Document Loa0rZQVXyDDnngdn9239vGoQ

1 1 SUPREME COURT STATE OF NEW YORK 2 COUNTY OF ST. LAWRENCE 3 INDEX NO. 96061/95 4 IAS NO.' 44-1-95-0516 5 6 REYNOLDS METALS COMPANY, 7 Plaintiffs, 8 -against- 9 AETNA CASUALTY & SURETY 10 COMPANY, et al., ) 11 Defendants. 12 X 13 if! 111 IM 1 14 PROTECTED MATERIAL - 15 REYNOLDS INSURANCE COMPANY LITIGATION 16 17 Videotaped Deposition of 18 WILLIAM PAPAGEORGE 19 Wednesday, July 16, 1997 20 9:30 A.M. 21 Reported by: 22 Tara Schwake, CSR, RPR 23 24 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063848 2 1 VIDEOTAPED DEPOSITION of WILLIAM PAPAGEORGE, the 2 witness, taken on behalf of the Defendant Travelers 3 Indemnity Company, on Wednesday, July 16, 1997, at 4 9:30 a.m., at Husch & Eppenberger, 100 North 5 Broadway, Suite 1300, St. Louis, Missouri, 63102, 6 before TARA SCHWAKE, Court Reporter and Notary 7 Public within and for the State of Illinois. 8 9 APPEARANCES: 10 ANDERSON, KILL & OLICK, P.C. 11 BY: FINLEY T. HARCKHAM, ESQ. 12 1251 Avenue of the Americas 13 New York, New York 10020-1182 14 (212) 278-1543 15 Attorneys for Plaintiff 16 17 WILEY, REIN & FIELDING 18 BY: DALE E. HAUSMAN, ESQ. 19 1776 K Street, N.W. 20 Washington, D.C. 20006 21 (202) 429-7005 22 Attorneys for Defendant 23 The Travelers Indemnity Company 24 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063849 3 1 APPEARANCES (Continued) 2 3 MINTZ, LEVIN, COHN, FERRIS, GLOVSKY 4 AND POPEO, P.C. 5 BY: NANCY M. REIMER, ESQ. 6 One Financial Center 7 Boston, Massachusetts 02111 8 (617) 542-6000 9 Attorneys for Defendant 10 Liberty Mutual Insurance Company 11 12 HUSCH & EPPENBERGER 13 BY: CAROL RUTTER, ESQ. 14 100 North Broadway, Suite 1300 15 St. Louis, Missouri 63102 16 (314) 421-4800 17 Attorneys for the Witness 18 19 20 21 22 23 24 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063850 4 1 INDEX 2 WITNESS EXAMINATION BY PAGE 3 Wm. Papageorge Mr. Hausman 8 4 Ms. Reimer 160 5 Mr. Harckham 177 6 Mr. Hausman 209 7 EXHIBITS 8 DEFENDANTS' DESCRIPTION FOR IDENT. 91 Excerpt from larger document by 10 Don D. Irish 57 11 2 General Information Concerning 12 the Handling of Aroclor 13 1254 by W.E. Alexander 14 dated 12/1/41 64 15 3 12/14/49 Document to Mr. N.G.H. 16 Thomas from W.H. Ritchie 68 17 4 12/11/51 Document to Mr. P.J.C. 18 Haywood from E. Mather 71 19 5 12/17/51 Document to Mr. P.J.C. 20 Haywood from E. Mather 75 21 6 2/12/54 Document to Dr. H.R. Newman 22 from R. Emmet Kelly, M.D. 78 23 7 Excerpt from The Chemistry of 24 Industrial Toxicology 81 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063851 18 2 39 4 5 6 10 7 11 8 12 9 13 10 11 14 12 13 15 14 16 15 16 17 17 18 18 19 20 21 19 22 23 20 24 25 5 Dangerous Properties of Industrial Materials by N. Irving Sax 82 Incomplete document dated 1/30/59 on Monsanto Chemical Company letterhead 84 Physical Properties of the Aroclors 88 Brochure of Aroclor 1248 91 Therminol FR, Safety of Handling 93 Therminol FR-O, Toxicity and Safe Handling Information, 8/17/66 96 Toxicity and Safe Handling, Therminol FR-1, 7/18/69 100 Document by W.B. Brown dated 26.11.54 102 A Guide to Accumulation and Shipment of Waste Askarel Fluids 108 Presentation to Field Sales, Personal and Confidential 110 6/17/70 Document, Head: How To Keep Your Therminol FR System Leak- Free 118 7/13/70 Document to W.G. Canham from W.B. Papageorge 120 7/13/70 Document to B.W. Corlew from W.B. Papageorge 122 CARDINAL REPORTING COMPANY (212) 227- 9490 WATER PCB-SD0000063852 1 21 2 3 22 4 5 23 6 7 24 8 25 9 10 11 26 12 27 13 14 28 15 16 29 17 18 30 19 31 20 21 32 22 33 23 34 24 35 25 6 8/17/70 Document to G.L. Jessee from W.B. Papageorge 124 1/8/71 Document to P.J.A. Marsh, et al., from W.B. Papageorge 126 9/1/71 Document Headed Therminol FR Fluids from T.L. G****** 128 12/8/71 Therminol Conversion Bulletin 130 Monsanto's PCB Program, Document created by W.B. Papageorge for Meeting 9/14/71 131 Discontinuation of Therminol FR Sales 132 Document Headed Sales Meeting, Tuesday, April 27, 1971 135 8/16/72 Letter from W.B. Papageorge to B.P. Collins 139 April, 1972, Document from W.B. Papageorge 141 8/7/78 Document from D. Wood 143 8/31/70 Letter to Bruce Hulcher from W.B. Papageorge 145 Sales Summaries 146 New York, PCB Content 1968 - 1969 152 Exhibit L (Revised) 153 Item 5 - Attachment B, PCB Returns 154 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063853 1 36 2 3 4 37 5 6 7 38 8 9 39 10 11 40 12 13 41 14 15 16 42 17 18 43 19 20 21 22 23 24 25 7 Bulletin, An Indirect Aroclor Heater for Unit Chemical Operations Technical Bulletin: Aroclor Resins and Plasticizers for Chlorinated Rubber Brochure: Care and Grooming of Askarel Transformer Fluid Data Sheet for Toxicological and Safe Handling Information Data Sheet for Toxicological and Safe Handling Information Monsanto Askarel Inspection and Maintenance Guide, Revised September 1963 2/9/70 Document from Donald Olson to Dear Sir 4/13/70 Memorandum from W.B. Papageorge Re: Aroclor Labeling 177 180 183 186 188 189 193 197 CARDINAL REPORTING COMPANY (212) 227 -9490 WATER PCB-SD0000063854 William Papageorge Protected Material 8 1 WILLIAM PAPAGEORGE, 2 residing at 321 Pebble Valley Drive, St. 3 Louis, Missouri, 63141, having first been 4 duly sworn, was examined and testified as 5 follows; 6 EXAMINATION BY 7 MR. HAUSMANi 8 Q Could you state your name for the 9 record, please? 10 A William B. Papageorge. 11 Q Current address? 12 A 321 Pebble Valley Drive, St. Louis, 13 Missouri, 63141-8039. 14 Q Okay. Are you currently employed? 15 A Self employed. 16 Q In what capacity? 17 A Technical consultant. 18 Q Again, my name is Dale Hausman, I 19 represent the Travelers Indemnity Company, that's an 20 insurance company, in litigation against Reynolds 21 Metals. Just a few guidelines for this deposition 22 First of all, because we're making 23 both the paper and oral record, if you could wait 24 for me to finish all of my questions before you 25 answer, I'd appreciate that. That way we're not CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063855 William Papageorge Protected Material 9 1 talking over each other at the same time. 2 A I'll try. 3 Q Okay. And also if you could give 4 audible responses to all the questions, say yes or 5 no rather than a nod or a gesture or something 6 similar. 7 Any questions that you can't 8 understand, that you don't understand or can't hear, 9 please feel free to ask me to rephrase them. We can 10 also have them read back from the, from the record. 11 Also - 12 A You used the word "understanding." 13 Sometimes I have an understanding that may not match 14 your understanding or your intent. 15 Q ! Right. 16 A So my answer may not quite fit the 17 question. 18 Q Feel free to ask for any 19 clarification, because we do want to make sure that 20 you do understand the question that you're answering 21 so we have a truthful testimony on the record. 22 A Very good. 23 Q And finally, if there are any breaks 24 that you need for any reason, just let me know and 25 I'll be happy to accommodate that. Okay? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063856 William Papageorge Protected Material 10 1 A Thank you. 2 Q What did you do to prepare for this 3 deposition? 4 A I had discussions with my attorney. 5 Q And that's Ms. Rutter? 6 A Yes. 7 Q Okay. Did you review any documents in 8 preparation for this deposition? 9 A Yes. 10 Q Did you review documents that referred 11 to the Reynolds Metals Company? 12 A Yes . 13 Q All right. When did you meet with 14 your counsel? 15 A Yesterday afternoon. 16 Q Okay. How long was this meeting? 17 A From noon until about 4 or 5 o'clock. 18 as I remember. Most of the afternoon, all of the 19 afternoon, really. 20 Q Okay. Have you spoken with any l 21 lawyers representing the Reynolds Metals Company? 22 A No . 23 Q Have you recently spoken with any 24 employees of the Reynolds Metals Company? 25 A I have not. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063857 William Papageorge Protected Material 11 1 Q Have you given prior deposition 2 testimony before? 3 A Yes. 4 Q Approximately how many occasions? 5 A I have never kept score. It's over a 6 couple dozen times. 7 Q Did that include any insurance 8 coverage litigations, to your knowledge? 9 A Yes . 10 Q And of the dozens or so of depositions 11 that you' ve given, about how many of those were 12 insurance coverage actions, if you know? 13 A I don't recall the exact number, but 14 it's less than half a dozen. 15 Q And of those less than half a dozen 16 insurance coverage actions in which you've given 17 testimony , did those involve user!3 of Monsanto 18 fluids? 19 A Some of them, yes. 20 Q Do you remember the names of any of 21 those actions? 22 A No, I don't. 23 Q All right. To your recollection, did 24 any of the cases in which you've given testimony, 25 any of the insurance coverage cases involve the use CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063858 William Papageorge Protected Material 12 1 of Monsanto heat transfer fluids? 2 A I don't recall the heat transfer fluid 3 associated with an insurance situation. 4 Q In any of these insurance cases in 5 which you've given testimony, have any of those 6 cases involved hydraulic fluids supplied by 7 Monsanto, to your recollection? 8 A I don't recall. 9 Q Same question for fluids to be used in 10 transformers and capacitors, any recollection of 11 that? 12 A I don't recall anything specific. 13 Q Okay. Have you given trial testimony 14 before? 15 A Yes . 16 Q Okay. And have any of the occasions 17 in which you've given trial testimony been insurance 18 coverage actions? 19 A I don't recall any associated with 20 insurance coverage. 21 Q Okay. On how many occasions have you 22 given trial testimony? 23 A Between, less than half, less than a 24 dozen. Half a dozen to a dozen, somewhere in there. 25 Q Do you recall the nature of the cases CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063859 William Papageorge Protected Material 13 1 in which you've given trial testimony? 2 A I think I can recall some of them. 3 Q Could you tell me that, please? 4 A There was a situation in which the 5 allegation was made that PCBs caused harm to mink in 6 mink ranches up in the northeast. 7 There was a situation in which the 8 dairy farmer claimed that the PCBs affected his 9 cattle herd and the health of his family. 10 There was a case in which the user of 11 a PCB fluid was informed by the regulatory agencies 12 to clean up, and his contention was that Monsanto 13 should participate in the expenses involved. 14 There was another case, let me see. 15 There were three cases that I recall where workers 16 claimed that their health was affected because they 17 were involved with PCB materials. That's all that 18 comes to mind at the moment. I'm sure I missed 19 something there, but -- 20 Q That's okay. The case you just 21 described where the user of the PCB fluid was 22 informed by the regulator to clean up, do you know 23 who that user was, do you recall? 24 A Yes. 25 Q What was that company? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063860 William Papageorge Protected Material 14 1 A Stroh? Gosh, I forgot the official, ` 2 it's a metal casting process under the name of the 3 Stroh, just like the brewery family up in Milwaukee, 4 Wisconsin. 5 Q Did that case involve heat transfer 6 fluids? 7 A No. 8 Q What type of fluids? 9 A Hydraulic fluids. 10 Q All right. I'd like to sort of get a 11 brief review of your both educational and 12 professional background, so if you could first start 13 by just briefly describing degrees that you received 14 in college or post-graduate? 15 A I received a Bachelor of Science in 16 chemical engineering and the Master of Science in 17 chemical engineering. 18 Q And where were those from? 19 A Washington University in St. Louis. 20 Q Both of them? Both of them? 21 A Yes. 22 Q Okay. And what years did you receive 23 those degrees? 24 A The Bachelor's Degree was awarded in 25 1943; the Master's Degree in 1947. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063861 William Papageorge Protected Material 15 1 Q Any other formal education beyond 2 that? 3 A Help me with the word "formal." Is 4 this courses for credit towards some degree? 5 Q Yes. Yes. 6 A No. 7 Q Okay. Have you taken courses not 8 designed for a degree, i.e. professional oriented 9 courses ? 10 A Yes. 11 Q Okay. Is that something thatyou've 12 done over the course of your career? 13 A Correct. 14 Q All right. When did you first, when 15 were you first employed by Monsanto? 16 A November of 1951. 17 Q Can you tell me brieflywhat you did 18 between 1947 when you received your Master's and 19 November of '51 when you started with Monsanto? 20 A 1947? 21 Q '47. 22 A I worked for the Phillips Petroleum 23 Company in Bartlesville, Oklahoma. 24 Q What was the nature of your job there? 25 A For half of that period I worked in CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063862 William Papageorge Protected Material 16 1 the Research Department working with oil wells, 2 drilling fluids and, predominantly in what was 3 called secondary recovery. This is the use of water 4 or air pressure to push the residual oil out of 5 wells that appear to be spent. 6 The latter half of that period I was 7 in their Refinery Design Department doing 8 calculations to help design equipment for refining 9 petroleum. 10 Q Did you have any worker safety 11 responsibilities in that position? 12 A No. Other than the equipment that we 13 eventually end up proposing had to consider the, 14 what I'm going to call the normal safety 15 considerations. 16 Q And in that position did you have any 17 pollution prevention responsibilities? 18 A Well, we practiced the preventions 19 that was common at that point in time. We did not 20 design equipment that would deliberately release 21 materials to the environment. 22 Q So did that work include preventing 23 spills of petroleum products onto the ground or into 24 the water? 25 A The intent was to prevent, yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063863 William Papageorge Protected Material 17 1 Q Okay. In November of 1951 when you 2 began with Monsanto, what was your first position 3 there? 4 A The first position was similar to the 5 one I had just left at Phillips, designing equipment 6 to be used in the manufacture of chemicals, and the 7 initial assignment, of course, just picked up the 8 experience I had in distillation equipment. 9 Q Did that job have a title? 10 A Yes, as I remember, it's Process 11 Engineer, I've forgot if the word "Senior" was 12 attached to that. For sure Process Engineer. 13 Q And where did you do that work? Was 14 that St. Louis? 15 A In St. Louis, yes. 16 Q How long were you a Process Engineer? 17 A Oh, about three years. 18 Q As a Process Engineer did you design 19 equipment for the manufacture of heat transfer 20 medium fluids? 21 A No. 22 Q How about hydraulicfluids? 23 A No. 24 Q How about transformer or capacitor 25 fluids? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063864 William Papageorge Protected Material 18 1 A No. 2 Q Did you design any equipment at that 3 time for the manufacture of any fluids that 4 contained PCBs? 5 A No. 6 Q What were the nature of the chemicals 7 for which you designed machinery at that time? 8 A It was phthalic anhydride, 9 p-h-t-h-a-l-i-c a-n-h-y-d-r-i-d-e, which is a 10 material that is further processed to make what is 11 known as a family of plasticizers. These are 12 materials that are added to plastics to make them 13 pliable, flexible instead of brittle. 14 Q So is it correct that you were a 15 Process Engineer until 1954? 16 A Roughly so, yes, sir. 17 Q What did you do then? 18 A I was assigned to work in an 19 operation, a department as we call them at the 20 plant, which made these plasticizers I just referred 21 to, under the guidance of a Senior Supervisor. It 22 was a sort of a training, learning exposure. 23 Q And what was the nature of the 24 activities that you were trained in at that point? 25 A Well, it was the supervising of the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063865 William Papageorge Protected Material 19 1 foremen who in turn supervised the workers, making 2 sure that the scheduled production was being met, 3 that the quality of the material met the 4 specifications , that all the necessary coaching and 5 training of the workers took place, safety meetings 6 and the like. 7 Q And your role was what, your role was 8 the training function, overseeing the training 9 function? 10 A That's just part of it. 11 Q Okay. And how long did you do that? 12 A About a year. 13 Q Okay. What did you do after that? 14 A I was given my own producing unit 15 instead of being a trainee. 16 Q And that was for plasticizers still? 17 A No, this was a, a production unit that 18 made chemicals that are eventually used in, as 19 rubber additives, or in the manufacture of rubber 20 additives. 21 Q 22 PCBs ? Did any of those chemicals contain 23 A No. 24 Q 25 unit? i And your role was oversight of that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063866 William Papageorge Protected Material 20 1 A Yeah, I'll use the word, I was boss o'f 2 the unit. 3 Q Where was that, is that still in St. 4 Louis? 5 A The same plant, still in St. Louis. 6 Q Okay. How long did you do that? 7 A Couple years, as best I recall. 8 Q Do you know where that takes us? Does 9 that get us up to 1960? 