Document 6nevMwkMNpm2aeoz51pJgxbR

Monsanto ' r*. * iof.Tio. a. E. Peterson, JFQ p<_ ("> ' I V 6 > 0t( US^CCY mitt MCI TO November 30, 1 f)71 Potentlo! PCD Contamination - JFQ F, J, ilolzapfel ec P. B. Hodges - 0.0, D. C. Mo I m E. D. Ho I one 0. E. Mun! e Pepageorge - G.Q,< E. F. Take B. L. T11 ford R. L. Wiese There ore three general sources of potential PCB contamination in JFQ products: 1. leaks from heat transfer systems. 2. Carry over from compressor fluids. 3. Impurities In process chemicals. A program to minimize PCD losses from heat transfer systems and compressor fluids has been underway since September 1970 and is essentially complete. The program consisted of eliminating one unnecessary system, chonglng exchange medium to non PCD containing fluids In six systems, ond changing to less persistent Arocior 1242 from 12^>o In three systems. In addition, necessary equipment modifications have been made to both minimize and contain arocior emissions to the atmosphere and sewer. All Arocior from leaks and change out of fluid Is collected and sent to unit for Incineration. I. Heat Exchange Systems. High rCD content Aroclors are still used In three heat exchange systems. Two of the systems are In the W building and the other In Phthnlyl Chloride. a. W Dldg. - Arocior 1242 Only one of the two units Is In use. The other unit has been cleaned and shutdown. The pump on the active unit has been panned ond leaks collected for disposal at WGK. Approximately one year ago cons I derat I on~was given to the use of non PCD containing fluids In these systems. Both units ere gas fired. The Increased safety hazard and expense of eleborete protective systems that would be required for other fluids did not appear warranted at that time. Mo leal'J hove been experienced 1 n the vessels us I ng arocior as the heating medium, During the post year the following products have been produced In the arocior heated units. Product Uses OS-124 2 phenyl aminopyrldlne\ thenyl pyramlne besej TrImethoxy benzoldehyde lubricant, vec pump fluid Intermediates for methopyolines (antIhlstamlnes) Drug Intermediate IN.I# tV !- EXHIBIT nr /cJ- & - ?-<z- TRAN 036583 WATER PCB-SD0000005924 Homo to F. J. Holzapfel "2" 11/30/71 b. Department 32 - (Phthalyl Chloride) - Aroclor 1242 The foil/ Inf) products mr.de 1 n this uni t and the I r uses are: Product . Uses Phthalyl chloride Intermed, for diphenyl phthalate an FDA approved plasticizer, paper binding, Astroturf Denzyl esters Perfumes for soap, FDA approved for foods OS-59 Hydraulic fluid, dielectric coolant OS-120 Hydraulic fluid OS-l^O Hydraulic fluid Aroclor is used as heat transfer fluid In a nlcltel lined reactor which 1s heated by electric cal rod units brazed to the jacket surface. The fluid Is circulated through an external heat exchanger cooled with City water during a portion of the cycle. A leak In the jacket would contaminate the product, however, no leaks to the vessel contents have ever been experienced. Consideration was given to the use of non PCB containing fluids about one year ago. The potential fire hazard from the use of cnlrod units In a non fire safe fluid precluded the change at that time. 2. Compressor Fluids Low PCB content (1%) Pydraul ACA Is used In one plant air compressor. A long range program has been established to convert all plant air compressors to Pydraul ACA by 1976. The entire plant air system Is tied together distribution-wise. Any product using compressed air directly for processing could be contaminated by fluid carryover. 3. Process Chemicals . a. Chlorosulfonlc Acid produced at WGK Is used as a raw material In TSC1 and is believed to contain PCB Impurities. No determination of PCB level has yet been made. All TSCI family products could be contaminated with PCB from the CS acid. TRAN 0365BA WATER PCB-SD0000005925 Memo to F. J. Holzapfel -3- 11/30/71 The following TSCl Family products and their uses are: Products Uses TS Amides Intermed. for Saccharin and oral diabetic agent, Plasticizers, Paint Saccharin Sweetner Santicizer 3 0, S 1-H Plasticizers b. CLHS used reformulated terphenyis which still contain low levels (about 1%) PCB impurities. Cross contamination with subsequent blends could result If equipment is not cleaned out properly. No food related blends are made In these systems. Elimination of Aroclor Fluids The use of aroclor fluids has been discontinued In the following places: 1. \A7 Bldg. - Research All units using Ar-oclor 12*$ have been switched to Therminol 66, 2. TSCl The two heating systems have been switched from Aroclor 12-48 to HB^O. 3. TSCl Nosh compressor has been switched from Aroclor 1232 to Sant I clzer 140, a phosphate ester. The fol1 owlng program will be undertaken to minimize potential PCB contamination at JFQ. . 1. Meat transfer systems - Determine the feasibility and cost of safely using a non-PCB fluid In all three systems. 2. Compressor Fluids - Determine the feasibility and cost of switching to a f1 re resistant non-PCB fluid 1n all plant air compressors* 3. Process Chemicals - Request WGK to provide CS Acid guaranteed not to contain PCB1s. TRAN 036585 WATER PCB-SD0000005926 Memo to F. J, Holxapfel 11/30/71 In addition, we will consult with Dill Papageorge to determine the frequency and analytical accuracy required to measure PCB content In the following materials. 1. All products exposed to Aroclor heat transfer systems. 2. Plant air system on a spot basis. 3. TSC1 family . Food related products blended at CLHS which follow Aroclor b!ends A sewer monitoring program for PCB's has been in operation for the past year. Recently PCB's have been found In the dirty acid sewer which Is connected to departments with no known PCB'usage, A special sampling program has been undertaken to locate the source. A. E. Peterson /ft, i M. T. SChade : ld< TRAN 036586 WATER PCB-SD0000005927