Document Lg58BOZ61Nnqmzn3vD1EVvYvz

*r crcxtoct TC s e * N. T. Johnson St- Louis February lb, 1970 POLLUTION LZ7TZR ee< / / / / ?. Craska. - Wiliaisgtoa C. day - Sc. Louis J. K. Davies on - Los Angeles R. A. Damiani - Chicago G.F. Fague Detroit R.A. Garcia - Akron R. Gamawerthy Melbourne J. A.-.Keilala - Akron R. Irwin - Houston . J. S. Pullman - New York J. J. Rader - Chicago R. Giles - Melbourne P.J.A. Marsh - Brussels R. Zarhardt - New York T. W. Gaesoa - Montreal J. N. Kaggaxt - Brussels V. Morse - St. Louis J. Brydoa - Montreal R. Graham - New York P. G. Secigaus J. G. Bryant D. Z. Roush D. A. Hall D. R. Pogue D. F. Smith D. A. Olson Attached is a list of questions and answers which may be asked of ' you by customers receiving our Arodar-PCB letter. You can give verbal answers; no answers should be given m writing. If the customer asks a ouestion you can't answer or if he wants an . answer in writing, then send his questions to me and we will . answer from here. We want to avoid any situation where a customer wants to return fluid. The new reformulated products wiH be available within a month. We would prefer that the customer use is his euxrent inventory and purchase Pydraul 62 S A, Pydraul ACA, Pydraul AGA Winter Grade and Pydraul 540A when available. He will then top off with the new fluid and eventually aH Areclar 1254 and Arcelor 1260 will be out of his system. We don't want to take fluid back. Sell him the replacement. We must be very positive in our approach with each customer ' relative to our decision to eliminate the use of Axoelor 1254 and Aroclor 1260 in our Pydraul produets. We (your customer and Monsanto) are not interested in using a product which may present a problem to our environment. We certainly have no reason to be defensive or apologetic about making this change. The decision ts change makes good sense and our customers should eommend us, not erhneixe our acmsas. No m e has forced us to make this PLAINTIFF'S EXHIBIT V-un STh CCJ3 1C 17 " WATER PCB-SD0000026319 z change. We have done is to keep our easterners out si possible trouble. They should appreciate our effort, and stay with us as a customer on the reformulated Pydrauls. To make this change has cost us research monies and time. Fortunately, we possess the technical skills to'make.a, change in eux formulations without affecting the performance of products. Be positive. Take the offense. Don't let a customer or competitor intimidate you. I doubt if our competitors knew whether their product could present a problem to our environment. You might ask your customer, if he has ever asked Houghton or Stauffer, Carbine, etc. about the effects of their products. We should also recognize (point this out to your customer) we must clean-up. The Chemical Week article gives him an idea of laws in effect in 'his state. Head this yourself. Be familiar with the data on each state in which your customers are located. Use this in your discussions. ' " We have ns replacement products for Arcelor 1254 and Arodsr 126 Q_;* ... We win continue to make these products; however, customers will have to use their own judgement os, enanusd use. We can't afford to lose one dollar of business. Our .attitude in discussing this subject with our customer will be the deciding factor in our success or failure in retaining aU our present business. Good luck. ' (We have also attached a copy of the letter sens to transformer customers.) i N. T. Johnson lb STB 00" i > WATER PCB-SD0000026320 Monsanto ..* Ugniams Cameenv 300 K. Unatar^n loul*ra Si. Usuis. Missouri 33166 Wistir. SUI 86-1080 . .. <. February 9, 1970 ...........&mrngjmg GMG*sMS Dear Sir: Recently several newspaper and magazine articles have been published Indicating that Polychlorinated Biphenyls (PC3a) have been discovered at seme points in some marine, aquatic and wildlife environments. The quantities detected axe said to be in the parts per million and parts per billion categories. Zt is claimed that the ?3s found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. Produets which are sold by Monsanto under the trade names of Arcelor 1254 and 1260 do contain chlorinated biphenyls'. In addition to Aroeier 1254 and 1260 , Monsanto sells certain functional fluids containing Aroclor 1254. These include Pydraul 625 , Pydraul AC, Pydraul AC - Winter Srade, Pydraul 540, Therminol PR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Arodor* 1254 and 1260 and formulated products containing 1254, w@ wish to alert you to the potential problem of envirasmental contamination as referred to in the newspaper and magazine articles. ..We would like to point out the following additional facts. 1. Products such as Pydraul 90, 125, 230, 312, A-200, F-9, 150 and 60, Turhinel 153 and Thexainsi PA-1 and PR-2 are net formulated with Arcelor 1254 or 1260. 