10 A I think we're about '57 or 11 thereabouts 12 Q Okay. And what did you do then? 13 A I was transferred then to the plant's, 14 excuse me, Maintenance Department, Engineering and 15 Maintenance Department as a Maintenance Supervisor. 16 Q 17 correct? And that's still in St. Louis, 18 A Yes, same plant. 19 Q How long did you do that? 20 A Couple years. 21 Q Did that plant at that time, from 1957 22 for the next couple years, did that plant make any 23 PCB containing fluids? 24 A Yes. The plant blended ingredients 25 that resulted in the PCB containing material. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063867 William Papageorge Protected Material 21 1 Q When you say "that resulted in PCB 2 containing material," what types of materials would 3 that be? 4 A Primarily the hydraulic fluid 5 products. 6 Q As a Maintenance Supervisor, did you 7 have responsibility for preventing releases of these 8 hydraulic fluids onto the ground or into the 9 waterways ? 10 A No. 11 Q Was there somebody at that time that 12 had that responsibility? 13 A Oh, yes. Many people did. 14 Q Okay. Was there a, a department or a 15 title of a person who had that type of 16 responsibility to prevent these releases? 17 A Not at that time. 18 Q When you say "many people," who do you 19 refer to? 20 A Every person at the plant who had some 21 supervisory responsibilities, from the Chief 22 Operator to the Foreman to the Assistant Supervisor 23 to the Supervisor, the Superintendent, all the way 24 to the Plant Manager where the buck stops has that 25 as part of their responsibility, and the theme at CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063868 William Papageorge Protected Material 22 1 the time was respect all materials you handle. All 2 of them. Because even the water can be scalding 3 hot. 4 Q At the time, in the late '50s, was 5 there a general awareness in Monsanto that releasing 6 hydraulic fluids into waterways or onto the soil 7 could result in damage to the water or soil? 8 MR. HARCKHAM: Objection, lack of 9 foundation. 10 Q (By Mr. Hausman) Can you answer that? 11 A Well, the thought wasn't limited just 12 to hydraulic fluids. Any material that was handled 13 in the plant should not get into the waterways. 14 Q All right. 15 A That was the objective. 16 Q Is this objective something that you 17 were told in your role? 18 A Well, yes. It was like breathing. 19 Q All right. 20 A It was, it was part of the discussion, 21 part of the orientation, part of the safety 22 meetings, it was covered all over and over again. 23 Q Okay. Is it fair to say that that 24 objective of not releasing any of these materials 25 onto the ground or waterways was known by all CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063869 William Papageorge Protected Material 23 1 employees throughout the plant? 2 MR. HARCKHAM: Objection, lack of 3 foundation. 4 A I cannot speak for all employees, 5 because some of them were in clerical positions and 6 not near chemicals, so those employees that were 7 involved with these materials were certainly 8 coached, tutored, trained, constantly reminded. 9 Q (By Mr. Hausman) All right. And as 10 far as worker safety issues, were there precautions, i 11 we're talking in the late 1950s, for being exposed 12 to hydraulic fluids? 13 A Nothing other than the usual 14 precautions of don't get it on your skin, wash your 15 hands at the first chance you get. Don't breathe 16 fumes, if they're bad, don't go into the area; if 17 you have to, use a respirator. If your shoes are 18 soaked in the material, get a new pair of shoes. 19 Don't keep wearing them. That type of message was 20 always preached, if you will. 21 Q And those were common procedures at 22 the time? 23 A For almost all the companies. 24 Q In your role as Maintenance 25 Supervisor, did you have any responsibilities for CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063870 William Papageorge Protected Material 24 1 providing information to customers? 2 A No. 3 Q All right. Was there somebody in the 4 plant at the time who had that responsibility? 5 A In the plant there were people who, on 6 occasion, would be asked by the marketing 7 representatives to participate in discussions with 8 customers. This was looked upon as a resource to 9 the, to the Monsanto representative out in the 10 marketing field, that if a question came up that he 11 didn't feel he knew enough about to respond 12 properly, he could call some individuals at the 13 plant and get the assistance. 14 Q All right. Again, if you know the 15 answer to this, do you know whether, again, the time 16 period of 1957, late '50s, Monsanto issued any 17 warnings for the dangers or hazards of any of its 18 substances to its customers? 19 A Certainly, where it was appropriate, 20 yes . 21 Q Do you know when a, specific warnings 22 of hazards were issued with regard to hydraulic 23 fluids at that time? 24 A I recall some paragraphs in the 25 brochures that were available that would describe CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063871 William Papageorge Protected Material 25 1 the product and its uses, and am also aware that the 2 product label had a message regarding exposure to 3 the material. 4 Q Were these brochures and labels 5 something you saw at the time that you were in this 6 position as Maintenance Supervisor? 7 A I'm sorry? 8 Q Letme repeat that. Were these 9 brochures and labels something that you saw in your 10 position as Maintenance Supervisor? 11 A Yes. Oh, in fact I consulted them 12 from my own work force, if they run across this 13 material, they had to know this. 14 Q Do you have any awareness in this 15 period of the late '50s of whether Monsanto sold any 16 of these hydraulic fluids that were made at the 17 plant to the Reynolds Metals Company? 18 A I just don't recall the dates. Late 19 '50s, I don't remember that. 20 Q Okay. After you were the Maintenance 21 Supervisor, what was your next position? 22 A I was made the Superintendent of the 23 Maintenance Department. 24 Q And how long did you do that? 25 A About, until about 1960? Two or three CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063872 William Papageorge Protected Material 26 1 years. 2 Q And did you have any responsibilities 3 for customer relations in that job? 4 A No. 5 Q Did you have any responsibility for 6 the formulation of worker safety precautions and the 7 handling of various materials? 8 A I was a participant whenever a program 9 would be developed or when an existing program would 10 be reviewed and revised if necessary. Yes, I would 11 participate. 12 Q What would be the nature of your 13 participation? 14 A Well, it was sort of offering my 15 personal impressions regarding the proposed approach 16 to teaching the work force on how to control leakage 17 and how to control exposure, and I would, being a 18 member of the Maintenance Department, would take the 19 position of the mechanic who breaks into a pipeline 20 and that this material spills out all over his 21 coveralls, that kind of, so I kind of try to fulfill 22 that role, when the program would be developed under 23 what do you do under these conditions. 24 Q All right. Did the plant itself use 25 Monsanto's own hydraulic fluids in its machinery? CARDINAL REPORTING COMPANY (212) 227-9490 l{ WATER PCB-SD0000063873 William Papageorge Protected Material 27 1 A Oh, yes. 2 Q And were there procedures to prevent 3 the leakage of this machinery? 4 A Oh, yes. 5 Q Were there written procedures? 6 A Ijm sorry? 7 Q Were there written procedures? 1 8 A Some of the equipment had written 9 procedures, but most of the principles of 10 controlling leakage and loss were common to most 11 liquid handling systems under pressure, under heat, 12 and there are some practices that evolved through 13 time on how to drain a system before you disconnect 14 and what to do with the drained material, and it 15 depends on whether you can reuse it or it must be 16 discarded, how to clean up a spill on a concrete 17 floor, that type of subject would be -- 18 Q Were there specific procedures on how 19 to dispose of hydraulic fluids? 20 A Were there? 21 Q Yes . 22 A When you say "specific," are you 23 referring specific to the fluid or specific 24 procedure on where to go in the plant? 25 Q Fair enough, the latter, but let me CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063874 William Papageorge Protected Material 28 1 refine that question. Were there any prohibitions 2 at the time for, against disposing of hydraulic 3 fluid into waterways? 4 A Oh, yes. Yes. 5 Q And that was prohibited, let's be 6 clear? 7 MR. HARCKHAM: Just for clarification, 8 what time period are you asking him about? 9 MR. HAUSMAN: When Mr. Papageorge was 10 supervisor of the Maintenance Department, I think it 11 was still in the late 1950s. 12 A 59, up to 1960 or so, yes. 13 Q (By Mr. Hausman) And what were the 14 reasons for that prohibition? 15 MR. HARCKHAM: Objection, lack of 16 foundation. 17 Q (By Mr. Hausman) If you know. 18 A The plant is located in metropolitan 19 St. Louis area. Its waste waters enter the 20 metropolitan sewage treatment system. Introducing 21 many chemicals into that waste could upset the 22 treatment plant, which uses bacteria to decompose 23 the waste. So one of the reasons for it being a, 24 I'm going to call it a no-no, is you didn't want to 25 upset the treatment plant of the, this area. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063875 William Papageorge Protected Material 29 1 Q Okay. 2 A And then there's the desire not to, 3 not to put large amounts of chemicals into the 4 sewer. Now, the occasional drip that is hosed down 5 and gets into that water, that's extremely hard to 6 control. It's like the oil spot on your garage 7 floor. But even then we would discourage, where 8 possible, this hosing until at least an attempt was 9 made to pick up the fluid that could be picked up, 10 either with rags or sawdust, some means, that you 11 take that solid material and you take it to a proper 12 landfill for disposal. 13 Q When you say "proper landfill," what 14 do you mean? 15 MS. RUTTER: Objection, lack of 16 foundation. 17 Q (By Mr. Hausman) Again, if you know. 18 A Well, the intent, and you got to keep 19 in mind that it's an evolving kind of situation. At 20 that time, the landfill that was selected would be 21 one that was not near any waterway, there was no 22 evidence that there was underground water that's 23 moving through, picking up contaminants and taking 24 them where they would be undesirable. 25 Q As the Maintenance Superintendent, did CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063876 William Papageorge Protected Material 30 1 you have responsibilities for the disposal of 2 fluids? 3 A No. 4 Q Was that somebody in your department 5 or a different department? 6 A Different department. 7 Q What was that department? 8 A What was that department? 9 Q Yeah. 10 A There was a function in the plant 11 which was a sort of a group to assist the 12 Manufacturing Departments with the movement of 13 material, whether it be the raw material going to 14 their operation or the finished product leaving the 15 operation, getting rid of its trash, supplying it 16 with steam and water and electricity, sort of 17 assisting the Operating Department. That is the 18 department that arranged for the trash and waste 19 chemical pickup services. 20 Q Okay. Now, let me ask you this. We 21 spoke earlier of brochures that went to customers 22 and warning labels. In the time period around 1960, 23 as a general practice, would the brochures for 24 products that Monsanto sold include information on 25 proper disposal methods for those fluids? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063877 William Papageorge Protected Material 31 1 MR. HARCKHAM: Objection, lack of 2 foundation. 3 MS. RUTTERS I join. 4 A At that time? 5 Q (By Mr. Hausman) Yes. 6 A I don't recall any example of a 7 proposed disposal method other than for some 8 chemicals there were words to the effect, "Be 9 careful," but they didn't ever reach the point, "You 10 got to take it to ABC Landfill" or anything like 11 that. 12 Q Okay. All right. After you were 13 Superintendent of the Maintenance Department, what 14 did you do? 15 A I was then made a Technical Services 16 Superintendent, which was really the, the group that 17 I had originally served in as a Process Engineer, I 18 was now supervising engineers and technicians who 19 were assigned technical problems to solve, and help 20 the manufacturing people wherever the manufacturing 21 people would perceive a problem of any kind. 22 Q Okay. This was at the St. Louis plant 23 24 A Still, yes. 25 Q Okay. And what were the years that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063878 William Papageorge Protected Material 32 1 you were in that position? 2 A I think that lasted a couple three 3 years, '62 or '63? My memory's not real sharp on 4 these dates, so it's -- 5 Q I understand. 6 A That's decades ago. 7 Q I understand. In thatposition did j 8 you have any customer services responsibilities? 9 A Not as a responsibility, per se, but 10 as a, an assist to a fellow Monsanto salesman, yeah, 11 I would participate. 12 Q What type of assistance ingeneral 13 would you provide to a salesman? 14 A Oh, I can't think of a specific at the 15 moment, but it would fall under the engineering 16 assignment that I had where someone may say, "I'm 17 proposing to put in, say, a pump. What kind of pump 18 do you folks use?" And, well, we'd share that 19 information with them and then we'd tell them, "For 20 us, this works. It may not work for you." Then 21 we'd, we'd participate in that kind of thing. 22 Q All right. Do you recall providing 23 any assistance to customers through the salesperson 24 on construction of heat transfer machinery? 25 A I don't recall any. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063879 1 |Q William Papageorge Protected Material 33 - Do you recall providing any assistance 2 to customers through the salespeople on recommending 3 pumps for hydraulic systems? 4 A My recollection is not that good. I 5 can't remember. 6 Q Okay. What did you do after you were 7 Technical Services Superintendent? 8 A I was then assigned as a General 9 Superintendent of this department I described 10 earlier that assisted the production people with 11 delivery of materials, the utilities, trash hauling. 12 Q And what were the years that you did 13 that? 14 A '62 and 3, somewhere in there. 15 Q Until when? 16 A I'm sorry? 17 Q Until when? 18 A 1962 and 1963 period. 19 Q So you did that for a short amount of 20 time? 21 A Couple of years, yes. 22 Q Did you have any increased 23 responsibility from the Technical Services 24 Superintendent for Customer Services? 25 A Well, since I was involved with the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063880 William Papageorge Protected Material 34 1 shipping function, on occasion, and this didn't 2 happen often, I would get involved with delivery of 3 the product to the customer in the right container 4 or the right vehicle or on time, I would get 5 involved with that kind of thing, but I had a, a 6 good staff to handle the majority of those cases. I 7 would only get involved in their absence or if there 8 was some problem that they couldn't handle. 9 Q Okay. Did you have any involvement in 10 communicating any potential hazards to the customer? 11 A No. 12 Q Okay. After that position as General 13 Superintendent, what did you do? 14 A I was made a General Superintendent of 15 Manufacturing at the Monsanto Plant located in, 16 across the river from St. Louis. 17 Q Is that the Sauget Plant? 18 A The Sauget Plant. 19 Q Okay. And did you have any customer 20 services responsibilities in that position? 21 A Again, on occasion, I would be 22 involved with a, a dialogue with a customer and its 23 representatives regarding one of the products that 24 my particular group was manufacturing. 25 Q Would that dialogue include advice on CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063881 William Papageorge Protected Material 35 1 any potential hazards of the product? 2 A I don't remember specific, but that's 3 a very appropriate subject, yes. 4 Q And what were the nature of the, what 5 was the nature of the products that your group was 6 manufacturing? 7 A There were several, I can't propose to 8 say I remember all of them, but I do remember we 9 made, in our group we made phenol, something known 10 as carbolic acid, we made a sodium phenate, which is 11 the salt of that carbolic acid -- 12 Q Well, let me ask you this. Were any 13 of those products PCB containing fluids? 14 A No . 15 Q 16 position? Okay. How long were you in that 17 A Until 1965. 18 Q And what did you do after that? 19 A I was assigned to the Plant Manager 20 in, at the plant in, Monsanto's plant in Anniston, 21 Alabama. 22 Q And did that plant manufacture any PCB 23 containing fluids? 24 A Yes. 25 - Q Okay. What fluids did they CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063882 William Papageorge Protected Material 36 1 manufacture? 2 A There was a series of PCB mixtures 3 that we at Monsanto referred to as Aroclors, 4 A-r-o-c-l-o-r, followed by a four digit number to 5 designate the type of mixture in that particular 6 batch of material that was made. 7 Q Were those, did, let me start over. 8 Did those mixtures include heat 9 transfer medium fluids? 