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.ft . .a;*.' O' N. T. Johnson ot. Louis. February 16, 1970 __ P. J. A. Marsh - Brussels G.F. Fague - Detroit R. A. Garcia - Akron R. Garnsworthy - Melbourne J. A. .Heilala - Akron R. Irwin - Houston J. S. Pullman - New York J.J. Roder - Chicago R. Giles - Melbourne J. R. Fallen D. A. Hall D. R. Pogue D. F. Smith D. A. Olson Attached is a list of questions and answers which may be asked of you by customers receiving our Aroclor-PCB letter. You can give verbal answers; no answers should be given in writing. If the customer asks a question you can't answer or if he wants an . answer in writing, then send his questions to me and we will answer from.here. / / We want to avoid any situation where a customer wants to return fluid. The new reformulated products will be available within a month. We would prefer that the customer use q? his current inventory and purchase Pydraul 625A, Pydraul ACA, Pydraul ACA Winter Grade and Bydraul 540A when available. He will then top off with the new,fluid and eventually all Aroclor 1254 and Aroclor 12 60 will be out of his^system. We don't want to take fluid back. Sell him the replacement. We must be very positive in our approach with each customer relative lo our decision to eliminate the use of Aroclor 1254 and AroclO'T 1260 in our Pydraul products. V/e (your customer and Monsanto) are not interested in using a product which may present a problem to our environment. We certainly have no reason to be defensive or apologetic about making this change. The decision to change makes good sense and our customers should commend us, not criticize our actions. No ai e has forced u3 to make this TNGS 008633 STLCOPCB4024904 / /' change. We have done it to keep our customers out ox possible trouble. They should appreciate our effort, and stay with us as a customer on the reformulated Pydrauls. To make this change has cosh us re search monies and time. Fortunately, we possess the technical skills to make a change in our formulations without affecting the performance of products. Be positive. Take the offense. Don't let a customer or competitor intimidate you. I doubt if our competitors know whether their product could present a problem to our environment. You might ask your customer if he has ever asked Houghton or Stauffer, Carbine, etc. about the effects of their products. We should also recognize (point this out to your customer) we must clean-up. The Chemical Week article gives him an idea of laws in effect in his state. Read this yourself. Be familiar with the data on each staLa in which your customers are located. Use this in your discussions. We have no replacement products for Aroclor 1254 and Aroclor 1260, We will continue to make these products; however, customers will have to use their own judgement on continued use. Wc can't afford to lose one dollar of business. Our attitude in discussing this subject with our customer will be the deciding factor in our success or failure in retaining all our present business. Good luck. (We have also attached a copy of the letter sent to transformer customers. ) N. T. Johnson lb TNCS 008684 STLCOPCB4024905 POSSIBLE CUSTOMER QUESTION'S ON PC3s Question 1 PUBLICITY / Will you send me copies ? Answcr: In the U. S. , nev^spaper articles have appeared in the San r rar.cisco Chronicle on Fob. ZT, 1969, the San Francisco Examiner on Feb. Z5, 190#, and the Hartford Times on Aug. 3, 1969. Numerou articles wye generated by the Wisconsin. "DDT Hearings" in May, 19F#. 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 r.o ease was PC13 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 bo for warded to the customer through the regional manager's office. in addilion to the newspaper articles mentioned alxjvo, there have been radio broadcasts. At the time of the San 1* r.n.cisco Ch ronicle and Examine r articles, radios in Lhc San Francisco area also carried the story, in August, the sports editor of the Hartfcrd 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 nx dicai <|e pa rtiv.e nt. Question Z Were Monsnato's Aroclors specifically mentioned in these a ."tide s ? if so, which ones? TNGS 008685 STLCOPCB4024906 An swe r Monsanto's Aroclors were mentioned in some of Lhc articles bu; 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 (J. 3. producer of polychlorinated biphenyls, marketed under the tradename of Aroclo r. Ouestionj V/hal did the articles on Lhc PC11 problem say? Answe r Since Lhc outset of the "PCB problem", when the first article appeared in the U. S. press in Fc b. , 1969, Lhc whole question lias been closely interwoven with Lhc question of DDT as a possible environmental contaminant. . The San Fraitcisco 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 poilutant in l!ic Bay and Mothers' Milk/" This article called PCB an "alarming" new chemical pol/iutant that is playing a role in the declining peregrine falcon population, has hen found in mothers' milk, and is the "latest addition to a /rowing list of chemicals in the ocean--------the newest -.ympLorn of/man's chemical invasion of the ocean. " Tiicsc two articles quoted Dr. .Robert Risebrough, a researcher at (lie institute of Marine Resources in the University of CMifo rr.ia1 o Department of Nutritional Scientists, on the detrimental effects o; PCBs. Later Dr. Risebrough said he had been misquoted in some r.ewsDaoer stories. Tin: Hanford Times \tory 'min': po!i .' Less ser.sei.iGu.nl Luan the ban } rancisco article... L/.e Time;. 