Document KG6VdD2r45KqZjrynErVybVMr

/ Monsanto Ctafior 00 N. lMMr|l Itilmrl StlMtt. MimmH B3ISS Mmm: OMI M>t000 March 12, 197* WtNNI ^\*2> Mrs. Betty J. Billings ' Hearing Clerk Environmental Protection Agency Room 1019-Bast Tower 401 "M" Street, S.W. Washington, D. C. 20460 . ` * Re: Proposed Toxic Pollutant Effluent * Standards for Aldrin-Dieldrin, Et A1 - FWPCA (307) - Docket No. 1 * Dear Mrs. Billings: . i In accordance with the ORDER AND NOTICE of Judge yiilian. J. Sweeney dated February 6, 1974, enclosed are the original and three copies of the written testimony with attachments submitted on behalf of Monsanto Company In connection with the above described matter. Yours very truly. t FSP/Jmd fine. i Senior Attorney i 174 ia I -I 100C TOWOLDMONOOOI385 e. t 'Monsanto '1 MONSANTO MOUtTXUU. CNSMCALS eO. 00 N. llMMrfk Si. Uail. HuiNti SS1IB MM: OM) SSMI000 Zb Us: PROPOSED TOXIC POLLUTANT EFFLUENT STANDARDS POR ALDRINDIELDRIN, ET AL - IVPCA (307) - DOCKET KO. 1 >>/ .(A7 Br-* v. State of Missouri ) County of St. Louis ) * V. B. Fspsgsorge, being first duly even ssys: My name is V. 8. Fapageorge and I sa Manager, Product Acceptability for the Functional Produet Croups, Monsanto Industrial Chesleals Coapany, an operating unit of Monsanto Coepany. I as a graduate of Washington University, St. Louis, Missouri vith a Bachelor of Science degree In Chemical Engineering and have received a Master of Science degree in Chemical Engineering frea the saae institute. I aa a Registered Professional Engineer in the state of Missouri. I have been caployed by Monsanto Coapany for approximately 22 years, during whleh period Z have served as an engineer, aalntenanee superintendent, distribution superintendent, . manufacturing superintendent, plant manager and manager of environmental protection. In my present position X aa responsible for seeing that the quality of products produced by tvo business groups la Monsanto Coapany is properly maintained. One of the business groups within my area of responsibility is the Specialty Preduets Business Croup which manufactures and markets polychlorinated biphenyl (FCB) products for use as dielectric fluids in transformers and capacitors. I aa a meaber, and have served as chairman, of a eoaaittee of the National Electrical Manufacturers Association whleh has reviewed the environaental offsets of PCBs and has reeoonended procedures to users of PCBs which should ainiaize the possibility of entry of PCBs into the anvironaent. ,*u c**mm 275 .10039 TOWOLDMONOOOI386 -2- . t-Hf MOKSAKTO COKPJLWS POSITIOW AND RICOKghDATlONS As major producer mod supplier of polychlorinated biphenyls (PCBs) to the electrical industry for fire resistant dleleetrle fluid applications, we have reviewed and evaluated the affluent atandards for these materials la proposed Part 129, Subpart X, Chapter X of Title 40, Code of Federal Reflations. Pursuant to this review, ve submit the following comments and recoaaendatlons s 1. The proposed affluent standards for VCRs are unwarranted and prsetleally and economically unattainable. 2. Actions by Monsanto and its customers, which have resulted In limiting the use of FCBs only to aleetrleal applications la hermetically sealed units, have dramatically reduced the quantities of the more persistent PCBs introduced directly into the environment. .' 3. The definition of PCBs In Section 129.09a, Subpart X should be changed to read: "Polychlorinated biphenyls (PCBs) means materials N containing the biphenyl group vhleh is chlorinated and vhleh have been shown to persist and rapidly bioaceumulate in the aquatle environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than 60, relative to j>.p-DPE100.- under the standard conditions recosaended la the EFA PCS test method." 4. The accuracy and reproducibility of results attainable between laboratories using currently available sampling and analytical techniques are questionable and further studies are recommended. 5. The proposed PCS effluent standard is based on inadequate toxicity information, on non-typical fish species and on an unusually high and artificial bloaceumulatlon faeter. Fundamental scientifically-based data is lacking and no responsible standards can be developed at this time. Ve reeoenend that studies be conducted to obtain the relevant .-data and that effluent standards be established which are appropriate for the unique conditions existing et eaeh point souree. 176 10000 TOWOLDMONOOOI387 -3 6. We object to e limitation of 10,000 cuble feet per oeeond being arbitrarily assigned ae a maximum stream flov, without a sound technical basis demonstrating adverse affects. 7* The presence of background levels of fCBs at point aourees should be considered when dettraining affluent levels. The following definition of "Background" should be added under Section 129.01a: * " 'Background* ueane mounts of tonic pollutant (1) presently found in the waterways of the United States (including the intake waters of a discharger), * or (2) arising out of operations aubjeet to this Bart that oeeurTed before the effective date of this fart, but were sot discharged to the waterways of the United States before the effective date of this fart.** . S. Technology for the attainaent of the proposed PCB effluent . standard has not been demonstrated and is not available to the industry. Unaehlevcaent of the strict standard proposed would have the effect of a baa on the use of FCBa with serious economic and soelal consequences very thoroughly described la an lmpect statement submitted to the Ageney on January 15, 1971, by the General Electric Company. The ehemleal structure of polychlorinated biphenyls (PCBs) has been known for nearly 100 years. It was not until the late 1920s that a use for PCBs was found -- as a dielectric fluid in transformers. - The properties of FCB -- inertness, fire resistance and a non-conductor of electricity -- are perfectly suited to those eleetrleal applications where high-voltage arcing eould occur; possibly resulting in serious fires or damage to the equipment. Commercial production of fCBs began in 1*929. As the unique properties of the material became known, new uses were found. For example, their 'fire-resistant nature made them excellent choices for use la heattransfer fluids. Their inertness gave long-lasting qualities to lubricants. Their use in surface eoatings Improved waterproofing charaeterlstlca. Baadliag of the preduet at the manufacturing level has net presented problems as long as the normal industrial hygiene practices were followed and FCBs have always been considered less hasardous than many other ehemleals in everyday use. ft 177 1003 TOWOLDMONOOOI388 / fi i Therefore, It appeared that PCBs were a unique preduet vhleh net important seeds of industry. When questions about the affaet of PCBs on the aaviroment first surfaced, Monsanto Company reviewed its product line and the applications for these produets, is sore data ware developed concerning the effect of PCBs, Monsanto took steps to redoes the entry of PCS into the evironaest. The Cospasy stopped the sale of PCBs for use in various applications, except vhere no aeeepteble alternatives were available. Today, PCBs sanufsecured by Monsanto Cospany arc sold only to the aleetrieal industry for use in elosed systems as a dielectric fluid in transformers and capacitors -- applications for which there axlst no acceptable substitutes. . * * Thus the situation today is drastically different free conditions vhleh existed only three years ago. Today about 40 million pounds per year are being earefully used in the United States by less than 50 Monsanto eustoaers in the manufacture of sealed aleetrieal equlpsene. . Prior to 1971, close to SO million pounds per year were used by thousands of customers. This lends perspective to the current debate ever modest losses of PCBs to waterways. * Our manufacturing and sales reduction program was a unilateral action taken by Monsanto and was based on our evaluation of developing environmental data. The Interdepartmental Task Force on PCBs in Its report (l)q concurs that the safety benefits derived, justify the continued use in dielectric applications. Recommendation 6 under Findings, Conclusions and Recommendations reads as follows: , .J-L.p>e use of PCSs should not be banned entirely. Their continued'"use''fok!*Tira<&*eriihr "hnd^cxpmct-cvr* in-stive .naax,^.-.K,_MS<tt future is considered neeessary because of the significantly - * Increased risk of fire and explosion .and the disruption of aleetrieal service vhleh would result from a ban on PCB use. Also, continued use of PCBs in transformers and . capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic , producer, has reported voluntarily eliminating its distribution of PCBs to all exeept manufacturers of aleetrieal transformere and capacitors." Numbers in parentheses refer to reference list attached. 