10 A Some of the Aroclor mixtures were 11 marketed under the heat transfer brand. 12 Q And in your role as Plant Manager, did 13 you have any responsibility for overseeing any 14 research into potential hazards of these Aroclors? 15 A Research into it? 16 Q Yes . 17 A No. 18 Q 19 plant? Was there such a function at that 20 A Not at the plant. 21 Q Was there a function in the Monsanto 22 corporate umbrella? 23 A Yes. 24 Q And where did that take place? 25 A That was Monsanto's Central Medical CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063883 William Papageorge Protected Material 37 1 Department, located in St. Louis. 2 Q Did that Central Medical Department, 3 to your knowledge, create reports on hazards of 4 Aroclors ? 5 A Yes. 6 Q And as a Plant Manager in Anniston, 7 did you have occasion to see such reports? 8 A Oh, yes. 9 Q Did you receive those as a matter of 10 course ? 11 A Yes. 12 Q And as the Plant Manager at Anniston, 13 did you have, again, customer services 14 responsibilities? 15 A On occasion. 16 Q What was the nature ofyour 17 responsibilities there? 18 A It would be varied. As I indicated 19 earlier, sometimes it had to do with the shipment of 20 the finished product. There were times when a 21 customer would want to visit our plant and see how 22 we handled things and what kinds of equipment we 23 used and, in terms of the routine as well as the 24 safety equipment. So we would be more than happy to 25 share what we had with them, and that happened CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063884 William Papageorge Protected Material 38 1 fairly frequently. 2 Q Mm-hmm. Did anybody at the Anniston 3 Plant provide advice on types of machinery that 4 customers could use for the Aroclors? 5 MS. RUTTER ; Objection, overbroad, 6 lack of foundation. 7 MR. HARCKHAM: Same objection. 8 Q (By Mr. Hausman) Do you understand 9 the question or do you need me to rephrase that? 10 A When you say "types of machinery," I'm 11 thinking of pumps and instruments, you mean, to 12 control and all of that? 13 Q Sure. 14 A Well, the plant was not in a position 15 to give good advice regarding that because they 16 didn't know enough about the customer's operation to 17 do that. We, at best we could just say, "Here's 18 what we use under these conditions." 19 Q All right. Did the plant in Anniston 20 provide any advice on ways to operate a heat 21 transfer medium system that used Aroclors? 22 A We would tell them how, how our heat 23 transfer system worked, we'd even point it to them, 24 but that didn't mean his system was anything like 25 ours, what was expected of it and so on. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063885 William Papageorge Protected Material 39 1 Q So beyond showing what Anniston had, ` 2 there wasn't a consulting role on heat transfer 3 medium machinery? 4 A No, we didn't feel we were qualified 5 to do that. 6 Q Now, as a general practice at 7 Anniston, would somebody at the plant advise 8 customers of hazards of Aroclors? 9 MR. HARCKHAM: Are you talking about 10 when he was Plant Manager? 11 Q (By Mr. Hausman) That's right. 12 A I hesitate because I don't know all of 13 the conversations my staff had with customers. 14 Q Okay. 15 A It wouldn't surprise me ifsomebody 16 did come up, they would share with the customer what 17 they knew and what they did. 18 Q Well, on the occasions where you spoke 19 with customers -- let me, let me ask the question 20 first. Were there occasions when you spoke with 21 customers, first of all? 22 A Yes, there were. 23 Q Okay. And on thoseoccasions were 24 there times when you would communicate hazards, 25 potential hazards of Aroclors? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063886 William Papageorge Protected Material 40 1 A Yes. 2 Q And would that be similar to the 3 information that you, that you would learn in the 4 reports that were prepared by the Central Medical 5 Department? 6 MR. HARCKHAM: Objection, vague and 7 ambiguous. 8 MS. RUTTER: I join. 9 A My comments were based on my personal 10 observations, experience at the plant, as well as 11 the reports that Central Medical Department would 12 submit. 13 Q (By Mr. Hausman) Okay. Fair enough. 14 Okay. How long were you the Plant Manager at 15 Anniston? 16 A Until the end of 1969. 17 Q Okay. What did you do after that? 18 A I was appointed as Manager, 19 Environmental Control reporting to the unit in St. 20 Louis that was responsible for the marketing of 21 PCBs . 22 MR. HARCKHAM: Just, off the record 23 for a second, if we're getting to a new subject, if 24 we could just take a minute break or two? 25 MR. HAUSMAN: Okay. Let's go off the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063887 William Papageorge Protected Material 41 1 record. 2 (A brief recess was held at this 3 time.) 4 Q (By Mr. Hausman) Okay, Mr. 5 Papageorge, when you were the Manager of 6 Environmental Control, where did you work out of? 7 A Out of St. Louis. 8 Q So you came back to St. Louis around 9 that time? 10 A Yes, I did. 11 Q 12 location? Was that at a plant or at a corporate 13 A It was at the corporate headquarters 14 of Monsanto. 15 Q Was the Manager of Environmental 16 Control a newly formed position? 17 A Yes . 18 Q Were you the first person to hold that 19 position? 20 A Yes. 21 Q Were you ever told why that position 22 was created? 23 A Yes. 24 Q And what were you told? 25 A There was an issue related to PCBs and CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063888 William Papageorge Protected Material 42 1 their presence in the environment in surprising 2 samples. Unexpected presence. The issue was being 3 addressed by university laboratories, government 4 agencies, some industries, and it became a situation 5 where so much was going on so quickly that the, 6 Monsanto decided they better have somebody to serve 7 as a focal point, if you will, to try to keep up 8 with what was going on not only within Monsanto, but 9 with its customers, with the representatives of the 10 governmental entities, with other producers of PCBs. 11 So my role was to try to keep up to 12 date with all new developments and share that 13 information with anybody what could use it, could 14 contribute. So I saw myself as really someone who 15 left, who tried to have the left hand know what the 16 right was doing, if you will. 17 Q In your role, did you specifically - 18 let me start that over. 19 In your role did you have direct 20 interactions with customers? 21 A Yes. 22 Q Did you meet withcustomers? 23 A Yes. 24 Q All right. Did you have occasion to 25 make visits to customers' facilities? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063889 William Papageorge Protected Material 43 1 A On occasion, yes. 2 Q How often would you do that? 3 A I find it hard to describe the 4 frequency. I recall my first summer on the 5 assignment, I made a concerted tour of the big users 6 of PCBs, which were primarily the electrical 7 equipment manufacturers, and the rest of the time it 8 was really on an invited as need basis, when I would 9 be invited to attend and participate in discussions 10 and plant tours and the like. 11 Q Okay. Was Reynolds Metals Company one 12 of the big users? 13 A They were a, I have a hard time 14 comparing, they were not as big, say, as General 15 Electric, but they were, a respectable amount of 16 material went to their operations. 17 Q Let me ask you this. Were they 18 included on the group of companies that you toured 19 initially? i i 20 A I, no. ' 21 Q They were not. Did you personally 22 ever travel to Massena, New York, to visit the 23 Reynolds Metals facility there? 24 A No. 25 Q At some point did Reyn -- let me start CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063890 William Papageorge Protected Material 44 1 again. 2 At some point did Monsanto make a 3 decision to discontinue the sale of PCB fluids? 4 A Yes. 5 Q Okay. Did you have a role in that 6 decision making? 7 A Yes. 8 Q What was the nature of your role? 9 Were you the one who made the decision, or did you 10 make a recommendation? 11 A I made a recommendation to a Vice 12 President of the company. 13 Q Did you have any reporting role to a 14 Vice President? 15 A Not direct. 16 Q Who did youreport to, ifanybody? 17 A At this point intime that we're 18 talking about? 19 Q Yes. Yes. 20 A At this point in time I reported to 21 the director of the business group that marketed 22 fluids for use in industry, whether they be in 23 electrical equipment or heating equipment or 24 hydraulic systems. 25 Q And did you have a staff as, when you CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063891 William Papageorge Protected Material 45 1 were the Manager of Environmental Control? 2 A No. 3 Q So you worked by yourself? 4 A Yes. 5 Q Did youcoordinate in that position 6 with any sales departments or sales personnel? 7 A Oh, yes. 8 Q Outside of sales was there a customer 9 services function in Monsanto? 10 A At Monsanto we had a group we referred 11 to as Customer Services, they were the people that 12 handled the details of the orders, the invoicing, 13 keeping score on when deliveries should be made and 14 how much and where to and who to send the bills to, 15 they got involved with these kinds of things. 16 Q Was sales a part of the Customer 17 Services function? 18 A No. They, the Customer Services 19 supported the sales. 20 Q And in your role as Manager of 21 Environmental Control, did you also work with the 22 Customer Services Department? 23 A Oh, yeah, occasionally, yes. 24 Q Okay. How long were you the Manager 25 of Environmental Control? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063892 William Papageorge Protected Material 46 1 A I hesitate because my job didn't 2 change, but my title changed. 3 Q Okay. When did your title change? 4 A It was decided, I've got to smile as I 5 think back, that we really couldn't control the 6 environment but we could protect it, so my title was 7 changed to Manager, Environmental Protection, and 8 this happened about 1972, '71, '72? 9 Q Did your responsibilities change at 10 all? 11 A Not at that time. 12 Q Was there a time later when your 13 responsibilities as Manager, Environmental 14 Protection changed? 15 A There was a, in 1973, as best I 16 recall, Monsanto, through its subgroup called the 17 Monsanto Industrial Chemicals Company, appointed 18 individuals with a title of Managers of Product 19 Acceptability. So in '73 I was given that title. I 20 retained my responsibilities relating to PCBs and I 21 was assigned additional products. 22 Q And those were non-PCB products? 23 A Correct. 24 Q All right. And as you were assigned 25 these additional products, were, were you assigned CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063893 William Papageorge Protected Material 47 1 an environmental protection function with regard to 2 those products? 3 A That was one of the considerations. 4 Q Okay. What other considerations? 5 A Well, it had to do with the quality of 6 the material, the packaging, the proper labeling, 7 the proper shipping, the brochures that were issued, 8 the understanding of the field salesmen of this new 9 environmental world that was evolving around them. 10 So that the expression "Product Acceptability" 11 covered all of those and had to be acceptable not 12 only to the customer, but to society, to the 13 government, to Monsanto. Did it meet all of these 14 evolving new considerations. 15 Q Okay. When you retained this 16 additional responsibility as Manager of Product 17 Acceptability, did the products in that category 18 include products that were used to replace the PCB 19 containing fluids that were previously used? 20 A Yes. 21 Q Okay. Then how long were you the 22 Manager of Environmental Protection? 23 A From,Environmental Protection? 24 MR. HARCKHAM: Excuse me, I just don't 25 understand your question. Are you talking about the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063894 William Papageorge Protected Material 48 1 1970 job or the '73 job? 2 Q (By Mr. Hausman) Yeah, let me step 3 back. Did you become in '73 the Manager of Product 4 Acceptability? Let me start over. 5 In 1973 when you assumed this duty as 6 Manager of Product Acceptability, did you retain 7 also your duties as Manager of Environmental 8 Protection? 9 A Yeah. The activities associated with 10 the Environmental Protection assignment as it 11 relates to PCBs were transferred under the Product 12 Acceptability title -- 13 Q Okay. 14 A -- and spread out over all products, 15 not just PCBs. 16 Q Okay. I understand. So in 1973 your 17 title became Manager of Product Acceptability? 18 A Correct. 19 Q That was your sole title? 20 A I'm sorry? 21 Q That was your sole title, correct? 22 A Yes. 23 Q Okay. How long did you do that? 24 A I believe it was 1976. 25 Q Okay. What did you do then? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063895 William Papageorge Protected Material 49 1 A There was a Monsanto reorganization, 2 and the unit I was assigned to was the Monsanto 3 Intermediate Chemicals Company, and I was given the 4 assignment of Director of Environmental Operations 5 for that unit in Monsanto. 6 Q And what were intermediate chemicals? 7 A These are materials that are used by 8 our customers or within Monsanto to further process 9 to make a product that has a, either an obvious end 10 use or can be blended with other materials to make a 11 product that can be used in commerce that is 12 acceptable to somebody. So it's an intermediate 13 step in the evolution of a group of chemicals. 14 Q At the point in time when you became 15 the Director of Environmental Operations for the 16 Intermediate Chemical Company - 17 A At that point, is -- 18 Q At that point in time, did any 19 Monsanto company make PCB containing fluids? 20 A Oh, yes. 21 Q Did the IntermediateChemicalCompany 22 make those fluids? 23 A No. That was over their --oh, the 24 Intermediate Chemicals? 25 Q Yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063896 William Papageorge Protected Material 50 1 A No. That was over in the Industrial 2 Chemicals Group. 3 Q And you had no responsibilities for 4 the Industrial Chemicals at that time? 5 A At that time I entered, in the first 6 six months or so of that assignment, I was still 7 involved with PCBs, but in, let me think a bit. I'm 8 confusing the dates in my mind. Let me back off. 9 In February of 1976, I transferred my 10 PCB responsibilities to another person in Monsanto. 11 Q Who was that? 12 A J.C. Weber. I'm pretty sure it was 13 February, '76. 14 Q Is that with one B or two Bs? 15 A One B. So when I was appointed the 16 Director, Environmental Operations later that year, 17 I did not have the PCB responsibilities any longer. 18 Q Okay. That's really what I was 19 driving at. After February, 1976, did you have any 20 responsibilities at Monsanto for PCB fluids in any 21 sense ? 22 A Yes, I did. I still had some 23 responsibilities. 24 Q Okay. What responsibilities did you 25 retain? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063897 William Papageorge Protected Material 51 v 1 A I'm, of course, being Director, 2 Environmental Operations for this group, the plants 3 assigned to that group had to handle PCBs the way 4 we'd been telling everybody. So I wasn't completely 5 divorced from PCBs. 6 Q Okay. What were, what was the nature 7 of your responsibility with regard to PCBs when you 8 became the Director of Environmental Operations for 9 the Intermediate Chemical Company? 10 A In 1976, it was my responsibility to 11 see that all of the suggestions and regulations and 12 anything that related not only to PCBs but all 13 chemicals were being followed at the plants assigned 14 to this subgroup within Monsanto. 15 Q Okay. 16 A This had to do with more attention to 17 maintenance, incineration of PCBs in liquids, the 18 proper disposal of the solid wastes, the changeout 19 of fluids in the equipment where an alternate 20 material was available. You see, by 1976, a good 2 1 bit of that was in place. It was a way of 22 operating, become fairly routine. 23 Q Okay. Do you know whether after 24 February, 1976, when you came into this role, 25 whether Reynolds Metals Company was one of the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063898 William Papageorge Protected Material 52 1 customers that you had continued involvement with 2 regard to PCBs over? 3 A In '76? 4 Q Yeah. 5 A I was notpersonally involved with 6 Reynolds at that point in time. 7 Q Do you know whether they fell into the 8 jurisdiction, as it were, of the Intermediate 9 Chemical Company, or do you know if that was with 10 the Industrial Chemicals Group? 11 MR. HARCKHAM: Objection, vague, 12 ambiguous. 13 A It wouldhave to beIndustrial 14 Chemicals. 15 Q (By Mr. Hausman) So just to close 16 out, do you recall having any involvement after 17 February, 1976, with Reynolds Metals Company in any 18 way? 19 A That is true. I don't remember any. 20 Q You don't remember any, okay. Okay, 21 and how long were you in this position of Director 22 of Environmental Operations for the Intermediate 23 Chemical Company? 