'croit'.'.t of PCBs being found in the environment and the studies ,:.:de r w^.y to determine their biological effects. This article, u/j, Dr. Risehrougii, tends to clear PCB of blame. an TNCS 008686 STLCOPCB4024907 Articles generated by the Y/isccusi r. DDT hearings "e on r; discussed PCD as an ir.te rfe ri:i g substance discovered in seter.' . ' search for DDT in the c nvtroninont. Dr. Riscbrougn ~a.ic. at .e hearings that there w_s no proof at the morn.1-::: that PCD lore .. 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 Fedn ral/Stalo/local laws unde r which the use or'7 discharge of Aroclors could be prohibited ? Answe r , 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 cart prohibit chemicals, deemed necessary, from being discharged. Question 2 is the DDT and the PCD problem related? An sv/c r W'e arc not a manufacturer of DDT or other chlorinated h yd roc a r i .on pesticide and, therefore, have no knowledge of the seriousness of the charges against DDT other than what has been so widely publicized oit TV, in the press and in technical journals. To t hr- extent that both DDT and PCB are chlormalcd hydrocarbons, then there is a similarity. They are sufficiently different in their chemical structures ; however, that it would be entirely wrong to assume tear both behave in the same way in the environment. The re is another and more obvious d iffc rc m:c . DDT and oilier chloriuaLod cl ruc.ir bun pc s tic id: c o were specifically designed for a job that obviously leads to their being scattered in wide spread fashion across the countryside. Rair., birds, wind, insecls further scatter these pesticides -n e:: unc cut Tollable manner. PCBs arc not used in this ` fashion, and TN&S I i i !i 008687 STLCOPCB4024908 Monsanto !us never sou'jiii to promote this. TLi*, v.-c bclicv_ an important distinction that should net be ove rioosod :i DDT an PCB are linked as a common pollutant o 1 the ei. virnitme.-.t. To our knowledge PCBs have never been identified in the absence of D1DT or other chlorinated hydrocarbon pesticide:.. Que s Lion 3 Could it be PCB that`s causing the environmental problems and not DDT ? Answc r: We believe that present-day GDC and mass spcclromclric techniques arc sufficiently accurate to be able Lo differentiate between DDT, related pesticides, their metabolites and PCB. Question 4 What authority do StaLe and lucal governments have in banning/ controlling the use of PCBs. ' ' An.awe r: They do have authority to ban or control use of any substances they consider harmful. EFFLUENT AND ITS CONTROL Quostior. 1 How do 1 dispose of Aroclor IZd-1/1260, etc. effluent from my plant ? Answe r: We would suggest collecting a?l process effluent, equipment washings, Lank or drum washings and then regularly taking to the nearest tonic, materials dump. You may also be able to use a sanitary land fill if permits arc issued for this in your locality. We dciv't recommend feeding this material to local sewage treatment plants or taking out to sea in drums for dumping. The: so methods do not TNGS 008608 STLCOPCB4024909 solve the problem, of contamination. V/c are rkin-j. or. disposal of these mate ria La by incineration. r.a;' :-,icd.- Our work in these areas has not yet reached ,,ht stage v- wc can offer practical suggestions. I: is of in:- re-at to nct_, however, that research is underway fo fi.id cat. lyses to r.._l.e DDT self-destructive. Th.e possibility exists that v/c coaid find catalysts that would destroy PCBs in Settling tanks con structed to catch all your effluents. , Question 1 Can I test iny effluent to see if my effluent has no Aroclor lb5 . etc. ? Answer: Yes. Analytical c cu ' that cun do this irTno proper technique is used. The basis of the method is GDC or gas liquid chromatography. Arc you or anyone in your company familiar with this? Do you have GLC equipment? Lf 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 il you want to test your effluent. Question 3 What is a "safe" PCD level for effluent leaving my plant? A:iswe r: As our letter points out, parts per million (ppm) and parts per billion (ppb) have been mentioned in the published articles There is still a lot of doubt as to how absolute tiny quoted values are. - .To bring this into the realms of reality, this definition.of ppm and ppb may help clarify