Document 6R8KNOBaZvLQXMb0zJKowbnr4

H. S. BBtQBt - ST. LOUIS SERZMBES 12> 1969 Lsnxss or aaoclor /PHCTIDXAL auous R. X. KOWIZ V. A. ram?*-- Tt-Snsisai Please rind attached a rough draft froa Dr. Richard to EUaar Hheeler regarding Aroclor tori city. I would appreciate your coeaienta to both Dr. Richard and BQrself regarding this draft. H. S. BHiOEH KNGAD-liy iwnt, .N .J PLAINTIFF'S EXHIBIT M2. OSW 014254 WATER PCB-SD0000006138 ?/?/& Cr &. otu.j/~ jf\. QO'n^rt~+J*IJLL AA'V-^j2>0 JxJ^ U*'- V &lU-^V^TN , cj^Liu^ M*-~ i>*A a. ,rfclkjjr! TUy^-> j /2<2/ /2^U.^r osw 014255 WATER PCB-SD0000006139  'oi.ier i0 woc*to R. Richard - Research Center September 9j 19^9 DEFENSE OF AROCLOR ET~?nriiJs-------------------- P. Kodges M. Fap?}rar ;R. BRfPeTr*gPePn PKODG Res. 1 HBEP.G TO E. Wheeler - EWHEE General Policy Make the Govt., States and Universities prove their case, but avoid as much confrontation as possible. Comply and work with public officials to meet or"exceed requirements ahead of time. Adverse publicity and competition are the real weapons. Analytical (in Air - Which Aroclors are present? Where?] for Aroclor tin Water- Which compounds:? (In Animals ^interfere? J1 Govt. Agencies Keep track of how much contamination - which sources. Prove Bioharmful - Let Govt, prove its case, on case by case basis. i Monsanto Visit-Govt. Biolabs - in search of toxicological . experiments and evidence vb. Aroclors to keep up with progress. Monsanto Prove Bioharmless - Limited work at Ind. Bio-test - "Safe" toxic Jman level for < mammals via (fish Probable Outcome Rats Chlckens Hsh Seek evidence of Biodegra- dation Question evidence against us. Question shrimp toxicology especially other toxic chemicals. If Aroclor bad, others must be worse. We can prove some things are OK at low concentration. Give Monsanto some defense. We can't defend vs. everything. Some animals or fish or Insects will be harmed. `-.roclor degradation rate will be slow. Tough to defer. wii.*.st. .I-i.-.er chlorination c orpounds will be wo.'.. . . .;or chlorine compounds. Therefore we will have to res-rlct uses and clean-up as much ns_we_an, starting immediately. rt. -I,- o UU., ? OS* 014256 WATER PCB-SD0000006140 j Make the Govt., States and Universities prove their case, / but avoid as much confrontation as possible. Comply and work with public officials to meet or~exceed requirements V ahead of time. Adverse publicity and competition are the real weapons. . Analytical In Air ' - Which Aroclors are present? Where? for" Aroclor IIn Water- Which enniTfflwrf^i ' Govt. In Animals ^interfere? Agencies Keep track of how-much contamination - which sources. Prove 31 charmful - let Govt, prove'its case, on case by case basis. Monsanto Visit-Govt. Biolabs - in search of toxicological ---- experiments and evidence vs. Aroclors to keep up with progress. Monsanto Prove Bioharmless - Limited work at Ind. 3io-cest - "Safe" toxic level for man mammals via fish Probable Outcome ' Rat~s Seek evidence of 3iodegra- Chlckens dation Pish Question evidence against us. Question shrimp toxicology . especially other toxic chemicals. . If Aroclor bad, others must be wofie. We can prove some things are OK at low concentration. Give Monsanto some defense. We can't defend vs. everything. Some animals or fish or insects will be harmed. Aroclor degradation rate will be slow. Tough to defer.-. '.yiir.st. u.ther chlorination compounds '.fill be woroa _u'.:er chlorine compounds. - Therefore we will have to restrict uses and clean-up as much -_s wa. can, starting Immediately, /j. Ti' --- OS* 014256 AO WATER_PCB-SD0000006141 -2- Pherefcre we will have to work for alternate predicts in end use applications; Tar Arcelor production facilities. Clean Uc Aroclors and substitute orcducos where necessary " and wr.en requires, before threats of publicity ana competitive activity over whelm us. ' * Water Pollution seems to be first issue Aroclor product is refractive, will settle out on solids - sewerage sludge - river bottoms, and apparently has a long life. . Florida or gulf Coast - Aroclor 1254 - Aroclor 1250- present . issue. 