Document brxaxazdZvEVEeom4ZNGV54Z

Ferw Approved OHB No. 44-R1387 Approvsl Expires: July 30, 1972 fi.S. ilPAQTDIUI Of UDD3 ' * . - *' MATERIAL SAFETY DATA SHEET For. no. osha-zo H*y, 1971 8njo . PLAINTIFFS EXHIBIT CBRh 001562 1 WATER PCB-SDOOOO010710 inerteen R2 SECTION V HEALTH HAZARD DATA To&i sK01.8 CIMlI V41U< Hot available. C#MCI O) CvIMI'OR/M ^- - .. . ^. sun ivrit*tian An the fora of ehloraene. systematic intoxication yiuo-cl-ei-x-ac--dr-*s--etiom---i-n-A-a-io-u--s-o-ec--iae-u,---a-w-s--o__a_it_i,,n_g_,__lo_s_s----o-^-f----w---e--i-g--h--t-,----e--d-e--^m---a-.--a--n--d----a-,-.b--d--o-,-m---i-n--a--lp&la Eemave frem unesurt Remove contaminated clothing. wash contacted area with large amounts of water and soap. Merer to physician. SECTION VI REACTIVITY DATA ntaiiutf WfT4*.| | 4*oa lL *T4Ht |X fl.C0w*4f4iUlv > . Wjaaeeu* eieesa^esnio* eoutn CO, COg, smoke, soot, chlorides I chlorine IKitueenuium 1,4V sew etu .ev eceua e2aftjneo$ tdAv&e X I SECTION VIl SR111 OR LEAK PROCEDURES ]"frniat Js&sslzSl^D clav. sawdust or other absorbent material.________ in drums. Bury in approved chemical landfill In aceordence with local and state regulations. I*<"` 8l,,OUttl|"tf^rn jn an approved incinerator In accordance with local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION *tt,'**te*'.qmchoa">h3ureau Cf nines approved respirator for organic -VmIM. riutllON IOC At IIMI41 '*>1 fCtwaU 4UM * *L'>V' * J etma *ouetivi ciovit rubber im nancnaa Oln|, v*ot|C1lvi lOuiVMIbt SECTION IX |'<ic.wiie<<i io u i.iid > ntoenkt tieuii. Olnt, UC4Vl)0n, SPECIAL PRECAUTIONS ~ I,,n.ha,,la_ti.on of vapors While the Information and reeoaaeedatfons set forth herein are believed to be accurate as of the date hereof. MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAG:HOH:JTG:VBP 1/26/12 00156J ^ WATER PCB-SD0000010711 Fora Approved OHB Xo. 44-R1387 Approval Expire*: ` July 30, 1972 I.S. BEPA3TUEKT OF LiuOJ * -- . .* . . " r*r. 0SKA-20 * 1171 . ixlio- i..l SSfEH DATA SliEEl"~". . . . . SECTION I "l J^jQjjgAKTQJIQMJ*A KY _ , # * lb d No 78?'2 rTdo^fimfeetl frvlirS]. St. Lo(a Mlaaourt 43t66 (*(w(a^ 9 a a Chlorinated Aronatie }u>tlyeltr *31* Mixture a4iati, rusdTttiviv a I C4i,nr VtHiCU Wkvimi AMlIlWI emu a oUm** ALltTI & BtVAltlC COATWCI mt&A &U0f MtAU< caavtuei iuHrntllcD(H4KiMllC m ran uut fuaas k. . 4Z4iut BitTuan m avail uavnei. tauaL aa cam U' UTUwV.t kf i| 1 j i tutt.Kv.t iL< H 1* . SECTION III _______________ f one r^64^'............ . Noi Avail. | """"'"IV'iK'c r.ecllcible Uo.01! I imuMd *M esoa eolorless Oil _____ n mi i mm \ rwr c PHYSICAL DATA 1_________ u*xvtmirwt aVOiAVlil |yuilia till ._JMAJC___ ASv VC) v. r l^l.a7rjJ > r ............. 41 H! B kTCJ^tid *wS? 1 SECTION IY FUE AND EXPLOSION HAZARD DATA PuS^ShSmSou^"Mot Avail `ttaWKrmfc. COp, or dry chemical. a | ^e34pi'ratcory6 profccSion when flphting fires where exposure to j vapors or gases la possioae. _ y^T>Vv*4^Vet0?:&,byi4Jflhloride3 and chlorine) can be evolved in I fires of this product. wt . ii ll H &BAN 00156*. WATER PCB-SD0000010712 Capacitor 21 ffefcUnOtU kiwi V.iwi SECTION V Not Available HEALTH HAZARD DATA * Mjlani rr it a t 1 on In the fona of chloracne, systematic Intoxication leads to nausea, vomiting,"loss j aeigKZ^Tsn3TS& &sTS~aodesdnal "piT?, ........... ,, _______i' |.iCRti.teo*meC*ovt.m*e8oTf<ier4oJTfmaAIiBeeeaxoopccioietutsjauut1tre. I Ber.ore contam..ina.ted._ e__lo.t. .h. i..ng_ . .,w. a.s.h............................. M `contacted area with large amounts ox water ana adAtST er to physician. SECTION VI REACTIVITY D&TA 2TTs"**" *0-0 (tie wrests m . eieeu^etiTieai moewsrs C__O, C--O?, se_o.ke, soo. t, c.h,lori,d.es and. e.h.lorl.ne & eccue * C0ftit>Ot to Avote u o eceya X | 1 SPILL OR LEAK PROCEDURES 1|MAb10sPoA rb on** Ce* IltaVv4,l|**s4ai *wt MdUus Mt 3 oO*r Mo'itlinoer ^ab^s^orwb^ent material, Place I4nm drums. Bury In approved checlcal landfill In accordance wltn local and state regulations. ">>S\?Pntln`<ais(approved incinerator In accordance with local and state regulations. : SECTION VIII SPECIAL PROTECTION INFORMATION 1 viinkAtio^ Y(a . fer vapors ciovii rubber i moTiettvt ieui<*t moiui-i wiciA, ViiPOf S , 6<te chemical goggles | | SECTION II tc.w*>0*I IS * JLvjald _jLkl_n nndLj* v _contJLl Avoid .Inhalation of vapors. SPECIAL PRECAUTIONS \1 I Hhlle the Informitlon and reeoeaendatlons set forth herein art believe t be seeurite as of the date hereof, MONSANTO COMPANY' MAKES NO WAfiRAKit HITH RESPECT THEPETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAO:HOH:JTG:VBP VlR/72 4 WATER PCB-SDOOOO010713 Form Approved 0MB No. 44-R1387 Approval Expires: July 30, 1972 8.1 DEPAilKMI OF ucso Form No. OSUA-20 Hay, 1971 ff/oli. TtUilTflEltRUUU. SAFETY DSTS SHEET' KCTION I 3E _MgH^NlQ_^PAI?Y l ___________________ ' - Tt*lk)_$k-AQQ6 *11)d>h/eFSr5^d^es'gir*fe^yfev4<,i^, St. Louie, MTgBgurTfeSifefe I Cai>(4k Fomu, 9 Chlorinated aromatics I ] Mixture | riiitt, Misiiutivn, a mvnm I !6tNt| 1 citttr | VtetCU . 1 latviMi 1 se<Dwii I % ruu*i UIITI AN MtTAtUC COSTM6I SAM tailAt &um% tatAtuc eoAtws&s lnAuttile HbAtiiiole o etn nut dates ** * . * 1 MlliSSOVt ISTVtfl Of OTnll UlUtOl. ttllBL 0* Clltl '` a . . O. * Uv 1 (UahiI 1 (Utt.vll.t 1 | SICTI OH 111 PHYSICAL DATA I Hume ?0<l flj | VA*ea fllltuD tmm J 1 VAMO* OIMtlTV UMill 1 saoa 7 20 )-*15c wcm.,.8V.(15(5/15.5,c ^ H99fiCVIfWevTuVq&VrtAlflU n >t Avail . ItVAHSAmAIlire.* fiAintl n,,llrlbl# Not Ava ax__________ ____________________ colorless to yellow oil aromatic odor 1.564 | N. A.j a[ i SECTION IV FIRE AND EXPLOSION HAZARD DATA iuk *Qt* I iaea en loauitatHo haoia HA ,,4^***L| UHI ie' w.l 1 ---- msciaa tienioab reaeisuaes Fesplrfttonr.protettlrtn whn fluting ,rir ,,vhr exposure. to vapors or gases Is possible. ^Yv^mriTa^eTmieridee and chlorine) can be evolved in fires of this product. 6BRh 001566 WATER PCB-SD0000010714 ) Inerteen PPO SECTION V HEALTH HAZARD DATA twuwoioumiiNot available, IllMCII 0* OVIllOfcJ*l sun in the . form cf chloracne. . ,,. systematic .^ . Intoxication 1 leads to nausea, vomiting. loss of weight* edema and Abdominal pal *o *>b*i aio neciMii .............................. .._................ .......... .......TtT "J J R*-nvn frnm exposure. Pcmove contaminated clothing* Wash contacted area with large amounts of water *nd aoap. hei'er --- to physician. w.r.M SECTION V! REACTIVITY DATA tWSiRtkl it.iu i*C0M4t 4.1.11* (hHIHlt M tnUI X ]..i4400ul DICOMOtltlO MOOwCTS 1'041JT4M4M00HU4|1IO* MAV Mews wuv *ei eeeua con&n&di le *vote i SECTION VII SPILL OR LEAK PROCEDURES MlA*1b1s0 otlrbmison14 Cc0l4aKy,illls'iai wU dUuIs*tM 0o0r* Mo>tkhlOer a.bsor.ben.t ma. ter. ia,l. Place AIn drums. Bury In approved chemical landfill In accordance with local and state regulations. `teurn^n^an^approved Incinerator In accordance with local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION ) mm*.i0n 'iomctio*of Mines approved respirator for organic vapor.* VlftflLAIIOM iOC*k II..UII _Yea - f_or vapors MIC4ftic fCt--mlt tf% Clkk oimt owetlvl CkOvM 01U *0UC1IV| lOumMtat rubber in *oticft chemical goggles SECTION IS IC.WllOXI 10 M l4* Id ...en.fi 4*0 * -- Ivni H *Hn and cnnt&gJL- Aold inhalation of vapors. Otnl* JC4Ull0ftS SPECIAL PRECAUTIONS While the Information and recomaeodatlons set forth herein are believed to be accurate as of the date hereof. MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THERETO AND OISCLAIHS ALL LIABILITY P.ROH RELIANCE THEREON. JAO:HOH:JTC:WBP 1/26/72 6 RHRN 0 0 I5 & P WATER PCB-SDOOOO010715 MONSANTO*S FOB PROGRAM W. Bo PAPAGICRGS Presented at ANSI Committee C-107 Meeting - September 14 # 1971 I appreciate the opportunity to share Monsanto's PC? experience . with you and Z hope the Information Z have can help'this committee plan and achieve its objectives. Ve at Monsanto first heard of PCB'a as potential environmental contaminants In early*1957 when we received copies of a talk given 'in Sweden by Professors Widmark and Jensen the University of Stockholm. Zn their paper they described how they were able to identify a material which had been interfering with pesticide analyses as being polychlorinated biphenyls. Our laTboratories began work on the development of analytical methodology to confirm that PCB's Indeed were being found in the environment. During 1953 and 1959 as methodology improved the evidence continued to indicate that the higher chlorinated biphenyls were being identified in the tissues of fish and birds. * During this period Monsanto mounted an extensive program aimed ** at acquiring more knowledge about PCB'a and their effect on the environment. Ve perfected our analytical methods, we started* / animal toxicity studies, began biodegradation work and evaluated alternative materials for those applications we felt were ccn- tributing substantially to contamination. y*7<s 100 WATER PCB-SD0000010716 Our animal toxicity work was similar to the type we would have undertaken if we had wished to have FDA approval for food use. Chronic toxicity and reproduction studies were made on leghorn chickens. Two year chfonic feeding studies were started on rats and dogs. Three generation reproduction studies were made on rats. The FCB's used in the tests were Monsanto's Aroclor 1242, Aroclor 1254 and Aroclor 1250. These were selected since they represented * the more commonly used PCB mixtures. The animals were fed con .centrations of 1 ppm, 10 ppm and 100 ppm in.their normal diets, * The results to date indicate that at the levels use*d the rats and dogs showed no effects with Aroclor 1242. At 100 ppm both _ the rets and dogs exhibited decreased weight gains and enlarged * livers. The chickens were affected by Aroclor 1242 at the 10 ppm level. The hatchability of the eggs was significantly reduced. ' 4 * 0' "stKmaf^zT-VhiVTr^rr irnSriftteu**Mohsantss* * toxicity work the. highly chlorinated polychlorinated biphenyls . . .1 at 100 ppm in the animal diet does have some effect on mammals. The lower chlorinated polychlorinated biphenyls at 10 ppm in the ' diet ha* some effect on leghorn chickens, and Z say specifically leghorn chickens because there is mounting evidence that there S are definite species variations as determined by the Pautuxet Laboratories here in Maryland with four types of wild birds. There is a species variation noted which frustrates many scientists 5M 007e9-i 101 WATER PCB-SD0000010717 I -3- o . I was asked what we know about the effect on marine life. Kor.sa-.to did sponsor static fish toxicity work and we were completely frustrated because these FSB's have the tendency to plate out on surfaces. Our inform* ation was garbled because in the static testing we were really exposing the fish to PCS environments a lot less than we thought we were. The data was so distorted it was meaningless. Zn the meantime, we found.that there are many competent laboratories looking at fish and the effects on fish that we decided that maybe this is an area that is best left to the experts. ' * ; & 9 We have been in touch with laboratories such as the. Water Quality Laboratory of Duluth, Minnesota. They have conducted studies which indicate there is some effect on some species. There has been some work done in the Columbia, Missouri Bureau of Interior Fish-Pesticide Laboratory which indicates, for example, magnifi cation about 50,000 times. By that I mean that the amount of PCS detected in the fish tissues was 50,000 times that present ' in thi water environment in which this fish was exposed. 0 There have been reports of fish kills and some very drastic effects attributed to PCB'a I*ve tried to get evidence that ' these things have occurred. Z have not been able to confirm any reported incident. */ We have talked with scientists at the Gulf-Breeze, Florida Commercial Fisheries Laboratory. They have conducted studies ADM 007695 102 WATER PCB-SD0000010718 -k with erab and shrimp. This is the laboratory that did detect a build-up in crab and also the lethal effect on Juvenile shrimp. Very, very low concentrations - 5 ppb in the water - do destroy 0 Juvenile shrimp. - There is a growing thought among many of the.responsible scientists that this environmental problem is most complex and it is not really any one Insult that is the demise of any particular species, but it could be the cumulative effect of all insults a creature t is exposed to and usually the last Insult is the one that gets .blamed.. Dr. Tom Duke of Gulf-Breeze is a proponent of this ; theory and he is conducting studies to substantiate*, this. It could be the lack or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a cadmium or a mercury or an arsenic, and along cernes a ?C3 and the fish dies. PCS might get blamed. This is the kind of thing-that does happen in the environment. There is a growing concern that we should be considering to a * greater degree chronic effects of all these materials rather than relying on the old acute studies that used to serve as a screening*' for many, many chemicals. I have sketchy data on marine life. We know that it does build up in the marine environment and ' there is, of course, the published evidence that it does affect the fish eating birds. ADM 007696 103 WATER PCB-SD0000010719 I ^5- 9 There is some indication in the Duluth studies that reproduction . and survival of the frye is affected. There seems to be minimal affect on adult fish. It was suggested earlier that I might want to review the manufac ture of PCB's, the many applications in which it was used and what our present program is. To the best of my information, it was 1929 that these materials were introduced as very attractive fluids for use in transformers, and there are many in this audience * ' that '.re more familiar with this development that I am. FOB'S _ were usedin transformers as aninsulating cooling .fluid because # they are more resistantto breakdown, less apt to explode and burst into flames and cause property damage and human injury. Through the years, additional uses were found for these materials - because of these properties that I mentioned earlier. They gradually at first, and of course with increasing amounts, ended up in applications that Monsanto through its in-house usage referred to as plasticizer usages. That is not a very good description, but At fit our needs for many years, and you'll find* 1 us using that expression. These are uses such as in paint formu lations, the specialty ink uses, the plasticizer in sealants, adhesives, and paper coatings of all sorts. */ There was a use that was a real thorn in our side and you'll see at least some of the earlier articles on FCB's referring to pesticide use. There were some studies conducted by the Department of Agriculture in which FCB's were used to extend the effect of * * * A .0 # a **Aw.-4 'J sj . y J t104 104 WATER PCB-SD0000010720 life of pesticides such as lindane. It was never intended for broadcasting as we visualize DDT was on food crops, cotton crops, or orchards. The only widespread use that Z could find was a limited trial to help prevent or curtail the dutch elm disease, and that proved to be a failure. The other uses were extremely small in private formulations that were used to spray or coat hard surfaces - shelving, corners of floors and all for the typical crawling type insects such as the roach and silverfish. In fact it was so small that.Monsanto did not market directly to pesticide formula tor's; we gave this business to our distri- e ts> butors. On the other hand, this use did cause considerable emotion and was used by some to explain thepresence of PCS *s t, in remote areas. We wrote to the Department of Agriculture suggesting that during 1970 when pesticides were being re registered that PCB's not be approved. Finally in October they did put out a notice to that effect. We have had questions raised, "Is it in my shower curtains at home?' Is it in the draperies? In the Carpeting?" The answers f0 to those is "not very likely". And I use those words because we really don't know. If it was put into these applications, it was so small we, Monsanto, were not aware of it. It was not used in automobile tires; it was not used in brake linings. ^ Other major uses Include the use in hydraulic fluids which are fire resistant. Monsanto marketed these fluids under its trademark Pydraul. I am sure some of you remember the Livonia,*** *** CO;**,. 105 WATER PCB-SD0000010721 Michigan fire? This was a disastrous fire in terns of property damage and was really a high mark in terms of convincing industry that there was a need for fire resistant hydraulic fluids. But the application la not the type that is maintained to a degree where everything is leakproof. Many of these connections leak, hoses burst, and the tendency is to keep producing by adding more fluid. So it is conceivable that many of these hydraulic fluids ended up in the sewer. Z do not Intend to criticize the customers of our products* From the knowledge that we had * at that time of the material the practice was considered acceptable * #f Another fairly widespread application of PCB's is the use of these 'fluids as a heat transfer media to achieve high temperatures, have a fire resistant transfer fluid, and avoid the installation of high pressure equipment. These materials were Ideally suited ' for this application. Ve thought at one time that these were adaptable to close control and proper maintenance where we could logically call them closed systems. Some recent evidence indi cated `that we were wrong and I'll get into that when Z discuss 0 our present applications. Cne application that was a fairly significant one and one that ** in our thinking is associated with coatings is the use in car bonless reproduction paper. Vith the emphasis on recycling paperS wastes and with the persistence of PCB's there is a problem developing in that PCB's are being found in many paper products and many of these paper products end up in food packaging. SM 007fe95 WATER PCB-SD0000010722 ) -8- Initially the evidence we were getting seeaed to point to the higher chlorinated materials as environmental pollutants. As soon as we were aware of this, we. sent a letter to all of our customers telling them that what little we knew indicated that these materials could be an environmental.problem, and care should be exercised in handling. When the results came in on our chicken toxicity studies they indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that *e better place some restrictions on these materials because there were to us some uses that deserved to be kept in spite of the problems that we saw facing t , us. '' We decided that we've get to get out of those applications where we felt there was no earthly chance or it was beyond our ability to control the introduction into the environment, so we got out of all the so-called plasticizer applications. August 33* . We then went into*a very active program of reformulating the hydraulic fluids. There'again, it required a lot of testing. We had to run these new materials through the Underwriters / Laboratories for approval on fire resistance. They had to be compatible with the machinery then in use. This is not easily / done, but it was done. ' We decided that we could and must continue to supply the trans former manufacturer, the capacitor manufacturer, and at that ADM 0077 107 WATER PCB-SD0000010723 time closed heat transfer systems based primarily on our concept that fire resistance was Important In heat transfer. To pick up the point that was raised earlier about foreign im ' ports, we are to the best of our ability trying to monitor Imports. To this day, we have no Information that any have arrived In this country. On the other hand, we are getting some reports that some of our former customers have made inquiries of the foreign producers. Z am also told by some Canadian provincial agency people that they had heard and were going to further Investigate that PCB's were entering Canada.and from there ,9 moved .into the United States. I have talked to representatives * of the Japanese producer, the Kanegafuchl Company, and Z am led to believe that they are most reluctant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering the U.S. market. Z have talked to representatives of the French companies. They assure Zn Kay, 1970 Congressman William Fltz Ryan Introduced a proposed bill which would In essence place Into law the very things that Monsanto had proposed doing on a voluntary basis. The bill provided that PCB's be banned except for those situations where the Secretary of KEW would give special permission or license. ' We went through the latter part of '70 and early part of this year feeling, however, that we were still walking on thin 1st. -I ol 00 ios WATER PCB-SD0000010724 10 - But we thought that we had made seme tremendous strides In the right direction to preserve those uses which we thought were essential while eliminating those uses which were grossly con taminating the environment. This summer our hopes of control in the heat transfer business vanished when we found that a user of PCB did not appreciate the problem, did not `maintain his equipment and created the recent chicken, egg, fishmeal problem. t. Became of this Incident, Congressman Ryan withdrew, the first bill that was submitted and has now placed before the same com mittee e bill which totally bans PCB and does not provide for any use whatever. And there are, of course, penalties for the marketing, manufacture, or use of PCB in this country. A very drastic measure which does cause or can cause a lot of concern among.these of us who feel that PCB has a place in our society under proper conditions. "XI Trisult position. We decided that,although heat transfer systems could * be closed units, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the * situation where even a pinhole leak can create tremendous pro blems before it can be discovered. So we have taken, again, ' *" an arbitrary position and informed all of our customers in the food (whether it's animal or human food), packaging business, and the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. adm OjTT j- 109 WATER PCB-SD0000010725 I 11 - * In addition, we will no longer market to any new heat transfer applications. Our efforts will be concentrated on reducing those that we market today. This business should decrease as time goes on. - To get back to legislation ... as many of you probably know, there is before Senator Phillip Hart's committee a bill referred to as the Toxic Substances Act of 1971 The purpose of this bill is to prevent the Introduction into our society of hazardous materials. It also provides*for the review of materials now In our society and the curtailment of the use of the more hazardous * .* ones.. Initial hearings were held in August, to which a select few Individuals were invited to testify. PCB was brought out as an example of a material Introduced into society and thought at one time to be most valuable, but is now considered a serious threat to all of us. The meetings will be resumed in October; 1 do not know the exact date as yet, and 1 IVvlf^ottrd" Tftr-*ttiV" opportunity for industry to apeak up in its behalf. .1 am assuming that since PCB's were brought up as an example of the type of substance this bill is supposed to prevent that Monsanto as . sole producer in this country will be either invited or we may choose to ask to be Invited (we don't know at this point Just what is the proper approach here) to speak on the merits of retaining PCB's in transformers, capacitors and fire resistant heat transfer systems, non-food applications. AD. 007703 110 WATER PCB-SD0000010726 - 12 I mention this bill because it is our opinion, and we could be wrong, that rather than act on Congressman Ryan's bill, which Is specific toward PCB*s, we suspect that the Toxic Substances Act will have in it provisions which will refer to such materials as PCB's. 'e We feel we have good technical data to Justify our staying in the business for limited applications. But we cannot overlook the emotions that have set in. And believe me there are many and they are deep. Xt is difficult to combat emotions, as you know, and the references in the popular press to hazardous poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we talk about per sistant versions of PCB and degradable versions of PCB X sus pect, and this is a personal opinion, that there would be many who Just discount' this kind of information. This is a very real problem; in my opinion it is a difficult problem. As a little more background let me describe what X understood from a meeting we. held last week with representatives of the Food and Drug Administration. Xt is my personal opinion that the Food and Drug people are as conscientious as can be in trying to cope with the PCB problem. They are objective people trying to work with a minimum of data. X suspect they are as frustrated as any group of people can be as to what is the right way to go. There are tremendous pressures on the Food and Drug people today as well as the Department of Agriculture brought about by critics. . ADM 007714 111 WATER PCB-SD0000010727 .1 - 13 - e These agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. . . The FDA people really don't at this point in time have much Infor mation that will lead them to a regulation as to ho* much PC3 should be tolerated in food. They have established some guide lines based on what little information they have from their .own laboratories and the information that Monsanto has shared < with them. The FDA will permit fish at 5 ppm on the market place;- milk at .2 ppm or less; eggs .5 ppm; #-pountryf (they have a double standard) 5 ppm in the fatty tissue and 5 .ppm in the muscle tissue. Another problem that Is disturbing to the FDA, is the recycle paper problem. The cereal boxes, the cracker boxes, all of ? these boxes that are made from what is known as chipboard, are made from recycle paper. Fairly high levels of PCB's are being.found in this recycle board. It probably comes from about three or four different sources. It may come from some ink application in the past, some adhesive application, some coating application, as well as the carbonless reproduction paper appli- ** cation. There have been some pilot studies made by the American Paper Institute to isolate the carbonless reproduction paper* S from the recycle batch. They still found PCB's in that batch. They are probably looking at maybe the second or third genera tion of recycle. And with the emphasis on recycle, I cannot see any way out of this dllema except that there will be more and more PCB's in these cartons. ' ADM 00770= WATER PCB-SD0000010728 14 - A thought we must all keep In mir.d, too, is that wt'vt got to live with the PCS 'a we Introduced into the environment for the past 40 years. They have not disappeared overnight; they will not disappear overnight* We do not have any tests that tell us how long it will take. We can only made an educated guess *e and we might say they will be out there for another .`generation, 25 to 30 years yet. Hopefully, It will be a decreasing amount as time goes on. - *, t Monsanto has conducted .biodegradation testa on its products. We have three programs that are now active.* One program we are conducting in our laboratories in Ruabon, Wales in which we are making what I would refer to as scientifically basic studies in terms of wnlcn isomers are most degradable and with what type of microbe. This is a little bit on the impractical side at this point in time. We have as a consultant, Professor Charles Evans of Bangor University in South Wales, who is a noted authority worldwide in this kind of activity. He has isolated at least three microbes th0at seem to thrive on polychlorinated' biphenyls. These microbes he developed from soil that he obtained from his garden. What this tells us la that there are microbes out there # in the environment that will eventually destroy these materials. In the St. Louis area, we have two types of tests going. Cne y la the use of river water with Its normal biota in it, in which we introduced polychlorinated biphenyls and look for the disappearance rate. It is a very quick and rather unsophisticated type of study. The other type of test is the one that simulates AL)M uO 77lie n: WATER PCB-SD0000010729 ) - 15 - ' & those conditions which ere apt to be found in a normal municipal sewage treatment plant. Zt'a an aerobic test using an activated sludge from a St. Louis waste treatment plant. As a standard, we use a soft detergent 'because It Is well known to other laboratorie Vhat we are doing, really is using our expertize that we established back in the days when the hard versus soft detergent? controversy was quite common. And we are using these soft detergents that do degrade as our controls and comparing the PCS'a to these con trols. The studies so far show that there are Isomers within each of these mixtures 'that do degrade. The lower the chlorine . level,* the faster they disappear, the higher the chlorine level the more resistant they are. Which only confirms what many of I( us had suspected. We were not too surprised by this data. I will attempt to summarize ... Z think we can conclude that PC3's.are in the environment. There is no question about it. Many of these PCB's are manmade and were Introduced to the environ ment because of our lack of understanding of what these materials can dd to the environment. Zn this country Monsanto, as sole , producer, has attempted to Improve the situation by limiting the applications to which these materials are used. Studies . .. today would Indicate that these PCB's are not and cannot be 0 classified as highly toxic. There is still a lot of information that Is needed to help us determlne the long term effect on human beings. We feel that the properties of these materials make them# at least as of today, the most suitable material for use in trans formers, capacitors and heat transfer systems. We also believe that under proper conditions we can control the amount of these ASM SO7707 WATER PCB-SD0000010730 - 16 - * that do eater the environment to the point where the adverse effects are not great and that the benefits we derive far cut* weigh the minor adverse effects that we might notice. Now there are many of us in the transformer and capacitor application that have made tremendous strides in controling these materials. I suspect our objective Is to further improve our ability to control this material. In my personal opinion the emotion that is now prevailing regarding PCB's is something that we must contend with. Whether we believe In it or not, there are many people that sincerely believe PCB's should-be totally banned. .* *115 t 00 V3 j 115 WATER PCB-SD0000010731 Monsanto 00 N, liritfStrfh St. I*wit. Mittturi iSISS 014) CiUe*4 4*1000 March 3, Ifif mmttgmguni On February 24, the San Francisco Chronicle carried a major feature about "a menancing new pollutant" found in the San Francisco Bay area. The article was based on marine life re search carried out by Dr. Bobert Bisebrough of the University of California. It stated that residues of polychlorinated biphenyl (PCB) were killing certain marine birds and posed a long-term threat to humans. and its claims may be repeated elsewhere. As you know, Monsanto manufactures polychlorinated biphenyl and markets it under our Aroclor trade name. We, therefore, would like to present some additional facts. The work done by Dr. Bisebrough dates back to earlier research by other scientists to analyze the amount of pesticides in wildlife, soil and water. The initial pesticide research was extremely difficult since any search to detect mate rials in the parts-perbillion range also brings out ether *'interferrngM substances. *0 100'! 18 . 1130 I WATER PCB-SD0000010732 Sever*! years ago, two Swedish scientists at Stockholm University's Institution of Analytical Chemistry, Professor Gunnar Widmark and Soren Jensen, reported they had identified the ether substances which we re appearing during analysis of chlorinated pesticide re si* dues. They said some of the materials were polychlorinated biphenyls or PCB. The amount reported was in the parts*per*billion range, er less. Since PCB's are not "broadcast" er spread around the land as are pesticides, the scientists theorised that the source must be the** industrial wastes ef PCB users. * . Dr. Kisebrough's more recent work reports the identification of PCB, along with DDT and DDE pesticides, in the tissues ef birds and fish on the West Coast. 9 e The conclusionsof these scientists are puzzling from several aspects. Polychlorinated biphenyls are stable chemical compounds which are essentially insoluble in water. Their use does not make them easily released into the natural environment. . " A principal market for PCB is in electrical applications where they are used as insulating fluids for transformers and capacitors. In this use, the chemical is completely sealed in metal containers. Another market is for heat transfer applications where the PCB fluid functions in a closed system. PCB's are also used in several "plastic type" applications. Here the * lhemfe*X'Sb 'of-1 solid material. This applies whether the polymer is used as an adhesive, an elastomer or a surface coating. * * The Swedish and American scientists also imply that polychlorinated biphenyls are "highly toxic" chemicals. This is simply not true. The toxicity ef any material, whether it be chemicals, drugs, natural plants er even foods, is relative. Compared to the thousands ef industrial chemicals and home products, PCB's are not toxic unless they are mishandled or misused. During more than thirty years ef e U.S. production and use, cases of any toxic effect have been extremely rare and then only where the simple precautions recommended for use were not followed. 81 100215) 1131 WATER PCB-SD0000010733 J V. 3- To our knowledge* polychlorinated biphenyls are not sprayed or dusted on crops* woodlands or any other areas* as are pesticides. It is. therefore* not only puzzling, but extremely difficult to con* ceive how commercially produced PCS can shew up in wildlife as DDT and other pesticides appear to be. This raises the question whether the substance identified in the Swedish work* and now in California, is actually PCB -- <r whether they are materials which, due to the metabolism of other materials in the marine environment* appears to be PCB. ' Unfortunately* even though techniques for analyzing tissue samples have become quite precise, the ability to analyze the possible impact of naturally occurring substances in the food cycle of living organisms has not made comparable advances. Monsanto has a research program to confirm the identity of the compounds reported to be PCB by the Swedish and California scientists. We also cooperate* on a regular basis* with federal, . state and university laboratories in their analysis of chlorinated hydrocarbon residues. Additionally* Monsanto will continue to exercise the highest degree of control in its manufacturing, shipping and storage of PCB -- as we do with all products. In the functional fluids market, we have m. v ** *o.ar#ie^'out ^-programJSHrv.al -years.oX`.$h*urelam*t6fe. cafe used PCB's to avoid disposal of these valuable materials. The source of the marine life residue identified as PCB is not yet known. It will take extensive research, on a worldwide basis* to confirm or. deny the initial scientific conclusions. We will keep you advised of our own research and are available to answer questions as they may arise. Very truly yours, , /ecd Elmer P. Wheeler Manager Environmental Health 100250 82 ? 132 WATER PCB-SD0000010734 Form Approved OHB S.S. OEPABTLjEST OF lACOB Form No. 0SHA-2( No. 44-AUiI . .------* Hay, 1971 Approval Expires: _ ^/OlV July 30,1972 * ~ MATERIAL SAFETY DATA SHEET' . prrigrrgsCTSgSEsrnrT^^ 1 `` ' * *.' * SECTION 1 . 1 MPNSANXO-CQMRAKY 1 * HIM 6^-JQQO... I * 1^)d'n o rt)TLirnib e' rfTT'feoufevar<1, St. Louis, Missouri 63166 1 Mixture * * * 1 fnerteen 5*201 JKJ 1 , *ww * 1 f*>Wb4 i Chlorinated Aromatic 1 mixture 1 SECTION II I fillTI, MMI4tlV S MlVlNTt % 1 hcm*U...................... I CAtaitrt .. 1 VIMICll | taiviNit .. * 1 400irivtt I OlHItt . . . .' 1 .. tLV &LIST1 4N AtTAttIC CSATWCI 64JI mtAk AAtSV MTtAlUC eATl6t . luWi1itCw64itiile tm CM UI et*aes | ` " Hiiitoeus biituiii r Stall utuist, tOList, St SAUI 1 - 1 " . ' 1 -- ... 1 . . ............. lx ihbi AT ""l a Ttv j 11 | ' T tv | 1 1 1 i ' SECT! ON 111 pe.^o ^ fM 760 n f< 0-350e v**o eiaiirt Mam t Avail t Avail tatuaibm m etie ,, _______________ 2 QPCjafiffll jrihli *o eeoa eolorleaa oil PHYSICAL DATA ________ ____ MC.su.y..B|M.t25/15t5,c) *HCI* VMATItl IvtrgiiMM sail aromatic odor 1.333 N.A. <1 ! [ 1 I f * SECTION IV Ub*ra*r . Non@ emeetAsmiMe me* FIRE AND EXPLOSION HAZARD DATA j o*T8 I ^ 1,1 Uei | :: 'Trap oicitk nemao nocti __ ,gLfis^hpn T.ifhLing-tires.j<harjt avpntug*| to vapors or gases Is possible.. Wiftl'/'m`^cgyW*ahlorldss and chlorine) can be ovolved in Tires of this product. ~ X Z*',7ZX. . S'* CBRh 001568 WATER PCB-SD0000010735 Inerteen 5R201 KJ SECTION V / HEALTH HAZARD DATA' 7t* t-375Tn.it y^.wi" Not available. 1 In0'fr leads r to ^aVion in tbe fora of chloraehr.e, systematic intoxication, nSui"d7"V6falTXngr"ggrc~CT,wrsnT7-^i^jifTHrapstEZl-pcr T. .a **.o * aidMoeiewua2)ueV( contaminated clothing. Wash contacted area. Remove from exposure. Wash with large amounts of water and soap. Refer to physician. SECTION VI REACTIVITY DATA UUPMLl Tvqstrse) *COw*4f4l<4)f* IT4IU M tn^/ X B4/4*oowt oicoM/oimsx meewejLV. Q4j4*00ul OlM44U4tlO*4 uat oeeua mu ei eecua eo*oio* to avoid X- | .. 1 SECTION VII SPILL OR LEAK PROCEDURES lll'l I0n Ui|i, I. C4II 1'4|(-'UI*II|4MS 6< t>HUO . tt . Absorb on clay, sawdust or other absorbent material. Place In drums. Bury in approved chesleal landfill in accordance with local and state regulations< B4|T| 9l|Ct4l M| IMOO lurn^ln^Jin .j local and state regulations, jartLam s t i'l th. pj* *!*? SECTION VIII SPECIAL PROTECTION INFORMATION oTfd f?y>r 40644,-4W,, yeB _ for vaper. VICI44 MlCuotCtk iCtmmU eiM,* in neuciwn Chemical goggles 1 j SPECIAL PRECAUTIONS ana eve contact. avoid inhalation of vapors While the information and recommendations set forth herein are believed to be accurate as of the date hereof. MONSANTO COMPANY MAKES NO WARRANTY WITH RESPECT THEPETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE ?HEREO-N. JAC:HOH:JTC;WBP 1/26/7? OBAN 001569 .............................. 8 WATER PCB-SD0000010736 Form Approved 0MB No. 44.11317 Approve! Expires: July 30. 1972 0.1. DEPAMOT Cf IAOOB Form No. 0$HA-i Miy, 1971 MATERIAL SAFETY DATA SHEET' SECTION i MONSANTO COMPANY - 11 vUj \ fioii.i n*o d00 North Linebereh Beulev&rl* St. Louie* Missouri 43166* . *Chlo*r InaVtd Aromatic Aroelor 1212 Mixtures fj l 1 iC**t c.t.nn mi ;ti4'.ii * Munn MlV|t| .ee>tivit e*<N* ! s ! J.V,, tUITI M iltlUK (IIIINII All Mt*4 e&i.en Mt4|lC ClilMI H\witlleeM.no4|e m cm hui mil itliiMut .iiTvart .a 1MIUIvtet. tenet. mi IVTt.V..I s rv?i. 11 | .-V--i. tottotr-S4*b *M*-**vv**-* W....C e.*i fii 760 SOB 290-325*C *** `M*"' *''{25/15.5*0 ''WMMtP--M elm.** umii 1 .60S H8 K.OIIiIl*V* .H*.itlll Ndt A. va.i.l tv..ov* mi iol..i.f..ifi^t 25c ntRllr:l*lt<0.ei ' ^ i^umii<Mei eoloricss on l aromatic oaor rrmmmml.T,,lm"-`.--^1"41B, 1.271 f W. *. 1} <1 >j J i SECTION IV FIRE AND EXPLOSION HAZARO DATA c.o.c.. 3io*y ..Bit* ^ _ ' Not Avan. | soars.*:.) i==l *Wa,,E'A"",<r`gift, CO? or dry chemical. Pr*tri*rtof rr" tec'tion when flrhtlnr fires where exposure to vapors or faicseesi lIsi cposslible. ^-T-V VSxycTOrfcTf chlorides end ehlorlne) can be evolved in fires of this preuuct. " 6BRN 00157Q WATER PCB-SD0000010737 Aroclop 1232 SECTION V HEALTH HAZARD OATA I k'W>! VAkUl vrsssnr Eit'tll <4 Ot Ovi*.lCk>*l ,,,, . 1 _r.lij n ir-jat1 a: In the fom of chloracne. svr.ter.Atle Intoxication , "leads to nnu&er, vomiting* less of wiir.nl, eocna and tudonunaj. paim 1 ^HemevV"frcmVxVosuro. Peaeve eentar.lnattd elothlng. Wash *eontaete3" area *itn large amount* #ofUilir "and-u*p Jliiir1 ;o*pKysTe`ian7" .......... * ...................... ................ .. - k'4.k.l. W*ft4fel IHHI *C0**4V4#utv* (***! SECTION VI REACTIVITY OATA ^ I*w*4 *L **4A0 X .4i*ovt#ie*^on'**Awwet^Q^ C02t aaoke, seel, ehloridea and ehlerlne >4f400ut ** ecct* su*eteeeue fnmomt t lM X L 1 | SECTION VI! SPILL OR LEAK PROCEDURES T' Ab s orb "on" Vi'aV.'Vhvdus t'Vr Vine r "atsorfc'ant Ratlri" Place In' -- drums- . ---b--u--r--y----i-i-T---a--p--p--r-o--v--e--d----c-n--e--m---i-c--a--j.---i-a---r--.--a--i--l-l-l-'-I-n-----------------------`-w- l lit' local ina-xiiTTTgcgxrfBnrT----------------------------------------------------------- ** approved Incinerator lr. aceerdanee witn local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION "**' ,*"**/*' Yes - for vapors Micitk ... | it|(*n(Mrnn0 .U *0!|C'II CkOvll rubber Ct.|* S<IC"v< IBuMwtVt | u wmiw ehemieal goggles iTHHIUllflilHI--^.W'lliilu.jillA* . SECTION IS *ll 4 /jvoi`dJrf R*alk*ini * *a^d evtA**4#eHonvt+nuef^c. | /yoli inhalation of vapors E t-U PtlCAwMMft SPECIAL PRECAUTIONS OBAN 001571 1 uasst mJ While the Information and recommendations set forth herein are believed to be accurate at of the date hereof, MONSANTO COMPANY HAKES NO WARRANTY with RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. JAC:HOH:JTG:VBP * a/it/79 10 WATER PCB-SD0000010738 firm Apsrove* ,M8 NO. 44-R1387 Approve) iplr*: . July 30, 1972 * v.5. cj uEaa Fora No. OSHA- Miy, 197) Hn SAFETY Uffi SHEET' " SCCT10221 . . iwiwwpwwa^ | - MONSANTO COMPAVY____ ,_________________ .1 CU.jQ^ I *ib*d*N^V/riTreBercn'VouIevVrS, St. Louie. Missouri 6S166 . * { fixture (*"*-** '`Cftlorlnated erasable 1 flrae!e?_JLPi. f-"?S in ___ !i Kixturo { ! Mutt, Mill *WMI ct*ktr n<u tOlvC*U &en>vij N>I S?CTI0`J II MAYS* rr.N tV'*#*f>`*`JTa * HiYUM JhX || ll tuirt mi imiuc cseTHici UtllHtM UI>I f MtAUIC (MIMtl , 1 H>tUviHceK.ll*i*te e, e* nut | smu 1 ft n* ! tU.M.I : S )| l i (1 .I ft IUSUmV ) u m 4 H 1 . SECTION !!! PHYSICAL ATA. **m,r,,lr60 tr. | V.'O* >||tw *4. , __ | v'e*ei*M 4uu 1 I 125*0 *, (ff/i ,|e> i.v2o?i*2C{',T-:* w-t .. M >t Avail li4*e*.its catiltl 1 reC neclirlble CC.01S ut.ei *& &ee ilirf.S trerasis Oder i i 2.317 .1 Cl ^ SECTION IV FIXE AND EXPLOSION HAZARD OATA *i* xit i<aM nw U'.O.C. AOC*C <* Water, feaa,.COy.r.4ry thtiaie&A Mte>,k ** (>(! hkimii n v?mm' exposure to vapors or gases 1* possible. ^tMv^W:^.1t J#11._<J-SLAI-tI5f_ttUt atiitll &2^mmeh2xZsxX evolved In fires of this areduet. nuduBMi .%n * r%t C8AN 001572 11 WATER PCB-SD0000010739 SECTION V ) HEALTH HAZARD OA< leaos to nausea* vcaAtihc, T5ST" -J 4 v 1] SECTION VI REACTIVITY DATA * 1 &.> 1 **nk| | IfiU i L_ " nepdP|fAl<tltt /VdiaaMdd M Mdl ' Ktjtspevt ei eeeevct* CO. CO? . smoke, toot, chlorides and ehlorlr.e eaveect* tewtiM if t*M net eeew* X J f i ! | 1 SECTION VII SPILL OR LEAK PROCEDURES Absorb en eiav. sawajst or otr.er absortant material. Plsce In I drums. Bury in approved eneateal iar.oi'ili in accorcar.ee asn loeal iu state regulations. bmi wie guJ.n in rn approved incinerator In accordance with local and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION *U>"4*0M--"`gaVc'rtrhT'Mlnca aooroved respirator for organic, vapors. W6rvt^n5i eC*tU.~.t Yf| . fer yaper9 tntm, te*C *4 <awmtS 'oim* i-utb.* Hl MHIl'iw igwwk.t C ehemieal goggles | j | SECTION 11 SPECIAL PRECAUTIONS * 1 "1(4.14.1 18 M l.lt * .W Avoid skin and eye contact. ONI PAUavliOM '' Avoid inhalation of vapors. SBRH * 00151 VMle the fnferaatton and rcceaaendatfons tet forth herein are believed to be accurst as of the date hereof* MONSANTO COMPANY MARES NO warranty WITH RESPECT THERETO AND DISCLAIMS ALL LlAtILSTT FROM RELIANCE THEREON. , JAO:HOH:JTG:WSP * 1/25/72 ... & 12 WATER PCB-SD0000010740 ""Wi!1! J" T^r'"1, ii iA f *^/s,f5`i*!j?v^^s*i5.v>j?.v'^^ Monsanto [ ^^? 4r-V' ^'>^r\r*- MONSANTO INDUSTRIAL CHEMICALS CO iroelor 1016 MBBUCT UOB i6ifii03 CMC rpgevtvs June 10. 1975 CMAHACTtfllBTICf Msave Color (1FHJO CSpo.ndOitri.on85/15.fC Acidity (mg XCH/g) tO Max. Clear 1.362-1.372 0.010 Hex. Moisture Refractive Index, 25C Inorganic (Free) Chlorides Four Point dielectric Constant 0.05 ppm Max. -14C Max. 6.80-6.95 (60 Kz, 100C) Hydrolysis Stability Test 0.5 ppm Wax, (48 Chlorides) Henaanto Stability Test 0.6 ppm Max. (aa Chlorides) distillation Range (ASTM 0-20 Corrected) 10% (by weight) 90S (by Height) Higher Soiling Horologe Suirates dielectric Strength . 2J C, XV Plash Point. P Fire Point Vise. 100F (SVS) 383C Min. ||IC Max. 0.6* Max. Hone 35 Min. 33 Min. None to S.l*. 71-81 . *Foeer Factor. Sulk fVnB 100C, 60 Hz Max " 1.0* 60 (Slv. *V|| 6BRN 001578 e m * , ae ' ' 13 WATER_PCB-SD0000010741 Monsanto teMMTeewwT eofttoum MfBi&ai toxicity tNtctauA non fssiarr information m-.______________ **00.0** iei6 ceoedtor p^eetne tosaarr fh ret soft ens! LDse # AALfl 1311 h tJ gremsAilogrtm. When Md to eanttououa 14-hour esnte with rabbit skin, As derm*! Idas was imatd to ha between 1.S3 grarmAjlogrsm end 2.0 grameAilegram. Thus. AAOCL0R 1616 is e@asdftd Is 3 Highty last by in single 6mm mi by single dermal sppiiartions. Whm ufttflluttd M0Q.3H 1316 wss piseed tote tie esAtuRrtvsI see of tie rabbit eye. i night degree ef irritation rssuRod. The average score of the f4. 4> end 72-hour readings wee it w i scale of 118.3. The irritation ta < ef I treated eyes had tubeJdod fey 71 hours after teeing. The ether two tested eyes hat regained e normal oppeargncs by 188 heurs after teeing. A severs degree ef Irritation resulted when-'undiluted AA6Q.6R 1616 was held in continuous 24-hour contact with totact and abraded rabbit akin. The Primary Irritation Index was 1.3 an s scale ef t.6. HANDUN6 PRECAUTIONS Cart should be taken te avoid AAOQ.O* 1816 earns with the akin, to eat# ef akin eentact, immediately wash exposed surfaces thoroughly with eeap and water, tf irritation persists, eeneuft a physician. to earn ef eye contact, flush Immodistefy with large volumes ef water. M iffRation persists, eonauft s phyweian. AftOCLOR 1616 has a negligible veper pressure at room temperature and R to net expected te present a significant vapor inhalation hazard under ambient conditions. However, precautions should be observed te avoid inhalation ef increased vapor concentrations which may occur if AAOCLOft 1616 is used at elevated temperatures. ENVIRONMENTAL HAZARDS ` During the peat several years, evidence has accumulated to indicate that petyehlerinsted biphenyls are widely dispersed throughout the environment end tost they esn have kNerse ecological and tesieelegieaJ effects. Extreme ear should, therefore, be taken by oil users ofAftOaOft 1616 to prevent any entry into the enviroment through spills, leakage, use or SepeoaL w*rrvt-n>m fe*N 001575 T*e etss=s .nereqnsa m tmm* ee m*mm e*asiS tm ttmmsm Cemmm. K a *a W ana R e>e.ea m m*vt tn sa>t.ea n emmm tmemts a eaa m ema swama m m eatmmtv mm* mafmmm, me mmtmn mw*mm m mmam itm**** me ***"> a ai nin>m m * wg ts es sbb mem m mm less,eta nwse, tan omeremmm me m m femme* m mm CnnH Uesu* mmmmm, $aa m. St tea, t @6S tli tH . . _ ,, ... <?.S. . . 14 WATER PCB-SD0000010742 Monsanto Industrial Chemicals Company Sales Offices AKRON. OHIO 44313 MO SfingB09 Qrme Muaees Onmleemsm T* (318)888-4111 ATLANTA. GEORGIA 30339 330 lommste Mere* 7$t*wy T*. (404) 432 7111 BOSTON MASSACHUSETTS 02149 fmn Station Tel. (817)387.8010 CHICAGO. ILLINOIS SIM On Mtttm An. Om Slemm, Ithnon 80018 Tel. 1313) 2884688 CINCINNATI. OHIO 46206 ISO) NtaOimn Deed Tel. (8131781470? DETROIT. MICHIGAN 800 Nw&UmS Tetmn met SeutUlml* He*. 48078 Tel. (313)3874810 HOUSTON, TEXAS TTSS7 tseoeme* Teem SOSt mstfteimm See* H (713)8314880 LOS ANGELES. CALIFORNIA 90040 M701. HeMa Si T*. (313) 733 3482 NEW YORK. NEW YORK 10036 i114A*ewaettha Aummm Tel. (313) 784.8000 ST. LOUIS. MISSOURI S3166 SOON. We*. TeL 014) 884.1000 SAN FRANCISCO BAY AREA 3710 Latveem Sstm &mi. am. sms Tel (408)3434414 WILMINGTON. DELAWARE 19910 3411 Silmern Sent Tel. (303) 478*800 MONSANTO, 80 N. UNOUSON 81 VOt. Sf. LOUIS CORN 001*7* 15 WATER PCB-SD0000010743 fora Approved OKI Do. 44-M387 Approve! Expires: July 30. 1972 I.S. KP1CIEEBI Gf uses Fora No. OSHA-2 Hiy. 197! MATERIAL SAFETY BATA SHEET .Mk23a SECTION I JM ONS AN TO 6 QM VA NY _____________ *lo`d 'Nofyul^^e'reKH^feva?!, 8...j^oii 3166. .... . [%! % * * ! MiTure `""cK'lorTnated Aromatie I jggagMt, -JLrojilfir-llilL Mixture SECTION II HA?;V.*Jfnft l'(T*v3fmS rmTt, MiiimiiMt, e Mvim % IVfmt*iI (UITt ABt afVAttIC tlilMII IIIm C4lH.fl Wvltll AM't'vIt eue*s tsr&ute eeattaas fn*wU le4ttnts m ew nw etHin a tt* d I 1 i 1 1 I a (Una*iul j9l 1 1 I 1 SECTION III PHYSICAL DATA | w*>*>6 *.i ru j60 3 j 5-360*0 IIMtd UttMl *m$ mm fVllnvaff.e'il iu ' N.A. ||( t Avail uruattiw mii <1 ncrllriM# JsfiLJIlI-- g lories oil allrht aromatic odor SECTION IV FIIC AND EXPLOSION HAZARD OATA ( .........---- e>0.e;-7ioe |^L^ra..r 1 -- Vat#Pt feaBt co? or drv ehemieal MtC'H #.W6 ceCtew4ft vapors er gases is possible; ~' 'Kri'c^Vv*'(oYfe*ran"es**T*ehlorldes and chlorine) tan 6 evolved In fires of this preduet. 66RN 001577 16 WATER PCB-SD0000010744 #rilr 12*2 SECTION V HEALTH HAZARD OATA 1.0 mr/mJ of air. '"I&fn^lrrftrtlen in the fora of chloracne, eyotematlc Intoxication leads to nausea, vomiting, lost or weight, edema ana abdominal rj*t *o (ti> *> wattauxi _ ,. ,. . . Jala. Ptemeve from exposure. fteweve contaminated elothlnr. Wash contacted area with larr.e amounts of water and soap. Refer to * physician. SECTION ! V6l6&f f*eu *ce*6tA&w*v fBaaewtt m i ofcjtaeeut titeMVtea Moowcti my mewe wu men eect* | Sf REACTIVITY OATA eea&tieat te " SECTION VII SPILL OR LEAK PROCEDURES i>m >0 M l| t.M >, ilkltut O* -JkhSJSTh^ an cl*v( aavdiiat _ar OThag. aMarhsnt and bury in approved chemical landfill in accordance with local and state regulations. l<) io^UYut ?Mn"OJfn an approved Incinerator in accordance with leeal and state laws. SECTION VII! SPECIAL PROTECTION INFORMATION *,*.>*.ion *ot|CTto* limit* mmi OSS***mrnvrn- '** htvll 0< **OMC1fv ItuMIM aa --- J m emueum Chemleal gogglea SECTION !i SPECIAL PRECAUTIONS P*4C4W*Q*I * M f*|* ** ea04M4 aa |I0m4 ",, ^ --A3md-akln-aad..-ayt-..aflntafii^-Meflid-iahalatloiL-fl-3gtttfleij 6b** OOlS^4 Hhtle the tnforaatten and recoaaeedatfont set forth hereto ire believed to be seeurste at if the date hereof, MONSANTO COMPANY MAKES NO WARRANTY HITM RESPECT THERETO AN DISCLAIMS ALL LIAIILITY FROM RELIANCE THEREON. JAQ:HOH:JTO:WBP . . 1/2R/T2 17 WATER PCB-SD0000010745 fgpp Approved OHB 5#. *<} Approvtl Expires: Q July 30, 1972 I.S. GICEEJ t; usat Fora No. OSHA Miy. 1971 KAtERiiU SSFEIY BAIiS SHEET' SECTION I FfV.A \ ficS!`^r>nr\ auu Xortn Linf.scrsn tlemcvard, St* Louis, Missouri 43l * eol * Mixture______ _ j fh'foflVsted sreaatle * 1 ** ArrelVr^l3Vr l,"**)llxture actSuSaClsTcIefmWi yIwI oH&i?xAaf^uP*SS.M*S<dUVil*i^ wm, Miiiifiiriv ft i I ^T. I ib*M aw* atmbic etitMci n-- 8&S4 Milb i.tat'P 1 AbbO*8 13.V1M1 a 6*m 1 tttUutC (litwei ( (Hit* MltAl *twt cetie ea eo>i *tv* f #t4M ___!_____ lUIMUt BllfUfilt If THtl b*UI*l, Mbllt, *8 6*111 ib* Hv % IW*H 1 OBAN 001579 I seen on in BM PHYSICAL DATA on ----- w 18o->ree __ 3_pn_ *t*f!|.,tVttMltlHI I.UMtiioa eat. mfA,,t 0** <0.015 V* 1 ^ AV y sr**.? ! arosuitle r*i*r SECTION 1? Fill AND CZPLOSION IIAZAP.O DATA ^r/rnr*N.A. <1 : t I 1 .<!& 4>al Missis* e-<3) eeej BIOA none J*ICi4. at J.i-.t MMthMt .*.e sol rater*/ erotcstlon vfc ft.V|K to vtpors or roses Is possible. 11 tt.wi.ia mmi * i1 . .. .t.. ' t . . 1 I } W.fV'aiW?4hlorldcs tad ehlorlae) can fee evolved la fires of this proeuet. eauwast o ee % ' * WATER PCB-SD0000010746 f.l VkWI nmvn t tttAtlH HAl I) OAT i ! 