Document Rp6pBYaD4KBrrj52Zrk0M0dmX

DRAFT - ' Opening Remarks - F. J. Fitzgerald Meeting with Russell Train, Administrator of the EPA - Washington, D.C ' Jan. 14, 1976 Good afternoon, my name is Jack Fitzgerald. I an a vice president of Monsanto Company, a member of its Corporate Administrative Committee and managing director of Monsanto Industrial Chemicals Co., an operating unit of Monsanto Company. Sinpf it is the Monsanto Industyta)l Chemicals ffl manufacture's dielectric .fluid John Hadley, hur president, has asked me to reaffirm to ypu Monsanto's oommitafent to wo::k wi/h the sctrical industry in findil^/solutions to 4 + iJu Let me ^fcgpt stateythat Monsanto agrees wholeheartedly with EPAsiMims desire to work toward # goal of^felimlnating useSof PCBs. designed to & restrict the entry of PCBs into the environment. 'p First, Monsantom T-imit the. ^' PCBS so]Lely to r /> f*A\mr- closed eVectrid&l jkystems</(n (This/ ectlyon ,/ii: should be no^4d,/6ccuri/ed ptioi c$mpleiffnvt5f thi ryddfal Irtttfragenc Task(Edfcce study'on PCBs that wa finished in 19721 . -more- MONS 060121 Since X am responsible for the operating unit which manufactures polychlorinated biphenyl dielectric fluids, John Hanley, our president, has asked me to represent him today and reaffirm to you Monsanto's committment to continue working with the EPA and the electrical industry in finding solutions to the PCB issue. First, Monsanto began restricting the use of PCBs solely to closed electrical systems, for which no viable alternates existed, back in 1970. It should be noted that this voluntary program was fully implemented prior to the completion of the study done on PCBS by a Federal Interagency Task Force in 1972.. While the PCB issue is a tough one to handle, the difficulty does not nor will not in the future stem from any lack of cooperation on the part of Monsanto. The problems that we face, collectively, are rather rooted in the unique characteristics of PCBs and the irreplaceable roie they have served in our electrical-industrial The challenge: environment for the past 45 years./ Replacing them in an orderly manner without creating another hazard of equal or potentially greater consequence, while at the same time avoiding serious power and transportation disruptions, HONS 060122 Let me emphasize that we have no desire to remain in the PCB fhb S . y --^ manufacturing business any longer than is necessary.4 As soon as we are satisfied that the electrical power supply industry's needs for useable, acceptable alternate dielectric fluids have been met by whomever, Monsanto will voluntarily shut down its PCB manufacturing uni t, * s f etae. hwAasas-- j VtC VkX-I CivCLl^^ ^8 Wile UrO-- Cwl W- 'l-- 1C tU a--fTu, b If 70^1 /U---^2. U. t-Jl /w ,, --2 Secondly, Monsanto has been working for a number of years on non-PCB replacement products. These materials, designed to rep i&ct ' ' PCB-4&fluids in capacitors and transformers. are currently being evaluated by the major electrical manufacturers in the United States. While $h> PCB issue is a touglj one to handle, tpnTvJifficult does not or w}dl nc(t arise from any^lack pf cooperation, particularly from Monsanto. The problems that we faca are ra they rooted in\ the unique character of PCBs an^the role theV\ have served in our electrical-industrlial env^fronment. Replacing t1y(t role in an orde/ly manner without/creating another hazr<j/of equal or potentiall greater consequencj/is the problem. le emphasize that we hav"bo desire to rpmai , in the PCB mar jg business any^l^nger thr n is replacement procjucts wl which power Ai -0O0- HCNS 060123 BRIEF DESCRIPTIONS OF SIGNIFICANT ISSUES ARISING FROM THE PCB CONTP.OVrnsv Monsanto Progress on Alternate Products It's important to discriminate between fluids designed for transformer cooling and those designed for capacitor impregnation Because each application has requirements not shared by the other, Monsanto knows of no candidate replacement products which would be applicable to both. For capacitors, we have studied several alternative technical approaches and have settled on a product which duplicates the electrical behavior of PCBs, yet contains no chlorine. Our testing program has included accelerated life tests on capacitors impregnated with this material. While our^results favorable, the ultimate acceptance