178 1000: TOWOLDMONOOOI389 Eeeogalclng the need for proper controls la the handling aad use of PCBs, representatives of the trsasforaer sad capacitor industries, vtllitles sad governmental agencies aader the initial ausplees of the Rational Electrical Manufacturers Association forced American Nedeasl Standards laetltute Committee C-107. Proposed guldellaee (30) for the handling aad disposal of dlelattrle fluids have beta published. These tuldellaes refleet the ladustry'a understanding of the need for i proper eoatrol aad have contributed significantly toward achieving I this objective. *' Proposals for the eoatrol of PCBs internationally vere considered by the member countries of the Organisation for Zeonoale Co-operation aad Development (OECD) aad la February, 1973, they adopted an agreement (31 vhieh restricts the use of PCBs to dielectric applications, nem-fcod related heat transfer fluid applications and hydraulie fluid applications in mining equipment. This agreement is less restrictive than Monsanto's sales policy sines it supports the eeatlnued use of PCBs in heat - transfer and hydraulic fluids. - Ve have reviewed with considerable Interest the effluent standards proposed for polychlorinated biphenyls in new Part 129, Subpart Z, Chapter 1 of Title 40, Code of Federal Kegulatlons aad have objections relating to the following: ' 1. Definition of polychlorinated blpheayls. 2. Saapliag aad analytical methods. 3. Toxicity data. . 4. Bioaccumulation factors. . ' 5. Safety factors. 6. Stream flov rates. ' 7. Background levels of polychlorinated biphenyls, t. Economic considerations. DEFINITION OF POLYCHLORINATED BIPHEmS _ Commercial polychlorinated biphenyl products, of vhieh Arcelor produets are examples, are produced by dlreet chlorination of biphenyl; the degree of chlorination being ehosen to provide desired properties. These produets are in all cases multi-component mixtures and not single entitles as implied by the commonly employed aeronym "PCBs". 179 10000 TOWOLDMON0001390 While it is veil understood sad seetptsd that polyehlorlasted biphenyl Isoacre have a unique sec of physical sad cheaieal properties, it is apparently not traderstood that they bloseetnulaee, dissipate and biodegrade at different rates. This leek of understanding Is reflected la the definition proposed in the CPA Tozie Pollutant effluent Standards {Federal Eeglster, Pol. 38, Bo. 247* page 35393* Section 129.09a) and ve quote: * ' * . "As used ia this Subpart, the ten: Polychlorinated biphenyls (PCB's) aeeas materials containing the - biphenyl group vhleh here been ehloriaated to varying degrees. There are 210 possible diffareas P C S compounds." * a Ve object to this definition because it implies that all polychlorinated biphenyl isoaers are of equal environmental concern, l.e., that they all persisc end bloaeeuaulate ia the saae manner la our eavlrenaent. It has been veil established by academic, government, aad industrial researchers that this is simply not true. Environmental monitoring programs have clearly demonstrated thst, vith the exception of direct high-level controllable release Bear points of manufacture or use, the ?C8s found la our environment are the more highly chlorinated ones, l.e., those containing predominantly five or more chlorine atoms per biphenyl molecule (2 thru 13). . This is true even though the lover polychlorinated biphenyls have constituted more than 65Z of all the PCBs manufactured over the years. This is strong evidence that the lover polychlorinated biphenyls degrade rapidly. It further demonstrates that even under conditions of unlimited use, end vlthout special precautions to avoid release into our environment (vhleh is not the case now), that the lower polyehlorinate biphenyls degrade rapidly enough to prevent bloeccumuletlon (4, 5, 6, 27, '.VWfc.Wl More recently, it lias^ alsiT be'en^ieao r'at1fd'Tife*sla'BdfSrtfrrry*'ii'fxrrIseat . that chlorinated biphenyl Isomers, resdily undergo beeterlal degradation at rates dependent upon the number of chlorines per biphenyl molecule' (17, 18, 19, 20, 21 and 37). There are also good Indications that ambient environmental PCB levels are deereeslag at rates more rspldly than ' predicted (14, 15, 16). . The rapid metabolism of these chlorinated isomers aad their lack of importance as contributors to the chlorinated biphenyl tissue burdens is evidenced in the results of numerous studies. Blsebrough (2) reported that the chlorine composition of the PCBs detected in Atlantic Oeean zooplankton was approximately 542. Be eoaeluded "U.S. production of Aroelor 1254 in 1970 amounted to 12 million pounds -- only one quarter ISO 10 00' TOWOLDMONOOOI391 . of tht production of 49 Billion pounds of Aroclor 1242. It Blghe bo expected therefore that biphenyls with fever ehlorlne atoms would predominate In planktonic samples unless these compound* were selectively degraded." Similar findings In fresh water sad marine fishes were reported by Zitko (3) and Jensen, t al., (4). The disappearance of the lover chlorinated hooologs la extracts of tissues from birds (5, 34) and aammals (6, 33) Indicate rapid metabolism or excretion of the lover Chlorinated bomologs. As a result of the metabolism and/or exeretlon of the chlorinated biphenyls containing less than five ehlorlne atoms per Boleeule, their contribution to the effluent should not be used In measuring polychlorinated biphenyl effluent from a facility. On the basis of these data it is unrealistic to consider All poly chlorinated biphenyls equivalent in terms of persistence and blosceumula- tlon as does the proposed regulation. Therefore,' for environmental purposes, the definition of FCBs should foeus upon those vhleh are of concern and we recommend that the following definition be substituted for that proposed la Section 129.09a, Subpart X, Title 40, Code of . Federal Xegulatloas: '. "Polychlorinated biphenyls (PCSs) means materials containing the biphenyl group vhieh Is chlorinated . and vhleh have been shown to persist and rapidly bloseeumulate In the aquatle environment. These chlorinated biphenyls are identified as those components having^ gas chroaatogrephle retention times greater than 60, relative to p,p-DDE - 100, ' under the standard conditions recommended in the EPA PCB test method." ' AHAITTICAL METHODOLOGY Ve have no reason to doubt that the recesaended CPA PCB test method la capable of detecting parts per trillion (ppt) levels of PCBs in waste . waters. However, our experience with analyzing Industrial waste waters for PCBs at the parts per billion (ppb) level prompts us to be concerned about the following areas, some of which are not covered adequately In the test procedure. - 1. Sampling Procedures * 2. Correction for Laboratory and Heagent Background 3. Correction for Hon-FCB Sample Interferences 4. Absolute Verification 181 100J.0' TOWOLDMON0001392 5* Physical State of PCBs (Adsorbed/Dissolved) C. Quantitation 7. Precision and Aeeuraey Our concern lies in the fact that any aethod, especially one as coaplex as a PCS analytical aethod* vhleh is to he used for effluent control purposes aust he tnorouthlv evaluated and its aeeuraey and reproducibility proven. If this is not done, the effectiveness of any effluent Halt* no natter vhat the level, will prove to be .difficult, if not impossible to deteralae. Per exaaple, ve have found that if waste water streams ara noe sampled properly, the PCB levels found depend on the saaplins procedure employed and bear no relationship to the amount of PCBs discharged. Per this reason, saapling procedures used must be designed for the discharge in question and elearly seated. To our knowledge, this has not been done. Ve also note that no provisions are reeoamended for correcting the apparent PCB level found in a sample for laboratory and reagent background. Zt is our experience that as one approaches the ppc level, 'this background ean significantly affeet the observed PCB level. Vlth regard to correction for non-PCB sample interferences, we feel that, while the procedure notes many of the possible interferences, it does not really address Itself to those which are more likely to be in industrial waste water streams. For this reason, if the electron capture chromatogram does not mateh the PCB being manufactured or used, complete absolute verification of all components counted as PCB must be validated via an alternate technique such as gas chromategraphy/mass spectrometry. m Ve also note that the recotraended EPA PCB test method does not specify ' a means of differentiating between dissolved and adsorbed PCBs. Ve - ` * believe this should be done since there is a definite difference in the toxicity and availability for bloaeeuaulatlos of dissolved and adsorbed Vhlle the seheme proposed for estimation (quantitation) of PCBs is logical, it suffers from the same shortcoming as do the multitude of oth< procedures which have been proposed. It is an empirical estimate and only a reflection of the real PCB level. Therefore, it should be determined via an alternate, swre^elaborate procedure how elosely the calculated PCB levels (for caeh of the cases) are to the real PCB levels so that they may be eorreeted. 