Document gay19egr5NEa7zg2M7JMMazLe

POSSIBLE CUSTOMER QUESTIONS ON PCBs PUBLICITY Question 1 /V A What'articles have appp^red 'on the PCB problem? Will you send me cophas ? / Answer: In the U. S. , newspaper articles have appeared in the San Francisco Chronicle on Feb. 24, 1969, the San Francisco Examiner on Feb. 25, 1969, and the Hartford Times on Aug. 3, 1969. Numerous articles we/e generated by the Wisconsin "DDT Hearings" in May, 19hF At the hearings, witnesses discussed the problem of PCBs as "interfering substances" in their search for DDT in the environment. PCBs, they said, produced peaks on a gas chromatograph similar to the peaks produced by DDT. In no case was PCB indicted at the Wisconsin hearings. Copies of the articles will be made available on request. Regional managers should contact E. V. John, Public Relations Manager Organic Chemicals Division, in St. Louis and copies will be for warded to the customer through the regional manager's office. In addition to the newspaper articles mentioned above.1, there have been radio broadcasts. At the time of the San Francisco Chronicle and Examiner articles, radios in the San Francisco area also carried the story. In August,- the sports editor of the Hartford Times syndicated a radio broadcast on the subject of PCBs, and in Dec., 1969, the Canadian Broadcasting Co. (radio) carried an interview they taped with a member of our me dical department. Were Ivlonsnato's Aroclors specifically mentioned in these article s ? If so, which ones? DSW 201633 STLCOPCB4059700 Monsanto's Aroclors were mentioned in some of the articles but only in the San Francisco Chronicle story in Feb. , 1969, was Aroclor 1262 specifically mentioned by number. In several of the articles, Monsanto was also identified as the sole U. S. producer of polychlorinated biphenyls, marketed under the tradename of Aroclor. . Question 3 . , What did the articles on the PCB problem say? Answc r Since the outset of the "PCB problem", when the first article appeared in the U. S. press in Fe b. , 1969, the whole question has been closely interwoven with the question of DDT as a possible environmental contaminant. . , v- , / /, . ' The San Francls'co' Chronicle article carried a headline, "A Menacing New Pollutant. "/In rather sensational style, it identified PCB as a threat to birds and humans, highly toxic in a gaseous state and related to known cancer-causers. PCB presence in the environment is rising .swiftly, the article stated. The. Examiner article called PC3 a "plastic pollutant in the Bay and Ivlothers1 Milky" This article called PCB an "alarming" new chemical pol/lutant that is playing a role in the declining peregrine falcon populatioit, has Men found in mothers' milk, and is the "latest addition to a growing list of chemicals in the ocean--------the newest . symptom of/man's chemical invasion of the ocean. These, two articles quoted Dr. Robert Risebrough, a researcher at the Institute of Marine Resources in the University of California's Department of Nutritional Scientists, on the detrimental effects of PCBs. Later Dr. Risebrough said he had been misquoted insome newsoaoer stories. Tito Hartford Times story c allied PCB pollution a "new oe/./.;o. " Less sensational than the San i rancisco articles, tr.o Time s account of PCBs being found in the environment and the studies aiider way to determine their biological effects. This article, says Dr. Risebrough, tends to clear PCB of blame. an DSW 201634 STLCOPCB4059701 Articles generated by the Wisconsin. BDT hearings generally discussed PCB as an interfering substance discovered in scientis search for DDT in the environment. Dr. Risebrough said at the hearings that there was no proof at the moment that PCB alone can cause thin eggshells, one of the phenomenon that he had discovered in studying the declining population of the peregrine falcon. LEGISLATION / / / / Question 1 / / Are there any Faderal/Statc/local laws under which the use or.' discharge of Aroclors could be prohibited? Answer; No existing Federal, State, or local laws prohibit the discharge of Aroclors, However, in a number of states the basic water pollution control legislation is so broad that state agencies can prohibit chemicals, deemed necessary, from being discharged. Question 2 Is the DDT and the PCB problem related? Answo r; We arc not a manufacturer of DDT or other chlorinated; hydrocarbon pesticide and, therefore, have no knowledge of the seriousness of the charges against DDT other than what has been so widely publicized on TV, in the press and in technical journals. To the extent that both DDT and PCB are chlorinated hydrocarbons, then'there is a similarity. They are sufficiently different in their chemical structures ; however, that it would be entirely wrong to assume that both behave in the same way in the environment. There is another and more obvious difference. DDT and other chlorinated hydrocarbon pesticides were specifically designed for a job that obviously leads to their being scattered in wide spread fashion across the countryside. Rain, birds, wind, insects further scatter these pesticides in an uncontrollable manner. PCBs arc not used in this .'fashion and DSW 201635 / i/ STLCOPCB4059702 Monsanto has never sought to promote this. This, we believe, is an important distinction that should not be