0< BiMHiKIMt . Skin irritation In .. the fora of ehlcracne, ayster.atle Intoxication ! j leads to nausea, vonitinc, loss oi weignt, eueta ana audoninai pal itu|b*.0 ill mil Aie I Henove from exoosure. Remove enntr.Blnr.ted elntMiv. V**V contacted area vith large anounts of water-apd soap. Refer to physician. AUUill utruti SCCTtOtt V! REACTIVITY DATA irt.gVri^wrW^gyywmga IHHI IVtitdtli m timil a&j&smijt ettea^eiiiisaa xAJ&a&euf u&veeewi eoju tnoke. soot, chlorides and chlorine emmimt te ve wu w eeet* X ! 1 1 SECTION VII SPILL Oft LEAK PROCEDURES Afcsors cn ciav. sawdust er ctr.er absorbent p.sttrial. Place in dx-uns. fury in approved enesleai ianefili in aeeoroance witn local and space regulations, *4>Vurn4ln j>n__eiproved Incinerator in accordance.vlth..local. and state regulations. SECTION VIII SPECIAL PROTECTION INFORMATION Ml *********l* ,,r*Bureau of Kir,ns r.roroved rernirntor tnr orrtnlc >j VtiUIIOM It '3 iKm iwwti Yes - for vapors 715=1 I.J I'M 1 VI(IM IMt vapors. z 'flew b*tri$ Rubber cited cal r.oiuUcs nua nonciivi SECTION II SPECIAL PRECAUTIONS puei&fi'BAa 4lAyolo"*1i:in ,ana'l,i':/i*`S'oirtt'at. avoid Inhalation of vasors etu CbRh OOlStoU VhUe the Inferaatlen and recoBoendatlons set fer.th herein are believed to be accurate as of the date hereof, PONSANTO COMPANY MAKES wo warranty KITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON. .JAO:HOH:JTC:VDP . . - 1/25/12 _ 19 WATER PCB-SD0000010747 ) Monsanto Industrial Chemicals Company Safes Offices AKRON. OHIO um *8 Sertetymes Orim Menmm 0mmim>mem TeL (3181*4*^111 ATLANTA, GEORGIA Xt<9 Inwewuw Her** Otettmef n.t404i4nn 60ST0N. MASSACHUSETTS 02149 gmmtSmtiee m m/jMftoto CHICAGO. ILLINOIS SIS On Heims An. Dm Heims, IMimnSOOlS Tel. (313J ****** CINCINNATI, OHIO 45206 1801 Meekest Mm$ Tel. (8131 nun? DETROIT. MICHIOAN SOONerffUeagfeommm Sevthrmt*. m&, 4**8 m (3131 WWW HOUSTON, TEXAS f?27 iSOdfimG* Tmm mtmnfrnmmAe* WeLtmeStMSS LOS ANGELES. CALIFORNIA 80040 870 8. HetHs 8t T*. (2!Si m-xu NEW YORK, NEW YORK 10006 IIMAmweMMe dUmtism Tel. t*l*l M-SO* rr. louis. Missouri 3166 S*/L Uwmrgi && TeL 01418*10* SAN FRANCISCO SAY ARIA SftOLeterem Sao &m. Gsiif. *8*3 TeL <4*13434414 WILMINGTON. DELAWARE 1M10 S4ll$imr0Aem0 Tel. (3*14*-*** MONSANTO. *0 H UN04806M 01Vft. ST. LOUIS 001562 */ 20 WATER PCB-SD0000010748 WATER PCB-SD0000010749  se emasAL ckjw Cecil X. firlater, lt.fi. fitea asd Prefeeeor e Physiol^ Ear?art School t Public Health, Bostoa, Haas. Septaaber If, 1938 ACfr 0C3*JC 22 WATER PCB-SD0000010750 I fa&a Z. Erperiaeats to detaralae tit possible toxicity of tit folio*i-a ubstaaeas:....................................................................................... ^# 9 1* Gblofoasase g S tl}bi8fl pbtheists ** tm 3 S. Chlcriaated diphenyl #1258 ....................................................... 4. 4 Vlztura of chlorinated diphaayl aad ehlorlasted diphenyl ba&2aaa #5460........................... 7. a 11. Sosa general ctnildirttlosis 9 1. Erl dense for the destruction af a mixture of paata aad hexaehleraapbthalenes (#1006) la tba body........ 1 The effect of Inertsinn the sodium ehlerifli la the diet upon animals raealrlag tszis doses af #1006 ... 10 i He effect of high aad low calcium intake ea aalssls inhaling high ccneentratiene of #1006 10 4 lbs effeet of iajeetioas of xanthine ea entails lnhal lag high eoaeeatratleas of #1006 ................................ 11 23 WATER PCB-SD0000010751 i z. gpggignB to gmTO ss kssaa Toneirr c? ?w wr>T *. --.,... 1. caDneotAja a Jbly 14, Its?, we rt laferssd fey T. S. Sfcith that ueh eusc bu:l* f a eft teiak sight toatala l to 70 sgp^ f ihleroasaaee a? w phazaoelogical nuoa to believe the eexpound weuld ba irritatlag or taxie ia *7 nj, aad therefore it was dsaidad to dee rata with, it vary haavlly, tb argusest balaf that if they survived b&fj dosage without any avidaae af dsaage a verdict ef so toxicity sight fee g$,fm aad aach fiat saved. If, m tb a ether hand, tbs large doses proved poisonous it would ba meeeissry ta rsduca desag ustil a nsn-toxie level was rase bad. fbe first ef tbs alternatives proved eesraet. rperis eats. August 16, 1137. IB adult white rats raagiag la weight frea 112 ta 210 ps. ware aaeb fed 70 ags. ef chlorsossaa ia 1 ee. ef olive all daily by stsaaeb tub. Shsse anlaels showed aa evideaee ef dange ia aay way attributable to ehloreosaa. They war exsained alerteeopieally frea tbs SStb to tbs f&d day. Tbs o&ly ee&staat ebasge observed was a possible slight increase ia tbs granularity of the cells of the liver eerds, but tbs v 'patTa2o'git tl'tTa'-fe e "within nerskl 1 lilts 1 'This flading is deubly reassuring else may ef the aaisals developed a cbresle suppurative luag condition very prevalent ia Boston stock rats at tbs tins. But even with this added baadieap there was bo rrldaae of daaag and we thus ceacluds that ehlereosaa even ia enorsoua dosage is aa ta&rs saterial ia the body aad la all probability passes ttrough the iatsstias uacbsagsd. uor wC3**i4 24 WATER PCB-SD0000010752 t CffHBfn, HCZ&XJ3 to *agut 83, 1937, we mi iaferaid by Dr. S. Z. Silly that tijbssyl pbthalat M* b ubiierbsi through tbs aids er sight b inhaled m& gw&iiemid iurlsf spraying operations. after consultation it mi deeldad te feed heavily, ud If thare were indications of texlcity to project othar oxperlssnts. ZrperissBts. -- September SO, 1937. W adult obits rite ranging s* weight fxon 141 to 501 pa were each fed 05 spa of diphaayl pbtkalate cuspandad in 1 ce. of water bj otosmeb tabs dally. lbs aaiaals were frca sew stock ead with eas exceptiea remained elesr of tbe luag condition wbleb existed in tbs ehlorceeeae gremp. during tbe period of experiat, thicb lasted 91 day, practically aU tbe aaiaals gained weight. Sseel unties of i a*<an Jd,Hed at intervale during this perled ef test resulted as fell'owi: &i organs were normal ^oesly, end on aicreeeopie examination tbe liver alese waj ef peeelble interest. She changes in tbe liver varied frea these in which tbe eelle of tbs live? eords were alsost ncrsal, having only a slight swelling end pasnlarlty ef their cytoplasm, te those in which these changes were prenounced. la the latter there was a moderate dapee ef vaeuellsatiea 4 `-.-j *>,*-*.. end a rare ih. y.-ja.-'lziln.z-e>'> body. ***/:?*"?S* These alia? at lens it sust be underetto*-e.d* ww-cereswt*h*refcrfae<w result ef very certain deeage, sines the compound was given by stench tube and the animals had ns peeelble way ef avoiding, it. Neither the pathelegist ' ner sywelf was able te consider thu ef eneugh accent to cause us te make further exper int X a confident that with the ordinary precautions aeeospesying spray lacquering no possible harm could b ion, oven if the concentration of . diphenyl pbthalate in the lacquer was far above the 5 per cent figure given . us by 1. 1. Sally. ACr* CC3*33 25 WATER PCB-SD0000010753 I 9. GELDHKA23 SI?sm -- 0C1P0CB #UI material was fuxsiah4 by th Hmmte ghesieal Coqiagy. j* ^ &i4 te hve a Uts-is mtmt ot per cent, the highest chlorine f igyrs f any eeapomd tiitii by us during ths p*st ttrse years. 2t bad been ear irq?r#sion that toxicity and chlorine content relieved m another ele*ely, bat this ha act taraii at to be th case fey #11 .a*rfaoMsssxijH3otx* Rosassxymtex Farther discussion f this feist will fiU t* deeeriptisa f the experimental beesvatiens aad thsir resultse Sxeoriaonta. * august , 1937. She ee^ound #1H ms afeiaiitsxefi by * Inhalation, the technique be lag that described is the paper eatitled The ?reblaa of Possible Syitcnlc Effects from Certaia Chlorinated gydreeerbeas. Journal of Industrial Sfgiene, 1937, !, 183. 7or the first observation 80 adult white rats were used. Thay were expesed as fellowa: Greup 1. 8 aniaals. fei^erature te which th ea^eund was heated te iatredaes fua iate air line 140-190* 6. Average eeneentestisa is air breathed by rats 0.53 &sx, per eabie aeter. Average daily exposure II hours. She experiment was eoatisued for 119 days, anisnls being sacrificed at iaterrals for pathological examination and for the carbon tetrachloride and aleshel test (see paper previously cited} *' The eenditien Ascribed ebeve caused ewelling and increase ef granulsrity of the liver cell. Syaline inclusions were rare, ^ese changes were quite tmifena in eU aniaals examined after the ilst day, but were net certainly progressive. The rats were very healthy throughout the period and there was an `alnost unlfera gain In w tight. Tha earbon tetraehlorids-aleshol test was positive after 51 days, s6ieb*indicates that though liver dasage was apparently . slight sobs dipti if harm had been dens the ergon. There was so evidence if AC* CC3** 3* 26 WATER PCB-SD0000010754 damg is tay pan f thi body eeipt the llvar. At thi ad tf 13 lari 10 rat, qpirntlj in excellent eendliis, were fron tbs p?issat and sat mi&@ far abaerr&tiens upon lir@t recovery. These recovery anteals showed as clinical changes of any sort. *hta aerlfieed 72 and 141 days after moral frcs azpaaura It mi observed that the swelling ef tbs liTtr calls bad dlsappaarad, but tba granular and hyalins satarial remained in tba llrar calls aad bad apparently bacons permanent. as absalutsly sa precession if dang* after mere! from caesura# These changes my ba capered with tboaa produced is rats by inhalation af chlorinated dipbssyl #4465, administered in a s tellsx manner in concentre-* tlaas af 0*57 ta 0S3 mgs. par cubic aster crer teller perieds ef tlm. Za the ease af this eer?ouad the ceaspieuous difference waa the far greater incidence af hyalteisatien ef tbs llrer cells, Aieh in eur eptales was tbs charsetsristle Issian caused by #4463 and nixturee containing it. One can therefore conclude that #1268 in lew concentrations la definitely leas tsxic than #4463. * Croup 2. -- After Hi days, the law concentration of #1211 hrrtef proved but slightly poisonous, it was decided ta Increase the coneentmtien In the air 'saintalned as during the first 119 days, but by the use af 4 Taperiners instead of 1 the average concentration ef #1268 in the air was brought to 6.23 sags, per cubic aster ef air. Exposure to this very high concentration was continued fer 7 days. Under these extras conditions the as teals again resained in perfect health. Tba carbon tetrachloride and aleofcp test was positive but there was absolutely no other indication of liver dasage and na evidence of disturbance ta ether ergans. eei*3- 27 WATER PCB-SD0000010755 ) ^hua axaaiaad at autopsy at tbs nd f 87 days -- the ^ azparieaeed a total ozposwo f 806 days -- tfcars war m irif m4aacM of abneraality is aay fart* a nicreeeepie exialaatlea a rgsa ahonad ehazges azeapt the lire, a sober of alls eeatalaiag hyaline aad the mount of ^roliaa is tfco eH involved inereassd Avisf this period f axpegwa te tho higher eaaeaatratioa f #1218, fh ^alia was soot abodaat ia the parsal its of tho letalo with vary littit is tha astral warn After 41 day of' ezpesur 10 rata ora aat aalda aad war aaerlflead 73 daya later. ^ey were is excellent eeaditlea whea reaoved aad did aat ehaafe. Grossly, at autopsy, they a breed 0 aethiag abnorsal, aad a Bieroseeple azaaiaatlea tha liver alls had lest their swell lag but retained iaereased granularity aad hfilis- iaeluaiesa. . 7h* expariaeats a iahalatioas of high eoaestratias of #1268 reeaforee the eeaelusioa that this eoapot&d ia of lev tezieity as eoapared with #4465 or with ehlerisated aaphthaleaas above triehloraaphthalsaa. Sia questiaa as to why #1268, the seat highly ehlarlasted conpcuad tested, proved but slightly harsful cannot be aaswered with asy definiteaess. St has been suggested that tha tezieity of all these ehlorlasted eesyouada, avea though of varied ee^esitioa, say depead ea the ability of tha aaiaal to deeespese thas after ledasat ia the tissues, aad that this decaspealtiea sight be showa by aa iaerease ia the ehloria la. the uriae la suitably eoaducted feeding aoperineats. Za experiments upea this paint va hrr shows a deflaite iaerease ia the urinary ehlerldes whea degs aad rats vara fad a srtxfcure af pasta aad hazaehloraaphthaleaes (#1006), a eerpouad highly injurious te t^ liver aad aaataiaing 12.6 par aat of ehleriae, but sinil ebeervmtloaa have set baea aada edth asy of the ehloriaated dlphs^ls or allied eammmAm, Jt a^, however, b that when about II par eat ehlwinstiea is reaeh the aubetanees formed are quite stable In the body aad so eause a rlnl--na of daaagw. . . AL* CC3<3fc '` 28 WATER PCB-SD0000010756 I 2a conclusion, #3268, If handled with ordinary precautions as to T*::ii, ties should bo entirely harmless to warloan. Hhile it eaaaot Is nn u absolutely dean bill as to health, it is preferablo to #4441 tad fsuo. 4 lCECHS @F OTfilSiAaa MPHEreL MID SlII2UCT JJSSfj; - Witmm --. @05*OTl #3460 !Mi substaaeo ms furnished by the Moasaato Chesieal Oo^uy and ms said te hare a ehlorlae eoateat of 60 yea seat, being la this respset bslow #4443 aad ' 4 far below #1268* Sreeriaaats. -- The lahaletlea technique ms used as la the ease of #1268 aad #4463. August 1, 1937. 0 adult white rats were the subjects. Terperatur# to which the ccrycuad was heated to latreduee f\ae lato the air liae 140-196* C. Arerage coaeentratioa ia air breathed by rats 0.083 n^. per cubic aster. Average daily exposure II hours. Tbs `experiaeat lasted 119 days, a eertaia amber of aaisals were sacrificed for patholegie&l exasiaatloa, ethers were used for tha carboa tetraehleride aad aleehol test, aad still others set aside fsr ebserratioas as to recovery from possible damage. Ia spite of the fact that the eeaeeatratioa ia the air breathed by the rate averaged about 1/6 that obtained at cos?arable temperatures froa #1268, a amber of these became sink aad lost weight towards the ead of the second aoath of xpoeuro. Vben killed, such Individual! showed gross settling of the liver but as changes ia ether or^as. te microscopic exasisatiea smiling of the e liver cells, increased grsaulerity and ^rtliat iaelusiea* ware noted in animals lulled as early as th 16th day of exposure. These changes obviously occurred rapidly. Hyalin deposits ware never as numerous as with #1258. Aalrals rr At* CC' 29 WATER PCB-SD0000010757 resorad for reeeriff litas' 51 asd 119 lays ei iQUtfi did sot <jj -arkedly is Might, mi mm died for m ttrrlmus tus thsa en&ised at mtepnj the m @w@msg of the lifer t@U had subsided, hut abaorsal crasularity asd hymlisisatien rwisod. ' . HHilui to 117 the evbea tetraehlcride asd oleohol teat mi positive gfetarrw usd * * rim of the fast that #46 is tush low aets`atia proved g@ defisitely toxic, so higher eoneeatratioas w tested, 2t seeas iterative that tshearrer this eospo* is used Is iMwtarf, greet tare be takes to keep . eeaeeatratieas is the air at as extreaely low lerai. Ho libertiea eas be takes with it, as with #1268. <&*> CC 343e 30 WATER PCB-SD0000010758 I " . n* sets cggux coyazaaucscia Za addltlen to this* tit* @f ccsyeunde, eirtals zptxSsiats nri teas sxt of ists*a*& to thin sanuf&etaring er using chlerlaated hydrocarbons. Satails u to thin ispirbnti iri of course available but ora set included la this roport a lac a they 0 met' of direct iafcietrial interact. l* ifzsbjcs yes, ts Bi3?x*zcai 0 a isxtsks bf hkia a*s EffiMCTES (#1001) 21 SHE TOT a1 a Zt hu always beau a question as ta whether thi chlorinated bytoaesTbens which have bean exaained by ourselves and by etbaxs do bars par aa or whether toxicity depends on their breakdown in tha bady with tbs libaratian of soae- thing harrful ta the 11m. A partial answer has been ebtained by feeding #1001 to rats and dogs tfcieh ware an a low ehlarida diet with unifera excretion ef ehloridea in the urine. Than these anInals received the chlorinated hydrocarbon (#1661) tha urinary chlorides rasa. Shis indicates that the bady certainly has power to detach chlorine fra this eespeusdt and it is prababla that tbs ss&s condition is true for allied toxic eospounds. Zt would be seat interesting ts sea father ingestion ef #1268 results in siniler* findings er wbatbar in tbs ease ef this relatively non-texie eas^aund there is praotiesUy ns flitting off ef chlorine. Jfeither tine nor m* financial resources permitted sueh tests* ' ` # **> CC3<,39 31 WATER PCB-SD0000010759 jr ^. -C I 2. TS5 SI5CT CDF BfSElSrSI SES S0DX5U egjET-r ^ WQS 3amM3 8SS7SS SIS 2CSS Cf #lci to th grouad that thlerids sight hi fusdsnentally aiseelttei with toxicity, a group ef 18 rats w fed a loo tcsie dost ef flee# ^4 es=psrtd irith a siadlsr pwup on the @mm Asags ef fleet plua a narked izttmm in ehlorlds intake stewed by firing 9 ee. per kUegrsn ef body f 4 par cent SaCl a duties dally. . I7e dlffereaees were found between the tee groups, md it my he concluded e< that chi trine increase secured threugh the diet dees set enhance toxicity. This experiment m lone la erder te find mt whether increase is chloride iat&ks during hot. weather sight he haxtful. - A particular phase ef the problem, the peesihle enhancement ef typical skin lesie&s by increasing chloride intake, eannet he decided by experiments en fur-bearing anlaels with ne sehaeeeus glands. All that ean he said at the moment is that increased chloride intake dees set increase systemic toxicity. So TS UTICT GP SSI A2 UBtf GALSZS: 2US to* sqalsib high concsnsjaxcb of #1001 * It is veil knoea. that a diet rich in calcium is sarkedly effective is preventing the acute yeUe atrophy f the liver produced by eerbea tetra oblwids (a frevention and &etet of,arbn Tetrachloride Xataxie&tiea, By ?. 9. lessen, VJ., A* S. Ulsot, Ph.9., and S. S. Bobbins, M.S., femmel ef the saerlcen Uedleal Association, 1929, relume 90, page 341). ' To discover whether ealeium is the diet would protect against liver desage ALP rZlk 32 WATER PCB-SD0000010760 i troa a texie chlorinated hydrocBbea, 30 adult white rata wart flaetd upon a ilt of leas hsrsaaat, itk tud lxd, a arabisation adetuate for ssaistasasei but very low is calcium. Another poup u gives a diet eesslsttag af dag efeow, allk, lattus tad ogp, Mth addad calcium l&et&t -- a rat lea wesy Mgh is calcium* Seth group wora axpeaad ilwltasaoualy to inhalation of high coscantra- tioa of #1006, as average of 11.21 aga. par oublo rater for 16 hours a day. After 16 daja, 11 high calcium diat rats war# alire aad 7 of tha low * calcium group. At istwval asis&ls wars ldHed for esraisatioa. Is both groups tha lirar was abnormal grossly asd microscopically, and is both iroupa * Mlmls disd f*em lirar damage. St was impossible to eoasidar that tha high . ealeium diat was is the least degree protective. St say, therefore, be . ceseluded that addisg calcium to the diet of workers either is the fore of extra silk or of ealcius lactate will sot prwrest liver daaage. 4. tSTSCT ST BCSCSSBB CT 2AN3T3 Of JCQJILS TWiT^ir. SS eC2?2UnJS Of #1006 - v -s* Is 1937, 2. C. Keale published a brief paper (She Protective Act lea of Certain Puxines against Liver Jfecresis Produced by Carbos Tetrachloride aad Chloroform. Selesee, 1937, volume 86, page 83). Ee claimed that rata lnjeeted with sodium xasthlse beesae sarksdly reslstast to carbos tetrachlerlde. This suggested that xasthlse sight have s lailer protective power over liver draage frra tha ehlorlsated hydxoe&rbeas s exuelaatlos is this laboratory. Accordingly 88 adult white rats were caused to inhale #1006 in concentra tions averaging IS mga. per cubic aatcr for 16 hours daily One group ef ID rats was ^vea 10 of xanthine wubeutasesusly very other day and 40 mgs. ACM CC34W 33 WATER PCB-SD0000010761 . ..) c ef xaathlaa bf stcoeeh tuba on the iltirut* d*7*. lie eecead peup ef 18 rata bad the in exposure to #1006 lthut xaatMs* freataest. He 4Ufa?&et war aotad ud eu eaaaot expeat sy iffleuj frm either la tha prereatien @r treataeat ef lift? disease Sua t this thleriaatad hfdroeirbea, mi la all probability tha sooe uiitlTi result nuld be eaeouatered la eeaaaetloa with ail la a texie to^euadse C ^ "B. -V-***-* '.*>*'**** k AC** 34 WATER PCB-SD0000010762 WATER PCB-SD0000010763 RPQRT m 4US AalnftljL. VhlU rata hr# Uta employed throughout. p#ralt th us of a largo state of aaisala is a relatively ibsII *lntlon installation. They thrlwa upm a gift wery sl&llar to ms, M la th mii of thoso chlorinated impounds it la possible that diet mj bo Tory significant. Finally, thoi'r soraal eharactsrlstles have boos described so well as to aako the detection of abaorsalltlos both . easy aad certain. Method of Stop sure, The inhalation txper iamt aero earned out o la four large alx-tlght soodea boxes, eaeh capable of holdlag tea rat cages, ala 22" z 22" z 14", la tso tiara of flTs cages eaeh. the a the experiment sae sot la progress the deers were opeaed wide aad the cages kept Is place (see Figure 1). . It the eeater of oae oad of eaeh box -- the 1allow end. -- air was introduced through a pipe 7 laches la disaster (see Figure 2). ach box was equipped with ea iadlTidual electrie blower which blew the air through several feet of 7-laeh pipe before eaterlag the end of the box. la orifice was placed la the pipe llae, aad the flew of air la cubic feet per alaute could be reed off directly froa calibrated flew &store. 1 dsaper placed at the eotraace of the pipe late the box was adjusted , to assure a unifora dlatrlbutloa of the atraaa of air to the two tiers of cages. At the apposite cat of the bez -- the outflow oad -- the air froa each bos was exhausted through a 7-iaeh pip fitted with a daqpsr e aad eoaaetd to a large eeatral exhaust fan (see Figure 3). About 4 laches froa the eatraaee of the 7-iach pipe late the box, the fuaoe of the aubstaace were latroduced late the laflewlag air. t * a . ----------------------------------. * `; aDP CC3^iv 36 WATER PCB-SD0000010764 ) Flge 1* JVont Tiew snd Inflow tad of two boxes with rat cages in glace and doors open. *> CC2**C 6 37 WATER PCB-SD0000010765 fig, le Heotrie heater for calntilni&g chlorinated dipktayl at a eonetaat teaperature in place at iallow end of box. ACH CC2<2 1 38 WATER PCB-SD0000010766 ) c c Tig* 3* Outflow and e two bszes showing connections ts ezhsnst sjstem. 39 WATER PCB-SD0000010767 ) c c AC* OC 2 40 WATER PCB-SD0000010768 Specially designed pjr Class fie eke (flews 4), f 3/4" le&g lad a diameter f 1 1/2"( wr used to held the heated waxes. Ilm flasks vsre stii with ft aide am ud tub ehleh extended to the fetf. ft* top ef the flask ms peuad, a4 late this fitted ft aheri tube l i/g ^ length. All short tube vas inserted late large rubber stepper saieh fitted tightly late a hole cut out of the 7-ineh pipe ea the under side (see figure 2)* The flask la tun ms plated la aa eleetrie heater * znde to cover It eespletely belev the side are ead greuad glass top. lubber tublag eeaaeeted the side an vlth a eospreased air reservoir aad a gentle stress ef air blom through the ftolted ms kept it la . notion aad assured uaifen heating. late each flask ms inserted ft long stea emtigrade thermometer vhieh me kept la place aad eeuld be read at say tine above the 7-ineh pipe through rtileh it passed (see figure 2). Approximately SO vs. ef pulverized SCXlm.si,jert"cwli*i`/adBCBxsg atVJ^ixstf ehleriasted diphenyl were placed la the Vapbrlziiigi"^ flask sad nslted la the eleetrie heater, fresh aeaples were used every ether day. tosdaoms^jdAxaj^^ affp ttna i ilAtejDia,iil Ibe eelleeted subliaste ms slmjv removed froa the upper part ef the flask aad a eleaa tap used eaeh dsy. He sample ms ever used for sere than _ tve runs. The flask plus the entente ms earefuUy veighsd at the beginning ef the run aad at the end, aad the less la might used to aleulato the average aneuat la a eubie meter ef air par minute as dstenlned by a asriss ef flsr a ter readings. The figures ebtaiaed ire art abselute because ef alight variations la the air flawing . . through the boxes and beetuse ef deposition f material en the thsraess- tera and cm the inside surfeits ef the box, but they checked well with direct determinations through air samples. AC* CCS***4* i 41 WATER PCB-SD0000010769 Approxlnately at tow m illmi for thi u is thi fluki to salt aad etna te a initut twnperaturo. At that tin the hex doers were tightly aloeed, air bubbled through tha flaths, i&fl the blewsrs tursad w. Thi a was tha beglaaiag of tha axpeaura period. By aataa of tha thaoatata m the faai aad tha daxpera is tha outflow pipaa, tha aaaust of air flowiag through tha boxes was adjusted aad aa attest waa aad a te keep the feur boxes as toifora as possible usually betweas 111 and 175 eubie fast par xiaute.. Zrosrlasata Ecposure te ehloriaated diphenyl was bogus os fulp 1, 1936 aad esssad on Horaaber 18 of the asaa pear. Tha areraga laagth of exposure was 16 hours dailp for i dtps a wash. Beeh sonlag at about 9:00 axpssurs cessed, aad bstwaaa this tlaa aad 4:00 pm. the rats wars deaaed, fed, weighed, ate. Za order to aeeure uaiferaltp of exposure the esgss wore shifted oa a regular schedule, Maeo wax eoaesatratieas were senswhat higher at the laflew ead of the boxes. Prollalaary ruas shewed that eaeo propexlp adjusted, wax eoacaatratleas la the air xeoained torp uaifera from dap te dtp, but te lasuro absolute safotp xoadiags of tasporatuxe, air-flow, ete. wore ala etarp sight betweoa 10:00 aad 12:00 ;x. as well as ea atartiag aad atappiag. At differcat tlui duriag the eourae ef the experiaeat tests for frss ehlsrids wore s&d but ware usif oralf asgstits ud showed that TOdor the tpr*ures used ae Aesoapositiaa oeeuxred. MU Conditions iiaiatsiaed la Zahalatioa Experiment frca Julp 1 te War. 18 CC3<. Material Chlorinated Aiphropl Taopcrature Average aaaeaatratiea . ef air is hex Total laagth of exposure *c 165-173 Ug./ml*. Range OA7. Kig^ 1.19 Low 0.23 hears 1896 Average da.1 expasura 16 42 WATER PCB-SD0000010770 BeiUlta ef f&halatim IbragiJiaBtii K@ abacrmlitlea ! *ea t My %im la tba living rat. jacd ad arias examinations nr* aii; thare Mr ae leases la weight, gad as euld Mr eeasldered that the aaiaala era perfectly eouad. Eossvcr, rata sacrificed after Mika sxpeaurc shewed slight Unr damage, bleb advanced turiag tbs asxt te meaths. The sbsafes essistsd la aligat t moderate eveiling ef tbs liver sells, laerssasd granularity, sad may altstls figures. Hyaline laelualoaa Mrs prsssat sad were invariably plaatiful la aaisals receiving chlerlaatsd diphenyl by iabslstioa or fey mouth. ' , ( Cas Is forssd to eoaeluds froa tbs experiments tbat ss average eencaatxation sf 0*57 mg. psr cubic aster labeled II bsurs daily produess dsfiaits slight ebaagsa ia tbs liver sad la this ergta less. Tbsss ebaagss arc rsaistsd sfficisatly fey tbs animals sad ssuas as dsprseistiss of health. Tbs situation is act Unlike tbat sssa la faetorlsa sbars scuts yellow atrophy sf tbs liver bas occurred. Za tbs eass of aueb ' instances tbs patisats have fessa alaglsd eut la asms say or etbar frsa largs groups ef ftllev svkaaa Me bars bass perfectly healthy. Za coaaldsrlag tbs satire mttsr it ass&ad ts us tbat tbs eblsrlnatsd bydre>earfeoas,/lf l&balsd is aufflclsst eoncastration, sight cause a slight dsgrsa ef damage ts tbs Htst. This damage la resisted sfficisatly sad esussa ae dsprsclatiea ef health, but if tbs individual * la question bappsas t suffer sees erdlnary dl assss ef tbs liver tbs sMdltlca la aupertspeeed up s eubatratm of injury Za accordance dtb this hypothesis we dstsralasd that s dess ef 0,73 ce. ef caxboa ' tstraehlorlds plus 0.75 ss. bf ethyl slesbsl psr kllegraa ef rmt ms ' entirely aea-to.e to normal animals. Shea, however, this dess ms given ts aalmls which bad labeled cblsriaatsd dlpbsayl as bas fessa described la this experiment, tbs result ms aeute yslle strspby '* CC j<,t 43 WATER PCB-SD0000010771 ef the liver. Zt would im thinfiri that inhalation of a concentration ef chlorinated diphenyl la tha manner Z bar* described la capable of producing a condition which any be dangerous to tbs Individual inhali-g it, though f Itself aa visible bars will be dene. Aninala reved from zpeswe to ehlwiaatid diphenyl after tie months inhalation and given two months for recovery still shewed liver ehangea when killed and examined, ao that it la evident the alteration* produced fey this hydro-carbon are persistant and Individuals whe have been caused treuble by It should be raseved completely and for a Ions time. Hie Inhaletlep of a emewhat Maher concentration ef ' ehlerlsated dlnhenvl over an hour dev The circumstances attending this experlant are given In Table l Hattrial Chlorinated diphenyl Teblt-J. Teapereture Average eoaceatrstlea ef air In bez Total length Average ef ezpesure daily ex? 0 c &./eu.a. Sense Hours Heurs 153-174 ' 0.93 High 5.23 lew 0.03 920 S Again SO rats were used in this experlaent Xene at any tins shewed the slightest evldaaee of lUnese. Jileroeeeple esnainstlons, however, shewed a degree ef change vary comparable to that found in the li hour azpariaaats which hava ban described and tha earban tatraehlorlda tact was uniformly fatal. Trom thesa ezperlaenta we are forced te conclude that eateestratims ef chlorinated' diphenyl In workrooms should net be aliened te rise above 0.5 eg. per cubic meter of air. This ementratlon is readily ebtalaed by careful Atr CC2^ ftA WATER PCB-SD0000010772 beodias. It la la ur eplnloa mX for wrtaaa who would aot be exposed rtth tbe absolute ituilMii ebaraeteriatie of our experlceate s rats a4 such ooaeeatretloa Halt would probably do awy with tha troubleseao alda lesions ^bieh Maw been tbs partieular eua for worry la regard ^ to thin eewpouads la tbs post* la addition to the Inhalation oxporlaoats aw? food lag experiments this nr( goas wlth/ehiorlaotod diphenyl. Tbo general ohaagea la tbo liter noro tbo os those already deeerlbod. Ho diarrbaa or gaetro-lnteetlnal aepeeta aeened to bo procent. . 45 e WATER PCB-SD0000010773 con xo. proczss foe the momcnm of AROCLORS, PT1ANOLS, 1TC. AT THE ANNISTON AND AT TSH NX, @* SRSNKH20I PLANT April If55-----------------------S. Mather * t Distribution tilt (aatnded July lf If56) 1. Mr. J. 1. Brough, London ' 2. fr. N. B. Dyson, Newport 4 Newport T.Z.Z. file 5. Mr. 0. V.'Taylor, Newport 4. Mr. 0. 7. Ttylor, Newport 4 Newport Process Superintendent 5. Mr. V. K. 'Hamer, Stuabon 6. Mr. J. P. Stickley, St. Louis 4 Kruoarieh Plant 7. Mr.- J. P. Stickley, St. Louis <# St. Louis Library 8. MOL file at St. Louis f. Mr. D. B. Hosier, Anniston 10. Spare held in -M.C.L. file at St. Louis 11. Dr. V. A. Hayward's file Ruabon also Section ZZ, Specifications and Test Methods, to Newport Analytical Department. WATER PCB-SD0000010774 I VI. FROCESS IN DETAIL, eontd. - VI - 34 Frocess Detail Fa eking Sit finished Aroclcrs art run ff Into drums, a piece of diaper cloth being tied on the pipe outlet for the lighter Aroclors, and a piece of fine gauze for the heavier Aroclors, which have to be handled hot. This, of course. Is to arrest stray bits of pipe scale etc., but the precaution Is now omitted at the JCrusmrlch plant when material: are being filled- directly from the delivery of the filter. Newpor. arrangements for filling and weighing drums are discussed In Londoi Engineering Final Report, September 1951, page 1D8 and 1 F5-10, also in the start-up reports, July 24, and September 27, 1951. The drums must be clean and dry, especial care being needed with electrical grades. Newport complaint NF/61, November 1951, of turbidity In 1248 was traced to the presence of water In the drums. Apparently, in presence of water, the Aroclor reacted on the galvanizing of the drum. Newport plant report, December 1951# mentions the Installation of equipment for drying the drums. . Care is taken not to do any packing If there Is HC1 fume In the air The gaskets for the bungs of the drums have to be correctly chosen. A sample of the gaskets supplied by the Helrath Supply & Gasket Co. to the Krummrich plant was sent to MCL, April 1947. See also the ,, .discussion .&fLgaak*ts^wvpmce-'*2 t Mr. Pemberton, December 1950, collected samples cf the labels used at -the Krummrich plant; cne a patent list label, and the other a warning label on toxicity. The effect of exposure of Aroclors to metal contact is discussed in Section VIZ,` comments, page 17 below. Generally speaking, the distilled Aroclors are packed in galvanized drums, the undistilled ones in black steel drums. Flaked or milled solids were packed In barrels or Leverpac containers, bulk solid or resinous Aroclors go out in friction type lid drums, (galvanized for the distilled grades). Storage and blending of the distilled Aroclors is done in steel vessels sprayed with tin or zinc, or aluminbm lined. ADH 00253C 47 I t WATER PCB-SD0000010775 I VI. PROCESS IK DETAIL, contd. vx - 35 Process Detail Packing^ eontd. Since the Arodors are such effective solvents , they damge, and are damaged ty, ordinary paints* lacquers* Insulating varnishes* et This feature is important in connection with hydraulic fluids containing Arodors. See* for example* MCL Research Progress repo: 1151* DP 54/26/7 and DP 54/277/6 and 1152 DP 4/16/7 and 6 July 195* etc.* also the Section III* Physical ft Chemical data* above. Drums for electrical grades of Arodors art not painted. Newport Plant Technical Committee meeting* April 14, 1955, page 2* reported some promising tests with lacquered drums for electrical grades, It was decided not to use lacquered drums for resinous Arodors on a returnable basis* because the lacquer suffered at the high temperatures likely to be used In melting the material fro the drums. . Arodors also are dispatched In rail ears. At the JCrummrich plant the manhole of the car Is protected by a tarpaulin tent during fill; Newport plant report for July 1954 mentions the Installation of tank-filling facilities. The Krummrich plant operating instruction* August 10* 1954 mention that rail cars for Pyrands and Arodors are insulated and have either a steam coll or a steam Jacket. They . are lined with Aluminium or else sprayed with tin and zinc. Only dry air Is used for unloading. HOC have a "Christmas Tree" fitting, a one piece fitting carrying air valve* dip pipe* release valye^ ^ st anksv* ant*tif 'Ifrfr. the coll cr Jacket of the rail tank in cold weather. Galvanized ' or lacquered drums are used for Pyrands. aCH oc 2 53 4B WATER PCB-SD0000010776 U. HAZAUBS Toxicity XI - 1 Hazard! Thtrt art many littraturt references*to harmful affects of the typ of "chlor acns" resulting from txposurt to chlorinated diphenyls especially in eases where people working with small electrical com ponents have been exposed to the fumes of hot, highly chlorinated, Aroelors. Chlor acne is sometimes accomj*iied by gastric troubles,# and there are literature references to liver troubles. There was some trouble of this kind among the production workers a' Anniston in the early days of the development of the Aroelors. At that time highly chlorinated Aroelors were being made from dlpheny: which had come from low grade benzene. Since good benzene has bee: used, the same Aroelors have been made without trouble. Zn March : it was reported that the Anniston diphenyl and Aroclor plants had : 12 years without lost time accident. From the start of Aroclor manufacture at the Krummrich plant the operators have been supplied a clean change of clothes every day, ' and time has been allowed at the end of the shift fer bathing. Operators are advised to wash hands and face before eating. The Anniston operators de not have the same issue of clean clethes. * Percy May, "Chemistry of Synthetic Drugs" , 3rd edition, page IS The "Chemist Analyst", September 19^7, Volume 3, No.2 page 33, - v .^.^asd^a imsten^-AnniatonAplanfr* *19 on the toxicity of diphenyl. " MCC Bulletin P-ll^/ientions^S^to 1.0 mg. per cbm in air as the highest safe 'concentration of higher Aroelors, and 10 sg. ler more - highly chlorinated Aroelors. . K. B. Edkins "Chemistry of Industrial Toxicology", page 1*9 give 0.5 to 1.0 mg. as the allowable limit in working rooms. The MCC Bulletin "Physical Properties of Aroelors" mentions ays . temlc effects arising from the oral injection of Aroelors. See the letters, Z. Mather to P.J.C.Haywood, December 17, 1951, ; Mather to Newman, January 8, 1952, reviewing the literature on t; toxicity of Aroelors. See also correspondence relating to the article in Chem. k Big. 1 May 17, 1954, pages 2038 -> and the warning labels mentioned on page VI-34 above. AC* C02532 49 WATER PCB-SD0000010777 ) XI. HAZARDS. eontd. XI - . Hazar: St. Louis, Main Offlea Mr. P. J. C. Haywood Newport (Airmail) @si Mr Mr X>r Mr Dr Mr 'December 11, 1951 W. . Hamer, Ruabon W. H. Ritchie, Ruabe H. R. Newman, Ruabon S. M. Kulifay, Kruzsa D. S. Veddell, St. I F. T. Marshall, St. AROCLORg;.`TOXICITY Since writing to you on December 3rd Z have come across a letter of mine to Mr. V. M. Cooper, London, June 24, 1948, (copies to W.D.S., V.H.O., and others), calling attention to an article In the J. ?. Baker Company's "Chemist Analyst", Volume 26, No. 2, page 33, September 1947. Z attach a copy of this article, and Z think you will 4,,, .^,^.^agrea-^ha4<;-the.i.w*ain^.Tiate*--only bor--r*ai'ly ^sd 'exptwartfr*?* not such as should occur In ordinary analytical work. On October 27, 19^7 Mr. Barbre of the Krummrieh plant sent a copy- of the Journal to Dr. Jenkins at Anniston for comment. Dr. Jenkins did not make any comments at the time, but the following extract from Mr. Barbre *s letter is inter esting: "During the 11 years of production here only one man evidenced dermatitis. He had also . shown similar symptoms In several other departments. When making Aroclor #1270 which is flaked, a noticeable amount of fine fume solidifies in the air. Zf men are exposed to It during hot humid weather, the skin is Irritated, but we have not had any difficulty In curing cases of dermatitis from It". ACM oc Kn . Mather WATER PCB-SD0000010778 xx - hazards, contd. -: Haitre Tht Chesd.it Analyst, Vel. 36, No. 2, page 33, J. T. Baker Chemical Co., Phillipsburg, n. j. ` September 1947 ON THE Tonaw OP THE "AJIOGHLORS" (lie) Robert If. Brown, Chief . Industrial Hygiene Section, Division of Health ' Dept, of Public Welfare, City of St .Louis,-Mo. A recently published article (Magllo, K. Martin, Chemist Analyst, 35 9^ (1946) ), has recommended the substitution of one of the "Arochlors" as the melting-point bath liquid in preference to the customary sulphuric acid. As stated in that article "Arochlors" are a group of chlorinated diphenyls produced by the Monsanto Chemical Company. There is need therefore to give warning. For the toxicity of these compounds has been repeatedly demonstrated, both from the standpoints of their absorption from the inspired air, as well as from their effects in produ c-lng a serious and disfiguring dermatitis when allowed to remain in contact with the skin. Since these effects have been repeatedly observed, industrial hygienists have taken care to see that the proper controls have been established wherever these products are used. For example, the maximum allowable concentration of chlorinated diphenyl for an 8-hour working day la 1 milligram per cubic meter of air. It is probable that nothing like an uncontrolled industrial expo sure will occur in the laboratory. However, whether an individual is subjected to a possible acute exposure to chlorinated diphenyl, and its serious consequences, will depend upon the size of the melting-point bath, the caution with which it is used, and the temperature to which it may be heated. Likewise, with careless handling of the material and the resulting contamination of the . ^kln, clothing, laboratory towels, work table surfaces, etc. the way is left open for the producing of dermatitis. Scrupulous ' cleanliness must be insisted upon wherever this material is handled X The foregoing remarks have been prompted by the belief that in re commending the use of a material with which is associated a potentia hazard from the health standpoint, it is very important that the possible consequences be presented together with recommendations fo: correct handling. ' 51 ACM 002 WATER PCB-SD0000010779 XX. HA2ABDl eontd. XX Hazar Hr. A. C. W. Pennington of Newport, reporting on Ms Aaer<ean toure December 29* 1950, page 5 writes: " "HEALTH AND SAPm": "At Anniston, no special protective clothing i provided f the Diphenyl and Aroclors operators. A dally change of clothing was provided In the past but this practice ceased before the war Gauntlet leather gloves and face shields are, of course* avallab as required on the plant. . " Tins of cold cream ointment* theatrical quality* are to 1 In the building* but the application of the cream is left to the operator's decision of the Job in question. The men are expected take a bath* In their own time* at the end of the shift. A good quality soap* and alcohol for rubbing down purposes* are provldec The operators are sufficiently trained In the need for personal cleanliness that a record of bath taking is not warranted. "Baergency showers are provided on each floor of the Dipher. building and safety notices are widely used. "At It. Louis* Plant B* the Aroclors building Is rated a toxic department. Each operator Is provided with a complete set of clothing comprising hat* coat* trousers* combination under clothes* socks and rubber shoes. A clean change of clothing* except shoes* Is placed In the operator's locker In time for the following shift. Ken working extra shifts are given a clean set of clothing. Canvas gloves and goggles are provided and 'Ply hand barrier cream is available for use when necessary. "Twenty minutes1 paid time Is allotted for bathing at the end of the shift but* again* no record is kept that baths are actually taken. Theoretically* food is not allowed to be eaten within the Aroclors building. Instructions are issued that hands and face should be washed well before eating. "Employees In toxic departments are given an annual medical examination and a lung X-ray every three years.". ACM 0C2 52 WATER PCB-SD0000010780 ) - XI. HAZARDS, contd. Toxicity, contd. XI - 5 Kaiarda 0 A good deal of work has been done on determination of the vapour pressure of the Aroclors, and on the determination of/concentrate of Aroclors in air. See pages 9-, Section III, above, for a sumrof this work. In 1950 (letter April 20, N. 7. Sapps to E. Mather) the Admiralty expressed Interest In the determination of micro-quantities of Aroclors. MCC have a method for the determination of traces In air by means of the "Halidometer". . Mr. Ellenburg, March 15, 195^, mentions work done by K. B. SI chart Jr., of MCC, June 17, 1953, on the determination of the concentrat of Aroclors In air. Mr. Ellenburg also states: work on the safe limits of Arodor vapour concen tration In air is being carried on by the Medical Department at the Kettering Laboratories in Cincinnati. This work on . animals Is well under way, and will help us to know a little better Just what is the safe limit of Aroclor Vapours that one might work in." ' A question has been asked about the possible harm to plants if Aro< containing paints are used In greenhouses. The reply Is that most paints are somewhat harmful, and there Is no evidence that Aroclor: make them worse. Aroclors have been used as rabbit repellents, wl*. out doing any harm to vegetation. * Care Is needed in laboratories etc. where Aroclors are used in heating baths; there should be very positive ventilation. The vapours of hot Aroclors are distinctly irritating to eyes and nose above a concentration of about 3 mg per cbm in air. Newport plant report for December 1951 records bums by hot Aroclor -- a case of a splash into a man's eye -- without serious damage. . Packages of Aroclors leaving thfe Krummrlch plant bear a label calll attention to possible toxic. effects. 53 ACM COi WATER PCB-SD0000010781 c 6 I XX. HAZARDS. eohtd. II - i Haiars Fire Hazards Diphenyl, of sours, will hum, mud reasonable etre is needed in handling it. Precautions with toluene are mentioned also on pages VI-29# and under "Special Risks", below. The Arodors are handled as if non-inflammable. Drums of material are melted in the middle of the operating building, by open gas flames, and open gas flames are freely used to heat pipe lines. An instruction, dated April 28, 19^8, calls for a daily inspection of safety showers, fire extinguishers and gas masks, a check list being provided. Flanged joints on Aroclor heating system can be a source of fume. . See the notes on gaskets, page 2, Section HI, below. Phosgene may be generated in electrical flashes and fires in trans formers containing Aroclors, but this is not thought to be a major risk. Safety Equipment Each operator in the Krunmrlch Aroclor plant is supplied with goggle rubber covered gloves, canvas gloves, rubber shoes and fume resplra' See also page XX-1. A spare suit of clothes is kept in a case in ti department. The department has the usual first aid cabinet, gas ma: (chlorine), fire extinguisher, (toluene, diphenyl), stretcher, safet showers, drinking fountain, eye bath. Special Risks * The usual cart is necessary in dealing with chlorine, in lighting the gas furnaces, and in handling hot materials, steam lines etc. Diphenyl might start to burn In chlorine gas if conditions in the chlorlnator were badly out of line. A Davis "Vapotester", model M-l,, Type A, (Division of Davis Emergent; Equipment Co., Inc., Newark, N.J.) is held in the department for use in testing the air of the working building after toluene has been used, and for testing vessels before men are permitted to enter, and before "flame certificates" are given. The instrument contains a ACM 002 J 54 WATER PCB-SD0000010782 I U. HAZARDS i, eontd. XX - 7 Hazards . Special Risks. eontd. . catalytic cell electrically heated to a fixed temperature, and the air to be tested Is aspirated through It by means of a "squeeze ball". 2f combustible vapours are present, the teaperature of the eell rises, and the Indicating thermocouple registers on a cali brated scale. The instrument has a zero adjustment, and It Is checked twice a month by the Instrument department. Flame certificates must give the number of the Vapotester used, also the data of its last cali bration by the Instrument department The Instrument has been use ful In detecting gas escapes, and In tracing spills of gasoline, etc., from a neighbouring oil refinery Into a public sewer which runs under Monsanto territory. Mr. Benignus, of St. Louis, September 1953, discussed the dangers of using Aroclors In Indoor paints. He discounted the possible dangers from phosgene formed by flash discharges in transformers charged with Aroclors. See the references to safe handling of glyeldyl phenyl ether on pages 1X-161 etc. 55 I AC* 0025 WATER PCB-SD0000010783 S** c 4 Zs >#*-, '* */<i - g+ytCj +** ***^ ^ /'1*C,C- 1I ^p*f^s*4k *wr*4-: <JI *!a*.Vffc$w ?**--.^Vi. ?c*y.* %5^'***,fc""**:^i- 56 4SM eeis3? WATER PCB-SD0000010784 ) 1C2 Minutes of Meeting of the CORPORATE DEVELOPMENT COMMITTEE April 22, 1968 Present: C. B. Sommer - Chairman E. J. Sock J. L. Christian J. L. Gillis R. K. Mueller 1. A. O'Neal M. C. Throdahl R. K. Flitcraft - Secretary A DM OG&CH5 78 WATER PCB-SD0000010785 J 103 Dr. Anagnostopoulos reviewed the functional fluids group. Phosphate esters and AROCLOR are the two major products in this group. The product group expects to be above the 1968 budget in terms of R01 and on the objective line for net income. In the case of AROCLOR the key issue becomes how to significantly increase the sales growth while maintaining the domestic supply position and profitability. It is believed that transformers and heating systems provide the major opportunities. A target of 10 per cent of the transformer market by 1972 has been set. In the case of THERMINOL we have about a $1 M business in 1968, and a target of a $10--20 M business by 1972. In this area, a total systems approach is being used; supply the fluids, design the system and supply the hardware. 79 AOM 006046 WATER PCB-SD0000010786 f^anlCL^hi^^ t. Lcmli# Missouri fir. J.W. Barrett imim COPY fir fi.ViKi Btrdy^ fir B.R. Kivbiq( lepteaber 2@ lfff Ifour aeo Septsaber 6 to Kr. Nason mocim toxics* ' V. *^3| Howard Nason has gives a roar aeao of September S. 2 vlll be happy to discuss this vlth fir. Nevnaa dtiring Ms visit here. Z think} however* there are several peiats that 2 eaa answer yea now. You consent upon the difference in toxicity between Aroclor 129* and 1242. This is not particularly surprising because in the eerller werk it was found that texlclty increased with chlorination. Of course, froa the standpoint of vol atlllty In the case of Inhalation or absorption froa the fut froa the point of view of ingestion are iaportant. rankly there wee not too great a difference between the two coapoundiy hovevor. ii you know, the aexlsua allowable ooncentrete is O.l al/euble aeter in the caee of 124, and as high as 10.0 aga in the cete of 1268. 2 think the former is too low and the latter is too high. In this country they don't use the fclCs very routlnelyy but certainly in England 2 think it would be alright to consider 0.2 aga/eubit aeter as perfectly safe. * doing aore work. What is It that you want to prove? 2 believe your werk should be directed towards finding out what tbs concentrations are of Aroclor during different operations .whether it .is industrial or painting. The re ports you have seen froa Kettering Laborstory are the re salt of approximately Ilfe 000 to #20y000 expenditure by MOC* . MCC'a position can be sua&arlzed' in this feshloa. know Aroclors are toxie but the actual Halt has not been pre cisely defined. It does not asks too auch difference# it setae to at# because our aelo worry Is what will happen if an Individual develop#s any type of liver disease and gives a history of Ar&olor exposure. 2 aa sure the juries would not pay a great deal of attention to MiCa. i 57 \ WATER PCB-SD0000010787 sm fag# i $ptabir 20, 1955 ^OCLOR TOUCH! Xa, therefore, riTliv every new Aroelor as fro tbla point of view. If It la as industrial application wharf we ean get air concentrations and have aoae rtitoaibli expectation that the air coneentratlofia will itAjr the saae, ve Are nueh ore liberal la the ate of Areelor. If, however. It it distributed to houiehelderc where It can be used in alsost any shape and fora and we are sever Able to know how ouch of the concentration they are exposed to, we are aueh ere strict Xo aaount of taxioity testing will obviAte this last dlleaaa and therefore Z do sot believe any sore test ing would be Justified. Let's see whet our dltousslons with Pr. Kcwbas aad yourself bring out. .o'. JL Esnet Kelly, K.P. 4 'X* "" i--,|j-rij 58 WATER PCB-SD0000010788 ?au c oiubir n$ im mjw. to. 1. tUbur Speisher Mmn9tm&m3s, &Asj trial werUafhoua &mtri @er?ereti@n MS% nttSfeUFgfte FtsnsyifSaifi to mtwri /cm for f&s? Irttej* f etofeer 21 in^uiriAg about th safe w ef tri*hlef>e44pbnyi and a atrtvu* ef 40^ triahl ` ac4 6 hesaahlerodLphesyl erodinhinyj r*41pbQyl ,, " i the bmgl b mkLrm%lm is Bse and thmieal prepertia* ef the Irmlam wmotimmi ere mmm m the %Mm m pages 4 end 5 ef the irmXm bulletis. ^sloi else is a reprint IMMMm th remits ef ahrmds tsslsity studies with Arm lore njehrand Iff*, ffce feUeeins %&msm% &>mmTtng your questlms serially art a eetala4 in these fcuHetins. 