182 TOWOLDMONOOOI393 ) list* but sot lust the precision end aeeuraey of aay procedure propose as e standard acthod should undergo e chore ugh inter-laboratory evaluate If this has not already been done. It buss be earned out prior to the use of the procedure for eaforeeaeat purposes. The accuracy and precision of the Koaaaato PCB procedure has been subjected to a pre liminary evaluation. Prior to this evaluation, we probably vould have everestisated the precision and aeeuraey of our proeedura. The exact details ef the evaluation are available. ! . Briefly, staples were prepared by spiking distilled water with 300 oob PCBs. Individual preparations Include blanks (no PCBs), Aroelot*1242 c Aroelor 1254 only, Aroelor*1260 only, all 50-50 tvo-ceaponent Bixture: and a 1/3, 1/3, 1/3 preparation containing all three eouponents. Six saaples ef eaeh Bixture were prepared and analysed by two experienced analytical laboratories. Each result, expressed in ppb of the individual Aroclox, was converted to percent of the total added. Aaalysla of variance was run on all data taken together and on eaeh laboratory independently. The 951 confidence Units observed for individual results were: Either Lab 87.5 + 55.22 Lab A. 81.3 + 46.42 Ub B . 93.7 + 19.22 ' The repeatability for the individual labs, based on repeat tests of saaples having identical prepared eoaposielons was: Ub A + 12.02 Ub B 11.62 . He feel that these results deaonstrate the importance ef evaluating the precision of any PCB procedure. Vote that the test did not include stapling problems, used distilled water free of Interferences, and was carried out at a relatively high PCB level (500 ppb; 500,000 ppt) by two experienced laboratories. It is expected that, if stapling problem: were involved,, and the level of PCB present was extreaely low, the accuracy and precision of any PCB aethod vould decrease considerably. 183 10070j TOWOLDMONOOOI394 10- .' BACKCROUNP FOR FROFOSTP PA tTTICgr STANDARD. |* In tbc establishmert of the proposed effluent itudird the primary basis for toxicological consideration ease fron tba Wator Quality Criteria. October, 1973. (Federal Register, ?ol. 31, pages 29646 et seq., Friday, October 26, 1973)* These criteria vere, la turn, based oa Water Quality Criteria, 1972, by the Rational Acadeay of Sciences aad the National Acadaay of Eaglaeerlag. . * a The Veter Quality Criteria, October. 1973. have not undergone the cornel revlev, criticism, consent aad revision before final adoption. Ve object to the use of ehallengeable portions of a proposed publication in the development of critical affluent standards. Ve note la Water Quality Criteria. 1972. la those sections pertaining to polychlorinated biphenyls, the frequent use of unpublished data and the disturbing use of qualifying phrases sueh as "...may adversely affect."...apparently related...", or "...tbe work...suggest..." Zn our opinion, none of the discussions present adequate data to support establishment of responsible effluent standards for FCBs. On psge 5 of Water Quality Criteria, 1972. the Cosmictee emphasised the importance in understanding that there is a distinction between criteria aad standards aad that the vords vere not interchangeable nor or they synonyms for vords sueh as obiactives or coals. The report further states that it is necessary to establish sclentifleally-bssed recommended for eaeh assignable vater use, implying availability of practical methods of detecting and measuring vhleh ean be applied to monitoring. Once these fundamentals are available, political, soelal and economical factors enter into the decision-making process to establish standards. In our opinion, these procedural steps vere not followed in arriving at the proposed effluent standards for FCBs. ' The maximum acceptable concentration in fresh vater that would be permitted by the proposed standard is 0.002 mg/1. The rationale described *in the Statement of Basis end Purpose, Toxic Pollutant Effluent Standards is based on results of a preliminary study which have suggested (not yet proven) a threshold FCB level for salmon egg mortality. Ve eanaot aeeept the selection of salmon as representing organisms vhieh are usual or may potentially be present in vater systems near facilities described in Section 129.09, Code of Federal Regulations. The cumulative sales of FCBs in the Waited States since 1930 has been estimated to be about 500,000 tens and that total world production was probably 1,000,000 tons (1). About one-half of the FCBs vere used in applications where containment was difficult and losses into the environment vere eommon. With this amount of material discharged into the environment, it is of considerable importance to note that extensive barm predicted by some theories has not been found and documented. 184 100701 .<*1 TT TOWOLDMONOOOI395 *11' This lack of evidence indicates that all of the FCBs do net persist In the environment as a result of feetors sueh as the blodegratlon ve hare discussed previously. Also, the FCBs thai. do persist say not be available because of none factors not elearly understood at present. One characteristic which undoubtedly Is of significant importance Is the ability of FCBs to adsorb tenaciously to particulars natter. Under these conditions, can FCBs be rightfully considered to be environmentally active and. If so, to what degree? There exists at present a critical need for data relating to partition eoefflelents between water and sedinents and diffusion coefficients in sedinent (1, 22 , 39, *0). Although nany reports have bees published os the subject of poly, chlorinated biphenyls and living organises, the najorlty of these describe the presence of FCBs la the eavlroaaent. Fresenee should not be assumed to imply adverse effeet. To our knowledge, no published report exists vhieh conclusively relates the nortallty of any wildlife speeles to the presence of FCBs. The only reported sortallties are those achieved la laboratory studies. Hot enough Is known about the fate and effeet of FCBs la the natural and diverse aquatic and narlne environments to properly design laboratory studies. Results froa sueh studies are not extrapolatable to the natural situations and any conclusions derived froa sueh studies aust still be considered speculative. Fundaaental scientifically-based data is lacking and. In Its absence, the establlshaent of effluent standards for polychlorinated biphenyls cannot be cade intelligently and responsibly. Xn the establlshaent of the FCB effluent standard for freshwater systems a bloaecuaulatlon faetor of 200,000 was selected. This factor has no extrapolatable relationship to either the residues of FCB in salaon eggs or to FCB residues of fresh water forage fish. The only published report (27) of an accumulation faetor of the nagnltude selectee was that for the hepatopancreas of the pink shriap, Fenseus durarua. Evan though an aeeusulatlon of 204,000. la the hepatopancreas has oecurrec a nearly eosplete elimination of FCB from that tissue was aehleved when the shrimp were plaeed in water free of added FCB. The equilibrium whole body accumulation plateau indicated an approximate accumulation faetor of 22,000. These results are In agreement with those reported by Stallings and Kayer (29), and with the studies of Ryther (28), Creiehus et al (24) and Crump-Velsner, et al (22) showing equilibrium blosagalflc, tlon factors between water and fish ranging between 1,000 and 75,000 depending on the presence and absence of sediment and the specific FCB sdxture present. These data would support the selection of a factor considerably lover than the factors whleh were applied. o 185 100703 TOWOLDMONOOOI396 . . .1 c J 1 3 I ' J Arbitrary uftt; factors vert applied te the tolerable chronic Halt to establish the oo-ealled "critical ehronle Halt" vhleh vac then need to compute the aexlaua elloveble effluent. These safety factors were proposed to eeeouat for a auleltude of variables Including non-point sources aultlple discharges and Industrial grovth. The safety factors proposed vere identical for 7 of the 9 materials for vhleh effluent standards vers prepared. These safety feetors* resulting in approximate! two-fold reductions, are so snail as to be ef no benefxelal toxicologies! consequence. We reeosaead that no safety faetor be applied.' * In establishing the effluent standards, an attenpt vas aade to distinguish between types of receiving vsters by classifying then as streams, lakes and Impoundments, estuaries and cosstal voters. We do not believe this attenpt to distinguish water bodies is by any measure adequate. Water bodies are universally known to be conplex systems with no two systems alike. With a complex notarial such as poly chlorinated biphenyls, the determination ef possible adverse effects in each voter body becones exceedingly difficult. The uniqueness ef each voter system at eaeh point souree must be considered. A key parameter need to further deaeribe the water body is the flov race vhleh was limited te the probable low rete ef stream flov occurring during a seven-consecutive-day period once in tea years. We do not agree that this is realistic or appropriate. In eur opinion, spprepriatt control is achieved using average stream flov rates. Further# the naxlmun flow rate that can be used in .calculating