2. PGi with a chlorine content of less than 54% have not . been found in the environment and appear to present no potential problem to the environment. _ '.J b _ .C C U l WATER PCB-SD0000026321 2 We have developed, and are now testing, new formulations to replace the Arcelor* 12S4 and 1260 components in our Pydraul products. The new products appear to be equal in performance and to have similar physical properties. We feel that all possible care should be taken in the applica tion , processing and effluent disposal of these products to prevent them becoming environmental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969 regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good manufactu-*' ng practice in the future may require that no products used by any company should find their way into waterways. Sincerely yours, ale Attachment /L ft. Donald A. Olson Director of Sales , Functional Fluids Group - i i u CCijjr WATER PCB-SD0000026322 Monsanto .. ..' m a mm me Cawianv 800 H. unaar;n 9euleer3 S( warns. Missouri 83)8! *ISA ,3HI 8SA-:ae0 -- ................. iBn^r- February 18, 1970 SMSiart Dear Sir: Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (FC3s) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the parts per million and parts per billion categories. It is claimed that the PCBs found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. _ Products which are sold by Monsanto under the trade names of Arodor 1254 and 1260 do contain chlorinated biphenyls. In addition to Arodor 1254 and 1260, Monsanto sells certain functional fluids containing Arodor 1254. These include FydrauJr 625, Pydraui AC, Fydraui AC - Winter Grade, Fydraul 540, Thermmol? FR3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Arodor 1254 and 1260 and formulated products containing 1254, we wish to alert you to the potential problem of environ mental contamination as referred to in the newspaper and magazine artides. 'We would like to point out the following additional facts: 1. Products such as FydrauE 90,135, 230, 312, A-200, F-9, ISO, and 60, Tux bind 153 aijd Therminol4, FR -1 and FR-2 are not formulated with Arcelor" 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not been found in the environment and appear to present no potential problem to the environment. SIR CCilU WATER PCB-SD0000026323 We have develooed# and are now te stine, new formulations to renlace the Arcelor 1254 and 1210 components in ur PydrauT products. The new products appear to be equal in performance and to have similar physical properties. We feel that all possible care should be taken in the application, processing and effluent disposal of these products to prevent them becoming environ mental contaminants. Of interest to you may be an article in Chemical Week , October 29, 1969, regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good manufacturing practice in the future may re quire that no product used by any company should find their way into waterways. We realize that you have marketed or may now market transformers and other electrical equipment containing dielectric fluids which include Aroclor 1254 and 1260. Although these fluids are sealed into such equip ment it is recognized that occasionally the fluid may be lost through leaks resulting from equipment misuse or equipment repair necessitating replace ment of the fluid. Since the dielectric fluid contained in this equipment is only an incidental pare of the over-all unit manufaemred by you, we are not notifying the purchasers of such equipment of the potential environmental contamination problem described in this letter. We do recommend, however, that you notify such equipment users of this problem. Sincerely yours, Attachment Donald A. Olson Director of Sales Fuae^onal Fluids Group s Tfi CC2 2 i s WATER PCB-SD0000026324 POSSIBLE CTSTCMZ3 QUESTIONS CX ?C3s publicity ' Question 1 What articles have appeared on the PC3 problem? . Will you send me copies ? ' /. Answer; La 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. 5, 1969. Numerous articles were generated by the Wisconsin "DDT Hearings" in . May,' 1969. At the hearings, witnesses discussed the problem of ?C3s as "interfering substances" in their search tor DDT m . the environment. ?C3s, they said, produced peaks on a gas chromatograph similar tn the peaks produced by DDT. In no ease was FC3 indicted at the Wisconsin hearings. Copies oi the articles wiH be made available on request. BegtonaL managers should contact E. V. John, Public Eolations Manager Organic Chemicals Division, in St. Louis and copies will be ier' warded to the customer through the regional manager's oifice. In addition to the newspaper articles mentioned above, there have been'radio broadcasts. ' At the uxne oi the San F rancisco Chronicle &ud Examiner articles, radios in the San Francesco area also carried the story. 