24 A 1983, '82? I retained the title of 25 Director, Environmental Operations, but then was CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063899 William Papageorge Protected Material 53 1 assigned to the Industrial Chemicals Company. There 2 was another reorganization where the Intermediate 3 Chemicals unit was dissolved. 4 Q Okay. And how long did you do this? 5 A Until 1985. 6 Q And at that period from '82 or '83 to 7 '85, do you have any recollection of being involved 8 in any way with the Reynolds Metals Company? 9 A No. 10 Q What did you do in 1985? 11 A Another reorganization took place and 12 I was made, I think the title was Manager of 13 Occupational Health for the Monsanto Company, which 14 was the new designation of a combination of all 15 these other subgroups that we talked about earlier. 16 Q Okay. Did this deal with occupational 17 health for Monsanto employees or for customers? 18 A Monsanto employees. 19 Q And how long did you do that? 20 A Until I retired at the end of 1986. 21 Q And you have been a consultant since 22 then? 23 A Yes. 24 Q Over the course of your employment 25 with Monsanto, were you a member of any trade CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063900 William Papageorge Protected Material 1 associations ? 54 2 A Can you help me with your expression 3 "trade association"? 4 Q Sure. Why don't I give you 5 categories. Were you a member of any organizations 6 that dealt with worker safety? 7 A No. 8 Q Were you a member of any organizations 9 that dealt with environmental matters? 10 A The reason I'm hesitating, I played 11 some role in these kinds of matters, but I didn't 12 picture myself as being a member. I was 13 representing Monsanto, which was the member. 14 Q Did you participate in any seminars of 15 any groups that dealt with environmental matters? 16 A Oh, yes. I wish I could remember them 17 all, but there were -- 18 Q It's a large number? 19 A Yes. Yes. 20 Q Okay. Were you a member of any 21 chemical or chemical engineering societies? 22 A Yes. 23 Q Do you remember the names of those? 24 A I'm a member of the American Chemical 25 Society and the American Institute of Chemical CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063901 William Papageorge Protected Material 55 1 Engineers. 2 Q Okay. Have you ever been a member of 3 I think the American Industrial Hygiene Association? 4 A No. 5 Q Okay. When you were Manager of 6 Environmental Control and later Manager of 7 Environmental Protection and Manager of Product 8 Acceptability, those three positions, did you 9 receive trade publications on environmental issues? 10 MS. RUTTER: Objection to the 11 overbroad and vague form of the question. 12 A Yes, I did. I don't remember all 13 their titles now. 14 Q (By Mr. Hausman) Did you receive a 15 broad range of such publications? 16 A I have no way to measure the range. 17 MR. HARCKHAM: I'm just going to say, 18 I don't understand whether you're asking him whether 19 he received things throughout that period or at any 20 time during that period. 21 Q (By Mr. Hausman) My question was 22 broad enough to include both, I think. 23 A I would receive periodicals, some of 24 which I personally subscribed and some that were, 25 may have just arrived in the mail to me. I just CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063902 William Papageorge Protected Material 56 1 don't remember them all. 2 Q Did you receive similar periodicals 3 when you were the Plant Manager at Anniston, 4 Alabama? 5 MR. HARCKHAM: Objection, vague and 6 ambiguous. 7 MS. RUTTER: I join. 8 A Any environmental periodicals when I 9 was Plant Manager? 10 Q (By Mr. Hausman) Yes. 11 A I don't remember any such thing 12 existing. I never saw anything then. 13 Q Okay. When you became the Manager, i 14 Environment al Control, did you take it upon yourself 15 to read the literature that dealt with health and 16 safety and PCBs ? 17 A That was a very important part of my 18 assignment, yes. 19 Q Okay. Do you recall reading 20 literature from as far back as the '40s and '50s on 21 PCB health and safety matters? 22 A Yes. 23 Q Okay. Let me ask to have marked as 24 Papageorge Exhibit No. la multipage document that 25 appears to be an excerpt of a larger document, CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063903 William Papageorge Protected Material 57 - 1 possibly a book, the first page has a page number o'f 2 1342 on it and Don D. Irish on the top, and it has a 3 Bates number of MONS 076165 through 170. 4 MR. HARCKHAM: Dale, was that all of 5 the document that was produced? 6 MR. HAUSMAN: Yes. 7 (Defendant's Deposition Exhibit 8 Papageorge 1 marked for identification by the court 9 reporter.) 10 Q (By Mr. Hausman) Mr. Papageorge, I 11 don't think you need to read the whole thing, I just 12 have a very few questions, and I'll point to one 13 passage. 14 First of all, do you recall ever 15 seeing a, a book or article by a Don D. Irish that 16 deals with, it appears to deal with cyclic 17 halogenated hydrocarbons? 18 A As I scan the document I see some 19 references to information here that I'm familiar 20 with. I don't at this point in time recall 2 1 specifically the name Irish, Don Irish. That 22 doesn't, I just don't remember that name. 23 Q Okay. So you don't recall seeing 24 either this passage or the book from which it's 25 taken before? That's what you have in front of you. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063904 William Papageorge Protected Material 58 1 A It just doesn't look familiar to me. 2 Q Okay. If you look at the very first 3 page, the last paragraph which begins "Human 4 experience," do you see that paragraph? 5 A I see that. 6 Q Halfway through the paragraph there's 7 a sentence that reads, "Jones and Alden reported on 8 human cases working with chlorinated diphenyls. 9 They observed a typical acneform dermatitis among 10 workers handling this material." Do you see that 11 passage? 12 A I see that, yes. 13 Q Are chlorinated diphenyls the same as 14 chlorinated biphenyls? 15 A Yes. 16 Q Do you recall ever seeing a Jones and 17 Alden report on chlorinated diphenyls? 18 A I do not. 19 Q This condition that's described in 20 this document, the typical acne form dermatitis, are 21 you familiar with that condition being associated 22 with chlorinated diphenyls? 23 A I'm familiar with allegations made 24 that PCBs are associated with this skin condition. 25 Q Okay. Do you recall when you learned CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063905 William Papageorge Protected Material 59 1 of those allegations being made, what period in 2 time? 3 A As best I recall, it happened when I 4 was for sure at the Anniston Plant. For sure. I 5 believe I had heard some reference to this condition 6 because of another product that I was associated 7 with at the Krummrich Plant. 8 Q What was that product? 9 A That was chlorobenzenes. No, no. 10 It's nitrochlorobenzene. Wood treating chemicals. 11 And at that time there was some reference made to 12 the broad family of chlorinated hydrocarbons, and 13 there was a suggestion that the chlorinated 14 hydrocarbons Monsanto manufactured could fall into 15 that broad category. And that's the extent of my 16 memory, really. It was not a new subject, but I did 17 associate it with chlorinated hydrocarbons. 18 Q The Jones and Alden article report 19 that's referred to, if you see, there's a footnote 20 that appears to, it's a reference a date of 1936. 21 Were you aware, when you learned of these 22 allegations of acneform dermatitis, that they were 23 alleged as early as 1936? 24 MR. HARCKHAM: Objection, lack of 25 foundation. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063906 William Papageorge Protected Material 60 1 A I don't remember the exact year, but I 2 do remember being tutored by the Medical Department 3 about chloracne before World War II period. That's 4 as close as I can get date-wise. 5 Q (By Mr. Hausman) Okay. Just to be 6 clear, before the World War II refers to when the 7 allegations were made or when you were tutored? 8 A No, that was, I was tutored in 1970 9 about the past. 10 Q Okay. 11 A And the reference to this chloracne 12 situation was described to me as occurring in the 13 early '40s, late '30s, some, I don't remember the 14 dates, but it was before World War II. At least 15 that's my memory. That was my first exposure to 16 someone dating that information. 17 Q All right. Okay. You used the word 18 "allegations" in describing the acneform dermatitis 19 or chloracne condition. 20 A Yes. 21 Q Are you aware ofwhetherthose 22 allegations have been proven to be true with regard 23 to PCBs? 24 MS. RUTTERs Objection to the form of 25 the question to the extent it asks a non-medical CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063907 William Papageorge Protected Material 61 1 person to form a medical conclusion. 2 MR. HAUSMAN: Fair enough. 3 MS. RUTTER: You can certainly ask him 4 questions based on his personal - 5 MR. HARCKHAM: Same objection. 6 Q (By Mr. Hausman) I don't even want to 7 know your conclusions. Let me reask the question. 8 Are you aware of any studies -- well, 9 let me see how I can ask that. Okay. 10 Let me ask, in your opinion, given 11 your experience, have you seen any studies that in 12 your opinion establish that chloracne is caused by 13 PCB exposure? 14 MR. HARCKHAM: Objection. 15 MS. RUTTER: I object to the overbroad 16 and vague form of the question and also to the 17 extent that it's calling for a medical opinion from 18 a non-medical person. 19 Q (By Mr. Hausman) I don't want you to 20 give a medical opinion, but I do want to know 2 1 whether you've seen anything in which you personally 22 would have formed that opinion. 23 A When you say medical report, are you 24 talking about formal report, or are you just 25 information that is available? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063908 William Papageorge Protected Material 62 1 Q Any information, whether it be a 2 report or studies or anything like that. 3 A Any information? I was, during my 4 tutorial with the Medical Department in early 1970, 5 a reference was made to an incident that occurred at 6 the precursor company, before Monsanto bought that 7 facility, having an experience with chloracne 8 amongst its workers that were making PCBs and it was 9 traced to a poor quality benzene. That is the only 10 information I have regarding chloracne. 11 Q Okay. When you used the word 12 "allegation," do you have an opinion as to whether 13 those allegations are true or false? 14 MR. HARCKHAM: Objection, vague and 15 ambiguous. Lack of foundation. 16 A I have an opinion. 17 Q (By Mr. Hausman) And what is that 18 opinion? 19 A There is an allegation, there was a, a 20 coating system for cable in which they used a 21 mixture of chemicals called Halowax, and I 22 understood, as a result of my tutorial, that the 23 allegations initially included reference to the 24 presence of PCBs as being a cause. I was informed 25 that the information later developed that it was CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063909 William Papageorge Protected Material 63 - 1 the, a different chemical, not PCBs, that was the ' 2 cause of the skin condition. 3 Q And does that lead you to believe that 4 PCBs do not cause chloracne? 5 MS. RUTTER: Objection to the vague 6 and confusing form of the question to a non-medical 7 person. 8 A I have never seen symptoms amongst the 9 workers, I've never read anything to lead me to 10 believe otherwise, so I, I find it difficult to 11 associate chloracne with PCB exposure. 12 Q (By Mr. Hausman) Well, let me ask you 13 this. Have you read any -- let me strike that. 14 Have you read any reports in which the 15 medical community has concluded that PCBs do not 16 cause chloracne? I'm just asking if you've read any 17 reports. 18 A Medical community report, I have never 19 seen any such report. 20 Q Okay. All right. Let me ask you to 2 1 mark as Papageorge Exhibit No. 2 a multipage 22 document with the title General Information 23 Concerning the Handling of Aroclor 1254 by W.E. 24 Alexander, date, December 1, 1941, it has Bates 25 number MONS 060030 through 38. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063910 William Papageorge Protected Material 64 1 (Defendant's Deposition Exhibit 2 Papageorge 2 marked for identification by the court 3 reporter.) 4 Q (By Mr. Hausman) Again, Mr. 5 Papageorge, if you could just briefly scan this 6 document, I'll have a very few questions, and I'll 7 point to, any passages to you that I have questions 8 about. 9 A I have scanned the report. 10 Q Okay. Do you recall ever seeing this 11 report before? 12 A I don't recall it. 13 Q All right. Do you know who W.E. 14 Alexander is or was? 15 A I think I remember Bill Alexander but 16 I have a hard time placing just under what 17 circumstances I met the man. 18 Q Do you recall him being employed by 19 Monsanto? 20 A Yes. As an engineer I think in 21 engineering, but I don't, I'm not certain. 22 Q Is Aroclor 1254 a PCB containing 23 fluid? 24 A Yes. 25 Q Okay. If you'd turn to the fifth page CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063911 William Papageorge Protected Material 65 1 of this document that has the number 2 on the top 2 with the heading Hazards, do you see that? 3 A I see that. 4 Q The first sentence reads, "The fumes 5 from Aroclor 1254 are quite obnoxious and are, when 6 inhaled excessively, dangerous and hazardous." Do 7 you see that? 8 A Yes. 9 Q Are you aware of what condition that 10 this refers to? 11 MR. HARCKHAM: Objection. I don't 12 understand your question. 13 Q (By Mr. Hausman) Do youunderstand 14 the question? 15 A Well, I'm puzzled because it does 16 refer to fumes and 17 Q Okay. 18 A Is that the condition you're - 19 Q Yes. To your knowledge are, to your 20 knowledge of Aroclor 1254, are its fumes quite 21 obnoxious ? 22 MR. HARCKHAM: Objection. 23 Q (By Mr. Hausman) If you know. 24 A Of course that depends on the density 25 of the fumes, and it's subjective in terms of what CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063912 William Papageorge Protected Material 66 1 is obnoxious to me may not be to you. 2 Q All right. Let me ask you this. Are 3 you aware of any hazards associated with the 4 breathing of Aroclor fumes? 5 A Yes . 6 Q And what are those hazards? 7 A The first symptom that would be 8 noticeable if an excess amount of these fumes are 9 inhaled would result in a coughing and chest pain 10 similar to a severe chest cold. I call that an 11 early warning symptom that the individual is 12 overexposed. Now, that varies from person to person 13 also. Some people can withstand it longer than 14 others. 15 Q I believe you used the term "excessive 16 exposure"? 17 A I'm sorry? 18 Q Did you use the term "excessive 19 exposure"? 20 A Yes. 21 Q Can you, is it possible to define what 22 you mean by that? 23 A One way to define it is to use the 24 ACGIH, which is the American Conference of 25 Industrial, or Governmental Industrial Hygienists. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063913 William Papageorge Protected Material 67 1 They have a published, an exposure level from years 2 back as to what is considered an acceptable maximum 3 level in the workplace. 4 Q Do you know when they published that 5 exposure level? 6 A As best I recall, it was in the '50s. 7 Q And when they published it, do you 8 recall what form they published it in? Was it a 9 pamphlet or a book or anything else? 10 A I recall seeing a pamphlet, and I also 11 know that it's listed in the booklet which lists 12 many, many chemicals and the exposure levels that 13 are recommended. 14 Q Are there any other definitions of 15 "excessive exposure" that you would use, or is that 16 the primary definition? 17 MS. RUTTER; I would object to the 18 overbroad and vague form of the question. 19 MR. HARCKHAM; Same objection. 20 Q (By Mr. Hausman) I think you said one 21 way of characterizing excessive exposure is by 22 referring to those levels. Is there any other way 23 of characterizing - 24 A Yes, the other way would be the 25 employee developed this chest pain and discomfort. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063914 William Papageorge Protected Material 68 1 That's a way to say, now, that's excessive for sure, 2 in spite of the numbers in this booklet. 3 Q Do you recall, again, when you first 4 learned of potential hazards from excessive 5 inhalation exposures of Aroclor 1254? 6 MR. HARCKHAM: Objection, vague and 7 ambiguous. 8 A As best I recall it was during the 9 period that I was at the Anniston Plant, that's 10 starting in 1965. 11 Q (By Mr. Hausman) Let me ask to be 12 marked as Exhibit No. 3 a one page document with the 13 date 14/12/49, which I take to mean December 14. It 14 appears to be from a W.H. Ritchie, R-i-t-c-h-i-e, it 15 appears to be to a Mr. N.G.H. Thomas, has a Bates 16 number of MONS 095207. 17 (Defendant's Deposition Exhibit 18 Papageorge 3 marked for identification by the court 19 reporter.) 20 A I have read the document. 21 Q (By Mr. Hausman) Have you ever seen 22 this document before, Mr. Papageorge? 23 A I'm sorry? 24 Q Have you ever seen this document 25 before ? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063915 William Papageorge Protected Material 69 - 1 A I recall it, yes. 2 Q Okay. What are the circumstances 3 under which you recall seeing this document? 