1 balie-re preler^ed end repealed eentast with any ctf Hi Areelers should hi avoided for tve reasons. & the fint Ilas, Ih lets hlri>sJd produets ire MfuMa and ere easels eot solvents for @Hs and fats is the itetn as mil as ether mA&ri&Mo geasndlyi it ii poeaihls that preim$ed m treated rtda sentMf eemli lead te ehlera*a 1 bnv v sal/ tee ea#% Aer susfe wa^mrLMom has depilated during the Umg history ef fap#Airti and use ef the Arealers# & o as an Ajw1 ms halag used as a heat trenef^ medium in a system that aUsmed vipers te esaap shea the mterlal ms heated t fey sn Industrial Ay*Is Ian hut Aiih in Ms wds mr m 4a it^UX&arl that mi mm mr not asaw ef them nor muld a iMnl fraatiUmsr notls th this io&hamMm t fe@evr# cbrn ooooo 59 WATER PCB-SD0000010789 . * ) Wo I, MUbw9 fpeleher--Page 2-tbr 23* 1959 that euffieiant j^esurt# lAtihii9 bj infmiatiGn of ?i#ra r skin eentasf# ean result in eJUerasne itii&h I think w mst aesvM fail4 be as Indieatien ef more mp4a* sy4@ injury If th exposure u allem4 i@ entljjue &seeend ease f alii *hi arean# about idiieh m have mny' '* knowledge resulted from werteen dipping their hands in th liquid Aroeler as if it %r# mineral oil r vegetable eil#. 2b sedition# their siething ay ear later bceaae imprecated with th@ material and thus exposure was magnified# 1m sated at idmt ts^>eraturo local exhaust ventilation should he provided. Although the distillation range fer Aroeler 12*i is 325"360Ce and 385-420ec. far Arcelor 1260, I feel that g4 practise dietate that Im&X exhaust ventilation he provided t&en gey ef the Aroelort are heated above l0y. la pen tanks ear in any systems tdiere the material is net in a completely easleeed ijsfem (vaper-preef tanks# kettles# pimps# piping# ete.)# this may be ultra eoneervative because as the distil* latien ranges and vapor pressure eurves (page It ef the Aroeler bulletin) indieate# the less ef vapere at 10F# sheuld net be slgnifiaant except la any werk area where general ventilation er air ahanges de aet exist# Your next question related again te possible sldn and systmi offsets and 2 believe it is answered above# la eenneetien with the h0 triehlerobensene-iOjI Aroeler 1S60 e cabinet ion, 1 believe the thoughts expressed above also apply# 2 understand that the trlahlorobensene tdiieh is used is a mature ef the 1#2#3~ 1,2,*-# and l#35*lsoBers tdileh will begin te distill at 20fe# Again# 1 believe this indisates a low vapor pressure fer the solvent at roan ifiratio*#* e She only roftrenoe we have te triehlerobenseoe texlsiiy is eon* tained in the Pub111 Bsalth Jervis fublieatie Me# til entitled "the Sslogesated lydreearbens fesdsity and Potential ganger6 by Brt We f# von ettingea# 0.1. eeverrmsat Fristing efflae# 1955 (p&f 27~f9@) Sr. ven Settings refers te earn work don# in 193? tidLsh indleafeed that the triehlorebenasa wu less tootle than sene er diahlerobensen. In sy pini# a reasonable HA ter this material would be 100 parts per aUliea# the emleeed publltatie on the texieiby ef Areeler 12tf and 125^ suggests an MS for 12t ef 2 aUltcaas per eubia meter whleh Is twist that roeooetnded by the kSQM ter a ehlerimted ti- phenyl ef imitated ehlerlM sente*# In the ease ef 115*# the publication suggeats that th MM of 1 mllllgr*a per eubii meter roe@feoded tentatively far mft ioAmtrial prastiee by the teerlea Confer ef ovemimtal bdustrlal ^rginists is reasonable# te the thar hand# roftrem# te Bnry iayth'i tunings H@rial LmUam @f 1|S In he dlaeuswd the basis fir the than exLstinf ^hyglsaii standards6 indisates that CSRN 0000S36 60 WATER PCB-SD0000010790 1. Ubux ft* 3~cttar m m Wmaj' ommm that MSa # l tm Ares lap 2l*i ast il ^m4 fer MtoZn Z2S* a* sr mlXstoJe fii ten ab-> mo@m a# nr iteaii tntoitr date atn immlm U69, ns fyggast SB @X @e| g/fUem,# |M MM l Jfl 1^0 fSB @f ZS^t* 2 hart ton la tee pint ite this a&tortoif wn tts4 ftr apwiteirs ini tmmf^arie -t aart a@4 hardline sad the mrifina af etfeaujf mtliaties @r mm to a@r4aa with the %htmMu ator Bis mlf rtpartod diffisultr m m saili r iiwlMMlm mm is^e&mtim cafeiaati vhmww the Items Mfi ml4 to ZXZ mlommi *apr @# trmzn- taam asi to Isto tbs wm%a*mm mm Us eafetoa-t tea m Sa M4# M mhimt atmM to mUZatoi 1# wwbbst tto rw^rnm imMsm? mm iU thm to to wImM iato tbs Z tort ton toZi that rur ts^asr fe&s had seas teiS rtf lto tfc gr*4iat 4is\9#4 &to*e It oi sugstatod that m>. B Ffr* wmmxsw el transfers* MmfMtwiag at gwr Mmres fiaa* touli to a asura of iafersa tin rt^o-itog *p?iaa with fctrtona WO* HmHwlyg to 1 I, Rato? f r@y? Hnigtfi ZadLam Hast has ton &*sei*to4 with tto wm @f Amin ZS4i# ptffcap# yea tia? al md? &Ufu*s4 petosttoi with that pnUmn, If m 2 @aZ4 to Zstoraatoi is Znmtoi f ihuljr fMtto&Z as 2 ZtoH fn in f&ttete^i gimmmlwt fii MINIM baf f IteZar Mg%affialtjoi|s* HmtoP 66RN 0000C4 61 WATER PCB-SD0000010791 I April $o 1962 Si?. 1. Wilbur Speieher* Adainistfmter Industrial Hygiene . Westingheuss itrl toperatlss Eut Pittsburgh* ftmijrlYiaU gear Wilbur* * ' . thank you to your letter of April t I was in Mow fork > and Philadelphia lul mk so 1 did sot receive the crres pcodenoe until this aaraSng * ` 1 ogre* that no should reconsider our statement in any Arecto bulletin relative to tes^eraturee above tdiioh local exhaust ventilation should be provided* 1 believe the specific bulletin you aentiee (Bulletin -fH) is out of print* If 1 find that it is sot* 1 will have oorrectiene s&de is any reaainin eepies* Proa your familiarity with the Aroelere as a elass f compounds* .1 know you appreciate that it is a aistak to attempt to desoribo safe handling practices in generalities, WUle exhaust ventilatien-to Aroolor 5460 &ay sot be required until temperatures reach 200@ to 30&V, such would probably sot be the mm fer Aroolor 1242, the differenoe here sen be appreciated free the f&ots that Aroolor 460 has a distillation range of 260 to 335C at 5 n&8g* whilo Aroolor 1241 distills between 325 to 366C at ?6o m.gg# the experience of your company in handling the specific Aroelere that you use Should die tats mere end at tt temperatures local exhaust ventilation should be provided* 1 sen think of no better p#rts than you end SA lames as to tdmt soetrel asasures are necesaasy in jour mm plaat@ . 4 . In connection with hand creams, it would be ay impression that one intended fer protection against Organie solvents would be preferable to the type intended to protect against aqueous GBRN 00000562 62 WATER PCB-SD0000010792 I Mr* 1* Wilbur flpeichsr - Figi 2 - April 30# 1962 aoluticn. Th# liquid Aroelora art good aolvuta for tha normal fill and ill of the gida* In our mm perationg v try l ifcrtaa pptvuntien of skin tent*I rather than the us of creams* to answer four specifit question# however# it would appear to m that Fu4 f would offer mere protection than Fend 1 or find | . . -. ,, i. I # v / ^ ' ' : / .. *. Very Indjr 7i . "/ Will Bmi> P* Wttml&w Assistant X&reetor Medical Pepartneaf el i *f4 <? ij.*ff**+K***xiJ*+, *" *"v .* ** > - ' s . " '** v^-t . ^rw#vrs 6BRN 000006 63 WATER PCB-SD0000010793 ) ItaiASf COffAHT MMStm, MJMM tahmu epmyxHs iismoraeii rot MXLm Ktvlaed: July 1964 Copy He. AJ" Pripirid ky: J. V. Nolley Froductiea Supervisor K. C. Needy Freduction Supariataadaa \TIAL 64 ACM OC25 WATER PCB-SD0000010794  c * J -- %** 1. C ( *1$^ ^V^'^i'Vi.Wvy.* W` r<S**U*A;rfrwhSC<%*. ADM 002506 65 WATER PCB-SD0000010795 ePMiw xusixncixan ttOCUU 1. lAFftf ahb H0iisttgmsc Safety I operations is the Aroclor riant depnds a thi individual operator. Materials balm bandied and operations Hit be observed closely to guard against tha followingi I. @ileriae aa Causa & Action to Prtvaae Chlorine gas la & vary toxic corrosive gas. leaks or high pressure can occur to liberate it. Action to Frevent: . c. lepert Chlorine gas exposure lmedlataiy for treatment with Antidote. Milk nay ba used la nild cases to relieve threat Irritation. . Oxygen free the resuseleater in the Dispenser? ' is available. b. Keep gas mask in good condition. Keep a good cent star in the seek. Use these type casks only in Chlorine concentrations to 2*31 Chlorlai la air. e. Use a Scott Air ?ek in concentrations of Chloric gas above 31 in air. Three units are available la the Aroclor-llpheayl lepertaant. ,, -r.-J .<*>*-***. Slf h >r,J|f..^%ugh ^1 .Chlotloe.'ga .wtthous your breath and go cross tried until you era , out of range of the gas. Place a handkerchief over your nose in snail quantities of Chlorine. c. ftepert all Chlorine leaks for repair 1 mediately Make tsoporary repairs with tape if possible. f Sn case of c major Chlorine leak the source of Chlorine gas saist be stopped. lotlfy Che Chlorine Plant immediately if the pressure on the Chlorine manifold exceeds 30 pslg. Cut off liquid Chlorine item the ear. 1. Thermal luma Contact with hot uninsulated product lines at the ehlerinaters and still areas. Contact srlth uminsulatad steam lines and op am team. * Contact with hot Aroclore fro broken lines or leaks. Contact with open flames at Stills er from heating lines in the department.66 66 ACM cr WATER PCB-SD0000010796 . - ,1 c maitm asnumms . Mocums 1* SAfTtY ABB HCOSPJJPPfi Astia to Pfevent: 2 1 Thermal Bums (Cot'4.) * a. bw that contact vith equlpaent and produet will eauao a therul burn duo to the high temperatures. Kako changos la operation with this hatard In mind. he Know the first aid treatacnt for burns. Sold Waemr treatment (See Appendix A *> laargeney Mrntim) @ Wear gloves and long sleeve shirts vlth the sleeves rolled down vhen operating. ` Cloves and clothing can nake the differs between first and seeend degree burns. i. Baport uninsulteed lines for repair of insulation. @. Dee onlp ataaa lines vlth hose end hose clanps la good condition. c f. Tho following operations are haeardoua and should be dene vlth care: (1) Catehing enables at the Aredor chlerlaater airculating punpa. (2) Sailing the Solid Areelor still receiver. (3) Droving bettooa on the Aroeler still; 3. Explosion . An explosion could eceur in the chlorines bp slugging liquid ehlorlns to the dietrlbutor or shutting off the voter die charge valve on the ablerinaeor cooling cell. Slugs of Liquid Chlorine could react feat enough to cause excessive pressure la the vessel. A rupture of thi chlorinetor could occur. Closing the voter discharge velve on the ehlorinetor cooling cell isolates water in the ceil. As the reaction occurs releasing heat, the voter vlll vaporise end could split e cell and tank. Action to Prevent: a. Observe operation of the Chlorine reports and do net let liquid Chlorine get into the rotameters. Pipe lines vill be frosted. ' 67 AC* CC WATER PCB-SD0000010797 ) arnAixM aimimtDi AHOCLOM >. gAFfTY MS gwmg^ ie feplooloo (Cont'd.) 4. Falls b. fa east Chlorino faad Haas ara froatat eloea liquid Chlerlaa faad valve to cb< vaporiser. Cheek ataaa addlelea to th< vaporiser. Xaapecc oparatioa of tha vaperisar. Do see scare up uocil aourc f ereubla has haaa locacod. fi. * 00* el* valve la vater discharge line from tha chlorlaaear cell. 4. Observe temperature of the chlorlaaeor periodically and ho sura le is aee too hot (160C maalaua). Slipping on caaaat floors, stairs, ipoe! on floor, lee conditions; tripping ever objects (hose, pipe, valve handles, ate or losing footing on ladders, etc., can cause falls. Action to Prevemt: fhe majority of sdner, serious, end near miss injuries la the Aroclor Dept, fire the result of falls. Prevention is alva vltbla the ability of tha operator by ua of expert operating practices. b. fhe following items should be done: CD Saturn heae to rack after using. (I) leap operating areas clean of all foreign objects. (3) teturn ladders to racks whan nee la use. (4) leap gloves on end heads out of peek especially going op stairs. Cl) Place guards around any area that presents a hasard that should he guarded. a. Peer lighting due to burned out bulbs Should be corrected at ace. Poor light ing due to inadequate facilities should he reported. d. Spills oust he cleaned up immediately fallowing ebalr occurrence. Sepert any spill that can net he cleaned up within the shift to the Chief Operator. SpU'* are to he reported in the log book. 68 WATER PCB-SD0000010798 OfOAfOtg XRSTUeZXCBS A&QCtjMtJS > iAFiTf mb Bcpsggtpywe i e fif Fires ess eceur Biphenyl, lutwu t, er Sentovax Ignition. meriae prokliu ia the viptrlte allowing reeetlea vlth itue to release Hydrogen. Funeee burner beekflre. Seed, rege, w paper ea hee liaes. Sparks from velding apparatus er open flaaes. &mt&m te Prevent: a. ires must be clear of trash er flaaeab materials. Us* trash skips aad cans. i. Smoke only ia areas so designated. Use spark producing equipment only vit' a fire perait aad proper inspection. d. Use care in lightiag gas torchs or the still furnaces a* Fire fighting equipment includes: Cl) f*o wheeled dry powder units. (2) lose house with 200 ft. of hose. (3) Twe dry pcwder hand extinguishers, Ona C0| hand extinguisher. (4) fee 3/4" voter hoses. (5) lose connection north of Scntwax. (6) Scott Air take. (7) Fir a truck la fire house. f. Observe visitors In the plant and he eur they observe safety rules. . The following Is a list ef the chart eels handled in the iroclor Flant operations and the precautions te be token during their handling: a. Chlorlaa Cas Chlerlna Is a vary toxic corrosive gee. Lea or beck pressure can occur and liberate chlo rise gas in tha area. Operators should have their cartridge type respirators heady at altines vhila la the area. Use of ges masks it explained ia Section 1-1.69 69 WATER PCB-SD0000010799 mwMim msnucnais AIKUU S B. tAfTTT 4TO ietSlgKlEP>aiS i a. ftlerlu 6u (Coat'd*) If feu irt caught without a gae seek and large amounts cf chleriaa gae are liberate kXd your breath cad go eroee wind uatil you are out of raaga of the gas. Oaea out f tha area, obtaia aa snifftagy gae @aek cad ratura to the area aad correct the tro 4 vletin ef chleriaa gae fusee eat he ras aa guickly ea feasible free the gaaeoua or. Place patioet oa his hack with head cad ha> elevated. Milk say he used la slid eases t & relief item threat irrltatlea. If the patlaat has stepped braaehlag, start artiflcial rasplratlee 1Mediately. b. Biphenyl Blphaayl is a flaasable material which will hura. Buralag should aet he does la the prasaace ef Blphaayl or Blphaayl vapors. 1 salting point is 68.7C.j flash point 106*C the fire point 124C., aad tha auto lgaltis tosperaeura is 258C. Zahalatlon of Blphea fuses is aet racoosaadod slnca it can cause a drugged offset on the person. c. Saneevax 1 faatewax 1 is a flaaaabla satarlal which wi hum. It is relatively nee-tesie to husaa helags. Bovaver, tha vapors ef Saatowax 1 ere lrrieatiag to the sucous sasbraaes aad hronlchial traet. Prolonged hraaehlag of the vapors should ho avoided. Ihe seltiag point is 160C. * 4. Saatowax Base as Saneevax 1, slaca it is the crude satarlal prior ta distillation. s. Ferric Chloride Ferric Chloride is a black-brow aelid. It causae only slightly irrltstiag effects on the ekia or sucous sasbrtaes. When heated it will deeesposo sad release toxic fusee ef 1C1 (hydrochloric add). It will react with water to produce toxic end corrosive HC1 fuses. f. detspulgus Earth This ssesrlel is a dried earth. Me danger la haodllag. Mash off with voter to clean. . lydrated Use Me particular hssard ia handling this sscarl< the dust is lrrltatlag to the ayes and akla cad should he washed off with water. h. Crude Aroclore Crude Areelors are hoe elace all are handled ia staea traced or jacketed Hate. They can easily cause thermal burns ia contact with ' 70 WATER PCB-SD0000010800 mmaae oktkdcxxons momas a. iAPirr ahp logs topnta i. k. Crude Arodors (Coat'd.) thi akin, frier ie sir blowing material baa IC1 funea entrained la It isMek are Irsrltstiaf to th gkiB mi m%wB mamkgmme 1* lydregea Chitrine Cm ' This a eerreslve gaa which ia toxic. St 4* irrltatlag te the aueeua aambrenes, t< tbe eyes, and te the respiratory tract* It will react with water te fern Hydro chloric Aside J. Still bottoms er Kaaldua HOPSECIgPgBG fuses from atlll bottoms era toxic* She; are extremely irritating te the eetui membranes, te the eyes, add respiratory greet* .. The Ireelor chlorioator and atill operators are raspeosibla for house* ksspioi duriag their shift* Good housekeeping is the sark of good operations, safety practices, quality, and costs loueekeoplBg duties are equal ia importance with all ether operating duties Poor Frectlcee Aetion to Prevent *. 4 -r5E 1. Hoses, valve haadles, dip a. Beplaca after msa. sticks, rags, and ether material m ground or floor* . h. ^ i Jyj aids* . c. Kapert Beads to supervision. f. Product leaks a. fightob valve peeking glaads Bad flaage holts* h. Xaport leaks to Chiof Oporator for maintenance altorstloa* 9* Trash aad crude drums 4. Product opills er cleaa out masses a* Contact chief ta have drums moved fro area. h* Use trash skip ia ar AD* COg a* Prevent aoeassity of dean-eut hy keopiag traciag, iasuiatieo, or Jacket is good repair by getting items turned la for melateBeace work. b. fpille must be cleaned up whoa they arc made. Clean up will continue through the fell owing shifts te finish the Job. 71 WATER PCB-SD0000010801 0AUA1IK3 ZKSlklKllttii AtOCLQtS ) 32. DETAILED IHSTRUCTIONS III. Loading Refined Aroclors Arcelor* are flipped la fire (tiles eaasj. 55 gtllen druas; 4,000, 7.0CC ted 1,000 (tlloe Unk cars; tad 3,000 or 4,000 gtllcra teak trucks ee * euitCMTi. a. Spotting ftak tea Noras Uy ebo rtilretd switch craw trill spot ears at the Arcelor lotdiag deck. Occasionally it will he necessary te aeve a tar. Vbca it it accessary use the half track aad pull the car late positlea. (1) Obtain balp te movc the car. (2) Attach hook ea cable at treat of the bait track to a strong part of the ear. Oe act hook oato the ladder or other weak parts. (3) Kalcase the winch tad let out 15 te 20 feat of cable te coeaect te the car. (4) Ksleaso the brakes ea the car. (5) Use the half track te pull the car into petit!oa. Put the half track ia four wheal drive. Do aet use the winch te pull the car. (6) Step pulling the car when it is la petition. (7) Set the brake on the car. (8) Reaevs the cable hook free the car aad triad up oa the viach drua. b. Pilling Tank Cars or Trucks 4\V*i :vp. Areelers are shipped ia lined vessels te protect the electrical pro perties free csntaai nation. Mott vessels are lined trlth aluaieua or a zinc-tin liaiag. * (1) Zaspection of car or truck for leading: (a) later each car or truek for inspection prior to leading. Zf necessary clean out the vessel. All material in the tank should bo raaovod. Damaged lining areas should be cleaned of rust parti el os. Isport damaged areas. (b) Use a tank anearing parade and a fire permit vbaa entariag a car. Observe safety rules for each permit. (c) A fellow worker oust bo on top of the ear holding the rope harness. Vssr the safety belt harness, an air mask, gas test the ear, and use a light whan entering a tank ear or truek. Ii I ADM C02513 72 WATER PCB-SD0000010802 OPERATING INSTRFCTZONS MOCL0RS 33. EETAILED INSTRUCTIONS ZZZ. b. Cl) (d) Fill cue tank inspection sheet. (2) Fut itwa on the ear after it ia clean. (3) Cheek to be aura there ia enough material in a storage tank to load a ear or truck as required. (As 8,000 gallon ear requires about 63*' of aeterial in #2, #3, and #4 storage tanks. (4) Circulate the aeterial in the storage tank for two (2) hours, sample the tank, and have the sample cheeked for loading by the laboratory. Zf aeterial la in specification proeeed with loading of the tank. (5) Install diaper eloth sock in the filter in the loading line and plaee a soek over the and of the loading line extension. (6) Attaeh extension to the loading line at the doek and plaee eoek and into the done of the car. (7) Connect ground ylre to the car. (8) Set valves in the loading line free the storage tenk to the loading dock. Do not open valve in line at the car. NOTE: Care should be taken to see that the correct valvea are opened so only the desired Aroclor enters the loading line. (9) Start pump at the storage tank. (10) * --5 >." (11) Open valve in drain line at the loading dock and allow one drum of Aroclor to flow through the line to flush out the loading line. Close valve in drain line end open valve in line to the can. Approximately 2| hours is required to load a car. * (12) Vben the car la leaded, stop the pump, and close valve to the loading line. Fill car up one to two feet into the done of the car. (13) Kamova loading line from car. (14) Taka samples from car and send to laboratory for final analysis. (Sae Schedule ASH 0C2514 73 WATER PCB-SD0000010803 m cimirs raaoiK AIOCLO&S 34. C. DETAILED IMSTRDCTIflliS ZZZ. b. (14) lAfflti TO.11 TAm ?m LIO'JID AEOCLOR LOTS MATERIAL TAM CARS TRUCKS er MtM 1221 2 x 1/2 Cellos 1232 1 s 1/2 Gallon 1242 3 x 1/2 Gallon ilil Fisc " 1243 2 x 1/2 Gallon 1234 3 s 1/2 Gallon & 1 x 5 fiat 1240 3 x 1/2 dalles 1262 2 x 1/2 dalles (15) Close and tlghtea lid es car. (16) Seal car asd record seal Busbar asd car suaber is Aroclor leg beek. c. filling Drums .v-*--* Liquid Arecler can be drumed frees Che storage tanks er the filtrate receiver. Solid Aroelsrs that are drumed are normally filled free the still receiver. Solid AroelersJL26S and_5460rwer. .--are '8eraa4iif 'ftk'#d^6i^%k*ggedT`,*AI!'sihff ^565'Is" a''Bendistilled produet vhleh Is druaaed free the bloving tanks. The folloving steps should be folloved when material Is te be drumeed:.- (1) Send a representative saaple (1/2 Cal. for Llguid Aroelers) . of the material to the laboratory for Inspaetiea. Zf the material la via storage tank it should be circulated for two (2) hours. Msterlal la a filtrate receiver or bloving teak should be agitated for 20 to 30 minutes. Zf msterlal Is la specification proceed with drumming. (2) Cheek the seales to be used. Set the scales for the weight specified for each drum (See Table ZV). (3) Start the pump. 74 ADH OC2515 WATER PCB-SD0000010804 Material 1221 1232 1242 1248 1254 1260 1262 1262 - 10Z toluene 1262 - 10% Xylene 1260 10% Toluene A13B3B 5442 2565 4465 Inerteen PPO fABLE S? AH.XIC FINISHED GOODS BRUM WEIGHTS Ptub Welahte tbe. - 3 Gtl, & S5 Cals. 30 or 520 50 or 550 55 or 00 55 or 00 0 or 00 0 or 00 0 or 00 0 or 00 0 or 00 0 or 00 5 or 75 50 or 450 500 50 or 500 5, 360, or 674 24*9 AO* CC;516 75 i WATER PCB-SD0000010805 0FEBA7XKG XUSTSOCIIONS ttKLK I 36 PgTAILIS IHST2UCTI0KS If. Fl&kiat Aroelers Aroclors 1266, 5460, aad 5060 are flakad ea a drua flakar mad baaiad la 100 lb. baSs. ; . fraearatlea for Flaklat (1) times hot Aroclor hsae on tbs pips liass, nlvss, aad flakar bold tank. Hast tbs Aroelor ay tea up to 250C. Obsarvs taoparaturs oa tbs aultl-point rseordar la tbs cblorlnator eeatrel room. (2) ?uaq> Aroclor to bs flaksd late tbs flakar bold taak. (3) Choek temperature of aatarlal la tbs hold tank, it should be 22QC. ala. Ta^eratura raeordad oa #3 still aultl-point rseordar. r b. Start-Op of Flakar Svf (1) Turn electrical beat la tbs flakar paa oa about 20 to 30 aiautes before atart-up. (2) Opoa valve la water lias feed to tbs flakar drua. (3) Start tbs flaksr drua. Start breaker at discharge of flakar. (4) Open valve et bottoa of the fleker bold taak. (5) Open valve at sight glees to start Aroclor feed late the flaker paa. Observe flew la sight glass. Adjust valve to maintile the level la the flakar drua about oeo laeb frea the top of the drua. (6) Observe operaeloa to be sure the drua Is pleklag up the aatarlal. (7) After the flakar baa run 15 to 20 aiautes notify the Chi if . Operator aatarlal Is la the hopper to be begged. CD Coatlaue to flake uatll the flakar hold teak Is os^ey. c. Shutdown of Fleker Cl) normally the fleker will be rua uatll the hold teak Is empty. - C2) Allow the drua to pick up materiel from the paa uatll It will so 1 eager coateet the bet liquid product. C3) Stop the fleker drua aad the breakera. 8 ) AC* 00251776 76 WATER PCB-SD0000010806 opimtzkg xhstmctxcns Mocims 40 DETAILED DESTRUCTION 2. lallinc Arm?lots Aroclor 1268 it Che wlj Aroeior vhieh it cold u * dllmd product. The material oist first ba flaked. '` a. Solset ths drias of material to be milled. b. Check the scales to bo used. Place a new drum undar tho dlllng machlae to collect the 1268. c. Crushed dry ice is used during milling to keep ths machine cool. This keeps the ixoclor 1268 from dogging up the machine. d. Start the dll cad auger. e. Pill the bucket vlth crushed 1268. f Bland dry lee vlth the 1268 and feed It Into the hopper over the dll. Use approximately five pounds of dry lee to each 100 pounds of Axoelor 1268 that Is dllod. . g. Pill ths drums to the specified weight (normally 200 lbs.). Stasell the drums with the name of the product, lot number, net weight of each drum, and the Initials of the person doing the work. h. Continue this operation until the required number of drums ere filled. Then step the dlllng machine end clean up the scales; the dlllng machine, and the dlllng room. 1. 411 drums filled are palletised and moved to the loading platform for transfer to the warehouse. !C ) < ACM 002516 "77 WATER PCB-SD0000010807 "7 J-- c-' > 1 Mmif i t <t TO --1 W. ft. Richard - Research Center April 1*, 1969 DISPOSAL AND INCINERATION 6? 'AROCLOH-------- --------------------- " i?. A. Olson J Bryant. ~ 1h H, Kountz -lW. A. Kuhn N. T. Johnson DOLSO smxh RKOUN VKUKNNJOHN P. Benigmis - PBSfl . To defend the Aroclo'r position, it seems that we should provide for disposal of and ineineration-fif^off-grade * fluid and %/ork %fith Vestinghouse and . on the disposal of the off-grade capacitors as well. I think %/e can foresee that control of the total material bal ance for Aroclor will be important for future operation. Ve should therefore help control the entire cycle of a capacitor. # . .* * At present - we are putting reclaim Aroclor into new Pydraul hydraulic fluid. Ve can't really satisfy pollution people with this explanation. This %/ill . . Just bring the focal point* to hydraulic fluids that ` much sooner. * .* Will you please look over the figure for capacitors,* l add any disposal Aroclor from transformers. Please convey our guesstimate to Bob Kountz for preliminary sizing of incinerator. ' * ' Capacitor Industry O At Present ** *' For Kyd Fluid - For Disposal 180.000 lbs/yr 1.62 Production *50 Drums 250,000 lbs *62 Prod 6,000 lbs Vestinghouse 216.000 lbs/yr 6.02 Production 20-*0 Drums 20,000 lbs 200.000 lbs/yr 6.02 Production Future For Disposal 2$ Prod 200,00C 2$ Prod 80,00( 2% Prod 60,00! Say 22*500,000 Say 12-250,000 Say 2% 500,00( (: lbs/yr B3 . 10 0'23*I Recycle and Destruction of^Off-Grade Capacitors for WATER PCB-SD0000010808 Vestinghouse prefer not to.bury capacitor - want to drain * ' ` Xrodor, salvage parts, destroy the rest. -6 '^Minir m-|iiilliF Monsanto asked to. see 0what we can do. Transformer Industry- Transformer Rebuilders - e Transformers Scrapped W. R. Richard ms ( t 100fJ35 84 25 WATER PCB-SD0000010809 I Minutes of Meeting of the CORPORATE DEVELOPMENT COMMITTEE April 28, tfgf E. J. lock. Chairman H. H. Bible J. L. Glllls E. J. PutzeI1 C. H. Sommer M. C. Throdahl J. N. Ehlers, Secretary 85 AOM 00o0*7 WATER PCB-SDOOOO010810 I c APPROPRIATION REQUESTS The President advised that he would recommend to the Board of Directors for approve 1 ' Organic 01vIs Ion Approprlation Request No. CEA*2080 for $ 1 , 100,000 for solid Aroclor expans Ion - Anniston86 86 <A OH 0060 WATER PCB-SD0000010811 7# v v * ? e 5f v?lE?TiN C? 7Hi tZKfiKA7i ZS'JSlZ?*f.VT November 17. IflS Present: . Miuri. " I. J. Sock, ihilrsia H. H. Bible J R. fek J. 1. Stills Pufiell C. H. Sommer J N. fhlers, tieniary i .Si 'V -s* - ORGANIC 01 VISION, LAW AND MEDICAL DEPARTMENTS -- REPORT ON P01V- . CHLORINATED BIPHENYLS ______________________________________________ ___ Present: Messrs. C * J. Smith, J. Meson, T. K. Smith, H. 5. Bergen, . 4. E. Springgate, R. I. Kelly, I. P. Wheeler, Rodney Nerrls, Jr. 0. W. Ml I ter, W. C. Robinson Monsanto's worldwide Aroctor busInessjimounts to 10* M I b s. / y r., 70ft used in functionel fluids end 34 M In plasticizers. This represents III M in seles. Products renge from monochiorobiphenyl 87 ADM 006027 WATER PCB-SD0000010812 ) 7B. to deeachlorobfphenyl, terphenyls, and ehlerlnatad terphenv Is. Product ion locations ara at Anniston, Alabama, Sauget. ili;A:e Newport, U.K. and Vokkaicht, Japan. . 0 ** nvlronmanta1 Asoacts - E. P. Wheeler The 5 nd i chlorinated biphenyls (Arcelor 1214 and (260) have been found at Halted locations In water. In birds and seme forms of aquatle 11 fa. Jteeent Indications are that such biphenyls may affeet reproduction of fowl 11fe and may be toxic to shrlap. These products are not toxle froa the acute standpoint to man or fish but there Is some evidence of ecological buildup In certain . water depes 1 ts. In fish and ultimately In bird Ufa. Aroclors 1248 and lower In number ara ballavad to be biodegradable but this has not been conclusively establtshed as yet. . ret'?.* * Plan ef Action - H. S. Bergen and J. C. Sprlnggate The avallebl11ty of alternate products to satisfy customer requirements was reviewed. Main problems are that no replacement product Is avalleblo for capacitors and replacement products for other uses poso a pellution problem. e In plasticiser uses, evidence Is not available as to whether Aroclors escape from end products, alther through leeching or by dIspersaI In burning. . *. * The recommended plan of action Is to establish a tailored program for each bus iness -group end each customer market s 1 tuation to assure that the loss of PCI's in the environment, If any. Is minimal.88 88 ADM 006026 WATER PCB-SD0000010813 3/ I. Aspcin: s Project Manager - responsible for she ovgrall inanageraeat of the Aroclor pollution problem. ft WOuJfl . assisted by a Task Force from members of each business group plus Medical Law, Engineering and Manufacturing. *2.. Notify all Aroclor customers of PCI problem. 3* Reduce and affectively control FC8 effluents from plants. . Educate customers on need to reduce and affectively control PCB effluents at their plants. 5. Develop and Implement new packaging systems for Aroclor 1214/1213. . I. Introduce to market, roplacomont products for Aroclor 1254/1260. 7. Continue and oxpand biodegradation test program with Aroclor series, particularly 1242, 1241 and 1254. ` . 0 I. Continue toxicological tost program. S Accelerate present analytical test program. ' . . 10. Determine feas ibiIity and cost of eliminating 5/6 CI_ In Aroelers 1242 and 1241. 2 11. Study incinoratlon products. * 12. Develop business plan to offer: - Monsanto Fluid Reclamation and Recovery.with Envtre Chem. (Reelamation already under*way at Findett.) Cos t of this program Is ast.lmated atyp!|itpJ-y-l*i'40ftK^SA=R?S---an*',w . Conclusions: In 1ight of the recent and developing evidence of a possible threat to certain species of bird and aquatic life, we should plan to discontinue the manufacture* of Aroelers 1254 and 1260.* The 0(vision Is Instructed to develop a program to discontinue these products and report this to the Committee. i The status of Aroclor 1242 should continue to be tested to determine whether 11 contributes to this problem. Other products which might be Involved shouId also be examined. (Excerpt to Messrs. H. L. Mlnckier, Rodney Harris, Jr., R. E. Kelly, T. K. Smith.) AOM 006049 69 WATER PCB-SD0000010814 St Louis March 30, 1970 H. S. Bergen - HSIRG H. L. Minckler - HMIKC P. S. Park - PPARK J. E. Sprlnggate - JSPR RETYPED FOR LEGIBILITY W. B. Papageorge WPAFA We have been in communication with a Dr. Rill of the Ohio State Board of Health. He has found PCB, particularly Aroclor 1251*, in samples of milk from at least three herds in Ohio. He has traced this contamination back to silage from three different silos. Dr. Hill reported concentrations of 0.2 ppm of PCB in the silage in the oenter of the silo and up to 20 ppm in the material next to the walls. He also stated that concentrations in the milk were between 0.1 ppm and 0.6 ppm and that some of the milk had been destroyed. The silos are concrete silos whose interior surfaces were painted in 1967 using a formulation that contained 125^. I don't know if there was any other Aroclor in the formulation nor do we know the coating manufacturer; although, this could be found out if important. The presence of PCB in the silage came from flaking off of the material and possibly from leaching out during the silage storage. At present they will have to destroy about 150 tons of silage which is valued at about $30 per ton. As a rough guess, they consider there may be 50 other silos involved in Ohio looking into the fat contamination of the cows themselves. All in all, this could be quite a serious problem, having legal and publicity overtones. This brings us to a very serious point. When are we going to tell our customers not to use any Aroclor in any paint formulation that contacts food, feed, or water for animals or . humans? I think it is very important that this be done. It may be that some of the customers will assure themselves on the basis of non-extractability that a particular formulation might be safe but I think we should make a blanket recommendation against these uses. . . .. REK/ln90 R. Emmet Kelly, M. D. 90 ' WATER PCB-SD0000010815 . v-..^r. nor 6'.ye .`fcnow.jco*Ih*g>;anof*eturer? >2t>.*c*fcch*Ms-rfcot "s?vfr'r * '.''r : ffoouuin:d :'ut*`i,rin^rtint:.;''nlTjse prfeseacs".ef .SC3 ia"the~ si'ie .^^5^S8.e.s ys J, n s t ....................................................... WATER PCB-SD0000010816 \ > KJNteTII OF MEETING OF THE CORPORATE MANAG. EMENT r*`-*-41-_ _ _4_4 . April 20. 1370 * Presents . . .' .* . ' . Messrs. ' . ! J Bock, Cfci< rein . M. M. Bible Jo ft. Isk ' ' J. i.illlf* ' ` . I. J* Fulfil * C. H fomaer U. C. Throdahl Jo N Ihlofi, lecfelify . Organic Pivision - Report on RCB Status - Hours. H. L. Minck J.'ftoson, C J. Smith, U. I. fapageerge, H. I. Bergen, J. I. Springgate, X. I. Kelly, I. F. Wheeler. Total Aroelor business roprosonts $2lM salts returning $1 On gross prof Ic on IIJM gross investment. - Sales of non-degradable Arcelor, (1210, HS4_and post Ibl . 1248 Isotopes], account for )Ih sales - $l|n in functie . fluids and $|H plasticisers. e Aroelor 1221 Is degradable end there Is no evidence that sol id Aroclors pose e threat to the environment. Division has maintained an aggressive program of customer . education, end cooperative efforts with researeh organisation goverhaenta1 agencies end wildfire groups to identify the see of the problem, eliminate discharges, improve analytica1 methods and conduct toxicity studies 92 ADM 006031 WATER PCB-SD0000010817 113 . I Cone*rned agencies and groups ora appreeiative our afford. ' 7 DA Indleatad It mii contemplating a residue jcv@l of 6.| ppm In mllk and 5.0 ppm In food. Publlelty about PCI's has boon 11mltad to a faw artiel as In scientific publications and newspapers until Congressman iyan's press conference Implicating Monsanto and the products Program has been establIshed to curtail discharges from our plants and levels have already been reduced sIgnifIcantly Ve are targetted to reach 50 parts per bi11 Ion by year end with an ultimate target of 10 parts per bill Ion. Sales are being terminated to a number of Industrial users where there are Inadequate posslbl1Itles of control, for such uses as pesticide extenders, medicinal, denta1 and cosmetic, and cutting ells. In addition, we are terminating all sales through distributors to ensure better control of end uses. Action Is already Ir^ hand to replace $flH of sales for Fluids applI eat ions and 13? of sa1 as for Plasticizer appl leat tons by alternatIve produets. Target for completion Is end-1570. - SubstItute products are being developed to replace the nen-degradab)a Aroclors. Sales wi11 be centInued for transformers, capacitors and heat transfer uses which are closed systems or sea 1ed units and whieh permit reclamation or ether control of material. - Transformers are dependent upon Aroclors for reliable eperation and no substitute product is available. Corye 1 us ions : The Committee felt that while the division had taken major steps to resolve this problem, more affirmative act Sen must be .taken. A replacement product should9 be developed on a crash basis for the NCR applIcation. It was decided that the affIrmative action being taken should be communicated to concerned governmental ageneles together with the reasons for continuing sales to the * limited uses whieh would involve major public hardships If Immediately diseontinued. Messrs. Eek, Outsell and 0111 is are to recommend actions ^o demonstrate the affirmative program being taken. .The division is to report Its specific plans to the Committee by June .1. . , (Excerpt to Messrs. Minck1er, Smith, Kelly and Harris.}93 93 - I AOM 006032 WATER PCB-SD0000010818 fj.tienat ficetriest Manufacturers Asseclatlen II i last 44tn Street New York. N.Y. 10017 212-682*1500 mare H. Salk @ViseeePnreMt'SiueMa Mtra&arafiig Sarvteea August 2, 1971 TO ALL REPRESENTATIVES OF MEMBER COMPANIES IN THE TRANSFORMER SECTION AND CAPACITOR SECTION Subject: H.R. 10085 - A Bill to Prohibit PCB . Gentlemen: Congressman' Ryan has introduced H.R. 10085, a bill to prohibit the introduction or delivery for introduction into commerce of the chemical compound known as polychlorinated biphenyl. A copy of the bill, as well as Congressman Ryan's statement in the Congressional Record of July 26th, is enclosed for your information. . 9* You will recall that on May 19th, Congressman Ryan introduced H.R. 8576, which would have banned PCB, except for use in certain applications such as the dielectric fluid in capacitors and the coolant in transformers. Apparently, Congressman Ryan now feels that PCB's are even a more serious threat than he thought at that time and for this reason is seeking a total ban. ' We will keep you posted on developments. In the interim, we will still appreciate receiving comments from those of you who have not yet.expressed their views on this matter. Sincerely< SHF mg . A* Ends. cc: Committee on Use and Disposal of Askarel, Power Equipment Division Board of Directors Joseph P. Miller - President, NEMA _ A. M, Salazar - Secretary. 8-TR, AO* C. A. Parris Secretary, 8-CP . H.P. Michener - Technical Director and Manager Engineering and Safety Regulations Dept, j. j. Kark - Engineering i Safety Regulations Dept. 007212 94 WATER PCB-SD0000010819 c H. SR. 10085Jr Session ' IN THE HOUSE OF REPRESENTATIVES . Jolt SR, WT1 Mr. &TAn introdnred the following bill: which eras referred to tlie Com mittee on interKtaU and Foruigrt Commerce A BILL * i'i To prohibit the introduction or delivery for introduction .into commerce of the chemical compound known m polychlo rinated binhenvl. ^sbsbb!SB^1.... . a* -.* .>' 2 fives o/ the United Stales of America in Congress assembled, 8 That for the purposes of this Act-- ' 4 (I) Th temr #*omjBereew means commerce between ft any State and to or through any place outside thereof; or 6 within any territory or possession of the United States or the 7 District nf Coluinhiu; or from a foreign Viaintiy fit any tnie. i ft) The term '`Stiite*' mums eacii of the several Stnle% c 9 the District nf C'nluuiVm, the Commonwealth of Pncrlo Rico. CC1213 95 WATER PCB-SD0000010820 c 1 the Virgin Inlands, American Samoa, Guatn, (he Canal Zone, 2 and the Trust Territory of (he Pari/ic Islands. 3 (:i) The term "gwirHon** nicanx any private person or 4 entity, any officer, department, agency, or instrumentality of i any State or local unit of government, and any officer, depart xnent, agency, or instrumentality of die Federal Government. 7 Sec. 2. It diall he snlawfnl for any person to intro- 8 duce or deliver for introduction into commerce any of the chemical compound known ns polychlorinated biphenyl. 10 Sec. 8. (a) Any person who knowingly violates aeo- tion 2 of this Act shall he fined not more than $5,000 or c 12 he imprisoned not more than one hundred and eighty days, 13 or both. * . , 1* ;, (h) Whenever any corporation knowingly violates sec- 1 tion 2 of this Ad, such corporation, and any individual 1 . director, officer, or agent of such corporation who know ingly or willfully authorized, ordered, or performed any of 1 the acts or practices constituting such violation shall be fined . not more than $5,000 or imprisoned not more than one hundred and eighty days, or both. .' Sec. 4.`The provisions of this Act shall first take effect thirty days after the date of its enactment. A0H 00721*96 96 WATER PCB-SD0000010821 H713S CONGRESSIONAL RECORD--HOUSE July 26, 1971 Me g&tbmi at Andrew ASs Feme f V*t-r '. * \pn| iiffmacra IB prime*! pbuamphy . r^*: ptimvaeutiy divide ut pidpies a* uuyrena. / What is moit important terAt United tiiA u that thoee toirertnats in politi es! pA'stophy should sot M turd like * vice totnull the mdrpiruPnt. natieaal- teuc ce4.se wiueh the g&n.amaw have chrarn for themselves. This will net ee* . cur so l.if bj Asifiiin reeegmzes that Independence asd acUrcly eseouraiet it. President sNtxon recegnized that independence, ana* new hot urced the ensrtu to stt/t foster it A* with the pmg-peng *..iroa.nent is China, the hall u new in cm court live in Congress ere to fulfii^ewh responsibility ta the determinauth olW.uonzl policy. then hearings should bevitid en our Eastern European frafie poilckat an early daU. The tad bJti I jun\ntreduelng today claosusl.d p/sdvioe the feeuk\fer those hear- The 'general bill I today tntrodueed would permit the President to extend MTS to any country wti)\wWeh the Untied States has diplemauV relatiene and which It a member ef OA1 eifcl Agreement on Tarifit and uade jr the President determines sueh\ An theRational interest. ^^PCS'5--EVTRONMZSfl'Ah POISON The SPEAKER. Under a previous order of the House, the gentleman from New York (Mr. Utah) Is recognized for 10 minutes. Mr. RYAN. Mr. Speaker, en Friday. July 23, the US. Department of Agneul* ture revealed that a aigrtiflezat propor tion ef ehtekens raised In 12 States have been contaminated with an extremely dangerous chemical--polychlorinated bi phenyl--PCS. . This occurrence tragically illustrates the failure ef the Federal Government to take preventive action acalnst the tin.controlled use ef this deadly chemical. During the past 2 yean X have attempted to get the appropriate Pederal aieneles to take the nectuin protective actions that would have forestalled such an oc currence and would have guaranteed the health end safety of the public. But in an almost unprecedented display of dis PelyehJerin&ted Mphenyls may be taken into to body by direst action @pen tot fen of the importation, mar.t^aeture. and ale of all products eeamrmag PCB's ekia m es a vapar through toe respira tory tract. The eCect en too alan is hloracne: toe early symptens e* which ere pimples end dark pigmentation: tatar. mere serious eruptions. Persons who have been continuously exposed to PCB's may suSer nausea, eemitiag. less ef weight, tadema end abdominal pain, increased respiration, lowered bleed esU count, and inhibitiea ef the eartwhydret met&beUam. Mere etrtous effects ere these en the kidney* The principle ef fect, however, is en too Hear--possibly leading ta atrophy, followed by death.. PCB's are very persistent in toe en with the peanbk exception ef wrun rimed system apnUetticss. Z urged that he require that any proaue: eer.t&mmg PCB's not tne-uded in such a baa be labeled with s wanting as to their detri mental environmental effects I requested that he ebt&m from Monsanto these pro duction and sale figures accessary to de'etvuuw the extent ef possible PBC eeataminatlen--data which Monsanto has refused to provide me. And z urged that the &mronmental Protection Agency ooordiuate all appropriate gov. e&AmSmAfefiLntal agendas in dealing with tots vironment thus saakiaj them a long term threat. They are not soluble in water and resist feieiogveal brtakduwa. . Zb replying to me. &A ignored aS four ef my requests and is so way responded to them. In toe pUi, PCB's have been said by the Monsanto Co. for use to pbstielser applications; ta elated system applica In short eseeptifer tot action ef toe Department of Agr-ettoura in oamung PCS'e in pesaddu. toe Federal Govern tions. such coolants to Xrsasfemssro; as hydraulic Sudds; and as an extender in pesticides. . . ment bet not taken any ef too accessary steps which Z have requested ever toe past 2 yearn to eombaPtius eery aeneus When I first brought toe potential dangers ef PCB's to toe attention of the appropriate Pederal ageneia to April 1270,1 requested that certain speelfie ac tions be taken to pretest our health had environment from the hazards ef PCB's. Z urged the Secretary of Agriculture to baa the use ef polychlorinated biphenyls to pestieides. The Department of Agri culture agmd to discontinue toe use ef PCB's in pestteldes end to eaaeel redstratioas for pesticides containing PCB's. Z urged the Pood aad Drug Adatomtratlea to aet food tolerance levels for PCB's. to require the labeling ef all prod ucts containing PCB's. and to determine whether this chemical should be banned completely. In replying to me, the FDA advised me that ft was undenakint a survey to determine the extent ef food contamination from PCB's--the results environmental aad health hazard. The results ef this Government mac- ties are now tragically apparent. Large amounts ef poultry and hots la a 12 State ares may sow be eontaauaated with tins toxic chemical. For nearly 9 months PCB's have been leaking into fish meal processed at the feat Coast Terminal. Zne,, plant in WUamgten. N.C. The meal has born sold to fit poultry producers ta Virginia. Dela ware, North Carolina. South CaroUna. Ooorgia, Alabama. Florida. Zndiina, Tennessee, Kentucky. Arkansas, aad Mississippi. According to the Departmeit of Agri culture, le.oco tons of fish meal had been produced at the WUmtogtcn pleat be tween April 90 and July IP--when the plant was closed down. ef which 2 still have net received. FDA This contamination would yet be tm- refused to set food tolerance levels aad noticed if u were not for the fact that a to require labeling. commercial poultry processor beeame Z urged the Secretary ef the Interior to alarmed at the tow rate of hatching ef act to protect fish aad wildlife from this eggs ta his broiler breeding ehiekens. hazard. He replied that invest*gatiens Z ean toe ao way Dm eU toe poultry were bring carried out by various egen- and hogs eubjoettd to this chemical can eies of the Federal Government aad the sow bo traced. The potcaual resuits multi of these studies would be funnaled oould be dlsasterwB. to toe etaS ef toe Council cm nviresmental Quality. And this ts aot the sole InstaBca ef widespread PCS contaaunatiea la the regard for the public health and welfare, S urged tbs Commission Product Safety feedebem. that administrative action has not boon to determine the nature aad extent ef la December 1970. the Campbell Soup forthcoming. . - toe threat to our environment The Com- Co. discovered that fat samples takes Therefore, S am today iatroduetot leg suasion replied that it was not possible from slaughtered ehiekens contained ft islation to totally ban the distribution for them to conduct an indepth investi high quaauty of PCB residue. Upon be ef PCB's in Interstate commerce, thus gation af toe hazards ef PCB's at that ing notified ef tins finding aad recognis insuring that our health aad environ ment aie safeguanled from the hazards Mme. Aad S urged the Ceunefi es &vires- ing the potential danger of this occur- note, the New York State Deportment ef ef tls chemical. mental Quality to coordinate toe aSoru Agriculture and Markets immediately snufactured In the United States solely by the Monsanto Co.. eolychio- Hwsted to our htei-,.i.tther.evnlsd are to a senouv threat on? thvitofimtBt. ef aU appropriate Government ageietm, m that the public aught feew the sources and toe eeriousnesa ef toe PCB danger, and that It take stops to eUml- stopped toe movement ef all poultry from the area in SuUivaa County. N.Y where the chickens had been raised. The New York State Department ef Juke"-Birr--tnetr chemical eousla-- PCB's and their residue art extremely toxic to antmal life, eause birds to lay sets with shells toe thin to protect the embryos they enclose, and have ft deleterious effect en the reproductive aate this hazard as eeon as possible. The Council advised me that It was working with ether Federal agenda to determine wbat ooune ef action was available to the Federal Government, Earlier this year Z renewed by eal! for Agriculture and Markets then began a full-scale investigation into the extent ef possible PCB contamination in poul try. Their laboratory confirmed the findtngs made by Campbell Soup Co of high levels of PCB's. and the U S. Department capacity ef animala. administrative action by requesting toe of Agriculture estabhsned a cc:;atiXfi3 But by far the mon frightening hatard Administrator ef the Brnrenmehtel Is the effect ef PCB's en human bernga.97Pretocuea Agwmy to place aa tmmsdieto restraint en the movement o- ah poul try for slaughter la Sullivan, miter, sad 97 AUM 007215 WATER PCB-SD0000010822 July SC, 1971 CONGRESSIONAL RECORD--HOUSE 7137 Orange Countia. N.T,ttnlil It tu found I am catUnv for ggaptatemi tetriap la fee sale through a dpcciel tcreenlng lest eperaUw*. A* e result of their invrotumUeue and Into this matter. Further, Z am ftltefaitas my taS lor Die Drpwrunsht ef Agnu.ture. the Food In r'lRjiinritun with UHD.V the Hew York atus* UeiHtnmtm of Asr.niKurs and and Drug Adsur..tra4<wi. and rn virmmmtsi Proteetten Apney u com- fetuiteu ordered that 140.(90 FCB-cun* t menet tuuneouiteiy a full end ethuus- temtoaud chicken* be feurtfr. under elm tlve Inrcstlgation la to Uie meat of upc.-vulon to moke abeoieiciy curt that FD8 eentasunauen. And Z am e&Uag pubis, bas bats teas and widely used ia the VA. as a aeivsat la thr productiaa ef paiat pMctdet piastioi aaa m.j aas suck items so "mSMJrs' narcos papei. m wtu as ta htstuig and eeuilng dushfasty. Hmsmva now recemmeads its tu fes bmned to heat tdebeegt systems aa 88A tpekesmaa aaid. l*Ck eecttauaaiiea ef tbs uwurt ef peuitey presumed m Jew T Stale tost year re suited la tbs ettsure aad deesruettsa ef mors they would not men the a*kctpl*ee. lor an Issmediau admtoistrauvt ban on The Camnhell Soup Cj,, USDA. and the Kew York Sum Dcpaitmtnt of Agriculture and Mcrkcatol took prompt the manufacture, aUfCS's. The problem ef ahlpatm. and Bis KS'i Is indicative ef ef cuon to deal with this acrioui problem, a mueh larger problem^that os the al thas 109.0*0 birds. Tbs satires ef ee&temu neiiea la tbxt case has met esea piapoiatte AUheuih PCS bas beta la mst weridwies foacs befers fferld War 8. n was eat ur.tit 1066 that hs presence Is eefi. water aad esima) tissues escame baesm. and tliat u reoccuring. Koveter. the po most tmmsmsted laflus ef harmful r'SavMenraset'' Magtsiat. which im tential damate which couid tow re chemleals into the marketptoee. A sys beeught tr.o PCS problem te astisaai asten. sulted if thu incident had not ban diecovered In time cannot fee ignored- And I suit: stress that this ts sc* as toal&ted example. Sr. January 2979. s&sigtos of miSc eel- leeied by tns bute cf C..-0 Sc.isrtmeat ef Agnsulture rrvtaled thueua cf a prodact closely resembling DDT sad DDD. On February 28. s dairyman. Ocerge Sehwarrwaldrr. eras lasuod a sotlee fey the division of food, dairies, aad drugs to d'.seoachut the sale of sulk until each time as the residue found in his Bilk vu below the actionable level. Os Feb ruary 27. another dahrymar.. FrankUa Humphrey, received a timiiar notice. Subsequent samples from Individual eovs and the bulk tank on these farms submitted to agriculture laboratories and the pesticide laboratory at Ohio tem must be established to insure the Ves. seperted that eecesatmtieas ef pen safety of a ehanuesJ before u tsa be add aad then ealy for spgeiSs uses. - ware overlooked la cbesvsal analyses because is U CO tifihr te ?. S`ir in the mebndse, entrains pw Abie Bust hs eoau to posse; tto pubHe yea *at.u% ehah^sd tasters. We know the han^ds eS K&x. We tesw Sena &hea. Iks macs&xsb eetoatlflc di. geese?. yef*;y sdspu-sd A geveraatantw sM?sess &-. fo&e meet are cot ea tbs toMkst. *2 xttoArct PSA eeataB>naus8 may bs ^utoe wtSfopma.0 hj s&to m a telephone what can aad bus* be dsns to eombst gatemeu Sms, st. S0isn. bfo. - these hasarda Aad we must naSsrhuse nv tr teid te ektc.