2n August, the sports editor oi the Hartford Times syndicated a radio broadcast on the subject oi ?C3s, and in Sec., 1969, the Canadian Broadcasting Co. (radio) carried an interview they taped with a member oi our as dical dsparmem Question 2 # _ _ ` Were Monsnats's Arodsrs speciiicaHy mentioned is these asra.de s ? _ If so, which ones? Si* WATER PCB-SD0000026325 7 Ar.awo r Monsanto's Arocia rs were mentioned in some of the article s bus only in the Sa.-. Francisco Chronicle story in Feb. , 1969, was Arcelor 1262 specifically mentioned bynumber, is several oi the articles, Monsanto was also identified as the sole U. S. producer of polychlorinated biphenyls, marketed under the tradename o Arsolor. , Question 3 . * What aid the articles on the PC3 proolcm say? Answer Since the outset oi the "FG3 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 DOT as a possible environmental contarr. in ant. The San Francisco Chronicle amide carried a headline, "A ' Menacing New Pollutant. " In rather sensational style,, it identified PC3 as a threat to birds and humans, highly toxic in a gaseous j state and related to known cancer-causers. PC3 presence in the environment is rising swiftly, the arncle stated. - ' The Examiner article called PC3 a "plaitie pollutant in the 3ay ' and Mothers* Milk. " This article eaUed PC3 an "alarming" new chemical pollutant that is playing p/role in' the declining peregrine falcon population, has Luea found in mothers* milk, as-d 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. Hebert Hisebrough; a researcher at the Institute of Martne Hesoureas in'the University of Califor"^ Department of Nutmtional Sciesdsts, on the detrimental effects of FG3s. Dater Dr. Hisebrough said he had been misquoted in some newspaper stories. . ;* " ' The Hartford Times story called PG3 poUudoa a "sew puzzle. " Dess sensational tnan the.San Francisco articles, -the Times gave an. account of PG3s being found in the environment and the .studies : under way to determine their biological effects. This article-, says Dr. Hisebrough, tends to otnar PG3 of blame. ` -' ST* CC23 1 7 WATER PCB-SD0000026326 Articles generated by the Wisconsin DDT hearings generally discussed ?C3 as an interfering' substance discovered in scientists I search for DDT in the environment. Dr./Risebrough said at the hearings that there was no proof as the some as that PC3 alone can cause thin eggshells, one of the phenomenon . that he had discovered in studying the/declining population of the oeregrine falcon. /, Question 1 LEGISLATION / Are there any Federal/Statc/local laws under which the use or discharge ef Aroclors could be prohibited? Answer; No emsting Federal, State, or leeal laws prohibit the discharge ef Aradors. However, in-a ttnbr of states the basic water pollution control legislation is so broad that stats agencies can. ' prohibit chemicals,- deemed necessary, from, being discharged. Is the DDT and the ?C3 problem related? Answer* Wc arc not a manufacturer of DDT or other chlorinated hydrocarbon pesticide and, therefore, have no knowledge of the seriousness of the charges against DDT ether than what has been so widely publicised . on TV, in the press and in technical journals. To the extent that both DDT and PC3 are chlorinated hydrocarbons, then there is a similarity. They are suffieiaatly different in their chemical structures , however, that it would be easrely wrong to assume that both behave in the same way in the environment. There is another and more obvious difference. DDT and ether chlorinated hydrocarbon pesticides were specifically designed for a job that obviously leads to their being scarared in wide spread fashion across the countryside. Rain, birds, wind, insects further seastsr these pesticides in an uncantrsLahlo manner. PC3s are not used in this fashion and WATER PCB-SD0000026327 4 Monsanto has .-.ever sough.: a promote this. This, we believe, is an important distinction that should cot be overlooked ii DDT a-nd PCS ere United as a cessis.se pollutant of the eavisoasest. To our knowledge ?CBs have sever been idee.sited^'ic. the absence cl DBT or other chLsrisassd hydrocarbon pesticides. Could it be PC3 that's causing the environmental problems and not DDT? Ar.swe r: We believe that present-day GLC and mass speetremetrie techniquesare sufficiently accurate to be able to differendate between DDT, related pesticides, their metabolites and PCS. Question 4 ' What authority do State and local governments have in banning controlling the use of PCSs. .