must come^from our customers. Sample quantities of this replacemenfWre ^alraatly^'being evaluated by customers. Should we receive an early favorable verdict from enough . of the industry to support an investment, we could get into interim production at a volume sufficient to supply the industry in a relative ly short period of time. Initially, the replacement product would be more expensive since the electrical industry would have to be supplied from an interim production facility. A fully dedicated plant could be constructed within two to three years. In transformer fluids, we are not as far along. PCBs are only used in those applications where a high degree of fire resistanc< is required. Unfortunately, there is no accepted,quantitative -more- HQhS C6C124 2 definition of the degree of fire resistance needed in a fire- resistant transformer fluid. We have -aeMMS^itlM^candidate CUMj which we will mete testing by transformer manufacturers. ftresepcg ouj / key issue!in the.final acceptance of these OM. candidate dielectric fluids iff their environmental and toxicological properties. We have approached -*Mss^BMan in two ways: first by pursuing chemical structures thought likely to be relatively Innocuous from previous experience or analogy; and second by a thorough testing program. A report on our testing to date will be available in a few weeks. While some of the more extended tests are still under way, I can say that we are anticipating very positive results. Cleanup Action at our Plants Measurable losses from the Sauget Village treatment plant to the environment are approximately one to two pounds per day, . .la 7AX ^. which equates to approximatelyone to two parts per trillion PCBs CTujo f*n.+s auf of /o biilm fa^A/iaJ, in the Mississippi River at average flow ratesy^ While there presently are no formal PCB discharge limits, proposals under consideration call for ambient water concentrations at levels not to exceed one part per trillion. M0NS 0601,25 1 level^pf^PC^s in th^at^osphere-^is] less Thres'hjold Limlp^olues| available. TLV /sampling and^analytica^t^chniquos^purrejntl; J'SLrborne concentrations of substances and -more- --3 L In our manufacturing area we have acted to prevent loss of PCBs in the environment by literally making the department a "concrete bathtub." Drainage is collected in an isolated PCB sewer system with settling basins to insure PCB containment in case of accidental spill or equipment failure with the capability of monitori the effluent from the department. , Storage tanks are blanketed with nitrogen to eliminate tanks "breathing," and mist eliminators have been installed in vapor lines to eliminate the possibility of PCBs leaving the manufacturing area. The key to our continued success in controlling PCBs is in our maintaining a high housekeeping level. A Monsanto chemical waste treatment facility, to be complet in late 1976J followed -hyamotropelitee trentmewr plflnf In-tUft? . 9s Gill Eerurther step{ in reducing PCB effluents. tinwsTd a nepll gib.1 Steps taken in labeling and transport practices Monsanto ships PCB fluids in both bulk carriers and in drums. Bulk shipments are made in a Monsanto-owned fleet of tank -more- HONS 060126 4 cars which Is used exclusively for thae service, or in customerowned tank trucks. Drum shipments are made in special reinforced drums which we believe to be the best available. A multi-lingual warning label is affixed to each package I giving a brief description of the nature of the material and appropriate actions to be taken in the event of a spill or leak. We also supply a label to be used on return shipments for incineratii which gives similar Information. t The Monsanto Incineration Service . An incinerator was built at our Sauget, 111., plant for the specific purpose of destroying waste FCB-containing liquids, both from our own operations and from our customers. Firebox temperatures above 2000F are maintained to completely destroy the POT compounds, and combustion products are removed in scrubbers. Routine sampling of both the stack and the scrubber effluent has confirmed the effectiveness of the system. During 1975 our Incinerator at Sauget, 111., burned 3.5 million pounds of PCRs. -oOo- MCNS 060127 PCB PREPAREDNESS O&A -- 1/7/76 Assuming acceptable replacement dielectric fluids become available from some