Document LJk2DRzvexden9nzkQpV7DLj3

POSSIBLE CUSTOMER QUESTIONS ON PCBs In the U.S., newspaper articles have appeared in the San Francisco Chronicle on Feb. 24, 1969, the San Francisco Examiner on' Feb. 25, 1969, and the Hartford Times on Aug. 3, 1969. Numerous articles were generated by the Wisconsin "DDT Hearings" in . May, 1969. 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 ^>eaks produced by DDT. In no case was PCB 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 alcove, there have been'radio broadcasts. At the time of the San Francisco Chronicle and Examiner articles, radios in the San Francisco area also carried the story. In August, the sports editor of the Hartford Times syndicated a radio broadcast on the subject of PCBs, and in Dec., 1969,/the Canadian Broadcasting o. (radio) carried an interview they taped.with a member of our mo dical department. Question 2 Were Monsnato's Aroclors specifically mentioned in these article s ? ' If so, which ones? ' l00U9 wqns Answer 2 Monsanto's Aroclors were mentioned in some o the articles but . only in the San Francisco Chronicle story in Feb,, 1969, was Aroclor 1262 specifically mentioned by number. In several of the articles, Monsanto was also identified as the sole U. S. producer of polychlorinated biphenyls, marketed under the tradename of Aroclor. 1 Question 3 What did the articles on the PCB problem say? Answc r Since the outset of the "PCB problem", when the first article, appeared in the U. S. press in Feb., 1969, the whole question has been closely interwoven with the question of DDT as a possible environmental contaminant. . The San Francisco Chronicle article carried a headline, "A Menacing New Pollutant. " In rather sensational style, it identified PCB as a threat to birds and humans, highly toxic in a gaseous j 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 Mothers' Milk. " This article called PCB an "alarming" new chemical pollutant that is playing a role in the declining peregrine falcon population, has U,en found in mothers' milk, and is the "latest addition to a growing list of chemicals in the ocean-------the newest symptom of man's chemical invasion of the ocean. " ' These 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 been misquoted in some newspaper stories. . ' The Hartford Times story called PCB pollution a "new puzzle. " Less sensational than the.San Francisco, articles, the Times gave an account of PCBs being .found in the environment arid the studies under way to determine their biological effects. This article, . says Dr, Risebrough, tends to clear PCB of blame. ' / 3 100130 MONS Articles generated by the Wisconsin. DDT hearings'generally discussed PCB as an interfering1 substance'discovered in scientists' search for DDT in the environment. Dr./Risebrough said at the hearings that there was no proof at the foment that PCB alone can cause thin eggshells, one of the phenomenon . that he had discovered in studying the/declining population of the peregrine falcon. / LEGISLATION Question 1 Arc there any Fodcral/Stat<^/local laws, under which the use or discharge of Aroclors could be prohibited? / Answer No existing Federal, State, or local laws prohibit the discharge of Aroclors, However, in'a number of states the basic water pollution control legislation is so broad that state agencies can prohibit chemicals,- deemed necessary, from being discharged. Question 2 / Is the DDT and the PCB problem related? /' Answer* We are not a manufacturer of DDT or other chlorinated hycJiocarbon pesticide and, therefore, have no knowledge of the seriousness of the charges against DDT other than what has been so widely publicized , 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 more7. / obvious difference. DDT and other chlorinated hydrocarbon pesticides were 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 are not used in this fashion and . lOOl31 4 Monsanto has never sought to promote this. This, we believe, is an important distinction that should not be overlooked if DDT and PCB are linked as a common pollutant of the environment. To our knowledge PCBs have never been identified'in the absence of DST or other chlorinated hydrocarbon pesticides. Question 3 . /' - Could it be PCB that's causing the environmental problems . and not DDT? '. I ' Answer: ; We believe that present-day GLC ajnd mass spectrometric techniques arc 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 PCBs. y" Answer: . . ` . They