-^ Answer: . . . # **" . They do have authority so ban or control use of any substances they consider harmful. . * . EPTL.OZNT AND ITS CONTROL , Question l . How do 1 dispose of Axedor 1254/1260, etc. finest from my plant ? . Answer: / We 4#ould 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 far dumping. These methods do not STR_ C C1 2 14 WATER PCB-SD0000026328 3 solve the problem of contamination. We are working on the . disposal si these mats rials by incineration and biodegradation. Our work La these areas has - not yet reached the stage where ' we car. effe r prachcal suggestions. It is of interest to note, however, that re search is underway to find catalysts to make DDT self-castructive. The possibility exists that we could find catalysts that would destroy ?G3s in settling tanks con structed to eatch aH yeur effluents. / Question 1 / Can I test my effluent to see if ray effluent has- no Aroclor 1254, . etc. ? . . // /, / Answer: ` Yes. Analytical eo.uipmcnt is available that can do this if the proper technique is used. The basis of .the raethod is GDC or gas liquid chromatography. Are you or anyone ' in your company familiar with this ? Do you have GDC equipment? If you do, we can send you a description of a method that eauld.ideasiy PC3. If not,/there may be a good analytical testing laboratory m the vieinisf where you . could send samples and rely on the results if you wans to test your effluent.. / Question 3 ` / / // What is a "safe" PC3 level for effluent leaving my plans? Answc r: ; i As our letter points out, parts per million (ppm) and parts per biHioa (ppb) have been mentioned in the published articles. There is still a lot of doubt as to how absolute any quoted ' values are. To bring this into the realms of reality, this definition of ppm and ppb may help clarify things. To give you a practical example, the escape of one-two gallons per day could lead ts samples La a traa beside the plans showing 10-30 ppb on analysis. ' STk CC13*'- WATER PCB-SD0000026329 L ___Que s'izr. 4 / / // You rr.uss have quia a contra! problem as your plants--1 would think Monsanto's Arcelor plants are the major aeHusers--how are yea. bandHng control?/ * '' / ' Answer: ...................... / / / The Arcelor products wc make to sell at a protit, so economics dictate maximum housekeeping, minimum loses. The Arocior process is & "dry process" or closed system. ./ Question 5 /^ How does Monsanto think Arociors can get into the environment and cause so much poUnuna? Answe r: / Disposal, leakage from- systems using it, spills, etc.-'' / Question 6 / ' Z I analyse my edUoens stream and iad ppo `there, how do I ' knew is didn't come mom air-bome contain.inasioa or was _ jaresens is. the process water that 1 pump from the XYZ river into my plans? Answer: Analyne water easrag your plans and compare. There is a method .available or sampling air. * Question 7 .* You seem to think Irtm the tone o your letter that the source ' a poUusisn. is from eminent disposal inso streams. In my .process. Are dor 3234, 3260, te. vapors eseape. What pre- / cannons can 1 take to prevent (a) employee problems and / (b) escape o vapors inso the asnosphere ? / S Tk CC2311 WATER PCB-SD0000026330 7 Articles on ?C3 interference wish, pesticides analysis have mentioned in possibility of lass to the across he re from vasorinasioa whan Aradors are heated. We Had this hard to believe and is warrants eossidierahle iavessgancc. TOXICITY Question 1 If PC3 is a danger to fish and birds, how about burn ana ? Anawo r: ' 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. Question 2 Are Aroelsr L2S4/1260, etc. Why? y' toxic than other Axoeiors 7 Answer: There is a difference in toxicity depending on degree si chlorination. This is not to say that higher chlorination, is mors toxic than lower ehloriaaeiea. The alleged PG3 problem . Answer: They are chlarisasod terphesyis. ' '/ / >7K_. CC.3i- WATER PCB-SD0000026331 8 Question 1" What's the difference between a. chlorinated biphenyl and a. terpheayl? Ar.swe r: A terphesyl has three beasenes Haked together and hiphe ayl only two. They are, thereto re, similar bus different, just as Naphthalene is different from benzene. Question 3" /, / Why should PCB be an environmental contaminant and chlorinated terphenyls not? / Answer: I don't think there **is any positive answer on this and I ean't ' five you any theories. However, I would emphasize.'that not aU PCBs appear to be contaminants. Those such as Aroelor 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 Aroelor 1254 and 1280, jwhy are they not found in the environment?/ Answer: t ' ' One reason could be that they biodegrade and hence never build up to a level where they can be labelled persistent contaminants. Therefore, although you would find it in an effluent stream if you analyzed it just after you poured PCB into is. 