4O-2C0 ppb - causing problem at Pensacola (Monsanto) in plant effluent-causing " with shrimp. - can't rlslc shut-down of plant. ' Federal and State can extrapolate to other plants in Gulf area. ' San Francisco - Arcelor 1254 and 1260 Reported Aroclor to.be present in San Francisco Bay. Reported to be -thin egg shells in birds - Lot of screaming - . - Great lalces Warf studies on DDT Aroclor 1254 will be found'. Aroclor 1242 will be found? . Air Pollution - Possible spread - but less of an issue right now. *JFo Analytical woric more difficult. ' ~- . ' A' . .1 -D- -i-r-e- -c- -t- - -C- -o- -n- -t-a- c- -t- - w- - -i-t-h- - -P- - r- -o-d- -u- -c- -t r t Ai-'/P- ^ -i. Doesn't seem to be an issue - except for food heat transferr^.^~ /We don't believe Aroclor is being used as carrier for insecticide - sprayed around . W I< We are not positive but most uses are "closed" systems;* or products used in solid plastics, or adhesives, or ! r-S* sealants. OSH 01*257 WATER_PCB-SD0000006142 -3- F. Fluids Product Hydraulic Fluids Air Compressor Fluids Heat Transfer Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutio* Customers Plant Operation by Customers Free: Yes, leakage external Yes, leaicage external Yes, leaicage external Yes, leaicage from plant - Scrap materials. Ho, Should be clean. Yes, Heworiced trans formers Possible - See Johnson Motors Castings. Leakage Into produc Leaicage Into produc In product but closed for end use* In product but closed for end use4 * Capacitors can go to land fill dumps. " Probably not burned. In A1 containers. * Need to take care of Aroclor in discarded transfoxmers. Product could be drained and reworked. ' Probable Conclusions Hydraulic Leakage Air. Compressor Fluids Product could be caught at machines but will take a lot of clean-up work with customers. Will have to have replacement product - with less-sensitive components. Work from this base on clean-up to prevent more pollution problems. tf . Hydraulic Fluids ' Must expect *shrimp" experiments. West Florida State, to he "aiped" sometime soon; next few months. This will lead to bad publicity and competitive action vs. all Pydrauls. We will have to try to confine to Aroclor 1254 and Aroclor 1260. OSM 014253 WATER_PCB-SD0000006143 'Je will have to talcs action before that time. Gulf Coast - Action w. Richard Fallon/ Richard 3e able":to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in 2 month's time before Nov. 15. 1969. Have trial product in hands of Gulf Coast accounts and distributor before Sec. 15. Fallon Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS___ for insurance. Richard/ Suggest possible substitution of Aroclor 5442 for Aroclor 1254 in hydraulic and compressor blends. E. Wheeler Judges lower order of toxicity and solubility for 5442 series. Have to test product in pump test for deposits. '. Fallon/ Richard Suggest field trials of our own all-phosphate ester. Fallon/ Kuhn/ Kountz Worlc with large customers to clean-up streams. Bring in Findett as mfg. partner in the recycle business. Get money out of recycle operations. Inland-Waterways- Wheeler/ Richard Be close enough to Great Lakes studies to Judge situation. Are there animals which are being affected by the concentrations found? [Richard Be prepared to replace.Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and in air compressor fluids. Richard Be prepared to replace all Aroclor 1242 or 124P In 6 months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. Heat Transfer ' OSW Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. 014259 Fallon/ Roush Need to replace FR especially in food or sensitive prodnat area a wh?v- the prnduos is r.ettlns into water. Sec uish washer ecapouncs. See letter E. Wheeler to T`. Fallon. We have possible rep cement products Therm tr. fhermih.. imn *\oo WATER_PCB-SD0000006144 -5- Acrion Kuhn Kuhn/ Fallon Try to assure adequate production of Therainol 66 in face of decreased Aroclor production. Ha and terphenyl supply may become shore. Switch customers to Therainol 55 or Therainol 66 ahead of pollution problems in customers plant. Work with customers on plant and dumping practices. Findett already set up to rework. Heed to make them a manufacturing arm. We get sale of recycle-rework fluid.- Capacitor Capacitor plants have re- Fiulas purification and recycle systems but up to 53 of product can be lost by poor plant producers and off-quality material. Kkt. Benlgnus/ Bryant 5% of production could be Eng.