Document rxmw2Mpjv0oDK8zKe49d8Y3JE

LiKiSciiito -......... .lo. .... ( * i w< t TO : [uAK 10 3 v.'. H. Richard - Research Center March 6, 1969 AROCLOR WTEDLIFE ACCUfATIONS E. Wheeler - EWHEE H. Bergen J . Rprlngatc W . Schalk D. 01 son R. Kelly J. Ca2'rett P . Hodges P. Park R. Keller E. Tucker 11 EE KG JSPRI V.'SCHA D0LS0 RKELL JGARR PHODG PPARK JFQ JPQ Riccbrough in a recent paper "Nature", Vol. 220, Dec. l'i, 19 attacked chlorinated biphenyls in three ways; (]) a pollutant - widely spread by air-water; therefore an un controllable pollutant. (2) n toxic substance - with no permissible a.llowaole levels causing extinction of peregrine falcon by Induced hepatic enzymes which degrade steroids upsetting Ca metabolism lead ing to reproductive weakness, presumably through thinner egg shells. (2) a toxic substance endangering man himself; implying that the peregrine falcon is a leading indicator of things to come. As outlined in Science,Vcl. 163, Pg. 5^8, Environmental Defense Fund (EDF) Is attempting to* write nev/ legal precedents in conservation law by hearings and court action. In the V.'isconsin case, water quality standards are at issue, "A suhstance shall be regarded as a pollutant if its use results in public health problems cr in acute or chromic (injury) to animal, plant or aquatic life". Wisconsin is one of 7 states which now have federally approved water qualify standards. According to Bern Wright, acting chief of the Federal Water Pollution Control Administration*a Water Quality Standards Branch, DI/T would fit the definition of a pollutant upon a showing that it is hamful to aquatic life. These people in EDF are Baying we must not put stress on any living thing through a change in air or water environment. Eagles, plant life, anything which lives or breathes. This group is pushing hard on the extension of the word harmful. They claim "enzyme inducer" activity is the real threat of DET and PCB's and are using these arguments to prove that very small amounts of chlorinated hydrocarbons arc "harmful". Monsanto is preparing to challenge certain aspects of this problem but we are not prepared to defend against all of the accusations. Monsanto is preparing itself to identify trace ppb quantities of chirr.', nated biphenyls in water samples, in concent'/ated collected air samples, and in animal tissues. We will know whether we have been falsely identified and accused or not. We will eventually know where any pollution is taking place and the extent of the pollution. TRAN 058816 | EXHIBIT NO WATER PCB-SD0000033737 F., Wheeler -2- March 6, 1>69 (b) We are not prepared to defend ourselves against the accusa tions made of enzyme and hormone activity,- the isolation of enzymes or metabolic products, the indirect accusation of cancer, or the splitting of ger.es, when this accusation is made. Whether we can defend this route or not needs further discussion. (c) Through the Industrial Bio-Test program wc are to establish the long term allov;able limits of chlorinated biphenyls for certain birds-fish-animals by feeding experiments, pathologi cal examination, and tissue analysis for chlorinated biphenyls. We may be able to answer reproductive ability in some animals. DDT has been under attack for some years because of its chlorine content, its persistent ability to be identified, and the wildlife problems attributed to it. We will still be under the same attack by the mechanisms listed in (b) even though we might establish safe operating limits for humans and certain animals. Where does this leave us? Under identification and control of exposure - we will be able to identify and analyze residues as well or better than anyone in the world. We will probably find residues other than DDT and PCB's. We will probably wind up sharing the blame in the ppm to ppb con centration level. We can take steps to minimize pollution from our own chlorinated biphenyl plants, we can work with our larger customers to minimize pollution, we can continue to set up disposal and reclaim operation:;. We can work for minimum exposure in manufacture and disposal of capacitors, transformers and heat transfer systems, and minimize lo3Beo for large hydraulic users. But, we can't easily control hydraulic fluid losses in small plants. It will be still more difficult to control other end uses such as cutting oils, adhesives, plastics and NCR paper. In these appli cations exposure to consumers is greater and the disposal problem becomes complex. If chlorinated biphenyl is shown to have seme long terra enzyme or hormone activity in the ppm range, the appli cations with consumer exposure would cause difficulty. Risebrough has taken known Aroclor samples and claims to have evidence of enzyme and hormone change. Here there is no question of identification. Either his position is attacked and discounted or we will eventually have to withdraw product from end uses which have exposure problems. Since Risebrough's paper in "Nature", Dec. 1968 has Just been published, it is timely, perhaps imperative, that this paper and its implications be discussed with certain customers, This is a rough one because it could mean Iocs of business on empty and false claims by Risebrough. Well prepared discussions with Ind. Bio-Test, Monsanto biochemists, the medical and departments must take place now. The TRAN 058817 WATER PCB-SD0000033738 E. Wheeler -3- March 6, 1969 position of DOT manufacturers should be determined as a guide. We are being accused of the same things attributed to DOT. I have written this memo to clarify some of the Issues. May I please have comments. Thanks, ms Att. W. R. Richard TRAN 053818 WATER PCB-SD0000033739