Document zdYEY4MNJD7byg3ODE7J10d60

Monsanto MOH&ANTO INDUSTRIAL CMCMtCALS CO. 800 N. lindtotrgh Boulevard St. Louit. Missouri 63180 Phone (314) 694-1000 February 21, 1974 Dr. Sidney R. Oaller Deputy Assistant Secretary for Environmental Affairs Office of the Assistant Secretary of Commerce U.S. Department of Commerce Main Commerce Building 14th Street & Constitution Avenue, N.W. Washington, D.C. 20230 ' Dear Dr. Oaller: Your letter to Mr. Warren Easley dated January 15, 1974 was forwarded to me to respond with comments relating to the proposed effluent standard for polychlorinated biphenyls (FCBs). With regard to the five polntB listed, we have the fol lowing Information to offer: 1. Can the proposed standards be met by existing . technology? No. There Is evidence to Indicate that poly chlorinated biphenyls can be removed from water by absorption or adsorption by parti culate matter such as clays and soils. In fact, currently-used analytical methodology utilizes this characteristic. Further studies will be required to determine the best method for disposal of the contaminated solid waste which would result. A detailed manufacturing process, engineering design, capital cost and manufacturing cost have not been com pleted or determined. Hie cost would be substantial. There la no "turn key" tech nology available to Industry. HUNS 092378 Dr. Sidney R. c.aller February 21, 1974 Page 2 2. If the technology to meet standards apolicable to your operatlon(s) exists, please describe any poten tial problems you foresee In applying the technology within the proposed time period. Assuming the technology discussed In (l) above could be made available, we esclmate 24 to 30 months may be required for the design, procurement, Installation and demon stration of the facilities. The situation, as It relates to Monsanto's polychlorinated biphenyl-producing unit, is further compli cated because of the yet-unknown requirements which will be Imposed for the local and re gional waste treatment systems which are now being planned. We do not know specifically the situation as It would pertain to the uuers of chlorinated biphenyls and we suggest they be contacted for their views. 3. Describe the manner and extent to which meeting the standards would impact upon your energy requirements. If the adsorption technology proves effec tive, large quantities of solid material containing polychlorinated biphenyls will be generated. Disposal of this waste will require incineration which will consume a considerable amount of fuel. The quantity cannot be determined until pilot studies are completed. 4. If the standards are to be met, describe the antici pated economic and social impact as reflected In the following: a. Plant closings. b. Employee layoffs. c. Projected Increase In capital and operating costs as reflected In finished product cost. a. Termination In manufacture or consumption of products. HONS 092379 Dr. Sidney R. Caller February 21, 197** Page 3 If practical technology remains unavailable, the low effluent standard proposed cannot be met. This could lead to forced termina tion of the manufacture and use of polychlori nated biphenyls. Monsanto's PCB operations directly utilize 25 employees with an addi tional 30 In supporting service functions. Ir, addition, the unit which supplies the Inter mediate raw material Involves 47 employees who would also be laid off If no alternative use of the material can be developed. The current users of polychlorinated biphenyls, electrical capacitor and transformer manu facturers and their customers, will also be affected and we believe the extent of the economic and social Impact would be considerable. Representatives of the capa citor and transformer manufacturers and the power distribution Industry can provide more specific Information and should be con tacted. Sincerely, WBP/bt cc: Mr. K. W. Easley Washington, D.C. W. B. Papageorge Manager, Product Acceptability Functional Product Oroups MOWS 092380