Document G9N4ELOXXMxZE0Bm05ZrOx24

I I / Monsanto TO o * W. B. Richard - Research Ctnttr September 9, 1969 DET?EENNSSE 0O!F AROCLOR yr"mpnrror -------- -- ?. Hodges. PHODG X. Wheeler - EUHES General Policy Maks the Govt., States and Universities prove their ease, but avoid as mueh confrontation as possible. Comply and */| work with public officials to meet or*exceed requirements ahead of time. Adverse publicity and coapetitlon are the real weapons. Analytical fin Air - Which Aroclors are present? Where?! ' for Aroclor tin Water- Which empniiw<<'> V( (in Animals ^interfere? Jaj Keep track of how niuch contamination - which sources. Prove Blohamful - Let Govt, prove its case, on case by ease Monsanto Vlalt-Oovt. Blolaba - in search of toxi colog: r " experiments and evidenc vs. Aroclors to keep up . progress. Monsanto Prove Bloharmless - Limited work at Ind. Bio-test - Safe" toxic /man Rats Seek evidence of 1 level for <mammals via Chickens d (fish Pish Question evidence a u Question shrimptcxl . . . especially other t< chemicals. If Aroclor bad, oV. * . must be worse. Probable Outcome Va can prove some things are OK at low concentration. Give Monsanto some defense. . Ve can't defend vs. everything. Some animals or fish or insects will be harmed. Aroclor degradation rate will be slow. Tough to defend -gainst. Higher chlorination compounds will be worse . lover chlorine compounds. . ,, *1" Therefore we will have to restrict uses and elean-up as muchwe <en. starting immediately. ^ 5 PLAINTIFFS i EXHIBIT : j23 EV 91 ( M0N 0209 STLCOPCB4023930 -2- 3 Therefore will have to work for altimti produets la sad use applications; for Aroelor production facilities. Clean TTp Aroelor* and substitute products where necessary and wen requirea. &o7ori`~E5Fsta of publicity ana competitive sctlvitv over, whelm us. " Water Pollution seems to be first Issue Aroelor product Is refractive, will settle out on solids sewerage sludge - river bettens, and apparently has a long life. ?lorlda or Gulf Coast - Aroelor 125* - Aroelor 1250 pres Issue. *0-200 ppb - causing problem at Pensacola (Monsanto) In plant effluent-causing " with shrlnp. - can't risk shut-down of plant. federal and State can extrapolate to other plants la . Gulf area. San franc!aco - Aroelor 125* and 1260 . leported Aroelor to be present In San fraaelaeo lay. Deported to be thin egg shells la birds - - Lot of screaming - Great Lakes Varf studies on SD7 . Aroelor 125* will be found! Aroelor 12*2 will be found? Air Pollution - Possible spread - but less of an issue ----------- : right now. Analytical work more difficult. 0- Direct Contact with Product /V: Doesn't seem to be an issue - except for food heat transfe: Ii Ve don't believe Aroelor Is being used as carrier for [ Insectic.ide - spraye. d around - . ! >.ivr/f * . if * Ve are not positive but most uses are "closed" systems-! . or products used la solid plasties, or adhesives, or ; sealants. 1 . . . /. MON 0210 4 0079 STLCOPCB4023931 J) o 3 r. rands t ____ ___ ' ** Produet Hydraulic >1uida ' Air Compressor Fluids Heat Transfer: ' Capacitor Fluids Transformer Fluids Possible Pollution by Possible : Customers Plant Operation by Custcn Yea, luki|t external Tis 1m)u|i ixtinsl lot, leakage iztinal Yea, leakage from plant - Scrap materials. No, Should be clean. Tea, Remorked trana formers Possible Johnson Kot Castings. Lalca( int Leakage 1st In produet closed for In product closed for Capacitors can go to land fill dumps. Probably sot burned, la A1 containers. ** Need to talcs care of Aroclor la discarded transformers. Product eculd be drained and Probable Conclusions .. Hydraulic Leakage . ' .. ' - Product could bo caught at machines but will take a lot of dean-up work with customers. - ' Will have to have replacement product - mlth less-sensitive components. York from this base oa clean-up to prevent more pollution problems. Air. Compressor Fluids ` * ' Hydraulic Fluids * Must aspect * shrimp" experiments, t * ** * . Vest Florida State, to be "aired" . / . '** . sometime soon; next few months. ' ' ' ` '- . ' v' * . * f ' * . ' . This mill lead to bad publicity and competitive aetlon vs. all ` Pydrauls. .. . * ^ Ye mill have to try to confine to Aroclor 1254 and Aroclor .1260. * 0080 MON 0211 STLCOPCB4023932 <J 4 Vt will have to take action before that time. Gulf Coaat - Action V. Richard Pallon/ Richard Be able to replace Aroclor 1254 and Aroclor 126o In Pydraul AC and 625 la 2 month'a time before Xov. 15, 1969. Have trial product In hands of Oulf Coast accounts and distributor before Bee. 15. Pallon Suggest possible buy of "all phosphate" ester from Pood 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. Pallon/ Suggest field trials of our own all-phosphate Richard ester. Pallon/ Work with large customers to elean-up streams. Kuhn/ Bring In Plndett as mfg. partner In the recycle Kountz business. Get money out of recycle operations. Inland-Waterways - . Wheeler/ Be close enough to Great Lakes studies to Judge Richard 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. Beat Transfer 4 ooei Pallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Heed to work with customers on clean-up. . Pallon/ Roush Need to replace PR especially in food or sensitive preduet areas where the product is getting into water. Se dish washer compounds, oee letter 2. Wheeler to J*. Fallen. ' . Ve have possible rep oeaent products in Themirv.. MON 0212 Therr.ir.