( bust frem tbs those tenons now. Seuth mere thas woo mexsas ago. but At this point Z delude hi the Eseees two articles by Saak Surchard which appeared la the Westogvea P&A ea July 34 and July 25 ruoecnrcly, aad a haveat fet bees able ts week tt dews.** hs easd. 29c. Peeepb Stoic ef TCSEA evd the ageacy tad *bcsa abcefobg etotkeas ta tbs South durtag tbu ported cad kavr rouad aetbtag July 24 Kew York Times story by Wil e lead us ta etupect eaatamta&uea ef mar- liam Blair. . keud birds." The artieles feBevr: eeitatide epinjen ea *bt dsagen prseeatod (Prom tbs vreshfagtab Pest, Salt 84. 2871] Ckskkm. Poewe s eweaews Cawvam- asw Pews Pavwasr u-sran Aaaa by PCS Is dmdsd. COA roaearebsro. a epekssmaa sold, fwgard tbs eutcry evef PC8 (cud 6tn`| as sxaggerafod. Aa P8A spsksemaa mIC tbs ageacy forbids State University revealed that the resi (Sy Saak 8orchard) use ef PCS la feed ar ta tbs prwductiea ef due was sot DDT but PCS't. The Ohio A `Wgulfieaat prepsmea* ef tbs ebleksaa gaed eeatalasrs. "2to effsc-s ars aot teewa State Department of Agriculture found the contaminating substance to be AROCXOR 1254. manufactured by the Mon santo Co. Apparently, the dvrysea'a alios were Uncd with a product called Cumar which included AROCIOR In Its raised ta 13 states bars hsaa eoRtamtsated mb a BBT-Ilks eeapsuad. ths Ospartmoat ef Agriculture aaaeuaeed pastarosy. I'SSA sajii It bas "ue evideecs* thst any ef tbs birds bass reoebed consumers ead bat takta stays ts make aura sens to. Tbs eoBtaauaaai Is poj*-ebJeriaate til ta Uotfol," be 4fod. "but te tu lib aa adtUteraat aad tmpemuulbls." 8r. Pebert (Useteree^H. ef the Caivmity ef CaUferaia at Serbo^r. dUmversd while detag ressarcb an tbs browa pelieaa that PCS was oecangerlng tbs spoeiss. dioee tbsn hs has reported Sadlag PCS eesldiua conuat. The PCB's were tiien absorbed pybsayis. taowu as PCS. Vet aeariy three widespread. , by the silage which in turn raj fed to the milk cows, resulting la FC3-eoatasi* saeatbs it bad bees leafcmg tats dab eaJ pracctaad at the East Coast Ttrsueal, lasK (Fern the vrasbiagtea Pest. July 85,10711 hated milk. ibii la WUsuafiea. tt.e. The ewal baa haw Severn Te Saw VST-Lms CHBstcac Although Z have been assured by the Ohio State Department of Agriculture that this problem is now under control, the harm that might have resulted Is bvlous. In view of the lack of administrative action even after these Incidents were brought to the attention of Federal agen b-ta eeld to 84 poultry producers ta Ttr-. (Sy Saak Surthard) glut, Pslarars. Nertb CarolLas. Seuth CareUna. Osorgia. AJabama, Plertda, Indiana, Taoatssee. SsatweXy, Orkansaa ead bHasiaalppL PCS. USe 80?. ts e persutaat ^tapeoae that aceuisulaftB ta ratty tissuw aad u arjd A Sew Terk eeagtssvataa said yesurday bs will latroduee a bUl te baa all use ef a 88Tlike compeund that bas eeetnmiiiatsd bumsa aad wiidiife feed ebatas la tbs E. aad areuad tbs world. Tbs aaseunesmeat by Ssp. wuiiam Pitts So esusa lew feruiity aad forth defects la Xyaa (8. R.T.) cams after It was revealed eaimsjt. Its effects ea humans are imeartaia. Friday that high levels ef pelyebJenaatod cies and In light of the obvious threat posed by PCR-eentamuu.uon la mUk and poultry, on May 28. Z introduced legislation tHJV 8576) to ban the dis tribution of polychlorinated biphenyl In Interstate commerce. However, this but C80A bat set the maumum aeceptablt terai e( PCS la marks led stab at 8 pans per BUI lee. the tame as fer 88?. Tests of peuirry la markets la ths fieetb sad Zest dunag tbs past %.k bars found swat that bare as much as 6 pp m. or PCS, eeeerfltng to Gfr. PTed J. PuUenea ef PS2U blpbsayls (PCS) bas bsea found la flih msai fed te pouluy la 18 ustn. laeiudiag Virgtaia bad Bsiawars.evsr tae pest tares months. A Depanmsat ef Agriculture epokesraen estd ysturdsy that dab xital from tbs same WUmiar-ea. H.C., elaut bad foes beep fed ts u uakbavu buaihsr ef begv Tbs depart- legislation gave the Secretary ef Health. eaiununsr and markstlag sanies. mini aaid it stoss ret believe at? ef tbs Education. and tVelfare. the authority "la mr eplrusa, there would be m breUera poultry er perk Involved bas reeched eea- ts exempt from this ban PCS's for use la certain elosed-svstem applications: namely, as the dielectric fluid In capaci tors, the eoolant in transformers, er as a Are resistant In heat transfer media, ta stores above tbs telseaaee.aPuJlerten cvC Tbs ageBey doss aot regularly test fer PCS. la poultry act yet foeugbtered. tfsOA Pouad PCS eaacentfwueas as high as Si yya.. end one poultry predutsf teptriod levels as high as 46 p pa. eumer anarfeeu end te sevtag te peeveat them frem beiag aUd. pttb meal procured by East Ceast Tecmt- bai. gnen er wumlagten. was contaminated grem about Apru ueiu tbs plant was ordered eleard Prtday. Tbs PCS. bsisg uaed as the provided that he found auch uses toouid Tbs eentaauaattaa et fish meat Is ebt beat emnsfer medium te eteruuiag au. net adversely affect the pufehe health aad WUmingten ptaat was eauiad by leokaee leaked ttsutoueed lato the mtai. welfare. ef PCS bsieg used as tbs heat eschaage Tbs euntammatlea was aot dtoaevered be It Is new apparent, however, that Pd a *e a serious threat even in these dosed bvstem applications, as evidenced by Rhe current Incident of poultry feed conRsminaUoa. Therefore. Z am today in troducing legislation to totni.'y ban the Bteehaalsm in e stenitsiag macbins. Ths sccidtnui Isaktgs, which may have bsgua around April so. was brought ta tbs attention ef the rood and Drug Admtautra. 41oa last week by tbs Mootante Carp., oole VS producer ef PCS compounds. YSA ta Ours aimed C8SA ea July 16. any geverumsat egsnry. It came te Sight when c customer ef the Monsanto Cerp. the eels OS. producer ef PCS sesnpifonsd shat his eblekens were toeieg ssttesd end tbeir eggs were ef low tenuity. bfeesante traced she problem te the aLiekse feed aad tns feed to tee tvumingles Interstate diatnbutiton ef FCBi. And PCS. waieb stands fer a eeasa relaied m< ptaat, then eetidsd lbs OS. Pees eaa drug AO* 007216 98 WATER PCB-SD0000010823 "e B. BV23S CONGRESSIONAL RECORD--HOUSE July 2Ct 12) AdmUfistraUea. whlnfe soused BtBA. whlefe mmenama regaiktlcfe a; pes um %m& VUm entiui *r u. --......-- #fc.... week later made tfee &m pu6U aaasaaee* ternteg,tm mml >> tSn Tmu v* n*. m * wH f to flad* ,8,< ssees ____ van. who** effU- baa baas tseceUgaUng ill* (*.) prefelsai fer tew gear*. tM& the mas "gnphieaily ritutrstti tb* grass segleet el She federal govuuseiit t Wi preveauvt ectioii against ui* uitcortruies us* el deadly ebtmtests by Aeirricaa industry." M* laid bis biii wuuifl fee introduced Kn it; It Ml rcplve feu UR MTI. UiMyctl Mey te. wlueh would permit tfee Recretery r Hriklui. Education aae Welfare te iunfi aerutn um* ef PCR* Ires um bee. "The latest mm eenetams us tfesre Is *e fief* *y fer tLe ttuS te fes ttsed,'' eaM Ayes fete* erne Edwards. ear SMrrm ff * RTM fee te 6* added u feud {tKrJura. A tauf ernes otfeer ageusia mf tfesr am mama&pmg nlmosgsriyueetanasleuefoaeearaplaayt a.imrsdufa'ogarucedteafttseltatmadv-issneaydimuusaosftataPri'yr'ey,oamhgsatmmus^mmmaateatagtsgteetIois*r IUtftesMtefeeetueeestmtcoooatmodtiaerflpisiBassjaoySauuadrtsaadeaeetlsc.s.atrioleyestatfeMeedla a egtaesnnJ dtMuBctsecedoeaemtvtayeiraeittowtegopsuioyepeeteeato&dn,iImMdshsoonpMws.pefadnattto.baaibsteortosee.tdseo(oeand** lareemeat et tfee tteer feat euCered so stfeer MsejoMeet ItBen*Ss or feeUaLAsVt Atrletdiuf* SNp^tBcat Motmmait said that about if Ouj tons cl flea steal bed feoea Preduced a*, the T.'Usj.nt*u plant fee* ***** AJW nn duly te. irsrmai'.y. esa H<u!ynMbf '6 mBtpe A epokesaaa fer epreetatattee iruuam S*. Ryaa. biaerni bI Masaattan. said taat Mr. Ryaa feaa teen tmng lor e year to get tfee afeipmeat el PCil prohibited la later* state commerce. Be introduced Irnaiattoa to tfeat eSeet but It bss lauyuiebed *a the Route internet* Commerce Committee, tfee enekes* Man acid. ^ 8* mid Mr. Ryaa bed framed or >Vd*. spread" feaiaB-.!aa'iea si fecnstuCe psmeu* A spekeemaa for the Maurante Serf laid ytttiroty the me a.* FCRa it "absolutely it- stem tfee tampsay epsbssstss said. Sags skewed so tU- eS-ecta. .fee ta.f.i. tariy poultry, feeler* tfee h`e verb ct. Me Rad looked late tfee toti.e etfeets el ki oi* eaatur ler fe*'.7 etecinc&i equipment end Rep. Ryak said fee ns adepts M feasts Ser reading a study fey Caufernis secatiets lUi tU* eompjr.y has tUn "very suiageat sae&uret" te tei.irsi tu* el Use cempetsaa. Since (eat Atijutt. (it said Uoaier.te fees vithdrewa Pest Ires uu ler eor purpose ether thee m the taruiattcg fluid In else* tneel cepeciters. as e sedan: in trenafermrrs rut Bre-retituui Ingredient la Industrial fetettng end reeling syttrmi. The efeiberge also tppitet te the United Xlsgdoei. la wbtcb Meni&nta sice fees a monopoly IB PCSt or mere than 0 yesre feeler* tfee Man* Mats action. TCBj, which ere a group of a dortn chlorinated feydrocorboat. bad been trfitred by tfee eeapaay tm it* ova pfbfiwsta. Sdaarfls. fits aids. ead *%fe AfllettloM ta Rave ta mtreduce a every Us asutfear family et fiaaycreua eempeuafi. turas up is pur bodies aad tferovufecttt toe tanreasrst, but. given tae topeatsd febum e.* geveia* Meat ageaeics ta act, t&ace* SfetMig ** m eaa do.*1 . (e tfes Rev Verb Tmm. iuSt M. mi| Barm Svatss Pcsas Petsea fm Bern Csncts* Bwa--Ssssefi air in IS Srsm Arts Pen Is Pb*k Tssnwa en tk# kbea.es! acf za&a$ mst u vas &et aelualiU a tawr ana csuid ee ukea tats fefet feuara r,tws by pkysies; eeatect. tfee fipekssaiaa satci. PCS fees a vide rasge ef tadusiml ms. tmdud.Bg psutts aad rstian aas ta the maau* Isettur o.' feb^s isi etaer astenais. ta Cfee North CshMias cbm: tfee suastsase vss Med ta a beat esefeasger te east liquid, ta tfee Mew Tete cMcfcea cbm, the P was Relieved re ha** beta ta paint tttt flaked eff a ateragt bin er te have beea absorbed by tfee feed Bern tfee palat. , aridity used aa plMtieiseie (aortaerrs I la <By WUUaa M, Slfelr) paints. seeJantt. adhtaieee tail other aurlae* oaatingi. with nurrcilaaeous aapltcauen* la thermostou. leed. pharmaceuticals aad fey* draulic fluids, achordlng te the April, lift, flee Scientist and Science Journal." A epoWesmas ler tfee National Paint, Vara* Ish * Lacquer Association, lue- said yetter* day that PCSt ''never have beea `widely uaed' la pemu. They had oeiiali limited indue* trial applieatieb* and nr* do longer uaed. Aay paint buytr aay be oasurvd tfee products ooatair, ao PCBs." WsatcnrctBirr--Tfet Bepartmmt ef Agrt* culture aaeeuaeed tefiay a aesrea la ta bisuse fer fereutr cfeicseas aad ofeiekea feed tfeat may be costamiaated by ea mdustrial efeea* teal. ' The tea* tubetaace Is of tfee efeemlcR ftaa* fly et poiyehlonacted btpheaye*. Spokesmen for the Agriculture Department aad the Peed aad Drug Adnuaittrattoa earn tbat tfee PCS. as the ebmietj u kaeva. bad leaked from feeeuag taacktaery used ta iswuru Safe meal at tfee feast Coast Terminal. Xac., WU* Ruagtea. M.C. Ths meal van sold fer tsse as Tfee SPEAKER, finder a previous er* pr et the House, ths gemlfmaB t/bm (Ur. Hon Is recognroiseedd,for i nutas. ROY addressed the h/m. 81s fomr.rks tsssran* eerttlRi eampp&erfaershrereayfter m the fit* THE PEOPLE OF VTO HELP PtHm>OoTCWwCA--As/JhhfAlS'SSM 40? The effects et PCBs la aniamis are Mmllar ea Ingredient la poultry teed aad may bate The KSfAJCnR. Ondex l previous order to those aI BBT, aad beIon 1MI tbs pres ence of tfee compound ta the biological sham *u not suspected bemuse It ere* aatstea for BDT IB Isborslery andyoan. There is bo censentut among acieaUcu about bow dangtroue the compound l>. Their concern eraun on tfee Ion that Rli. Ilk* BBT. te e highly stable compound tbel brocks down BBT Uovly. will be pAropnoosreiedvaldte',th.beVeeBba2otntLeKdofmNes.ahtiaonn2ds feuae its vty lets earns beg feeds, Metals said. ' They said tfeat tfee meal bad bees told fee at fit feed processing pinsts. These is* eluded plants mat raise aad process poultry fer retail markets. Tfee odlciai* uid tfest tfee WUmingioB piaat had recniltd au flek reeal matufheoe*Jopepdbptsdvgi_*otsaiinua^cinae!sgsAnpelrlyile_t*Sb_wOs.eetphkr'eebl*elee*m teT~fdeedapti'eaaas~f et the House, the gent!enmn from Georgia. &r. Ourrmis megmsed lor 10 mlnuteiX / Mr. ORZPrCf. Mr/Speaker, la early June, the prop;* cf Ctin. Mlu. ay feometovn, unltrtcek the task of send ing tco rtpro^nunves to Paris, FTane* and Rome, lull te srpreu their support *yef.e.tr .is _la_s_e.l.u.f.e..lt _la___w_a.te.r..k..n..it..s..o..l.u. .ble .la.. fats, fe factor Which caused It te become cenaen* trated la tfee tlsiute et preprsaively larger aaimslt la tfee feed cfealn. Resulue* of up te 1000 parte per million ip pm.) feave been found la tfee tissues et American seabirds. The CSBA Rules fie at* permit sale fer hu man consumption of fleck eeetaiBiag mere then I ppm Some chickens fed ea tfee eon* tomineted flab m>! feevs bees found te eas tern up te aop.pju. Last Beeembrr a CamphaU'i Beup pleat ta New Jersey discovered uapeirelsubl* levete e( PCBs ta ehlekenr purebtoed from Rev Tors growers. Ague tfee discovery ess mafia la pnvtu teste, since tte federal gevemassat does est regularly tact fer FCBs la marketed New Tors gikte eeuais traced tfee eea* damiaettea to efeiekea feed produced la e pleat tfeat tteos stale bakery goods (vfetefc may heve beta wrtpptd ta piesue made vltfe fi. PCS) loeit (40.080 ckickoaa veto de* etroyed aad buried. Earlier, milk frea tve Bhte dairy feerde mas found to center'. PCBs dented frem ell* age stored Is sues ousted vltfe FCB-treatod totee. naaeusea,. fever aad ether bepe*uts ta feu* maae. eseials said. Tfeo Read aad Brug Ad* miAietratioB sud it feed a guirtlia* af parts per mUllea fer tfee PCS tufertaaee. Ag* rteulture tettattsts taid tbM M te SO pane per mtllloa had beea feuad Is flak meal aull et tfee Rena Carettaa plant. meats eves sos*BatmiMS Tbs eestaataatiBB was dteetared fey as tta* feamed cemaercial petutby pmreir vfee be* easae alarmed at a* lev rate et featcfelsg of egge Ut Itu breuer breeding chickens, flung private laboratory teets, br feuad up to 40 parte per mULen Is tfee fas a,* seme M feie klcseat. Agrtrultur* Mfuais saifi. Ss tramfi tfee meu te tfee Wumutgvte pleat, tfesy eauL Tfee meal vos sold te uters Is Alabama. Ayfcanaas. Belsvare. Plenda. Seergia. f&fii* baa. Remtueky. Rend Careuaa, Mnaissippi, Sbutfe CsreUfea. Teaamses aad VUgt&ta. Tfeo PP A PH a guideline ef flee pans per mUllea fer tfee eubetaase after It fend beea found ta feed from aa Agway. fas. pleat ta Sullivan County. K.T,, early tfet* year. XigBcr eeaeentratiens were feuad 1st ckicktas ted ib* feed ead ehipped te a pracmaag pleat la Rev Jersey. ^ Fedend eBcialt sud tfeti ItlBO cfe'ikns feed beea destroyed ta Sumvaa, ere*g* aad BkBiue .p*r,iso**ns. y_W** rFio*r.e<s wMeixl. *Tmh.o*.m*a*s E. CctUns 02. hflt'`>en a prisoner cUteo October ii. ICf^p. HaU a native of OUca. Tfee renruentatitm were Mayor John W. TUiman and PestAiaster F. L. Beott, both noted and >eU*re.*pected members et the community. The mission proved puceessful jieyond the Hopes of oil of ui mho supported and cneeulraged the effort. Hist ,4uree of enorad-u pride to rib that ettittiu n end crouni a smsil town Uke Vtisa. 1.033 popuItuoA ntouid tm* derukepuch a preieet wuh fs:.tiiieai and ftnsjicui problems to be overcome. Over* come they vrere. Mr. Speaker, for. vtlhin r remarkably short tune afUAUte effort toian. the money eaa riiec\and orran*iments made fer Mayer T?ftaa aad PoiJnuter leett to embark on tagu mts* Mob. V R wua eommtir.lt* profett. and fene in dieh people of all walks of We per* tiitpaud. Its motives wore ci tits coblcst wder and M tnun.itw pur:.v mrun. Tfeef wait x nrrii: t *.( f.J*-`> break and coneern aad love of aiUoas et 40H 007217 99 WATER PCB-SD0000010824 I ENVIRONMENTAL PROTECTION AGENCY i s tsn< ChimbIt* Toxicology laboratory 4770 Buford Highway oct Chamblot, Georgia 30341 pc&u. October 14, 1971 c -- s cv: i * '-1 l i Or. Gcorgt Levinskaa.. Monsanto Company " 800 R. Llngbergh Blvd. 8t. Louis, Missouri 63166 Osar George: Enclosed is a copy of the article on bladder cancer la the U.K. that Z mentioned on the phone. Another article chat discusses this problem Is one by Case/R.A.M.: Tumours of the Urinary Tract as an Occupational Disease In Several Industries. Ann. toy. Coll. Surg. Engl. 39:213*235, 1966. " Does Monsanto have a cytology screening program? If this Is aot the case It may be prudent to set up a cytology screening program vhere workers would submit about a 200 ce early morning urine specimen once a year. The freshly voided urine could be filtered immediately through a milllpore fil ter, then stained by the 'Pap" method and examined under the microscope, or It could be fixed in an equal amount of 50% do not think that collecting 24 hour urines would give any more information and would be a nuisance ta collect. , * For the sake of completeness Z am also enclosing the sunsnarles of two articles which Z am sure you have seen. Both | articles report some findings on Aroclor 1260 Lot AK-3. Let me know if you need any Aroclor. Ve seem to have more than sufficient for our ^tu&ie's. * . * Sincerely yours, /*, 9 Renate D. Kimbrough, M.D. nc: 3 AOM 0064* 116 WATER PCB-SD0000010825 /V3 -m, /?tr I Aastsgouir toadmeeo .Mst,4bpaui, fSSiUUSdcS *awse* &?g. so. 202. A fc* IfeS* ____r Tie* Lancet Saturday 24 July 1965 Csalaisem CiBiwm, g 6m (ditto* ssato$ieal for praam mi w ytvrem ssnadam 14 gLADDER TUMOURS Of TUB disease stacked w*y ef pmip of 15 workers _ eleczric-cablb industry cnpged on distilling' 9-aaphthylamine in on* particular '. ' Joan M. Davos MX0ass*8ip.?.SWL . plant (Case, is the press). If The average " induction-time * betvrem first erposure eo die arrinegem asd die development ef the disease was efte Ekpmtmmft ef CZriocsf Rnamth, Meys! Rtmaiia , SI yean; but some tumours appeared within 5 years, tad Hatpital, and budtate ef Cvtett Rotaeth, f ourfiie, S.VTJ ' some after 49 years. Thee was so evidenee that this Sobfecu la alealt. Tka a umw4 be Min-tKmdinirdmlal Wukm&tsm, In 1949 Cast and Hotkey iavestagated the laddmes ef tumours ef the bladder is the rubber industry ia England sad ^Taie ; this study was net sponsored by the industry, sad wu based largely on daa frets census reports, doth esrrificatea, and hospital records. The fadings srert feiduetieQ-timc was shone? in these with sever* exposure, or (eager ia those with comparatively slight exposure. During the survey it was observed that rumours bad occulted among chemical workers mgagtd la masts* fteturing die aatioridant mentioned, which contained @mraunioted to the appropriate sutheride* asd ts the M*, ef free naphthylaminc ef which 0-29% was. ootoas* sad industry ia 1949, but at that time the Rubber Maaufaetur- $*<upbthyiamiae, asd this was die ebservaden wteiA' 8C8M< after1 sees oewd a rf. Dun an dimics, asd mK.M V. fag Employers' Association did not sanction publication prompted the study ef the rubh industry. ' ,,. {Tima 1965). The results mere finally published fire years' The fimerios ef astiesidaaa is to retard the perishing liter (Case aad Hosker 1954), asd demonstrated aa occu ef the rubber in a finished article, aad thus preseve to pational risk among skilled rubber workers both ef eon-' stresgth aad ckse'dty. They arc among the chssial; meting tumour of the bladder aad ef dying free this agens added to raw rubber to fora a rubber mix, which` disease; these fadings were compatible with the hypothesis; is then manipulated unde hast a fora a tompomi,' gee*. Hus that a risk was introduced into the industry when a certain Aariesidaats are frequently need in powder fora, aad are teUtdtag sub* f tstenunn, a tad ia 1**4 ?*> rubber-antioxidant came into use is 1921. The production ef this widely used substanee ceased in 1949 when the danger to those making aad using it was recognised. _ , . Case and Hosker regarded this aa a preliminary study, usually added a the mix in the propernes ef one or. two para per hundred. Subsequently the compound is. meulitk eg exmdid to the shape required, aad subjected" a hat (usually by stesm) for the process ef tvtomtsrun. m of ton* eal Adelaorr aril sari Ui and considered that a much more intensive survey of the If the aaeoadane contains nsphthylimino, they win rubber industry m necessary in order to aaemain whether. contaminate the air ef the room where aay.ef. these, ' *-*' : *fr!*e&e'uaiWWf!' ' the antioxidant in `sehhifihSf'tfh'St question was in fact mpessible-^Snd if , ft'l ioteiiffeat-l^^SSTd^feasSfflHhlfWlk'1' operations are carried out They may he absorbed 'as p*mfd&^>p&d ^'TsMir*lr.BT4rbr^reieitonr^^ asnluUawusmut eunm i <4h AJiaaada and srudy ia dynamics: Suds a survey has never been * handling the rubber, hut by anyone In die room.'' . made, and for mforaanon about the background the In 1948 the rubber industry purchased 1410 toss ef Ns cku|i.| disease we must turn to die survey ef occupational gmiosdants ef aU types. At that time the industry at Rsriisdsa. racomlreeeei* cntofpaucnu. jticululy ki|t bUdder*mmours is chemical workers of Cue ct aL (1954), although we cannot be ceraia how doiely the fadings of this survey win apply $n the eontes ef e different industry. The survey was sponsored by the Association of British employed 77,000 persons ia over 300 facades in InglaM" and VTales (Board ef Teade 1952). . ' The Bectrie*eable faduse^ M2LBkeItm. (ITLeMei.. Chemical Manufacturers, and was concerned with th & terms of maa*pewe, the eleetrk*obIe industry is half &* mengliry and morbidity from bladder tumours in a group tin ef- she rubber industry, and it is eaneentraied mainly is asm if tbe OSnrs. Ik* .he Aaer-ieas i (Tphilii ban "22 aim wert *42 Keyem- m m,toi & m ia *em C*tai should ** v^amunoat. ' hire? YorS. t Feeding eel uu1m.L.b0a..ldas** eHsutd `*'4tae-tMmJ .dfSinaign&udsinae1**` ef 1466 dyestuff workers in England and Wales. a hiie freteriet in Greater Londea, Lancashire, and Oteahite, The multi showed that by 1952,1 in 10 of these men had already developed bladder tumours, and that in time the inddetee was expected to reach T & $. These ` thdbgh there are factories ia ether aunties. At present SI com panies tn England aad Vain are parties te the Joint Industrial Council for the industry, and these control about 40 factenes.. Elecwic able* may be temmmurii* cables-"**., submarine fetsaun could be attributed t| exposure to x-naphthyla- * r telephone ables--*r power table*. ITe are eenceratd only mine, J-naphthylamiae, ep benxidine; 5-ruphthylaraine with she latter because eemmurunoen obte* do nos mmilf being the most poteM,cardnegea. These substances may eonuia rubber. Power ablet vary in siee oeeording she readily enter into the body whether they are in the form voltage they atry; me tmaUat contain a smjle conductor ef powder, liquid, or vapour, for they aiy be ingested, absorbed through the skin, or inhaled. . ... The risk to the workers increased with the amount ef exposure, measured by either duradoa or degree of wire whilst larger ones eeatam many wm srrandrd sogrthw. 2s most power able* the eondunor is insutated, and (espt a ablet carrying *) high voltages) rubber was thtuiual iniulatbig material until the recent introduction f thertaepUsee materials such a pelyethyltne. The iniulaied conductor is exposure in various operations with the substances. Thus covered with s pretecere outer shesth. and rubber remarna the st one end of the scale 8 small number ef tumours most suitable material for thn Heath is artaut typv of able-- developed among workers such as fitters and plumbers, e.g., boutt-wtring and 6tuble trading able*. who handled contaminated machinery or worked in ea- in |M9 the elenric*cable isdusoy used 10.500 tent ofrubba. tasuaated atmospheres, and at the ether md ef the sole Thia aa only 4% aU rubber amumed is the Uiw^ .- ,, 117 WATER PCB-SD0000010826 I 144 JVLT 24, ms mwmsa, Atneim 1 MJOf /aaU, Tbs gwfrapfeJeil dism'btsa'ta eg die deaths is shows fa tm BSS IMM4 I Oils a as lbs eesaspasymg Rgura; serif half fae able wertm Meed fa the Stew Leader arts, wham the highest mmam&em eg rubber workers west fa the Midkads 2* If. md the North-West. lathe past there has been a tesdraey fissurae that fadustmi bladder tumours ceeasaed ealp efadekas fa rite North of laglaad; a study of tho map friU show thanhk is ase fas esa. ' fyagdem, sad only a teuh ef the mourn taed ta tils nn> foenue ef tyres sad tube (Central Sueniol tfka 1932). Aadssdaaa are essential iagredleats in fae csapouafoagef fubfatr used for tnsuUung er covering ekeme tama If we tawnr fas aumbera aad ages of aS male wtea agsged fa fae ssaufseurt of deraris rabies duriag fas anas period, we wild e&kuktt as espmed stabs of btaddsr>fumeiff deaths la rampart with our @kmmd eattasdans that are used ia the rubber industry. Us aasa- sumb of 61 Uafomtaatriy this fa wm possible bemuse oidsas withdrawn ia 1949 wat popular ia the ebls ktdmsr, fae. oaly esurm of such fafotraades me fae Reper of md had feea ia use tiaet 19JS, and possibly rarlter. This &@ fae 1931 Cessna, aad fae eceupatfaa tables dfatmgmsh md is impliaoea* seta hss'e.etaped eetiee for e deads. oaly a loud group of some 4100 * Ueesrie Cable aad Less the ponibility of a bladder-tumour hazard ia the able Wire ftuehias Oifaa, Sencra-up aad Assuaas" fadrasy nt mentioned hy the Snath Association ef Uioiogi- {eedes 233,234); aU efara eblt-factory workers (ataber> el Surgeons (1941! and by Seas ;1962), aad the eeeurreee of deaths frea bladder tumours among cable swim was fisted fey Case aad Davie (1965'j. Ye, only alter the publicity which followed the inquest on G. L, a former able worker who died la Jaauaryt IMS vLvwrr 1963i)(ni much attcatioo paid to this fag over 30,000) fans part of heteogcaeous gmups ef employees fa fae "Metal Maau&sure, fagfaeesag ad Allied Trades Za most ease fae occupations gfvra a fas 65 drafa . aiak, aad it seems (tkaiy that is severity a ask set fuUy certificates iadicite fae able workers' tarns (e.g., labours, able maker, foreman) raths faaa fae depsmeta fa Deaths la Cable Worker* which they worked, aad so afibrd few dura as to whefas The dia analysed bee wee obuined by caainfag all fae deemed sea were fa eoatact whb rubber. We da, death enre totes on which papUlema or rareness ei the however, kaew fae histories ef 8 of fae mca, aad ad but btadde was srarieaed as a cause of doth of male ia 1 ef these had had eoatas with rubbs. It must bo Eaglaad aad Wales from 194S to 1964. During thee temembpred that exposure aa ecur without fae aoual 30 years the eccvp&aeg gives oa 63 of these emie&ia handling ef rubbs; fab was illustrated fa fae rase ef odicated e worke is the e!eemie*able isdustrys fas the 6. L., whose recorded eeeupstiea ef wire straadfag was use peiod 118 such certifiates related to rubber workers. . probably faaocuous but who incurred faddcatal expoeun Table r give the distribuB'oa of thee deaths by date, sad whet he visited the rubbs departments fa his faemry la shews that in both industrial groups the aurabe of fae course ef fire-sratchfag dutia (fawn 1963a). deaths has iaeeased ia eaeh successive quraqucnahis. The gun of 63 is Ufcety to be a considerable sadcr* mdmate ef the aumbe eg men who worked fa eabb ' ftemrin aad subsequently developed bbdds tusaoun, fbr it Rdudn thrn groups of mca: (I) Those, such as G. L., who tears the fadustxy aad are see Bubbsr waphe^ deaeibed oo their death entiftates u able workers. Such ,,. oses do net auaUy rame a light unleu patients have bees u urfote eadsdrpemWemiinkfarin^-e: asebistoies with their death eenideates. (D These who develop bladder tumours but whose death estimates do net mention this condition. Cate m eL f1954) found that 19', ef patknu with bladder turnouts netmed by Inspiuls and known to be dead had ee mention ef this disease os theit death cswftrates. (3) Those who have been successfully (rested aad are stfll Bring. At the Royal Marsdcn Hospital alone eight such patterns have been eested. . Similarly fae Route ef hi must be m uadmntcmeat ef fae aumber or tumours among rubber workers, and . there can bf no d&bt that fae uformatioa available about fae aumber ef eases ef industrial bladder rumour fa fae gable aad rubber industries is woefully faadequate. SM&tHknmiti et SutevAemu by DUddir Tumours at i Cable Faetery Attentioa was rst drava to these cases when a feme? worker at a large eahlc-faetsfy in London was treated for tumour of the bladder at the Royal Marsdca Hospital and reported that 2 ef his former workmates bad received similar treatment. The factory had recently been elated dewm, but these 2 men were traced; it was found that they were alive and well, but had ia the past been treated for papilloma of the bladder. All three men had worked ia the rubber mill, and subsequcatly other rases from this department ame to light. .. ' Twd tetmwvsi>*v-susuu)| Yew) I before 193 withIfmaferti fa fae mil Table a 1 of fae U! 10 years'< Wales she oeeumd i 1946-44 ' freaaade differaaee (o thee 4 -'eiresdpw asaour/ Alt 6 e mere than are ghrea i agvef 60) the end of 4 deaths e reeuned a Ko drat mong fat However, i 1-3 years' < aad that t group semi was fa 193 Ko vases r !! 22b ADM 006447 WATER PCB-SD0000010827 .nrtMHerr t pir 24, 1945 lIOtNAl AITICLIS *M uxor 145 C -hew is-- werkm ibs highest is Midlands assendency seemed only ef tim.map gale vrorim during the i aumhra el car skurvti :He beaus* w Reports ef distinguish ^ Cable end Assistants" 4it (number* 4i groups ef paeeriag sad . 2 TfUfL yna m atani tm went m rarrasai m mu. me Hi____ .. * it-i ; in* itSSsS-Siara e *i - 0^ "T* *- a | m -- *-- 1 lU'iil l u i ;w The faewry manufactured wbb4suht*d ebles, sad used the aetiesdasi refered ts fiem 1931 m 1949, and possibly earhra. The operations tamed out ia she rubber mill included tile ernghtag out of the edditiva that woe mixed with the raw rubber (these included the aatioadaat, in powder torn), the mixing prom% aad the subsequent rolling ef the rubber eempeund ee i required tiuehamt. The coating of the conductor wire with rubber sad the proems ef vuteanisatiea mt ranted out ia eths departments. ' Madder tumour among watkefs fa ether depareneats of t$m fenery, but 6 eses have eem to light, aad three of these patients hart died (fa 1959, 1964, aad 1965). 2 of the men concerned were members of the scientific m** ^ the firm and spent seme efthetr time at this particular factory; 1 man was a laboratory teehnitian; 1 worked os the process efvuleamsatien, aad 2 worked fa the stranding deparenmt. The first & ere believed to have aosaHy handled the antioxidants the vuleasm wag presumably exposed to vapour item rubber compounded with this substance; the smandera may never have handled rubfes, fens it is known that me ef them had aeration to go into the rubber departments, aad the ether probably did Ekcwiao, The period wb@ the aatieridant was used included the whole ^ the 1939-45 u, and it is likely that there was iararased movement between depaments m this time. Indeed, is would be diSeult to exclude tspeture fa the ose ef anyone who worked at this factory during the war, for at one sage the rubber m31 served as an sir-raid shelter beause it was on ths pound floor ef easef the tseagmbutidinpef the factory. . the if doth e.g., labourer, farsneaa in s* to whether hcr. We do, s. sad aU but ft must be st the aetual s the ose of #" tdfag was V. exposure hit factory m The firm concerned pve across e the meeds ef feme? workers at the faeery, and fern these reeards The resula shown above ssengly tuggers thts the risk e list of men said ts have worked fas the rubber mill as ef contracting occupational tumours ef the bladder, tome time during the port 1935=49 was compiled. already knows to exist fa the rubber industry, meads, There were 159 auA men esciudisg ferenea end other tee the deesse-oble industry. One ef the eausal sfesss "staff " workers. Many ef tiiem also worked in ths mill, is almost eeminly an antioxidam ef which manufacture before 1935 and/or after 1949, but we arc concerned only eessed fa 1949, but we have no assurance that this is the with the length ef their exposure to the antioxidant, and only enures ef danger. ' this length of earpoiure is defined as the period ef temee The severity ef ths risk deneeaBWed fa one group ef in the mill between January, 1935, and December, 194$. rubber mtii workers should help ts dispel any doubts Table u shows the years of birth and length ef exposure afew*t &e necessity for tracing exposed workers cad of the 139 men; it can be sera that 30 men had mm offering them cytologies! screening tests. There is bo !>*5i). stable usds'r'-id ia eable 10 years' exposure. - Examination ef death emigrates fas England and Wales showed that 4 deaths from bladder tumours had occurred among the 139 men during the 19-ycar period reuen to suppose that the cpidestie of tumours at this factory is unique, for we knew ef ehutm ef 3 or mere cases at some ether factories. It it possible that thorough searches would reveal mm at most able and rubber 1946-64. The expected number of such deaths, ralcitiated factories that had used this antioxidant. Hitherto mom sad Breast from national age-ipecifie rates, was found to be 0-2. This factory managements have not been corneous ef this risk w.-rkm. Such difference it highly significant (PraO-OOOIX In addition to their workers, and many esses ef industrial bladder v si have been to these 4 deaths there are the two eases of papilloma tumour have gone unnoticed by them. Ho firm should t-i link their already mentioned, making a tool ef 0 eases ef bladder assume that its workers have naped this risk unless r whose death ft al. (1954) a notified by s i thts disease tumour. AH 6 eases occurred ameng the group ef men with more than 10 years' exposure, and details ef these eases are given in table m. AH the deaths occurred under the , egc ef 60 years. There are no grounds for believing that e soutiny has been made ef the ausa ef death ef aH present and forma employcm who have died during the past 10 or 20 yean. Bladder4umour is net a common muse ef death and the ausher of osturaHy-oceumag asa that mav be expected to occur under the age ef *1 aad ere tell . ` the end of this epidemic baa been reached, for 3 ef the 65 is very smaU; this is illustrated by the expectation ef i t tuck patieaa * 4 deaths occurred last year, and 1 ef the 2 papillomas 0-2 deaths among the 139 miU workm ova a period ef recurred a few months age. . n.*cmstemeat Me deaths from bladder tumours have occurred as far . * It seeas inevitable that ftmhe esses ef this disms wSl ** sorken, and among the 109 men with shorts periods of exposure^ occur as the result ef past exposure, but at least we m*y a skable about However, it should be noted that 25 out of the 31 men witif hope that early diagnosis wiU save or prolong the Uvea ei * unour hi the 1-5 years* exposure did net ester the mill until tfto 19-66, tome ef the future victims. equate. and that tumours would he espeeted to develop in this The probable industrial origin ef many cates ef nny , group some 10 years late than in men whose first exposure Madds tumour among able workers appears to have -* a former * nested for C apital aad * received * een closed * -J that they * 5 Seated for - worked ia * from this 1 was in 1935. ,f gone unnoticed not ettiy by factory aanagsaenrs, bus Ke eomprehmsivs search has been made fee rota of also by the doctors who treated these rases. We have mu a---eunora rt.-Met.-BS t Bt.as(B.Mtu weasras noted that ef 65 bladder-tumour deaths that occurred 1 .. , Cm, es. (Pviae^vwk. 1 m tk suU bub ! A* B ' Vme ef ! Ate w enact irrJ tal Cnu, ,vr4 i i leu-jj CnJuirve - Citini, IMS SS 14 tvie-eo l*:*-*o . ' IM 1 M 1056 1 | ivu-eo . IMI 44 : Akn . 1 AIVt*4e . |-f! I . IVHMO ttiUJte^s tfeBftee* IM4 1 |f nc- . itM , as t J * tees a among cable worken some art definitely known to be ef faduttrial origin, and yet none ef these 65 men w certified aa dying ef faduttrial disease. The most likely explanation for this omission is that the deaths were net teponed to coroners as being ef possible industrial origin betause the certifying doctors failed to notice tins aspect ef their patients* disease. f U9 ADM 006V WATER PCB-SD0000010828 y r .trsM .td iJ .m j. m H M if-m iiE iJ ts J fn m d S rtl;; r m pm m, im wmwu uncus )~ A* tmferassstt mult of Ail befc of kw mf deemt m that is mas; tsstasess wfcm the able wwteet jmg% tsetied beaefit far a pmebed isduimal iimat Cee. 39, gspdJema'efthfll&^B') Wy eim&si tM mm that they #m Sf!|iyg fer this benefit, md ata. mry hardship may have rmleedi it is beUtvti &at; 1951 uadi mid-196J ealy eae .adit weeks* mm beadit. As eld oh of this kdusst^) dmems Mght a amber of tirim pa bdag made rmmfsmwdf, vmm by sad wm$ If widows (fer taBusmal widows' pampas). To s lam enast tack ef gwarmea %$Um m sum tfbladder rumour emeag robber weritm, md tbs danh mi ftmmrth sad published Mfemmdm ess targriy rapeeiibla for this igaenact. Disquiet may be felt one the meat raposse ef the .Medial Rsart CmmML bad had mm than 18 yon* opetvt m the t_ and f thme as develop^ bladda maw. ( was ebsemd tmtrng 109 ad) werkers with periods ef mspemsss, but # Amber asm eeromd wertes fa ether para @f the ^oasy. Ia?efshel2i As ditme ptotti fmL Them w ao mumef that aU subsmaem mpotdbte fcr this risk have beea ^rodfitd aad withdrawa; ealy a fefl iamggadsa ehsridass peiat. geh0aridhtwmmk8r.P.I.Tbsssvtaa Kom^dimweefae dveJy*ernstt.wRernidt MitassrsltiewKwwssefhia, ekafetrMtwr.mDu.ahaaiTtlisUaa=m, --'tamsImmw 4 b ess eUaM twwrdii tswal esner wvtspm tm hwuin tow ^ar {tee asi! ef s lartv esste^roMst km im mOy ffiepwsnsa eM tmt ptmims SmdeA mmSti md ths ef Ufcm fer feeesdfef mam m star ngaw dmmbf fomteaM&mmmm. fjLmim 196Sb) to the request tee m to&spmisae . '. fcmdpriaa iate bladder tumours Is the robber bdussft, * ss* ealy has the Ceuaril deedaed to any et sued femdgtdea hself, but it has suggested ehss a mere _ ^7nSt nfS fM Seven ef fee < tIofttoetVASMA/.m-u-m-,-Ta-n-mS-m-a-da V. Bnluesmesm. l -------Jv^ma(!St!Be.9. (M.SfeL lIMi 6m> 8. A. M. J% iammt Bern * SMisan Aaael &sewe% &M fished study ef die hodeaea ef ruaoun should be Bide If the Rubber Miauraerurirf Employers' Association-- HmShmU.IDM. (.I8fieh. fe()I.t&SM?..)&ft..hrfaiermm&.h.j..T.neMSfe)ISeI.,y. body whieh opposed the pubUatioa of the origiBal study (gBsW Saasasl OteOSSS) AAsuh Ume ef Sc e this problem, sad which hss aot published say ef the ratable iaforastiea h Bust possess from the first ? Gssimnm, Il. (IMS) 'Suuionl SntOui t_a t.he <C uslstr ti i Kc(mvMrlmifHtalUab.t!IOh: B.t3.eUw. md BsMS. i #> SSI. fears* rerols of its eytologieal saeeaiai service. .* teas, r. i (ini) The bade rnsoa why a thorough investigation ef the { -- 0tmir*n*."*. robber (aad able) indusm'a is sought remains the same. es when this was dm proposed is 1949: thee ia set emaiaty that all the dsagerous robstaasm have been/' Ratified sad withdrawn from use. This doubt has bass' strrogihrnrd by findings such as the conriauing rise mj the aumbtr ef eertiied deaths from bladder tumour b} j msm-alutudi romoNAEY JUPERTENSION ` . . Ijb Sans able aad rubber workers. * MM, ttmmm, XC*M, PXCP.&, PAMJ. It hss bees seriously suggested that the ssphtbyisstes easestirAMy at sum to m &msa team . 'o ecateat of etraia aaties'daaa may aot have beea the ealy dsagerous eonstitutst ef these products. The very high ?. K, RO.tau Mabak La MM. feadrnor ef bladder rumours ia eae poup ef able workers leads some support to this suggest!cm, for dim' aa wert ia contact with sa aatios'diat esammaf a mee X. S. Koon M.U. P*al, MXCPX B. D. P. Rao MM. Pema, 2*5% of aaphthylamiaa of which only 0*29*4 vu the wtmum &snsa tumimm. mmsaa or ear 0-isomer, to that their exposure to these ordaegess was fmm the fHrmevu Gmural, drmmi Pena Medial ahaost eeminly much less severe th&a that ef groups ef fim DM, ll, India . chemical workers with a similar`tumour iaridcace. The impliesties is that we may have to deal with a completely new aad unsuspected class ef chemiol cardnogeai. Oeamesea (1965) discusses the An that the survey ef bladder tumours among ehemieal workers was made ealy Joag after, the risk ia this iadustry had beea first respected, aad eommeau M... It may (^difficult to future weriten to understand that so many deades should pass before a statistically souad evaluation ef risk was curried tut **. It teems aUjoo likely that this remark easy apply equally t@ asy comprehensive study ef the rubber iadustry. Bata et aL (1956) first reported thst people hriag a high altitudes ia die Peruvisa Aada hsd moderate pul* meaary hyperteasiom It was less evidest ia temporary resideas with a year's continuous say at high altitude, and most evident ia patients with dtroaie mountain riekam. Their findings hi permanent residents ef the Peruvian Aada were confirmed by Simc et aL (1963) aad by Pe&sloza ct aL (1963) and by findings ia the nodncxual Ualted Sates by Vogel ct L (1962). * have been cosceraed mostly with high*aldrode puSaosfiiy hypertension ia temporary residents in the HtssUyas. The feUesriag b aa account ef our esperiroe* A high fatddenet ef bladder tusteurs amoag akOled rubbo* workers was dmioroersted is 1949 aad may bava beea caused at least ia part by %a satieadsiu used between 1921 aad 1949. This &`gh iaddeaes hss mm beea fully iavesripted. . Factories manufacroring electric power ablet also used this aatioudsm. i&aminatisa ef doth emiiaiei fer fiaglaad aad U'aJet fer the yean 1949-64 revealed IS eases ef bladder tumour where the deceased was ef 102 osea. PreibpostBg Fseeor* The oposed ^puSstton esmimd of mm aged betweea SI aad 47 yean. . Fot 9| tatponry midma fiom sa-bvtl the vulneabk atn'wdt began at 11499 feet. Fee I person it w* 8000 feet, aad fer 2 persons bom and brought op at an altitude ef 11400 feet tbs vulnerable altitude was 12400 feet and 14400 feet. 1 maa was a tool resident Using at 12400 feet. la 61 men symptoms ef putmenary hjpertension began eftee described as a able worker. five to forty-ewe months* stay at high altitude, la 7 men tta Is eae large able factory 90 workers ia the robber mill high-altitude stay was eentmueus far five te sis months, and ia rii 120 AOH 006AA WATER PCB-SD0000010829 town an &mM3 if, ##! (1970) |c 1 Comparativn Toxicologic Study with Polychlorinated Biphenyls In Chickens with Special Reference to Porphyria, Edema Formation, Liver Necrosis, and Tissue Residues J. G. VosanoT. H. Kocmam , . Mmitfm 0/ Vmerimtf PefMyrsmttkt tmtttsm ef Vtmimrp Pkmmwkgf tmdTmimhgy, Vabmitt ef UimtiSe NasM&mAa JSmfesrfAfefsaO^A/SS? ' . afls'ruf.' g.St^Jlul " U4M tl * 4hr*ni St ttMl .M.wrutof r;.*(\tattO ffei ,,d.*fk *U Comparative Toxicologic Study with Polychlorinated Biphenyls fat Chiekent with Special Reference to Porphyria, Edema Formation, Liver . Necrosis, and Tissue Residues. Vos. J. 6. and Kocman, J. H. (1970). Toxicoh Appi Pharmacol. 17, 656-661. In a comparative 60-day oral toxicity test (400 ppm) in chickens, three 60*.{<hlorinated comnwrcial polychlorinated biphenyl (PCD) preparations were used: compound I (Phenoclor D P 6). compound 11 (Clophen A60), and compound III (Arodor 1260). Using morulity, mean survival time, mean weight, and pathological . (he PCI . ,UI>PH ' mrip in th ,wLereU(l 44ontinuo c observations (hydropericardium, abdominal, and subcutaneous edema and eentrolobular liver necrosis) as parameters, a significant difference in tow . city was found between the compounds: compounds I and U showed the they were * | he birds 1 ft*upU.4( highest, compound lit the lowest, toxicity. Microscopically eentrolobular liver necrosis was found in chicks fed compounds 1 and it. Atrophy of the . ' 4t)troL spleen wat found in all test groups. Chemical porphyria was found as a Ihcywei general PCD effect: increased fecal excretion of coproporphyrin and proto- . ' **icdofa< porphyrin and fluorescence of tissues occurred in alt test groups. Additional experiments with compound I (2000 ppm) in Japanese quail and rats con firmed the porphyrogenic action. Gas chromatographic analyses of liver and brain of dead chicks gave PCD levels that varied between 120 and 2900 ppm. The relationship of hydropericardium (chick edema) r.d liver necrosis to the differences in toxicity observed between the technical PCS . * carefully in tnuuhe rat iw! the an ff,up II di> by the 1*0! mixtures is discussed. diwarded a At new In recent yean the presence of polychlorinated biphenyls (PCS) has been exhibited in rcedteona Ash and wildlife ip many countries, including the United States, Great Britain, Sweden, renuned fri and The Netherlands (Jensen, 1966; Holmes tt o/n 1967; Holden and Mandat, IVt "; 4 t the fluid ; Kocman it 1/., 1967; Riscbrough et eU 1965; Keeman.ef *#/,, 1969). . And *uhcut; *' ^Commercial PCS preparations arc oily fluids coesisdng of a mixture of different hver. vplcer chlorinated biphenyls. These chemicals are extremeiy.ftible with very low aquctwi* vcntHHial n' solubility. They are used as lubricants, as fluids for brat transfer and dielectric medu. . In protective coatings for wood, metal, and concrete, and for many other application* Which of these applications has contributed to the present widespread environmental Contamination has nos been elucidated. The occupational hazards in the use of PI # `have been known for years; normal handling of these compounds has not given rise to great difficulties (Irish, 1963), * Animal experiments with rats and guinea pigs have shown that the ingestion of PCH ylin<o*it M with nu M,un blue audio with dautewenct ewetwe of I <36 jt.rw 121 ADK 006451 WATER PCB-SD0000010830 t c \1though tpport it: affect om those . dim eti *r,I967). pisium etiea b Agnestum t, fateh cssmion ssta aug. . Jtudffliai- sc is urine Aat a&Ier- dmad mi j I | * } is!support c magamium spat ism*. & Root and jraaetabo j. Med, m. wmbtff Bftd .ynen, A. V. `*4 Springer. fMtaiea . . 0 j - / . Otrmal Toxicity Studies of Technical Polychlorinated llphonyli and Fractions Thereof in Robbies . J. G. Vos akdILB. Roms Vmerm W l/mHif, Bdtmwm l?&, (fonfc, TM NtUmkmit Mmirkw'iGmkmg' iff Dermal Teiidty Studies of Teehaim! Polychlorinated iipteayb tsi Factions Thereof ia Rabbits. Vos, 1. O., tad Bums, R. B. (1971). T@gk@L Appl. Pharmtcvl It. 617-4)3. A significant difference in toxicity between I polychlorinated biphenyl (PCD preparations was found ia a prior study; , . Clophen A10 and Phenocior DP6 showing the highest, Arodor 1260 the lowest, toxicity (Vos and Koeman, 1970). A subsequent study revealed the presence of tetra- and pentachJerodibesvsefuran in Ptwneelor end Gophsst (Vos eieL, 1970). In the present study, application of 11S mg of the I PCB's (J turns per wfc, for II days) a the back skra of tabbits also multed is differences in toxicity. PCB-indueed skin leaioas were hyperplasia and hyperkeratosis of the , epidermal and follicular epithelium. Histopathology of the liver included ' centrolobuiar degeneration, centrolobular liver cell atrophy, focal necrosis, and cytoplasmic hyalin degeneration. Definite hyperplasia and hypertera* tosis of the follicular epithelium of the ear skin were seen after the topical application of fractions of Phenoctor and Ctophen eluted from chromate* paphic columns with 23% diethylether ia hexane. The fraction from Are* dor caused a minimal hyperplasia and hyperkeratosis of the follicular epithelium. PCB*indueed kidney lesions wea hydropic degeneration of the convoluted tubule and tubular dilatation with the presence of cuts. This dilatation was demonstrated also by a significantly increased relative percentage of the diamcter'which corresponds to the space of Bowman. Moreover, thymus atrophy and lymphopenia were found. Fecal copro* . porphyrin end protoporphyrin excretion an increased.' Polychlorinated biphenyls (PCI) have been identified in tissues of fish and wildlife in many countries (Jensen. 1966: Holmes tt a!^ 1967: Holden and Marsden. 1967; Koemweiei., 1967; Ritcbroughrra/., 1961; Koeman ero/., 1969: Jensen a/., 1969; Duke f eU 1970; Prcstt a </,, 1970k * PCi preparations arc extremely stable, oily fluids with very low aqueous solubility. They arc used as lubricants, as heat transfer media, in protective coatings for wood, metal, and concrete, and for many other applications. Which ofthese applications has contributed to the present environmenttfconumination has not yet been established. Inhalation and feeding experiments iifrats with 63 % chlorinated PCi resulted in liver Injury (Drinker tt @L I9J7: Bennett ero/., 1938). Liver damage and skin lesions have been described after inhalation, ingestion, and application to the skin using rabbits, guinea pigs, and mice (von Wedel ttol* 1943). Hydropericardium occasionally accom panied by abdominal edema wit found in chicks fed PC (McCunc ei a!., 1962; Flick ` <17 122 ADM 006451 I WATER PCB-SD0000010831 mmmm mdostbzal mms comm . JTOCTMMAL fWBUGTS GROUP STANDARD EANDFACTDHSI0 FROCKS tor 4ft*' AROCLORS (Take-over distilled) partsent 146 Supercedsss Standard Kamifigturing Preetii fer Aroelers Department 246* datad Oetobar 1966, and all amendments A through L # ; Tantatlra Froeaaa for the Contlnuoua Manufacture of Aroelor 1242, dated 9/16/68, and designated Report Me. P-1504. Frepared by: R. ft. IScCutchan T3. %Approved General Manufacturing Superintendent to R. ReWy -Hireea rcg^Bevri.epaent Onager^ \ <? rsir^g Manufacturing Manager^) Issued: 1971 > # opy t I o .... v v' . . * 7'`This process la the property of Monaanto Industrial Oiemieala * l`i'-e@pany and the recipient is responsible for its safekeeping. Zt contains confidential information of Monsanto Industrial . Chemicals Company which oust not be reproduced, re retied te 'unauthorized persons or sent outside the company without proper "authorization. Either retain In a secure file er return to the Standard Documents Department. 123 IB* 0016] WATER PCB-SD0000010832 .1 department 246 - standard rjs:tTAcru?,gn6 pp.ecssf AROttOR ' APPENDIX J SAFETY AND TOXICITY DATA . I. SAFETY EQUIPMENT . A# Fire Extinguishers. - 1. Carbon dioxide 1st floor, ME ef lean-to 2m Dry ehsr.ieal - 1st floor, SE of lean-to 3. Dry chemical - 2nd floor, west wall 4# Dry chemical 2nd floor, west wall . fie Gas Masks# le 1st floor, on sprinkler house 2m 1st floor, outside west wall of repair room 3* 2nd floor, on west wall 4e Control room, east wall 5, 4th floor., on handrail by #1 chlorinator , 4th platform, Aroclor column (2) ' C# Scott Air F&k, 1# Outside west wall of lean-to D# Emergency Clothing# 1# Box on 2nd floor, vest wall, E, Safety Showers With Dye Nash. '. 1 Batch department, 1st floor, 2m fiateh department, 2nd floor# 3# Batch department, 3rd floor# 4# Continuous department, 1st floor# 5# Continuous department, 2nd floor# f# Continuous department, 3rd floor# 7# West side of tank farm (alarm in control room) 8# Control room (eye batch only) * F# Personal Safety Emigrant Available. 1# Bard hat. 2# Safety glasses# * 3# Safety shoes 4# Goggles# I# Rubber or canvas gloves# i# Rubber overshoes# 124 I AD* 0C2fcl WATER PCB-SD0000010833 DEPARTMENT 246 STANDARD MANUFACTURING PRCCESS AROCLOR (Cont'd) APPENDIX J (Cent'd) SAFETY AND TOXICITY DATA (Coat'd) II. DEPARTISN? SAFETY RECORD (246/259). . A. Lott time accident! - Last occurred on January 28, II4ie B. Sariout Injuries The last two serious Injuries wart s 1) i/i/76 - See Attached informal investigation report. . 