the dally discharge permitted haa been arbitrarily set at 10,000 cuble feet per seeond. This limit is based on s nondegradation philosophy vhleh tolerates United diffusion and on a desire to dlseourage industry from locating facilities on large nain inland waters and coastlines. This limitation deprives eur society of the.Judicious use ef an important gre; natural resource. Discharge limitations should be based on the effects ' a naterial will have on a water systen, giving consideration to its sise * and flov rate. For FCBa, proper control will not oeeur by Imposing maximum flov rate conditions, but by applying results from scientific, studies which properly define how each water system responds to the presence of FCBs. - PZSIDUAi FOLYCHLORIKATZD BIFHESYLS Because of their chenleal and physical properties, FCBs esn be found la soils and waters at point sources long after a discharge has occurred. This source ef FCBs to the environment will diminish with tine but Its presence will distort and nask results froa current control activities. To maintain control of leases, emphasis should be directed toward discharges resulting froa current and future uses of FCBs. 186 1 0 07 01 . TOWOLDMONOOOI397 ) -13 Since this problem of background lords oecurs vlth *11 materials la varying degress, wo propose the following revisions: Prom Seeeloa 129.Ole(b), delete the words "la lateke waters for discharger" Add sa additional definition In Section 129.01s: " 'Background' wcaaa aaouats of toxic pollutsat # (1) presently found la the waterways of the Halted ' .* .States (laeludlag the lateke waters of * discharger) ( . ` or (2) arising out of operatloas aubjeet to this Part that occurred before the effective date of this Part, but were not discharged to the waterways of the *; Baited States before the effective date of this Part." ECONOMIC CONSIDERATIONS At our PCS manufacturing facility, we developed aad Instituted an aggressive control progrsa whieh we described before the Effluent Standards and Hater Quality Zafornatlon Advisory Committee, EPA (41). let, in spite of all our efforts, wa eaanot today meet the proposed effluent standard. ; In response (42) to an Inquiry fron the D.S. Department of Cosaeree, we emphasised that technology has not been developed to the point that facilities eould be designed to sect a reasonable standard. However, .analytical techniques suggest a conceptual design using sdsorptlon, settling and filtration of aqueous waste, folloved by incineration of the adsorbent, probably carbon. He estimate the capital cost of sueh a facility, sized to handle our plant waste, at $600,000, not including a dedicated Incinerator for the disposal of the adsorbent material. ^ Annual operating cost would approximate $150,000. 'The value of Monsanto's annual PCS production Is about $8 million, while the value of the electrical devices made therefrom Is aa order of magnitude larger. If Monsanto were to cease production of PCBs, the jobs of 55 employees would be eliminated directly, while those of an additional 47 employees in a supporting facility would be la jeopardy. The total payroll involved is oa the order of $1.5 million. The lapses of a PCB baa on our customers can best be described by them.*" However, it is apparent that capseltors or transformers made without PCBs will be less fire-resistant than present products, thus leading to an undeterminable incidence of fires, higher insurance rates, and additional protection facilities. Zn the case of capacitors, the replacements are likely to be larger and less efficient, thus consuming more of the resources required la their manufacture. A more complete 187 jOOTOr, TOWOLDMON0001398 -14- ) analysis of the consequences of a ?CJ has vat developed by ibe General Electric Ceapaay and addreeaed to Dr. Martha Sager, Chalnan, Effluent Standard* and Water Quality Advisory Cosalttee, EPA (43). We eoneur with the General Eleetrle Company's conclusions. Our purpose la eonanting on the proposed standards Is to aid the Ageney la the developaeat ef realistic affluent atandards vhleh vill achieve the Intended objectives without serious technical, aoelal and econoale disruptions. He reeogalxe the seriousness of this endeavor and find a stateaeat aade by Mr. John t* Quarles, Jr., Deputy Administrate: Eavlroaaental Protection Ageney, of considerable laeereat. At a recent conference, Mr. Quarles (26) stated! "Ve have found It virtually lsposslble to devise Intelligent standards which specify an appropriate degree of control over texle pollutants Irrespective of the sources of those pollutants and factors effecting the feasibility and timing of their abatement." .* The difficulties, vhleh eould be anticipated In establishing affluent standards were recognised by the Katlonal Aeadeay of Science in Its preparation ef Water Quality Criteria, 1972. Zn a review vhleh appeared in the Environmental Reporter (38) dated August 24, 1973, the following pertinent statements highlight some of the areas ef eoneera: "Knowledge of loeal environmental conditions is ' essential prior to application of any water quality recoaoeadatlons for marine aquatic life and wildlife..." ` "HAS said application ef reeoeaendatlons to a loeal situation Is unique because It requires an under * standing of the circulation ef water and the resultant nixing and dilution pf pollutants, a knowledge of bio logical speeles and determination of the most sensitive speeies, and an evaluation ef the transport of materials through the food web." "NAS said it is not practical to make recomendatlons for the relatively persistent organic pollutant based on weter concentration, especially when partition coefficients are unknown." *` a 288 300700 TOWOLDMONOOOI399  -15- ) e ean ipprieliti Kr. Quarles* eeaem, particularly as it ippllu to PCBo. Laeklat good elaatlfie Information ea the fata and affaeta ef PCBs la eosplex water aysteas aaeh having unique characteristics, we urge extress care be taken to avoid the promulgation of effluent otandarda whieb are unattainable and unwarranted. -Subscribed and avorn to before so Notary Public 289 t TOWOLDMONOOQ1400 ;'o;iuruo C~ ro * t -C W. S. Papageorge B2SK December 9 1974 ?Cs - Minutes of Meeting with NIOSH - 11/22/74 G. L. Sratsch W. C. Engman 0. F. Fort R. . Kelly G. J. Levlnskas J. R. Savage 1740 i t y/ E. P. Wheeler-- A2SA cc H. S. Bergen F. J. Fitzgerald Robert Flint - 1740 D. B. Hosmer Clarence Sweets The meeting was held at the request of Joseph X. Wagoner, S. D. Hyg., Director, Division of Field Studies and Clinical Investi gations (DFSCI), National Institute for Occupational Safety and Health (NIOSH). NIOSH reports to the Center for Disease Control (CDC) In the Department of Health, dv:*tlon and Welfare (DHEW). The participants In the dl~:..;l:n are as shown In the attached list. The original purpose was to explore whether Monsanto had a "suitable occupational group for study" to assess the potential chronic effects of FCBs. To be Included were T,?CB-exposed active and Inactive workers at Monsanto In a planned retrospective cohort study." What this would involve Is obtaining work histories of time spent in ?CB departments, and medical records of active and still-living Inactive employees. ' The study would not be complete without examination of death records of those "PCB-exposed" employees who are deceased -- including those who expired while employed and those who expired after termination of employment because of retirement or for any other cause. * The proposed study was stimulated by a report from Dr. * Kimbrough, Toxicologist, CDC, to N1CSH, that she had found an alarming rate of liver cancers in rats fed Aroclor 1260. Briefly, she found 15 of 100 female rats with "definite hepatic cell carcinoma" when fed Aroclor 12fin at 100 ppm in the diet for 22 months. Only one of 173 controls had the carcinoma. She then described a number of other liver tissue effects as "pre-cancerous lesions" and found these in 175 of the experimental rats and in Only three of the controls. 000043 190 TOWOLDMONOOQ1401 .* Westlnjhouse Electric Corporation t ItO *t FEB * Scutloran 0rvfen bMpamr 5. in SO Stem Slow jMitaiN|a)4!s tfOltVSTVI ft Sr. V. S. Papageorge Manager Environmental Control Montanto Cocfany '* Organic Ottolcala Division . 100 Kerch Linbergh llvd. . ` St. Louis, Miacourt Miff " Saar Or. Papageorge: . * Attached you will find a lire of questions that have been aakad by our eoployss regarding the uaa of Znartaan. Mr. Carry Vllkuro, our Eaginacring Manager, fait if thaaa questions could ba answered you would ba the man to ansver them. Va have had .in the pact .vert^laea maetloga with our e^loyea explaining proper uaa of Znartaan and tailing them unlaaa it ic consumed, it preaenta no raal danger to tham. Zn answering thaaa questions, hopefully ve will gain uuch needed knowledge on Znarteen and bow to praaent it properly to our eaployea. Thank you for your help. Vary truly yours. Staff Supervlaor Personnel Kalatlona cet George SvSrdoa, Herrin Sovliag # / .. J . .. 