4 A I believe as best I recall that this 5 was one of the documents shown to me when I had my 6 tutorial with the Medical Department in January and 7 February or so of 1970. 8 Q Is that when you became the Manager of 9 Environmental Control? 10 A Yes. 11 Q Do you recall any discussions about 12 this document or the matters described therein? 13 MS. RUTTER: Objection to the vague 14 form of the question. With, with whom? 15 Q (By Mr. Hausman) I can ask that 16 question, too. Well, do you recall who showed you 17 this document? 18 A I do. 19 Q Who was that? 20 A Elmer Wheeler,w-h-e-e-l-e-r. 21 Q And what was his position in January 22 of 1970? 23 A At that time he was the Assistant 24 Director of Monsanto's Medical Department. 25 Q Did Mr. Wheeler -- let me start again. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063916 William Papageorge Protected Material 70 1 Do you recall any discussions with Mr. 2 Wheeler about this document? 3 A I, of course, don't recall the 4 specific words used, but the overall impression was 5 that these suggestions on clothing, rubber gloves 6 and ventilation and all were quite appropriate. 7 Q You see the second paragraph, the 8 first sentence reads, "Dr. Newman and myself are of 9 the opinion that the greatest danger lies in the 10 inhalation of vapors at high temperatures," and that 11 appears to refer to Aroclors. Do you recall 12 discussing dangers of inhalation of Aroclor vapors 13 with Mr. Wheeler? With Dr. Wheeler? 14 A Yes, it has to do along the lines with 15 this severe chest pain bit that I mentioned. 16 Q Okay. Do you know who W.H. Ritchie is 17 or was? 18 A I don't, no. 19 Q How about Dr. Newman? 20 A I had heard, I've never met Dr. 21 Newman. He was the Medical Director of Monsanto's 22 European facilities. 23 Q And just referring to the top, to 24 these other names, do you know who N.G.H. Thomas is 25 or was? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063917 William Papageorge Protected Material 71 1 A No, I don't recall., 2 Q How about J.W. Barrett? 3 A Dr. Barrett was a chemist involved 4 with the research in the European operation. 5 Q And do you know who J.A. Gardner was? 6 A I don't remember Mr. Gardner, Dr. 7 Gardner. 8 Q Do you know whether this is a document 9 that was prepared by a Monsanto person or employee? 10 MR. HARCKHAM: Objection, lack of 11 foundation. 12 MR. HAUSMAN: If you know. 13 MS. RUTTER: I join in that objection. 14 A I don't know. 15 Q (By Mr. Hausman) Okay. Let me ask to 16 have marked as Exhibit 4? 17 MR. HARCKHAM: Right. 18 Q (By Mr. Hausman) A two page document 19 with a date December 11/51, it appears to be from 20 E. Mather to P.J.C. Haywood, H-a-y-w-o-o-d, Bates 21 numbers MONS 095205 through 206. 22 (Defendant's Deposition Exhibit 23 Papageorge 4 marked for identification by the court 24 reporter.) 25 (A brief recess was held at this CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063918 William Papageorge Protected Material 72 1 time.) 2 Q (By Mr. Hausman) Okay, Mr. 3 Papageorge, Exhibit 4 is a one page memorandum that 4 attaches either an excerpt or a whole article from a 5 chemist analyst. Do you have a recollection of 6 seeing either the memorandum or its attachment 7 before? 8 A Yes, I have seen this. 9 Q And do you recall what circumstances, 10 under what circumstances you saw it? 11 A It's part of this Medical Department 12 tutorial I mentioned earlier. 13 Q And this was from Mr. Wheeler? 14 A Yes. 15 Q Do you know -- let me start again. 16 Did Mr. Wheeler tell you whether the 17 Medical Department kept any files of documents 18 pertaining to toxicity of Aroclors? 19 A Oh, certainly. 20 Q He told youthat? 21 A It was part of the medicallibrary. 22 Q Did you have occasion to go into the 23 medical library? 24 A I'm sorry? 25 Q Did you have occasion to go into the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063919 William Papageorge Protected Material 73 1 medical library? 2 A Oh, yes. 3 Q When you were Director of 4 Environmental Control or earlier? 5 A Since I was assigned Environmental 6 Control. Prior to that I had to request copies of 7 articles and so on by mail or phone. 8 Q And did you see a file of documents 9 such as Exhibit 4 in the medical library? 10 A Yes . 11 MR. HARCKHAM: Objection. 12 MS. RUTTER: You're talking about as 13 of 1970, Counsel? 14 Q (By Mr. Hausman) Yes, I am. Yes. 15 A Yes . 16 Q 17 entitled? Do you know what that file was 18 A As best as I recall, it was Aroclor 19 Toxicity Studies. That's my recollection. 20 Q And in the 1970 time frame, do you 21 know how big this file was? Was it several inches? 22 A I don't know how to describe, it was 23 several drawers of a metal four- or five-drawer 24 cabinet. 25 Q Do you know how long that file was CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063920 William Papageorge Protected Material 74 1 kept for? What the earliest date of that file was? 2 A No, I don't remember. 3 Q Did you have any responsibility when 4 you were Director of Environmental Control or in 5 your two other similar positions for sending 6 materials to that file? 7 A I would send any material that I felt 8 was relevant and of interest to the Medical 9 Department to either the Director or the Assistant 10 Director, and it was up to them to make a decision 11 what went into the file. 12 Q Who maintained this library in 1970? 13 A Who maintained it? 14 Q Yes . 15 A I don't understand. 16 Q Was that a Medical Department 17 function, or was it, was there a broad librarian? 18 A It's a Medical Department facility 19 manned by a librarian who reported to the Medical 20 Department. 21 Q And when you saw the document that's 22 Exhibit 4 in 1970, do you recall having any 23 discussions with Mr. Wheeler about its content? 24 A Yes . 25 Q Do you recall what those discussions CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063921 William Papageorge Protected Material 75 1 were? ' 2 A It's just shown to me as an example of 3 the kind of experiences that Monsanto had at its 4 plant, and also the interest shown by others in 5 exposure to the Aroclor vapors. 6 Q When you say, "interest shown by 7 others," who are you referring to? 8 A I'm particularly referring to this Mr. 9 Brown, who was with the City of St. Louis Department 10 of Public Welfare, that's an example. There are 11 others. 12 Q All right. Let me ask to have marked 13 as Exhibit No. 5 a one page document dated December 14 17/51 from E. Mather to Mr. P.J.C. Haywood, Bates 15 number MONS 095204. 16 (Defendant's Deposition Exhibit 17 Papageorge 5 marked for identification by the court 18 reporter.) 19 A I have read the memorandum. 20 Q (By Mr. Hausman) Okay. Do you recall 21 ever seeing this document before? 22 A I don't recall the document. I 23 recognize some of the information in there. 24 Q What information do you recognize? 25 A Well, that first paragraph seems to be CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063922 William Papageorge Protected Material 76 1 referring to the incident I mentioned earlier about 2 Swan Chemical Company's experience that occurred in 3 1933 . 4 Q And where did you learn of that 5 incident, if you recall? 6 A It was during this tutorial. I don't 7 know if it came up with a document in front of me or 8 whether it was just passed on to me. 9 Q All right. The second paragraph 10 reads, "A little browsing into the literature 11 reveals quite a history of skin troubles and liver 12 troubles (including some fatal cases) attributed to 13 heavy exposure to chlorinated diphenyls." 14 Did you discuss in this tutorial 15 potential liver damages from PCBs? 16 A Yes. 17 Q Do you recall what those discussions 18 were? 19 A I was told that if exposure to PCBs 20 continued to be excessive, it is very possible that 21 the liver is affected, and if the exposure 22 continues, that liver reaches the point where it 23 cannot heal itself, and that could prove to be 24 fatal. 25 Q Do you recall learning of any studies CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063923 William Papageorge Protected Material 77 1 that were done of the potential liver damage from 2 PCBs ? 3 A I'm not aware of any studies. 4 Q Okay. 5 MS. RUTTER: I'm going to belatedly 6 object, objection to the overbroad vague form of the 7 question. 8 Q (By Mr. Hausman) When you learned of 9 potential liver troubles from PCBs? 10 A Yes . 11 Q Do you recall learning whether those 12 liver troubles were the result of any one type of 13 exposure, be it breathing, skin contact, or 14 ingestion? 15 MR. HARCKHAM: Objection. 16 A No distinction was made during our 17 discussion 18 Q (By Mr. Hausman) Do you recall 19 learning at any later point of any distinction? 20 A No. 21 Q Okay. Let me ask to have marked as' 22 Exhibit 6 a one page document dated February 12, 23 1954, from R. Emmet Kelly, M.D. to Dr. H.R. Newman, 24 Bates number MONS 095193. 25 (Defendant's Deposition Exhibit CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063924 William Papageorge Protected Material 78 1 Papageorge 6 marked for identification by the court 2 reporter.) 3 A I've read the document. 4 Q (By Mr. Hausman) Okay. Do you recall 5 seeing this document before? 6 A Yes. 7 Q Is this one of the documents that you 8 saw during the 1970 tutorial? 9 A Yes. 10 Q Would you tell me who R. Emmet Kelly 11 was ? 12 A He was at that time the Monsanto 13 Corporate Medical Director. 14 Q And when you're saying "at that time," 15 do you mean 1970 or 1954? 16 A 1954, the date of this memorandum. 17 Q The date ofthememo, all right. Was 18 he still at Monsanto in 1970? 19 A Yes. 20 Q And what was hisposition then? What 21 was his position then? 22 A Still Corporate Medical Director. 23 Q Okay, the first paragraph, the first 24 three sentence reads, "We do not know what the 25 maximum allowable concentration of Aroclor is. One CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063925 William Papageorge Protected Material 79 1 milligram per cubic meter has been set up. We have 2 run animals for about 60 days at 7 times this and 3 found some liver damage." 4 Do you recall in 1970 learning of 5 these studies that were done on or about 1954? 6 A Yes. 7 Q Earlier I showed you some documents 8 that discussed potential hazards from breathing 9 Aroclor fumes? 10 A I think I remember which. 11 Q Based on your understanding of that 12 potential hazard, is the concern there liver damage 13 or something else or both? 14 MR. HARCKHAM: Objection, lack of 15 foundation. 16 MS. RUTTER: Object to the overbroad 17 and vague form of the question to a non-medical 18 person, but subject to those objections, Mr. 19 Papageorge, you may respond if you understand the 20 question. 21 Q (By Mr. Hausman) Did you understand 22 the question? 23 A I think I do. You mentioned a liver 24 damage as being the real concern, actually the 25 concern is for symptoms that appear before that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063926 William Papageorge Protected Material 80 1 liver is damaged. The very fact of the individual 2 that breathed too many fumes is experiencing 3 discomfort, can't breathe, he's coughing, you don't 4 want that either. 5 Q Okay. 6 A So, and an individual who has the red 7 skin from getting too much on his skin, we don't 8 want that. And that's a long, a long way to go 9 before you get to the liver damage problem. 10 Q All right. Thank you. 11 Now, based on the documents that we've 12 seen so far, is it fair to say that in 1970 in this 13 tutorial, you learned of three alleged hazards from 14 PCBs, one being skin, either chloracne or problems; 15 two being this coughing that you talked about as far 16 as inhalation goes; and three being liver damage; is 17 that correct? 18 A I knew of those before, when I was 19 down in Anniston. 20 Q Okay. Were there any other hazards 21 besides those three that you either knew of at 22 Anniston or you either learned of in 1970 resulting 23 from PCB exposures? 24 A I can't think of any. 25 Q So those are the three main ones? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063927 William Papageorge Protected Material 81 1 A That's it. 2 Q Let me ask to be marked as Exhibit 7 3 an apparent excerpt of a book that was produced by 4 Monsanto, the title appears to be The Chemistry of 5 Industrial Toxicology, it has Bates numbers of MONS 6 076158 through 161. 7 (Defendant's Deposition Exhibit 8 Papageorge 7 marked for identification by the court 9 reporter.) 10 Q (By Mr. Hausman) And Mr. Papageorge, 11 I don't think you have to read this, very simply I 12 have one question, maybe two questions. Are you 13 familiar with a book entitled The Chemistry of 14 Industrial Toxicology? 15 A This is, can you help me, sir, is this 16 the Sax manual? Dr. Sax? 17 Q That I don't know, because this is how 18 it was produced, and actually, I don't believe it 19 is . 20 A I'm not familiar with a book by the 21 title you just mentioned. 22 Q Okay. 23 A But I am familiar with the Sax 24 reference book on toxicology. 25 Q Okay. Let me show you that. Let me CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063928 William Papageorge Protected Material 82 1 ask that marked as Exhibit No. 8, certain pages from 2 a book entitled Dangerous Properties of Industrial 3 Materials by N. Irving Sax, including the cover page 4 and certain other pages. It does not have a Bates 5 number because it was not produced by Monsanto. 6 It's from a, from a third source. 7 (Defendant's Deposition Exhibit 8 Papageorge 8 marked for identification by the court 9 reporter.) 10 Q (By Mr. Hausman) Mr. Papageorge, does 11 this appear to be an excerpt of the Sax manual that 12 you just mentioned? 13 MR. HARCKHAM: Objection, lack of 14 foundation, and I further object to you using a, 15 bits and pieces of a document like this and asking 16 the witness if it's an excerpt. 17 Q (By Mr. Hausman) Okay. Well, if you 18 look at the first page, then, let's go through it 19 from that. Are you familiar with a book entitled 20 Dangerous Properties of Industrial Materials by N. 21 Irving Sax? 22 A I am. 23 Q And is that the book that you were 24 referring to in your prior testimony? 25 A Yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063929 William Papageorge Protected Material 83 1 Q How are you familiar with that book? 2 A In my involvement with many Monsanto 3 chemicals, I found this to be quite helpful as a 4 reference book. At least as a starting point. 5 Q Do you recall when your earliest 6 reference to the Sax book was? What year? 7 A About, during the tutorial we talked 8 about, 1970. 9 Q So not before 1970? 10 A That's true. 11 Q All right. Do you know whether this 12 book is kept in the Monsanto medical library? 13 MR. HARCKHAM: Are you asking him now, 14 if it's kept there now? 15 Q (By Mr. Hausman) I'll ask in 1970 16 when you first saw it. 17 A 1970, at least one volume was there. 18 There were many around. 19 Q Many around, all through Monsanto? 20 A All the desks, medical personnel, they 21 all had copies. 22 Q Do you have any knowledge of when the 23 earliest time it was that employees of Monsanto had 24 copies of this? 25 A Oh, I don't know that. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063930 William Papageorge Protected Material 84 1 Q Okay. Let me ask to have marked as 2 Exhibit No. 8, No. 9, excuse me, a one page document 3 produced by Reynolds, not by Monsanto, it's on 4 Monsanto Chemical Company letterhead, it is a single 5 page, appears to be an incomplete document dated 6 January 30, 1959. The author, or the recipient is 7 illegible, it appears to be Mr. D.A., the last name 8 is illegible, and it refers to that person as 9 Purchasing Agent, and it has a Bates number of RLD 10 0770380 . 11 (Defendant's Deposition Exhibit 12 Papageorge 9 marked for identification by the court 13 reporter.) 14 Q (By Mr. Hausman) Mr. Papageorge, I'll 15 represent to you that this is the only page of this 16 document that's been produced. The first page, in 17 the first paragraph refers to a shipment of Aroclor 18 1248. Do you see that? 19 A I see that. 20 Q Okay. Now, if you look at the bottom 21 of the page, the very last sentence at least begins, 22 "I am sure that your people will be interested in 23 the attached information covering dermatological and 24 toxicological characteristics of handling," and then 25 it ends. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063931 William Papageorge Protected Material 85 1 I want to be very clear, I want you to 2 be very clear on what I'm asking here, and by that I 3 want to know what your knowledge is, and if your 4 answer is I don't know, then that's a fair answer, 5 okay? 6 On or about January 30, 1959, did 7 Monsanto have a general practice of advising its 8 customers of dermatological and toxicological 9 characteristics of Aroclors? 10 A As a general rule, yes. 11 Q And how do you know that? 12 A Well, a good example is the brochures 13 that were in print at the time. 14 Q Around 1959? 15 A '59, there are sections with various 16 titles, but the reference was to the proper way to 17 handle the material and respect it. 18 Q Okay. 19 A We cannot forget that thelabels on 20 the products referred to don't expose to, don't have 21 prolonged exposure to fumes, don't get it on your 22 skin, these kinds of warnings. 23 Q If you know, again, in this 1959 24 period, did Monsanto as a general practice advise 25 purchasers of Aroclors of potential skin hazards CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063932 William Papageorge Protected Material 86 1 from, from Aroclors? 