2) 12/2/68 ftafer to fozaal investigation report L-17-20-68. C. Minor injuries. Year Injuries No. of Men ' 1969 1970 1971 12 12 13 20 20 24 III.TOXICITY The following toxic rating code will be used in describing the toxicity of these materials! 4t -.)} 0 - none f1 - slight U unknown . A. Biphenyl (Code 82601) * 1. Synonymsi* Diphenyl. . 2. Description! Khita flakes or solid off whits mass; somewhat pieas ant odor. .3. Constantst liol. Wt. 154.2y M.P. 9*C. B.P. 255*C. Density .9910 6 75*/4*C. 4 Flash Point! 235* F. (C.C.). 5. Xuto ichitTon Temperaturet 1004*F. I. Toxic Harare Aatir.ci Acute Local! V Acute Systematic! Ingestion 3, Inhalation 3 . Chromic Local! U ' 7. Fire Hazard! Definitely when exposed to heat or flare j can react with oxidizing materials. 8. Fire righting! C02 or dry chemical. 9* Formula! SfTsCiUi 125 ADM 002 WATER PCB-SD0000010834 SEPARTIX:rr 246 - STANDARD MANUFACTURING PROCESS AROCLOR APPENDIX J (Cent*d) fAFE7Y AND TOXICITY DATA (Cont'd) XII*(Cont'd) A (Cont'd) , 10 Biphenyl vapors ars irritating to tha upper respiratory tract. Workers should not be exposed to vapor levels throughout their shift in excess of the threshold limit value of 1 milligram per cubic meter of air (or about 0*2 ppm) * The compound, or organie solutions of the com pound can absorb through the intact skin; therefore, repeated skin contact should be avoided. 11. See Hygienic Guide Series on Diphenyl* . B. Chlorine (Code 81059) 1 Descriptioni Greenish yellow gas. 2 Porr.uia; Cl2 3 Constants 1 Mol. Wt. 70.914; K.P<*101*C.;B.P. - 34.S*C.; Density 1.47 9 0*C. 4 Toxic Hazard Ratinet Acute local1 Irritant 3; Xnhalation 3 Acute systemic; 0 Chronic locals V Chronic systemic; U 5. Toxicology; Chlorine is extremely irritating to the mucous membranes "of the eyes and respiratory tract. It combines with moisture to liberate nascent oxygen and from hydro ' chloric .acid. Both of these substances, if present in quantity, cause inflansoation of the tissues with which they coma in contae*. Zf the lung tissues are attacked, pulmonary edema may rasuT A concentration of 3.5 ppm produces a detectable odor; 15 PPM causes immediate irritation of the throat. Con centrations of 50 PPM are dangerous for even short exposur 1000 PPM may be fatal even when the exposure is brief. Because of its intensely irritating properties, severe industrial exposure seldom occurs, as the workman is forced to leave the area before he can be seriously affect Xn cases where this is Impossible, the initial irritation 126 oC2 WATER PCB-SD0000010835 I c DEPARTMENT 246 - STANDARD HKreFACTCRiyC rP-OCZSS AROCLQR ` APPENDIX J CCent64) SAFETY AND TOXICITY BATA (Cont'd) III. B. S. (Coat'd) of the eyes end mucous membranes of the note end throat is followed by eeugh, e feeling of suffocation and later pain and a feeling conatriction in the cheat, if exposure has been severe, pulmonary adorns nay follow with rales being heard ever the cheat. . 6. Fire Hazardi Moderate - can react to cause fire or explosion upon contact with turpentine, ether, ammonia gas, illuminating gas, hydrocarbons, hydrogen and powdered netals. 7. Explosion Hazardi Present by reaction with reducing agent 8. Disaster Control t Dangerous; salts highly toxic fur.es; C wrll react witTI.water to fom toxic and corrosive fumes . of HCl; is heavier than air gas will hug the ground. People without adequate protection should go across wind until out of the affected area. C. HCl Off-Gas (Code 828.51) 1. Synonyms s Muriatic acid, Chlorohydrie Acid, Hydrogen Chlo: 2. descriptiont Colorless gas. 3. Formulas HCl. .' 4. ^cxie t.&zard Ratingi . ' Acute locali Irritant 3, Ingestion 3, Inhalation 3 . Acuta Systemics U Chronic locals Irritant 2 Chronic Systemics U . 5. M.A.C.s 5 ppm in air for 8 hr. day. i. ^dxXcoiocy s Hydrogen chloride is an Irritant to the mucous membranes of the eyes and respiratory tract. Concentrator of 35 ppm causes Irritation of the throat after short expos Concentrations of 50 to 100 ppm are tolerable for 1 hour. More serious exposures result in pulmonary edema and often , laryngeal spasm. Concentrations of 1000 to 2000 ppm are dangerous even for brief exposures. Mists of HCl are con sidered less harmful than the anhydrous form since the droplets have no dehydrating effect. 7. See Hygienic Guide Series on "Hydrogen Chloride". 127 ACM COZf WATER PCB-SD0000010836 I c LEPARTtXtTT 246 - STANDARD MAKCTACTfETTG f>F.GCfgf AROCIOR . APPEJDIX J CCent'S) SAFETY AND TOXICITY DATA (Cent'd) ZZZ. . (Conn'd) D. Ferric Chicride (Code 33500) . 1* Description* Granular solid. 2. Formula: jfeCla (Annydrous) 3. 'Con's't'anna: Kol. K$t. 111.22, Kelting Ft.iufelines, soTuTUIz/ in H^O very soluble with heat rise. . Toxic Hazard Ratine: .... Acute Local: Irritant li Zngestion 1 Acute Systemic: U Chronic Local: Irritant 1 Chronic Systemic: U . 5. Fire Hazard: Tnere is no fire hazard under normal cenditi but. it win ex.'it toxic fumes at high temperatures 6. Handling: Protect the shin with approved protective ciot.ur.g, avoid the breaking of FeClj dust, wear approved c respirator with adequate cartridge, and protect the eyes with approved goggles. There are no storage regulations; however, it should be stored in a dry place as heat is released upon solution in water and wst ferric chloride will not catalyze the chlorinaticn reaction. Lime (Cede 38600) (Calcium Oxide) 1. Description: Fine white or slightly gray powder, Rhomerie ' trigonal crystals. . 2. Formula: CaO. . 3. froxrc hazard Ratine: ^, ' Acute local: Irritant 3; Zngestion 1; Inhalation 3. * ` Acute Systemic: Zngestion 2; Inhalation 3; skin . absorption 0. Chronic local: Irritant 3; Inhalation 2. Chronic Systemic: Ingestion 2; Inhalation 3; Skin absorption 0. 4. Toxicology: Has a caustic reaction and, therefore, is irritating to th< akin. As a dust it can causa dermatitis and irritation of the eyes and mucous membranes. It is a general nuiaanci type of dust. 5. Fire Hazard: None. i. Explosion hazard: Virtually none. . * 7. handling: Cuss respirator, adequate protective clothing, including rubber coated gloves, optional rubber full cover apron and full cover plastic goggles should be used when 128 ADH 0C26 n WATER PCB-SD0000010837 department 246 - standard manufacturing process AHOCLOR APPENDIX J (Cont'd) SAFETY AHP TOXICITY DATA (Cont'd) . X. 7. (Cont'd) handling lino (dust) Adequate ventilation and dust remove equipment should be used in the handling area. . Line is added to the stills to neutralize any liberated HC1 prevent sublimation of the re Cl 3 catalyst, it is handled in SOI bags. . F. Nitrogen (Code 43099} ' 1. Description! Colorless gas 2. I'orr.ula't... 11? 3. Constants 1 Ilol. Wt. 28.02) II.P. 210*C; B.P. 195.8*C.f Density 1.2506 gr/liter at 0#c. .. 4. Toxicityt None. In high concentrations it is an " * asphyxiant. G. Areelors. (See Kygienic Guide Series on Chlorodiphenyls") 129 adh 002fcie WATER PCB-SD0000010838 i \p\ BE PORT TO Tffi JANUARY KSSTZK9 OF TK2 BOARD OF DIRECTORS ON TiE STATUS OP KB IMPLEMENTATION PROGRAM // 4 The worldwide PCS action plan reviewed with the Board in December / la being fully implemented. Although customer acceptance has. in general, been positive, some are raising questions which may creat problems. Ve remain hopeful we can resolve these problems on a case by case basis. Ve are on our established time schedule. The status report on the domestic program is as follows $ 1) Formal letter of notification to heat transfer customers was sent by registered mail on December 15, 1971, to all known users. All sales have been discontinued, some customer conversions to other fluids have been made, and ?ur engineer team is available to help others convert on equest. 2) All original equipment capacitor and transformer customers for our PCB dielectric fluids were notified on December 21, 1971, that further sales after January 15, 1972, would be dependent on receipt of financially meaningful and acceptable hold harmless agreements. To date six companies have com . plied, which represent $3% of domestic dielectric sales: General Electric, Westlnghouse, McGraw-Edlson, ITS Imperial, Sprague Electric and Federal Pacific. Additional customers ,indicate they will comply and we expect the majority to do V so. Progress on this part of the program now permits us to v notify miscellaneous "top-up" customers and repair shops of our plan and will permit referral to original equipment manufacturers for fluids. The dielectric program is also being extended to a small group of miscellaneous dielectric customers using our fluid in the manufacture of closed.switch gears, electric magnets and hermetically sealed electric motors ^ 3) All plasticizer customers were notified on December 31, 1971, of our intention to discontinue PCT sales for this use effec tive March 31, 1972. In a limited number of hardship cases where the customer requires lead time to develop alternate formulations, such as certain investment casting customers, a program consistent with our overall program has been developed, including hold harmless agreements, to allow sufficient purchases before our cutoff date to permit the customer's required reformulations. ADM 00t>02*130 130 1 WATER PCB-SD0000010839 *) A letter will toe eent on January 31, 1972* to all users of PCT-containing hydraulic fluids, notifying them that Monsanto will eliminate sales of PCT's for this use no later than ^une 30, 1972. The status report on our SI-V.S.A. program is as follows s 1) All sales of PCB'a for all uses other than as dielectric . fluids will toe terminated January 31, 1972. 2) Continued sales of PCB's for use as dielectric fluids after March 31* 1972, will be dependent upon receipt of hold harm less agreements acceptable to Monsanto from customers whose financial responsibility makes such agreements meaningful in Monsanto'a opinion. 3) Sales of PCT's Ex-U.S.A. will be discontinued on the same time schedule as used on domestic sales. The President has authorised MZCC's Managing Director to make exceptions on a ease by ease basis. Two have been made in our Ex-U.S.A. program: 1) Because of the safety needs of the german coal mining industry . for our FCB-contalnlng hydraulic fluids, sales will continue for this use for the shortest possible time beyond January 31# 1972, to permit clearance of substitute materials. Indemnity agreements art not possible, but techniques of sale reviewed with German counsel are being utilized to minimize our exposure 2) A commitment to sell 600 tons of our PCS dielectric fluids was made to the Russian state purchasing authorities In December, 1971, prior to formulation of our Sx-U.S.A. program. Completion of deliveries before our March 31# 1972, cutoff date is not possible nor is an indemrjitvjggjMifclft*-- a,,a .n.-di-ac-losure:Tg- toelhVffiadb/But;''some deliveries will occur Into July, 1972. Ve have been in close touch with the Federal Interagency Task Force under Dr. Edward J. Burger, Jr.'s direction. This task force is preparing to issue a report on PCB's about mid-February. Ve will be allowed to work with them in its preparation. On January 21 and 22, Monsanto representatives met with a group of scientists to discuss the general PCB situation. Present were Dr. Varren Muir, Council of Environmental Quality, Dr. Edward Goldberg, Scripps Institute of Oceanography, Dr. Robert Riseberough, University of California, and George Harvey, Woods Hole Oceano graphic Institution. The meeting went well and we feel the scientists left with a much fuller understanding of the overall PCB issue than they had previously. V131 131 I ,. AO* 006025 5 WATER PCB-SD0000010840 > -3- Ve have discussed the essentiality of the use.of PCB's for dielectric fluids with key companies in the electrical industry and General Electric and Vestlnghouse Electric have submitted reports to the National Industrial Pollution Council and the Office of Science & Technology in which they testified as to the necessity for continued use in these applications and the steps being taken to contain the PCB's In these electrical closed system Ve expect to complete our entire implementation program on sehedul \ ADH 006026 132 WATER PCB-SDOOOO010841 Monsanto es@SA@ tstmjsfMAt. gMemcau ee. 00 N. itMH'i* lelevere *l l*wt, sues MM! 0141 M4-I00S Dear Sirs Wo art writing to advise you that Monsanto has adopted certain restrictive policies with respect to its further sale and delivery of all polychlorinated biphenyl (PCI's) products used as dielectric fluids in transformers and capacitors including but not limited fco^those sold under tradenames such as Aroclor, Znerteen0l and Pyranol W and under the generic term askarel. Effective 15 January 1972 Monsanto will sell and deliver these products only to manufacturers of transformers or capacitors who have entered into agreement to indemnify and hold harmless Monsanto in the use of these products. The two copies of such an agreement are attached. The acceptance by Monsanto of such an agreement is subject to receipt of financial and other information from you .fcsetioni which, in Monsanto's opinion, makes the agreement meaningful. 9 . * As we have previously advised you, studies Indicate PCB's may be accumulating in the environment. Zn some instances, PCB's have been found in food or in the food chain. For your information, attached is an article by Carl C. Gustafson of the Federal Water Quality Administration appearing in "Environmental Science 4 Technology" which deals with this subject. Because of Monsanto's concern over this problem, we are discontinuing sales of PCI's in any applications except as dielectric fluids for use in transformers and capacitors. unit ef M*,**i Cmim 133 AC* CG*7 WATER PCB-SD0000010842 Pag* 2 X you doslre to continue purchase of these products from Monsanto aftar IS January* pleas hav th attached copies of agreement signed by an authorised officer on behalf of your company and forvard a fully signed copy* together with your most recent audited financial statement and any ether information which you feel will assist Monsanto in its valuation. If you have any questions please telephone (314) 694-2455 or write directly to Mr. a. 5. Bergen* Monsanto Company* P. O. Box 14617* St. Louis* Missouri 63176. We sincerely regret any hardships that this decision may cause you but it is taken in an effort to continue to make available these products for critical electrical applications. Vory truly yours* 4t* r.-x tjstfg&s: Enclosures toward Bergen* Director Specialty Products Croup Monsanto Industrial Chemicals Co, 134 ACM 0024 WATER PCB-SD0000010843 ) Monsanto wrarnn&j, 00 W. UMItrik IttiiMU il. bettie. Miiuiri ISlil Mini mm MI000 ee, SPECIAL tmDlRTAKZHG BY PURCHASERS OF POLYCHLORIKATEB BIPHENYLS Monsanto Company ("Konainto") manufactures certain poly chlorinated biphenyl products ("PCB's") which ("Buyer") desires to purchase. While Buyer desires to purchase PCB'a because of certain desirable flame resistant and insulator properties. Buyer acknowledges that it Is aware and has been advised by ' Monsanto that PCB's tend to persist in the environment: that care is required in their handling, possession, use and disposition: that tolerance limits have been or are being established for PCB's in various food products Monsanto has therefore adopted certain restrictive policies with respect to its further production, sale and delivery of PCB's. including the receipt of undertakings from its customers as set forth below, and Buyer is willing to agree to such undertakings with respect to sales and/or deliveries of PCB's by Monsanto to Buyer. Accordingly. Buyer hereby covenants and agrees that, with respect to any and all PCB's sold or delivered by or on behalf of Monsanto to Buyer on or after the date hereof and in consideration of any such sale or delivery. Buyer shall defend, indemnify and hold harmless Monsanto, its present, past and future directors, officers, employes and agents, from and against any and all liabilities, claims, damages, penalties, actions, suits, losses, costs and expenses arising out of or in connection with the receipt, purchase, possession, handling, use, sale or disposition of such PCB's by, through or under Buyer, whether alone or in combination with ether substances, including, without implied limitation, any contamination of or adverse effect on humans, marine and wildlife, feed, animal feed or the environment by reason of such PCB's. 6 nit *1 Mmii.ii CtmttHf 135 AC* 002* WATER PCB-SD0000010844 All existing contracts for tho tilt of PCB's by Monsanto to Buyor aro horoby amended to contain tho provision! sot forth above. Nothin? horoin oh all eroato or imply any duty or obligation of Monsanto to loll or do1Ivor any FCB'a to Buyor. No condi tions# undorstandings or agreements purporting to modify or vary tho torms horoof shall bo binding unloss horoaftor nado in writing spoeifieally roforring to this agreement and signed by tho party to bo bound and no modification or variance of tho abovo undertaking shall bo effected by tho acknowledgment or acceptance of any sale document# purchase order# shipping instruction or other forms containing terms or conditions at variance herewith.* 136 (Buyer) BY: TITLE: ____ DATE: MONSANTO COMPANY BY: ...... _ 136 ACM CC2<t7 WATER PCB-SD0000010845 ) Monsanto MwiiMrm rnmmnm, cmmmmm co. 6 M. iMfiergR 8l. Imi. Wittaan @3166 Mim: a>) 66>IOOO . February 4, 1972 Dear Sirs Ve are writing to advise you that Monsanto has adopted certain policies with respect to its further sale and delivery of all polychlorinated biphenyl (PCB) products used as dielectric fluids lncludlng-but not limited to those sold under tradenames such as Arocleruy, ZnerteenCH^ and Fyranolvfl^ and under the generic tera askarel. ^ Effective immediately Monsanto will sell and deliver these prod ucts only to manufacturers of electrical equipment or components who utilize the products as dielectric fluids and who have entered into agreement to Indemnify and hold harmless Monsanto in the use of these products. The two copies of such an agreement are at tached. The acceptance by Monsanto of such an agreement is sub ject to receipt of financial and other information from you (such as evidence of adequate insurance protection) which, in Monsanto's opinion, makes the agreement meaningful. As you are undoubtedly awars, .studies indicate FCBs may bo accumu lating in the environment. Xn some Instances, FCBs have been found in food or in the food chain. For your information, attachec is an article by Carl 6. Gustafson of the Federal Mater Quality Administration appearing in "Environmental Science & Technology" which deals with this subject. Because of Monsanto's concern over this problem, wo have discontinued sales of FCBs except for use as dielectric fluids in electrical equipment and components. If you desire te continue purchase of these products from Monsanto, please have the attached copies of agreement signed by an authorize officer on behalf of your company and forward a fully signed copy, together with your most recent audited financial statement and any other information which you feel will assist Monsanto in its evalua tion. a unit at M.ni.nt. Ca--... 137 22 AOH 00 WATER PCB-SD0000010846 I Pag 2 If you hare any questions pleas telephone (31*0 694.2455 or writ`directly to Nr. H.S. Bergen. Monsanto Company, p.o. Box 146X7. St. Louis. Missouri 63178. ' V slnearaly regret any hardships that this daelslon &ay eaus you but It is taken In an effort to continue to oak avallab1 these products for these important electrical applications. Try truly yours. /bi Enclosures Howard Bergen, Director Specialty Products Group Monsanto Industrial Chemicals Co 138 ADM CC2* WATER PCB-SD0000010847 Monsanto m&mmm toteurmut, mmtmts e, 00 N. iHimrt il beets. Mistseri @8I@| MMi 0141 MA'IOOI SPECIAL UNDERTAXING BY PUPlti^SERS OF POLYCHLORINATED BIPHENYLS Monsanto Company ("Monsanto") manufactures certain poly chlorinated biphenyl products ("PCB'a") which __________ __________ ("Buyer") desires to purchase, while Buyer desires to purchase PCB'a because of certain desirable flame resistant and insulator properties. Buyer acknowledges that it is aware and has been advised by Monsanto that PCI's tend to persist in the environment; ' that care is required in their handling, possession, use and disposition; that toleranee limits have been or are being established for PCB's in various food products. Monsanto has therefore adopted certain restrictive policies * with respect to its further production, sale and delivery of PQ's. including the receipt of undertakings from its customers as set forth below, and Buyer is willing to agree to such undertakings with respeet to sales and/or deliveries 9 b - by--Moftianto "*tt>: 3uyeft:?',-.*'- ***!* -<*u** Accordingly. Buyer hereby covenants and agrees that, with respeet to any and all PCB's sold or delivered by or on behalf of Monsanto to Buyer on or after the date hereof and in consideration of any such sale or delivery. Buyer shall 'defend, indemnify and hold harmless Monsanto, its present, past and future directors, officers, employes and agent*? from and against any and all liabilities, claims, damages, penalties, actions, suits, lossfs, costs and expenses arising out of or in connection with the receipt, purchase, possession, handling, use, sale or disposition of such PCB's by, through or under Buyer, whether alone or in combination with other substances, including, without implied `limitation, any contamination of or adverse effect on humans, marine and wildlife, food, animal feed or the environment by re a sen of such PCB's. el CuMKf 139 AD H GOi^t WATER PCB-SD0000010848 I c 2 - All axis tin? contract! for tho sale of PCB'a by Honaanto to Buytr art hereby amended to contain tha proviaiona aat forth abova. . nothing harain ahall craata or imply any duty or obligation of Monsanto to aall or dalivar any PCS'a to Buyar. mo condi tion!, understandings or agraamanta purporting to modify or . vary tha tarma haraof ahall ba binding unlaaa haraaftar mada in writing spacifieally rafarring to thia agraamant and aignad by tha party to ba bound and no modification or variance of tha abova undertaking ahall ba affected by tha acknowledgment or acceptance of any aala document, purchaso order, shipping instruction or ether forms containing terms or conditions at variance herewith. 1 *i*.*e % rf-sj, * BY: TITLE: BATE: (Buyer) MONSANTO COMPANY BY: frvf.a .at** O ADM COJfc 140 WATER PCB-SD0000010849 Mr. Paul DePaleo* Jr* I Regional Administrator U.S. Environmental Protection Agency Region ZX 100 California Street San Francisco, California 94111 Dear Mr* DeFaleoi 1 have been asked to respond to your letter addressed to Mr. I* J. Bock, asking for certain Information regarding sales of polychlorinated biphenyls by Monsanto and Central Solvents and Chemicals in the Los Angeles County area. Z know that you have die cussed this by telephone with Mr* W. 1. Papageerge and Z have reviewed the situation with him. the niMi o our custeMrt Vor the product, wo ' nor the quantities of products these customers , purchase. We consider this to be proprietary informa tion and therefore hold it confidential. Consequently we do not feel free to comply with your request for data on customer name# and quantities purchased. On the other hand, last Moves&er we did release to governmental agencies, Including the SPA* Monsanto's total production and sales figures on PCB's for the years 1960 through 1911* These statistics have been released publicly and earlier this year we discussed them in detail with members of the scientific tI I 4141 141 AOH 006163 WATER PCB-SD0000010850  I -1 J - e ! I tI l I J J Mr'. Paul DeFaleo* Jr. March J, 1172 Page 2. -xs&ammity iad with rtprsatafeivas of th WMhLagtoa sulti-agency" PCS task fore @f which if* ia a member. For your ready reference Z as enclosing a copy of this Infojsatioo. W ertmialy share your concern aad Iair# to control, ths discharge of FC8*s into th environment. St is because of this eeneera that w implemented a profm of @lfijiposti curtailment of sales of these products so that now we are oaly offering continuing supplies for closed system dielectric applications where the potential d&ager of environmental eentaainatiea is carefully controlled. Furthermore# as another step in safeguardinf the environment we have informed all easterners of PCS materials of the potential dangers should these materials escape and have strongly urged them to take every precaution to prevent losses through spills, usage, leakage, disposal, vaporisation or otherwise. Z regret we cannot comply with your reguest for customer information but if w* can be of assistance to you in other ways we will be glad to visit you or your designees to discuss th Pd situation further. I incerely. , . ,, W 1. Corey. Director . Functional Product droops /it. Enclosure eei Mr. Charles B. Sewer/Monsanto142 142 OCoiev WATER PCB-SD0000010851 MITsum Sin MONSANTO CHEMICAL COMPANY MM iMIMll ------------ .Tokyo T* ` r' * .*. * . V. * J R Du7^S -V. * Cor V--7'" -.*PCB IN JAPAN " - . , . * <> .. * V. 5t. Lojrts : * . epic) - * % / . - Br? 'Marsh. -.* ; (chard " - St. 'unch -?I - jeorge- 8 - r:*-... a. ....* Colerean -*New I . ,, ..., - . r;. Vl:/ - r. '. : ; * *i i "..V Sear Paul: M t A -1 are pleased to answer your questions in your letter ' of March 20, 1972. * /. e . The-Ministry of International -Trade- and -Industry.-(Mil 1 ` > issued notiefe yesterday--to almost4 every industrial r i: association concerned, as suremarized*in the following * ' a*. No-electrical machinery and equipment which r contain*4 PCB must be manufactured-after Sep?'* '1972. . - - b.* `No heat - exchange equ'i-pmentr must -be produced * 4 after-July 1, 1972 which -use PCD4as a-transit *.* r1- . medium. . 4. *. ' c. .Exceptions to the above are those- which are- V; 4 sold to the specific users and which can be - . '* -1 7- returncd.*after njse-to the 'producers orrmanu.t. * * facturers-for :PCB "disposal*.: They reustrr." 4 periodically report-to the>ministry how PCB-* .* . is used,-shipped, stored, -recovered, returnei and -disposed,, including machinery- in additi< T.: 4... to -the quantity dealVTVith .and so and so for - */ - `SSVfery user-of-PCB-contai-nlng -machinery-a nd-a equipment-wilT-"haverto .be -recorded -and-regis in the. official "list `to- insure strict superv ** " in the -future.. *' * m d. Import -of such machinery and.equipment will possible-only-4.f permission -Is granted by_*h Government^ after`September 1, 1972.- 4 i . ePCB containing machinery and equipment alrea in use must be Identified and reported to th authorities so that the disposal of PCB is t ' - be made complete..- . * looas? 143 WATER PCB-SD0000010852 You will understand that the above action is not the* total* * ban of PCS usr.se. However, who can meet such stringent regulatory requirements to continue'using PCB, other than *. son-civil organisations?ki `s ?^ V called the M1TI yesterday to learn the following:.> * *' * \* The MITI foresee by the action taken yesterday'thfe ** * t**e of PCB fluid will be limited in the near future to the transformers used by .the Japan National-. * Railroad and certain electronic parts In missiles belonging to the Defense Ministry,* in addition to '* the high voltage electro-furnace capacitors as a possibility. . ... * * * 2. Thermal transfer systems with PCB will sooner or later undergo change in fluid or-the whole line will have to discontinue operation. . 3. Xaneka agreed to follow the recommendation by the MITI to discontinue the production .of PCB, probably after September of this year. .* 4. Those who are able and obi iged to use PCB will have III to import PCB, possibly from Bayer,wwith permission from the Government.. * You rightly pointed out that the actions being taken by the Japanese Government appear out of line from the Test of the world today.- I can agree -to Mr. Terasaki's statement . in this respect that the folks go all the way when they decide to do something in -this country.. I -think?-the la.test- happening- sensationally*, moved the--: 'Government- to 4his .direction - the analysis .of. mothers milk in Osaka showed PCB level of 0.7.to 0.1 PPM, as against the FDA*s 0.2 maximum level' fbr-cows' milk.. In the Diet ' commit tee-the Welfare Minister was .at* a .loss when "asked if-- or not babies tan* drink.`mi-Hr.wi-th-^O.^ PPM'-PCB. without - any-* danger to their healthy growth. You might recall Yodo River "flows from Lake Biwa to Osaka Bay. Two capacitor plants are- located by jthe- Lake-Nichicon's and Kisshin Electric's'. Samples of the. soil were taken from the vicinity.-of Nichicon^to run analysis -of PCB with an - unfortunate result showing. 1,000 PPM PCB!-: . e ** .. * * ' 144 *10002* WATER PCB-SD0000010853  " . . * People associated the contamination of the soil with the mothers * milk case. Thus *Kichicon Vas forced to announce last week that they plan to discontinue production of PCB capacitors, after coming September. .* 4 m Today the* world seems to be ruled by feeling and not reason. The fessure against PCB usage is.far from logical. it is* quite emotional and--at the same time political, It was this pressure that led Xaneka to the discontinu2 ation. .- It has not fceen 100% confirmed but I think you may rest * assured *Kaneka will not go after overseas markets after the fall of this year, although they are exporting substantially today. . . . . The grand funeral of PCB in Japan is close at hand. Y.*hat .will replace PCB 4n the dielectric- markets is yet known to nobody exactly.* We only are aware a number of products . ranging from silicone to polylsobutane, wax.and DOP are competing.* The strongest -candidate on `the-longer term . basis seems*t"me innovation. entirely-- - new sy~ stems afte r technological-* * *& T wish you good luck.* . /0 * *. a * e TK/ym -. ' * . ' * T. Katayama - t P.S.-Just before. 1 had-this- letter typed, Xaneka. announced . -- . that1 the*y detideB to discontinue-the production of--- . * * Xaneclor-by-.the. end of--June,- which.was.confirmed by . * myself today, with Xaneka. . .. * " * Also Kichlkon was forced-to -terminate the Jr production of -' PCB capacitors at the end. Of- April. * . ' - * .* - - 145 Nj -10 0 3 WATER PCB-SD0000010854 Monsanto 6S9B8&0V9 CK0UgrftiA& CNSHCM'S SB. 00 0 0,i*,ra 81 taw*. Unm OHM NM (SMI M4l000 April, 1972 Dear Sir: Since early 1970 we have been advising your company of signifi cant developments relating to the polychlorinated biphenyl (PCS) environmental situation. . As ycu know, many pollution control agensiei conduct monitoring programs to evaluate the presence and impact of many materials on the environment. Some of these programs Include PCS. . Recently a representative of a governmental pollution control agency contacted Monsanto requesting information concerning ?C3 sales. Specifically, he asked for names and addresses of ?C3 customers in his area, with the quantities of PCS product sold to each. He stated that this information was being re quested because significant amounts of PCS were being detected ir. the discharge from sewage treatment facilities in his area. He was informed that Monsanto considers information of this type confidential and, therefore, does not disclose it outside the Company. Me subsequently informed us that the request for information was being sent to the local federal district attorney for appropriate action. As we have pointed out on numerous occasions to representatives of government and of private groups Monsanto has long had a policy, which it continues to follow, of treating information concerning its customers as confidential information. However, you should be aware that, because of governmental or judicial orders or requirements or because of a change in circumstances resulting from the unique nature of the PCS problem, Monsanto may at seme future date be obligated to disclose such informa tion to qualified persons.146 146 WATER PCB-SD0000010855 I 2 We wish to strongly re-emphasize with you the Importance of avoiding direct or accidental FCB contamination of feed* food and packaging material and of preventing FOB'S from escaping into the environment. We direct your attention so the recent FDA notice of proposed rule making on FOB'S published in she Federal Register* Vol. 37. No. pp 5705 end following* dated March 18* 1972. If FOB'S arc still present at your locations you are urged to thoroughly review your procedures and Inspect your facilities to Insure that extreme care is taken in the handling* use* storage* and disposal of these materials. Sincerely* W. 9. rapageorga Manager Environmental Protection WATER PCB-SD0000010856 Monsanto meutmtM, mmou m. 00 N. le.ievere Ik Ihii, MittMri aatee , * 0141 M>I000 July 13. 1973 Dr. Martha Sager, Chairman Effluent Standards and Water Quality Information Advisory Committee Environmental Protection Agency Room 821, Crystal Mall, Building 2 Washington, D.C. 20460 Re: Effluent Standards and Water Quality Information Advisory Committee Agenda and Notice of Public Hearings Federal Register, Vol. 38, No. 116, Page 11868 Monday, June 18, 1973 . Dear Dr. Sager: Monsanto Company, as an Interested party and a manufacturer of polychlorlnated biphenyl (PCB), would like to take this opportunity to share with the Comittee, and present for the record, our experiences regarding the manufacture, sale and handling of FCB and lta relationship to the environment. ( will be helpful to the Committee and the Administrator when proposing effluent standards for toxic pollutants. BACKGROUND Monsanto Company has been a major manufacturer of chemleal products since 1901. These products are used in numerous American Industries, and In fact, through our research department, we have played a role In developing new pro ducts to meet the needs of Industry and the consumer. On some occasions a chemical compound with specific pro perties la developed to meet a need in a certain applica tion. In other cases a chemical compound with unique properties Is developed first -- possibly through innova tive research or even by happenstance -- and then an enduse Is found. Hit Uhimi* Claim ADH COilii 1,4 WATER PCB-SD0000010857 Pr. Martha Sager July 13, 1973 Page 1 the chemleal atrueture of PCI has been known for nearly 100 year*. It was not until the late 1920s that a use for FCB was found -- as a dielectric fluid In transformers and capacitors. The properties of FCB -- Inertness, fire resistance and a nonconductor of electricity ~ seemed to be perfectly suited to these electrical applications where high-voltage arcing could occur, possibly resulting In serious fires or damage to the equipment. Monsanto began commercial production of FCB in 1929. As . the unique properties of the material became known new uses were found. For example, their fire-resistant nature made them excellent choices for use In heat-transfer fluids. Their Inertness gave long-lasting qualities to lubricants. Their use In surface coatings Improved waterproofing characteristics. .. * Handling of the product at the manufacturing level has not presented problems so long as the proper Industrial hygiene practices were followed and FCB has always been considered less hazardous than many other chemicals in everyday use. . Therefore, It appeared that FCBs were a very suitable product which met the needs of .Industry. Late In the 1960s, sophisticated analytical procedures were developed which could detect very minute quantities researchers discovered that FCB could possibly be affecting certain forms of aquatic, marine, terrestrial and avian wildlife. ' The persistent nature and stability of FCB, while so de sirable from the standpoint of many Industrial applications, appeared to be undesirable In terms of our environment. INDUSTRY ACTIONS * When questions about the effect of FCB on the environment . first surfaced, Monsanto Company reviewed Its product line and the applications for these products. As more'data were developed and the environmental controversy grew, Monsanto took steps intended to reduce the entry of FCB Into the environment. The company stopped the sale of FCB for use In various applications, except where no acceptable alternatives were available. ACM 0C2269 149 WATER PCB-SD0000010858 Dr. Martha Sager July 13, 1973 Page 3 Today, PCS manufactured by Monsanto Company la aold to the electrical Industry where It la used In closed systems as a dielectric fluid In transformers and capacitors -- applications for which we understand there continue to be no acceptable substitutes. . Our manufacturing and sales reduction program was a uni lateral action taken by Monsanto and was based on our evaluation of developing environmental data. Recognizing the need for proper controls In the handling and use of RGBs, representatives of the transformer and capacitor industries, utilities, and governmental agencies under the initial auspices of the National Electrical Manufacturers Association formed American National Standards Institute Committee C-107. A copy of the Committee's recently Issued proposed guidelines for the handling and disposal of dielectric fluids is attached. These guide- lines reflect the Industry's understanding of the need for proper control and should contribute significantly toward this objective. TOXICITY IN FERERSCTXVE In Section 502 (13) of the current Federal Water Pollution Control Act, the term "toxic pollutant" Is defined as "those pollutants or combinations of pollutants including disease causing agents, which after discharge or upon exposun organise by Ingestion through food chains will, on the basis of in formation available to the Administrator, cause death, disease, behavioral abnormalities, cancer, genetic muta tions, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such organisms or their offspring." . While the breadth of this definition can be so construed as to permit the inclusion of many substances on a list of "toxic pollutant(s)," we concur with the recent suggestion of the ERA'S Acting Administrator (Federal Register Vol. 38, No. 129, page llCm) that Congress Intended the Administrator under the Act "... to be selective in determining Which of the potentially large number of candidate substances ADK CC229C150 150 WATER PCB-SD0000010859 I Dr, Martha Sager July 13, 1973 Page U actually ehould be listed at various times." Although not spelled out In the definition. Me feel It Important to consider the degree of toxicity of the substances differences in biological species' sensitivity; and whether or not the substance poses a threat to man, animals, birds, the aquatic environment or some other aspect of the ecosystem. For example, there is a material difference between the threat to human health posed by equal amounts of the "cyanide Ion" and "PCBs," both of which substances appear on your proposed list of pollutants. We feel certain the members of your committee will agree that these two substances should not be considered on the same basis merely because they are both suggested for inclusion in the same list. ' We trust that comparative differences in the potential hazard to health and our environment of the various sub stances proposed for your list will be an important factor in your deliberations and determinations. On the basis of available evidence. It would appear that PCBs pose less of an acute toxic health hazard than many substances not proposed for your list, and at the levels found In the total environment are rot a threat to public health. We believe these views agree with the conclusions reached by the Interdepartmental Task Force on PCBs In Its report dated May, 1972 (CCM-72-10^19). We sincerely believe, because of Monsanto's sales policies discussed elsewhere, and actions of others throughout the world, that the levels of PCB In the aquatic environment are even lower now than at the time the Task Force report was prepared. . BIODEGRADATION '' A valid assessment of the environmental impact of poly chlorinated biphenyls must Include consideration of the persistence of these materials. Certain reports have been made that FCBa'are non-degradable. However, although much work remains to be done, an analysis of available information and information from studies by Monsanto Indicate beyond any reasonable doubt that the many PCB AC* 151 WATER PCB-SD0000010860 I Dr. Martha Sager July 23* 1173 PH 3 isomers degrade In the environment at different rates This information indicates that under the proper condi tion* of use and control, some of the cossnerclai pcBs, which are mixtures of several isomers, can be utilised and their safety benefits can be realized without serious adverse consequences to the environment. Xn May, 1972 we shared with members of the Federal inter departmental -Task Force on FCBs the results of studies of residual FCBs in animal tissues and biodegradation by activated sludges. A copy of this presentation is attached for review by your Committee. Articles describing in more detail the results of the degradation studies in activated sludges and soils are being prepared for publi cation. Copies of these reports will be mailed to your Committee when they are completed. EFFLUENT STANDARDS . She worldwide Interest in FCBs and their environmental Impact has resulted in an abundance of published articles. To assist the Committee we have attached a bibliography of some of the pertinent literature, copies of selected articles and a copy of the Interdepartmenta1 Task Force report. This report, in our opinion, is an excellent reference document and we recommend it to the Committee as a valuable source of information as you consider possible effluent standards. . . Although much has been published, much more scientific information is required. This critical need for more knowledge was recognized by the Task Force and is high lighted in its report under "Findings, Conclusions and Recommendations" It is our considered opinion that in the absence of critical basic scientific data any attempt to establish a FCB stan dard for water effluents at point sources would be pre mature at this time. Fending the availability of the data which would contribute to the establishment of a realistic effluent standard, it is appropriate to consider that the restricted use and proper control of FCBs have and will continue to result in a diminished Impact on the environment. Further more, the recent ruling by the Food and Drug AdministrationiSi Ac* C023S* iSi WATER PCB-SD0000010861 I Dr. Martha Sager July 13, 1973 Page 6 (Federal Register, Volume 38, Number 129, July 6, 1973) provides for temporary FOB tolerances in food, animal feeds and food packaging materials, thereby limiting exposure to humans and domestic animals. Ve appreciate the opportunity the Committee has provided for Interested parties to contribute Information, if you have any questions concerning our comments or any of the attachments we will be pleased to supply further explana tions or Information upon request. . a 0 . Respectfully submitted. WBP/bt Enclosures W. B. Fapageorge Manager Product Acceptability a ACH CC2393 153 WATER PCB-SD0000010862 MINUTES OF MEETING ON PROPOSED PCI EFFLUENT STANDARDS February 28, 197^ Monsanto Coapany St. Louis, Mo. * AOH 007276 154 WATER PCB-SD0000010863 Chairman* Mr. V. 1. Papageorge Manager, Product Acceptability Monaanto Industrial Chemicals Co. Objective* The purpose of the meeting was to share Information, experiences and Impressions to help each of the participating companies In taking appropriate actions which are mutually supportive and effective In persuading the Administration of ZFA to modify the proposed PCS Effluent Standard.155 AJH 007277 155 WATER PCB-SD0000010864 PARTICIPANTS PCB STANDARDS MEETINO February 26. 1974 CERTIFIED BALLAST MAOTFACTOTERS Mr. N. R. Clark Universal Manufacturing Co E.I.A Mr. Arnold S. Doty Dr. E. M. Moore Mr. Rudy Carlson P. R. Mallory ft Co., Inc Electrical Utilities Co. Electrical Utilities Co. GENERAL ELECTRIC COMPANY Mr. James S. Nelson Mr. Stuart Rlchel Dr. Edward L. Simons JARD COMPANY, INC. . VRTfhl T*"*"*** t Itvrt NATIONAL EZECTRICAL MANUFACTURERS ASSOCIATION (NEKA) Mr. A. M. Salazar VESTINOROUSE CORPORATION Mr. E. Sheppard Mr. N. 1. Smith . asm. AJM OOlile 156 WATER PCB-SD0000010865 c IfONSAWT COMPAKY P. 0. Benlgnua H. S. Bergen D. B. Bosmr R. H. Nuacb V. B. Papageorge V. W. Vlthera C. Pates V. R. Richard J. R. Savage c . S. Tucker P. I. Wright \ V -SWi* . 2 Market Manager Builstii Director Utliltlea and Environmental Protection Director Senior Science Fellow Manager, Product Acceptability Attorney Product Manager Manager, Reaearch and Development Manager, Manufacturing .. Reaearch Oroup Leader Manager, Toxicology ^*.*'***.%* iirMv-har-Trer c AOH 007279 157 WATER PCB-SD0000010866 AGENDA PCB IFPLOEHT STANDARD MEETING February 28, 1974 9:00 AM 1. Welcome B. S. Bergen 9:10 AM 2. Introductory Remark* - W. B. Fapageorge m. Brief Review of Proposed Standard b. Critical Action Bates c. Objective* of Meeting 9:25 AM 9:45 AM 10:15 AM 10:30 AM 11:30 AM 12:00 Noon 12:30 PM 1:15 PM 2:00 PM 2:45 PM 3:00 PM 3*30 PM 4:00 PM 3. Discussion Topics a. PCB Characteristics - Realistic Definition chemical, physical, biodegradation ' b. Sampling and Analytical Methodology Break c. Toxicity Acute Chronic d. Bloaccumulatlon - Blomagnlflcatlon e. Dilution - Stream Size Lunch i f. Proposed Effluent Standard I* Control at Manufacturing and Use Sites Current losses Background Break h. Sconomlc Considerations 1. Action Plans Adjourn ADH 00726J 1S8 WATER PCB-SD0000010867 ) MINUTES OF KB EFFLUENT 1TANDARDS PBBTDIO 1. Hr. Howard S. Bergen, Jr., Director, Specialty Products Business Group of Monsanto Industrial Cbeolcals Company, welcomed the participants. 2. Introduction - V. B. Papageorge Mr. Papageorge aummarlzed the timetable past and future on toxic pollutants: July 6, 1973 - Toxic Pollutants Hat published ' September 7, 1973 - Pinal toxic pollutants list pub lished including PCBs and 8 other chemical classes (e.g, cyanide, mercury, BUT, cadmium, etc.) December 27, 1973 Proposed Effluent Standards published January 18, 197* Piling date for status as participant at proposed EPA Hear ing on Standards January 25, 197* (l) Prehearing Conference with EPA (11)- NEMA, Monsanto, O.E. and Vestlnghouse recognized as participants. (ill) A total of 38 objectors ex pressed an Interest. They represented Industry or trade associations with the exception of the Michigan Water Research Commission and two powerful environmental groups (Environmental Defense Fund and National Resources Defense Counc11). (lv) Presiding officer made It clear ihat hearings wlTl be strictly for cross-examination of participants 1 testimonies In affidavit foraonly. 