191 TOWOLDMONOOQ1402 f) V. Question: Does Znerteen hove permanent effeete on the human body? If so, what type of permanent damage sad how long e period of tiao does it take for this to develop? Zf not, explain why. tt possible. Question: Question: Several hourly esployes have sectioned reeently that aany eheadeels such as Znerteen eesse sterilisation nfter a prolonged use. Za this erne? _ . Since Znerteen effeete blrda and oehar animals, if there is no real effects to hiaan beings, how do you explain it to e^loyss in such a way that they will understand why it can kill n bird end not a huaaa? Question: Zf an eapleye spills Znerteen on his clothing and later eakes the clothing hone to be washed with ocher clothes, will this have any efface on he or hie family and should he carry hie clothes hone he bo washed? Question: Esployss carry Znerteen hose on the soles of their shoes and ceeplaln quite a bit about the effect Znerteen has on wearing oue their shoes. Zs this a serious problea? Hill Znerteen la the soles cad leather of shoes, aver a long period of time, have an effect on the feee end skin slaee the shoe is the only protective equipment we wear on our feet and the Znerteen penetrates through the leather. Question: Qtsatloa: There is one esployc in our plant who had no problcn whatsoever with Znerteen years ego. After sis years of asing, now idiea he verks la Znerteen (which is a part of bis job) he developa a swelling on the inner bicep of his left arm, only in one location. Could this be froa Znerteen or not? Zt goes away as soon as he gets out of the Znerteen. Zt is slallar to the swelling after taking an Injection. Are there hand cleaning aolvent materials that we ahould be nslag when working in Znerteen to eoet our skin before working in it and to wash it off after va finish working fa it? Please give your recouadatioa. Our saployes working in Znerteen era not able to use gloves sines it is an asseably area. Even if they could, the Znerteen would destroy tho protectlva glove. Sianary: Zf there are any questions we have not brought up that you ere aware of, please include la your counts, or any othe; information you can give us concerning the proper use of Znerteen. CBRN 000027 192 TOWOLDMONOOQ1403 Monsanto MOttUOTB WOWttMAl CMMCttC CO. 100 a. !<**** laws. (}) ommi omi uioeo t*anTTt moots SQC*J 0**f. ' February 26, 1975 * * i. Mr. San A. Albert Staff Supervisor Personnel Relations Vestinghouse Electrie Corporation Box 290, Highway *3 Vest Sc.th Boston, Virginia 24592 Sear Mr. Alberts Z have received your letter dated February 3 asking us to respond to a Hat of questions. Since these questions relate to human health considerations, Z have asked our -Medical Department to prepare the response. You should be hearing from us shortly, either from my office or from a representative of our Medical Department. Zf Z ean be of further service pleaae let me know. Sincerely, VBPspd V. B. Fapageorge Manager, Product Acceptability Specialty k Process Chemicals SBftft 00002a * 193 TOWOLDMONOOQ1404 Monsanto (MM UCll V W. 8. Papageorge March 18, 1975 5TDOOUSEV Xnerteen TO B. X. Jbrd St. louls B2SK C. faton . f. Wheeler J^Woo* Attached la the original of a letter addreaaed to Mr. Dan A. Albert of Westlnghouse, South Boston, Virginia. She eontenta of this letter have been reviewed with Pave Vood and It was agreed that the letter be delivered by you personally to South Boston, giving you an opportunity to dlacuBB with the Weetlnghouee representatives the proper approach that nust be taken in presenting this information to avoid undue concerns and sisunderstandings. Will you please deliver this letter as soon as practical. V. B. Papsgeorge /pd * M-H (. ** CBfth 0C1640 194 TOWOLDMONOOQ1405 i Monsanto 00 M. U#r|* .l*rt tl. Uait. Miitxn Ulll MM: 0141 M-I000 March 18, 1975 Mr. Ban A. Albert Staff Supervisor Personnel Relatione Vestlnghouse Electrie Corporation Highway 58 Veat South Boston* Virginia <1593 . - Bear Mr. Albert: Attached are responses to the questions Hated In your letter dated February 3# 1973. Zn 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 Znerteens to prevent their eseape into the environaent. Also* In discussing this Information with your employees* I strongly recoraend that the perspective gained from over to years of experience in which no human harm has resulted* be emphasized. In summary* the proper handling of Znerteens should pose no environmental or human health problems* permitting society's continued use of a very valuable material. Z hope the above Information Is useful to you. Zf Z ean ' be of further service please let me know. . Sincerely* * ** if< SJ. V. B. Papageorge Manager* Product Acceptability Specialty k Process Chemicals VBP:pd Mill *1 Ml GdflN 0016*1 ... 195 TOWOLDMONOOQ1406 V. 1. Question: Dues Znerteen have peraanent effects on the human body? Zf so, what type of permanent damage and how long a period of time does It take for this to develop? Zf not, explain why, if possible. The polychlorinated biphenyls in Znerteen can have peraanent 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. Zn 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 eause either the skin eruptions or deaonstr&bl liver Injury. She 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 organic ehemicals are Irritants. Beeause of their "solvent" action In removing the natural fats and oils from the skin, leaching, drying and chapping, repeated and prolonged skin contai should be avoided. When the polychlorinated biphenyls are mixed with other chlori nated hydrocarbons, the mixture may be classified at a ekin irritant. The potential toxic effects in humans from excessive exposure to polychlorinated biphenyls Include Injury to the liver and chloraene. Zn animals, the liver effect Is demonstrated by Increased liver weights and Injury to cellular tissue. Although chloraene Is difficult to evaluate In animals, in humans, this take the fora of comedones (large blackheads with typical acuce 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 - "Chlorodlphenyls" attached.) 2. Question: Several hourly employees have mentioned recently that many chemicals such as Inerteen eause sterilization after prolonged use. Zs this true? There is no evidence that polychlorinated biphenyls eause "sterilization" in humans. bbRN 00I6<*2 196 TOWOLDMONOOQ1407 V. 5> ) 3* Question: Since Inerteen effects birds and other animals, if there Is no real effects to huoan beings, bow do you explain it to employees in such a way that they will understand why it can kill a bird and not a human? Sbere is a potential real effeet to humans - ineluding death as discussed in the answer to Question 1. Ike 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 partleualrly sensitive to many chlorinated hydrocarbons including polychlorinated biphenyls. 4. Question: If air 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 elothes home to be washed? There should not be'any effect on an employee or his family from home laundering of work elothing. If washed with other clothing, there may be residual odor of the chlorinated hydrocarbons in the clothing. 5. 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. 6. 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. . CBRh 0016*3 19? TOWOLDMONOOQ1408 ! Ve do not believe there ean be any association between "a evening on the inner bleep" of the an and exposure to polychlorinated biphenyls. 7. Question: Are there hand cleaning solvent materials that we should be using when working in Znerteen to coat our shin before working in it and to wash it off after we finish working in it? Please give your recommendation. Our employees working in Znerteen are not able to use gloves since it is an asseably area. Even if they could, the Znerteen would destroy the protective glove. Ve 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. bSRh OGlo** 198 TOWOLDMONOOQ1409 c C HYGIENIC GUIDE SERIES Chlorodipfcenyls (Containing 42% and 54% Chlorine) (x y 3 or 5) Significant Physical ftiywtin1 . The tkMiphnrli in lifhi siraw<aliid wUi (42% cfcleriaated) and vweoiu (54% afclorinaird) Naiidi with typical chlorinated atoaiotic odors. The* compound! art chlorinated la specific wtifhu W chlorine. CMorodipbenri (42%) eaaiains 42.0 S 04 chlorine, on amount anrne|wndin| to three chlorine atoms in tmaaaifnsd pmilieiu Chlorodiphenyl (Sl%) contain! 04.1% chlonne coneepoadiai la Ove chlorine Moms ia anusifnrd petitions. Beth compound! an Intolubie in water, hut mluble ia htamnt, tsraaeni, acetane, amyl alcohol, ether and Mnlsntlsr might: IWi ^sht (Osvslsnd Pistillnino mate: tparili tenuity: Vapor Somme: 0*C t5*C IS0*C 100*C Al 2S*C and 7*0 mm M|t (arurosed air amiaias 1 mc/litm Iron* 247.55 12S`.iOO*C CMf.JM'F) S25*-SM*C !5IM5n <25yi5J*C) 0.001 mm ' O-OOCmm (an) 4J mm 2* 0 aua e.00 mc/Swr MJppm 0.010 mc/listr CUsfoA>**syf (54%; 020.45 None OtS*>2SO*C I.4I5I5CS (05715.5*0 0.00000 ami 0X0054 am (t 1.4 mm Maa 0.000 mc/tiicr 54J ppm C.0IJ aw/littr I. Hygienic Standards A. lUeOMMCWDCB MAXIMAL ATMOSFHtXJC OONcaMimATsoNC (0 hours): One aiHli. grant chlorodiphenyl (42%) per cubic meter at air and 0.3 milligram ehlorodipheoyl (54%) per cubic meter at .' This is baaed on the remits at ths ftaeieo riia MmMs Ua mamma f CU mdaal letwwsiae am el Oe b>o Ot ria Uant Hum sad flwl TeiiWl CmiM aS IH. h, as a atanisn da Ua --anew af Cam . M ad |m T. Carom a ska imra al ska chronic animal inhalation studies.