-.. iO PI Ot lW STLCOPCB4023933 o5 Action Kuha . Kuhn/ Fallon ' Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. Ha and terphenyl supply nay become short. Switch customers to Theminol 55 or Therninol 66 ahead of pollution problems in customers plant. - Vorlc with customers on plant and dumping practices. Flndett already set up to rework. Need to make them a manufacturing aim. Ve get sale of recycle-rework fluid.- Capacitor Capacitor plants have re- Fluids purifloatIon and recycle systems but up to 5% of product can be lost by poor plant producers and off-quality material. Mkt. Benlgnus/ Bryant 5$ of production could be =?`" nrg-age* . p0nution we are trying now to guard against. Capacitor products Enclosed in A1 or stainless steel for 5 to 25 year period. Vill ultimately hav< to dispose of capacl tor products. Recommend we try to save this product fe a time. Action ng.,TSDPlant Pol lution Con trol Bodges/ Counts Monsanto must start to work with capacitor people to dean up plant practices. Ve have set-up to accept material for rework into . hydraulic fluid but this relocation is not a satlsfactory 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 replacemen future Aroclor busin with other products. Save 2 years. Action Monsanto must help plant elean- - up of customer plants decantation, - ~ coalescing, adsorption, dls- posal of adserbent or recycle of adsorbents, .. Monsanto badly needs "know-how" for clean-up. - Monsanto should seek Oovt. contract money for elean-up research, (see KRC R. Binning, D. Mellon) . MON 0213 * 0082 STLCOPCB4023934 Transformers Transformer Plant eta operate' in a clem, efficient manna? with recycle of off-grade Aroclor. Product transfor can remain close Action Should advise disposal of no exposure fer Benignue/ ' filter eleaent materials so as to minimize chance of Bryant water pollution. Incinerate . . .-..-.d-'or dispose. . Reworked transformers pose a threat If the Aroclor Is dumped Into a water stream. Should try to re business by clea: by education of t toners. Action Benlgnus/ Bryant Should try to minimize chance of dumping "old" fluid by re working and by educating eo. shops and collecting product for rework or disposal. Belton is set up In England to rework electrical grade fluid. XuhnAountx Findett? Heed rework facility here + disposal scheme. Monsanto Plante The Bept. of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Krummrleh 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 Aroclor entering water streams. Try to reduce to ppb level. . ' ' t.Bodges-Seek a Govt, eontraet on adsorption and Incineration TSB cycles - KRC. Xngrg.- Counts 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 e*e*n up anU procedures. * 0083 mpn o?i <i STLCOPCB4023935 o 7 0 Action Zngrg. k Mfg. Kountz and Kuhn Evaluate liquid Incinerator* vs, solids handling incinerators for dlaposinc of Aroclor and pentaehlorophenol wastes. Z estimate Aroclor disposal at l-4ff lbs/Vear, exclusive of cleaning up river bottom* or outfall hottoms. .. Hydraulics 20$ of 4ff lhs Heat Transfer 10$ of 2ff lhs Capacitors '' 5$ of 2CfT Transformers 5$ of 15fT . 600.000 lhs 200.000 lhs 1,000,000 lhs 750.000 lhs 2,750,000 lhs Central Eng. k Mfg TSD Kountz fc Kuhn Set up an incinerator to handle Aroclor dls-\ posal - preferably one which will handle \ -r* solids such as muds - slurries as well as ., liquids. Have in operation within 12 months. /C~ ' Zdeally have incinerators available different ` sections for disposal. / Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller 2nd.Bio Test Continue studies to establish FDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Rework with R. Keller-S. Tucker the number of samples which are to he analyzed for Aroclor in tissue. Try to see if 'Aroclors are changed metahollcally. 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, blologleal studies on these species to eon- fizm or deny adverse findings. ***-. *' i t 0064 MON 0215 STLCOPCB4023936 f :> % . Biodegradation Studies * ' Set up rate of biodegradation studies with Xnorganlo Dlv. on Aroelor 1243 vs. Aroelor 1254 . ' Aroelor 5442 vs. Aroelor 5400 Swisher Chlorinated diphenyl ether Chlorinated paraffin vs. ehlorlnated naphthalene ' ' Chlorobrca Aroolora 1242 and 1248 Baxter Contaet Baxter and Lldgett. at MCL regularly for results on Lldgett Aroelor degradation. They are reported to be moving on MCL laboratory experiments. Establish eontaet with ehlorophenol degradation studies of Cellu-Chea Group. .* * WRRras V. R. Richard 4 ooss MON 0216 STLCOPCB4023937