0072 c 1 159 WATER PCB-SD0000010868 March 15, 1974 - Written testimony by 38 objectors to be eubmltted lrTarridayTt fora/ April 8, 1974 - Hearings open for cross-examination and rebuttal evidence. CW/Cd/Hg . first three. PCBs are 7th (third from last). Mid-May, 1974 - Hearings completed. (Evenings/week ends may be used.) June 25, 1974 - Final standards published - effective In one year. It should be noted that others who are affected by these standards can still comment by March 25 to: .... Dr. C. Hugh Thompson, Chairman-Hazardous and Toxic Substances Regulation Task Force Office of Water Protection Agency, Environmental Protection Agency Washington D. C. 20460 Industry representatives still wishing to comment and who need more background Information can contact any of the industry participants (see attached list) or Mr. W. B. Papageorge of Monsanto (314-694-4051). Mr, Rlchel (O.I.)s (1) (ii) Made a plea for greater Industry participation. Comments can still be made up to March 25 with sound excuse for tardiness. i EPA at January 25 prehearing Conference were reluctant to expose themselves to cross-examination* Dr. Hugh Thompson to be available for cross-examination at Hearings. (ill) Many objectors had common interest (e.g. environmentalists). EPA suggested a common counsel for this group. (iv) On each of first 3 pollutants, EPA would offer 2 witnesses. Mr. Doty fP.R. Mallory) asked about bearing of economic factors bn standards. ' Mr. Rlchel (O.E.) stated: . (i)Law is clear-economic factors are not relevant in establishing standards. (ii) EPA is somewhat of a split personality on this. The ADM 007232 160 WATER PCB-SD0000010869 3 Presiding Officer at the Prehearing Conference ruled that economics are relevant, NRDC (National Resources Defense Council) objected and was over-ruled. (ill) Industry can and should therefore Introduce relevant economic data. EPA would be wise not to expressly refer to ouch data in the published standard otherwise NRDC could go to court and EPA over-ruled. Department of Commerce It was pointed out that Sidney R. Oallier, Deputy Assistant Secretary for Environmental Affairs at the Department of Commerce wrote Monsanto on January 15 asking their views on the proposed effluent standards. Copies of Dr. Oallier'a letter and Monsanto's response were circulated at the meeting. Industry should contact the Dept, of Commerce. Their legal counsel (Mr. Norland) has been active on the aide of industry in other environmental hearings. Mr. Salazar (MIMA) pointed out that the PCS Task Force had recommended a standard for PCBs of 0.01 ppb in the main body of water. (EPA was a member of that task force). ANSI -119 proposes to use this Task Force recommendation and print this as a standard of 0.01 ppb In main body of water. Mr. Sheppard (Vestlnghouse) queried if plant effluent standards could be sec to meet o.oi ppb. Dr. Simons (O.E.) said this implied an acceptance of ANSI C-119 by Industry. There seemed to be some doubt on this.. PCB Characteristics * Dr. Tucker (Monsanto) presented hand-outs on: ** (a) Monsanto's proposed definition of PCBs ' (b) Comments on EPA'a proposed analytical methodology (c) Monsanto's pre-publication paper on biodegradation of PCBs. (a) Definition of PCBs 1-h chloroblphenyls do not have long residence time. PCBs up to tetracbloroblphenyl are not of concern on environmental persistence or blomagnlflcatlon. Dr. Tucker proposed the following definition: AO* 0072*i 161 WATER PCB-SD0000010870 "Polychlorinated biphenyls (PCBs) aeans materials containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaccumulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than 54, relative to p, p-DDE * 100, under the standard con ditions recommended in the SPA FOB test method." . Hr. Sheppard (Vestlnghouse) said Monsanto's proposed definition was relevant to persistence but was it relevant for atandards directed toward toxic materials? Are persistent materials non toxic? Hr. Wright (Monsanto) stated the proposed effluent standard had two parts: (l) acute limits directed to toxicity of materials and specifically limits PCS concentrations on that basis. (ll) dally load in effluent - based solely on bio magnification (relevant to persistence). Dr. Simons (0 .) pointed out that section 307-A of the proposed standard refers to persistence as being a critical factor to be considered. Dr. Tucker (Monsanto) stated we were badly hurt If all PCBs are regarded as persistent and If blomagnlflcatlon factors of 200,000 are used. Researchers other than Monsanto have found bacterial degradation of PCBs and that PCBs have been found to 't'uhd%r,fQrl,m>dtabdi'iWBfwln-both^avlaitaTr-aiid-:ttmallAn^anlnala^er^..rMK^ s# Mr. Kelson (O.f.) asked if proposed PCB definition would exclude Aroclor 1016. Dr. Tucker (Monsanto) Aroclor 1016 would be excluded for the most part 1^0.95 is lower than pentachloroblphenyl) Aroclor 1242 would be excluded to 65% or better. Aroclor 1254 however would not be excluded. * Mr. Papageorge (Monsanto) pointed out that of the factors listed as being critical in determining which pollutants made the 1PA list of 9/7/73 only blomagnlfleatlon appeared relevant to PCBs. Dr. Simona (O.E.) agreed. ADM 0D71S*162 162 WATER PCB-SD0000010871 5- ) C Mr. Wright (Monsanto) stated that an scute toxicological level la defined in the EPA Basis k Purpose document as c 10 ppm (96 hour LC-50). He also believes that differences In toxicity among PCBs are minor until chlorinated as high as Aroclor 1260. Hr. Kelson (O.E.) stated that words should be used in a dis course on definition to properly screen us on acute toxicity. In reference to a comment that Aroclor 1254 would not be excluded by the proposed definition. Dr. Tucker (Monsanto) offered the opinion that transformer fluids were easier to re cover than capacitors. (b) Analytical Methodology Dr. Tucker (Monsanto) stated the EPA's proposed method for PCB analysis was being submitted to ASTM. He thought the method was well written and capable of detection to ppt (parts per trillion) but it was untried and the quantitative accuracy is in question. The method was not submitted for round-robin testing before EPA adopted it. Honsanto has found that by spiking distilled water with 500,000 ppt or 500 ppb of PCBs we get values for PCB that vary by x 552*. The EPA, however, claims a capability of detecting absolute values at 50 ppt. The EPA method ignores interfering substances. ( Hr. Clark (Universal Manufacturing) said that with a proposed upper limit for PCB discharge of 0.0648 lb./day the sensitivity of the analytical method would vary "all over the lot" depending on the size of the water "reservoir" into which the PCBs dis charge . Mr. Sheppard (Vestlnghouse) commented that If the analytical techniques on determining PCB levels are so difficult, how valid are the determination of toxic values for PCBs. ` Hr. Clark (Universal Manufacturing1 asked'if analytical techniques differentiate between different chlorine levels. Dr. Tucker , (Monsanto) said it would depend on the PCB mixture. Aroclor 1242 could probably be identified quantitatively in a mixture with Aroclor 1260 but addition of Aroclor 1254 to the mixture would prevent identification because Aroclor 1254 contains PCB homologs that overlap both Aroclor 12#2 and 1260. Dr. Hunch (Monsanto)said that the proposed EPA method does not use high resolution and hence handicaps identification of . individual peaks. Dr. Simons (O.E.) mentioned that after EPA set automotive emission standards (NXOX) the analytical methodology was found faulty and the standards were delayed. In this ease, EPA is not setting the effluent standard on analytical methodology but163 163 WATER PCB-SD0000010872 on factors such as toxicity and persistence. She methodology Is relevant In enforcement and monitoring. This then leads to the possible argument that the effluent standard is correct and Justified on the basis of toxicology et al, but Is not enforceable due to lack of an accurate method for absolute value deter mination of PCB discharge. Hr. Blchel (O.E.) pointed out that SPA won't buy an answer to that argument which seeks to raise the effluent standard to a level that can be accurately measured. Mr. Savage (Monsanto) felt strongly, however, that this dilemma needed to be In the record. Others agreed. * Pr. Tucker (Monsanto) said ASTM would hold a round-robin on the Spa method and that Monsanto would participate. Be will aend the name of the ASTM contact to the participants so that they can decide if they want to Join the round-robin test. Mr. Sheppard (Westtnghouse) said he was not prepared to accept that the proposed epA method for determining quantities and types of PCB in samples and animals was accurate enough so that toxic limits could be defined on the basis of PCB levels of question able accuracy. Toxicity Mr. Boomer (Monsanto) stated that the original 1PA publication on Water Quality Criteria came from a publication by McKee and Wolfe for the State of California. The McKee/Wolfe volume was well done and EPA did not change much of it. There is now a new 2-volume EPA edition extracted from the work of 10 committees of the National Academy of Sciences. . The toxicity of PCBs is related to salmon egg studies and Monsanto doubts the validity of this. Monsanto has made their * lefcTffi$s,*fcjWi#tf `tb'^rv`iThtffilpsohr*of^SPA -bufc-hr'thought-iihe^ criteria were sound. Since then Russell Train "has been sued by NRDC and other groups on the grounds that the toxic pollutants list is not long enough and the proposed standards are too len ient. . Mr. Wright (Monsanto) went through the rationale used by EPA in arriving at a PCB discharge maximum of 0.0646 lb./day. He also shoved how the standard could be changed and yet be consistent with published data on PCBs. Details follow. ` (a)FDA set arbritary proposed tolerances: 5 ppm in fish for human consumption 5 ppm in components for animal feed 0*5 ppm in complete animal food OOl*'164 *0* 164 WATER PCB-SD0000010873 (b) Monsanto would not disagree with thsse tolsranees. (c) FDA has presented - acute toxicity limits (point sources) * chronic toxicity limits (dally load) Acute toxicity limits: 9& hour LC-50 studies for PCBs show: *80 ppb in fresh water (blueglll) ~10 ppb In coastal or seawater (pink shrimp/oysters) Published data based on materials leaving an outlet and going into a body of water. Acute limits have no direct relation to chronic limits. Chronic toxicity limits: The EPA equation is: Chronic limit X water flow rate X safety factor gm/day discharge Zn Marine organisms the chronic limit is set ms 0.0167 PPb In fresh water the chronic limit has been determined by using 0.5 ppra as toxic limit for salmon eggs and a 200,000 biomagnlflcatlon factor. This gives a chronic limit of asta iron oia-iaing m neyer (run resucioe ubd, u. s. Interior, Colombia, Mo.). Dr. Simons fa id that in response to repeated requests by 6.1. to the Columbia Lab the only reference they have been given is a Stalling & Meyer paper presented in - Carolina in 1971 and which contains no mention of a 200,000 factor. Mr. Wright (Monsanto) stated he has seen only one literature reference to an accumulation factor of --200,000 and that was in the hepato pancreas of a pink shrimp. If the PCB level was calculated on the basis of the total shrimp then the accumulation factor was only 22,006. Other references give accumulation factors of 1000-75#000 for whole tissues of various fresh water organisms. Accordingly, Mr."Wight proposes that a blomagnlflcation factor of 307000 and not 200T00o~be used, fie also proposes that we retain~cT>e chronic limit of"U75 ppm with; out..debating the salmon egg issue. 1 AOH 007267 165 WATER PCB-SD0000010874 } -8- ftila would load to a discharge level for FCBs: ^5_ X. 10,000 X 0.5 % X 5.4 O.M59 lb ./day 50,ooo (flow rate! (safety factor) (conversion . Into lb./ day) This compares to the proposed standard of 0.0648 lb./day. The safety factor cones from the EPA's Basis and Purpose document supporting the proposed effluent standards. It is supposed to take account of non-point sources of PCBs and is the sane as 6 of the 9 toxic pollutants proposed for EPA standards Monsanto's Medical Department, feels this safety factor is arbitrary and confers no real toxicological benefit. Xf deleted, the revised Wright PCB discharge level would be 0.918 lb ./day. One of the most critical parts of the discharge equation is the water flow rate'7 X"TTgnlITcinin5um5eFTriffleIectrlc--FCF'`"""" manufacturers have plants on rivers where the flow rate is under 100 cfs or 1% of the EPA cut-off flow of 10,000 cfs. Several plants discharge into sewage plants which in turn have treated liquid flowing into rivers or streams with very low flow rates. For a river with 100 cfs flow the EPA maximum discharge would drop to 0.000648 lb./day or 0.15g"Tb. in a 250 work-day year. Even a revised standard of 0.915 lb./day at To,000 cfs would only be 0.00918 lb./day at 100 cfs or ^2.3 lb. fer 250 work-day year. Clearly this is a staggering target to ave to meet. Mr. Doty (Mallory) pointed out that in the present language of the EPA standards municipal sewage systems are not considered point sources. Mr. Blchel (O.E.) was of the opinion that where a plant diecharged into a sewage system without treatment and hence into navigable waters the plant could have to comply- with effluent standards on toxic pollutants Mr. Papageorge (Monsanto) felt we should not be complacent and regard discharge to sewage plants being the answer to problems Mr. Hosmer (Monsanto) stated that 10,000 cfs represents the largest flow the E#A will consider on the grounds that all industry would move to the largest river. The opposite of that argument is that it encourages small plants on every stream in the country. Mr. Sheppard (Vestlnghouse) raised the issue of sedimentation. Blnce it appears that all the experiments to establish toxic values were run without sediment effects being considered, the real-life values were questioned. FCBs attach themselves to sediment. Furthermore the sediment moves down river and so PCB would be dispersed from the point source. Xt was pointed out by Dr. Richard (Monsanto) that Aroclor 1254 is soluble in water up to 50 ppb ana that in time partitioning between sediment and AOM 0072 do 166 WATER PCB-SD0000010875 9 water could take place. Mr, Wright (Monsanto) agreed that the discharge limits were extreme.eases...In the absence of eedimenT considerations and this was worth study and incorporation.into arguments against the~proposed levels. .......... ............ Dr, Simona (O.E.) queried whether we were correct In eonceniratlng our attacks on the criterion of toxic effects of mammals eating fish and ignoring the possible argument that fish per se suet be protected. Mr, Wright (Monsanto) said the proposed standard aaya both, limit water, standards are proposed that would protect the species that eat organisms containing PCB. In fresh water. If 0.5 ppm in salmon eggs correlates with <5 ppm in salmon then we are protecting salmon. Be also said that the chronic limits and blomagnlflcatlon limits he was proposing would protect the species themselves. We should, however, beware of arguing fer higher levels In fish because we could draw EFA and PDA into conflict. The PDA level* in food, fish etc., are temporary tolerances and any arguments against their validity could lead to a reduction in these tolerances. Mr. Savage (Monsanto) queried whether raising the level in organisms could cause possible danger to predators. Dr. Simons (O.E.) quoted from page 39 of the Baals & Purpose* document which states that the body burdens of birds and mammals should not increase over present levels. Page 51 of the same document cites a Mat. Acad. Scl. report which gives 2.0 ppm PCB ss tolerable level in flesh of whole fish. 2.0 0.1 ppm PCB 2o6,666 is given as tolerable level in water divided by a safety factor of 5 to give a maximum PCB concentration in water of 0.002 ppm. Thus EPA accepted 2 ppm PCB level In fish but got to water concentration of 0.002 ppm by using a high level of 200,000 for blomagnlflcatlon and an arbitrary factor of 5* l If we were to revise the proposed EPA standard by: (i) using 2.0 ppm ss chronic limit In fresh water species instead of 0.5 ppn; (ii) substituting 30,000 Instead of 200,000 for blomagnlflcatlon factor; mad . (ill) ignoring safety factor of 0.5 then the maximum permissible discharge in lb. PCB per day would be: 2.0 10.000 * 5.4 ~ 3.6 lb. x x* AGM 007289167 167 WATER PCB-SD0000010876 10- Por the plant situation on a rlrer with a flow of only 100 efs the discharge would be 0.036 lb/day or 9.0 lb. per 250 work-day year. These levels are still far below tfie"8""Ib./day given in AR5T"C-107. It Is therefore apparent that other aspects of PCBs must be highlighted In order to set away from FOB discharge levels as low as even our "revised* proposals. Aspects to concentrate on are: (1) Definition of PCBs that excludes biodegradable homologs. This could exclude 90 or better of Aroclor 1016 and 65$ or better of Aroclor 1242. On that basis, discharge levels would be as follows: PCB Type Stream Discharge (lb.PCB equlvalent/day) Plow (cfs) EPA Wright Slmons/Vrlght Any PCB Any PCB Aroclor 1010 Aroclor 1016 Aroclor 1242 Aroclor 1242 10,000 0.0648 0.918 100 0.000648 0.00918 ""10,065------- o.o48 9.1b 100 0.00648 0.0918 "TS700S------- 07154" " "2.75 100 0.0019 0.027 3'6 * 0.036 3&.o 0.36 10.0 0.10 (2) Try to change stream flows from the present value of the flow rate In cubic feet per second (efs) expressed aiTThe"probable low rate occurring during a j consecutlve~day period once in lo years at the effluent point. If the average flow rate over a period of time (to be agreed on) was used, the lowest flow rate In the equation could conceivably be raised by a factor of 10 from 100 to 1000. In the Slmons/Vrlght version for a standard the Aroclor 1016 discharge could be raised to 3.6 lb ./day at 1000 cfs flow and Aroclor 1242 to 1.0 lb./ day at 1000 cfs flow. * (3) Magnitude of PCB Point-Sources It is possible that EPA and envlronmentalists are totally misinformed on the number of plants still using PCBs. In the U.S. today there are: ADM 007290168 168 WATER PCB-SD0000010877 11- 1 1 PCI manufacturing plant --18 capacitor plant! using PCB --27 transformer manufacturing plants using PCB In the past there were probably 1500-2500* plants using PCBs. Only 2-3$ of these plants continue to use PCB today. * (Subject to closer checking if necessary) Xn the past --97Jf of plants using PCBs purchased ~40 million pounds of PCB per year. Monsanto's PCB sales policy has therefore - reduced number of using plants to ~2-3 of previous total. - eliminated --40ft lbs. PCB sales per year. The EPA standard would limit PCB discharge per plant to 0.0648 lb ./day or --32 lb./day across the U.S. ( -- 50 plants). This equates to--800 pounds in a 250 work-day year. Since fish have survived throughout the 40+ years that PCBs have been produced and widely used, the standard proposed by EPA seems far too drastic. Turning again to the Slmons/Vrlght proposal we can estimate the effect In terms of annual PCB discharge Into water across the U.S. at lOOOcfs: Discharge As "'tf5 Total" Discharge ----- per As Persistent PCBs 250 days Discharge No. US (lb ./day)_ Plants (pounds) (lb ./day) Plants Tota: Any PCB 3.6 Aroclor 1016 3.6 Aroclor 1242 1.08 Aroclor 1254 ___ 0.36_____ 1 18 4 8.3___ 900 16200 1080 2070 1.2 1 300 0.36 18 1620 0.36 4 360 0.36 23 2070 20.250 _____________2252. Plant Is on river in excess of 10,000 efs. Using this technique an argument can be made in favor of the ANSI C-107 proposal of 5.0 lb ./day. ADM 007291 169 WATER PCB-SD0000010878 Proposed Effluent Standard! Dr. Simons (6.S.1 summarised the points he felt had to be dealt with in trying to change the proposed standard: 1. Higher persistence of higher PCBs venus alleged lower acute toxicity 2. Background levela of PCBs 3# Written testimony of participants and correlation Toxicity SPA Basis & Purpose document (page 0) states that f hour LC-50 to fish cannot adequately measure toxicity of FCB. Where is time demarcation between acute and chronic. Chronic effects can be either lethal of non-lethal Why are PCBs on the list on toxic grounds? LD-50 for PCB is such that it la not considered toxic to humans For protection of aquatic life the Nat. Aca. Scl. set a 6 hour LC-50 of 10 ppm or less. In proposing a definition for PCBs, Dr. Simons (O.E.) felt we should stress: (a) lack of persistence of homologs below tetrachloroblphenyl. (b) chronic toxicity does not arise for the lower homologs because they are non-persistent. t lgnow*ac^te^-toxloit-y*'no-;Teal*-Td4ffmeBc-=* T.* between Aroclor 1016, 1242 and 1254.- Participants need to consider: Do we have the best definition? In the tentative SPA analytical method we should take note that in the.table on p.3-22~. the percentage of PCB was not controlled. Mr. Carlson (E.TJ.C.) pointed out that In its present form the standard could saddle present PCB users with all other dis continued uses. Dr. Richard (Monsanto) pointed out that PDA and Boxboard Manufacturer's Association had agreed on a protocol that protected recycle paper users from Just such a situation. Mr. Bergen (Monsanto) asked that copies be circulated to participants. . AQH 0072*2 170 WATER PCB-SD0000010879 Ve need to word our definitions to exclude residuals. Participants should exchange proposed drafts on wording re garding residuals by March 7* 0, g. stated we should not approach the bearing on the basis SKat things canrt be done. Rather"talce'the proposed'atandard aid point out what it Beans `in reiiTgF6 In O.E.'a case they use.VTriB./year and jet can't lost 0.5 drops per daj. Stream flow rates stake the matter worse. Tbia Is a point on which Dr. Thompson should be eross-examlned. Of the participants present^ f plants discharge into sewers with outlets into rivers (very small except In 2 eases). Three plants discharge Into small rivers. Ho one at the meeting could cone with the SPA standard as it is proposed. Only Jard expressed an opinion on what level they could live with. (Jard stated 27 lb. Aroclor 1016 per day. This would be 2.7 lb. FCB by our proposed definition.) *-fc t AuH 007293 171 WATER PCB-SD0000010880  Participation at EPA Hearing Definite participation: Honeinto G. E. Veatlnghouaa . Undecided: Electrical Utilities mJamrd Ho participation: Electronic Components Malloty Objectors of record eould adopt non-responding company aa witness. G.E.'a testimony will fall Into the following areas: - Explanation of why PCBs are used - Consequences of ban on customers - Inadequacy of EPA/Hat. Acad. Scl. statements - How standards would apply to G.E. - Inadequacies of the Standard .. - definition - methodology - logic behind the standard Other contributory actions: - Involve Federal Energy Office (e.g. Aerovox letter on motor-run capacitor contribution to ease energy crisis.) f Involve-.F^CU/pthar^gqn$lesaleag- aAAtyy petrochemical producers' FEO report. - Power Systems Group of IEEE will circulate a posi tion paper on PCBs (technical aspects) In the dielectric industry to Congress, SPA, FEO and Dept, of Commerce (target date: April) . ADM 007294 172 WATER PCB-SD0000010881 15 ) Action Plans 1. (V. 2. Papageorge) Circulate to participanta copies of . PDA/Boxboard Manufacturers protocol on PCSa in recycle paper. 2. (Participants) Exchange drafts on testimony regarding PCB reslduals/background levels with each other by March ?. (Monsanto contact should be V. B. Papageorge.) 3. (Participants) Submit to V. B. Papageorge their thoughts on proposed PCB definition (to exclude 1-4 chlorine homologa) 4. (Participanta) Communicate with each other on how beat to handle sedimentation phenomenon (as raised by Mr. Sheppard of Vestlnghouae). 5. (E. S. Tucker) Send out name of ASTM contact for participation in round-robin on proposed EPA analytical method. 6. (Participants) Write to Dr. Caller ef Commerce Dept, opposing EPA standards. (See Caller letter to Monsanto and Monsanto response.) 7. (Participants) Those who have not responded to EPA can at111 write Dr. Thompson by March 25. *t ^ * - &4 ^A,*Salar-#.WP^fPr**,, Edison on the proposed standards. (b) determine role WEMA. will take on affidavits/testimony at EPA hearing. 9. (V. B. Papageorge) Obtain PEC report and send to Mr. Nelaon (O.E.). 10. (Participanta) . Involve F.E.O. In EPA Bearing along lines of Aerovox letter to Secretary Simon. AOH 007295 173 WATER PCB-SD0000010882 e. &t ** Monsanto HeeeiRte *** 00 M. U>M|I Ittlwarl it.leiMS. Hieseuri S3ISS Mtu:OMI 4.1000 March 12, 1974 * -\2> Mrs. Betty J. Billings Hearing Clerk Environmental Protection Agency Room 1019-East Tower 401 "M" Street, S.W. Washington, D. C. 20460 . ` * Re: Proposed Toxic Pollutant Effluent Standards for Aldrln-Dieldrin, t A1 - FJPCA (307) - Docket Ho. 1 Dear Mrs. Billings: . In accordance with the ORDER AND NOTICE of Judge William J. Sv.-eeney dated February 6, 1974, enclosed are the original and three copies of the written testimony with attachments submitted on behalf of Monsanto Company in connection with the above described matter. Yours very truly, PSP/jmd Enc. Senior Attorney 174 100 WATER PCB-SD0000010883 Monsanto MNiurn industmal BMawcau bo. tOO N. Uft6ler* Iselevere il. lU. MtiHwi 13ISS **: bm) 4*tooo 1b It: fROPSSB) T0XK POLLUTANT EFFLUENT STANDARDS FOR ALDRZN8IILDRZN, HM.- TOGA (30?) doom ho. i < State of Missouri ) t County of St. Louis ) 885 W. 1. Papageorge, being first duly tvorn says: My name is V. S. Fapageorge and 1 am Manager. Product Acceptability for the Functional Product Croups, Monsanto Industrial Chesicals Company, an operating unit of Monsanto Company. Z am a graduate of Washington University, St. Louis, Missouri with a Bachelor of Science degree in Chemical Engineering and have received a Master of Science degree in Chemical Engineering from the same institute. Z am a Registered Professional Engineer in the state of Missouri. Z have been employed by Monsanto Company for approximately 22 years, during which period Z have served as an engineer, maintenance superintendent, distribution superintendent, . manufacturing superintendent, plant manager and manager of environmental protection. Zn my present position Z am responsible for seeing that the quality of products produced by two business groups in Monsanto Company is properly maintained. One of the business groups within my area of responsibility is the Specialty Products Business Croup which manufactures and markets polychlorinated biphenyl (PCS) products for use as dielectric fluids in transformers and capacitors. Z am a member, and have served as chairman, of a committee of the Rational Electrical Manufacturers Association which has reviewed the environmental effects of PCBs and has recommended procedures to users of PCBs which should minimize the possibility of entry of PCBs Into the environment. 4ii il Himimi Cemetnv 175 .10039 WATER PCB-SD0000010884 :w MOKSWTO CBMPUn'S fOSITIOK ASP KCKtgSBATlOSS > As a major producer and supplier of polychlorinated biphenyls (PCBs) to the electrical Industry for fire resistant dielectric fluid applleatlo&s, we have reviewed and evaluated the effluent standards for these materials la proposed Part 129, Subpart I, Chapter Z of Title 40, Code of Federal Regulations. Pursuant to this review, ve submit the following comments and recotmaandatloas: 1. The proposed effluent standards for PCls are unwarranted and practically and economically unattainable. 2. Actions by Monsanto and its customers, which have resulted la limiting the use of PGls only to electrical applications In hermetically sealed units, have dramatically reduced the quantities of the more persistent PCBs Introduced directly into the environment. .` 3. The definition of PCBs In Section 129.09a, Subpart Z should be changed to read: "Polychlorinated biphenyls (PCBs) means materials N containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaecumulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than 60, relative to p.o-DDE100. under the standard conditions recommended in the EPA PCS test method." 4. The accuracy and reproducibility of results attainable between laboratories using currently available sampling and analytical techniques are questionable and further studies are recommended. 5. The proposed PCI effluent standard is based on inadequate toxicity information, on non-typleal fish species and on an unusually high and artificial bloaeeumulatlon factor. Fundamental scientifically-based data is lacking and no responsible standards can be developed at this time. Ve reeommend that studies be conducted to obtain the relevant .data and that effluent standards be established which are appropriate for the unique conditions existing at each point source. 100G0 ' WATER PCB-SD0000010885 s ) 6. V* object to a limitation of 10,000 eubie foot for atcond being arbitrarily aaalgned as a maximum atream flew, without a aound technical basis demonstrating adverse affeeta. ? The presence of background levels of FCBs at point sources should be considered when determining effluent levels. The s following definition of "Background" ahould be added under Section 129.01a: ' " 'Background* means amounts of toxic pollutant ! Cl) presently found in the waterways of the United States (including the intake waters of a discharger), 6 * or (2) arising out of operations subject to this Fart that occurred before the effective data of this Fart, but were not discharged to the waterways of the United States before the effective date of this Fart 8 Technology for the attainment of the proposed FCB effluent . standard has not been demonatrated and is net available to the industry. Unaehlevcment of the strict standard proposed would have the effect of a ban on the use of FCBs with serious economic and soelal consequences very thoroughly described la an impact statement submitted to the Agency on January 15, 1974, by the General Electric Company. The chemical structure of polychlorinated biphenyls (FCBs) has been known for nearly 100 years. Zt was not until the late 1920s that a use for FCBs was found - as a dielectric fluid in transformers. The properties of FCB -- inertness, fire resistance and a non-conductor of electricity -- are perfectly suited to those electrical applications where high-voltage arcing eould oecur; possibly resulting in serious fires or damage to the equipment. Commercial production of FCBs began la 1*929. As the unique properties of the material became known, new uses were found. For example, their `fire-resistant nature made them excellent choices for use in heattransfer fluids. Their inertness gave long-lasting qualities to lubricants. Their use in surface coatings improved waterproofing characteristics. Handling of the product at the manufacturing level has net presented problems as long as tba normal industrial hygiene practices were followed and FCBs have always been considered less hazardous than many other chemicals in everyday use. r vy-rr- 177 1006' WATER PCB-SD0000010886 f f.' ) -4- Tberefore, it appeared that ?C1 were a unique produet whieh net important seeds af Industry* * Vhen questions about the effeet of FCBa os the environment first aurfseedi Monsanto Company rtvlcwed its product line and the applications for these products. As sore data vere developed concerning the effeet of FCls* Monsanto took eteps to reduce the entry of FCB into the environment. The Cospany stopped the sale of FCBs for use in various applications! axeept where so acceptable alternatives were available. Today ( FCBs sanufaetured by Monsanto Company are sold only to the eleetrlcal industry for use is closed systems as a dleleetrle fluid in transformers and capacitors --- applications for which there exist me acceptable substitutes. . * ' Thus the situation today is drastically different from conditions which existed only three years ago. Today about 40 million pounds per year are being earefully uaed in the United States by less than SO Monsanto customers in the manufacture of sealed eleetrlcsl equipment. Frier to 1971, close to 10 million pounds per year were used by thousands of customers. This lends perspective to the current debate over modest losses of FCBs to waterways. * Our manufacturing and sales reduction program was a unilateral action taken by Monsanto and was based on our evaluation of developing environmental data. The Interdepartmental Task Force on FCBs in its report (l)q concurs that the safety benefits derived.justify the continued use in dielectric applications. Recommendation 6 under Findings, Conclusions and Recosaendatlons reads as follows: _____] "ft. The use of FCBs should not be banned entirely. Their continued' us t Tof'Tia'&H'dfSibf pod-tors - 1-a^the vuaax*... future is considered necessary because of the significantly Increased risk of fire and explosion end the disruption of eleetrlcal service which would result from a ban on FCB use. Also, continued use of FCBs in transformers and . capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the eole domestic producer, hes reported voluntarily eliminating its distribution of FCBs to all except manufacturers of electrical transformers and capacitors." "Numbers in parentheses refer to reference list attached. 178 ioog: WATER PCB-SD0000010887 Racognlxlng the need for proper control* in th* handling end uae of n Fell, r*prcsent*clvs of the transformer and capacitor industries, utilities and gevemaental agencies under the initial ausplees of the f Katlenal Electrical Ksnufacturers Association formed American National I Standards Institute Committee C*107 Fropesed guidelines (30) for I the handling and disposal of dleleetrle fluids have been published. I These guidelines reflect the Industry's under*tsndlng of the need for al proper control and have contributed significantly toward achieving this objective. ** Froposals for the control of FCBs internationally were considered by the member countries of the Organlsstlon for Economic Co-operation and Developnent (OECD) and in February, 1973, they adopted an agreement (31 which restricts the use of FCBs to dleleetrle applications, non-food related heat transfer fluid applications and hydraulle fluid applications in slning equipment. This agreement is less restrictive than Monsanto's sales policy sinee It supports the continued use of FCBs In heat transfer and hydraulle fluids. . Ve hsve reviewed with considerable Interest the effluent standsrds proposed for polychlorinated biphenyls in new Fart 129, Subpart X, Chapter 1 of Title 40, Code of Federal Regulations and have objections relating to the following: ' 1. Definition of polychlorinated biphenyls. 2. Sampling snd snslytleal methods. 3. Toxicity dats. 4. Bioaceumulatlon fsetors. . 5. Ssfety fsetors. 6. Stream flow rstes. "" ` ?, Background levels of polychlorinated biphenyls. 8. Economic considerations. DEFINITION OF fOLfCHLORINATED I1FBENYLS # Commercial pelyehlorlnsted biphenyl products, of which Arecler products are examples, are produced by dlreet ehlerlnatlon of biphenyl; the degree of chlorination being chosen to provide desired properties. These products are In all eases multi-component mixtures and net single entitles as implied by the commonly employed acronym "FCBs". 179 .10009 WATER PCB-SD0000010888 While it i veil understood and eeeepted thet polychlorinated biphenyl isomers heve e unique eec of physical end ehesleel propertlts, it le epperenely net understood thet they blosceumulate, dissipate end biodegrade at different rates. This lack of understanding is reflected in the definition proposed in the CPA Toxle Pollutant Effluent Standards (Federal Register, Wol. 38, Ho. 247, page 35393, Seetlon 129.09a) and ve quote: ' . "As used in this Subpart, the ten: Polychlorinated biphenyls (PCB's) scans materials containing the . biphenyl group vhleh have bees chlorinated to varying degrees. There are 210 possible different P' C' B compounds.** *o Ve ebjeet to this definition because it implies that all polychlorinated biphenyl Isomers are of equal environmental concern, l.e., that they all persist and bloaeeusulate in the same manner In our environment. It has been veil established by acadeale, government, and industrial researchers that this is simply not true. Environmental monitoring programs have clearly demonstrated that, vlth the exception of direct high-level controllable release near points of manufacture or use, the PCBa found In our environment are the more highly chlorinated ones, l.e., those containing predominantly five or mere chlorine atoms per biphenyl molecule (2 thru 13). . This is true even though the lover polychlorinated biphenyls have constituted mere than ill of all the PCBs manufactured over the years. This Is strong evidence that the lover polychlorinated biphenyls degrade rapidly. St further demonstrates that even under conditions of unlimited use, and without special precautions to avoid release into our environment (which Is not the case nov), that the lower polychlorinatc biphenyls degrade rapidly enough to prevent bleaeeumulatlon (4, 5, 6, 27, Here recently, it has also been'demohifratlin .that chlorinated biphenyl isomers, readily undergo bacterial degredatlen at rates dependent upon the number of ehlerlnes per biphenyl molecule* (17, II, 19, 20, 21 and 37). There are also good Indications that ambient environmental PCB levels are decreasing at rates more rapidly than ` predieted (14, 15, 16). . The repld metabolism of these chlorinated isomers and their lack of Importance as contributors to the chlorineted biphenyl tissue burdens is evidenced In the results of numerous studies. Rlsebreugh (2) reported that the ehlerlne composition of the PCBs detected In Atlantic Ocean xooplankten was approximately 41. Be concluded **U.S. production of Axoeler 1254 la 1970 amounted to 12 million pounds -- only one quarter 180 1000? WATER PCB-SD0000010889 7 . of the production of 41 llllea pounds of Aroelor 1242. Zc might bt expected therefore thet biphenyl* with fever chlorine atoms would predominate in planktonic samples tales* these compound* were selectively degraded." Similar findings in fresh water end marine fishes were reported by Zitko (3) and Jensent at al., (4). The dissppeerance of the lover chlorinated homologs in extracts of tissues from birds (5, 34) and menials (# 33) indicate rapid metabolism or excretion of the lover chlorinated hoaologs. As a result of the metabolism and/or excretion of the chlorinated biphenyls containing less than five chlorine atoms per molecule* their contribution to the effluent ahould not be used in measuring polychlorinated biphenyl effluent from a facility. On the basis of these data it is mnreallstlc to consider all poly chlorinated biphenyls equivalent in terms of persistence and bloaeeumula- tion as does the proposed regulation. Therefore*' for environmental purposes* the definition of PCBs ahould foeus upon those which are of concern end we recommend that the following definition be substituted for thet proposed in Section 129.09a* Subpart X, Title 40* Code of . Federal Regulations: '. "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which is ehlorlneted . and which have been shown to persist and rapidly bioaccumulate in the aquatic environment. These chlorinated biphenyls are identified as those components having gas chromatographic retention times greater than 0* relative to p,p-DDE 100* ` under the standard conditions recommended in the EPA PCB test method." ANALYTICAL KETBOPOLOCY Ve have no reason to doubt that the recommended EPA PCB test method is capable of detecting parts per trillion (ppt) levels of PCBs in waste . waters. However, our experience with analyzing industrial waste waters for PCBs at the parts per billion (ppb) level prompts us to be concerned about the following areas* some of whleh are not covered adequetely in the test procedure. 1. Sampling Procedures 2. Correction for Laboretory and Reagent Background 3. Correction for Hon-PCB Sample Interferences 4. Absolute Verification 181 100J.0 WATER PCB-SD0000010890 I I - 5. Fhysieal State of FCBs (Adsorbed/Dissolved) 6. Quantitation 7* Freclsion and Aeeuraey Our eoncarn lies la the fact that tay method, especially one as complex as a FCB aaalytical method, which is to be used for effluent eoatrol purposes aust be thoroughly evaluated and its accuracy and reproducibility proven. If this is not done, the effectiveness of any effluent limit, no natter what the level, will prove to be .difficult, if not impossible to determine. For example, we have found that if waste water streams are not sampled prsperly, the FCB levels found depend on the sampling procedure employed and bear no relationship to the amount of FCBs discharged. For this reason, sampling procedures used must be designed for the discharge in question and clearly stated. To our knowledge, this has not been done. Ve also note that no provisions are recosmended for correcting the apparent FCB level found in a sample for laboratory and reagent background. It is our experience that as one approaches the ppt level, 'this background can significantly affect the observed FCB level. With regard to correction for non-FCB sample interferences, we feel that, while the procedure notes aany of the possible interferences, it does not really address itself to those which are more likely to be in industrial waste water streams. For this reason, if the electron capture chromatogram does not match the FCB being manufactured or used, complete absolute verification of all components counted as FCB must be validated via an alternate technique such as gas chromatography/mass spectrometry. 9 Ve also note that the recommended EFA FCB test method does not specify a a means of differentiating between dissolved and adsorbed FCBs. Ve * ` * believe this should be done since there is a definite difference in the toxicity and availability for bloaeeumulatlon of dissolved and adsorbed While the scheme proposed for estimation (quantitation) of FCBs is logical, it suffers from the same shortcoming as do the multitude of oth< procedures which have been proposed. It is an empirical estimate and only a reflection of the real FCB level. Therefore, it should be determined via an alternate, more-elaborate procedure how closely the calculated FCB levels (for each of the cases) are to the real FCB levels so that they may be corrected.182 182 J oo:ci WATER PCB-SD0000010891 t Uiti but nee least* the precision sal accuracy of aay procedure propost as a standard method should undergo a there ugh inter-laboratory evaluate SI this has not already been done, it must be carried out prior to the use el the procedure for enforcement purposes. The accuracy and precision el the Monsanto PCI procedure has been subjected to a pre liminary evaluation* Frier to this evaluation* ve probably vould have overestimated the precision and aecuraey el our procedure. The exact details el the evaluation are available. Briefly, samples vere prepared by spiking distilled vater with 500 nob PCBs. Individual preparations Include blanks (no PCBs)* Aroclot"1242 c Asoelos 1254 only. Arodor* 1260 only, all 50-50 tvo-coaponent mixture! and a 1/3* 1/3* 1/3 preparation containing all three components. Six samples of each mixture were prepared and analysed by two experienced analytical laboratories. Each result* expressed in ppb el the individual Aroelei* was converted to percent si the total added. Analysis el variance was run on all data taken together and on each laboratory independently. . The 95S eonlldence limits observed lor Individual results were: Either Lab 87.5 55.21 Ub A 81.3 146.41 Ub 1 . 93.7 119.21 * . The repeatability lor the individual labs, based on repeat tests ol samples having identical prepared compositions was: Ub A Ub I 1 42.OZ 1 11.II . ' Ve ieel that these results demonstrate the importance ol evaluating the precision ol any PCB procedure. Mote that the test did not include sampling problems* used distilled water iree ol interferences* and was carried out at a relatively high PCB level (500 ppb; 500,000 ppt) by two experienced laboratories. It is expected that* 11 sampling problem: vere involved* and the level ol PCB present was extremely low, the accuracy and precision ol any PCB method would decrease considerably. 183 3 0070j WATER PCB-SD0000010892 . 10- ' $ BACKGROUND TOR tmfQSW ttk tfTLUENT STANSARP. Is the establishment of the proposed effluent stenderd tht primary basis for toxicological consideration cane from the Water Quality Criteria. October. 1973. (Federal Register, Pol. 31, pages 29646 et eeq., Friday, October 26, 1973). These criteria vere, is turn, based on Water Quality Criteria, 1972. by the National Aeedeay of Sciences end the National Academy of Engineering. a* The Water Quality Criteria, October. 1973. have not undergone the normal review, criticism, cement end revision before final adoption. We objeet to the use of challengeable portions of e proposed publication in the development of critical effluent standards. We note la Water Quality Criteria. 1972. la those sections pertaining to polychlorinated biphenyls, the frequent use of unpublished data and the disturbing use of qualifying phrases ouch as "may adversely affeet...", "...apparently related..or "...the work...suggest..." In our opinion, none of the discussions present adequate data to support establishment of responsible effluent standarda for FCSe. On page 5 of Water Quality Criteria, 1972. the Committee emphasized the Importance In understanding that there Is a distinction between criteria and standards end that the words were not interchangeable nor or they aynonyms for words such as objectives or goals. The report further states that it Is accessary to establish scientifically-based reeommendatl< for each assignable water use. Implying availability of praetleal methods of detecting and measuring which can be applied to monitoring. Once these fundamentals are available, political, aoelal and economical factors enter into the decision-making process to establish standards. In our opinion, these procedural steps were not followed In arriving at the proposed effluent atandards for FCis. & The maximum acceptable concentration in fresh water that would be permitted by the proposed atandard la 0.002 mg/1. The rationale described *in the Statement of Basis and Purpose, Toxic Pollutant Effluent Standards is based on results of a preliminary study whieh have suggested (not yet proven) a threshold PCS level for salmon egg mortality. We cannot accept the aelectlon of aalmon aa representing organisms whieh are usual or may potentially be present In water systerna near facilities described in Section 129.09, Code of Federal Regulations. The cumulative sales of PCBs in the United States since 1930 has been estimated to be about 500,000 tons and that total world production was probably 1,000,000 tons (1). About one-half ef the PCBs were used in applications where containment was difficult and losses Into the environment were common. With this amount of material discharged Into the environment. It Is of considerable importance to note that extensive barm predicted by some theories has not been found and documented. 184 . 10070"! ffj" ' ' *""" WATER PCB-SD0000010893  -JJ' Thl lack of evidence indicates that all ef the FCBs do not persist la the environment as a result ef factors such as the blodegratlon we have discussed previously. Also* the fds the: do persist say not he available because ef ewe faeters met clearly understood at present. One characteristic which undoubtedly la ef significant importance is the ability ef FCBs to adsorb tenaciously to partleulate matter. Under these conditions* can FCBs be rightfully considered to be environmentally active and* if so* te what degree? There exists at present a erltleal need for dsta relating to partition coefficients between water and sediments and diffusion coefficients in sediment (1* 22* 39* 40). Although many reports have been published on the subject of poly chlorinated biphenyls and living organisms * the majority of these describe the presence of FCBs la the environment. Fresenee should not be assumed to imply adverse effeet. To our knowledge, no published report exists which conclusively relates the mortality of any wildlife species to the presence of FCBs. The only reported mortalities are those achieved in laboratory studies. Mot enough is known about the fate and effect of FCBs in the natural and diverse aquatic and marine environments to properly design laboratory studies. Results from such studies are not extrapolatable to the natural situations and any conclusions derived from sueh studies must still be considered speculative. Fundamental selentifleally-based data is lacking and* in its absence* the establishment of affluent standards for polychlorinated biphenyls eannot be made intelligently and responsibly. In the establishment of the FCB effluent standard for freshwater systems a bloaeeumulatlon factor of 200*000 was selected. This factor has no extrapolatable relationship to either the residues of FCB in salmon eggs or to FCB residues of fresh water forage flah. The only published report (27) of an accumulation factor of the magnitude selectee was that for the hepatopanereas of the pink shrimp * Fenaeus durarum. fven though an accumulation of 204*000. in the hepatopanereas has oeeurrec a nearly complete elimination of FCB from that tissue was achieved when the shrimp were placed in water free of added FCB. The equilibrium whole body accumulation plateau indicated an approximate accumulation factor of 22*000. These results are in agreement with those reported by Stallings and Kayer (29)* and with the studies of Ryther (28)* Crelehus at al (24) and Crump-Velsner* at al (22) showing equilibrium blomagniflct tlon factors between water and flah ranging between 1,000 and 75,000 depending on the presence and absence of sediment and the specific FCB mixture present. These data would support the selection of a factor considerably lower than the factors which were applied. 185 100703 WATER PCB-SD0000010894 .) Arbitrary safety faeeera vara applied ee the telarabla ehrenle limit to establiah the ao-called "critical chronic limit" vhlch vas then used to compute the maximum allowable effluent. These safety factora were preposed to account for a multitude of variables including non-point sources, multiple discharges and industrial growth. The safety lectors preposed were identical for 7 of the 9 materials for vhlch affluent standards vere prepared. These safety factors( resulting in approximate! two-fold reductions( are so small as ts ha of no beneficial toxicological consequence. Me recoosend that no safety factor be applied. In establishing the effluent standards( an attempt vas made to distinguish between types of receiving vaters by classifying them as streams, lakes and impoundments, estuaries and eoastal vaters. We do not believe this attempt to distinguish vater bodies is by any measure adequate. Water bodies are universally known to be complex systems with no two systems silks. With a complex material such as poly chlorinated biphenyls, the determination of possible adverse effects in each vater body becomes exceedingly difficult. The uniqueness of each vater system at each point souree must be considered. A key parameter used to further describe the vater body is the flow rate vhlch vas limited to the probable low rate of stream flow occurring during a seven-eonseeutlve-day period once in ten years. We do not agree that this is realistic or appropriate. In our opinion, approprlat< control is achieved using average stream flow rates. Further, the maximum flow rate that can be used In .calculating the daily discharge permitted has been arbitrarily set at 10,000 euble feet per second. This limit Is based on a nondegradatlon philosophy vhleh tolerates limited diffusion and on a desire to dlseourage Industry from locating facilities on large main Inland vaters and coastlines. This limitation deprives our soelety of the. Judicious use of an important gra; natural ressurce. Discharge limitations should be based on the effects a material vlll have on a vater system, giving eonslderatisn to its site and flow rate. Per PCBs, proper control vlll not oceur by Imposing maximum flow rate eondltlsns, but by applying results from scientific studies vhleh properly define how each vater system responds to the presence of PCBs. RESIDUAL POLYCHLORINATED BIPHENYLS Because of their chemical and physical properties, PCBs can be found in sella and vaters at point sources long after a discharge has occurred. This source of PCBs to the environment vlll diminish with time but its presence vlll distort and mask results from current control activities. To maintain control of losses, emphasis should be directed toward discharges resulting from current and future uses of PCBs. 186 10070 1 WATER PCB-SD0000010895 IIbci this problem of background levels occurs with all materials la varylag degrees, v propose th following rovlaloaa: From Saetloa 129.01c(b), dclaco tha words "in intake vattra for a discharger". Add as additional dafialcioa is Saetloa 129.01a* * 'Background' taasa amounts of texle pollutant s (1) praaaatly found is tha vatarvaya of tha Onlted ' ; .Stataa (laeludlng tha intake vatara of a discharger)* . * or (2) arlalag out of operations subject to thla Part that eceurrad before tha effective date of this Part* but were net dlaeharged to tha waterways of tha *; United States before the effective date of thla Part." ECONOMIC CONSIDERATIONS At our PCS manufacturing facility* we developed and instituted an aggressive control program which we described before the Effluent Standards and Vater Quality Information Advisory Coaalttee * EPA (41). Yet* in spite of all our efforts* we cannot today meet the proposed effluent standard. Zn response (42) to an Inquiry from the tl.S. Department of Coserce* we emphasised that technology has not been developed to the point that facilities eould be designed to meet a reasonable standard. However* analytical techniques suggest a conceptual design using adsorption* settling and filtration of aqueous waste* followed by incineration of the adsorbent* probably carbon. Ve estimate the capital cost of such a facility* sised to handle our plant waste, at $600*000* net including a dedicated incinerator for the disposal of the adsorbent material. Annual operating cost would approximate $150*000. 'The value of Monsanto's annual PCB production is about $8 million* while the value of the electrical devices made therefrom is an order of magnitude larger. If Monsanto were to cease production of PCBs* the Jobs of 55 employees would be eliminated directly* while those of an additional 47 employees in a supporting facility would be in jeopardy. The total payroll involved is on the order of $1.5 million. The impact of a PCB ban on our customers can best be described by them. However* it is apparent that capacitors or transformers made without PCBs will be less fire-resistant than present products, thus leading to an undeterminable incidence of fires * higher insurance rates, and additional protection facilities. Zn the case of capacitors, the replacements are likely to be larger and less efficient, thus consuming more of the resources required in their manufacture. A more complete 187 3 0070.-, WATER PCB-SD0000010896 14- ) aaalysls of the consequences of a fCB ban vas developed by the General Ileetrie Company and addrasacd to Dr. Martha lager, Chairman, Efflusnt Standards and Water Quality Advisory Committee, EPA (43). We eoncur with the Central Electric Company*a conclusions. Our purpose la consenting on the proposed standards is to aid the Agency la the developsent of realistic affluent standards vhieh vlll achieve the Intended objectives without serious technical, social and economic disruptions. Va recognise the seriousness of this endeavor and find a stateaant Bade by Mr. John 1. Quarles, Jr., Deputy Administrate1. Environmental Protection Agency, of considerable interest. At a reeent conference, Mr. Quarles (26) stated: a **Wa have found it virtually impossible to devise intelligent standards which specify an appropriate degree of control over eerie pollutants irrespective of the sources of those pollutants and factors affecting the feasibility and timing of their abatement.