Document JvvB7BKeDOkr4nbe1kMBNrX0a

I..0 ,........tocrnowi w. r :'Richard - Research Center September 9, 1969 DEFENSE OF AROCLOR F FL0IBS------------ P. Hodges PHODG TO E. Wheeler - E^WHEE General Policy i Make the Govt., States and Universities prove their case, but avoid as much confrontation as possible. Comply and y work with public officials to meet or'exceed requirements ahead of t i m e .Adverse publicity and competition are the real weapons. Analytical (In Air - Which Aroclors are present? Where? " forArocTor ijn Water- Which compounds^ V Govt. . . ' (in Animals ^ i n t e r f e r e ? _ J Agencies Keep track of h o w m u c h contamination - which sources. Prove Bioharmful - Let Govt. p r o v e i t s case, on case by case basis. ' 1t - - -r- j Monsanto V i s i t -Govt, Biolabs - in search of toxicological experiments and evidence va. Aroclors to keep up with progress. Monsanto Prove B i o h a m l e s s - Limited work at Ind. Bio-test - "Safe" toxic f man level for < m^rnials via (fish Rats^ Seek evidence of Biodegra- Cnickens dation Fish Question evidence against ` us. Question shriiptoxicology . 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 defer.; gainst. ii.gher chlorination compounds will be wore-...: . . ..er chlorine compounds. \ Therefore we will have to restrict uses and clean-up as ch c._s.._we._.r,an, starting inunediately. .v 4- ..... NV 027584t oCoO 0o0 r- - 2- Tnerefore we will have to work for alternate products in end use applications; for Aroclor production facilities. Clean Up Aroclors and substitute products where necessary '~ ' and when"required, before threats of publicity 'and competitive activity o v e r 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. - c a n '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. ' <>< /i Direct Contact- with Product J- A "' V j D o e s n 't seem to be an issue - except for food heat transfer.- /V v... We d o n 1t believe Aroclor is being used as carrier for insecticide - sprayed around - ^ i .-v j V We are not positive but most uses are "closed" systems;: or products used in solid p l a stics, or a d h e s i v e s o r ;; sealants. 740839 NEV 027585 ! -3- . F. Fluids Product Hydraulic Fluids Air Compressor Fluids Heat Transfer. Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutlor Customers Plant Operation by Customers Prod.; Yes. leakage external Possible - See Johnson Motors Castings. Yes, leakage external Leakage into produc Yes, leakage external 'Leakage into produc Yes, leakage from plant ' In product but - Scrap materials. closed for end use0 No, Should be clean. Yes, Reworked trans formers In product but closed for end use* * Capacitors can go to land fill dumps. Probably not burned, in Al containers. ** Need to take care of Aroclor in discarded transformers. 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. ii Hydraulic Fluids ' Must expect "shrimp" experiments, West Florida State, to be 11a ired11 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. 740840 NEV 027586 - 4- We will have to take action before that time. Gulf Coast - Action w. R i c h a r d Fallon/ Richard Be able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 1n 2 month's time before Nov. 15, 1969. Have trial product in hands of Gulf Coast accounts and distributor before Dec. 15. ft ( Fallon lI M Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid M C S ___ 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/ Suggest field trials of our own all-phosphate R ichard. ester. Fallon/' Kuhn/ Kountz Work with large customers to clean-up streams. Bring 1n Flndett as mfg. partner in the recycle business. Get money out of recycle operations. Inland-Waterways- lheeler/ Richard Be close enough to Great Lakes studies to judge situation. Are there animals which are being affected by the concentrations found? [Richard I ' Be prepared to replace Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and in air compressor fluids. iRichard I Be prepared to replace all Aroclor 1242 or 124f in 6 months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to o t h e r 'hydraulic accounts such as Cities Service and Mobil. Heat Transfer NEV 027S7 Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. Pallon/ R o \j:>h Need to replace FR especially in food or sensltJvc product arose w h r . r i - c produot is tfettin,:; 1.nco water. Se\;.' j w a s h e r oompounos. See letter E. Wheeler tc T. Fallon. We have possible re;: ::ement products i Them.! r fo . Therr.il.. . G . 