-Kountz/ Mfg-Hodges UT lbs/year. This is & big loss for the type of pollution we are trying now to guard against. Capacitor products Enclosed In A1 or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product for a time. Action Eng.,TSDPlant Pol lution Con trol Hodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. We have set-up to accept material for rework Into hydraulic fluid but this relocation is not a satis factory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical. Must start now to get con trol of off-grade material. Recommend replacement of future Aroclcr business with other products. Have 2 years. * Action Monsanto must help plant clean up of customer plants c^cantation, coalescing, adsorption, dis posal of ad^c.-ber.c or recycle of adsorbents. Monsanto badly needs "know-how" for clean-up. Monsanto should seek Govt, contract --* money for clean-up research, (See KRC R. Binning, D. Nelson) osu 014260 WATER_PCB-SD0000006145 -o- Transformers Action 5enlgn.ua/ Bryant Transformer Plant can operate In a clean, efficient manner with recycle of cff-grade Arocior. Should advise disposal of filter element materials so as to minimize chance of water pollution. Incinerate or dispose. Reworked transformers pose a threat if the Arocior Is dumped into a water stream. Product transformers can remain clcae ' " no exposure for Should try to retain business by clean-urn; by education of cus"-* tamers. OtM Action Benlgnus/ Bryant Should try to minimize chance of dumping "old" fluid by re working and by educating co. shops and collecting product for rework or disposal. Dalton is set up in England to rework electrical grade fluid. ' Kuhn/fcountz Findett? Need rework facility here + disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of .chlorinated biphenyls ^ at Kruntmricfa or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. . Action - Take steps to see that every precaution Is taken to prevent Arocior entering water streams. Try ' to reduce to ppb level. . ' P .Hodges-Seek a Oovt. contract on adsorption and incineration TSD cycles - MRC. Engrg.- ` Kountz . Take samples of streams and river water and mud evidence for before and after clean-up. Samples can be stored for further analysis if we can't keep up current with analytical determinations. Apply Monsanto clean-up methods to customer plant OlsJ--'l u;> i.'.z ia'.U , DSH 01V261 WATER_PCB-SD0000006146 Action - Engrg. & Mrs. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing or Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at 1-W lbs/year, exclusive of'cleaning up river bottoms or outrall bottoms. . Hydraulics 20% or W lbs Heat Transfer 1056 of 2ff lbs Capacitors ' 5^ of 20fT Transformers 5% of 1ST 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. k Mfg TSD Kountz & Kuhn Set up an incinerator to handle Aroclor dls-\ , posal - preferably one which will handle \ solids such as muds - slurries as well as liquids. Have in operation within 12 months. ; AP 7 Ideally have incinerators available different / sections for disposal. /' . L 7 Possible help from MKC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio- Test Continue studies to establish FDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Reworic with R. Keller-S. Tuclcer the number of samples which are to be analyzed for Aroclor in tissue. Try to see if Aroclors are changed metabollcally. Does concentration level off, decline if feeding is-stopped? ,* Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Aroclor levels of toxicity, then we will have to have biological studies on. these species to con firm or deny adverse findings. DSW 014262 WATER_PCB-SD0000006147 8- - Blodegradatlon Studies Set up rate or biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 * Aroclor 5442 vs; Aroclor 5460 Swisher Chlorinated diphenyl ether Chlorinated pararrin vs. chlorinated naphthalene Chlorobrorao Aroclors 1242 and 1248 . Baxter Contact Baxter and Lldgett at MCI regularly for results on Lldgett Aroclor degradation. They are reported to be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. VRR:ms V. R. Richard OSU 014263 WATER_PCB-SD0000006148