2 A Can you help me with your expression 3 "skin hazards"? You mean -- 4 Q Sure. We talked earlier about 5 allegations of chloracne from PCBs. Do you know 6 whether Monsanto, in the 1959 time frame, as a 7 practice advised its customers of those allegations? 8 A I don't recall any specifics of that 9 type. The advice was always one of preventing the 10 exposure in the first place. 11 Q If you know, in 1959, did Monsanto 12 provide its customers of Aroclors with any reports 13 or analyses of the toxicology or dermatological 14 effects of Aroclors? 15 MR. HARCKHAM: Objection. 16 A As I understood it, and understand to 17 this day, if a request was made to Monsanto for that 18 kind of information, it would be relayed to 19 Monsanto's Medical Department, and it was a 20 situation where either a medical doctor was talking 21 to a medical doctor or industrial hygienist was 22 talking to industrial hygienist and the appropriate 23 documents would be forwarded if requested. 24 So it was on a case by case basis that 25 that happened. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063933 William Papageorge Protected Material 87 1 Q (By Mr. Hausman) Okay. Could you 2 refer back to Exhibit No. 2? That's the General 3 Information Concerning the Handling of Aroclor 1252? 4 A I have it. 5 Q Okay. Do you have any knowledge 6 of whether this document is the type of document 7 that 8 A I'm sorry? 9 Q Do you have any knowledge of whether 10 this document is the type of document that Monsanto 11 would send on to its customers? 12 MR. HARCKHAM: Objection. Let me just 13 expand on my objection for a minute, please. I 14 think in fairness you ought to point him to the 15 distribution page on this, just, the second page of 16 the document. 17 Q (By Mr. Hausman) Sure. Beyond what 18 the people that are indicated as distributees on the 19 second page, do you have any knowledge of whether 20 Monsanto had a practice of distributing reports like 21 this to its customers at any time? 22 MS. RUTTER: At any time, Counsel? 23 That's your question? 24 MR. HARCKHAM: I still object. 25 Q (By Mr. Hausman) Okay. Let's talk CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063934 William Papageorge Protected Material 88 - 1 about in the time period of 1940 to 1960. Again, 2 I'm asking for your knowledge, that's all I'm asking 3 for. 4 MS. RUTTER: I'll object to the 5 overbroad and vague form of the question, lack of 6 foundation. ' 7 MR. HARCKHAM: Right. That's mine, 8 too, as well. 9 A My understanding, not because I was 10 there at that point in time, but the kinds of 11 information that we are looking at now in this 12 exhibit were very commonly included in other 13 informational pamphlets, brochures and the like. 14 Marketing people were given a supply of those and 15 they would drop them off as they visit their 16 customers or mail it to them when requested. So 17 that information was very freely distributed. 18 Q (By Mr. Hausman) Okay. Thank you. 19 Let me ask to have marked as Exhibit No. 10 a 20 multipage document entitled Physical Properties of 2 1 the Aroclors, appears to be prepared by Monsanto 22 Chemicals of Quality, St. Louis. And it does not 23 appear to have a date on it. 24 (Defendant's Deposition Exhibit 25 Papageorge 10 marked for identification by the court CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063935 William Papageorge Protected Material 89 1 reporter. 2 A I have scanned the document. 3 Q (By Mr. Hausman) Do you recall seeing 4 this document before? 5 A Yes. 6 Q Under what circumstances? 7 A I don't recall the specific 8 circumstances This is -- 9 Q Is this a brochure? 10 A It's an early brochure, yes. 11 Q And when you say "early," can you give 12 an estimate of what time period this was prepared? 13 A Oh, golly, I was looking for the date 14 15 MR. HARCKHAM; I'm just going to 16 object, lack of foundation. 17 A I would suggest the '40s. 18 Q (By Mr. Hausman) Why do you say that? 19 A From the Monsanto logo that existed at 20 that point in time. 21 Q Do you know when that logo was 22 discontinued? 23 A I'm sorry? 24 Q Was that logo discontinued? 25 A It's, it's changed in appearance CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063936 William Papageorge Protected Material 90 1 through the years. 2 Q All right. 3 A And it wentthroughvarious changes. 4 Q And just for the, so the record is 5 clear, you're referring to the oval logo with 6 "Monsanto" in the center of it; is that correct? 7 About two-thirds of the way down the page? 8 A It's the oval as well as the line 9 below that says, "Manufactured by" with "Monsanto" 10 with those bars across "Monsanto Chemical Company." 11 Q Okay. 12 A That was typical in the '30s and '40s. 13 Q Okay. Let me ask to havemarked as 14 Exhibit No. 11 - 15 MR. HARCKHAM: Let me interrupt you 16 for a second. It's 12:35, you want to think about 17 breaking for lunch? 18 MR. HAUSMAN: Yeah, actually once I 19 get past this document, that'll pretty much be a 20 good breaking point. 21 MR. HARCKHAM: All right. 22 Q (By Mr. Hausman) Exhibit 11 is a 23 multipage document with a front page stating 24 Monsanto Aroclor 1248, and it does not appear to 25 have a date on it, and that's Bates numbers from CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063937 William Papageorge Protected Material 91 1 MONS 079962 through 079997. 2 (Defendant's Deposition Exhibit 3 Papageorge 11 marked for identification by the court 4 reporter.) 5 A I have scanned the document. 6 Q (By Mr. Hausman) Thank you. Do you 7 recognize this document, Mr. Papageorge? 8 A Yes. 9 Q And is this also a brochure that 10 Monsanto provided to its customers? 11 A This is a brochure, yes. 12 Q Is this the type of brochurethat as a 13 general practice Monsanto would give to its 14 customers ? 15 MR. HARCKHAM: Objection, lack of 16 foundation. 17 A Oh, I wouldn't call it general. This 18 is pretty specific to this particular product. 19 Q (By Mr. Hausman) Do you know whether 20 Monsanto as a general practice would provide this 21 brochure to its customers of Aroclor 1248? 22 A Yes. 23 Q Again, this document does not appear 24 to have a date on it. Is there anything in the 25 document from which you can make an estimation of CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063938 William Papageorge Protected Material 92 1 the date that this was prepared? 2 MR. HARCKHAM; If you look there's a 3 bibliography, just to speed things up. 4 MR. HAUSMAN: On page 995. 5 MR. HARCKHAMs Right. 6 MR. HAUSMANj Yeah. It's the third 7 from the last page, I believe, there's a 8 bibliography which provides some dates. 9 A I see that, yeah. 10 Q (By Mr. Hausman) From, from that or 11 any other indications, possibly the logo, is there 12 any way of telling from this document what the 13 approximate date was? 14 A Yeah, the middle '50s is what I would 15 say, yes. 16 Q And why do you say that? 17 A Well, first of all, this logo now 18 reflects the '50s. 19 Q That's the logo on the first page? 20 A And then this page 079995 where the 2 1 literature is cited, the first citation there is a 22 Applications Bulletin dated 1954. So this document 23 has to be at least that vintage, 1954 or later. 24 Q Thank you. Why don't we go off the 25 record. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063939 William Papageorge Protected Material 93 1 (A recess was held for lunch at this 2 time. 3 Q (By Mr. Hausman) Okay. Let me ask to 4 have marked as Exhibit No. 12 a one page document, 5 in larger print entitled Therminol FR, Safety of 6 Handling, Bates number MONS 076584. 7 (Defendant's Deposition Exhibit 8 Papageorge 12 marked for identification by the court 9 reporter.) 10 A I have read the document. 11 Q (By Mr. Hausman) Mr. Papageorge, do 12 you recognize this document? 13 A I believe I do. 14 Q Do you recall what circumstances, 15 under what circumstances you've seen this document 16 before? 17 A It appears to me to be a page out of a 18 Monsanto brochure relating to Therminols. 19 Q Okay. Is there a difference between 20 Therminols and Aroclors? 21 A You mean chemically or title-wise? 22 Q Chemically. 23 A Chemically, some of the Aroclors are 24 also called Therminols. 25 Q All right.Are Therminols used for CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063940 William Papageorge Protected Material 1 heat transfer media? 94 - ` 2 A Yes. 3 Q I've seen numbers on Aroclors such as 4 1248 and 1252, is there a name for those numbers? I 5 just want to make sure we're talking about the same 6 thing. 7 A Well, there is no name for the numbers 8 except that the numbers do indicate what type of 9 mixture is in that particular Aroclor product. 10 Q All right. Is it correct that the 11 last two digits of those numbers indicates the 12 percentage of chlorine? Is that correct? 13 A Yes. 14 Q So 1252 would be 52 percent chlorine? 15 A If there were a 52. It's actually 54. 16 Q 54. 17 A That means 54 percent by weight is 18 chlorine. 19 Q Do the Therminols have a specific 20 weight by chlorine? 21 A Well, the particular Aroclor used in 22 that particular Therminol is designated by that four 23 digit number we talked about. 24 Q So the Therminols have different 25 percentage weights? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063941 William Papageorge Protected Material 95 1 A Yes. Just like the Aroclors. 2 Q All right. I guess what I'm trying to 3 understand is, is this. Well, let me ask a 4 question. 5 Did Monsanto sell products called both 6 Aroclors and Therminols? 7 A Yes. 8 Q Okay. Is there a reason for those 9 difference in names between Aroclor and Therminols? 10 A I think there's a reason, yes. The 11 use of the word "Therminol" is used to imply that 12 this particular liquid is used in thermal systems. 13 As distinguished from the word "Aroclor," which is a 14 product that can be used in many, many different 15 ways. 16 Q Okay. Is "Aroclor" a broader term for 17 a broader category of substances? 18 A Oh, yes. It covers many, many 19 different products. 20 Q Okay. Back to Exhibit 12, are there 21 any indications on this document that would enable 22 you to make an estimate of when it was written? 23 A No, there are no indications. 24 Q Okay. Let me ask to have marked as 25 Exhibit 13 a two page document, Monsanto Company CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063942 William Papageorge Protected Material 96 1 indicated at the top, the title is Therminol FR-0, 2 Bates number MONS 064725 through 726 and it has the 3 date indicated on the second page of August 17, 4 1966 . 5 (Defendant's Deposition Exhibit 6 Papageorge 13 marked for identification by the court 7 reporter.) 8 A I have read the document. 9 Q (By Mr. Hausman) Do you recognize 10 this document? 11 A Yes. 12 Q And under what circumstances have you 13 seen this document before? 14 A I don't remember the specifics. This 15 is typical of the kinds of statements that the 16 Medical Department would issue on Monsanto products. 17 Q Do youknow whether this statement as 18 a practice would be distributed to customers? 19 MR. HARCKHAM: Objection. I don't 20 understand, for one thing, I don't know what time 21 period you're talking about. 22 Q (By Mr. Hausman) At any time after 23 its preparation. 24 A Yes. 25 Q And why doyou saythat? ' CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063943 William Papageorge Protected Material 97 1 A That was the intent of preparing it in 2 the first place. 3 Q To distribute to customers? 4 A Yes, for in, Monsanto's personal or in 5 house use and to distribute to any interested 6 parties, whether they be current customers, future 7 customers, or regulatory agents, whoever. 8 Q Okay. Does the fact that it includes 9 a Monsanto Company legend with an address indicate 10 that it's intended for outside distribution? 11 MR. HARCKHAM: Objection, lack of 12 foundation. 13 Q (By Mr. Hausman) If you know. 14 A Not necessarily. It could be internal 15 also. 16 Q If you could look at the last 17 paragraph of the first page, the last two sentences, 18 it reads, "In heat transfer installations, the fluid 19 must be used in a closed system free from leaks with 20 the expansion tank vented to the outdoors. 21 Accordingly, there should be little or no 22 opportunity for workers to come in contact with the 23 vapors." 24 To your knowledge did Monsanto -- let 25 me start this over, let's put this in a time period. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063944 William Papageorge Protected Material 98 1 Before the date of this document, 2 August 17, 1966, do you know whether Monsanto had a 3 practice of advising its customers that heat 4 transfer installations had to have closed systems 5 free from leaks? 6 MR. HARCKHAM: Objection, lack of 7 foundation. 8 Q (By Mr. Hausman) Again, if you have 9 that knowledge. 10 A Yes, that was the intent, to inform 11 customers on the need to have a leakproof system. 12 Q Okay. And under that intent, do you 13 know what hazards or dangers were anticipated, if 14 any? 15 MR. HARCKHAM: Objection, lack of 16 foundation. 17 A Well, the degree of hazard and danger, 18 of course, is related to the amount of material, to 19 the time of exposure, the number of people that 20 could be exposed, and that certainly was an 21 intention to minimize all that. In fact, not only 22 minimize, completely eliminate. The other intent, 23 of course, was to keep it from getting into the 24 sewer and leaving the premises. 25 Q (By Mr. Hausman) When you say the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063945 William Papageorge Protected Material 99 1 amount of material was a factor, does that mean if a 2 system used more, or a large degree of HTM fluid, 3 that ought to be more important to prevent leaks? 4 MR. HARCKHAM; Objection, vague and 5 ambiguous. 6 A Well, I don't think it has anything so 7 much to do with the amount of liquid in a system, 8 it's the amount that is leaving the system 9 unintentionally that's critical. 10 Q (By Mr. Hausman) Okay. When you say 11 that, I believe you said it's the intent to advise 12 customers to prevent against leaks; that a fair 13 characterization? 14 A Yes. 15 Q Where did you learn of that intent? 16 Or in other words, what's the basis of your saying 17 that that's the intent? 18 A Gee, I don't know whether I can 19 describe it. This is, this is so common to all 20 Monsanto products, it's just not unique just to 21 Therminols, it's based just on the need to operate 22 in what I'm going to call a professional kind of 23 manner and maintain the equipment, keep the place 24 clean, I don't know how else to describe it. 25 Q Let me ask to have marked as Exhibit CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063946 William Papageorge Protected Material 100 1 14 a two page document dated July 18, 1969, with ' 2 Monsanto named at the top titled Toxicity and Safe 3 Handling, Therminol FR-1. It does not appear to 4 have a date, it has a Bates numbers MONS 071021 5 through 022. 6 (Defendant's Deposition Exhibit 7 Papageorge 14 marked for identification by the court 8 reporter.) 9 Q (By Mr. Hausman) It does have a date, 10 July 18, 1969. 11 A I have read the exhibit. 12 Q Do you recognize this document? 13 A Yes, I do. 14 Q And under what circumstances do you 15 recall seeing this document before? 16 A I don't recall a specific incident. 17 This is another example of the kind of information 18 put out by the Medical Director of Monsanto 19 referring to, in this case, a specific Therminol. 20 Q Okay. And would this document also be 21 intended for distribution to others, including 22 customers ? 23 A Right. 24 MR. HARCKHAM: Objection, lack of 25 foundation. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063947 William Papageorge Protected Material 101 1 Q (By Mr. Hausman) Is there a 2 difference between a Therminol FR-0 that's referred 3 to in Exhibit 13 and Therminol FR-1 that's referred 4 to in Exhibit 14? 5 A Different Aroclors are involved in 6 making each of these Therminols. 7 Q Do each of those correspond with a 8 1200 number? 9 A Well, the Therminol FR-1 is Aroclor 10 1242 if my memory serves me right. 11 Q Okay. 12 A FR-0, as I remember, is a blend, I 13 hope I remember this correctly, it's Aroclor 1254 14 plus tri- and tetrachlorobenzene. It's a, benzene 15 is added to thin it out a bit. 16 Q Is it correct that tri- and 17 tetrachlorobenzene are not PCBs? 18 A That's correct. That's a chlorinated 19 benzene, not a PCB. 20 Q Okay. So your recollection is that 21 Therminol FR-0 had a higher chlorine percentage than 22 FR-1; is that right? 23 A The Aroclor ingredient had a higher, 24 but I have not calculated the total chlorine. That 25 one associated with the benzene and the chlorine CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063948 William Papageorge Protected Material 102 1 associated with the biphenyl, I have not calculated 2 the total chlorine. 3 Q When you say you haven't calculated 4 the total chlorine, what are you referring to there? 5 A Well, one can sit down, if you're 6 interested in a number, and by the molecular weight 7 or atomic weight of each of the carbons and 8 hydrogens and chlorine, you can calculate what 9 percent by weight a mixture of these would show. 10 Q Okay. You can set that aside. Let me 11 ask to have marked as Exhibit 14? 