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 on PCBs of less than 4% chLorino looks promising. - i T h CC1_ WATER PCB-SD0000026332 9 Cucati an 3 It- year lesser, you make no' mention. of Arcelor 1262 and 1263. What is their status? Answer: lc 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 Aroelor 1254 and 1260 are responsible for the apparent j lack of a problem. In any event, they have not been identified by scientists in the environment and--believe me-- a lot of Y scientists seem to be looking for PGBs. Question 6 Both Arodsr 5460 and 1260 contain 60% chlorine. Why is one a problem (1260) and apparently not the other. (5460)? ^ . Answer; . A terphenyl has three bensenes linked together and biphenyl only two. They are, therefore, similar but different, just as naphthalene is different from benzene. 1 would emphasize that not aH PC3s appear to be cenrarr.:Bants. Those such as Aroelor 1221, 1232, and 1342 haven't been _ identified in marine, aquatic and wildlife environments. Chlorinated terphanyls--at least those made by Monsanto-- have not been identified in the esvirenmeas.aisher. ' Question 7* /' . Does this PCS problem mean that you have disc@ass.uad efforts to get Aroelor 54&0 approved by FDA? / ' Answer; / No. J S TR -CC22*- WATER PCB-SD0000026333 u GwsiiaiiS55 Ls is reason for not resubmitting your pesidon to the FDA far approval of Arodor 1440 cue la this ?C3 publicity? Answer: No. Question 9 ' Wcat's the problem thee? Answer: We are bringing a new solid Arodor plane on-stream in the next two-three months. We wane to make sure it produces/ the same quality Arodor 5460 wc used in our feeding j studies tor the FDA. Once we're sure that's O.X. -- and. we- feel it will be--then we'll get the petition moving again bus / FDA clearances do ake time. / Question 10 -Does this FC3 publicity mean that FDA approval of Arodor 5460 is not going to be obtained? f / / Answer: We have no reason to think the two things are related. Arodor 5460 is net chemically a PG3. The delay resulted from the need . to set up certain analytical methods to satisfy FDA. This involved analytical instrumentation and is being completed now. . 1 Zx is my unde r standing we plan to re submit our petition although CONTADJZSS Guasmon 1 Joe Dos.buys &D my used Arodor drums without me having to wash them. I get S3. 0C a piece.' 1 can't a^ord to wash them out. Sven if 1 did. what would 1 do with the washings ? STS cc. WATER PCB-SD0000026334 n ( Question 1 coc't) ' / - What should I; do ? Should' 1 tell Joe Doe? Will Mens ants take them sack or .pay me S3-CQ plus sty costs to take them to a dun? ? .. .* ., ' t , Ar.swc r: , '/ Don't have an answer at this time.. We just don't know. ..APPLICATIONS . Question Is " . -- Could Asodar 1254/1260 escape from my sealant/adhesive/ coating whatever into the environment? '. Answer: '\ _ /* ' . , . . . */ t . This win depend entirely on t@ final use to which, your produc is used""itS'ulsma.ts disposition. / / i / Question 2* / - My pred*ast 3C contains Areeier 1254/1260. What should^ tail av customers ? . 1** *' `. . ' _ '* / * Answer: v- ' ' Tell your customer-We wans 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 Arodor 1254 or* 1260 for keeping dust down on the roads, for use in dental sealing compounds or as carriers far pesticides.')* 1 1 * . / ' * 4 *' / *Qnly if you suspect or are mid'-this is . * Cues-dsn 3 ` what the application 'is. . / . * . ./ ` ... : / . . ; Dees Monsanto intend to eosssue manufacmr of Arodor 1254/ 1260, etc. ? ., ---------- : CC131= SIR WATER PCB-SD0000026335 12 Answer (3): I have beer. given so indication otherwise. Question 4"J Should I leek tor replacement for Aroelor 1254/1260, esc. ? Answer': ' I thick only you can decide this. How easy would this be for you? Do you save any other replacement product in mind ? Question Does Monsanto have replacement products for Arodsr 1254 and 1260? '- '* Answer: As you know, we have over eighty plasticizers in our line and there's quite a hit 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. ' Question 6<* Is Monsanto working on replacements for Arodsr 12S4 and 1260? * ' Answer: These research fellows are always busy on things like that. To some people Arodor 1254 and 1260 have draw-baeks." quite apart from present publicity on PCB. Arodsr 1254 is fairly volatile. Arodsr 1260 is very viscous and difficult to handle. For polysulfide sealants, for example, the technical, people in Sc. Louis have just sent us'data, on products that will^ as have better than Arodor 1254 in polysulfide sealants. s'* Maybe there's something here for you to look at. Let's go over it. WATER PCB-SD0000026336