest an HAG of 0.5 sg/eu.m,, the sm as In the aw of 1254, I have been In one plant where thase materials were used for capacitors and transformers. The care and handling and the provisions of exhaust ventilation were not in accordance with the thoughts expressed above. The only reported difficulty was scma mild eye irritation when Impregnation cabinets where the items were heated to 110-12QC. released vapors of trlchlcrobensene and the Aroelor into the workroom when the cabinet doors were opened* In my Bind, such cabinets should bo ventilated to rtswrre the vspers rather than allow thesi to be released Into the westing atso^here. , I have been told that your soapany has had some 20-25 years' experience-with the products discussed above. It was nuggettad that Hr. JSms B. Ford* manager of transformer manufacturing engineering at your ah&roo Plant would be a source of informa tion regarding experience with Xnerteen PPO. Similarly, ftr. R. E, Hsrbury of your Bloomington, Indiana Plant has been associated with the use of Aroelor 1242, Perhaps you hare al ready discussed potential exposures with these gentlemen, if so, I would be interested in learning of their practical ex perience with these products. I look forward te seeing you in Pittsburgh next week. Sincerely, mvimi Enclosures 2 Elmer P, tfceeler Assistant Director Nodical Department FUR 003943 WATER PCB-SD0000071552