12 MR. HARCKHAM: 15 . 13 MR. HAUSMAN: 15, my apology, a six 14 page document, appears to be authored by W.B. Brown 15 with a date of, indicated as 26.11.54, which appears 16 to be November 26 of 1954, Bates numbers of MONS 17 095218 through 223. 18 (Defendant's Deposition Exhibit 19 Papageorge 15 marked for identification by the court 20 reporter.) 21 Q (By Mr. Hausman) Mr. Papageorge, 22 before you look through this whole document, I'm 23 going to have questions just on paragraph 3 of the 24 second page. But I think you should also quickly 25 look through the document to familiarize yourself CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063949 William Papageorge Protected Material 103 1 with it. 2 A I have scanned the exhibit. 3 Q Do you recognize this document? 4 A I do not recognize it. 5 Q Okay. Do you know who W.B. Brown is 6 or was? 7 A I, I don't recognize him. 8 Q Okay. In paragraph 3 of page 2 refers 9 to a Dr. Benignus or Benignus? 10 A Yeah, I see that. 11 Q Do you know him? 12 A I know Paul, yes. 13 Q Do you know if he's still alive? 14 A I believe he is. 15 Q What was his position in 1954? 16 A In 1954 Paul Benignus was a member of 17 Monsanto's Research Department studying PCBs and 18 applications of PCBs. 19 Q To your awareness is he retired today? 20 A I'm sorry? 21 Q Is he retired at this point in time? 22 A Oh, yes. Yes. 23 Q Do you know how old he is? 24 A In his 80s. 25 Q The last sentence read, "Dr. Benignus CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063950 William Papageorge Protected Material 104 1 keeps a careful check on sales of Aroclor and if the 2 replacement rate is high he has the situation 3 investigated." 4 Have you been aware of any such 5 practice, to monitor the amount of replacement of 6 Aroclors ? 7 A Yes. 8 Q Is that something that Monsanto did as 9 a general practice? 10 A That is a general practice, yes. 11 Q Including in 1954? 12 A Yes. 13 MR. HARCKHAM: Let me belatedly object 14 on foundation grounds. 15 Q (By Mr. Hausman) That was actually my 16 next question. And how do you know that to be a 17 fact? 18 A I, what I'm going to call normal 19 communications with marketing people, shipping 20 people, and we had meetings where they discussed, 21 "Boy, the sales to company ABC are skyrocketing, we 22 got to look into that," and then they come back 23 later and say, "They've got a new system going," or, 24 "They drained their system," or, "They had an 25 accident," depending on what they find out. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063951 William Papageorge Protected Material 105 1 Q Okay. Do you know what was done as a 2 practice if it was determined that a company had a 3 leaking HTM system? Heat transfer system? 4 MS. RUTTER: Objection to the 5 overbroad and vague form of the question. 6 MR. HARCKHAM: Objection. 7 Q (By Mr. Hausman) Okay, let me, let me 8 restate it. 9 Did Monsanto have any practices of 10 following up if, following up with a customer if the 11 replacement rate was determined to be high? 12 A Yes, they had a practice. 13 Q And what did that practice entail? 14 MR. HARCKHAM: Objection, lack of 15 foundation, and also object because there's no time 16 frame. 17 MS. RUTTER: I join. 18 Q (By Mr. Hausman) Why don't we start 19 in 1954, and that's if you know. Let's be clear. 20 A It was a practice where an unusual 21 amount of material was being delivered, shipped, the 22 field salesman would be asked to drop by and discuss 23 the matter. Sometimes those visits would result in 24 some information relating to, like I said earlier, 25 either a new system or a drain and fill of a system CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063952 William Papageorge Protected Material 106 1 or an accident, I can't think of any other examples'. 2 And the salesman would report that 3 back to his supervisor, in turn it would get back to 4 the Director of the Business Group. If he felt that 5 the customer wasn't going to take corrective action, 6 he'd get involved and call somebody, the customer's 7 home office, for example. That kind of dialogue 8 would take place on occasion. 9 MR. HARCKHAM; I didn't mean to 10 interrupt you, I'm sorry. Are you done? 11 THE WITNESS; I'm done. 12 MR. HARCKHAM: I just want to make 13 clear for the record that I have a continuing 14 objection on the record on a foundation basis to 15 this line of questions. 16 Q (By Mr. Hausman) Yeah, and the 17 process you just described, how do you know that, or 18 how did you obtain that knowledge? 19 A It would come up in discussions with 20 the marketing people. We would have, marketing 21 salesmen would come in and we'd have seminars and 22 meetings, this would come up as a way that they 23 functioned out in the field. Some of them would 24 describe their successes and some would describe 25 their, their failures, the customer wouldn't let CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063953 William Papageorge Protected Material 107 1 them in the plant, they wouldn't share any 2 information with them, so I couldn't help but pick 3 it up. 4 Q And you were present at these 5 discussions and seminars? 6 A I would be, well, because I was part 7 of the program. And I had my information to give to 8 them and they in turn would give me theirs. 9 Q You say you were part of the program, 10 what program were you referring to? 11 A I was involved predominantly with 12 marketing people after 1970. Prior to that, the 13 meeting with groups of marketing people was not as 14 frequent. We would have meetings, say, at the 15 Anniston Plant. I would be the host and we'd have 16 30 salesmen show up and we'd have a two or three day 17 meeting. Then I would be involved. But that 18 wouldn't happen too often. 19 Q And just to be clear, as you learned 20 of these procedures to let's say monitor these 21 heated exchange systems, did you learn that those 22 procedures were in place as early as 1954? 23 A Yes. 24 Q And did you also learn that those 25 procedures continued from 1954, say, to 1970? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063954 William Papageorge Protected Material 108 1 A Yes . 2 Q All right. Okay. Let me ask to have 3 marked as Exhibit 16 a multipage document entitled 4 A Guide to Accumulation and Shipment of Waste 5 Askarel Fluids, no apparent date, with a Bates 6 number of MONS 074772. 7 (Defendant's Deposition Exhibit 8 Papageorge 16 marked for identification by the court 9 reporter. ) 10 A 11 exhibit. I have read the, or scanned the 12 Q (By Mr. Hausman) Thank you. Do you 13 recognize this document? 14 A Yes, I do. 15 Q Okay. And under what circumstances 16 have you seen this before? 17 A In my assignment as Manager of 18 Environmental Control, Environmental Protection, I 19 was in a position where I was consulted on attempts 20 to put in writing the proper handling of PCB 21 containing materials. This was prepared by the, 22 this was prepared by Monsanto people in the group 23 responsible for the marketing of dielectric fluids. 24 Q And dielectric fluids are different 25 from heat exchange fluids? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063955 William Papageorge Protected Material 109 1 A Chemically not necessarily. Some of 2 them are identical chemically. Some of the 3 dielectric fluids are blends with other ingredients 4 present. 5 Q Is "askarel" a term that Monsanto used 6 to label these dielectric fluids? 7 A No, "askarel" is a term used by the 8 electrical equipment manufacturers who used fire 9 resistant fluids in their equipment. So in a way, 10 "askarel" is a generic expression for fire resistant 11 dielectric fluids. 12 Q Did Monsanto have brand names for 13 askarels ? 14 A No. 15 Q So did Monsanto also refer to them as 16 askarels as they sold them? 17 A On occasion, yes. Butgenerally we 18 would refer to them under the trademark which 19 reflected the particular recipe as ordered by the 20 customer. Like Pyranol was a General Electric name. 21 Inerteen was a Westinghouse name, and there were 22 several others. 23 Q Did Monsanto itself have any 24 trademarks for any askarels? 25 A No. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063956 William Papageorge Protected Material 110 1 Q Did Monsanto sell dielectric fluids 2 that had PCBs? 3 A Yes. 4 Q Was Exhibit 16 something that was 5 intended to be distributed to customers? 6 A I'm sorry? 7 Q Sure. Let me restate that. Was 8 Exhibit 16, this document, something that was 9 intended by Monsanto to be distributed to customers? 10 A It was intended to be so, yes. 11 Q Okay. And can you give me an 12 estimate, if possible, as to the approximate time 13 frame in which this document was generated? 14 A It refers to a document available from 15 the American National Standards Institute, and that 16 document went into print in 1974. So it would have 17 to be shortly thereafter. 18 Q Thank you. I'm going to ask to have 19 marked as Exhibit 17, I believe, a multipage 20 document entitled Presentation to Field Sales, 21 Personal and Confidential, has a Bates number of 22 MONS 058519 through 528, 528, excuse me, and no 23 apparent date. 24 (Defendant's Deposition Exhibit 25 Papageorge 17 marked for identification by the court CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063957 William Papageorge Protected Material 111 1 reporter.) 2 A I have scanned the exhibit. 3 Q (By Mr. Hausman) Do you recognize 4 this document, sir? ' 5 A Yes, I do. 6 Q And under what circumstances do you 7 recall seeing this document before? 8 A I saw this document, as best I 9 remember, belatedly, after a letter to the customers 10 was sent. I forget the exact circumstances, but I 11 saw a copy of this presentation after the fact, 12 after the presentation was made. I would suggest 13 that this happened about March or April of 1970. 14 Q And when you saw it, you were the 15 Manager of Environmental Control? 16 A Yes. 17 Q Did you have any role in the 18 preparation of this document? 19 A 20 earlier. No. Otherwise I would have seen it 21 Q Sure. Do you know who prepared the 22 document ? 23 A I'm not certain. 24 Q Okay. If you refer to the third page 25 of this document? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063958 William Papageorge Protected Material 112 - 1 A I have it. 2 Q The second paragraph reads, "Let me 3 summarize what Monsanto's letter says; No. 1, Its 4 primary function is to alert customers to a 5 potential environmental pollution problem." 6 Do you know what the phrase "potential 7 environmental pollution problem" refers to? 8 MR. HARCKHAM: Objection, lack of 9 foundation. 10 MS. RUTTER: I join. 11 MR. HARCKHAM: We have the letter, you 12 might want to show him the letter. 13 Q (By Mr. Hausman) All right. Do you 14 know what that phrase refers to? 15 A The reference to "potential" had to do 16 with effect on the environment as distinguished from 17 presence in the environment, and it was potential at 18 the time because there was no information to clearly 19 define what is going on out in the environment with 20 PCBs present. 21 Q Is there any specific event that led 22 Monsanto to take the action of advising its 23 customers of a potential environmental pollution 24 problem? 25 MR. HARCKHAM: Objection, because I CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063959 William Papageorge Protected Material 113 1 don't know what you're referring to. 2 Q (By Mr. Hausman) Do you understand 3 the question? 4 A I didn't hear a key word at the 5 beginning. 6 Q Was there a particular event that 7 caused Monsanto to take the action of advising its 8 customers of potential environmental pollution 9 problems of Aroclor? 10 MR. HARCKHAM: Objection, vague and 11 ambiguous. 12 A I would suggest that it was a series 13 of situations that led to that. It was not any 14 single event, no. It was the accumulation of 15 information from several sources regarding the 16 identity of this material and the samples taken and 17 the unusualness of the sample in that it's, it was 18 hard for Monsanto representatives to understand how 19 PCBs got into pine needles in Sweden, which is not 20 perceived to be a heavy industrial area. Or in the 21 hair from an infant, or even the fish up there near 22 Sweden. 23 So it was the strangeness of these, 24 strange to Monsanto with industrial perspective, to 25 associate PCBs with those presences. Even here in CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063960 William Papageorge Protected Material 114 1 the states we had reports, the pelican off south 2 California wasn't hatching its eggs, and the 3 peregrine falcon out of Cornell University study, 4 this kind of information all kind of was building up 5 to the point where Monsanto decided that we better 6 be responsible and do what we can within reason, 7 without creating explosions in transformers and what 8 not. 9 Q (By Mr. Hausman) Is there any further 10 information that Monsanto gained from what you just 11 described that led it ultimately to withdraw certain 12 PCB products? 13 A Certainly we, we kept learning as we 14 went. Some of the early information proved to be 15 erroneous. I mentioned the peregrine falcon and 16 then the pelicans, those situations were determined, 17 finally, to be due to DDT, although PCBs were found 18 there. The, the availability of alternative 19 materials helped a lot. 20 For example, the availability of a 21 fire resistant dielectric fluid was a real 22 challenge. It just could not be found easily to the 23 point where even the government, if, those of you 24 that have read the Interagency Task Force Report 25 that came out in '72 strongly emphasized that we CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063961 William Papageorge Protected Material 115 1 better not get out of the electrical applications. 2 It's too important. And I think you can visualize 3 what the World Trade Center would be like with a 4 fire up there on different levels where the 5 transformers are located. 6 Nevertheless, the idea was to withdraw 7 from those uses where a reasonable alternative was 8 available with some slight compromise in safety and 9 what have you. And when that was determined to be 10 possible, Monsanto moved. They didn't wait for the 11 government to dictate when to get out. 12 Q And just to place a time period on 13 that decision, was that in the early '70s? 14 A The decision to phase out, the first 15 step I want to call it was really arrived at, that's 16 a poor choice of words, in about April or May of 17 1970, and the recommendation was made to the top 18 executives in Monsanto and the program was approved 19 and the, what we call open uses, that's use in 20 paint, caulking materials, carbonless copy paper, 21 those uses were terminated starting on August of 22 1970 . 23 The heat transfer and hydraulic fluid 24 applications were perceived to be closed systems. 25 Nobody designs a leaking system deliberately, so we CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063962 William Papageorge Protected Material 116 1 said, well, wait a minute. We can tell our 2 customers, don't let it get away from you, and they 3 can still enjoy what we perceive to be important 4 characteristics. Fire and explosion-proof 5 properties. 6 The dielectric business, there was no 7 choice at the time. We just could not come up with 8 any alternative, and we felt quite comfortable that 9 since they were closed, steel boxes in essence with 10 no circulation, no pressure to leak out, if they did 11 leak it was more of an ooze that could be caught 12 quickly, and you could still enjoy the 13 explosion-proof transformer sitting outside your 14 Holiday Inn room. Some of you may have seen those 15 boxes out there. 16 Well, I'm talking more than I should, 17 perhaps, but nevertheless, it was an evolving 18 concept so that once we got rid of the open uses 19 with a lot of unhappy customers, very unhappy, then 20 we moved into the hydraulic fluids, because we had 21 an idea that phosphate esthers might be the 22 alternative. 23 But before that we got into the heat 24 transfer because of the applications in the food 25 business and there was some concern about the PCBs CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063963 William Papageorge Protected Material 117 1 finding their way into the food products. So that 2 program took off even before the hydraulic fluids 3 program. 4 I don't know if I answered your 5 question, it's just an evolutionary kind of phasing 6 out. 7 Q Yes. Thank you. In this time period 8 of the late '60s and early '70s, did Monsanto make 9 any let me start that over. 10 From the time period of 1968 to the 11 early 1970s, was there any information learned by 12 Monsanto indicating additional possible toxicity 13 from what was already known? 14 MR. HARCKHAM: Objection. 15 A Early '70s? No. Tests were under way 16 sponsored by Monsanto, but they were not anywhere 17 near completion. It would take a couple more years 18 before we would get the end results. 19 Q (By Mr. Hausman) Okay, then, after 20 the early 1970s, did Monsanto learn of any 21 additional toxic effects, potential toxic effects, 22 let's say that, of PCBs from what we discussed 23 earlier today? 