Document bOyV8Xqayj5DjnReZLbJQpz8O

Monsanto Monsanto Comoanv 300 N. Lindbergh Soulavard 5:. Louis. Missouri 33166 ?!>ona: (31<t) 694.-1000 February 9, 1970 ORGANIC CHEMICALS 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 o 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, Turbinol 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 and app ir to present no potential problem to the environment. PLAINTIFFS EXHIBIT 000020 qQI' QU WATER PCB-SD0000052864 2 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 ff< (* ( M*.( Donald A. Olson Director of Sales ' Functional Fluids Groups EQU 001639 WATER PCB-SD0000052865 CUM / OCTOBER 89, 1989 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. Legislation enacted in recent yean has forced plannen to pay close attention to pollution control standards. All 50 states have had their water quality standards ap proved entirely or in part 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 American Public Health Assn. (APHA) subcommittee headed by TVA Health Director F. E. Gartrell, 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 state 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-bv-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-treatment 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 5608 million. Cleaner Air Establishment of air quality standards is not nearly as far advanced as are water standards. The National Aar 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 paniculate matter, will 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 implementation and enforcement plans will be initiated that can take over a year to produce standards. So far, no firm sulfur oxide or paniculate standards have emerged. But NAPCA's criteria for setting the standards sug gest they'll be tough. The oxide criteria report, for example, emphasizes that there are deleterious effects to man at con centrations as low as 0.04 ppm. NAPCA's control data reports present detailed appraisals of various methods and equipment, along with estimated costs. As in the case of water, the costs will be high, although some pollutants--mainly sulfur dioxide-will have recovery values. NAPCA is sponsoring a number of research projects to improve technology. Pollution control is being spurred by financial assistance programs (mandated by state law) now operative in the following 28 states: Arizona, Arkansas, California, Connecticut. Florida, Georgia, Idaho, Illinois, Indiana, Maine, Massachusetts. Michigan. Missouri. New Hampshire, New Jersey, New York, North Carolina, Ohio. Oklahoma, Oregon, Rhode Island, South Carolina, Tennessee, Vermont, Virginia, Washington, Wisconsin and West Virginia. In addition. Pennsylvania offers financial aid sanctioned by administrative regulation. Several states, including Utah and Maryland have legislative studies underway. The incentives take a variety of forms. Most common are exemption from personal property taxes (e.g., Arkansas), fast 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 numben 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 40million-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. 79 tQU 0 0 1 6 ^0 WATER PCB-SD0000052866 For th first time, a summary of water quality standards set by all 50 states. pH ABomMa Tmnparatura (**} aKowabto laCfMM _________ _______ ________ Povtatisa Miilawi l>rw MuH Otfw Requirements 93* tiny 8 hr*.} 93* (cooling water) -- 10* ElifTn ft * ******>' C*tor- tn4 04mr- Totee Suit,nc Only in *** *maunt:, *hst xould not render waters unsuitable for .ndustriil- sooting and procssx-wstsr supply purposes. Solids: Fris from rst mstsrials that causa unsightly or putrssesm conditions or Irttartere directly or indirectly with Industrial usa Alaska 7.0-8.0 0.5 70* -- 5.0 BateiaactiyftyT Not a sxcaod limits of PHS Orinking Watsr Standaros. Turbidity: No Imposed values that would intarfare with established levels of treatment. Cater: True color less than 50 color units. Tecta and Odor. Shall not unreasonably Impair esthetic considerations. Sodds No dissolved solids sbovs na tural conditions causing corrosion or scaling problems. No vlslbla evtdanca of ether floating solids or siudga deposits. No Imposed sediment loads that would Interfere with established treatment levels.