source, be it Monsanto, Dow or whomever. would Monsanto then voluntarily phase out its PCB production in the absence of any federal mandate? Of course! When we made the conscious decision back in 1970 to begin restricting sales to closed-system dielectric uses, the main reason we elected to continue supplying the electric Industry was that they had no viable alternates to turn to. Mr. Train said he would not ask Monsanto to stop production because that would shut down the electrical power industry and the railroads in short order. He said we must find a way to proceed without shuting down the country. This is precisely the position to which Monsanto has been committed since 1970. -more- mqns Qfccua 2 Monsanto has every intention of eventually phasing out its PCB production (in a planned and orderly manner) as soon as we are satisfied that the electrical power industry's needs for usable, viable alternates have been met. In the interim, we will continue to work with industry and government to ensure that the restricted measures and controls we voluntarily implemented in the early 1970s remain in force and are diligently pursued. Mr. Train's objectives are aimed at the same results. ` Q2. According to EPA, Monsanto makes about 40 million pounds of PCBs per year at its Sauget, Illinois Plant. What does Monsant know about the effects this large volume has had on its plant workers and the nearby residents? Surely they must be inhaling vapors and being contaminated in ocher ways. What assurances ' can you give that this won't become another asbestos, VCM or Kepone situation? How many people are employed in the PCB production/incineration units? ' A2. PCBs are considered by our 19 production people and five incinerator operators to be a normal industrial chemical as contrasted to many which are actively toxic. We provide the same safeguards and monitoring program for PCBs as we do for other industrial chemicals. Exposure to the material and its vapors is very limited, protective clothing and related safety equipment is not only provided but required. -tnore- NONS 060129 --3 k la^u, - Proper ventilation is n1 so p 1 vi.led and standard industrial hygiene practices are vigorously followed. We perform routine maintenance and safety inspections on all the manufacturing equipment and we periodically monitor and sample the workers environment. Each plan- employe is eligible to undergo a thorough physical examination ever year at company expense. Several months ago a group from the National Institute of Occupational Safety and Health (NIOSli) visitet the Krummrich plant and cor-cl udod that employe exposure to PCBs in our operation was too lew to be of concern. NOTE - Any additional questions on this subject or on the subject of animal testing should be referred to Dr. G. Roush, Monsanto's Medical Director. ; Q3. The EPA said that from two to five pounds of PCBs per day are discharged into the Sauyct waste treatment plant from Monsanto's production facilities. Is this true? And what has Monsanto done to minimize its discharges? A3. No. Our current measurable losses to the environment are approximately one to two pounds per day. This equates to approximat 1 to 2 parts per trillion_ in the Mississippi River at average flow rates./I Levels of PCBs in the ambient atmosphere are less than Threshold Limit Values (TLV) using sampling and analytical technique " ---- ----------- Z\y currently available.. Since 19C9, wo have invested more than 30 man * . ft years of work and millions of dollars in this program ly J ) it i ** in^our manufacturing area, we have taken a number of significant ttH/ J V steps to prevent loss of PCBs to the environment. In essence, we have made the department a "roncrote bathtub* Drainage is i MONS 060130 -more- directed to trenches and piping, and then to one of two 3,000gallon settling basins. This insures PCB containment In case c accidental spill or equipment failure. We have also installed an incinerator to safely dispose of PCBs This is accomplished through incineration at or above 2000 +F. Use of the incinerator and other technical assistance is avails to our customers on a continuing basis. When small quantities of PCBs are collected into the settling basins in the manufacturing area they are later pumped into drums, and eventually incinerated. In the