Document 6RwXxy1X8pmy0krBg4ObJjzvE

V. B. PAPA033RQ- - ST. LOUIS s' KARCT 6, 1970 D. DANHA H. S. BiJIGa; aroclor snnRc?r-u?:TAL program J. E. SPni.VOQATS J, R. DURLAHD - TOKYO ^ 1 . . . I apologize for the delay record Inc comments on the questions In your memo dated Dcce.nfcer 29, 1969. The PCE "learning process", although not oonplctcd, h&a token longer than 1 had anticipated. Waste Handline - U. S. Planta Both the Anniston and W. G. Kruonrich planta have become more aware of the need to reduce the amount of Aroclors In the plant effluento to essentially zero. Lacking any positive Guidelines, we have tentatively selected a target or 10 ppb. Eoth plants have monitored their otrearcs to determine current levels or PCD presence a:xi have active prog rnnn to redueo leaks, spills and deliberate du'iplne. Ho nunJor capital expenditures are planned at this time. The Anniston plant plans to lr>otall a dump in their sewer cvstcra to trap Arocioru. All waste containing PCB'o is ot present hauled to the dumps the plants have been using ror other plant waste. We rccocnize thin Is not the ultimate, since PCB's could eventually enter the environment, but we will continue this practice until better methods of disposal ore available. I have arranged with the plants to send reports of the status of these activities to you through Loa Banna. A copy of the analytical procedure wc are using is attached. Aroclor 5460 Ve do not know what happens to Aroclor 5^60. Ho one has reported Its presence 21 samples of water or wild life. Ve are assuming that its lew solubility may preclude Its free movement in the environment. Some questions have been raised concerning the ability of current analytical techniques to discern Its presence. PLAINTIFFS EXHIBIT no HCNS 099591 n'i PENGAD-Bayonne.N J HARTOLDMONO017794 Aroe 1 or 2254 and Aroelor 1260 Our original plana to move toward discontinuance of 1254 1260 were primarily bared on the infor mation available which indicated the chlorinated biphenyls with 5 and 6 ehlorinoa were the type consistently round in the environment and considered to be harmful. lairing a recent meeting with repre sentatives of Ceneral Electric, this decision to discontinue 1254 end 1200 was challenged. The Q.E. representatives believe that the benefits of these Aroclorc in transformers far outweighs the yet questionable threat to the environment. It appears that in those situations bdiere control is practical, such as transformer usage, we could continue* to supply Aroelor 1254 and 12o0. We plan to take this position in our next review with the Corporate Management Committee. HCR Paper The presence of PCD in KCR paper poses a particular challenge. The ultinatc destination of this product is difficult to control, lior.aal incineration vapor ises the Aroelor which eventually is found somewhere in the environment. The NCR people, both in the U.5. and U.K. have been looking Tor a substitute for Aroelor 1242 for several reasons. The POi threat has accelerated this desire to convert. Ir. the U.K. arrangements have been made to test Hk-40 as an alternate. At this time, there appears to be come optimism that the tests will be successful. In the U.3. , with a slightly different process, the HJWtO is not considered an adequate substitute. HCR-U.S. is evaluating alkylated biphenyls as possible sub stitutes. Aroelor Toxicity - Anniston Plant Tour question as to why the toxicity of Aroclors has not turned up downstream of the Anniston Plant after 40 years of manufacture is difficult to answer. Ke Just don't know. Aroclors have been found in Snow Creek near the plant. There is no record of any water life observed in this creek for many years. Ve'vo assumed other plant wastes were to blamo; e.g. muriatic acid. Aroclors could be Involved also. HONS 099592 HARTOLDMONO017795 -3- Blodcgradablllty Testa cn the blodegnadablllty of Aroclors are being conducted both In 3t. Louis Research and at Ruabon. At present. Aroclor 1221 appears biodegradable In river water and activated sludge. Aroclor 12*12 undergoes slight degradation in sludge containing BacroorT.anls.us acclimated to biphenyl. All other Aroclors have isolated biological degradation, to date. There la soao indication that isomer structure determines ease of degradation. Incineration Aroclors will decompose at temperatures exceeding 800P. Bayer and Prod dec In Europe claim they are Incinerating PCL'e. Wo have been promised data on the stack gases formed. The Rolllna-Purle, Inc. people in hew Jersey claim that they incinerated some Aroclor 129**. We have aooie doubts about the degree of destruction achieved and wo plan to pursue further. We hnYe made arrangements for testing at the John Zink Coupary: Tulsa. Oklahoma for the week of March 9. Our objective is to get Incineration data which we can use to 1) evaluate commercial Incinerators, 2) design plant incineration systems or, 3) provide to our customers to help them with their disposal problems. Toxicity Studies are being conducted for Monsanto by the Industrial Blo-Tcst Laboratories outside of Chicago. The effects of Aroclor 1221, 12*42 and 1260 on rats, dogs and chickens are being observed. The results, so far, hare been Inconclusive. Ye are retesting and extending soao tests to confirm the initial results. Wasto Treatment Studies on the removal of Aroclors In solution or emulsified In water are being conducted. Anniston Is studying the removal by carbon. MJtC, Dayton, is studying the removal on acid clays. Once we have successfully removed the PCB from solution, we plan to develop means for oompletc destruction of the PCS on the carbon'or clay. HCHS 099593 HARTOLDMONO017796 -4- As you can see, there are many areas with unanswered questions. Much or our effort at this tine la being expended on activities aimed at providing us with oore information. As the results become available, we will forward them to you. Attachments W. B. PAPAGEORG2 HONS 099594 HARTOLDMONO017797