things. To give you a practical example, the escape 91 one-two gallon per day could lead .tp samples in a stream beside the plant showing-10-50 ppb-on analysis. / TNGS 008689 Question ' You must have quite a control problem a: your oi.. would think Monsanto1 s A rode r plants are y... i.u^r polluters--how arc you handling control? A'iswc r: The Aroclor products we make to sell aL a profit, so acor.o.v.icr dictate maximum housekeeping, minimum ioses. The process is a "dry process" or closed system. Question 5 ./ llow docs Monsanto think Aroclors can get into the cnviror.mc.f. and cause so much pollution? ' Answe r: Disposal, leakage from systems using it, spills, etc. Question 6 If I analyze my effluent stream and find pub there, how do I ' ' know it didn't come from air-borne contamination, or was jiresent in Live process water that 1 pump from the XYZ river into my plant? Answe r: . Analyze water entering your plant and compare. Tcere is a method available for sampling air. ' Que stion 7 You seem to think from the tone of your letter that the source of pollution is from effluent disposal into streams. Ir. ;v.y process, Aroclor 125-t, 1.260, etc. vapors escape. V/hat pre cautions can I toke to prevent (a) employee problems and (b) escape of vapors into tin- nlnvospliu re V, TNGS 006690 i STLCOPCB4024911 Question l--' What's the difference bufwvicn a chlorinated hi.,amyl an a a tcrphenyl? An. sv/e r: A Lcrphcnyl has three benzenes linked together and bicher.yl onLy two. They arc, therefore, similar but diticror.t, just as Naphthalene is diffcrent from benzene. Question 3'-;: V/hy should PCS be an environmental contaminant and chlormatec Lerphenyls not? Answer: 1 don't think there is any positive answer on this and I can't give you any theories. However, I would emphasize teat net all PCBs appear to be contaminants. Those such as Arocior 1121 1232, and 1242 haven't been identified in marine, aquatic and wild environments. Chlorinated tcrphenyls - at least those made by Monsanto - have not been identified in the environment c-ititar. Question 4 Since you sell other PCBs beside Aroclor 1254 and 1260, why arc they not found in the environment? , Answer: 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. Wc are actively working on this aspect of biodogreadability in our laboratories at this time. Results of tills type cf work won't come to hand quickly but our preliminary work on PCBs of less than 54% chlorine looks promising. TNiS 008692 Slioi, H* Is the reason lor not rnsu '.iv.iLai.1e._4 '>-r nutivo.t 10 for approval of Arcelor 5-b:0 due to eras ?C ?; . ' . No. Question 9 V/oat's the problem .hen? .Answer: _ V*c arc brinviu-4 a new solid Arealor plain on-sLreuin in Lite next Lwo-Luruc months. IVo want Lo in.me sure it nrCi. U(.c. .a the same fLuality .Arcelor 0-I0O we used in oar feeciii studies for the FDA. Once wc'rc sure that's O. K.- ana we feel it will be--tho:t v/c';l .,et the petitter, m.cvin at k w>. FDA clearances do Lui.c Lime. istion 10 Ljoj tr.is Pwri cuo^tcttp .nea that FDA approval of Arcelor 5-160 is not ifom.; to be obtained ?* I / V/c nave no reason to thmu vise two Lain;; s are related. .-.roelot A not chemically a PCD. T.:c delay re suite n front t-ie need to sot up curtail, analyttc.'.l methods to satisfy FDA. 'titij involved analytical in.'* trunie n toticr. ar.ci is be in;* completed urn . It is my understanding v.v to rue ::b.r.:t our ,.c tit. on <t__' t _ I personally don't know tJ.;. exoot date. COX'T.'fr'C.'fS n.yu i.t GV I v. :t _ V. l c v.' i \.,\xi Vf . TNGS 008694 STLCOPCB4024913 . .i: swe; I have beei: "iveu iio i::dic<A.ioit other .vise. Question :cald 1 loo! icr replacement icr Aroclor 125 1 /1265, etc. Aas suc r r ' I crdy you car. decide this. How easy voulc: this do icr you? Do you. has'e any other rcpiacainenr product ir. mind ? Question 5:': Docs ivioasanlo have replacement produces tor Aroclor 1252 and 1260 ? Ans,,-e As you know, sve have over oi"hty plasticize rj in our 1: at and there's cur.t a b: i of product interplay so it is possible that there is another product ir. our line that miyiit redact: V/hut resin do yo use? Tb: rh.-.ps we could look r v the.-a . / .. *. U wx^aIIC j. >. < : : HU. ^ln.r uS tit L. .a Out.. C_ t .tC D .Uc imf \j *>. i1 vc f;ct it witn me. rue r nor. Is iv! on same working cn re pi .-ce rr.c nts icr Aroclor iad-'r aitc :2o0 ? .i Arms.'a n: Ti.ese roseerch fellows arc always busy o.u l!u::y. like .nut. To some people Aroclor ] A:: :.d 1260 hive -- quite apart from ore .-eat pan -.icily on. hCB. A roe'.or lit-, is .`airily volatile. /. r c.lor 1260 A very vuilu.,:. . di.Tici.l. to li.anolo . 'Idor pelvic.: :de sealants, lor onn 'np... ,l,e lecumcol people i:t S.. Louil n.'.Ve jll.'L sC.il US .sUl p ./_ ,.C .S t.in.t bears;-, cotter than Aroclor 1..5-I in poly -ad ha .-i-. i nay he t!.ore's, something here ler yo.. to loo:, at. .h;t`j TUGS 008696 STLCOPCB4024914