* Teidc Substances: Chemical eonstttusnts should be below concentrations found to be of puollc heetth significance.* AriXSIM 6.5-8.6 0.5 93* 5* -- Bidlascthrtty: Not to eacaed 1/30 of the MPC- value given for continuous oceupatfonel exposure In NU Handbook 59. TurbidBy: 50 JCU (streams]; 23 JCU Gakaa). Os ten Free from wests mate- tils in amounts sufficient to change mating color truugh to interfere with Industrial uae or to crests a nuisance. Taste and (Man Free from wsstaa In amounts sufficient to produce enough testa and odor to crests a nuisance or Interfere with Industrial usa. Settee: Free from wsstaa that would ba unslgfttly, putrescent, odorous or In amounts that would Interfere with Industrial usa. Taste liibistiiuici Free from wsstaa toxic to human, animal, plant or aquatic Ilfs or In amounts that would Interfere artth ' Industrial use. Arkansas 6.0-9.0 1.0 (2* nrs*' 95* 5* 4-0 (average Hadtesufl>Hy: "Rules and Regulations for the Control of Ionizing TMrahjf cross Radiation." Arkansas Board of Health, apply. Tiobldlty: No dls- section] tinctiy visible. Increesee due to wastes. Cater: Shall not be In creased to the extant that It Intarfarss with Industrial use. present or future. Taata and Oden Must not cause offensive odors or otherw+se Interfere with Industrial use. Solids: No dis tinctly visible persistant solids, bottqm deposits or sludge - banka due to wsstaa. Toxic Tudteinrer Must not be present In amounts toxic to human, animal, plant ?r aquatic Ilfs. California S.5-8.6 7.0-8.6 (Coastal waters) -- 71.6** (fresh Nona that 6.0 BadtearltkHy? Shall not srrssri 1/10 of the MPC values given water) would causa Coastal watar for continuous occupational exposure in NBS Handbook 69. ecological 5.0 (untess Turbidity: Free from wsstaa that could altar water's editing ehanga or naturedy turbidity. Catert Free from substances attributable to wastes harm aquatic lower) llfa (coastal watars)* that produce detrimental color. Teats and Oder: No substances that impart foreign taata or odor. 3mldm Dissolved solids In hath watar must not mssd 300 mg./l. at any time; annual mean: 175 mg./l. Settiaabte solids must not be able to change nature of stream bottom or harm squetic environment. Texfc flubdUncan At ail times free from concantrstiqns harmful to humane, aquatic life or wild or damastic animals. Colorado 5.0-9.0 ' __ 93* -- 3.0 Baidas cthrttyr Not to exceed 1/30 of the 168-hr.uwask values In NS8 Handbook 9. Tuibkdtyi Must not Intarfare with astablishad leveia of treatment. Catert Wsstaa present must not causa appredabla ehanga In color or intarfare with industrial usa. Taste and Odsn Free from wsstaa that cause odor or appreciabte change in tasta. SeMu Free from wastes that are unsightly, putrescent or odorous or would Interfere with usa. Tsxte litestinrsar Free from wastes In concentrations or com binations sufficient to harm human or animal Ufa. C--OcUCHt 6.0-9.0 None unteaa K does not commended IknKs for in dustrial use 2.0 Bateaurffvdyi Limits to ba approved by aporopriata nets agency. Turtetety, Cater, Taoaa and Oden Nona In such quantittea that would Impair Industrial use. InHtVrn Umltad to imill amounts that may result from discharge of appropriately triad aasCBS. Tates tiiiliiiteiinuiiii Frea from chemical constitu ents In concentrations or combinations harmful to human, animal or aquatic Ufa. Oetanrara 64-83 5* - 50%apr4.0 BateaateMkh Alpha emftlare Itmhad to 3 pc/1_; beta smittars. to 1400 pc/1. Cater, Taata aad Odor: Nona In concentrations that cause color, tasta or odor. 3adda> Free from unsightly and malodorous nuissness due to floating Hds or siudga de posits. Taste ............ ..... None in concentrations harmful (synsrgteticady or atharartea) to humans, fish, shellfish, wildlife or aquatic IMS. Flaffda s.o-83 x.o 4.0 - Badtetiosa Uraaa beta 1.000 pe/1. On abaonca of Sr-90 and alpha ammare). TurtldByi 30 JCU. Caten Must not render wstar urrflt for Industrial cooling or proeese-wstar supply purposes. Tateet Must not render watar unfit for Industrial use: phenols 0001 maximum, aaddn Dtemnlvad solids must net axesed 1.000 mg./l4 monthly averspa- 300 mg./l. Mute be free from floating waotas that are unalghtiy or deteterious or other wsstaa that attie ta form putrasu amt ar sbtectionabte sludge deposits. Teste tidiidasiiniiin Free from wastes harmful to human, animal or aquatic Ufa. Cu. 0.3 mg./lj Zn. 14; Cr, 048; Fb. a05: Fa. 04; Ad. 048l F, 1041 Oi, node ilidniiiinitiliii, so EQU 0016 4 L WATER PCB-SD0000052867 3 ll q I i rg -4O *~4 o o 3 CJ HI 3 I iI . I. ,... mm? vriv . rr"T*\m "5 l 'm-4 WATER PCB-SD0000052868 Water quality standards WATER_PCB-SD0000052869 EQU 0 C lfc4 4 WATER PCB-SD0000052870 Water quality standard* 'ii. .............. Other naquirasnanta SMI not sarasd 1/30 at UPC. values for can id Mas Handbook ffl. Turbidity, ia amounts mat would change oditing turbidity __to croati public nuiaanca or Interfere with TdbiB Odert No wastes in amounts that would or ador. 1aMi Mo floating waste* that ara un- indMtrtaf use: no wastes that form unaigntiy or odereua budge or bottom deposits. ' Ho nates In cancan tr*Bona or combinations plant or aewatic Ufa or that would by appropriate state agancy. Mona in concantrstions that Mo floating aoitds, sludge ar aatid refuse. Taate titofnnrnim Mo chemical conid uoncanpetioad ar oombinatiema harmful to human. tea* change existing color a to craaaa nuiaanca or Na Hasting srastea that ara astea that sattia to that could titan 10 JCU Tsaaa said Odar, baibitir Dtaaolvad. or imanaigad mstiar shall not raduea vakna as as to rffart Industrial uaa. Cstart Maaa tfwt la abfactionabta. Taste -r--1 Odart Mo obfactionaWe odors In vtobdty ad tin water. Sadtio Mo iMsUnctiy visible Seating. irtitiahla or wspanded solIda of unreasonable kind or quantity. Mo obfacBonabta bottom dsooslts or sludge banka. Mo cancan(rations of oaatertala poisonous tohumaa, lalieud ar Ml Ha. dm Na materials producing cotor. taste titot sawla craaaa a noiaanea. WHb Ma- 1,000 m*./l.; dally merepa: 750 mO-/l- Na floating or utoniaigim dabrta ar waata subatancaa '' ' ' <fQuito In amounts to enaata Hana to eaneentratione or com- tads to tomaaa ar sf pudde haalth siqmflcaoca. Not e tooaad 1/30 af KM Handbook SS values. TetodKyi Na mans toad 11 XU shows natural (whan turbidity is IBS XU ar teas): ntiwrataa. na mors titan 10% abova natural Caton Csaantiaay fraa of aaatos tiwt visibly alter natural color af water or Impart eator ta vaaaata ar structuraa. Taste and Mart iHttiady fraa fram subatanoaa that would praduca dstactabla odar at alto of use. Mia tasantialty fraa from floating ar tin* ara uuatitiBif ar aattia to form sludge, ocean dnpoints. Tatoa BnaWsnimni Free from toxic In eonoonmtioas ar camtdnatlan* tsetie to human, sguotta life _______J rmmnm* from fdarti Wwter Poftrtfew Carrtrri AtkiWstowtan *wt'w*L ^ini . . JkMn __ r^h T hk. . : eumuMt* feast ddttton iftMfnfe few unnatural --ta raraso, t Mr posit fttrouetart tfes !* stream resc*i. T - highest t-m' z*&B"s'"rstsrt&nii*.s of Standards XU Jack*TM Canals UnM pe/1.--oteocurtoe par IIftar. and M Otetrtct of CteumMa. Amsocan Public Health Assn.. Suoeom- i an .W.. a.ter QuaSQf C-an-not-, and- -pdoflc iknHanr eof , carbon chloroform irtag isarin demand. tadSSrvanci im ite. oti. ganaa. sewn, bottom dppasks, paaticldaa. spseffie conana stana set rtaailnmn tar each ttnam reach or rhrar basin; In ;r -t-tuiv 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. ECU GQ16<t5 WATER PCB-SD0000052871