Document aqoXV9VRBM7O9YGbJ0GmeExX

Monsanto Monjanio Comoanv BOO N UndbrQh BouHvira 3: Louis. Missouri 63'SS '"ions: (314) 694-1000 February 9, 1970 ORGANIC CNEM-CALS Dear Sir: Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (PCBs) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the parts per million and parts per billion categories. It is claimed that the PCBs found strongly resemble chlorinated biphenyls containing 54% and 60% chlorine by weight. Products which are sold by Monsanto under the trade names of Aroclor 1254 and 1260 do contain chlorinated biphenyls. In addition to Aroclor* 1254 and 1260, Monsanto sells certain functional fluids containing Aroclor 1254. These include Pydraul 625, Pydraul AC, Pydraul AC - Winter Grade, Pydraul 540, Therminol FR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Aroclor 1254 and 1260 and formulated products containing 1254, we wish to alert you to the potential problem of environmental contamination as referred to in the newspaper and magazine articles. We would like to point out the following additional facts. 1. Products such as Pydraul 90, 135, 230, 312, A-200, F-9, 150 and 60, Turhinol 153 and Therminol FR-1 and FR-2 are not formulated with Aroclor 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not . been found in the environment arid appear to present no potential problem to the environment. PLAINTIFF'S EXHIBIT 000020 q0 00 xb 3i WATER PCB-SD0000043635 We have developed, and are now testing, new formulations to replace the Aroclor 1254 and 1260 components in our Pydraul products. The new products appear to be equal in performance and to have similar physical properties. We feel that all possible care 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 manu facturing practice in the future may require that no products used by any company should find their way into waterways. Sincerely yours, nlc Attachment /C (. (t t mj-c ' ' Donald A. Olson Director of Sales Functional Fluids Group ECU 001639 WATER PCB-SD0000043636 OCTOIIR SB, ISBi Environment The huge water requirements of the chemical industrynow the nation's third largest user-make water quality and . availability increasingly important factors for site selectors. Legislauon enacted in recent years has forced planners to pay close attention to pollution control standards. All 50 states have had their water quality standards ap proved enurely or in pan by the Federal Water Pollution Control Administration (FWPCA). Recently a state-by-state summary of key standards was put together for the first time. Surprisingly, it was not the FWPCA that did the job. Instead it was handled by an Amencan Public Health Assn. (AJPHA) subcommittee headed by TVA Health Director F. E. Ganrell, assisted by the APHA Engineering and Sanitation Section. A portion of the study, covering standards for surface industrial water, is summarized in the tables starting on p. 80. Contrary to widely held opinions, there is considerable variation in stale standards. Take the dissolved oxygen (DO) standard, for example. Minimum allowable DO (as milli grams per liter or percent saturation) is the single most impor tant standard to chemical site evaluators. As a rough rule of thumb, a 2-mg./l. standard is considered to be one industry can live with comfortably, while a 6.0 mg./l. value is pegged "extremely tough." California. Wyoming and Washington have set the stan dard at 6 mg./l. or higher. But a few states such as Con necticut. Maine. Illinois, Indiana. Massachusetts. Virginia and Wisconsin require 2 mg./l. or lower. Other standards--notably turbidity, taste, odor, color and solids--may also be important, depending upon the nature of the chemical plant's waste effluents. These standards also ex hibit state- by-state differences. Moreover, they are generally less specific than the straight numerical DO standards. Although chemical plant site experts see little point in "running