* B. Smoot txnivu tuujuncc: Ten ny at a diphenyl at unspecified chlorine content per cubic meter of air hat been reported as unbearably irritating.* C. Atmosokmuc concentmtion isi atcor* amr nataaoovi to urs: Not known for man. Irritation of the eyes, nose and throat at levels which have not caused acute illness preelude the likeli* hood of voluntary exposure to immedi- tcly sMieeiitribofU. 4 assN ooi*5 199 TOWOLDMONOOQ1410 V l /tstsy^fimiy, 1X5 0. TilNfMti Humaa earn of chloraene have not A. iMNAUnoN: Experiment! with chlorodiphenyl (429 chlorine) wen tm at concentration! of 13 pg/litcr and at CAS ac/liter of air. Can, mice, rabbin and ran were unaffected br die higher Inal while guinea pip snowed poor growth after seventeen 7-hour/day *r- Elite cm 24 days. Eighty-four 7r/day exposures at die lower can* bees reported from the use of these two speeifie chlorodiphmris. The potential undoubtedly gusts because of which sett* repotted from the use of cUorediphenyb with a higher chlorine cootmt and from mixtures with other chlorinated aromatic compounds.*-*-* C. Err eoirracr: The Squid products and thcirvmpor* art modentsly irritatiiig to centration had ewenrialty no affect on dmibr species of animals.* 9. Incsmosi: The acute era! tenodue of In the can of chlorodiphenyl (54% chlorine) eighty-thrre 7-hour/day oxpenirtt mar 121 dayi to a eonemtra. den of 5.4 mr/liter renilted in injury to liver talli ana inertued liver weights in rata At a concentration of 13 ng/liter for one hundred and fifty 7-hour/day exposure! mar 213 data, the fate die imdilutad cosnpounds are not great a* evidenead by oral LDm's in ran of approximately 1.65 gm (731 to 9.75 gin) per kilogram for the 42% chlori nated and 113 gm (10.45 to 13.45 gm! per kilogram for die 54% chlorinated.' Central atrophy of the Kver appear* to he the chief toxic effect. hewed distinct miermeopic changee fat the liver.* IIL Industrial Hy|iona Practice The literature contains many refer* men to the potential toxic effects of chlorinated diphenyls in man and ani* seals. The early work included investi* galions of chlorinated naphthalenes, A. Ismcmrat vacs: The cMorodiphenyls are toed as dielectrics for condensers, capacitors and transformers, plasticisers in synthetic resins, in emulsion adhes ives, as nonflammable hydraulic fluids - chlorinated diphenyls, chlorinated aad as oansfer media. diplienyl oxide and various mixturw of these. An early report indicated aerious toxic effects from chlorodiphenyl ehlori- B. Evaluation or Brosvacs: !. Aar sampCag and onafysir; anted to the extent of 659* A later a. Direct field methods: Hone report by the principal author properly identified die earlier sample as a mix* sure of chlorinated diphenyl and chlori* Bated diphtmyl benzene.* However, only a few authors of subsequent papers, bul letins oe textbooks have wed this cor rection and the original data are cited repeatedly as relating So chlorinated diphenyl alone h. Laboratory methods: (1) Collect in secondary butyl alcohol in fritted bubbler or two large tmpingert in tews; concentrate sample and complete analyst by one of various methods for chlo rinated hydrocarbons.* (2) Sample air through con- E Suss contact: Both compounds are readily absorbed through the clipped, bstaet skin of .rabbits. The minimum lethal dose when the undiluted mate* riab were applied to the covered cByycd, mtact skin of rabbin for 24 hows was approximately 13 gmAg for C Hamids bunion furnace, collect chloride ion from decom posed chlorodiphenyl an suitable alkaline solution and determine chloride ion con centration.* ana Titus bscommkmpco (he 42% chlorinated and 13 gm/kg for sontsk: the 54% chlorinated.* . L /mAotorioa: Absorption a chiefly by Local action on the Ain it similar to that of common organic solvents where inhalation. Concentrations m the workroom atmosphere should be contact leads to removal of natural fan and oib with subsequent drying and saaintained below the recommended levels. Whets the chlorinated cracliog af the skim diphenyls arc used at room tempera- 4 *BRN 00164,6 200 ) t 9 l I I TOWOLDMONOOQ1411 V *. January-Fehruary, I9C5 tarn, the haaid of inhalation h elevated temperatum, the patient oonsidered slight or absent. When should be moved from exposure and these materials art nibjccted to elevated temperatures, the process kept at rest until seen by a phvsieian. Oxygen should be administered if oithar should be completely enclosed breathing it difficult. or other adequate mechanical cx- Eyes contaminated with ehlorodi- boost ventilation must be provided phcnyl should be irrigated with water to raduee concentrations to nfe tor at least IS minutes and the patient levels. In heat transfer media appli- should be seen by a phyiician. Depend entiona, the system must be designed ing on the amount of inflammation and and constructed so that it is kak- pern present, drup like Cortitporin* proof. Special gasket materials and ointment and topical htneanr may ' pump teals art available to prevent be indicated. leakage. The reservoir tank should be airtight except for a vent to the B. Skoal enoeaavaaa: Persons who are outdoors. In the event of mills or regularly or repeatedly reposed to ehlo- leaks of hot fluids, use chemical lodiphenyt* should be examined periodi cartridge respirators or ru masks cally to detect early evidence of skin approved by the U. S. Bureau of briudon and/or liver damage. Persons Mines forjprotfction against organic with known liver disease should not be . vapors. These trill provide good erpostd so repeated contact with the protection up to the concentrations chlomdiphtnyu. shown on the approval labels and the odor will give ample warning if V. flaftrawcat it comes through the device. 2. Skin tenucl: Operations and handl ing procedures should be such as to avoid the possibility of prolonged or repeated skin cootact. Contaminated clothing must be laundered before reuse. - 3. Eye tarnart: Eye protection should be used where there it a possibility of liquid flashes. 4. Ingertion: Ingestion of them mate* rials is not a problem in industry. 1. Monsanto Company, Orgasiie Chemi cals Divtson: Teth. Bulletin dPL-306, Araelor PUiticiztrt (Dec. I960). 2. American Conference of Governmental Industrial Hygienists: Threshold Limit Values for 1964. AMA Arch. Em-iren. Health 9: 54S (1964). 3. Troon. J.F,F.P. Cleveland. J.Cappel, and R. W. Atchley: The Toxicity of the Vapors of AracJor 1242 and Araelor 1254. Amet. /ad. Hyg. Auae. Quart. 17: 204 (19X1. 4. Elkins. H. B-: The Chemiitry af Indus 5. Fire ui eeplenen: The chlorodi- trial Taaicelegy. John Wiley and Sons, phenyl* are fire-resistant or euenti- Int, New York (1959). ally nonflammable liquids. When 3. Drinker, C. K.. M. F. Warren, and G. asepenrri to flame or hot mrfaeee A. Bennet: The Problem of Pouible they may decompose to form CO, Systemic Effects from Certain Chlori CO,, HCl, phetolies and aldehydes nated Hydrocarbon*. /. Ini. Hyt. Tee depending en the temperature,avail* . ieal. 19: 283 (1937). ability of oxygen, area of the healed C. Drinker, C. K.: Further Observations surface, rate of application of the on the Pbasible Systemic Toxicity ol liquid to the surface and other Cataia ol the Chlorinated Hydrocar variables bon. /. Jnd. Hyg. Taaieel. 21: 155 IV. Medical Information * 7. (1939). Wheeler, E. P.: Persenal Communica A. EssaaetNev TncansawT: Skin airfares tion, Monsanto Company, Sl Louis, exposed to chlorediplmyls should be Missouri 63166. thoroughly washed with soap and water 8. Greenburg. L., M. R. Maven. and A. at ones If clothing has been contami R. Smith: The Systemic Effects Result nated* it should be removed promptly. ing from Exposure to Certain Chluri- If cxponste to a high vapor concert, stated Hydrocarbons. /. Ini. Hyg. nation occurs, as in the case of spills at Ta*UoL2l: 29 (1939). L 6BRN 001&4*7 t ii i t 201 TOWOLDMONOOQ1412 CM N. L kim LLCuiruu J. W. ClATTOM K. I. turn r. d.iuuct HYGIENIC GUIDES COMMITTEE Kui Hm J. A. Nmnw D.ILMcFu J.M. HeNisMtr.lt. J. I. Outuimi Z. A. hmu U.C.FMIMI ILL-IUimu W.LIima ICWmn C.LWem> Hi|Mc Guide Atrru BUT W aktaiacd Inn At umieu tawmw otbkki aseecu* wen. MI2J Prevent. Detroit 17. Mickwaa. M 25 renir earh (er me mi repnau; 10 emu each for laii-ai|t reprint!. Ail etden (or lm than 52 00 auai fee prepaid. Diaceuai at 20*% an ardrn afire er wm Cvirtn, 409 diacatiru ea ardrn e( 100 er mare Cuidn Special lent leal kieden ler tkc Guida may alia k* ardered (ran ike Anociriiea ate far $1.25 rack. I <abRh 00164b 202 TOWOLDMONOOQ1413 April 18* 1975 Dr. George Roush. Jr. Mennnto Company 600 North Lindbergh Boulevard St. Louie. Missouri 63166 . Dear George: X fully appreciate that the meeting on PCB'e today was not completely satisfactory and that many nagging questions remain. The enclosed is a brief summary of my personal views and X 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 agendas. We will be pleased to bo of help in any way that you may wish. '*** It