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H. S. BERGEN - ST. LOCKS SEPTEMBER 12, 1969 DEFENSE OF ARGCLOR * FUNCTIONAL FLUIDS R. M. KOUNTZ V. A. KUHN' "vrxr'dLsou Flease find attached a rough draft from Dr. Richard to Elmer Nheeler regarding Arcelor toxicity. I would appreciate your comments to both Dr. Richard and myself regarding this draft. H. S. BERGEN ms DSW 014254 STLCOPCB4003214 vv.. i\N`" . ;WXLLIAM RICKARD n. S <5. v>rt'-'vr--<-A'tiC !\sv-**iUO 0^- \f CK-(*&rs , /^Wi-V.. o^Ltc^c. ^ a. "t-clrfr</ A CiUfU. ' I w*-' DSM 014255 STLCOPCB4003215 fo ,NAMt * loc*t<on, yj # r. Richard - Research Center DATE SUOJECT REFERENCE TO September 9, 19&9 DEFENSE OF AROCLOR FT "FLUTES'--------------------- E. Wheeler - EWHEE P. Hodges, PRODG <V'fQ RE Vi General Policy . 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 In Water- Which compounds.^ Govt. In Animals ^interfere? JAgencies Keep track of how much contamination - which sources. Prove Bioharmful - Let Govt, prove its case, on case by case basis. ~ ----- . ^ j Monsanto Visit-Govt. Bloiabs - in search of toxicological experiments and evidence vs. Aroclors to keep up with progress. Monsanto Prove Bloharmless - Limited work at Ind, Bio-test "Safe" toxic level for man mammals via fish Rats Seek evidence of Biodegra- Chickens dafclon Fish Question evidence against us. . Question shrimp toxicology . especially other toxic . chemicals. , If Aroclor bad, others must be worse. . Probable Outcome 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 defend '.gainst. Higher chlorination compounds will be worse on. . -ower chlorine compounds. Therefore we will have to restrict uses and clean-up as much as_jwa_can,. starting immediately, a > n 1 OSW 014256 STLCOPCB4003216 -2 Therefore we will have to work for alternate products in end use applications; for Aroclor production facilities. Clean Up Ar.oclors and substitute products where necessary : and when required, before threats of publicity and 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 1260 present issue. 40-200 ppb - causing problem at Pensacola (Monsanto) in plant effluent-causing " with shrimp. - can't risk shut-down of plant. Federal and State can extrapolate to other plants in . Gulf area. San Francisco - Aroclor 1254 and 1260 Reported Aroclor to be present in San Francisco Bay. Reported to be thin egg shells in birds - Lot of screaming - . Great Lakes 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.. . . Analytical work more difficult. j. 7 ; Direct Contact with Product ii L ' ?. . . Doesn't seem to be an issue - except for food heat transfer -vv`' We don't believe Aroclor is being used as carrier for insecticide - sprayed around - ' ; ' We are not positive but most uses are "closed" systems!! or products used, in solid plastics, or adhesives, or H sealants. .' .. 'v #1 .cS*- DSW 014257 STLCOPCB4003217 3- - F. Fluids __ Product Hydraulic Fluids Air Compressor Fluids Heat Transfer . Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutior Customers Plant Operation by Customers Pro Yes, leakage external Yes, leakage external Yes, leakage external Yes, leakage from plant - Scrap materials. No, Should be clean. Yes, Reworked trans formers './ Possible - See Johnson Motors Castings. Leakage into produc Leakage into produc In product but closed for.end use* In product but closed for end use* * Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ** Need to take care of Aroclor in discarded transformers. Product could be drained and reworked. Probable Conclusions Hydraulic Leakage ; .. - 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. Air Compressor Fluids " Hydraulic Fluids Must expect *'shrimp*' experiments, . , ; . West Florida State, to be "aired" 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 125-4 and Aroclor 1260, DSInl 014256 STLCOPCB4003218 4- - We will have to take action before that time. Gulf Coast Action Wy Richard Fallon/ Richard Be 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 Dec. 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 Work 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 1248 in 6 months in hydraulic fluids. This means replacement of Pydraul 512 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. Heat Transfer D$W Fallon/ Roush/ Kountz Systems will have some leakage.depending strongly on engineering and maintenance. Need to work with customers on clean-up, .. 014259 Fallon/ Roubh Need to replace FR especially in food or sensitive product the product is getting into water. See dish washer compounds. See letter E. Wheeler to Fallon. ' . We have possible rep cement products in Therrairr. 55. Thermi 66. STLCOPCB4003219 5- - Action Kuhn . Kuhn/ Fallon Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. Ha and terphenyl supply may become short. Switch customers to Therminol 55 or Therminol 66 ahead of pollution problems in customers plant. . Work with customers on plant, and dumping practices. Findett already set up to rework. Need to make them a manufacturing arm. We get sale of recycle-rework fluid. Capacitor Capacitor plants have re Fluids purification and recycle systems but up to 5$ of product can be lost by poor plant producers and off-quality material. Mkt. Benignus/ Bryant 5# 0f production could be Eng,-Kountz/ Mfg-Hodges . 1FT lbs/year. This is a 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 Monsanto must start to work with capacitor people to Eng.,TSD- clean up plant practices. Plant Pol- . We have set-up to accept lufcion Con- material for rework into trol hydraulic fluid but this relocation is not a satis- Hodges/ factory solution. Material Kountz 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 Aroclor business with other products. Have 2years, , / : Action ' . Monsanto must help plant clean up of customer plants decantation, coalescing.* adsorption, bis- . posal of adsorbent or recycle of adsorbents. ' Monsanto badly needs "know-how11 for clean-up. Monsanto should seek Govt, contract money for clean-up research, (See MRC R. Binning, D. Nelson) / . QSW 014260 STLCOPCB4003220 6- - Transformers Action Benignus/ Bryant Transformer Plant can operate in a clean, efficient manner with recycle of off-grade Aroclor. : .. 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. Aroclor is dumped into a water stream. . Product transformers can remain closed and no exposure for 25 yrs. . Should try to retain business by clean-up by education of customers. . Action Benignus/ 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/Kountz 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 r- at Krummrich 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. . ' \ P.Hodges-Seek a Govt, 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 cleanmethods to customer plant . up and procedures. DSW 014261 STLCOPCB4003221 7- - Action - Engrg. & Mfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at 1-4m lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. .. Hydraulics 20$ of 4m lbs Heat Transfer 10$ of 2M" lbs Capacitors ' 5$ of 20M Transformers 5$ of 15M" 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. & Mfg TSD Kountz & Kuhn Set up an incinerator to handle Aroclor dls-\ j posal - preferably one which will handle A .' solids such as muds - slurries as well as \, LL liquids. Have in operation within 12 months. i/V5 / 1 Ideally have incinerators available different. / sections for disposal. / Possible help from MRC 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. Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Aroclor in tissue. Try to see if Aroclors are changed metabolically. 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. OSM 014262 STLCOPCB4003222 8- - Biodegradation Studies Set up rate of "biodegradation studies with Inorganic DIv. on Aroclor 1242 vs. Aroclor 1254 .. ' Aroclor 5442 vs. Aroclor 5460 Swisher Chlorinated diphenyl ether .: . Chlorinated paraffin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 . Baxter Contact Baxter and Lidgett at MCL regularly for results on Lidgett Aroclor degradation. They are reported to "be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. ` WRR:ms W. R. Richard DSW 014263 i STLCOPCB4003223