from tough standards," the criteria do make a difference: Plans for two nonferrous metals plants in Puerto Rico are now on the shelf, because of standards that call for a 4.5 mg./L DO. no wastes that interfere with the esthetics of the waters and other specifications. No compilation of ground water standards has yet been published. Ground water standards may prove important in the future as companies are forced to use costly deep-well dis posal for wastes. Availability of ocean waste disposal services is also looming more important Waste Cost: The price tag for pollution control is high. A recent FWPCA study on the organic chemicals industry esti mated that water waste-treatxnent facilities can increase in stalled capital equipment costs 40% or more. Between '69-73, the organic chemical industry would have to shell out S 182.5 million to remove 10% of its biological and chemical oxygen demand waste and 65% of its suspended solids. Removal lev els of 83%, 13% and 71%. respectively, for biologic oxygen de mand. chemical oxygen demand and suspended solids would require S242.6 million, while 98%, 30% and 89%, respectively, would up the ante to S608 million. Cleaner Air. Establishment of air quality standards is not nearly as far advanced as are water standards. The National Air Pollution Control Administration (NAPCA) is still desig nating regional air control regions. At last count, 16 regions had been formally designated and another 41 had been pro posed. NAPCA has issued air quality criteria and control technology data for sulfur oxides and particulate matter. ;il follow with similar studies for other pollutants. Once criteria and control data have been issued for a pollu tant and control regions have been designated, a complicated process involving standards, hearings and implemenut:;r. and enforcement plans will be initiated that can take over a year to produce standards. So far. no firm sulfur oxide or particulate standards h-e emerged. But NAPCA's criteria for setting the standards sug gest they'll be tough. The oxide criteria report, for examp.:, emphasizes that there are deleterious effects io. man at ccr.centrations as low as 0.04 ppm. NAPCA's control data reports present detailed appraisals of various methods and equipment, along with esumaiec costs. As in the case of water, the costs will be high, although some pollutants-mainly sulfur dioxide-will have recover- values. NAPCA is sponsoring a number of research project to improve technology. Pollution control is being spurred ry financial assistance programs (mandated by state law) nc-operative in the following 28 states: Arizona, Arkansas, California. Connecticut. Floncu.. Georgia. Idaho. Illinois, Indiana. Maine. Massachusetts. Michigan. Missouri. New Hampshire. New Jersey. New Yorr. North Carolina. Ohio, Oklahoma, Oregon. Rhode Islar.c. South Carolina, Tennessee, Vermont. Virginia. Washington, Wisconsin and West Virginia. ' In addition. Pennsylvania offers financial aid sanctioned by administrative regulation. Several states, including Utah ar.d Maryland have legislative studies under way. The incentives take a variety of forms. Most common are exemption from personal property taxes (e.g.. Arkansas), fas: depreciation (Arizona), exemption from ad valorem equip ment and structures taxes (Connecticut), exemption from lo cal taxes for stated period of time (New Hampshire), operating loss deductions (New York); credit against state in come tax (Oregon). Quantity: The large chemical complexes now in vogue make water-and lots of it--a major site criterion. The cooler the water is. the better, for it can reduce the investment in heat-exchange equipment. Occasionally, plants can manage on ground water, but usually surface water is required. That means location on or near the big, drought-resistant rivers. There are less than 200 riven in the U. S. with minimum flows over 50 cu. ft. per second (CW Oct. 