do have authority to ban or control use of any substances ' they consider harmful. Question 1 EFFLUENT AND ITS CONTROL How do I dispose of Aroclor 1254/1260, etc. effluent from my plant? . Answer: '` We 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. We don't / recommend feeding this material to local sewage treatment plants or taking out to sea in drums for dumping.. These methods do not i MONS 100132 / 5 solve the problem of contamination. We are working on the disposal of these materials by incineration and biodegradation^ Our work in these areas has'not yet reached the stage where/ we can offer practical suggestions. It'is of interest to note/ however, that research is underway fo find catalysts to make DDT self-destructive. The possibility exists that we coulcl find catalysts that would destroy PCBs in settling tanks con structed to catch all your effluents. / Question 2 Can I test my effluent to see if my/effluent has- no Ayoclor 1254, . etc. ? Answer: Yes. Analytical equipment is available that can do this if the proper technique is used. The basis of/the method ; is GL.C or gas liquid chromatography. Are you or anyone in your company familiar with this? Do you'have GLC equipment? If you do, we can send you a description of a method that could.identify PCB. If not,/there may be a good analytical testing laboratory in the vicinity where you could send samples and rely on the results if you want to test your effluent.. / Question 3 What is a "safe" PCB level for effluent leaving my plant? Answer: J ........ -/ 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 doub/as to how absolute any quoted ' values are. To bring this^into the realms of reality, this definition of ppm and ppb/nay help clarify things. To give you a practical example, the escape of one-two gallons per day could lead t<^/-samples in a stream beside the plant showing 10-50 ppb on analysis. ' MQNS 100133 ; 6 Question 4 You must have quite a control problem at your plants--! would think Monsanto's Aroclor plants are/the major polluters--how are you handling control?/ Answer: The Aroclor products wc make to se^i at a profit, so economics dictate maximum housekeeping, minimum loses. The Aroclor process is a "dry process" or closed system. Question 5 / ^ How does Monsanto think Aroclors can got into the environment 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 rive r into my plant ? . / Answer: Analyze water entering your plant and compare. There is a mcthod/availablo 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 ./ j,process, Aroclor 1254, 1260, etc. vapors escape. What pre- / cautions can I take to prevent (a) employee problems and j (b) escape of vapors into the atmosphere? / i MONS / / / / ' 100134 7 Answer (7): / ' Articles on PCB interference with pesticides analysis have mentioned the possibility of loss to the atmosphere from vaporization when Aroclors are heated. We find this hard |r to believe and it warrants considerable investigation. ' ' 7: 7/ = i I TOXICITY Question 1 If PCB is a danger to fish and birds, how about humtuis ? 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. IIi Question 2 / /f 1 Are Aroclor 1254/1260, etc. more toxic than other Aroclors? Why? Answer: There is a difference in toxicity depending on degree of chlorination. This is not to say that higher chlorination is more toxic than lower chlorination. The alleged PCB problem I 8 Question 2* What's the difference between a chlorinated biphenyl and a terphenyl? / . .. Answer: . A tcrphen'yl has three benzenes linked together and biphenyl only two. They are, therefore, similar but different, just as naphthalene is different from benzene. ' Question 3* / i / / 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, 1 would emphasize/that not 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 been identified in the environment either. Question 4 Since you sell other PCBs beside Aroclor 1254 and 1260, why are they not found in the environment?