incinerator area itself, drainage is directed to trenches and piping which flow into a 10,000-gallon basin. Recovered PCBs are periodically pumped to storage, or incinerated. In the manufacturing area, we have also rerouted relief valve lines and atmospheric vents through catch tanks, or redirected them to settling basins. We also provide nitrogen blanketing on storage tanks to elimin* any "breathing" of the tanks and resultant PCB escape. We have installed mist eliminators in vapor lines - once again to eliminate the possibility of PCBs leaving the manufacturing area through these lines.Finally, we have replaced underground sewers with above-ground sewers, and repaired or combined others, so that we can monitor -more- MCNS 060131 5 the effluent from the department. In addition, this will prevent any unknown buildup of FCBs In our sewer systems or any contamination of PCBs Into other sewers. Much of the success of our efforts also depends on maintaining a high housekeeping level in the''department Itself. Among the housekeeping responsibilities our operators have assumed are these: --All pumps are checked for leakage on every 6hlft. Drip pans that collect leaks are emptied into scrap PCB drums. ' "All leaks are reported and documented so that - corrections can be made and settling basins observed. --"Floor Dry"' Is used to absorb any PCBs that have spilled or leaked. If it becomes necessary to flush PCBs to the settling basin, a minimum amount of water is used. --Sampling drums and scrap-PCB drums are quickly - palletized, labeled and transferred to the incineration area. Through these kinds of programs, we feel we have literally built a "concrete bathtub" to catch and safely dispose of PCBs at our manufacturing location. Q4. Could you describe disposal policies regarding spent PCBs? ' -more- HONS 060132 --6 A4. Guidelines qr handling and disposal of capacitor and transfor grade PCBs were prepared in 1972 and have been approved by the American National Standards Institute. These guidelines are intended to restrict the release of PCBs into the environment. They provide standards- for incineration as well as for disposa by other than burning. Incineration facilities must meet the applicable requirements of the state in which they are located In addition, certain landfill sites have been classified by state governments and the federal government'as suitable for . the disposal of toxic and hazardous liquids. Where these "environmental" landfills exist, they may be used for the disposal of liquid PCB wastes. ' Q5. How are requests for incineration handled by Monsanto? AS. Arrangements for all return shipments of PCB containing materif to Monsanto are handled individually. Instructions are forwarded for each consignment to customers to ensure that they are aware of any changes in procedure. Monsanto supplies pre-addressed drum return labels marked "Disposal Only." All drums used must meet DOT 17E specifications as to construction. Monsanto supplies an identification number for each shipment to be placed on the bill of lading and on each drum. -more- HONS 060133 Monsanto does not accept solids such as sawdust, rags or sludge. These items can not be handled in the incinerator. A letter is provided by Monsanto to be attached to the driver's copy of the bill of lading. The subject of the letter is to be brought to the driver's attention. Included are instructionto the driver to prevent introduction of the liquid into the environment. Included in the letter are phone numbers of Monsanto Company officials and the shipper. Could Monsanto reach the "zero" discharge level being proposed by EPAT ' No. "Zero" discharge at a facility producing some 40 million pounds per year would be technically Impossible. Measurable losses from the Sauget Village treatment plant to the environment are approximately one to two pounds per day, which equates to approximately one to two parts per trillion PCBs in i* lu ^ 0*4. oijfcfj * o Oitlu'i 4.0 Ilona^ the Mississippi River at average flow rates.