Document n9VbLQ756Vx0Y6aEV9gbJQD86

Monsanto A. E. A. J.C, D.B. Leisy Gallion Weber- B2SK Hosmer-EISF MAY 21 1976 MONSANTO INDUSTRIAL CHEMICALS CO. Sougat, Illinois 62201 Phont: (618) 271-6636 May 19, 1976 Mr. Dale S. Bryson, Acting Director Enforcement Division U.S. EPA, Region V 230 South Dearborn Street Chicago, Illinois 60604 ' . Dear Mr. Bryson: 1 Your May 7 letter reached me on May 12 with the report on the January 27, 1976 visit attached. Our Mr. Heisler was in contact by phone with your Mr. Zar on Friday, May 14. Your suggestion for a meeting is appropriate and we would like to schedule one as soon as we have had an opportunity to review your report, along with the Versar report in detail. I'm sure after reading the 250+ page Versar report you realize the complexity of this problem and the recom mendations listed. We will need some time to evaluate these recommendations. We will be in contact with your office to confirm a meeting as soon as we have completed our evaluation of the recom mendations. I expect this to occur within a few weeks. Also attached for your information is a copy of statement delivered to Mr. Russell Train on May 13 regarding our position in the PCB business. Very truly yours, RWF/ap Attachment: ' R. W. Flint Plant Manager a unit ot Monsanto Company OSW 012504 STLCOPCB4002429 Remarks - J. C. Weber Meeting with Russell Train, ` Administrator of the EPA - Washington, D.C. May 13, 1976 Good afternoon, my name is Cole Weber. I am manager of product acceptability for specialty chemicals, including polychlorinated biphenyl (PCB) dielectric fluids, manufactured by Monsanto Industrial Chemicals Company, a unit of Monsanto Company. When Jack Fitzgerald, a Monsanto vice president and managing director of this operating unit, met with you in January, he assured you that Monsanto had no desire to remain inithe PCB business any longer than necessary. He also'stated that as Boon aB Monsanto was satisfied that the electrical power supply industry's needs for usable, acceptable alternate dielectric fluids had been met by whomever, Monsanto would voluntarily shut down its PCB manufacturing unit. l am here today representing Monsanto to reaffirm this position and to give you a brief update on the status of develop ment york on possible replacement products. I'll also comment on the phaseout timetable. * Based on customer feedback, the transformer industry is apparently leaning towards silicones, which are readily available, as the leading askarel (PCB) replacement candidate. We do, however, still sense some reservations on the part of our transformer customeps.with regard to the fire resistance of all current replacement candidates and are awaiting further clarifi cation of their evaluation programs. / -more DSW 012505 STLCOPCB4002430 Ip the meantime, we have shelved all development work on our transformer fluid alternates because they simply did not appear to be able to compete on a cost/performance basis with other viable alternates. In the capacitor segment, the trend is currently . 'towards commodity type solutions which are widely available in large quantities such as phthalate esters. If this approach proves satisfactory, it will obviously preclude further consideration of specialty solutions such as Monsanto's MCS 1238-type technology which is a proprietary blend specially designed as a capacitor dielectric. Consequently we are very close to terminating our development efforts in this area as well. If the. capacitor industry determines that commodity fluids are indeed the most expedient way to satisfy their cost/ performance criteria, we believe that Monsanto may have viable candidates to assist them in this approach. - Regarding the phaseout timetable, we are already involved in the transformer fluid phaseout. Since we . announced our intentions to exit the business, demand for I .PCB-filled transformers has declined substantially. Our trans . * former fluid sales in 1976 will be less then half the total ' recorded in 1975. ,' . . _ When'the capacitor makers complete their evaluation work and tell us they are satisfied that they have viable alter nates in hand, we will cooperate fully in an industry-wide changeover and proceed with the orderly termination of all PCB production, including Aroclor 1016, the current capacitor industry standard. . DSW 012506 -more- STLCOPCB4002431 Monsanto is often asked, and indeed pressed, to establish a firm exit date. We are as anxious as anyone to settle on a firm timetable so we can complete our exit plan and begin applying these considerable resources to ongoing programs. H, owever, toi unilaterally set an exit date would be inconsistent with our long-standing pledge to work with the electrical industry to ^replace PCBs in an orderly manner. So, to reiterate, Monsanto is fully prepared and indeed most anxious to exit this business at the earliest practical date. We will establish and begin executing a firm phaseout timetable as soon,as we receive a consensus judgement that viable alternates ar^e in hand. ' Thank you. -0O0- % ` * * . . / /i i OSW 012507 STLCOPCB4002432