overlooked if DDT and PCB are linked as a common pollutant of the environment. To our knowledge PCBs have never been identified in the absence of DDT or other chlorinated hydrocarbon pesticides. Question 3 Could it be PCB that's causing the environmental problems and not DDT ? Answer: We believe that present-day GLC and mass spectrometric techniques are sufficiently accurate to be able to differentiate between DDT, related pesticides, their metabolites and PCB. Question 4 What authority do State and local governments have in banning/ controlling the use of PCBs. ' Answer: They do have authority to ban or control use of any substances they consider harmful. EFFLUENT AND ITS CONTROL Question 1 Plow do I dispose of Aroclor 1254/1260, etc. effluent from my Diant ? Answer: We would suggest collecting all process effluent, equipment washings, tank or drum washings and then regularly taking to the nearest toxic materials dump. You may also be able to use a sanitary land fill if permits are issued for this in your locality. We don't recommend feeding this material to local sewage treatment plants or taking out to sea in drums for dumping. These methods do not DSW 201636 STLCOPCB4059703 solve the problem of contamination. We are working on the disposal of these materials by incineration and biode gradation. Our work in these areas has not yet reached the stage where we can offer practical suggestions. It is of interest to note, however, that research is underway fo find catalysts to make DDT self-destructive. The possibility exists that we could find catalysts that would destroy PCBs in settling tanks con structed to catch all your effluents. j Que stion Z / Can I test my effluent to see if my effluent has no Aroclor IZ54, . etc. ? Answer: . Yes. Ann! vHrrd ec. 1 rTtht can do this ------ IT'the proper technique is used. The basis of the method is GLiC or gas liquid chromatography. Are you or anyone in your company familiar with this ? Do you have GLC equipment? If you do, we can send you a description of a method that could identify PC3. If not, there may be a good analytical testing laboratory in the vicinity where you could send samples and rely on the results if you want to test your effluent. Question 3 ' What is a "safe" PCB level for effluent leaving my plant? .an s we r: As our letter points out, parts per million (ppm) and parts per b.ulion (ppb) have been mentioned in the published articles. There is still a lot of doubt as to how absolute any quoted values are.. --.To bring this into the realms of reality, this .. definition-of .'ppm and ppb may help clarify things. . DS\N 201637 STLCOPCB4059704 Question 4 You must have quite a control problem at your ulnar would think Monsanto's Aroclor plants are the rnajo polluters--how are you handling control? Answer: The Aroclor products we make to sell at a profit, dictate maximum housekeeping, minimum loses. process is a "dry process" or closed system. so economics The Aroclor / Question 5 , How does Monsanto think Aroclors can get into the environment ' and cause so much pollution? Answer: Disposal, leakage from systems using it, spills, etc. Question 6 If I analyze my effluent stream and find ppb there, how do I know it didn't come from air-borne contamination or was present in the process water that I pump from the XYZ river into my plant? Answer: A.nalyze water entering your plant and compare. .There is a method available for sampling air. ' Question 7 You seem to think from the tone of your letter that the source of pollution is from effluent disposal into streams, tn my process, Aroclor 1254, 1260, etc. vapors escape. 17hat pre cautions can I take to prevent (a) employee problems and (b) escape of vapors into the atmosphere ? / DSW 201638 i ! STLCOPCB4059705 Answer (7): Articles on PCB interference with pesticides analysis nave mentioned the possibility of loss to the atmosohere from vaporization when Aroclors are heated. We find this hard to believe and it warrants considerable investigation. TOXICITY Question 1 If PCB is'a danger to fish and birds, how about humans? Answer: / -j The amounts being found in the environment/are not considered a danger to humans or fish. The whole question on chlorinated pesticides relates to birds. / l Question 2 . I Are Arcelor 1254/1260, etc. more toxic than other Aroclors? Why? There is a rlifferenre indinon degree of _eiAc,, ...aitch? This is not to say that higher chlorination is more toxic than.lower chlorination. The alleged PCB problem is not really related to degree of toxicity. Dir F 'V; J\ EM AROCLC C Question 1* In your letter, you state that Aroclor 5060,v 5e 2 and 5460 arc not PCBs. What arc they? Answer: They are chlorinated ter phenyls.' DSW 201639 // STLCOPCB4059706 Question 2* What's the difference between a chlorinated biphenyl and a terphenyl? ir.s we r: A terphenyl has three benzenes linked together and biphenyl only two. They arc, therefore, similar but different, just as Naphthalene is different from benzene. Question 3* Why should PCB be an environmental contaminant and chlorinated . terphenyl s not? Answer: . I don't think there is any positive answer on this and I can't give you any theories. However, I would emphasize that not all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1242 haven't been identified in marine, aquatic and