is my feeling that we seed to get together again within the next few weeks to continue our discussions. Very truly yours. JCCsAR J. C. Calandra President cc - Dr. George Levisskas . ;. . Mr. Elmer Wheeler . . Mr. William Paptgeorge ; . v 1007-mi 203 4 S* TOWOLDMONOOQ1414 BIO-TEST AfcmfMfx1. Sme. REVIEW OF PCB MEETING . . The central issue ia question is whether the FCB's are carcinogens or not. The long term studies conducted at BIO-TEST indicate that the answer is so. X>rs. Ward Riehter 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 n rats. SIO-TEST has no basis for refuting the findings of Kimbrough except to take exception td the design of the experiment that uced 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 Kaneehlor-400, a commercial brand of PCB and ia a rat study of 400 days* duration concluded that "FCB'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 "speelfie or non-specific stimuli are introduced into the animal. " _ 100/3 204 G 02 TOWOLDMONOOQ1415 BIO TEST 2*i*aUMU. Sme. 2 Ito2 conducted a study la mice sad fouad "hyperplastic nodule and well-differentiated hepatocellular carcinomas" at a dose level of . * 500 ppm of Kaaechlor 500. Hepatocellular carcinomas were not in duced by Kanechlor 300 and Kaneehlor 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 carciaoma. Rats also are more resistant to the induction of these lesions than mice. To return to the BIO-TEST studies on FCB, it should be noted that the liver sections which were read by the pathologists and reported in 1BT No. 641-06672 and dated March 24. 1975. were not the same slides or sections as those reported on 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 205 1007? TOWOLDMONOOQ1416 fm/miftiaf BIO TEST Ac S' eliminate aome of the eevmrianta. The important point in the moat - recent study of the aectiona is the fact that no hepatocellular careinomas - - were found which is in agreement with die earlier findings. It mu at be emphasised that the diagnosis of 'hepatoma*1 by Cordon and Riehter 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 Aroelor 1260 with Drs. Cordon, 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 B20-TEST findings. Dr. Squires has stated in a letter to Dr. Kimbrough dated November 12, 1974, that *1 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 aecept or reject the view. Drs. Richter and Cordon 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 206 10073: TOWOLDMONOOOI417 f Ja/mihiat BIO-TEST JaLinfMint, /we. 4 of the final BIO-TEST report on chronic oral toxicity studies. One must note that Popper* la his studies on Aramite in i960 postulated that . hyperplastic nodules were transformed into hepatocellular caneer; however, this concept was not generally accepted by the scientific community. ` * An excellent paper whieh describes "the highlights of some newer developments in our understanding of liver carcinogenesis" 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 hepatocytosdc 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. 1007 207 TOWOLDMONOOQ1418 iai BIO-TEST Sma, 5' It is important to point out the .following: 1* The BIO-TEST petition 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 Aroelor 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 hyperplastie liver nodules to be pre- eaneerous. 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. 98:145 (1974). 208 ..rwx 100 iiJO TOWOLDMONOOQ1419 0 V Monsanto UtNMIl C* 00 N. iMlMTl Si. iMf. WitlH* Ulll Hnk 014 M>l000 July 18, 1975 Sr. J.C. Calandra Industrial BIO-TEST Laboratories 1810 Frontage Rd. _ Northbrook, 111. 60062 re: AROCLOR 2-year Rat Feeding Studies Sear Joe: . The attached table summarizes a comparison of the 3 revised AROCLOR reports (1242, 1254, 1250). In 2 Instances, the previous eonclusion of "slightly tuaorigenic" was changed to "does not appear to be carcinogenic". The latter phrase Is preferable. Kay Me request that the AROCLOR 125^ report be amended to say "does not appear to be carcinogenic''. The number of hepatomas reported for AROCLORS 1260 and 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 renumoered when the new slides were made and that a key relating to the sets of numbers f r 10073? wia.TP^T TOWOLDMONOOQ1420 f Dr. J.C. Calandra July 18, 1975 Page - 2 - c would be supplied. Shis has not been done. It stay not be necessary for AROCLORS 1260 and 1242, but AROCLOR 1234 rea&ins unresolved. Insofar as Z can aee, the remainder of the reports appear acceptable. . Kindest personal regards. Sincerely, George J. Levlnskas, PhD Kgr., Environmental Assessment and Toxicology /bkp att. cc: Dr. George Roush, Jr., M.D, 10073t -210 TOWOLDMONOOQ1421 Product Suppleaental Report #1 (called) _ AROCLOR 1260 conclusion lightly tuaorlgenic hepatomas 3 range of test animal nos: P. 9 p. 10 6oo to Boo 1000 series p. 11 70 to 100 p. 12 500 to 600 pp-. }134 600 to 700 700 series Supplemental Report #2 (JCC delivered) does not appear carcinogenic 7 100 to 300 Boo to 900 10 to 40 80 to 200 200 to 300 200 to 300 AROCLOR 12 ?4 conclusion hepatomas slightly tumorlgenle 6 slightly tumorlgenle 6 AROCLOR 1242 conclusion slightly tumorlgenle does not appear carcinogenic hepatomas 7 3 range of test animal nos. as in report #2 as in report #1 for AROCLOR 1260 AROCLOR 1260 an 1007 A TOWOLDMONOOQ1422 V.*! ' :'V? Aa|it4i 1975 . Dr< Cerf J. Ltvlaibi. Wau|r Bnviroamentnt Aimimtat and Toxicology Uoauote Company 00 North Lindbergh Boulevard Su Louiii Missouri 43166 Door Coorgo: Fe; Aroclor - 2 Ysar Rat Studiss Xa regard to the comment* and questions covered in year letter dated July 18, 1975, pertaining to the above, please aote the followiog: 1. We ariU amend our statement in the last paragraph oo page 2 of the Aroelor 1254 report to read, "does not appear to be carcinogenic" in ptaee of "slightly tumorigeaic" as requested. 2. Zn 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 aot renumbered. 4. Wo cannot find any discrepancy in animal identification umbers in the reports (original, rs>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 le the basis of your confusion. 2 hope that this will serve to further clarify the situation.. Thank yea for your asalstaaee and cooperation. Slaeercty yours, : J. C. Calaadra President 1007 212 (, 0213B TOWOLDMONOOQ1423 *CFntf OF ENFORCEMENT Monsanto Industrial Chemicals Colony <00 N. Lindbergh boulevard St. Louis, Missouri #3166 Ccatlsaent Keeent governmental stapling data indleafis tbs presence of Polychlorinated Biphenyls (PCBs) end comparable chemical substances in the sir, in water bodies, end in fish in several areas of the country. In order to deteralne the nature and extant of the possible adverse effects resulting from the presence of PCB compounds in the - - environment, the Environmental Protection Agency (SPA), in cooperation vith ether federal and State agendas, is attesting to determine the sources end anounts of PCBs entering the environment. It is laportent that this effort be carried out without delay. ' .. It is our understanding that your eeapaay bandies PCB conpounds or mixtures or conpareble chemical substances in its operations. I aa therefore requesting, pursuant to the authority provided by Section 308 of the Federal Water Pollution Control Act, as aaeaded, 33 U.S.C. 1318, and Section 114 of the Clean Air Act, as amended, 42 U.S.C. 185 7c-9, that your company furnish SPA with infemotion pertaining to your nee end handling of PCBs and eonparable chemical substances. In addition to a general description, which should include information as to sources, quantities, uses, and ultimate disposition, you should respond in detail to the enclosed questions. If any question Is set applicable to your eompany or operations, please so Indicate by responding *!not applicable." ~ * She information requested herein must be provided notwithstanding its possible characterisation as confidential information or trade seerets. tShould you so request, however, any information (ether than * affluent or emission data) whieh the Administrator of this Agency determines .to constitute methods or processes entitled to protection as trade seerets will be maintained as confidential, pursuant to procedures specified in 40 CFR Part L. t ADM 0062' 21^ TOWOLDMONOOQ1424 . - . 4 t 1. . -- Within 14 dave of rtetltt of thla letter, your cospany oust ^provide Ell Anfopsatlon concerning your current status and aetlvltlaa and covaslng the twelve aontb period isaedlstely preceding receipt of .Sfctn *Cter. -- . Within 30 days following raealpt of this latter, your eospany auit provide all infornatlon for all of tba prlor pears Indicated. The Information required herein should he^ewtvdlreetlT to the addrees Indicated below. If you have any questions you nay rail the parson indiestad below or Hr. Hake A. lilu of our offlea 6A*202)-755-#s7Jl. * We appreciate your proapt eooparatlen In this natter. Soeloaura Regional Contact: - * Hr. Earl J. Sfiepiicaebb Director, Enforcement Division Envlronaental Protection Agency 1735 Baltlaore Kansas City, Kiasourl 64108 Telephone: (816) 374-2576 !. x /* d` j ADM 00629 214 TOWOLDMONOOQ1425  ** POLYCHLORINATED BIPHENYL (PCB) COMPOUNDS OR WirmBPg ' . " Vlthln 14 days of receipt of this letter* your coapeny oust orovldt <11 lnforaatign concerning your current otetue end Activities -on7*eoverlng the,twelve eostk period iaaediately preceding receipt of this letter. ' '. * Within 30 days following receipt of thls letter. your eeapany use provide oil infemotion for oil of fbe.jjgttiatftto Indiested. for purposes op this unn, the phrase ^affiadPODKD oh MIXTURE" INCLUDES ALL CHEMICAL SUBSTANCES SKflUN or believed *y TOO TO IE PCI COMPOUNDS OH MIXTURES OR OP A SIMILAR CHEMICAL MATURE, IRRESPECTIVE OP TRADE NAME, AND SPECIFICALLY INCLUDING W CHLORINATED TEM>BESY1_S. . 