** * The difficulties vhieh could be anticipated in establishing affluent standards were recognised by the National Academy of Science in its preparation of Water Quality Criteria. 1972. Zn a review whleh appeared in the Environmental Reporter (36) dated August 24, 1973, the following pertinent statements highlight oome of the areas of concern: "Knowledge of local environmental conditions is essential prior to application of any water quality recommendations for marine aquatie life and wildlife...*' ' "NAS said application of recommendations to a local situation is unique because it requires an under standing of the circulation of water and the resultant mixing end dilution pf pollutants, a knowledge of bio logical species and determination of the most sensitive species, and an evaluation of the transport of materials through the food web." *' "NAS said it is not practical to make recommendations for the relatively persistent organic pollutant based on water concentration, especially when partition coefficients are unknown." 188 JOOTOO WATER PCB-SD0000010897  -15- ) Wt ean ipprieliti Mr. Quarles1 @aeatu8 pirtieululp at it applies ft PCBi. Laeking good aeleatlfle lafonatlon on the fat* and affaeta of fCIi in eooplex vatar aysteas aaeh having unique characteristics, va urge axtrema ear* ba taken to avaid tha proaulgatlon of affluent standard! vhleh ara ^attainable and unwarranted. i Subscribed and avorn to bafera aa this (P%. V. 1. Papaghorfb. T j i&f of n . My gasmlaaien expires I169 WATER PCB-SD0000010898 e- pi9tt*SoJ ........*> t w. B. Fipageorst --. B2SK C... December 9, 1974 PCs - Minutes of Meeting with KIOSK - II/22/74 ro G. L. British W. C. Enginen .-r.. 174? G. F. Fort R. E. Kelly G. J. Levlnskas J. R. Savage i1 E F. Wheeler** A2SA *c H. S. Bergen P. J. Fitzgerald Robert Flint - 1740 D. B. Hosmer Clarence Sweets The meeting was held at the request of Joseph K. Wagoner, S. D, Hyg., Director, Division of Field Studies and Clinical Investigatlons (DFSCI), Rational Institute for Occupational Safety and Health (NIOSH). KIOSK reports to the Center for Disease Control (CDC) In the Department of Health, Edv:*tion and Welfare (DHEW). She participants In the d!" : ..slsn are as shown In the attached list. The original purpose was to explore whether Monsanto had a "suitable occupational group for study" to assess the potential chronic effects of FCBs. To be Included were ''PCB-exposed active and Inactive workers at Monsanto In a planned retrospective cohort study." What this would Involve Is obtaining work histories of time spent In PCS departments, and medical records of active and still-living inactive employees. ' The study would not be complete without examination of death records of those "PCB-exposed" employees who are deceased -- Including those who expired while employed and those who expired after termination of employment because of retirement or for any ether cause. 4 The proposed study was stimulated by a report from Dr. * Kimbrough, Toxicologist, CDC, to KIOSK, that she had found an alarming rate of liver cancers in rats fed Aroclor 1260. Briefly, she found 1| of 180 female rats with "definite hepatic cell carcinoma" when fed Aroclor 12fin ft 100 ppm in the diet for 22 months. Only one of 173 controls had the carcinoma. She then described a number of other liver tissue effects as "pre-cancerous lesions" and found these in 175 of the experimental rats and in dnly three of the controls. r~J"1 1,1 " "r^'ng'li'iftiinn' ".'.'..u'""-- -"-m 190 000043 " WATER PCB-SD0000010899 " j -r * Westlnghouse Electric Corporation FEB e ifiT* 0 I r li ii ? Dr. V, B. Papageorge Manager Environaentai Control Monaante Ces^aay ' Organic Cheaiecls Divlalon . 00 North Llabargh llvd. St. Louie, Miseouri 63111 * ten#teflon thurM&i mm Wf^aw M W*SI teiit#ta*irv*K*m?4S2 amimwi Ptbruary 3, ISIS gw. ` , ' Daar Dr. Pepcgeorge: . Attached you trill fiad a liat of queetlona that have bcaa aaked by our employee ragardlag the uae of Znerteen. Mr. Carry Wilburs, our Engineering Manager, felt If theae quaatioaa could be aaawared you would be the aaa to anever the*. Va have had .in the peat .workplace seeing with our eoployaa explaining proper uae of Inerteea and telling thea unleaa it is conaumed. it preaeata no real danger to thea. In anaverlng theae queations. hopefully we will gain oueh needed knowledge oa laerteea aad bow to preaeat it properly to our eaployea. Thaak you for your help. Staff Suparrlaor Paraoanal Kalatieaa Ceorge tvisdoa. Marvia Bowling /e 0 WBAN 000026 191 * WATER PCB-SD0000010900 J) V. 1. Question: Ooes Xnertetn hsvt permanent offsets on the huaoo body? Zf so, trfiat type of permanent image end hov long e period ef * tiae does It tike for this to develop? Zf net, explain why, it possible* 2. Question: Several hourly cs^leyes hive mntioned recently that many `* chemicals such as Znerteen cause sterilisation after a prolonged use. Zs this true? , 2. Question: Sinee Znerteen effects birds and ether animals, if there is no real effects to human beings, hov do you explsin it to employes la euch e way that they mil understand why it can kill a bird and not a hmss? 4. Question: Zf an e^leye spills Znerteen on his clothing and later takes the clothing home to be washed with other clothes, mil this have any effect on he or his family and ehould he carry bis clothes home be be washed? 5. Question: bployes eerry Znerteen hone on the eoles ef their shoes and . complain quits a bit about the effect Znerteen has on wearing out their shoes. Zs this a serious problem? Hill Znerteen in * the soles end leather of shoes, over a long period of time, have . an affeet on the feet end akin since the shoe is the only preteeelve equipment vs wear on our feet and the Znerteen penetrates through Che leather. i. Question: r' . There Is one employe in our plant who had no problem whatsoever with Znerteen years ago. After sis years of using, now when he works la Znerteen (which is a pert of hie Job) he develops a swelling on Che inner bleep of bis left arm, only in one location. Could this be from Znerteen or not? Zt goes away as soon as he gets out ef the Znerteen. Zt is similar to the swelling after taking an injection. 7. Question: Are there hand cleaning solvent materials that we should be using whan working in Znerteen to coat our akin before working in it and to wash it off after we finish working $n it? Please give your recommendation. Cur alloys* working in Znerteen are net able to use gloves elnee it la an assembly area. Sven if they could, the Xaertetn would destroy the protective glove. Suaiiyi If there ere any questions we have not brought up that you are cvsre ef, please include in your eocnents, or any they lnfernaeion you can give us concerning the proper use ef Znerteen. GBRN 000027 192 WATER PCB-SD0000010901 it Monsanto mmutm rnmtnmt em*mm m. 900 N. ItMUrt* e<aa*d St. uwt. umnit estee Himi @141 M4*I000 &0C&S ~ Februsry 26, 1975 '4 Mr. Ban A. Albert Staff Supervisor Personnel Relations Vestlnghouse Eleetrle Corporation Box 290, Highway *3 West So.th Boston, Virginia 2A592 Bear Kr. Albert: Z hsve received your letter dated February 3 asking us to respond to a list of questions. Since these questions relate to human health considerations, Z have asked our 'Medical Bepartaent to prepare the response. You should be hearing from us shortly, either from my office or from a representative of our Medical Bepartsent. Zf Z can be of further service please let ae know. Sincerely, IfSPipd V. B. Fapageorge Manager, Product Acceptability Specialty It Process Chemicals 6 MH *t UHIHH ttMIW 68A* 00002a a193 193 WATER PCB-SD0000010902 Monsanto |MB( TO V, e V. B, Papageorge March 18, 1975 TIKGHOOSeV Znerteen .if 1. X. Bard I St. Louis____________ BSSK C. Paton Z. P. Wheeler Attached la the original of a letter addreaaed to Mr. Dan A. Albert of Weatlnghouse, South Boston, Virginia. The contents of this letter have been reviewed with Dave Wood and it was agreed that the letter be delivered by you personally to South Boston, giving you an opportunity to discuss with the Westinghouae representatives the proper approach that oust be taken In presenting this Information to avoid undue concerns and olsunderstandlnga. Will you please deliver this letter as soon aa practical. n, yfc t V. 1. Papageorge /pd ! sv. CBRN 0C1640 194 WATER PCB-SD0000010903 I Monsanto KsurmAi, 00 *t tiegeergii Bleer* s<. Uiit. esiee OlMM! 014) M4I000 ee. March 18, 1975 Mr. San A. Albert Staff Supervisor Personnel Relations Vestinghouse Electric Corporation Highway 58 West South Boston, Virginia 84592 . Sear Mr. Alberts Attached are responses to the questions listed in your letter dated February 3* 1975. Zn addition to the Industrial hygiene practices described In our responses to your questions, Z cannot overemphasize the need to properly control the use and handling of Znerteens to prevent their escape into the environment. Also, in discussing this information with your employees, 1 strongly recommend that the perspective gained from over 40 years of experience in which no human harm has resulted, be emphasized. In summary, the proper handling of Znerteens should pose no environmental or human health problems, permitting society's continued use of a very valuable material. Z hope the above information is useful to you. Zf Z can be of further service please let me know. . Sincerely, VBP:pd V. B. Fapageorge Manager, Product Acceptability Specialty & Process Chemicals ,ll el MeMeete GBRN 0016^1 195 WATER PCB-SD0000010904 I 1 . Question: Does Inerteen have permanent effects on the human body? If so, what type of permanent damage and how long a period of time does it take for this to develop? If not, explain why, if possible. The polychlorinated biphenyls in Inerteen can have permanent effects on the human body. The length of time or period of exposure necessary to develop symptoms depends on the degree or amount of exposure. In general a single exposure for a few minutes to atmospheric concentrations that cause irritation to the eyes and/or respiratory tract would not be expected to cause either the skin eruptions or demonstrabl liver injury. She problem arises from repeated and prolonged exposure to atmospheric concentrations in excess of the accepted Threshold limit levels or repeated and prolonged skin contact. The polychlorinated biphenyls have not been recognized as skin "irritants'' in the same sense that caustic materials or many organic chemicals are irritants. Because of their "solvent" action In removing the natural fats and oils from the skin, leaching, drying and chapping, repeated and prolonged skin cental should be avoided. When the polychlorinated biphenyls are mixed with other chlori nated hydrocarbons, the mixture may be classified as a skin irritant. The potential toxic effects in humans from excessive exposure to polychlorinated biphenyls Include injury to the liver and chloracne. In animals, the liver effect is demonstrated by Increased liver weights and injury to cellular tissue. Although chloracne is difficult to evaluate in animals, in humans, this take the form of comedones (large blackheads with typical acute pustules) and may be an external symptom of over exposure pre ceding serious liver injury. Animal data and human experience Indicate that the toxic effects are similar whether exposure results from ingestion, inhalation of vapors, or absorption of the liquid material through the unbroken skin. - (See A2HA Hygienic Guide Series - "Chlorodiphenyls" attached.) 2. Question: Several hourly employees have mentioned recently that many chemicals such as Inerteen cause sterilization after prolonged use. Is this true? There is no evidence that polychlorinated biphenyls cause "sterilization" in humans.196 fofcRN 001642 196 WATER PCB-SD0000010905 i V' * * ) 3 Question: Since Inerteen effects birds and other animals, if there is no real effects to human beings, how do you explain it to employees in such a way that they will understand why it can kill a bird and not a human? Ihere is a potential real effect to humans - including death as discussed in the answer to Question 1. Ike to differences in metabolism of food (and food contami nants) in birds and humans (and particularly the difference in the reproduction process in birds and mammals - inclu ding humans), birds are partleualrly sensitive to many chlorinated hydrocarbons including polychlorinated biphenyls. U, Question: If an employee apllls Inerteen on his clothing and later takes the clothing home to be wa ed with other clothes, will this have any effect on he or his family and should be carry his clothes home to be washed? There should not be 'any effect on an employee or his family from home laundering of work clothing. If washed with other clothing, there may be residual odor of the chlorinated hydrocarbons in the clothing. 5. Question: Employees carry Inerteen home on the soles of their shoes and complain quite a bit about the effect Inerteen has on wearing out their shoes. Is this a serious problem? ' Will Inerteen In the soles and leather of shoes, over a long period of time, have an effect on the feet and skin since the shoe is the only protective equipment we wear on our feet and the Inerteen penetrates through the leather. There should not be polychlorinated biphenyl on the floor for workmen to contaminate their shoes to carry home. The plas ticizer or solvent action will destroy or shorten the life of the shoes. More Importantly, the wearing of contaminated shoes could lead to absorption of the liquid through the soles of the feet as through any other unbroken skin surface. . 6. Question: There is one employee in our plant who had no pro blem whatsoever with Inerteen years ago. After six years of using, now when he works in Inerteen (which is a part of his job) he develops a swelling on the inner bicep of his left arm, only in one location. Could this be from Inerteen or not? It goes away as soon as he gets out of the Inerteen. It is similar to the swelling after taking an injection. . C6RN 0016<3 29? WATER PCB-SD0000010906 We do not believe there can be any association between "a swelling on the inner bicep" of the ant and exposure to polychlorinated biphenyls. 7* Question: Are there hand cleaning solvent materials that we should be using when working in Xnerteen to coat our skin before working in it and to wash it off after we finish working In it? Please give your recommendation. Our employees working In Xnerteen are not able to use gloves since it is an assembly area. Even If they could, the Xnerteen would destroy the protective glove. We assume the question refers to the use of "Barrier Creams" rather than a "hand cleaning solvent". There are a number of barrier creams available to protect workers against water Insoluble solvents. Probably the most effective Include silicone l,to provide an Impenetrable shield". A problem with such creams Is that they may offer a false sense of security. Proper use includes a discipline which requires liberal appli cation at the beginning of a work shift and after each washing of the hands during the work day. fc&Rh 0GU<< 198 WATER PCB-SD0000010907 V HYGIENIC GUIDE SERIES Chlorodiplienyls (Containing 42% and 14% Chlorine) 9 | I:\Ttnrt C:.!t SifntfUent Hiyilul The ehlerediphenris fen light itrow-colored BefcOo (42% chlorinated) imd viacom (34% chlorincitd) liquid! with typical chlorinated oromsiic odors. Thtse cempouodi an chlorinated to tpecJAe weight! a/ chlorine. Chlorodipbenrl (42%) contain! 42.0 04 chlorine, an amount amaponding ts three chlorine atom! in vn(aligned potitiani Chbrediphenyi (01%) contain! 044% chlenne cormponding to Ove chlorine atosu is unauigned peiitioni. Both compound! eaknhmhdttmelmub.ie an water, hut aalublc in bcaarae, katmmt, acetone, amyl akohol, other and CkUrtdipktmji (4i%) CkUttlipknyi (S4%) fefrJgguW weight: 3424) 224.43 fUah point (Qfvekrvd c O. ): DiKUlaiioo mage: tpoeitc gravity: l7(*.ia0*C (J4P*-S48*F) WMW'C 1411.1422 None 243*.J80*C 1.483-1405 (2071(4*0 (137154*0 Vapor pressure: 0*C 0.001 ns * 0.00004 mm 23*C 0.004 as (cat) 0.00034 mm (, iso*c 44 eta 1.4 BB soo*e K.O sea Mia At 23*C aod 2(0 m Hg: Saturated air ceataimi 0.080 Bg/StB 9.009 Bg/liter 1 Bg/Ute* tf.l ppm 744 ppm irm8 0.010 Bg/Uar 0413 BC/!il(T 8. Myfiwite Standards A. Rxoouubnbes maximal ATMOPPHEUC eoNCXMThATiONS (S hours) : One milli gram ehbrediphenyl (42%) peg cubic gnetm' &S air and 04 milligram ehkrredipHenyt (54%) per cubic meter of err.' This k bated on the reatltg el AafteBeCdssmwleiabrtaarnmiutmi anteia>aWofgeItstfaCwd> Or Oest ferfmrul Ktvw cod Qonl Tamtam Ciaaiaa 1 t. Id. A., eed a aaStevtH*! Ba U tnaa aI Itaw t. Wfcastw aarf Jo* T. Gam a Os eras* tt lAo chronic animal inhalation studies.6 B. Smoot ixmivu tuipaance: Ten mg el a diphenyl of unspecified chlorine content per cubie meter el air hat been (opened as unbearably irritating* CL ArsdOSPMUIC CONCZNTOATION IMMESt- ATZiv rtASAROOUt to u: Net known lor man. Irritation el the eyes, note sad throat at levels which have not aused acute illness preclude the likeli hood eI voluntary eiposurc to immedi ately hazardous concentrations. & c6s a010'5 199 WATER PCB-SD0000010908 J /MioyfriniHy, l$S ft, Toeb Properties Human cares ef ehferacne hare set EA. Inhalation: Experiments with chlori diphenyl (42% chlorine) were nm at eaneentrstbns el 8.6 ag/Hter and at (A3 of/liter el air. Cats, mice, tabbiu and rats trees unaffected by the higher fct.'el while guinea pigs ilowtd poor growth after ar-renteen 7-heur/day esire* over 24 days. Eighty-four 7r/day exposures at die fewer eaeentratbn had essentially no effect en been reported from the use ef these two specific chbrediphtnvis. The potential undoubtedly emus because ef ***** which were repotted from the tm of dsferediphenyb with a higher ehbrine eenteit and from mixtures with ether chlorinated sremaik compounds.*4'* C, Evs contact* The liquid preduets and their vapsrs are moderately irritating to eye (sue. rimilar ipecies of animals.' B. iNeasnoN: The acute oral tosdtie ef In the ease of chlorodiphenyt (54% chlorine) cighty*lhrec 7*bour/day ox* insures over 121 dayi to a concentre* don of 5.4 pg/liter resulted in injury to Urn relit ana increased liver weights in nta. At a coneentration of 1J ag/liter lor one hundred and fifty 7*hour/day exposures ever 213 days, the rats the undiluted compounds are not great as evidenced by dal LDM`* in rets ef approximately 8.65 gm (7.61 to 9.78 gin) per kilogram for the 42% chbri* Bated and IlSgm (10.48 to 13.45 gm! per kilogram for the 54% chbrinated.* Central atrophy ef the brer appears to be the chief toxic effect. showed distinct microscopic changes in tin brer.* HI. Industrie! Hygiene Practice The literature contains many refer* ernes to the potential toxic effect* of chlorinated diphenyls in man and aril* snals. The early work included invest!* ptions of chlorinated naphthalenes, chlorinated diphenyls, chlorinated dipltenyl oxide and various mixture) of these. An early report indicated serious tone effects from chlorodiphenyl chlori* Bated to the extent of 65%.* A later report by the principal author properly identified the earlier sample as a mix* tune of chlorinated diphenyl and chlori* Bated diphenyl benzene.* However,only a few authors of subsequent papers, buttruss or textbooks have noted this cor* faction and the original data are cited repeatedly as relating to chlorinated diphenyl alone. B. Sun contact: Both compounds are readily absorbed through the clipped, bstact skis of .rabbits. The minimum lethal dose when the undiluted mate* rials st applied to the covered dipped, satact skin of rabbit* for 24 bean was approximately 1.0 gm/kg for A. ImurretAL tries: The chlorodiphenyts are used re dielectrics for condensers, capacitors and transformers, plasticisers is synthetic resins, in emulsion adhes* ivre, re nonflammable hydraulic fluids aad re transfer media. 1. Evalvahon e? gsrosuass: !. da tempting and melysit: & Direct field methods; None b. Laboratory methods: (1) Collect in secondary butyl alcohol in fritted bubbler or two large impingen m term; concentrate sample and complete analysis by one ef various methods for chlo rinated hydrocarbons.* (2) Sample air through com bustion furnace, collect chloride bn from decom posed chlorodiphenyl in suitable alkaline solution and determine chloride bn eooesttretbn.' C. Hasasss asm thus bsconnbmbeo the 42% chlorinated and 1J gm/kg for the 54% chlorinated.* . 1. Inkeletio*: Absorption is chiefly by Leeal actios on the dun similar ta that of common organic solvents where contact loads to removal of natural fats and nib with subsequent drying and eradbiag of die skia. {ahaktbn. Concentrations in the workroom atmosphere should be maintained below Use recommended fevek Where the chlorinated diphenyls are used at room tempera- A ,{>1 CO18*6 * 200 ') t s < J WATER PCB-SD0000010909 I /mmry-Fekrmry, f55 asm, list Hazard @f inhalation Is elevated temperatures, the patient eonridered slight r absent. When dtould be moved from exposure and there materials are subjected ta kept at rest until test by a physician. elevated temperatures, the pteces Oxygen should be administered if dther iheuld He esmpkteJy enclosed breathing a difficult m ether adequate mechanical et- Eyes contaminated with eMoredi- feaust ventilation must provided Is reduce concentrations is mfe Phenyl should be irrigated with water for at least 13 minute and the patient levels. In heat transfer media appli should be asm by a physician. Depend cations, the system must be designed ing ms the amount of inflammation and and eonttrueted to that it is tak- pain prerem, drop like Certisperin peoef. Special gasket materials and haorient and topical Peotseaine* may Cmp seals are available to preveit he indicated. . kage. The reservoir tank should he airtight except for a vent to the outdoors, la the even of spills er teaks of hot fluids, use chemical cartridge respirators er gas masks approved by the U. S- Bureau of Mures fprprotection against organic vapors. These trill provide good protection up to the concentrations SraoAt. mecmvms: Persons who are regularly er repeatedly exposed to ehlorodiphenyis should be examined prrindieally to detect early evidence of skin faritatson and/or liver damage. Persons with known liver disease should net be exposed to repeated contact with the ehJerodipheayu. shown eo the approval labels and the odor will give ample warning if it corns through the device, t. Skin contact: Operations and handl ing procedures should be such at to avoid the possibility of prolonged er repeated skin contact. Contaminated clothing must be laundered before reuse. S. Eye eenteet: Eye protection should be used where there is a possibility of liquid splashes. 4. Ingestion: Ingestion of them mate rials is not a problem in industry. V. deferences 1. Monsanto Company, Organic Chemi cals Division: Teth. Bulletin 9PL-306, Arcelor FUsticitert (Dec. I960). 2. American Conference of Governmental Industrial Hygienists: Threshold Limit Values for 1964. AMA Artk. Environ. Health 9: 343 (1964). 3. Trsen, J. F., F. F. Cleveland, J. Cappel, and R. W. Atchlcy: The Toxicity of the Vapors of Arodor 1242 and Aroelor 1234. Amer. iud. Hyg. Ame. Quart. 17: 204 (1936). 4. Elkina, H. &.: The Chemistry of Indus I. Fire end eeplosion: The chlorodi- trial Toeieology. John Wiley and Sons, phenyls are fire-resistant or essenti Inc., New York (1939). ally nonflammable liquids. When 3. Drinker, C. K., M. F. Warren, and G. exposed to flame er hot surfaces A. Sennet: The Problem of Possible they may decompose to form CO, Systemic Effects from Certain Chlori CO* HCt, phenolic* and aldehydes nated Hydrocarbons. J.Imd.Hyg. Toe depending on the temperature, avail . srW. 19. 283 (1937)/ ability of oxygen, area of tlie heated .' Drinker, C. K.: Further Observations surface, rate of application of the eo the Possible Systemic Toxicity of liquid so the surface and other Certain of the Chlorinated Hydrocar variables. bons. /. Ind. Hyg. Toeisol. 21: 133 IV. Medical Information ` f. (1939). Wheeler, E. P.: Personal Communica A. EuueaHcr tatATwatrr: Skin surfaces tion, Monsanto Company, St. Louit. exposed to chlorodiplienyls should be Missouri 63166. thoroughly washed with soap and water i. Gresiburg, L., M. R. Maven. and A. at ease. If clothing has been contami K Smith: The Systemic Effects Result nated' it should be removed promptly. ing from Exposure to Certain Chlori If exposure to a high vapor concen- nated Hydrocarbons. /. lad. Hyg Nation occurs, as in the cate of spUb at TosdeeL2l:29 (1939). a 61RN 001&4*7 201 WATER PCB-SD0000010910 hygienic msmu Gommru C. F. Cuwnu. Ckmrmm K. E. Eoltox S.S, e&urtua 1. W. Cumox H. I. turn* M>.Kauay Mass Hm J. A. Mmm> 8.&MeFu M. McNsaxiv, Ja. J. E. hnsMM J. B. Ouassmst l, A. Shwtsa V.Chuui LLfUuaa W. L Svm E. C. Wakn 6. I> W&MK HrtienSc Guide Arm say It ebtanttd frets At aetBieax mmibtbiai. stock* mmcu* 1412$ Prrwui, Oetfoit 27. Mkhwau, si 2$ rtau each fsr iwbmw tvprtau; SO esnu each let feur>pst reprint*. Ail erdtn (at Ira then $2.00 mmt be prepaid. Diteeuni el 20% m erdtn el Sv* or were Guidrt; 40'S ditceunt ea erdtn el 100 er mere Gutdrt. Special Iopm teal biadsn let A* Guides say eke be orrisred (tea ibe Aesekdea efts fee $14$ eseb. I AI itbRS 001646 202 WATER PCB-SD0000010911 April 18. 1975 Dr. George Roush* Jr. Monsanto Company 600 North Lindbergh Boulevard St. Louis, Missouri 63166 . Dear George: 1 fully appreciate that the meeting on FCB's today was not completely satisfactory and that many nagging questions remain. The enclosed is a brief summary of my personal views and 1 would appreciate any open and frank comments that you all may have. Please let me know of any action that you contemplate in the way of seeking additional assistance in pathology or in contacting federal agencies. We will be pleased to he of help in any way that you may wish. - ..........* ' ' It is my feeling that we need to get together again within the next few weeks to continue our discussions. Very truly yours. JCC:AR J. C. Calandra President cc Dr. George Levin ska . ' . Mr. Omar Wheeler . Mr. William Fapageorge ; . . . * ." **. * i * 1 :. .v ' jt ' 203 1007-ni ~ ' *' ' WATER PCB-SD0000010912 c I c BIO-TEST AfctslWsrf. Smc. REVIEW or FOB MEETING . ,, The central issue in question is whether the FCB's are , carcinogens or not. The long term studies conducted at BIO-TEST indicate that the answer is no. X>rs. Ward Richter and Donovan ' Gordon are of this opinion which is shared by M. h. Keplinger and . J. C. Calandra. On the other hand, a study conducted by Dr. Renata Kimbrough presents evidence that in female rats of the Sherman strain, liver carcinomas were found. This is the only study in which this finding is reported in rats. BIO-TEST has no basis for refuting the findings of Kimbrough except to take exception td the design of the experiment that used only female rats and to point out that to our knowledge no one else has reported similar results in rats. It should be noted that the earlier allegation by Kimbrough that bladder cancers developed in female rats fed PCS was successfully counteracted by BIO-TEST and Monsanto personnel. Kiznura* worked with Kanechlor-400, a commercial brand of PCS and in a rat study of 400 days' duration concluded that "FOB's induced a benign neoplastic change, though it seemed to be still short of malignancy, and that the change appeared exclusively in the females. " The author expressed concern that the benign nodules in the liver may progress to carcinomas if "specific or non-specific stimuli are introduced into the animal. " * _ 204 ,,^ 10070 G 02. WATER PCB-SD0000010913 jfoArfAW BIO -TEST ^aUtttfulti, $mc. 2 Ito^ conducted a study in mice and found "hyperplastie nodulei % and well-differentiated hepatocellular carcinoma i" at a dose level of e 500 ppm of Kaneehlor 500. Hepatocellular carcinomas were not in duced by Kaneehlor 300 and Kaneehlor 400. The evidence to date indicates* that male rats are more resistant than females to the formation of nodular hyperplasia as well as hepato cellular carcinoma. Rats also are more resistant to the induction of these lesions than mice. To return to the BIO-TEST studies on FCB, it should be noted that the liver sections which were read by the pathologists and reported in 1BT No. 641-06672 and dated March 24, 1975, were not the same slides or sections as those reported on originally. The preserved livers were reprocessed by taking 4 "cuts" from different areas to obtain as large a representative sample as possible. It is not surprising that under these circumstances a different tabulation of the various primary liver lesions was found. Studies on thyroid hyperplasia and by Richter's associate, Dr. Stanley Vesselinovitch, have shown that this procedure generally results in a different qualitative and quantitative line-up of lesions that are reported by the same pathologist. Ideally one would like to be able to reaffirm the original findings by this procedure, but this is not always possible because of the additional variables introduced. Serial sections of the liver would 205 1007 WATER PCB-SD0000010914 jmJult+lat BIO TEST Sme. 3' eliminate aomt of the eovmriant*. The important point in the most recent study of the sections is the fact that no hepatocellular carcinomas - ** were found which is in agreement with the earlier findings. It must be emphasised that the diagnosis of 'hepatoma*1 by Gordon and Richter connotes a benign process and must not be confused with the classical definition of the term by 'human" pathologists. * Further. Dr. Squires reviewed a number of the same slides on Aroclor 1260 with Drs. Gordon, Devin skas, Kimbrough and Richter and agreed with the BIO-TEST pathologists that liver carcinomas were not present in the slides. In addition, the original slides have been in the possession of FDA since June, 1973 and to date we have not been informed of any disagreement with BIO-TEST findings. Dr. Squires has stated in a letter to Dr. Kimbrough dated November 12, 1974, that "1 define 'discrete nodules' and 'trabecular (basophilic) hyperplasia1 as precancerous lesions and thus indicative of carcinogenic response." This reflects a viewpoint which is not shared by all pathologists and the re is nothing that BIO-TEST can do to change this definition except for its pathologists to accept or reject the view. Drs. Richter and Gordon do not accept Dr. Squire's definition# Workers in the field have published extensively on the pathogenesis of hepatocellular carcinoma in recent years and the concepts have undergone considerable changes since the preparation 206 10073- water PCB-SD0000010915 Jmdmt&daS BIO-T EST &fe4 $m& 4 of the final BIO-TEST report on chronic oral toxicity studies. One must mote that Popper* in hia studies on Aramite in i960 postulated that o hyperplastic modules were transformed into hepatocellular cancer; however, this concept was sot generally accepted by the scientific community. * An excellent paper which describes 'the highlights of some sewer developments in our understanding of liver carcinogenesis" has been published by Farber.^ Xf the concepts presented in this paper as well as those of Squires, Saffiotti and others are accepted, a number of substances would have to be reclassified as liver carcinogens. Carried to extreme, we could argue that any substance that results is stimulation of liver microsomal enzymes or possesses hepatoeytoxic properties to any degree is a potential liver carcinogen. BIO-TEST is unwilling to accept these concepts. The lesions seen is the livers of the rats is its PCB studies for Monsanto do not show vascular invasion, metasteses or anaplasia - all classical features of carcinoma. We continue to view the lesions seen to be benign. Several additional things seed to be done by BIO-TEST and these include: (a) Ke-exunine the original liver slides. (b) Cut new sections at different levels from original paraffin blocks and read slides, (c) Tabulate liver findings separately in female and male rats. (d) If possible, develop information on the reversibility of the liver changes.207 100 207 WATER PCB-SD0000010916 BIO-TEST Sue, 5` Xt it Important to point out the .following: ! The BIO-TEST position was and remains that the PCB's were not shown to be liver carcinogens in Its studies. This conclusion is the opinion of its resident pathologists as well as its independent consultant. 2. The BIO-TEST results show that a no-effect level for the development of hyperplastic nodules was found in each of its studies. 3. BIO-TEST has no means at its disposal to dispute the findings of Kimbrough that Aroclor 1260 in female Sherman rats is a liver carcinogen except on the basis of experimental design. 4. BIO-TEST is not in agreement with the classification by Squires et al. that considers hyperplastic liver nodules to be pre- eaneerous. 5. BIO-TEST studies on PCB's meet the scientific standards of Toxicology and Pathology and we are prepared to assist Monsanto in any adversary situation in or out of government. J. C. Calandra April 18. 1975 References 1 Kimura, N.T. Gann 64:105 (1973). 2 Ito. N. J. Nat. Cancer Inst. 51:1637 (1973). 3 Popper, H. Cancer 13:1035 (i960). 4 Farber, E. Arch. Path. 98:145 (1974). 208 100 <<30 WATER PCB-SD0000010917 V / Monsanto see m. II. IMK. *(* 9111 *: HI* 04*1000 July 18, 1975 Dr. J.C. Calandra Industrial BIO-TEST Laboratories 1810 Frontage Rd. Northbrook, 111, 60062 re: AROCLOR 2-year Rat Feeding Studies Dear Joe: . The attached table summarizes a comparison of the 3 revised AROCLOR reports (1242, 1254, 1260). In 2 Instances, the previous conclusion of "slightly tumorigenic" was changed to "does not appear to be carcinogenic''. The latter phrase Is preferable. Hay we request that the AROCLOR 125^ report be amended to say "does not appear to be carcinogenic''. The number of hepatomas reported for AROCLORS 1260 and 1242 have been Interchanged. This appears to have arisen from con fusion regarding the numbering of the animals. The original reports show tumors in animals with numbers in the 100-300 range for AROCLOR 1260 and in the 500 to 800 range for AROCLOR 1242. This leads me to conclude that the numbering scheme shown in the second set of reports is correct. With AROCLOR 1254 confusion is compounded. The original report showed tumors in animals with numbers in the units to teens, but the revised report shows animal numbers ranging from Uo to 1000. Can this be straightened out? I was unable to reconcile the differences in the animal numbers between the first supplemental report and the original reports, 1 had inquired as to the changes in the numbers. As I recall, 2 was told that the sections had been renumoered when the new slides were made and that a key relating to the sets of numbers 10073? RECEIVED JUISHS* 209 WATER PCB-SD0000010918 c f Dr. J.C. Calandra July 18, 1975 Page 2 . would be supplied. This has not been done. It may not be necessary for AROCLORS 1260 and 1242, but AROCLOR 1254 remains unresolved. Insofar as 2 can see, the remainder of the reports appear acceptable. . Kindest personal regards. Sincerely, George J, Levlnskas, PhD Mgr., Environmental Assessment and Toxicology /bkp att. cc: Dr. George Roush, Jr,, M.D. 100736 -210 WATER PCB-SD0000010919 r if . * > P Product Supplemental Report Supplemental Report #1 (mailed! #2 (JCC deliver*^ AROCLOR 1260 conclusion lightly tumorigenic dots not appear carcinogenic hepatomas 3 7 range of test animal nos: p. 9 P. 10 00 to 800 1000 series P< 11 p. 12 70 to 100 500 to 600 P. ll P 600 to 700 700 series 100 to 300 800 to 900 10 to tto Go to 200 200 to 300 200 to 300 AROCLOR 125^ conclusion hepatomas slightly tumorigenic 6 slightly tumorigenic 6 AROCLOR 12^2 conclusion slightly tuaorlgenlc does not appear carcinogenic hepatomas 7 3 range of test animal nos. as in report #2 as In report #1 for AROCLOR 1260 AROCLOR 1260 in 1007 WATER PCB-SD0000010920 I Ii August 4, lf? If. . Vt* Gssrgs 7. Uvlaihi, M&mgr Eavirsamtotal Asssssmsnt and Toxicology Monsanto Company 00 North Lindbergh Boulevard St. Louis, Missouri 43166 Bear George: Bet Aroclor - 2 Yesr Bat Studies Za regard to the comments aad questions covered la your Utter dated July 18, 1975, pertaining to the above, please note the following: 1. We wlU amend our statement la the test paragraph on page 2 of the Aroclor 1214 report to read, "does not appear to be carcinogenic" in place of "slightly tumorigoalc" as requested. 2. Za regard to the animal numbers la the Aroclor 1242 aad 1260 reports, they are correct la our final revised report. In the original reports, the Aroclor titles for these twe materials were reversed. 3. The animal identification numbers appearing In the reports on evaluation of additional tlver sections are the same as those la our original report. The animals were not renumbered. 4. We cannot find any discrepancy in animal identification numbers la the reports (original, re-evaluntioa, final revision) on Aroclor 1254. However, in the report on re-evniuatloa of additional liver sections dated March 24, 1975, there was a typo graphical error on page 1 which referred to Aroclor 1260 instead * '- of 1254. Perhaps this is the basis of your confusion. 1 hope that this will serve to further clarify the situation. Thank you for your assistance and cooperation. Sincerely yours, ; J, C. Calaadra President 1007 212 (,' 02138 WATER PCB-SD0000010921 9 UNITED STAT1 ENVIRONMENTAL PROTECTION AGENCY c WASHINGTON. D.C. 10460 OCT 171975 **ma e? mmmmtm Monsanto Industrial Chemicals Company 800 N. Lindbergh Boulevard ft. Louis, Missouri 83166 ^ 22$< Centlemen: . 9. `*4 Recent governmental sampling data Indieatt tbs presence of Folychlorineted Biphenyls (FCBs) and comparable chemical substances Is the air, In water bodies, and In fish la several areas of the country. In order to determine the nature asd extent of the possible adverse effects resulting Iron the presence of FOB compounds la the - environment, the Environmental Frotectlon Agency (SPA), In cooperation with other federal and State ageneles, Is attempting to determine the sources end amounts of FCBs entering the environment. It Is Important that this effort be carried out without delay. ' .. It Is our understanding that your company handles FCB compounds or mixtures or comparable ehtmleel substenees In Its operations. I C am therefore requesting, pursuant to the authority provided by Section 308 of the Federal Veter Fellutlon Control Act, as amended, 33 V.S.C. 1318, and Section 114 of the Clean Air Act, as amended, 42 U.S.C. 1857c-9, that your company furnish EPA with information pertaining to your use end handling of FCBs and eocperable chemical substances. In addition to a general description, which should Include Information as to sources, quantities, uses, and ultimate disposition, you should respond In detail to the anclesad questions. If any question la not applicable to your company or operations, please so Indicate by responding "not applicable." ' t The information requested herein must be provided notwithstanding its possible characterisation as confidential information or trade * seerets. tShould you so request, however, any information (other than * affluent or emission data) which the Administrator of this Agency determines .to constitute methods or processes entitled to protection a as trade secrets will be maintained as confidential, pursuant to procedures specified in 40 CFR Part 3^ ( C ADM 0062' .-- 21^ WATER PCB-SD0000010922  V 8 1..... 8* * ' 2 -- Within 14 davs ef rtcaiot ef thl lettar. your company suit ^provide 111 information concerning four eurront status and aetlvitlas and eovaslng the twelve sooth period lsmadlataly preceding raeaipt of e Within 30 days following raeaipt of this Setter9 four company must provide ell information for ell of the frier years indicated. The information required herein should he sent directly to the address indicated halow. If you have any questions you say rail"the person indicatedbelev or Hr. Slake A. Silas of our office tit ^202)-755-^731. `` We appreciate your prempt eooperetion ia this matter. Slncer * Sttf&Ley K^Legro Assistant Administrator for Enforcement Enclosure Saglonsl Contact: -'f*<*.- Kr. Earl X Stepiienebh Sireetor, Enforcaacnt Division Environmental fretention Agency 1735 Baltimore Eanaaa City, Kiaaourl 4101 Telephone: (816) 374-2576 a * C ADM 00629 214 WATER PCB-SD0000010923 1 FOLTCHLORINATED BIPHENYL (FCB) COMPOUNDS OR ffimm ' . Within 14 days of neilpt of this letter, your company eust provide ill information cenesrnlnt yeur current status and activities *h7'coverlng the,twelve month period imedlattly preceding receipt of this letter* * . ` Within 30 days following receipt of this letter, yeur cespany must provide all information for all of the prior years indicated. FOE IMPOSES OF THIS WOT, THE PHRASE MfCl COMPOUND OR mnm" includes all CKmxcAL substances oun or ielxeveb it YOU TO II FCB COMPOUNDS OR MIXTURES OR OF A SIMILAR CHEMICAL MATURE, IRRESPECTIVE OF TRADE SAME, ANP SPECIFICALLY INCLUDING V CHLORINATED YERPBENYLS. . 1. For eeeh FCB compound or mixture produce! or l8&QLei.by your company, for each company facility, during each year of 197^. 1872. 1973. .197*. and the first two quarters of 1975l_ I a. The total amount of each FCB compound or mixture produced' . or l^orted. ` ^ b. The name end address of eeeh of your company's fadlltlae <> which handle FCB compounds or mixtures* (including production ( facilities and wholesale end retail outlets), and the -t** amount of each FCB compound or mixture distributed through each facility. * e. The name and address of each customer of eeeh FCB compound or mixture, the amount of eeeh FCB compound or mixture . obtained by eeeh customer from each facility, end etch , . %^^.9H%tpjw/.e^,iellvery-feinn<e) ^or*th,T*fcdlpV;f"mdch'EFCB' ^ compound or mixture. * I. For each FCI compound or mixture incorporated by your cespany late its produets, for each company facility, during each year of 1971, 1972, 1973, 1974, and tha first two quarters of 1975* . A a. A description of each product / * . b. . For oach product the total amount incorporated of each ' FCI compound or mixture. I i . ADH 006292 21 ` i -15 WATER PCB-SD0000010924 8. 2 "X. (continued) ", * # ^ .wTW" aeh preduet the name and addrui @1 aaeh eouret item whieh"your company obtained eeeh fCl compound er mixture, ' and the amount jsf aaeh PCI compound e? mixture obtained frea aaeh source. d Tha mu and address of aaeh of your company's faellltits which handle such preduets (including production facilities and wholesale and retail outlets) and the anount of each product distributed through aaeh facility* a. the naae and address of aaeh austoaer af aaeh product, and It . the amount of each produet obtained by aaeh eustoner Iron U aaeh facility. For consumer produets list only the total V production of aaeh product at aaeh facility and the total 1 number of custoners. Do not provide the name and address | of aaeh cue tester of coasuner produets. 0 3. For aaeh PCI compound or mixture used by your coopany in its ' operations othar than for incorporation into its products, for each company facility, during aaeh year of 1971, 1972, 1973, ' , " 1974, and the first two qu.arters' of 1975s ' a. A description of aaeh use. ' .U b. For eeeh use the total aaount of aaeh PCI compound or mixture. ' c. For aaeh use tha same and address of aaeh source from vhleh * ,, PPA>pqopR.u,nd^.lsixturar:aadt amount of each PCI compound or mixture obtained from aaeh * source. . .. t $ if V 4. For aaeh PCI compound or mixture reclaimed by your company, .' for e'aeh company facility, during aaeh year af 1971, 1972, 1973, 1974, and tha first two quarters af 1975s ,* . ... a. A description of each method.of reelamstion. * ,* . t bi For each method of reelamstion, the total amount of ' * aaeh PCI compound or mixture reclaimed. / .* " i e. The total amount af each PCI compound er mixture reclaimed. `- ' % ADM 0062 -- 216 WATER PCB-SD0000010925 c i. I*r .I -- --n %. u--j* L 3 --d. The mu sal address ef each source free which your , - company obtained fCi compounds, or mixtures, and the mount of oaeh FCB compound or mlxtura obtained from .'!T"*,ila'ch source. *" ' s. far oaeh method. f reclamation, the location of ovary * rselamstion site, the nase and address of oaeh party . Involved la the reelaaatlon ef oaeh FCB compound or . mixture, and the amount of oaeh FCB compound or mixture reclaimed by oaeh party. ' 4 ** 5. For oaeh FCB compound or mixture |laoeed ef by your company (with or without the involvement of ether parties), for each Company faelllty, during aaeh year of 1971, 1972, 1973, 1974, . and the first two quarters ef 1975s . a. A description of aaeh method ef disposal. ' e b. For oaeh method of disposal the total amount of aaeh FCB compound or mixture disposed.* . c. She total amount of oaeh FCI compound or mixture disposed. d. The name and address of oaeh seurea from whleh your company obtained FCB compounds or mixtures, and the Vjf**.-. amount ef aaeh FCB compound or mixture* obtained from aaeh source. For eeeh method of disposal, the loeetion ef every disposal ' site, the name end address of oaeh party involved in the disposal ef eaeh FCB compound or mixture, and the amount of aaeh FCB 15 delipbtmT df-i^ttra'^s'febid W-ly'-ilfeh^ftyr i. The composition by ehemleal asms end pereent by weight of eaeh FCB compound or mixture Aduee, imported, sold, reclaimed, used, oad/or.disposed of by your company since January 1. 1971. * t7. The results ef any and all aampllng-and analysis performed by . your company, its agents or contractors sines January 1, 1971, concerning the following: * * . a. ConcentretIona ef FCi compounds or mixtures in the affluent of any discharges by the company (into waters ef the United States or Publicly Owned Treatment Works) or in the emissions of the company into the air. . ADM 006294 gn WATER PCB-SD0000010926 i ! i f t fc * Jb. ' O J^,0; 4 --b. Th'| flow and/or composition of any discharges or emissions " bjTthe eospfny (into vatara of the United States or Publicly * <Ned treatment Works, or lato the air) which cpntaln PCB sTX""--espiB4 or mixture. * Concentrations of fCi compounds or mixtures in receiving waters (both upstream and downstream) of any discharges by the aompany which contain KB compounds or mixtures and concentrations of PCS compounds or mixtures in the air in . tha area of the company. , . the methods by which PCB compounds or mixtures are transported to, by, and/or from your company, including* .* a. A description of oseh method of transportation, and the form in which PCB compounds or mixtures are treesported by each method. Where different methods of trsns- fereatlon ere used at different facilities specify which ' transportation method Is used at each facility. b. The eases end addresses of all known transporters of PCI | . compounds or mixtures. . t. All oeessioas (including spills) of which pou are aware oh which t PCB compounds or mixtures have or may have been introduced into . the environment. In particular, describe euch occasions Insofar as they involved PCB compounds or mixtures in their liquid state, , ms incorporated into closed systems, or as incorporated into open systems. For each oeeaaion, indicate name and eddzeea of party Involved; dates, time, and location of the discharge or 10. A deacription of any adverse health or environmental effects f which you know or believe to have resulted from the introduction * * ` of PCt compounds or mixtures into the environment. Indicate f any specific occasions including dates, times, locations, amounts, ' and parties involved for which euch effects are known. ` f ; 11. Any and. all other information which you possess concerning: o * I a. The production, importation, reclamation, mat, distribution, " and disposal of PCB compounds or mixtures. I ADH 006295 WATER PCB-SD0000010927 rf * m 5 i 4iiehi|i of fCI eoapounds or mixtures into tha anvlronaeqt. . ^ Zb addition to tho above* SPA would appreciate receiving any other information vhleh you possess concerning the distribution and discharge of rCB eotBpounda ortmixcures by aourees other than pour company, including your coapany'a eustoaers and aoureaa. ' . * a l *f ' !**.* i* .* # . i AOM 006296 r 21 WATER PCB-SD0000010928 Monsanto . ..... e WM.TW. David Wood-St. Louis-B2SD WMCf WIMCl TO etobeirj, iffI **' f-ZPA COfMWTI OH*SPA LWT C*0 10-17 W. 8 Papageorge B2SK - ( * a..- -- `-T. ^ 1. Bill* till si!am* t be fl iiw w@fin6 1. #& 1. Cl. Terphenyls specifically mentioned. * ~ 3.a) Production records answer 1(a). bj Remember we warehoused PCBs for short period 1974 ahaa labor contract renewal. c) Question lc raises a problem that has been at bach of - my mind. #2 report is -supposed to shew "ship to" address, but if this is ease, %diy do 3rd party tf/Gl shipments appear under "bill to" locations. * 4. 02 a) Ho problem b) Ho problem c) Ho problem * d) Ho problem e) Policy - Hanley level? , 5. Q3-Ho problem except 71/72 6. Q4-Ho reclamation. ` . . `^ . 7. Q5-a) Ho problem * b) Difficult. Can split Dielec/Hr/Pydraul j But some returns mixtures of .oil/PCB, etc. e) Can do. . .*d) Difficult ` ) Difficult . i 8. Q6 -- Available , 9. Q7 -.-a) Guess we have . b) Guess we have c) Guess we have ADM 0062 10. 08 - a) Bulk Kail Bulk K - 3 accounts Drum - specify drum construction b) Z. M. Potter . )| MV. t'T* WATER PCB-SD0000010929 lie 09 <Mtould anm@w fren our activity? . lie 01* @ Mont? * Cloraena*yaars ago - Dangarous Question. lie Qll - a) Might fit mm again? b) Should writ this ona wary earafully can uk sobs positiva points * in this aa. e tion. -/dab DifM Wood 1 I I < i* > ADM 006289 52J i WATER PCB-SD0000010930 DEPARTMENT OP HEALTH. EDUCATION. AND WELFARE PUBLIC HEALTH SCR VICE CENTER ret MCAH CONTROL November A, 1975 MATIONAL INSTITUTE *OR OCCURATIONA CARrrv ANO HEALTH IINR|H(lt LANE OCKVUXE. MARYLAND HIM ** Mr. W. 1. fspageorge Speciality end Process Choie&ls Division Monssnto Industrial Chemicals Company 800 North Llndberg Boulevard - it. Louis. Missouri 63166 Dear Mr. Papageorge: . . Thank you for your assistance in providing us with information * ` '* on polychlorinated biphenyls. Enclosed is a copy of the current Intelligence bulletin on poly chlorinated biphenyls which was released yesterday afternoon. Sincerely. Enclosure Harvey F. Stein. Ph.D. Office of Occupational Health Surveillance and Blonetries CC6862 27 WATER PCB-SD0000010931 DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE - fuclic health service center for disease control RATIONAL INSTITUTE *6 OCCUPATIONAL ftAFETV AND health 6*ee fishers lane Rockville. Maryland joiu NOV `31875 Dear Colleague: The enclosed background material has been prepared by this office to Inform the occupational health community of current knowledge concerning Industrial uses and toxicity of poly - chlorinated biphenyls. Your consents and suggestions for changes to future reports are solicited. Enclosure J. William Lloyd, Sc^D. Director Office of Occupational Health CC6< WATER PCB-SD0000010932 BACKGROUND INFORMATION ON POLYCHLORINATED BIPHENYLS Office of Occupational Health Surveillance and Bionetric* NitIona1 Institute for Occupational Safety and Health November 3, 1971 t AC* CCttc*. WATER PCB-SD0000010933 POLYCHLORINATED BIPHENYLS Introduction * . Reports of adverse health offsees in huaans and the denonstmlon of carcinogenic effects in certain anlnsl apeeies liava lad to the reexamination of the distribution of polychlorinated blphanyls (FCBs) in the environment and tha potential health affects of human expoeure. Because the Industrial environment represents the major source of potentially high exposures to ?CBs the Motional Instltuts for Occuptlonal Safety and Health (H10SH) has gathered pertinent information on the manu facture, ses and reported deleterious affects of polychlorinated biphenyls and is advising the occupational health eotaaunity of these hazards. Background * Polychlorinated biphenyls (PCBs) describe a group of synthetic chlorinated organic compounds having the following structure: where aaeh of the tan Z'a can represent either a hydrogen or a ehlorine ton. There are tvo hundred nine different chlorinated biphenyls and they re collectively referred to mb 0SB although many are not actually polychlorinated. Approximately half of these conpounds have been synthesised and characterised. CCBE6 WATER PCB-SD0000010934 Mixtures ' of polychlorinated biphenyls are important Industrial products. The most eonaon tradenames for these mixtures ere Aroelor,* b *e d Znerteen, Kanechlor, and Pyranol. Other known tradenames for PC3- containing produets are listed in Table Z. TCB-containing dielectrics {electrical insulators). are generally referred to as "askarels" in the electrical industry.