740841 Action Kuhn Kuhn/ Fallon Try to assure adequate production of Therminol 66 1n 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 a m . 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/ B ryant 5# 0 f production could be^ Eng. -Kouhtz/ Mfg-Hodges 1R' lb s /year. This is a big loss for the type of pollution we are trying now to guard against. Capacitor products Enclosed 1n Al 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. CO ct Action ' Eng. ,TSDPlant Pollution Control 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 1 s 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 replacemen future Aroclor busin with other products. Have 2 years. Action ' Monsanto must help plant clean up of cuctou-:.:r pl.u.ta. '-v,cantation, cOalescinc, adsorption, dis posal o : ahso.-bei.t or recycle of Kous:::.nuc. bacly needs "know-how" for clean-up. Monsanto should seek Govt. contract money for clean-up research, (See MRC il. Binning, D . Nelson} 740842 NEV 0275d8 hr- 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 ant no eryosure for 25 y r Should try to retain business by clear; -u::i; by education of cus tomers. Action Benignus/ Bryant Should try to minimize chance of dumping "old" fluid by r e working and by educating co. shops and collecting product for rework or disposal. Dalton Is set up in England to rework electrical grade .fluid. K^mrmountz 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 K ^ ^ m r i c h or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. a ction - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try I to reduce to ppb level. ' P.Hodges-Seek a Govt. contract on adsorption and incineration TSD cycles - MRC. E n g r g .- Kountz .Take samples of streams and river water and mud evidence for before and after clean-up. Samples can be stored for rurther analysis if we can't keep up current with analytical determinations. Apply Monnnnto ...1oan-rp methods to customer plan'.. NEV 02758' 740843 - 7- Actlon - Engrg. &: Mfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at l-4[.f lbs/year, exclusive of cleaning up river bottoms .or outfall bottoms. Hydraulics 20% of 4M lbs Heat Transfer 10% of 2.ff lbs Capacitors 5% of 20f:f Transformers 5% of 15ff Bo0,000 lbs 200.000 lbs 1,000,000 lbs 750.000 ,lbs Central Eng. & Mfg TSD Kountz & Kuhn 2,750,000 lbs \ ,/ Set up an incinerator to handle Aroclor di::.-" , vr posal - preferably one which will handle . solids such as muds - slurries as well as , J ^ i, liquids. Have in operation within 12 months. 'fir ' 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 tjrpe 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 1f 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. NEV 0,7590 740844 - 8- Blodegradatlon Studies Set up rate or biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254. Aroclor 5442 vs. Aroc.lor 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 Lldgett 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 NEV 027591 740845 . CONFIDENTf.L . T A B L E JE* Product Index__ J*sf 1 kU.^(a Kcd a LAS Sfrirttvr ! AVAutu"M f T c* ^ r AttL . * O Cytfe* ' Ti'm (if) /^As L* I 2 4 >ff.5 1 p -C S ls.tn t/tc ,, o 0 _ ' S 2-- 1 j t -,- * "* i " ! ,o ,, {J .> q4.f . -- A fT P B c ^ > F** -/ o 2 - 78.2i_,,.2 ! s H B -(o o-- - 2-- - S.iH?i\ -i fl " ti . 1". K S -7 //_ 0 & 3t_7 j 0-N C 3 ' & ............... -- S . . , Z1/ s z s r s e ; 1 10 flH 'fo.3__S.' r f a k j a - f l t * e \ c , ' { J u* 1S lo -- " U C B e-O -i/a, M s . . ; 11 !1 -io Artcft, 2? . 2 Z U ... I --o S \s - F z-- *+'0.3t3Z\ ..it'n *24' 1 3 & /M i f. le.,, t * / _ .fl ' S /--_ . fa l_ ,,.eC ,,r/2 3 2 \s/^As / . i //%,, 5 i Z 7 -- 'S11 7'f__ 1/8 Si1/f.8.s 78 - S i/W i IM f t e s / r n . * . / -- 'V*4 s. -T-03PZ-$--:-t3--.8- . I', ! 740846 _ 15 1r*# clof U***. _ _ Uy P.C. !r ..rfvt & @ a &7.C I ' '\x?"W _ %r . , Ar0cUr f2& 4 1./ %1o J$ TCC / -T------------------1------;--------- -- t YL*18m 8 / 7A3 * 3*3" 1/8- Z+'.3t/sJ / GS 1 .# fais}? 1 2 / 1\ O , . : ^ -- SzV 0759