^ While there presently are no formal PCB discharge limits', proposals under consideration call for ambient water concentrations at levels not to exceed one part per trillion. The level of PCBs in the atmosphere is less than Threshold Limit Values (TLV) using sampling and analytical techniques currently available. J~TLV refers to airborne concentrations of substances and represents conditions under which it is believed that nearly all workers may be repeatedly exposed day afterj -more- HONS 060134 day without adverse effects. We presently are manufacturing about 80,000 pounds per day of PCBs. In our manufacturing area we have acted to prevent loss of PCBs in the environment by literally making the department a "concrete bathtub." Drainage is collected in an Isolated PCB sewer system with settling basins to insure PCB containment in case of accidental spill or equipment failure with the capability of monotoring the effluent from the department. Storage tanks are blanketed with nitrogen to eliminate tanks "breathing," and mist eliminators have been Installed in vapor lines to eliminate the possibility of PCBs leaving the nanufactur area. The key to our success in controlling PCBs ooa. tLtiili-bj is itaMpr maintainJsty a high housekeeping level. A Monsanto chemical waste treatment facility, to be completed in late 1976k *-11--J-3"r rlgp- __ ^ill be further steps in reducing PCB effluents. Q7T''""ln addition to Monsanto's own incineration service, are there other locations where PCBs can be disposed of properly? A7. Disposal service companies, meeting American National standard Guidelines relating to the disposal of PCB containing materials are located in at least nine states and include both incinerati services and environmental landfills. States where these Jbeil! HCNS 060135 fite located include the following: California, Delaware, Illinois, Kentucky, Louisiana, New York, New Jersey, Texas /nd Washington. QB, tfr, Train indicated that Japan had banned PCBs and that EPA Will conduct a thorough review of the Japanese experience. If $ highly industrial nation like Japan, with widely acknowledged electronic technology can get along without PCBs, Why can't the U.S. electrical power industry? Monsanto and the U.S. electrical industry are often asked this question. . In the first place, it should be pointed out that the major uses for PCBs in Japan were not electrical but rather "open applications," particularly for carbonless paper. The Japanese power distribution industry, less advanced than the U.S. technically, had never actually gotten around to taking advantage of fire resistant transformers to the extent they have been used in this country. Most of their transformer were either using mineral oil or were dry-type units. -The Japanese capacitor industry on the other hand was only In the beginning Stage of converting its equipment to the more reliabl PC dielectrics when the ban was announced. Reliability standards for capacitors in the U.S. are much more stringent than they are in Japan or anywhere else in the world. So the Japanese ban really did not materially Impact that country's electrical power distribution industry. HONS 060136 M- Lift- /Ua^JU^. dtU % $U/ / fat }u t 1h - <Q ?C$ 7^>*d&u 'kftst 6-k.A Tfa/ i^TK/d. )/Ve <f _ d- /fotfasCLA^. h>..../. S^TtjO ^Hj^Cloc dr tr*j dp P.C $ & /fC^ov-K- T^*d- - l/vib^cd...*S/ui / Sruryi /^/ Cd-eimfa}. Co...jyta&bfa dj-%dkd'faed At Aua. fh ..fas ... Pc&4 .-) . pu> &4-.J ..>*4-d Im-Ll~ ^ fyjie^ico ..../?._W.. Kj^nr\-.Spi/)(ic Sl^hiC. '^L^l^Ca. /*vn w------------------------------------------------------------------- - /&<-*> &*-v. thJLj ffi* / ,~y~ ^ "7Z> ^ fa~6&u.6C\ cL^L/ax. Py*cjgi0? --Wt** dmjC---^--------- ........^-4-c^. ^s*A-d . f\ldc6-**d. k\ OjLe^. 0~AjojZ&C*ttcr 7 S- , \ (Jfi<^uj*a r^o i)- ; <*&<+. ^ - PC & ^v|3*rvte ...."2>85(tf<?0 ^L<ju-*Jbo y?75T U/p> -4o ^3*-a <3t->^/ A^*< /*? ........ ................. .................. .................. ..J^v. }^ ft .S c^S-cy .<z4jl /L( duZZXirud^ i / \jgjt&& Stf'e^'*'*-'! BO jj. "itCi Q&kCu. -kl^ &Ov)**di Ca.