** Mixtures of polychlorinated biphenyls are aery resistant to degradation, are thermally atable, and resistant to oxidation, acids, bases, and other chemical agents. They are aoluble In most of the common organic solvents and lipids, but only slightly soluble in water, * glycerol, and glycols. PCSs are good electrical insulators. Although most individual polychlorinated biphenyls are* solids at room temperatures, the mixtures vary in consistency from mobile oils to viscous liquids or sticky resins. fCBs are generally prepared Industrially by the chlorination of ' biphenyl with anhydrous chlorine in the presence of iron filings or a ferric chloride catalyst. Trace quantities of chlorinated naphthalenes samples of fCis and it has been suggested that the presence of these Impurities may be of toxicological significance.(1,2,3) * Aroclor Is a registered trademark of the Monsanto Company. b` Znerteen Is a registered trademark of the Vestlnghouse Electric Corporation * for* its brand of fCS containing dielectric fluids. * Kanechlor is a registered trademark of the Kanegafuehi Chemical Industry Company, Ltd. 4 Pyranol is a registered trademark of the General Electric Company f-or Its brand of PCS containing dielectric fluids. at* cote* O' 2; WATER PCB-SD0000010935 3 - Commercial PCI* are generally mixtures of many different chlorinated biphenyls i si shown In TabIs XX* manufactured to meet operational specifications (such si dielectric constant, flash point, fire point, density,* percent chlorine, and color) | these commercial mixtures may vary chemically from batch to. batch. FCBs have found vide use In industry and have bean manufactured in the United States since 1929. the major domestic manufacturer, Monsanto Company, produces FCBs at lauget, Illinois and reports manufacturing 40 million pounds of fCls in the United States during 1974 (down from 85 million pounds In 1970).(4) Monsanto's domestic production and sales of -FCBs by grade and category from 1957 through the first quarter of 1975 are shewn in Table XXX. Uses ' FCBs are employed-in capacitors and transformers because they combine attractive dielectric properties with chemical stability and fire resistance. Approximately twice as many pounds of FCBs are used in the manufacture of capacitors as In the manufacture of transformers. _ Prior to the environmental concern surrounding the persistence and ubiquitousness of FCBs,(5) they were more widely used In Industry as fluids for heat transfer systems, hydraulic systems, gas turbines, and vacuum pumps, as fire retardants, and as plasticizers in adhesives, textiles, surface coatings, sealants, printing, and carbonless copy paper. Beginning In 1971, Monsanto voluntarily restricted its domestic sales f FCBs to closed system dielectric applications in capacitors and transformers.(6) Other current domestic applications of FCBs include use In Investment casting processes, as heat exchange fluids, and as hydraulic ACM eeiise* /? 'Y1! 22 WATER PCB-SD0000010936 fluids. Imports of PCBs have been estimated to exceed 375,003 pounds for 1974. Reclaimed PCBs also are reported to be available. (7) Kore than 95 percent of. all power capacitors contain PCBs. Among their applications are use on electTle utility lines, In air conditioners, and In the ballast of. fluorescent lamp fixtures. PCBs are employed for safety, reliability, and long life, as veil as to achieve size compatibility with equipment and installation requirements. However, non- PCB power capacitors are being Manufactured (e.g.. General Electric's Econol line and Sprague's Eccol line) vhich may serve as alternatives.(B) PCBs are employed In transformers at locations where their proximity to people and/or property demand a fire resistant dielectric. Approximately 5 percent of transformers are PCB filled and each of the transformers so filled contains between 40 and 500 gallons of PCBs (about 235 gallons Is average). Possible alternatives to PCB filled transformers may Include dry transformers (which are larger) as veil as transformers filled with silicone fluids or other materials under evaluation.(*,9) Chlorinated terphenyls, as veil as PCBs, are used in some formulations ef,wax for Investment casting processes.(R) The chemical structure of chlorinated terphenyls resembles that of PCBs. Chlorinated terphenyls have been reported to have toxicological effects similar to those of PCBs.(10) Approximately 330,000 pounds of chlorinated terphenyls were imported into the United Statea s during 1974(11) and 125,532 pounds during 1973.(12) Toxicity * . PCBs are poorly metabolized and tend to accumulate in animal tissues. Including humans.(13,14,15,16,17) The accumulation, particularly in228 228 "SUP CCfceet WATER PCB-SD0000010937 tissues and organs rich in lipids, appears to be higher in the case of penta and sore highly chlorinated biphenyls.(18) Studies have revealed FCis in human fat tissue and blood plasma. FCBs, in amounts greater than 2 parts per million, were reported in 198 of 137 (31 percent) samples of human fat tissue taken from the general population of 18 states and the District of Columbia.(14) PCB. residues ranging up to 29 parts per billion have also been found in 43 percent of 616 plasma samples collected from volunteers in a southeastern U.S. eounty.(15) * . Human: The known toxic effects of FCBs in humans Include an acnelike skin eruption (chloracne), pigmentation of the skin and `nails, excessive eye discharge, swelling of eyelids, and distinctive hair follicles.(19) For a number of years, chloracne of the face and neck has been reported among workers exposed to chlorinated hydrocarbons. Workers exposed to FCBs in the process of insulating cables,(20) in the production of condensers(21) and in the manufacture of ehlorobiphenyls(22) have "* VeporteY"* ihesV's`kin^Testn's''^l'6ng'",,vftS*s/sifehie*k$ ffe "itith Tt disturbances, edema of the face and hands, burning of the eyes, impotence, and hematuria.(16,22) * The toxic affects of FCBs in humans are further illustrated by a 196B ;, outbreak of poisoning in Japan that involved over 1,000 people who Ingested FOB contaminated rice bran ell for a period of several months. The contamination of the ell (estimated 1,500 to 2,000 ppm) occurred when beat transfer pipes Immersed in the oil during processing developed pin sized holes. The clinical aspects of the poisoning included chloracne,229 229 WATER PCB-SD0000010938 brown pigmentation of the skin and ns 11s, distinctive hair follicles, increased eye discharge, swelling of eyelids, transient visual disturbancse, and systemic gastrointes0 tinal symptoms with jaundice(19). in some patients, symptoms persisted . 3 years after tCB exposure was discontinued. Infants lorn to poisoned Bothers had decreased birth * weights, and showed skin discoloration due to TCB placental passage. Two stillbirths to TCB exposed women were also reported.(23) Animal: The toxic effects of FCSs In animals have been studied extensively. Reports of malignant, non-Balignant, and reproductive effects are shown in the following three tables: HAL2C5WKT PATHOLOGIC EFTECTS INDUCED BY KBS IN ANIMALS TCB Mixture Treatisest. Animal Iffeets . Kaneehlor 500(24) 500 ppm, 250 ppm Mice Eaneehlor 400 and 100 ppn In BCaneehlor 300 diet for 32 weeks Liver velght increased with percent chlorine and dosage. Kaneehler 400 end 500 produced liver cell hypertrophy. * 3 * w Sj V . 500 ppm of Kancclilor 100 produced hyper- ** tlostif'h'OduTA'Tn'-'^df-12 nitfrhna , hcpatoecllulor earcinomae in 5 of 12 alee go modules or carcinomas In controls Aroclor 3254(25) Aroclor 1260(26) 300 ppn In diet Mice for 4 A 11 months ; . e e 100 ppm in diet for 21 months gats Increased liver velght. Adenoflbresls in all mice fed for 11 months. None of 22 Bice fed for 11 months had hepatomas. One Of 24 mice led for 6 months had a hepatoma. go hepatomas in eentrel mice. Hepatocellular alteration in 183 of 184 rots fed KBs and in 28 of 123 control tats, geoplastic modules in 26 of 184 PCS fed rats and none ia control rats. Hepatocellular carcinomas In 26 of 184 rats fed KOa and in 1 of 173 control rats. CC88SC AC* 230 WATER PCB-SD0000010939 7 KOH-MAllCXAST FATHOIOCIC EFFECTS IUCE IY FCIS ZN AMLMALS # Smite ? * PCI Hieture *<* . Adslnlstratlen litem ACUTE EFFECTS * c* Unspecified Culnea Pigs Preduet tats Containing Rabbits 42 I Chlorine(27) Subcutaneous injection Skin application Feeding Fatty degeneration and central atrophy of the liver. ' Aretier 1242(28) Culnea pigs Inhalation Areeler 1254 Rats Mice Rabbits Cat 0* Areeler 1242 erodueed no 111 effects on basis of sortality, growth, pathology organ enlargeaent, liver function, or Sernatelegleal changes. Areeler 1254 produced no bars- iul effects regarding growth nr sortality, but did produce enlarged livers with nlere- acoplc evidence of hepatic . cellular injury. Aroeler 1248(29) Monkeys Feeding Weight loss, hair less, south and eyelid edesa, aentfora lesions, decreased hcsoglobin and henato- crit, eevere gastric eucesal ulceration and extresc hypertrophy of the liver.' ' chros'ic rrrrcrs Areeler 1254(30) Rats 4--_v Feeding typertrophy of the liver cells, **. *****: r'r*- -0h.rem)t-igenc.in. therRuptfw cells, lipid accumulation In the eyteplass of bepatocytes and adenoflbrosis. . #0 ** 0 0 0* CCbe** * 231 WATER PCB-SD0000010940 9a -8- HEPAODUCTIVE EFFECTS .OF FCBS IN ANIMALS KB mature . Anfaal Areeler 1242(31) Chlekenr Areelor 1254 Areeler 1260 ieute ef Administration . Feedlnf niii Areeler 1242 and 1254 reduced egg production and hatehabillty and caused thin eggshells. Areelor 1260 produced no . Manful effeees. ' Areeler 1254(32) Mallards Sebwhltes Feeding Me adverse effeets. Aroeler 1254(33) Fheasant Feeding Medueed egg preduetlen and Matchablllty. Aroelor 1254(34) Mink Feeding Severely affected repreductlen. Areeler 1248(29) Ferula aonkeys Feedlog . . Medueed ability te beeeae pregnant. Fregnaneies produced snail infants with *FCSs in tissues. . s *>* ,f.*:A^.v1>a4'V. %.>-e .. AC>* Cwteli 2 WATER PCB-SDOOOO010941 Occupational' Exposure . It is estimated chat 12,000 people are occupationally exposed to polychlorinated biphenyls. The 'majority of these exposures are in capacitor production and in Investment casting processes. Permissible Occupational`Exposure The current Occupational Safety and Health Administration, Department of Labor standards for chlorinated biphenyls are 1 mg/cubic meter for 42 percent chlorine mixtures and .5 mg/cubic meter for 54 percent chlorine mixtures. These are based on the Threshold Limit Values (TLV) established by the American Conference of Governmental Industrial Hygienists.(35) CCel^J 233 WATER PCB-SD0000010942 BIBLIOGRAPHY 1. Hutzinger, 0., Safe, f., and Zltko, V.s The Chemistry of PCB's, CRC Press, Cleveland, Ohio, p. 22, 1974 2. Bowes, G.W., Mulvihill, M.J., Simoneit, B.R.T., Burlingame, A.L., and Risebrough, R.U.: Identification of Chlorinated Dibenzofurans in Acerican Polychlorinated Biphenyls, Mature, 256:305, 1975 3. Curley, A., Burse, V.V., Jennings, R.W., Villanueva, I.C., and Kimbrough, R.D.: Evidence of Te trachlorodibenzof uran (TCDF) in Aroclor 1254 and the Urine of Rats Following Dietary Exposure to Aroclor 1254, Bui Environ Contaa and Toxicol, 14(2)*. 153-56, 1975 4. Communication from Monsanto Industrial Chemicals Company, St. Louis, Missouri, September, 1975 5. Interagency Task Force on PCBs: PCBs and the Environment, COM-72 10419, Washington, DC, March 20, 1972 6. Polychlorinated Biphenyls: Monsanto Company's Prograa of Restricted . Sales and Controlled Manufacturing Practices, Monsanto Industrial Chemicals Company, St. Louis, Missouri, October, 1974 . 7. Clcnn Schweitzer, Offlee of Toxic Substances, U.S. Environmental Protection Agency, testimony at an August, 1975, Wisconsin hearing, quoted in Toxic Materials News, p. 139, September 15, 1975 8. Personal corsunications with representatives of the industry, October 1975 9. Dow Coming Dielectric Liquids for Power Transformers, Dow Corning Corporation, Midland, Michigan, received September, 1975 (booklet not 10. Allen, J.R., Abrahamson, L.J., and Norback, D.R.: Biological Effects of Polychlorinated Biphenyls and Triphenyls on the Subhuman Primate, Environmental Research, ' 6:934 4-54, 1973 11. Telephone conversation with a representative of the II.S. International Trade Commission, Washington, DC, September, 1975 i, * 12. U.S. Tarriff Commission: Imports of Benzoid Chemicals and Products, Washington, DC. ,^p. 24, 1973 13. Biros, F.J., Walker, A.C., and Medbery, A.: Polychlorinated Biphenyls In Human Adipose Tissue, Bull Environ Con tarn and Toxicol, 5:317-23, 197014 14. Fobs, A.R.: Levels of Polychlorinated Biphenyls in Adipose Tissue of the General Population of the Nation, Environmental Health Perspective, 1:79-80, 1972 . CG6b94 2 WATER PCB-SD0000010943 15. Finklea, J.t Friester, L.E., Creason, J.P., Hauser, TI, Hlnners, T., and Hammer, D.I.: Folychlorlnaced Biphenyl Residues In Hunan Pls;a Expose a Major Urban Pollution Problea, AJPH, 62(5):645-51, 19?2 16. Kimbrough, R.D.: The Toxicity of Polychlorinated Polycyclic Compounds and Related Chenicals, Critical Reviews Toxicology, CRC Press, Ine., 2(4):445-98, 1974 . 17. International Agency for Research on Cancer, IARC Monographs on the Evaluation of Carcinogenic Risk of Chenicals to Man, 7:261-89, 1974 18. Hutzlnger, 0., at al., op. clt., p. 2 19. Kuratsune, M., Yoshimura, T., Matsuzaka, J., and Yanasuchi, A.: Yusho, a Poisoning Caused by Rice Oil Contaninated with Polychlorinated Biphenyls, B5MHA Health Reports, 36:1083-91, 1971 20. Fulton, V.B. and Matthews, J.L.: A Prellnlnary Report of the Dermatological and Systemic Effects of Exposure to HexachloroHaphthalene and Chloro-Diphenyl, Bureau of Industrial Standards, Harrisburg, Pennsylvania, 1936 21. Mayers, M.R. and Silverberg, M.C.: Skin Conditions Resulting from Exposure to Certain Chlorinated Hydrocarbons, J Indust Hyg Toxicol, 20:244-58, 1938 . 22. Schwartz, L.: Dermatitis from Synthetic Resins and Waxes, An J Pub Health, 26:586-92, 1936 23. Miller, R.W.j Cola-colored Babies, Chlorobiphenyl Poisoning in Japan, Teratology, 4:211-12, 1971 24. Ito, N., Nagasaki, H., Aral, M., Masayuki, A., Maklura, S., Suginara, S., and Hirao, X.: Histopathologic Studies on Liver Tunorigenesis Induced in Mice by Technical .Polychlorinated Biphenyls and Its S'* -3S freset ing Yiff eetf en*TCiv'e^^tiafters* ^Indt^se^'^ 'l>y * ^Be'Szehfe' "HexVchl'eriev, JNCI, 51(5):1637-46, 1973 25. Xiabrough, R.D. ' and Linder, R.l.s Induction of Adenofibrosis and llepatomas of the Liver in BALB/cJ Mice by Polychlorinated Biphenyls (Aroclor 1254), JNCI, 53(2):547-52, 1974 ' 26. Kimbrough, R.D., Squire, R.A., Linder, R.E., Strandberg, J.S.. Montali,. R.J., and Burse, V.W.s Induction of Liver Tumors in Rats by Polychlorinated feiphenyl Aroclor 1260, JNCI, (in press), December, 1975 27. Miller, J.W.s Pathologic Changes in Animals Exposed to a Commercial Chlorinated Diphenyl, Pub Health Reports, pp. 1085-93, August 18, 1944 ACM CCI695 WATER PCB-SD0000010944 28. freon* J.F., Cleveland* F.P., Coppell, J.W., and Atehley, R.W.: The Toxicity of the Vapors of Aroclor 1242 and Aroclor 1254, As 2nd Hyg `Quart, 17 s 204--13, 1956 29. Allen, J.R.: Response of Frlnates to FCB Exposures, Federation Proceedings, 34s1675-79, 1975 30. Kimbrough, R.D., Linder, R.E., and Caines, T.B.: Changes in Liver of Rats Fed Polychlorinated Biphenyls, Health, 25:354-fir4, 1972 Morphological Arch Environ 31. Keplinger, M.L., Fancher, O.E., and Calandra, J.C.: Toxicologic Studies with Polychlorinated Biphenyls, Toxicol Appl Pharracol, 19:402, 1971 32. Heath, R.G., Spann, J.V., Kreitzer,* J.R., and Vance, C.: Effects of Polychlorinated Biphenyls on Birds, Proc 15th Intern Omithol Congr, Leiden, Holland, p. 476, 1972 33. Dahlgren, R.B., Linder, R.L., and Carlson, C.W.j Polychlorinated Biphenyls: Their Effects on Penned Pheasants, Environ Health . Perspect, 1:89, 1972 34. Ringer, R.K., Aulerich, R.J., and Zabik, M.: Effect of Dietary Polychlorinated Biphenyls on Growth and Reproduction of Mink, ACS Div Water Air and Waste Chemistry, Preprints of Papers 12:149, 1972 35. Federal Register, Vol. 37, Ho. 202, p. 22140, Wednesday, October 18, 1972 ** L. ME**?.* V.fa'*-*' l AL* CCcc^t 2 WATER PCB-SD0000010945 BJLE l TRADENAMES TOR 1QI0UN PCB CONTAINING PRODUCTS Tradename Aroclor Chlorextol Clophen Dykanol Fericlor Inerteen JCaneehlor Noflamol Phenoclor Pyralene Tradename Owner ' Monsanto Company St. Louis, MO . Allis-Chalmers Milwaukee, MX ' Farbenfabrieken Bayer GmbH Germany Federal Pacific Electric Co. Newark, NJ Caffaro S.P.A. Italy . Vestinghouse Electric Corp. Pittsburgh, PA Xanegafuchi Chemical Industry Co., Ltd. Japan Vagner Electric Corporation Newark, KJ Prodelec France Prodelec Pyranol . Santotherm Thermlnol* 1 General Electric Co Schenectady, NY Mltsublshl-Monsanto Japan Monsanto Co. St. Louis, MO Therminol products now formulated in the U.S. do not contain PCBs. OOot^1 At* 23'/ WATER PCB-SD0000010946 ApproxInara Chloriao Content Cooponenta Biphenyl MBnechlerebiphsayia Aroclor 1221* 211 a 11 31 Aroclor 1014* 421 <0.1 1 TAUI.K 11 description or re* mixtures Aroclor 1242* 42X Aroclor 1254* 341 Aroclor 1260* SOI <0.1 1 <0.1 <0.1 4 XaCchlor 300* i s* j! i i laoechler 400* 4SX Dichlorobiphenyla 32 20 14 . 0.3 P3 Trlchloroblpheeyla 4 37 49 1 Tetrachlerobipheayla 2 21 23 ; 21 tfo 33 44 ftntachlorobiphaayla lasachlorobipheayis Meptacbleroblpheayle Octachlorobiphcnyla % Monachlorobiphenyla <0.3 1 none <0.1 detected aono MM detected detected nose naee detected detected i 4S 1 23 <0.1 4 none . none detected detected 12 31 41 i 1 >*0.4 7 i 1 ? ! 1 . 14 3 9 . - Kancchler 300* 331 27 33 13 Aroclor ie registered tn4tMtk ( die Noauott Company. KnicMar is a registered tradeaerh of tbi Kanegafuchi Chnlul Industry Coupon?, IU A U Bust be sopbasired tbat thaaa are approximate coapoeltlene ml the fCB aisturde and tbst a particular produce .say vary |a cbeuical ceapositioa free batch to batch. i * Welr.ht-welghi percent. None detected - less than 0.01Z. Source of component jcoapositlonel Menaante Company, Rooted ia Uutaloger* 0., at al., op. cit., p. 23 * * fercent. Source of coopoaent conpesitieoss Thruetoo, A.* PCI Newsletter* Noi 3* July 1971* Rooted ia Hutsinger* 0.* at al.* op. cit., p. 23 ** * Pereeot. Sourco of coapoaeac conpoaltiene: Xto* N.* ot al., op. cit.* p. e e ls *6 GnO 8! WATER PCB-SD0000010947 196S 1966 MONSANTO INDUSTRIAL CHEMICALS COMPANY ' 1965 THROUGH 1975 ? (Thousands of Pounds) J t 1967 1968 1969 1970 1971 i ' 1972 1973 (1st quarter) 1974 ' 1975 ' 11. S. PRODUCTION DOMESTIC SALES U.S. EXPORT SALES 60480 51796 4234 DOMESTIC SALES BY CATEGORY 65849 59078 6852 75309 62466 8124 82854 65116 11231 76389 67194 10624 85054 73061 13651 34994 v 38600 34301 , 26408 V*> 6388 4 i Heat Transfer Hydraulics/ Lubricants Mlsc. Industrial Transformer Capacitor Plasticizer Applications Petroleum Additives 1237 4616 1841 8657 23749 11696 9 -- DOMESTIC SALES BY PCI GRADE 1766 4258 1779 8910 28884 13481 -- 2262 4643 1426 11071 29703 13361 -- 2529 5765 1283 11585 29550 14404 -- 3050 8039 1079 12105 25022 16460 1439 3958 7403 1627 13828 26708 19537 -- 3060 5 752 1552 f 0 1155 ' 0 111347" 14141JC* 25656 3259 f i? -- *s ! 0 0 Aroclor 1221 .5 , 369 528 442 136 507 1476 2215 j 171 Aroclor 1232 * 7 16 25 90 273 260 171 I 0 Aroclor 1242 31533 39557 43055 44853 45491 48588 21981 | 728 Aroclor 1248 5565 5015 4704 4894 5650 4073 213 ? 807 Aroclor 1254 7737 7035 6696 8891 9822 12421 4661 i 3495 Arotlor 1260 5831 5875 6417 5252 4439 4890 1725 305 .raptor 1262 ' 558 768 840 720 712 1023 1a 0 Arocldr 1268 196 284 * 287 280 300 330 o? 0 Aroclor 1016 f * 0 0 0 0 0 0 3334 i 20902 * -r---------------------------- :---------------------------------------------- :-------------------------------------------------------------------------------- :-------------------- 1------------- * Used prinsrilyin capacitors * ** Used primarilyin transfoners w i t t5A 42178 37742 8346 37742 35 .0 6200 0 7976 0 0 0 23531 40466 34406 5395 8532 7986 1538 34406 7986 57 10 0 6207 *0 6185 .0 0 2201** 0 2115** 0 00 0 0 2195S 3660* t* P1 ACM C 0 6 6 S 5 o\ rcos A 1 WATER PCB-SD0000010948 t'ta IMUUI'AUUm* AIIM MONSANTO INDUSTRIAL CHEMICALS COMP, 1937 TIIKOUCII 1964 (Thousands of Pounds) 1957 1958 1959 1960 1961 > 1962 1963 1964 U.S. PRODUCTION DOMESTIC SALES U.S. EXPORT SALES DOMESTIC SALES BY CATEGORY (1) 32299 Cl) Cl) 26061 CD Cl) 31310 C2) 37919 35214 C2) 36515 37538 CD 38353 38043 ? (D 4 i 44734 38132 3647 50833 44869 4096 llcat Transfer llydraul ics/Lubrlcants Miscellaneous Industrial Transformer Capacitor Plasticizer Applications Petroleum Additives 1612 704 12955 17028 CD . 1549 755 5719 14099 3939 -- 2685 1569 5984 16499 4573 --* 2523 1559 7921 16967 6244 -- 4110 2114 6281 15935 9098 3. f 3915 y 1681 i 7984 {15382 8924 '4 582 3945 1528 7290 15606 9181 929 4374 1692 7997 19540 10337 DOMESTIC SALES BY PCB GRADE Aroclor 1221` Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 12S4 % *. 23 196 18222 1779 4461 16 113 10444 2559 6691 254 240 13598 3384 6754 ' 103 155 18196 2827 6088 94 241 19827 4023 6294 H iV 140 \ 224 {20654 ) 3463 S 6325 361 13 18510 3013 5911 596 13 23571 5238 6280 Aroclor 1260 Aroclor 1262 Aroclor 1268 Aroclor 1016 7587 5982 6619 7330 6540 6595 7626 8535 ' 31 184 359 326 361 *32 414 * 446 -- 72 102 189 158 DO 284 190 mm a* d . mm A r* (1) Production,figures and Plasticizer Applications figures unavailable during year indicated. (2) U.S. Export Sales figures unavailable during year Indicated. - ------ ----- - -- - ' SOURCES Monsanto Industrial Chemicals Company, St. Louis, Missouri, September, 197S. cctscc O u ] sJ WATER PCB-SD0000010949 MONSANTO INOUSTSUW CMMICJU.S CO. tOO N. ImmM'I* Ia.I*. fitil. le8. uuhwi 13 Mur OUt tf*lOM December 11* Si7 / Mr. Carl 3, Stephenson Director, Enforcement Division Environmental Protection Agency 1735 Baltimore Kansas City* Missouri 44108 * ' Pear Mr. Stephensons . .. . ' . . B. ' ' , 0m ^ Attached is a response to the questionnaire which accompanied Mr. Stanley tegro'fi letter dated October 17, 1975. To the best of my knowledge and belief, the information contained in this response represents the best information available to Monsanto. 2f Z can be of further assistance* please let me know. Sincerely, . Ho I. f&p&geerg - ^ Manager, Product Acceptability Process Chemicals Olvlsien Jt Attachment CCs Mr. Stanley U. Logro* ' US Environmental Protection Agency 401--5" Street, SW h'aahingicn, O.C. 10460 WATER PCB-SD0000010950 tOifCHLSRINATCP BIPHEMVt (PCB) eeHKtffflf OB HtSTJRgS fa tMa maponm the phras #fci compound or mixture inelMm %kom MtrUli listed under lase Products in Exhibit A. . 1. (a) - Monsanto Industrial Chemicals Company does nee ispere KB . compounds or mixtures. Amounts produced for 1971, 1972, 1973, 1974 and the first three quarters of 1971 are included in Exhibit Co (b) Production faeilitisifi ' ,TVor 1971 and 1922 . ' ** ** * ` f ftonsanto Cmpmy . ; Box 249 * ` . Anniston, Alabama 38201 . ' .` ' . * .. for 1971 to present `* ftonsanto Company flouts 3 .` Sauftt, Illinois 82201 . '. ' * ' . the amounts produced at the Annisten, Alabama plant are shewn Exhibit 0. the S&uee, Illinois unit produced the amounts ' shown on Exhibit E. Khoissals and retail outlets are not used. Ce) See Exhibit f for 1971, Exhibit C for 1972, Exhibit K for 1973 .'end 1974 and Exhibit X for 1975. The KB compounds or mixtures ' vabaft*>faeiU,|tein txhibit 0. The remain inf were shipped from the iaufet, XllinViV 2. (a) , . * (b) (e) \ Sen Exhibit A paqes 2, 3 and 4 and Exhibit 1. Sea Exhibit A - pefes 2, 3 and I.. * ' The KB compounds or mixtures used were produced by Monsanto. Sh 1(b). Id) Production facilities are those shown under 1(b) And far 1971 and 1972 also included Monsanto Company, 1700 South Second Street, St. Louis. Missouri 83177. Products distributed 'through r.tnr..into*s Anniston. Alabama unit are shewn on Exhibit b. Ail fy!raul f relucts wore .listributwJ through the St. Louis. Missouri facility. Remainder of products distributed throuqh the Saufct, Illinois unit. Amounts distri are shown on the exhibits listed in 2e below. 00 242 *0* WATER PCB-SD0000010951 Ir . a * <) Im Exhibit F for if71, Exhibit 6 for 1172, Exhibit K for 1171 md if74 and Exhibit X for if79. Tho produett' obtained from thr Anniston, Alabama foeilifey oro llotod in Exhibit 0. The Pydraul products eriflasted ot the St. Louis, Missouri urut; the remaining wore shipped from the Saugee, Xlliaeis facility. tf do ssot manufacture consumer product* containing PCI compounds ^ or mixtures . , S. CaJ Burihf i71 and 1572 PCI compounds or mixtures were used ss best trsnsfer fluids, hydrsulie fluids and in transformers and eapaelters. During ths latter part of if72, if73, If74 and * if79 PCI compounds or. mixtures are only present in transferrers - mod capacitors. * . * ' . . (b) See Isbibie 3, Amevmts shewn are for total Monsanto Company osa<)o. Mo records are available to determine specific company . facility. Xnertaen was used in transformers. Pydrauls in air comprssssrs. Thsrminols in industrial heat transfer systems. Ce) The PCI products were all produced by Monsanto Company. The: spcsific sources are shown on Exhibit J. . 4. PCI compounds or mixtures are not reclaimed. S. . ".a*..-, (a) During lf71 and lf72 solid waste material contaminated with PCS compounds or mixtures were buried in a secure landfill located within a fenced area on property owned by Monsanto Company at the Annisten, Alabama facility. Similar waste has . also been buried in a secure landfill located on Monsanto Company property at the lauget, Illinois facility during she period *1S71 - lf?S. Liquid wastes have been disposed by incineration for the period 1971 - 1979 in a high temperature unit located ,,lt .tha-Seutget,.411iO!i^.fi^i.A.^y.^. During. 1975 *elid waste was sett to Texas Ecologists, P. 6. Sex'Sb^T^T^sEdtfh,* fSXas (b) Wasee materials containing PCS compounds or mixtures are received from many sources. Tho type of PCS compound or mixture in the waste is unknown. The concentration is also unknown. Solid waste is estimated as``containing levels ranging from the ppm level to 50% by weight. Liquid waste is estimated to contain about 98% PCI compound or mitxture. 0 9* For amounts disposed see Exhibit X. No to the amounts shown refer to the total weight of waste. The actual PCI content is . unknown. (c) Sei Exhibit r. for total waste disposed. Concentration and type of PCI compound or mixture are unknown.243 243 I ,,,,,, 00 WATER PCB-SD0000010952 14} See 2xhlblt to' Total amounts of vasta an shown* eoneaneratlen md typ of PC* compound or mixture an unknown*. * , (A) Soo ia for mm and location. too exhibit X for aMunc disposed. I, Soo exhibit A. Monsanto Company decs not* import or reclaim PCI impounds os mixtures. Composition of disposed material i mkmm but can range from ppm iovol to 100% by woifht PCI. ' ; ' . 7. '(a) i@ exhibit M for Saugat* Slllnois facility vasts affluent analysts. Sat Exhibit M for Anniston* Alabama facility watar affluent analysts.,,fr PCI amistlant to the atmotphart at tha Saugat* Illinois facility mi Exhibit O. Analyses of air emissions were na%^ada at the Anniston* Alabama facility @J Sat Exhibits M* V and @ Ce) Mo information "is available regarding the Anniston* Alabama facility. He information is available relating to KB con- . contention in tha air in the area of the faucet* Illinois facil: Samples of the Mississippi Aivar varo taken in 1971. Results vara as followst . \ * *S8bt>1o Pats , Location at/1 PCI 10/30/72 12/13/72 * T.B. fridge (downstream) Chain of Keeks Bridge . /llMiPPAIft\ 0.00012 0.0002 - 0.0( 0.0002 - 0.Of e Q>) fee Exhibit P for transporters cf PCI compounds or'mixturaa from Monsanto facilities. Transporters of material returned for disposal can ba any common carrier serving tha it. Louis " Missouri area. ADH 0071 WATER PCB-SD0000010953 I - f, Wommta Company is not m&m @f an? scation in %(hieh PCS empom$ or mixtures vert introduced into the onvirenMnt which it not alrealy - known to nprnmtitivn of the Environmental trotsetion Agency. Ixiaplti include ths contamination of fish msI in North Carolina, ths drainage of fluid from a transformer in transit in Tsnnsss * and ths leakage of fluid from a dmpsd transformer in ths Ouwaadsh waterway in Washington. '; 10. Monsanto Company is not swart of any health or environmental offsets tssultinf from ths introduction of VCS eonpounds or sdxtures into ths environment which has not been reported in the scientific and popular press and already.X>oM& to' representatives of the Environmental Pretaetiefj Agency. 11. (a) Monsanto Company has received reports that shout 1100 drum, of PCS compounds- or mixtures are heinf offered hy a company located in the northeastern O.S. fer sale for any application, this inforrnation was received from Hr. Robert hahaa, Huh Fabric . leather Cempany, 7 Charlton Street, Everett, Massachusetts Q2J49; . Chit has been discussed with a representative of ths Environs*aeal Protection Agency. : .f * Sscently Pyramid Chemical Salt* Company, 1035 Virginia Orive, * . * Port Washington, Pennsylvania 11034 has advertised the ' availability fer any application of Arcelor 1221, Arcelor 1232 ' and Arelor 1460. A representative of the Environmental Protection Agency has been informed. .. "*'*** . W ^ V k' V,245 245 a dm oc WATER PCB-SD0000010954 F. J. Fitzgerald Vice-President, Monsanto Chemical Company . January 14, 1976 Good afternoon, my name is Jack Fitzgerald. I am a vice president of Monsanto Company, a member of its Corporate Administrative Committee and managing director of Monsanto In dustrial Chemicals Company, ah operating unit of Monsanto Com pany. Since I am responsible for the operating unit which manufac tures polychlorinated biphenyl dielectric fluids, John Hanley, our president, has asked me to represent him today and reaffirm to you Monsanto's commitment to continue working with the EPA and the electrical industry in finding solutions to the PCB issue. Let me state at the outset that Monsanto agrees wholeheartedly with EPA's desire to work toward the goal of eventually eliminating all uses of PCB's. Monsanto has already taken several steps designed to restrict the entry of PCB's into the environment. First, Monsanto began restricting the use of PCB's 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 PCB's by a Federal Interagency Task Force in 1972. Secondly, Monsanto has been working for a number of years on non-PCB replacement products. These materials, designed to replace PCB fluids in capacitors and transformers, are currently being evaluated by the major electrical manufacturers in the United a * ipta.tsS'Ui. 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 PCB's and the ir replaceable role they have served in our electrical-industrial envi ronment for the past 45 years. The challenge: 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. Let me emphasize that wc have no desire to remain in the l'CI> manufacturing business any longer than is necessary. By this I mean as soon as we are satisfied that the electrical power supply industry's needs for usable, acceptable alternate dielectric fluids have been met by whomever, Monsanto will voluntarily shut down WATER PCB-SD0000010955 f its PCB manufacturing unit. In the interim, we will continue to work with industry and government to ensure that the restrictive measures and controls we implemented in the early 1970's remain in force and are diligently pursued. l I t I* ; * i 't/SL' * S'.* % ,* * 8* 247 WATER PCB-SD0000010956 NEWS FOR RELEASE--: IMMEDIATELY 1976 Monsanto MONSANTO INDUSTRIAL CHEMICALS 0. R. CishOD (314) 694-2891 public utLATioNS eePABTb BOO W. Lmdtorgn Seu'wsre st. Uuw. um&i i S3iea MONSANTO RAISES PCB PRICI CITES PHASE OUT EXPENSES ST. LOUIS* Dec. 17 ~ Monsanto Company said today that effective Jan. 1* 1977, it will increase the price of all grades of its polychlorinated biphenyl (PCS) dielectric insulating fluids by about 24 per cent. Monsanto markets PCSs exclusively to the electrical power supply industry for use as fire resistant dielectric fluids in transformers and capacitors. Monsanto announced last October its intentions to terminate the production, sale and distribution of its PCB products by Oct. 31, 1977. The company said that it would have withdrawn sooner, but a majority of its customers required that much lead According to Monsanto, this protracted phase out program has caused certain production imbalances that make efficient ope ration impossible. The company said the resulting higher unit costs, combined with other phase-out-re1ated expenses, were major reasons behind the price increase. oOo-248 *0H 002323 248 WATER PCB-SD0000010957 Dear Mr. Jones: As you know, Monsanto will completely withdraw as a supplier of PC3 dielectrics October 31, 1977. Concurrent with this withdrawal date, Monsanto will step caking available to ask&rel users the ''Transformer Askarel Inspection and Maintenance Guide", Bulletin No. IC/PF-3SR-2. Although operators of askarel transformers have used this askarel guide as a reference manual in the nest, environ, cental regulations on PCB's ere changing rapidly and have cade the bulletin obsolete. This bulletin will not be updated. (May I suggest that -you destroy all copies in your files and offices so we don't inadvertently supply obsolete information tc the industry.) If your company has ever used our bulletin as a supplement to your own literature, we want you to be avrare of our decisicn. Equally, we ask you tc note that in your own use of this bulletin you recognise that tne last edition was issued August 1976. Iz should not be relied upon new or in the future. Sincerely, fi. ULl i-'J. A. Alley'Industry Specialist Dielectrics tme it el Mariam* Cemetny 10032 * 24$ WATER PCB-SD0000010958 PAGE 1 OF 4 Monsanto mat nal safety data ! NOTE: NO REPRESENTATION IS MADE AS TO THE ACCURACY Of THE INFORMATION AND RECOMMENDATIONS HEREIN. SEE PAGE 4 FOR CONDITIONS UNDER WHICH DATA ARE FURNISHED. MONSANTO PRODUCT NAME POLYCHLORINATED BIPHENYLS--PCB's* 'Sm page 4 for definition and notes MONSANTO COMPANY 800 N. LINDBERGH BLVD. ST. LOUIS, MO. 63166 EMERGENCY PHONE NO. ICALL 60LLIHI 014)894.1000 PRODUCT IDENTIFICATION Synonyms Trade Names (Commonly used Monsanto products) PCB'a Chlorodiphenyl (_% P) Chlorinated biphenyl Polychlorinated biphenyl Chlorinated biphenyls (approx. _% Cl) Aekarel** Arcelor' Series 1016.1221.1232.1242,12a, 12S4.1260 Pyrenol8 Series Inerteen** Series Therminl*' PH Serioe See pegs 4 for notes CAS No. 001336363.053469219, 021672296,01109769,011096825 end Others WARNING STATEMENTS Federal regulations under the Toxic Substances Control Act require PCi's and PCS items to be merited. (Cheek * regulations for details.*) Inoestion--Consult a physician. Do not induce vomiting or give any oily laxativee. NOTE TO PHYSICIAN--If large amounts ingsstod, gastric lavage is suggested. Skin--tf liquid or solid PCB'a are splashed or spilled on skin, contaminated clothing should bo removed and the skin washod thoroughly with soap and wator, NOTE TO PHYSICIAN--Hot PCB'a may cause thermal bums. Eyes--Eyes should be irrigated immediately with copious quantities of running water for at least 15 minutes H liquid or solid PCi's get into thorn. A petrolatum-based ophthalmic ointment may be applied to the eye to relieve the irritating offsets of PCB'a. Inhalation--Removo to fresh air. If skin rash or respiratory irritation persists, consult a physician. NOTE TO PHYSICIAN--If electrical equipment arcs ever. PCB's or other chlorinated hydrocarbon dielectric fluids mey decompose to producs HCI, hydrochloric acid, a respiratory irritant e er ; f ( J f * j J 464 250 ADM OC2159 WATER PCB-SD0000010959 inunMUiU MATERIAL SAFETY DAT' PACE 2C OCCUPATIONAL CONTROL PROCEDURES Inhalation--Workplace exposure should ba maintaintad balaw tha OSHA eight-hour. time-weighted ave fa Threshold Limit Valua (TLV). At room temperatures, tha hasard of inhalation is eonsidared slight t absent. Chamical cartridge respirators or gas masks approved for protection against organic vapors at recommended in tha event of spilla or leaka of hot fluids. These will provido gaod protection up to th concentrations shown on tho approval labels and tha odor will give ample warning if it comes through th device. Self-contained breathing apparatus should be worn when PCI's are encountered in an enclose spafee. . Threshold Limit Value (TIV)--Chlerodiphenyl (42% chlorine) 1.0 mgfeu.m. Chlorodiphenyl (54% chlorine) 0.1 mg/su.m. Skin Contact--Avoid prolonged or repeated skin contact Where employees may come Into direct eontac with PCB'a, protective clothing imparvioua to PCi'a should be worn. Gloves, boots, overshoes and bib-typ aprons that eovor tho boot tops should be weed when necessary. This protectivo equipment should b regularly inspected ter defects and to onaurs that H is in clean and satisfactory working condition. Contam natod clothing, gloves, ate., should be disposed of as prescribed by regulations. Eve Contact--Evo protection should be used where there is a possibility of liquid splashes. Ingeation--Ingestion of these materials is generally net a problem in industry. MATERIAL SAFETY DATA Monsanto PHYSIOLOGICAL EFFECTS SUMMARY: Skin Contact--Can bo absorbed through intact skin. Local action on skin is similar te that of common organi solvents wharo contact loads to removal of natural fats and oils with subsequent drying and cracking af th akin. A potential exists for tho contracting of chloracne. Eye Contact--Tho liquid products and thoir vapors aro moderately irritating to eye tissues. Ingcstian--.Tho acute oral toxicities of the undiluted compounds are: LDm rats--8.65 gm/kg for 42% chlor nated, and 11.9 gm/kg for 54% chlorinated--"slightly toxic." Inhalation--Animal experiments of varying duration and at different air concentrations show that for similt exposure conditions, tho 54% chlorinated material produces more liver injury than the 42% chlorinate Other--There aro literature reports that PCB's can impair reproduction function in monkeys. A study reports in the literature with fomale rats using Aroclor* 1260 stated that Aroclor 1260 caused liver esneors. Monsarit sponsorod animaffeeding studios of Aroclor 1242,1254 and 1260. Theso compounds, fed to both sexes of rat: did not produco cancors. Tho National Caneor Institute performed a study in 1977 using Aroclor 1254 with bot sexes of rats. NCI stated that tho PCB, Arodor 1254 was not carcinogenic under the conditions of the bioassay. The consistent finding In animal studies with PCB's is that they produce liver injury following prolonged an< repeated exposure by any route, if the expesure is ofsufficiont dogree and duration. Liver injury is produce: first, end by exposures that are loss than that alleged te cause cancer in redents. Therefore, exposure by a' routes should be kept sufficiently low to prevent liver injury. FIRE PROTECTION INFORMATION* 251 Fire and Explosion--Chlorodiphenyla are essentially non-combustible compounds. They may dtce-r form CO. CO,, NCI. phenolies and aldehydes under severe conditions such as exposure to fla-ne surfaces. No phosgene is formed. 251 i WATER PCB-SD0000010960 Monsanto ma thial safety data @ Standard fir# fighting wearing apparal and self-contained breathing apparatus should ba worn whan fightinc firs* that involve possible exposure to chlorodiphonyla. Fire fighting equipment must be thoroughly cleanse and decontaminated after use. PHYSICAL DATA TABU I--fprtks of Selected Arectera Property CollriAPHA) Physical state Stability Density Illegal 25*0 Specific gravity S/154T Distillation range PC) Acidity mgKOH/g, maximum Fire point PC) Viscosity (10CTF) 1011 -- mobile oil inert 11.40 1221 * 100 mobile oil inert iJS in 100 mobile oil inert 10JS 1242 100 mobile oil Iffrt 11.S0 1246 100 mobile oil inert 12.04 12S4 100 viscous liquid inert 1242 . 1J6-U7 8*25* 123-356 1.18-1.19 8-25* 275-320 1J7-1JI Jt-25* IS0-32S 1J0-1JS X-25* 325-366 140-141 x-65* $40-375 148-140 845* 365-390 4)14 4)14 4)15 4)10 4)10 none to boiling point 7e 1-81 176 38-41 236 44-51 none to boiling point 82-92 none to boiling point 185-240 none to boiling point 1400-2500 1260 150 fticky rosin inert 1340 145-146 8-90* 185420 414 none to boiling point * REACTIVITY DATA PCS'* are very stable, fire-resistant compounds. SPILL, LEAK & DISPOSAL INFORMATION . .. if PCB's leak or are spilled, the following steps should bo taken immediately: All non-essential personnel should leave the leak or spill area. The area should be adequately ventilated to prevent the accumulation of vapors. The spill/leak ahould be contained. Loss to sewer systems, navigable waterways and streams should be prevented. Spillaftoaks ahould be removed promptly by means of absorptive material, such as sawdust, vermiculite, dry sand, clay, dirt or other aimilar materials, or trapped and removed by pumping or other suitable means (traps, drip-pans, trays, etc.). Personnel entering the spill or leak area should ba furnished with appropriate personal protective equip ment and clothing as needed. Personnel trained in the emergency procedures and protected against the attendant hazards should shut off sources of PCB's. clean up apilla, control and repair leaks and fight fires in PCI areas. All wastes and residues containing PCB's (o.g., wiping cloths, absorbent material, used disposable pro festive gloves, clothing, etc.) should be collected, placed in proper containters. marked and disposed of in the manner prescribed by EPA regulations (40 CFR 761). Various federal and state regulations may require reporting of PCS spills. Consult your attorney or appropriate regulatory officials for information relating to spill reporting. 2$2 ADH 00 WATER PCB-SD0000010961  MonS.JO MATERIAL SAFETY DATA PAGE *. OF < NOTE: ALTHOUGH THE INFORMATION AND RECOMMENDATIONS SET FORTH IN THIS SHEET ARE BELIEVED TO BE CORRECT AS OF THE DATE HEREOF, MONSANTO COMPANY MAKES NO REPRESENTATION AS TO THE COMPLETENESS OR ACCURACY OF SUCH INFORMATION AND RECOMMENDATIONS. MONSANTO COM PANY SHALL IN NO EVENT BE RESPONSIBLE FOR ANY DAMAGES OF WHATSOVER NATURE DIRECTLY OR INDIRECTLY RESULTING FROM THE PUBLICATION OR USE OF OR RELIANCE UPON SUCH INFORMATION AND RECOMMENDATIONS. NO WARRANTY. OTHER EXPRESS OR WRJEO, OR MERCHANTAIiJTY 8 FITNESS OR OF ANY OTHER NAfURi WITH RESPECT TO THE PRODUCT OR TO THE INFORMATION AND RECOMMENDATIONS HEREIN IS MADE HEREUNDER. This form has been approved by the Occupational Safety and Health Administration aa "equivalent to" OSHA Form 20. * MATERIAL SAFETY DATA Monsanfr POLYCHLORINATED BIPHENYLS For regulatory purposes, tinder the Toxic Substances Control Act die term "PCB's" refers to a chemical substance limitad to the biphenyl molecule that has been chlorinated to varying degrees or any combination of substances which contain 50 ppm (on a dry weight basis) or greater of such substance (40 CFR 761). Chemically, however, PCB's are defined as a series of technical mixtures, consisting of many isomers and compounds that vary from mobile oily liquids to white crystalline solids and hard non-crystalline resins. Technical products vary in composition, in the degree of chlorination and possibly according to batch. The mixture generally used contains an average of3 atoms chlorine par molecule (42% chlorine) to 5 stoma of chlorine per molecule (14% chlorine). They are used as dielectric fluids in transformers snd capacitors. Priorto 1972, PCI applications included heat transfer madia, hydraulic and other industrial fluids, plasticizers, carbon less psper, paints, inks and adhesives. "Federal regulations now specify that non-totally enclosed PCB ac tivities are permitted only K specifically exempted or authorized." (40 CFR 761 see FEDERAL REGISTER, Vol. 44, P. 31514. May, 31.1971) CAS No. 001336363: For general class of compounds TRADE NAMES dielectric fluids. ' Registered trademark of Monsanto Company * Registered trademark of General Electric Company * Registered trademark of Wtstinghousa Electric Corporation ' This list of trade names is representative of several commonly used Monsanto products (or formulated with Monsanto products). Msny other trademarked products were marketed by Monsanto snd other chemical manufacturers. PCI's were also manufactured snd sold by several European and Japanese producers. Con tact the manufacturer of the trademarked product directly, if not in this listing, to determine if the formulation contained PCB's. DATE September II. 1960 REVISED ) X FOR ADDITIONAL NON-EMERGENCY INFORMATION. CONTACT: 80-010 SUPERCEDES All prior to 9H5/80 John H. Craddock. Manager. Product & Environmental Safety Monsanto Industrial Chem. Co. 800 North Lindbergh Boulevard St. Louis. Missouri 63166 (314) 694-4764 253 ADM 0021*2 WATER PCB-SD0000010962 PCI MANUFACTURING ANO SALES ' * MONSANTO INDUSTRIAL CHEMICALS COMPANY 1967 thru 1871 Ifhoussnd* @f Pmut^s) US PRODUCTION DOMESTIC UUS US EXPORT SALES DOMESTIC SALES IY CATEGORY 1687 IBM itm 1991 1892 1863 1864 im 1861 (11 (11 (it 37818 31111 38313 44734 60413 8841 32289 HOil 31310 38214 37838 38043 38132 44688 61781 89078 (21 (21 (21 (21 (21 (21 3647 4086 4134 8812 Heat Transfer Mydraulics/Lubricarra 0 0 0 0 0 1S7 git tit 1237 1766 1812 1S48 3688 2823 4110 3818 3941 4374 4416 4258 Miic. Industrial 704 781 1861 1888 2114 1681 1828 1192 1841 1778 Tranifermer 12955 8718 8884 7821 6281 7964 7290 7997 8687 8910 Gipaeitor 17028 14099 16499 16967 18835 18382 11601 19140 23748 26864 Pitstieiser Application! (11 3939 4873 6244 8098 8924 8181 10337 11688 13481 Petroleum Additives 0 00000000 0 DOMESTIC SALES BYPCBGRADE Aroclor 122t Aroclor 1232 23 16 184 103 94 140 361 S86 368 128 196 113 340 188 241 224 13 13 7 16 Aroclor 1242 18222 10444 13888 18186 18827 20654 18810 23871 31833 39557 Aroclor 1248 177 2888 3384 2827 4023 3463 8013 8236 S86I 8015 Aroclor 12S4 4481 8681 ersT^em* **(**1328* *89M'.*6iO-. Aroclor 1260 7887 1612 6618 7330 840 8698 7628 838 8831 1671 Aroclor 1262 31 184 SIS 326 361 432 414 446 886 768 Areder 126i 0 72 102 IBS 151 210 284 190 196 284 Arodor 1018 00000 0 0 00 0 (11 Prpduetie* figures end Plasticiser ApeficstieflS figum uwwlatt# during year <Miuw4. (21 U.& Eaport Saits fifjfgs unavailable during year indicated. *c oocai 254 i WATER PCB-SD0000010963 ( 1667 im imm 2854 ttm, 68111 iit4 11231 1970 1671 1672 1973 1674 1679 1678 76369 wmA 441? 42176 40118 16710 mn 7114 73061 34301 32242 S7742 mm Sill mm 10624 13111 16641 361 mm 8396 8712 4744 1677 13338 12701 1648 1971 0 0 0 2262 2526 30S0 SfSS 3060 712 0 0 0 0 0 4643 5765 036 74m 1512 0 0 0 0 0 0 1426 1263 1079 1627 1166 0 00 00 0 11071 mss 121 OS .13828 11134 11314 14176 12394 12763 6002 1617 29703 29SS0 2S022 26706 14141 20176 23566 22012 12646 16327 11064 13361 14404 19460 16537 32S9 0 0 0 0 0 0 0 0 1439 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 442 136 607 1471 2216 26 38 57 26 20 0 26 60 273 260 171 0 0 0 0 0 0 43055 448S3 46491 48588 21991 183? 200 207 Mi 4416 81 4704 4894 S5SQ 4073 213 0 0 0 0 0 0 *&8* mt''`9622 ***1 '~*664- .--148*,:33f. 4 m. ja% .1584 6417 5282 4439 4890 1726 414 0 0 0 0 1666 0 640 720 712 1023 1 0 0 0 0 0 0 287 280 300 339 0 0 0 0 0 0 0 0 0 0 0 3334 20160 23S31 21961 12620 18307 11064 0 0 0 0 0 *5* 0 0 0 0 .r.H P06li 255 WATER PCB-SD0000010964 fCB YEARLY SALE! TOTALS WESTINGHOUSE - ALL LOCATIONS ALL PCS PRODUCTS 1954 - 1977 1954 4,681,644 lbs 1955 4,346,780 lbs 1956 7,083,144 lbs 1957 8,367,139 lbs 1958 4,562,464 lbs 1959 5,648,271 lbs A960-".S 'Sf*. 6,294,977 lbs 1961 6,591,368 lbs 1962 5,843,134 lbs 1963 ` 7,517,688 lbs iv tv y.x v*-e * *-.** ,*** ` AO* CCt972 256 WATER PCB-SD0000010965 1964 7,492,896 lbs 1965 9,271,259 lbs 1966 8,027,542 lbs 1967 10,856,219 lbs 1968 10,316,063 lbs 1969 8,038,072 lbs 1970 9,071,230 lbs 1971 6, 851,689 lbs 1972 "*> '6,7*CV90* >>ib*-1973 7,951,141 lbs 1974 9,080,243 lbs 1975 7,754,663 lbs 1976 5,456,521 lbs 2 *3r VJ->W ?.* * e . rf**-* *0* 008973 257 WATER PCB-SD0000010966 1977 693*993 lbs 3 Total All Years t 170*539,344 lbs ( k-S"-3S 4e* C06974 258 WATER PCB-SD0000010967 IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS` STATE OF MISSOURI GLENN BROWN, et al. Plaintiffs, vs. MONSANTO COMPANY, Defendant. Cause No. 862-00694 ; AFFIDAVIT IN SUPPORT OF MOTION TO SEVER *' THOMAS M. BISTLINE, being first duly sworn, on his oath states: 1. I am Litigation Counsel for Monsanto Company. I make this Affidavit in support of Monsanto Company's Motion to Sever. 2. The information set forth in this Affidavit was compiled at my direction from historical sales summaries of Monsanto Company which were prepared annually in the ordinary coarse^o^*41oaa:rto ^-Cempany^'riwa* -The* matters ^sety-forth*--*-***- herein are true to the best of my knowledge, information, and belief. 3. Monsanto Company sold the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Bloomington, Indiana: 1957-1967 Aroclor Aroclor Aroclor 1242 > 1286 (Less than 6,000 lb./yr.) 1254 (Less than 100 lb./yr.) 259 . r WATER PCB-SD0000010968 1968-1970 Aroclor 1242 Aroclor 1232 (Less than 1,500 lb./yr.) Aroclor 1254 (Less than 200 lb./yr.) Transformer Znerteen PPO (Less than 1,000 lb./yr.) 1971-1977 . Aroclor 1242 Aroclor 1016 Znerteen 54201 CP Znerteen 54201 A9 Znerteen 54201 KJ Capacitor 21 Capacitor Aroclor 1489 (Less than 100 lb.) 4. Monsanto Company sold.the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Muncie, Indiana: . 1964-1970 Therminol FR-2 1971 Therminol PR-1 1972-1977 * v ** '"5 %**-i&alea. vw<*rv*;.'V.k * 5. Monsanto Company sold the following products containing polychlorinated biphenyls to Westinghouse Electric Corporation at its plant in Cincinnati, Ohio: 1959-1968 a Transformer Znerteen PPO 1969-1972 Transformer Znerteen PPO * Transformer Znerteen 100-42 (Less than 1,000 lb./yr.) 260 WATER PCB-SD0000010969 1973-1976 Inerteen 70-30 COUNTY OF ST. LOUIS ) ) STATE OF MISSOURI ) IS. ..Subscribed and sworn to before me, a Notary Public, this ** day of March, 1987. /38 to ** rtt' .!! b SHJHLSt J. WAY PU3UC. STATE OF Ml^URI MY COMMISSION EXPINES 7iMiS7, ST. LOU'S COUNTY BUSCH, EPPENBERGER, DONOHUE, CORNFELD JENKINS to / Charles E. Merrill - #27238 100 North Broadway-14th Floor St. Louis, MO 63102 (314) 421-4800 T. Attorneys for Defendant Monsanto Company WMW t 261 WATER PCB-SD0000010970