5, '68. pp. 94-95). For companies whose plant needs at least 100 cu. ft/second, the list numbers only 150 (excluding Alaska). Sea water is generally avoided because of high equipment corrosion costs. Piping water in is expensive. Duval, now opening a 1.5 mil lion tons/year sulfur mine in the arid Northwest area, was forced to install a 36-in., 38-mile-long water line and a 40- million-gal. reservoir. Cost of the water supply system hasn't been disclosed, but it is estimated that the tab was at least sev eral million dollars. . The adequacy of domestic water resources in the year 2000 has recently been evaluated by the Geological Survey. Na tionally, projected demand will be 173% of potentially as sured supply. Only in three regions. New England, Ohio, and the South Atlantic Eastern Gulf, will future water require ments be easily met. Economic growth may be handicapped in nine regions: Eastern Great Lakes, Lower Mississippi, Up per Missouri-Hudson Bay, Lower Missouri, Western Gulf-- Rio Grande, Pecos, Colorado, Great Basin, and Central and South Pacific fcQU 0 0 1 6*t 0 WATER PCB-SD0000043637 For the first time, a summary of water quality standards set by all 50 states. m Alabama s.o-e.3 TefB^stofn dtssea abovw iMM l.o 90* (24 hre.) 93* (any B hr*.) 93* (cooling water) 10% 10* m&Jl- m Otfwr Raqulremanta 2.0 at 5 ft. or Rawtewctfivfty, Cater, Taste and Oter, Tsxte fcitetuma Only m mMdnitri ITIoea amount! that would not renatr wotora unauitabla for industrial- than 10 fl cooling and process-water supply purpooom. Soutec Tree from waste material! that cauoa unalghtfy or pulreacam condition! or Interfere directly or Indirectly with Industrial uh. Alaska 7.0-8.0 0.5 70* 5.0 Radtaacttvftyi Not to gxrirari limits of PHS Drinking Water Stanaaroa. TurMtety: No Imposod valuss tnst would Intarfars with established Iavals of traatmont Cater: True color Isas than 50 color unite. Taste and Oden Stull not unraaaonably Impair astiwtlc eontidorations. Badulr No dlaaoivad solids above na tural condition causing corrosion or scaling problems. Mo visible svldanca of other floating sol Ida or sludge daposlts. No imposod aadimam load! mat would 1 mar-fari wltti astabllshsd traatmom lavala.* Taste SudetencoK Chemical constituents should be below concentrations found to be of public health significance.* Arttons e.5-8.6 0.5 93* Not to escoed 1/30 of the M PC-- value given for cominuoue occupational exposure in NM Handbook M. TurMdHy: 30 JCU (straoma): 25 JCU Oakes). Oaten Free from waste matte rials m amounts sufficient to change eaieting color enough to Interfeia with Industrial use or to create a nuisance. Taster and Oden Free from wastes In amounts sufficient to produce enough tarta and odor to create a nuisanca or interfere with Industrial use. beliter: Free from wastes that would be unsightly, putrescent, odorous or In smounta that would Interfere with industrial usa. Teals Bubatsncaa: Fra* from wastes teadc to Human, animal, plant or aquatic IHa or In amounts that would Interfere with Industrial use. Arkansas 6.0-9.0 l.o . f(i2re*.) 95* 4.0 (averse* Bedteattlvltyi "Rules and Regulation* for the Control of Ionizing for any craoa Radiation." Arkansas Board of Health. apply. TUrhteNyt No dis section) tinctly visible increased due to wastes. Ceten Shall not be in creased to the extant that K Interferes with Industrial uaa. present or future. Tncto sod (Man Must not cause offensive odors or otherwise interfere with Industrial uaa. Solids: No dis tinctly vMMe persistant solids. bottom deposits or sludge banks due tp vestas. Tesic Bubatencac Must not be present in amounts toxic to human, animal, plant or aquatic Ufa. California e.s-8.6 7.0-S.6 (Coastal staters) -- 71.6- (fresh None that would cause 6.0 ShaH not turned 1/10 of the MFC* values given Coastal water for continuous occupational exposure in NBS Handbook 69. ecological 5.0 (unless TurtedSty: Free from wastes that could alter water1! existing change or naturally tumidity. Caton Free from substance* attributable to wastes harm aquotie lower) IHa (coastal eratore)" that preduca detrimental color. Taste and Oden No substances that impart foreign teste or odor. BaBdsr Dissolved solids In fresh ulster must not etmwrt 300 mg./l. at any time: annual maarr. 