---^x--Pc^sA^t' Pc & /e> <bmjn+-f Pc ft t-1*. X*/ HONS 060137 'BO 4 C'k^JP'-U^y^.J kr tU^' Atp AJt HONS 060136 VjATETrf. TtO/0 Coutplou Act- 72- Octobar 18, 1972 at* mwaa Dim* pollutant*, or oom- : dim-- cauaiiif agonta, which altar ation, Inhalation or aaaiinUatlon into tha anriroatMot or Indirectly b* II, an tha haaio o! infonoatlan availaath, diaaaaa, haharioral abnonnali- ijaWngtatl mallunctiona (inclodinr Jr phyaioal dalormationa, in cuon i any diacarnihla, oonllnad and nt nad United to atsf ditch. wata daaura, oontainar, rolfi ___ . itioun*,bo>rdruednuatrlioodraother floating ottering* dull nun the determine- belwiu accumulation of pollut- i do* to too discharge of pollutants a indudlng sampling of organisms itoof tho food eJiaiu appropriate to leal, and biological characteristics iriato fmieneias and locations. _ without qualification inolodaa IdWtacga of polJutonto hepttiMe' maana a schedule of rema* Iscoblo sequence of aedone or opera- Li OBoant limitation, other limitation, Ir1 meant thoaa Industrial identified ilaallow Manual, Buraau of tbo domtod, under tbo eatagoiy 4Divit other pltatia of significant waata lifanlnletraliii daania appropriate ' ms the man-made or man-induoed aieal, biological, and radiologiaal oatablhhod la tha Environmental mi Control Adviaorv Board, om> lalgnaa, who thall bo Chairman, and Piasidssrt. none of whom dull bo o appointed members, haring duo lttall ba otlootod from among topdata, and local governmental ag-- a oobtributingto, affoctod fay, or othar pubUe and private agendas, ting an active interest la thefteld of a wall aa othar Individuals who am t& by tha Prcaidant thall hold offca ti (I) any member apnointod to fill epilation of tha farm for which hit appointed for tha remainder of oa ox tha members first taking offlee `allows: tftraa at tlie and of ona veer wo yuan aftar such data, and urea iato,aa designated by tha President ii) tha term of any number under October 18, 1972 -73. Pub. Lew 92-500 tlie preceding provisions shall be extended until the ilete on which hie successor's appointment- is effective. None of the members appointed by the President dull be eligible for reappointment within one year after tlie end of his preceding term. "(B) The members of the Board who are not officer* or emplojeaa of Cmpanaesim. the United States, while attending conferences or meetings of the Board or while otherwise serving at tlie request of tha Administrator, lull be entitled to receive compensation at a rate to be fixed by the Administrator, but not exceeding $100 per diem, including travel time. and while away from their homes or regular places ofousinsas they may be allowed travel expenses, including per diem in lieu of subsistence, as authorised by law (ft CS.C. 78b-2) for persons in the so st*s, e*t| Government service employed intermittently. t) Hut. 1M. "(b) The Board shall advise, consult with, and msks recommends- 5 tians to the Administrator on matters of policy relating to the activ- 9707 m%*9 ities and functions of the Administrator under this Act. "(c) Such clerical and technical assistance a* may be necessary to discharge the duties of the Board shell be provided from the pw> sonnel of the Environmental Protection Agency. *--' ' ...... rnnaatitor roman ~ 1 *1 fifiaG. $04. Notwithstanding any other provision of this Act, the Administrator upon receipt ofevidence diet e pollution source or com* bination of sources is presenting an imminent and substantia) endangermeut to the health of persons or to tha welfare of persona where such endsnaetment io to the livelihood of such penone, such Urthubilfty to market shellfish, may bring suit on behalf of the United States in the appropriate district court to immediately restrain any person causing or contributing to the alleged pollution to stop tha di*- cliarge of pollutants causing or contributing to such pollution or to . takesuch other action as may oc necessary. J "cmsBx sunt "Sac. 00ft. (s) Except as provided in subsection (b) of this section, any citisen may commence a civil action on bis own behalf-- "(1) against any person (including (i) the United States, and (ii) any other governmental instrumentality or assney to tha extent perznittedtrr the eleventh amendment to the conantotiea) use pm. who is alleged to be in violation of (A) an effluent standard or utu 1. limitation under this Act or (B) an order issued by the Admin- . istrator or a State with respect to such a standard or limitation, or "(2) against die Administrator where there is alleged a fail ure or the Administrator to perform say act or duty under this Act which is not discretionary with the Administrator. * Till district courts shall have jurisdiction, without regard to the Dirtrin urt amount in controversy or the eitisanship of tlie partita, to enforce such Jarisdirtiww n effluent standard or limitation, or such an order, or to order the Administrator to perform such act or duty, as