1. for each PCS coapound or sizeure produced or isauUuLbr your coapsny, for each coapeny facility, during each year of 22Li 1972. 1973. 1974. end the first two Quarters of 197St The total oaount of eaeh PCI eoapouad or alxture produced' or laported. ' . . h. The none end address of each of your coapany*a facilities ri^, which handle PCS eoapounds or mixtures* (including production ( facilities and wholesale and retail outlets), and the _ oaount of eaeh PCI coapound or alxture distributed through * each facility. * c. The naae and address of eaeh custoner of eaeh PCS coapound or alxture, the aaount of each PCS coapound ox alxture . obtained by eaeh eustoner from eaeh facility, and eaeh ..tHRtPJReR'aidailvexyvpeinoCa) tfor^the/'rafedipt'-Wf**difh'*PCS% "" r.. - V'* coapound or alxture. ;* 2. For each PCI coapound or alxture incorporated by your coapeny into its produets, for eaeh coapany facility, during eaeh year of 1971, 1972, 1973, 1974, and the first two quarters of 1975s . % .* a. A description of eaeh product/ ' . .For each produet the total aaount incorporated of eaeh PCS coapound or alxture. C ADM 006292 21 JU5 TOWOLDMONOOQ1426 * 2 (continued) * ' *0* *ch frodset th uat sod Address of steh soures from whieVpour company obtained eaeh fCI compound er slxturc, mad the aswuntjof etch PCS compound ^srjplxture obtained from each source. ` . " ' ` 1""' ' d Die sum and address sf each tof your sfeellltles Vhleh handle sueh products (Including :tien facilities and wholesale and retail sutlers), of Meh product distributed through aaeh facility. a. the nsne and address et each cuttoner of aaeh produet, and l| the amount of each produet obealned bp aaeh custoaer iron U each facility, for consumer preduets list only the total 1 production of aaeh product at aaeh facility and the total I member of customers, ho mot provide the mama and address 1 mf aaeh custesar of consumer products. 3. Per aaeh PCS compound er mixture mead by your company in its operations other than for incorporation into its products, for aaeh company facility, durlat aaeh pear of 1971, 1972, 1973, . 1974, and the first too quarters of 1973s * * .* * ' a. A description of aaeh use. _ - b. Per each use the total amount of aaeh PCS compound er mixture. ` ^ c. Per aaeh use the name end address of each source from which ,, ,PSuJ-A9sTy^y-?^l`iJStd. .each.BPA.rqmpquad^-Oixtore^ead.the^-~-- ' amount of aaeh PCB compound or mixture obtained from aaeh * source. . .. 4. For aaeh PCB compound or mixture reclaimed by your company, V for eaeh company facility, during aaeh year of 1971, 1972, 1973, 1974, and the first two quarters of 1973s ' * . p# . . a. A description of aaeh acthoA-of reclamation. * .* Per aaeh method of reclamation, the total amount of * each PCB compound er mixture reclaimed. / 1 c. the total amount of each PCB compound or mixture reclaimed. * * 9 aDM 0062 -- 216 TOWOLDMONOOQ1427 9 -d. Th* nane *vi_ address of aaeh source free which your company obtained PCB compound^ or mixtures, and the __ _=-*uat sf each FCS compound or mixture obtained-from ..*T~"1a`chaouree. -- * -* . - a. For eh method. of reelamatlon.'thsioeatloeof every reclamation site, tbs oast and address :efaaach:-artv tt. ! involved la tbs reclamation of :oseb :^CB:iHBinRd or mixture, and tbs soeust of sseb PCI mixture reclaimed by oseh ysrey. , 5. For sseb FC1 compound or mixture flnotmi of by your company (with or without tbs involvement of other parties), for each Company facility, during sseb year of 1971, 1972, 1973, 1974, . mad tbs first two quarters of 1973: . e. A description of each method of disposal. ' s b. For aaeh method of dispossl the total amount of saeh PCB compound or mixture deposed. * . e. The total amount of each PCB conpouad or mixture disposed. d. The asms and address of aaeh soures from which your wH*..,company obtained PCB compounds or mixtures, and the amount of saeh PCB compound or mixture* obtained from aaeh sourest For aaeh method of disposal, the location of every disposal ' site, the name end address of aaeh party involved in the disposal of each PCB compound or mixture, and the amount of each PCB d. The composition by eheuleal name and percent by'weight of eeeh PCB compound or mixture jujjdueed, imported, sold, reclaimed, used, - and/ortdisoeed of by your company slaee January 1, 1971. * '* ,,*7.' The results of any and all sampling end analysis performed by your company, its agents or contractors sines January 1, 1971, concerning the following: * ' ~ . a. Concentrations of PCB compounds or mixtures in the effluent 1 of any discharges by the company (into waters of the Vnlted States or Publicly Owned Treatment Verbs).gr in the emissions of the company into the air. . ' * * AOM 006294 <2/7 TOWOLDMONOOQ1428 4 -I* Th`t flow and/or composition of any ditehir|ii or missions bjrtbe eosjpahy (Into waters of the Dnltsd Stsess or Publicly ' Oy&ed Treatment Kecks, er late ths sir) vblch cpatala PCB J,-;1 "coapouuda er mixtures. Concentrations of PCB eonpounds mr mixtures la receiving waters (both upstream sad downstream) wf,|ny discharges by the company whleh contain PCB conpotmdiimrmlrcures and concentrations of PCB compounds -:or nlxtursifcin -the air -In the area of the mempeay* ,4 vSMfe' 8. The wethods by which PCB ceapeeads or mixtures are transported to, by, and/or froa your company, including: .' a. A description of eaeh method of trsnsportatiea, and * * the fora la which PCB compounds or mixtures are trans ported by each method. Khare dlffereat methods of trees- portation are weed at different facilities specify which transportation method is meed at each facility. b. The maaes and addresses af all known transporters of PCB compounds or mixtures. . P. All oeeaelons {including spills) of which Jreu are aware on whleh f PCB coapouads or mixtures have or may have been Introduced into . the envlrenaent. la particular, describe eueh occasions insofar as they involved PCB coapouads er mixtures la their liquid state, as incorporated late closed systems, or as incorporated into open systems. Per each occasion, indicate aaae and address of party involved; dates, time, and location of the discharge er I 10. A description ef any adverse health or environmental effects : whleh you know er believe to have resulted from the introduction `af td coapouads er mixtures into the environment. Indicate any speelfle occasions including dates, times, locations, amounts, . ' and pasties involved for whleh such affects are known. ` 11* Any and. all other information whleh you possess concerning: 0 * / a. The production, deportation, reclamation, use, distribution, '* and disposal of PCB coapouads or mixtures. AQH 006295 TOWOLDMONOOQ1429 3 dleeharge of fCS coapouoda or aixtarea loco the aavirement. . Sa addition to the above, STA oonld appreciate receiving any other information vhleh you piiui concerning the dletribatlon and diecharge * af KB eoapounda or:nixeuree fcy aoureea other thsa^our coopany, . including your eoopeny'e eustooere and aoureea. |- . ' - i" * _. . A i J****7rj*ait*i Tb-v **a,*.*-A ^itVW.***** I- .ft i* # i AOH 00&296 r 1^ 21 TOWOLDMONOOQ1430 Monsanto #M| i c- David Wood-St. lmii-B2SO ^Oetobar~30, 1975 f-EPA TO : CQMHXMTS OH SPA LETTER PECO 10-17 V. H. Papagsorge B2SK - - 1. Bill, this seems to be a new ra 2. Page 1. Cl. Terphenyls specifically mentioned. ' 3.a) Production racords auvir 1(a). fc) Remember we varahouaad PCBs for short period 1974 ahaa labor contract renewal. ) Question le raises a problem that has bscn at baek of' my Bind. #2 report is -supposed to show "ship to" address, but if this is case, why do 3rd party tf/GE shipments appear under "bill to" locations. - C 4. Q2 a) Vo problem b) Vo problem . c) Vo problem ' d) Vo problem a) Policy - Hanley level? . 5. Q3-Vo problem except 71/72 . '. . 6. 04-No reclamation. ' 7. Q5-a) Vo problem j * b) Difficult. Can split Dielec/feT/Pydraul ) But some returns mixtures ef .eil/PCB, etc. c) Can do. . ' .*d) Difficult .. * a) Difficult . * 8. Q6 - 'Available .* 9. Q? --a) Guess we have . b) Guess ere have c) Guess we have AON 0062 10. Q8 - a) Bulk Bail Bulk B - 3 accounts " Drum - Specify drum construction b) E. H. Potter, M . *'* 22 TOWOLDMONOOQ1431  1.- 11. 9 Should answer Iren our activity? - - _ ' ._ -' 12. Q10 - Mona? "Imaho? Cloraena*yaara ago - Dangaroua Qutation. ,* ... . 13. fill - a) Might fiat HUB again? b) should writ# this enaivaty aona poaitiva pointa " " y>a.- can ukt Vdab David Wood .V ADM 006289 221 TOWOLDMONOOQ1432