Document LJbG6Y1bmbzk1pXmZN8gnqVrb

W,twl A lOt'I'ONt R, Richard - Research Center September 9, 1969 *' DEFENSE OP AROCLOR F7~PLUHS-------------------- P. Hodges. PHODG TO . Wheeler - EWHEE General Policy 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 ahead of time. .Adverse publicity and competition are the real weapons. Analytical pin Air ' - Which Aroclors are present? Where?! for Aroclor tin Water- Which cnmnnnnris^ i 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. Monsanto Visit-Govt. Biolabs in search of toxicological experiments and evidence vs. Aroclors to keep up with progress. Monsanto Prove Bioharmless - Limited work at Ind. Bio-test "Safe" toxio Tman level for < mammals via (fish [EXHIBITNO. <>?<% Probable Outcome Rats Seek evidence of Biodegra- Chickens dation Pish Question evidence against us. Question shriuptoxicology . especially other toxic chemicals. . . If Aroclor bad, others must be worse. We can prove some thingB 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, k-gher chlorination compounds will be wor-e .. _o-`.:er chlorine compounds. Therefore vie will have to restrict uses and clean-up as much as._we._can,. starting immediately. 11 - **' u*c. 7 TRAN 023807 HARTOLDMON0025206 -2- Therefpre 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 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 , Qulf 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 DOT Aroclor 1254 will be found 1 Aroclor 1242 will be found? Air Pollution - Possible spread - but less of an issue right now. -' ' ' ' Vo Analytical work more difficult. ,! , // . ; _- Direct Contact with Product ^ Doesn't seem to be an issue - except for food heat transfer.-4 We don't believe Aroclor is being used as carrier for insecticide - sprayed around - / {^ V,/ ,.y' ' j: We are not positive but most uses are "closed" systems'- or products used in solid plastics, or adhesives, or ; sealants. ' / ., TRAN 023808 HARTOLDMON0025207 F. Fluids ' Product . Hydraulic Fluids ' Air Compressor Fluids Heat Transfer . Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutlo: Customers Plant Operation by Customers Procv 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 ca.re 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. It . 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 1254 and Aroclor 1260, TRAN 023809 HART OLDMON0025208 -4- We will have to take action before that time. Gulf Coast - . Action W. 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 5^2 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- .. /heeler/ Richard Be close enough to Great Lakes Btudies 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 124T 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 TRAN 023810 Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. Fallon/ Rou 3h Need to replace FR especially in food or eens.ltJ vc pTonMct eroae 'v)ir vho product is f>ttins into water. Sec disk washer oompounos. See letter E. Wheeler to r. Fallon. We have possible rep cement products t:. Therm;r 55. Therm!... . to. HART OLDMON0025209 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- Flulds' 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# of procjuction could be Pnrr mg noogeB ^ lbs/year. This is a big pl0oSlSlutrioornthwee are troyfing 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 Eng.,TSDPlant Pol lution Con trol Kodges/ 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 is 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 replacement of future Aroclcr business with other products. Have 2 years. Action Monsanto must help plant clean up of cur-touer pl.a.ts u-cantatlon, coalescing, adsorption, clspcsc.l of adncrbei.t cr recycle of . ' Monsanto badly needs "know-how" for clean-up. Monsanto should seek C-ovt. contract money for clean-up research, (See MRC ft. Binning, D. Nelson) TRAN 023811 HARTOLDMON0025210 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 ar.c no exposure for 25 yrs. Should try to retain business by clear.-uo; by education of cus tomers. 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 at Krummrlch 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 Mor.r.nnto .0 nan-vp methods to customer plant 4* ovii 1 /. w m.* tyUrO H i' cS _ TRAN 023812 HARTOLDMONOQ25211 -7- Actlon - Engrg. & r Mfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling Incinerators for disposing of Arocior and pentachlorophenol wastes. I estimate Aroolor disposal at 1-4FT lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. . Hydraulics 20# of 45T lbs Heat Transfer 10# of 25T lbs Capacitors ' 5^ of 20fT Transformers 5# of 155T 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 Arocior dis-x ( , w-'- posal - preferably one which will handle , solids such as muds - slurries as well as /.l -- L liquids. Have in operation within 12 months, ft' ' 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 Arocior 1242, Arocior 1254 and Arocior 1260, Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Arocior 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 Arocior levels of toxicity, then we will have to have biological studies on these species to con firm or deny adverse findings. TRAN 023813 HARTOLDMON0025212 -8- Biodegradation Studies P Set up rate of biodegradation studies with Inorganic Dlv. on Aroclor 1242 vs. Aroclor 125^ ' Aroclor 5^2 vs. Aroqlor ^>k6o 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:ras W. R. Richard TRAN 023814 HARTOLDMONOQ25213