the esse may be. end to apply any appropriate civil penalties under section 800 (d)'of this Act "(b) No action may be commenced-- Netu and "(1) under subsection (a)(1) of this section-- mine. / "(A) prior to sixty deya after die plaintiff has given notice of the alleged violation (i) to the Administrator, (ii) to the State in which the alleged violation occurs, and (iii) to any alleged violator of the standard, limitation, or order, or "(B) if the Administrator or Slut* has commenced and it diligently prosecuting e civil or criminal action in e court i MCNS 060139 -- 10 Q9. Mr. Train has repeatedly said he will never be able to control PCDs effectively without Toxic Substance Control Legislation. What is Monsanto's reaction to this? 3 __ _ A9'. -We-don't really understaHH^His reasoning "here. He has said '--liu would not ask Monsanto to stop "production because it would - shut- down the country^ we assuiiiS-this statement would apply finally rri l-h -- n nnn Tnv<i. Substance L3W. If hn had Imports '.which we understand are being used in ft./ "riprn np| 1 i n 1l"ir'"r 111 iiiliil.|-Th1rVi according to figures releases by l?ftp, I.mb Aspin flD-Wls.) are projected to t ay lilgll Ss Jtti ,000 pounds'this year -- up 40 per cent since 191? , Monsanfcu fuult)~hn lias-all the authority he needs under section ^ 504 uf Lilt! FedSTUl Water Pollution Control Act. Q10. What is Monsanto's position regarding Toxic Substance Control Legislation? A10. Monsanto Company's corporate policy supports government actions whenever such actions are clearly in the.public's best interest and are needed to protect human hpalth and the environment. We recognize that there are certain gaps in existing regulatory controls, and that safeguards may be needed to fill those gaps. Consequently, we do not oppose enactment of reasonable legislatio that would provide for the testing and regulation of chemical substances which present unreasonable risks. At the same time, we object emphatically to any prospective legislation chat would impose broad, sweeping controls that overlap and duplicate existing laws. ,,0NS 060li,o n Qll. Are your replacement products fire resistant? If not, won't this expose the public to some new hazards? All. Our replacement capacitor fluid candidate is far from the category of "flammable liquids," but it will burn more easily than PCBs. To give a familiar analogy, it has about the same flash point as the ethylene glycol used in automotive anti freeze. We hope and expect that capacitor manufacturers can modify designs to minimize any potential fire hazard, but to some degree there will have to be a trade-off between, maximum fire safety and environmental compatibility. Q12. You stated that there is no accepted standard for fire-resistanc for transformer fluids. What is Monsanto-doing about it? A12. We feel that the proper agency for establishing such a standard would be an underwriters group or the Bureau of Standards. EPA might be able to^focu le attention of appropriate government agencies on this problem a*, KtJtXJL , Q13. why is Monsanto introducing a replacement dielectric fluid before environmental and toxicological testing is complete? A13. in a sense, that kind of testing is never really complete, because there are so many different kinds of tests, and some take several years to run. The data we have developed so far encourages us to believe that the new product is better than PCBs: that is - more biodegradable, not subject to biomagni fication, relatively non-toxic - and this lends urgency to getting on with a replacement program. MOWS 060141  -- 12, / *J- < /^ fa U \S - ^^ejcc'a*`-tt ~yvx^L^Z^ij <L---- i^-wf &a~*-*os " At k'^t* /- ...A-W -- C? ^ /w^<~C*P...../%*-' V- s. pA<Z&u*:kisri Jc, y *'>*. )fyLt-yr2~A 4* /V-- /7^ 3^4!^^fc^...eJuL^Y^^ ....... ...... a^JcLsi&Z un^cJ. fa fa /\^(/KyCL------- i -y* M si- JQAsTiCi^A*^ tf^rvwjf' .^CC'hcc^/ 44sl*M>(^ > J- (Vw, ^ 'XK.////6VJ /dcr>-*JZm. / 4? Vvw // < (61 $>>_< tttA. 42> )u>/ttr-i - Jo***xJ*> 0 <Ui*f+cA.'<hn 6r'^w_ /LuUcfatj /U Q^juJhJ h 6 fa*___ C&^~>ztx^ hlLu*. k* <*ffJt^ ^ ._ S'-'-w-c. - L/ -S . ^^-<- 4^-^. ,<sL****eS "i__ // ~^*4//1**\ dcrt'-rJ'*3 4^K^uow>-. t( S TO'wM-ifa**-- ' * V HONS 0 6 0 1 * 2 q /^-- ePw1 ____ '&)$ /$-*< / Pc&s 6pJLA4A*-J( &/t> k^r? C_ tr CM* (m. 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