wildlife, environments. Chlorinated terpnenyls - at least those made by Monsanto - have not been identified in the environment either. Question 4 Since you sell other PCBs beside Arcelor 1254 and 1260, why are they not found in the environment? Answer: /j One reason could be that they biodegrade and hence never build up to a level where they can be labelled persistent contaminants. Therefore, although you would find it in an effluent stream if you analyzed it just after you poured PCB into it, its absence when a river, for example, is analyzed downstream at a later date would indicate degradation by bacterial organisms. / / We are actively working on this aspect of biodegradability in our laboratories at this time. Results of this type ci work won't come to hand quickly but our preliminary work on PCBs of less than 54% chlorine looks promising. DSW201640 STLCOPCB4059707 Question 5 In your letter,, you make no mention of Arcelor 1268. What:is their status! : // / /. Answer: /' // / 1162 and .. It could'be that their semi-solid/solid water insoluble nature means they areyfar, far less likely to become "mobile" contaminants., ylt could be that their structural differences from A.rocloyl254 and 1260 are responsible for the atmare.nt lack of a pyfblem. In any event, they have not been identified by scientists in the environment and--believe me-- a lot of scientist's seem to be looking for PCBs. Question b/t- Both Aroclor 5460 and 1260 contain 60% chlorine. Why is one a problem (1260) and apparently not the other (5460)? Answer: A terphenyl has three benzenes linked together and biphenyl only two. They are, therefore, similar but different, just as naphthalene is different from benzene. I would emphasize that not all PCBs appear to be contaminants. Those such as Aroclor 1221, 1232, and 1342 haven't been identified in marine, aquatic and wildlife environments. Chlorinated terphenyis--at least those made by Monsanto-have not been identified in the environment either. Bees this PCB problem mean that you have discontinued lions to get Aroclor 5460 approved by FDA.? DSW 201641 STLCOPCB4059708 Question o* Is the reason, for not re submitting your petition to the FDA for approval of Arcelor 5-1-60 due to this PC3 publicity? No. Question 9 V/hat's the problem then? Ans v/e r: We are bringing a new solid Amoclor plant on-stream in the next two-three months. Yv'e want to make sure it produces the same quality Arcelor 5460 we used in our feeding studies for the FDA. Once we're sure that's O. K. -- and we feel it will be--then, we'll get the petition moving again but FDA clearances do take time. Qua stion 10 Does this PCS publicity mean that PDA approval of Arcelor 5460 is not going to be obtained? Answer: /' We have no reason to think the two things are related. Arcc-lor 5460 is not chemically a PCB. Tne demy resulted front tne need to set un certain analytical methods to satisfy FDA. Tms involved analytical instrumentation and is being completed now. It is my understanding va: plan to resubmit our petition n_tkoagn I personally don't know the exact date. CONTAINERS Question t fee Dee buys all my used Aroclcr drums without me .tavmg .o wash them. I get S6. 00 a piece. I can't afford to wash atom out. Even if I did. v/hat would 1 do with tne washings ? os***641 STLCOPCB4059709  ( Clue suion i con'1/ What should I do? Should I tell joe Doc? V, them back or pay me S3. 00 plus my costs to Answer: Don't have an answer at this time. We just don't know. APPLICATIONS sc alant/ adhesive / to which your product V! Tell your customer-- v,1 e v.;au to aevtse you ci u. tc11ttt ctvcctmental problem. Without knowing what your customer does with product X, this is hard to answer. (Vie would say that it would not seem wise to use Aroclor 1254 or 1260 for keeping oust cown on the roaas, tor use m denial seating comoouitcs or as carriers for pesticides. )* :`;Only if you suspect or are told tills is what the apolicstion is. Lion 3 Does Ivloasanto intend to continue manuiact 1260, etc. ? DSW 201643 STLCOPCB4059710 'cl' V ) I have been given no indication otherwise. Question 4* Should look for replacement for Arcelor 1254/1260, etc Answer r / . I think only you can decide this. How easy would this be for you? Do you have any other replacement product in mind? Question 5-1'- i . / Does Monsanto have replacement products for Aroclor 1254 and 1260 ? . / / Answe r: As you know, we have over eighty plasticizers in our line and there's quite a bit of product interplay so it is possible that there is another product in our line that might replace them. Y/hat resin do you use? Perhaps we could look at these re sin/nlasticize r Se is ctor Charts in the bucu of the Clue Coen. I've got it with me. Question 64 Is Monsanto working on replacements for Aroclor 1254 and 12 60 ? '! Answer: These research fellows arc always ousy on things like mat. To some oeoole Aroclor 1254 and i260 have cl raw- nacus- quite apart from present publicity on PCti. Aroclor ido-i- is fairly volatile. Arcelor 1260 is very viscous and di-- tev.-t to handle. 'For poly sulfide sealants, for examplethe tecnnioai people in St. Louis have just sent us data on pro cue vs mat wib bo have cotter than Aroclor 1254 in polysuliide seat urns. Maybe there's something here for you to loon at. . .Let's go over it. ' ' ` !i i DSW 201644 / i i STLCOPCB4059711