/ ! Answer: / One reason could be that they biodegrade and hence never build up to a level where they can be labelled persistent contaminants. lTherefore, : although you would find i 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 of work won't come to hand quickly but our preliminary work . MONS 100136 9 Qucsti on 5 In your letter, you make no'mention of Aroclor 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. It could be that their structural differences from Aroclor 1254 and 1260 are responsible for the apparent lack of a problem. In any event, they have not been identified by scientists in the environment and--believe me-- a lot of '/ ; scientists seem to be looking for PCBs. ' / Question 6*1' ' Both Aroclor 5460 and 1260 contain 60% chlorine. Why is one a problem (1260) and apparently not the other (5460)? , Answer:* I / / A .terphenyl has three benzenes linked together and biphenyl only two. They are, therefore, similar buV different, just as naphthalene is different from benzene. , I would emphasize that not all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1342 haven't been identified in marine, aquatic and wildlife environments. Chlorinated terphenyls--at least those made by Monsanto-- have not been identified in the environment,either. ' Question 7* / Does this PCB problem mean that you have discontinued MQNS 100137 Question 8* Is the reason for not resubmitting your petition to the FDA for approval of Aroclor 5460 due to this PCB publicity? Answer: 1 No. Question 9 1 .: '. ` What's the problem then? Answer: . We are bringing a new solid Aroclor plant on-stream in the next two-threc months. We want to make sure it produces, the same quality Aroclor 5460 we used in our feeding studies for the FDA. Once we're sure that's O.K.-- and.we/ feel it will be--then we'll get the petition moving again but j jFDA clearances do take time. ' Question 10 * '! Does this PCB publicity mean that FDA approval of Aroclor 5460 is not going to be/obtained? / Answer: '/ / ' ' f/ We have no reason to think the two things are related. Aroclor 5460 is not chemically a PCB.; The delay resulted from the need . to set up certain analytical methods to satisfy Jy'i)A. This involved analytical instrumentation and is being completed now. . It is my understanding we plan to resubmit our petition although : /I personally don't know the exact date, . // ' / / CONTAINERS Question 1 Joe Doe buys all my used Aroclor drums without me having afto wash them. I get $3. 00 a piec I. can't afford to wash them out. Even if I did, what would I do with' the washings ? MQNS 100138 (Question 1 con't) / What should I do ? Shoulc/l tell Joe Doc? Will Monsanto take them back or pay me 00 plus my costs to take them to a dump? Answer; Don't have an answer at this time. We just don't know. / .' t ~ / APPLICATIONS Question 1* /. Could Aroclor 1254/1260 escape from my sealant/adhesive/ coating .whatever into the environment? . Answer: / / / This will depend entirely on the final use to which your product is used--its-ultimate disposition. Question 2* // / My product X contains Aroclor 1254/1260.. What shouldjt tell my customers ? Answer: Tell your customer--Wc want to advise you of a possible environ mental problem. Without knowing what your customer does with product X, this is hard to answer. (We would say that it would not seem wise to use Aroclor 1254 or 1260 for keeping dust down on the roads, for use in dental sealing compounds or as carriers for pesticides. )# / /, Only if you suspect or are told'this is .1 f what the application is. / / / Question 3 fA Does Monsanto intend to continue manufacture of Aroclor 1254/ / 100139 MONS Answer (3): I have been given no indication otherwise. Question 4* / 12 Should I look for replacement for Aroclor 1254/1260, etc. ? Answer t I think only you can decide this. How easy would this be for you? Do you have any other replacement product in mind? . Question 5* . / Does Monsanto have replacement products fox Aroclor 1254 and 1260? / Answer: / / As you know, we have over eighty plasticizers in our line and there's quite a bit of product interplay so it is possible that there is another product in our line that might replace them. What resin do you use? Perhaps we could look at these re sin/plasticizer Selector Charts in the back of the Blue Book. I've got it with me. - ' . . 1 Question 6* ./ Is Monsanto working on replacements for Aroclor 1254 and 1260? ' .. Answer: These research fellows are always busy on things like that. To some people Aroclor 1254 and 1260 have drawbacks,-quite apart from present publicity on PCB. Aroclor 1254 is. fairly volatile. Aroclor 1260 is very viscous and diffici to handle. For polysulfide sealants, for example, the tec people in St. Louis have just sent us-data on products that behave better than Aroclor 1254 in polysulfide sealants. Maybe there's something here for you to look at. Let's go over it. HONS 100140 / / / / / / /