175 mg./l. SettfseMa solids must not be abla to change nature of stream bottom or harm aquatic environment. Toxic e.,,i.w~--At all times free from concentrations harmful Is humans, aquatic life or wild or domestic animals. Gotmvdo 5U>-a.o -- &O-9.0 -- &J-&5 -- Pteritia &0-&S 1.0 93* 3.0 Kona unless tt . doss not Smite for tndustrtel usa 2.0 E30%a or 4.0 4.0 ftwdteacthdtyt Not to exceed 1/30 of the lM-hr.-woek values In MBS Handbook . TtehMtyi Must not Interfaro with astabtished lavala of treatment. Ceten Wastes present must not causa aporedabte change In color or interfere with Industrial use. Teste snd Odan Free from wastes that cause odor or eppredabte change In testa. SsOtet Frea from wastes that are unaigmty, putrescent or edsrsus er would Interfere with use. Taxis attendances! Frea from wastes In coneantredona or com binations sufficient to harm human or animal IHa. Limits to be approved by appropriate state agency. Tteftfjr, Cater. Taste and Odxm None In such quanti ties that would Impair Industrial use. BoBdst Limited to smalt amounts that may result from discharge of appropriately Wasatsd uuMiaiM- Tawka teebasnimnuwi Free from chemlcsl conxtftuanta In auncantradona or combinations harmful to human, animal er aquotie Ufa. Pwrftawvteway Alpha uniten llmitsd Is 3 pc/1.: beta smitten, to 1TM pe/1. Cater,' Taste asd (Min None In concentrations that esnm cater, tests or odor. Steads Frea from unsightly and : malodarous nuisances due to floating eoilds or sludge depaafte. Tasdo Stdaraaoate None In eonsaitU atlona harmful (lyttor- a) to Humana. fttet, shellfish, srlldllfe or i lifts. 1;000 po/1. On absence of Sr-9Q and SO JCU. Ceten Must not render water or preeees-wnter supply purposes. _____ unfit for Industrial use: phenois DfeBahwd solids must not exceed 1.000 , ____ 500 mg./l. Must ba free from floating that are lOTSlgjftty or delatarioms or other wastes that saate. to farm putreacss* or obfectionebte sludge deposits. Tasds temre---- Free from aerates harmful to human, animal or squatis life Cu. 0.5 m*./l4 Zn. lJt Cr, QXB; Pb. 0.05; Fa. 0J; As. oxas f. iaxi c m EQU 001641 WATER PCB-SD0000043638 03-83 03-83 03-83 03 03-83 53-83 M" lOPMan bmmi 23 8.0 (date 0m fcquSnaniawta oBitom to OBCa aaniao. Tlvtttftr, Cater. Q*n Proa tea --tea that eauae sbfeettenabia eantetertera with InteasxilAf im B*iMm Proa from wvataa 2* Only If fteh aurvfvol 1/30 at the vafuaa ghran by MBS ?rw tram eon pn metes from amen t or oghcutturte urns. Taada end Oster: mtxtum. mica not Interior u mth In -- Proa from tutmmnam In eoo. entente. er martrea Ufa or that M Bmfta of '*2 PMS Drfrvldng Water wda- TBWrfcfiSyr Ms oteacftomtite turMdtty that can ba ta a patet aourea. fhdfate No floating or submerged met a ttodgo damlta ttat cents atearsaty street Industrial than natural origin r that could M_ ...__ Oates. Taste Bad 0dan Fioa horn a an2y" as nr. odor or taste te suesi a team aa fc ported) and form ursaigmty, datePrae from harmful to human. 13 XO (date swnisj Shot produce ' In aute.a degree a' " 1300 re0./l_- monthly oga. 7SO mg./l. Muss ba froa fnan unsightly, putreaeant tertete or Taste frm team anates ba EQU 001642 81 WATER PCB-SD0000043639 Water quality standards 1 WATER_PCB-SD0000043640 Water quality standards sctem, bottom da&edJtt, paattetoaa, spoetffc eontor escrt stream rascn or rMsr beam; sn This reprint is an excerpt from the "Plant Sites, '69" report that appeared in the October 29,1969 issue of CHEMICAL WEEK Copyright 1969 McGraw-Hill, Inc., New York, N.Y. This article may not be reproduced without permission. EQU 001645 WATER PCB-SD0000043642