24 A Well, we, our studies showed that 25 chickens were affected, the hatchability of their CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063964 William Papageorge Protected Material 118 - 1 eggs, they also showed that the higher chlorinated ' 2 types of PCBs affected the weight gain of the test 3 animals, and it affected some of their livers, which 4 was not a surprise, it confirmed what was known 5 before. 6 Q And that's what we discussed earlier, 7 the potential liver damage to animals? 8 A Yes, the liver damage was obvious, but 9 this was the first time that the animals were tested 10 in a multiyear test program, the kind that's used 11 for Food and Drug Administration approvals. The 12 first time to our knowledge it was done on 13 industrial chemical as distinguished from a 14 pharmaceutical or a food or cosmetic application. 15 Q Let me ask to have marked as Exhibit 16 18 a two page document with the date of June 17, 17 1970, first line reads, "Heads How To Keep Your 18 Therminol FR System Leak-Free," has Bates numbers of 19 MONS 080871 through 872. 20 (Defendant's Deposition Exhibit 21 Papageorge 18 marked for identification by the court 22 reporter.) 23 A I have read the document. 24 Q (By Mr. Hausman) Do you recognize 25 this document? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063965 William Papageorge Protected Material 119 1 A I do. 2 Q And under what circumstances do you 3 recall seeing this document before? 4 A Under what circumstances did I see it? 5 Q Yes . 6 A Well, I was involved in the 7 preparation of the earlier drafts, so I got to see 8 it fairly early, and made my comments, I forgot the 9 specifics of what I said then. Anyway, this is a 10 copy of a , one of the drafts. 11 Q And did Monsanto intend to provide 12 this information to its customers? 13 A Yes . 14 Q Okay. Did this, was this reprinted in 15 some more formal form? 16 A Yes, they had the logo and the colored 17 inks and so on. 18 Q When was that information to be 19 provided to customers? 20 A When? 21 Q Yes . 22 A You mean what year? 23 Q Yeah. 24 A About the middle of 1970. Shortly 25 after the date shown on this document. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063966 William Papageorge Protected Material 120 1 Q At that time in 1970 did Monsanto 2 institute a procedure of advising its customers to 3 prevent leakage from their heat exchange systems? 4 A Yes. 5 MR. HARCKHAM: Objection. 6 Q (By Mr. Hausman) And why was that? 7 A I'm sorry? 8 Q Why was that program instituted? 9 A It's part of our program of informing 10 the customer to do whatever it could to avoid it 11 getting into the environment. 12 Q And that's PCBs, when you say "it"? 13 A Yes . 14 Q Okay. Let me ask to have marked as 15 Exhibit 19 a one page document, appears to be 16 authored by W.B. Papageorge to W.G. Canham, 17 C-a-n-h-a-m, or Canham, dated July 13, 1970. It has 18 the Bates number of MONS 198181. 19 (Defendant's Deposition Exhibit 20 Papageorge 19 marked for identification by the court 21 reporter.) 22 A I have read the document. 23 Q (By Mr. Hausman) Do you recognize 24 this document? 25 A Yes, I do. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063967 William Papageorge Protected Material 121 1 Q Do you recall preparing it? 2 A Now that I read it I recall it, yes. 3 Q Okay. Do you recall why you prepared 4 it? 5 A Yes, I was trying to really educate 6 myself a little bit more on what we at Monsanto had 7 learned about leak-proof systems and whether they, 8 what we were doing was comparable to what I 9 understood our customers were doing, or if 10 necessary, share what we were doing with our 11 customers. 12 Q Okay. Who is Mr. Canham? 13 A Mr. Canham was a, one of the Monsanto 14 engineers in the Central Engineering Department. 15 Q Okay. Second paragraph reads, 16 "Monsanto's Therminols (FR Series) contain Aroclors. 17 In order to stay in this business, we are insisting 18 that heat transfer systems be designed to assure 19 minimum loss by leakage or vaporization." 20 Subsequent to this letter, did 21 Monsanto communicate to its customers that heat 22 transfer systems needed to be designed to assure 23 minimum loss by leakage or vaporization? 24 A That was our understanding and that's 25 what we believed in. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063968 William Papageorge Protected Material 122 1 Q And that was communicated to 2 customers ? 3 A Yes. 4 Q Okay. Let me ask to havemarked as 5 Exhibit 20 a one page document, again, from W.B. 6 Papageorge to B.W. Corlew, C-o-r-l-e-w, dated also 7 July 13, 1970, Bates number MONS 098182. 8 (Defendant's Deposition Exhibit 9 Papageorge 20 marked for identification by the court 10 reporter.) 11 A I haveread the document. 12 Q (By Mr. Hausman) And do yourecognize 13 this document? 14 A I do. 15 Q Do you recall preparing the document? 16 A Yes. 17 Q And I take it you prepared it on the 18 same date as Exhibit 19; is that correct? 19 A I'm sorry? 20 Q I will withdraw that question, the 2 1 document speaks for itself. 22 Who is B.W. Corlew? 23 A Mr. Corlew was aengineer at the 24 Sauget, Illinois, plant, Monsanto's. And he was in 25 their Engineering Services Department, responsible CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063969 William Papageorge Protected Material 123 1 for the kinds of things that I describe in this 2 memo. And I looked to him to see that progress was 3 being made. 4 Q Okay. And for the matters discussed 5 in this memo, was that part of your efforts as you 6 described to educate yourself as to the workings of 7 heat exchange systems? 8 A Educating myself as well as 9 encouraging - 10 MS. RUTTER: I'm going to object just 11 for a minute. He started a question, you started 12 talking, and then he finished the question, and I'm 13 not sure you understood the question. He may be 14 answering a different question than the one you 15 asked. So let's, I suggest we go back to the 16 beginning. 17 MR. HAUSMAN: Could you read back the 18 question as completed just so the witness knows and 19 understands? 20 (Last question read back by the court 21 reporter.) 22 A I don't know that I understand the 23 question that well. The kinds of things I talk 24 about here apply to any PCB application, and if so, 25 then it applies to heat exchange systems, heat CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063970 William Papageorge Protected Material 124 1 transfer systems. 2 Q (By Mr. Hausman) Okay. All right. 3 Okay, I think I understand your answer. Thank you. 4 I'll ask to have marked as Exhibit No. 5 21 a two page document dated August 17, 1970, from 6 W.B. Papageorge to G.L. Jessee, j-e-s-s-e-e, Bates 7 number MONS 098174 through 175. 8 (Defendant's Deposition Exhibit 9 Papageorge 21 marked for identification by the court 10 reporter.) 11 A I have read the exhibit. 12 Q (By Mr. Hausman) And do you recognize 13 this document? 14 A Yes, I do. 15 Q And do you recall why youprepared 16 this document? 17 A It' s a result of a visit I made to the 18 plant to observe the kinds of things they were doing 19 to reduce or eliminate PCBs entering into their 20 facilities and on out beyond the plant gate into the 21 environment. And this was my expression of the 22 kinds of things I saw that weren't quite as good as 23 I would have liked to have seen them. 24 Q At your, at that time, 1970, did you 25 consider the use of sand to pick up PCB liquid to CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063971 William Papageorge Protected Material 125 1 be, as you say, a practice that you would prefer 2 didn't happen? 3 A Yes. 4 Q And why is that? 5 A I'd prefer stoppingthe leakage or 6 loss in the first place. Using sand to absorb it is 7 one way to keep it from entering a water system, but 8 it creates a disposal problem of that contaminated 9 sand, and I was trying to reduce the problems as 10 much as I could in every direction, whether it be 11 the atmosphere, the water, or the landfill. 12 Q Who is Mr. Jessee? 13 A He was the PlantManager atAnniston, 14 Alabama at that time. He succeeded me. 15 Q Okay. This is the Monsanto plant? 16 A Yes. 17 Q Do you recall whether Monsanto, after 18 August 1970, communicated to any of its customers 19 that they should not use sand to pick up leaked 20 PCBs ? 21 A That was one of thestrong 22 recommendations we made to our marketing people and 23 to our home office people who might be contacting 24 the customers. 25 Q Okay. Let me ask to have marked as CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063972 William Papageorge Protected Material 126 1 Exhibit 22 a multipage document from W.B. Papageorge 2 to a number of people led by P.J.A. Marsh at the 3 top, has a date of January 8, 1971, Bates range of 4 MONS 099633 through 644. 5 (Defendant's Deposition Exhibit 6 Papageorge 22 marked for identification by the court 7 reporter.) 8 A I have scanned the exhibit. 9 Q (By Mr. Hausman) Just a very few 10 questions. Do you recognize this document? 11 A Yes, I do. 12 Q Okay. And on the last page, referring 13 to the, there's a photocopy of a signature, does 14 that appear to be a photocopy of your signature? 15 A The last page? 16 Q Yes. 17 A Yes. 18 Q Okay. And doyourecall why you 19 prepared this document? 20 A I decided that theactivities 21 undergoing at that, each month at that time were 22 being performed by so many people within Monsanto, 23 and the group was difficult to accumulate in a 24 conference room and share this data, so I decided to 25 use the monthly status report approach. And each of CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063973 William Papageorge Protected Material 127 1 the individuals listed are contributors to different 2 sections in it, so I act as sort of the scissors and 3 paste person, putting it together so that each of 4 them knows what the others are doing. 5 Q Okay. I'll refer you to the first 6 page under the heading Marketing, the very first 7 sentence reads, "Efforts continue to educate 8 Therminol FR users to control leakage." 9 A Yes. 10 Q Does that reflect that the marketing 11 people undertake those efforts? 12 A Yes. 13 Q All right. 14 A That's their contribution to this 15 effort. 16 Q Understood. Thank you. I want to go 17 off the record. 18 (A brief recess was held at this 19 time. 20 Q (By Mr. Hausman) Okay, Mr. 21 Papageorge, let me show you, first ask to be marked 22 as Exhibit No. 23 a two page document from T.L., 23 actually it's illegible, it's a name that starts 24 with G, dated September 1, 1971, subject is 25 Therminol FR Fluids, T.L. Gossage, maybe, and the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063974 William Papageorge Protected Material 128 1 Bates number is MONS 098533 through 534. 2 (Defendant's Deposition Exhibit 3 Papageorge 23 marked for identification by the court 4 reporter.) 5 Q (By Mr. Hausman) Mr. Papageorge, this 6 unfortunately isn't the most legible document, so 7 let me read the first several sentences into the 8 record just so we're clear. 9 "Because of increasing PCB 10 environmental pressures and questions as to whether 11 we can effectively 'close the loop' and eliminate 12 leaks in heat transfer systems, we have decided in 13 the United States to initiate a policy of no new 14 systems on Therminol FR fluids. We intend that 15 there will be no exceptions to this policy." 16 Also I note that there appears to be a 17 handwritten CC with the first name indicated as 18 Papageorge. Do you recognize this document? 19 A As I read it I recall it, yes. 20 Q Did Monsanto make a decision in 1971 21 to initiate a policy of no new systems of Therminol 22 FR fluids? 23 A Yes. 24 Q Okay. Why did it do that? 25 A It was primarily based on some CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063975 William Papageorge Protected Material 129 1 incidences that involved PCBs used as heat transfer 2 fluids getting into food and animal feed products. 3 In order to avoid future incidences of that type, 4 alternative fluids were developed but sacrificing 5 the fire resistance. 6 Those changeovers appeared to be 7 successful, and with that success and with the 8 continual leakage of the industrial type heat 9 transfer systems, it was decided that Monsanto would 10 not sell the PCB type fluids to the new systems, and 11 eventually it decided to promote the drainage of the 12 old systems and replacing with these alternative 13 materials. 14 Q Okay. Was the decision to promote 15 changeouts of those systems, was that in 1972, to 16 your recollection? 17 A The decision, did you ask me was it 18 made in '72 or -- 19 Q Yes. Or earlier. 20 A It was made about the time of this 21 memorandum, September '71, and evolved, by '72 we 22 were pretty far along, as I remember. 23 Q Okay. That's all with that document. 24 Let me ask to have marked as Exhibit 24 a multipage 25 document indicated as Copy on the front page, says CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063976 William Papageorge Protected Material 130 - 1 December 8, 1971, Job indicated as Therminol ' 2 Conversion Bulletin, has a Bates range of MONS 3 079843 through 866. 4 (Defendant's Deposition Exhibit 5 Papageorge 24 marked for identification by the court 6 reporter.) 7 Q (By Mr. Hausman) Mr. Papageorge, I'm 8 not going to have any specific questions on this 9 document, I just want to ask you if you recognize 10 this document. 11 A I recognize this as a draft, not a 12 final version, of an attempt to put in brochure form 13 a conversion program. 14 Q And that was a brochure form for, at 15 least to your customers? 16 A Yes. 17 Q Do you recognize the handwriting 18 throughout the document? I guess the real question 19 is is that your handwriting? 20 A It's not my handwriting. I don't know 21 whose it is. 22 Q Okay. Do you know whether the 23 information in this document was ultimately 24 converted into a final brochure? 25 A Yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063977 William Papageorge Protected Material 131 1 Q And was that in 1971, 1972? 2 A Early '72 was the final version. 3 Q Okay. Thank you. Okay. 4 Let me ask to have marked as Exhibit 5 25 a multipage document entitled Monsanto's PCB 6 Program, apparently prepared by W.B. Papageorge for 7 a meeting date September 14, 1971, and has Bates 8 range of MONS 041633 through 648. 9 (Defendant's Deposition Exhibit 10 Papageorge 25 marked for identification by the court 11 reporter.) 12 A I have scanned the document. 13 Q (By Mr. Hausman) Do you recognize 14 this document? 15 A Yes, I do. 16 Q And do you recall why you prepared 17 this document? 18 A Yes. 19 Q Why is that? 20 A I was appointed to be Chairman of a 21 American National Standards Institute committee to 22 address the issue of control of entry of dielectric 23 PCB containing fluids into the environment. 24 At the first meeting of the, I'm going 25 to call it a working meeting where the committee was CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063978 William Papageorge Protected Material 132 1 to get serious about which, what it was going to 2 produce, I prepared this presentation to bring 3 everyone in the room up to date. Several of the 4 people there had already heard this or these kinds 5 of thoughts; there were others that were totally new 6 to the issue, so my intent was to bring them up to 7 date. 8 Q Was the information in this 9 preparation put into any type of publication by this 10 group? 11 A No. 12 Q Do you recall whether any customers of 13 Monsanto attended this meeting? 14 A Oh, yes. 15 Q Do you know whether Reynolds sent 16 anybody to this meeting? 17 A I don't recall Reynolds being present, 18 no. 19 Q Let me ask to have marked as Exhibit 20 26 a multipage document entitled Discontinuation of 21 Therminol FR Sales, no apparent date indicated, has 22 Bates number of MONS 043488 through 496. 23 (Defendant's Deposition Exhibit 24 Papageorge 26 marked for identification by the court 25 reporter.) CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063979 William Papageorge Protected Material 133 1 A I have scanned the exhibit. 2 Q (By Mr. Hausman) Thank you. Do you 3 recognize this document, Mr. Papageorge? 4 A I have seen it before, yes, sir. 5 Q And under what circumstances have you 6 seen it before? 7 A As best I recall, Mr. Gossage's 8 secretary brought a draft by the office for me to 9 review. That was my first exposure to this. 10 Q And who is Mr. Gossage? 11 A Mr. Gossage at the time was the Sales 12 Director of the group that marketed Therminols. 13 Q Did you provide comments for this, 14 this draft? 15 A I did, but I frankly don't remember 16 the details. I don't remember the very first draft 17 I saw. 18 Q Was a document prepared for 19 distribution to customers pursuant to this? 20 A This document was really prepared for 21 the upper management, as you'll note, and on, also 22 the field salesmen. 23 Q All right. 24 A To help them respond to any questions 25 that they might be asked by the customers. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063980 William Papageorge Protected Material 134 1 Q So when you say "upper management," 2 you mean upper management of Monsanto? 3 A Yes. 4 Q All right. When you were the Manager 5 of Environmental Control or Environmental 6 Protection, did you receive any reports on the 7 status in progress of any changeouts at Reynolds' 8 Massena facility? 9 A Yes. 10 Q From whom did you receive those 11 reports ? 12 A Coordinator of the Therminol program, 13 Paul Gann, G-a-n-n, would either tell me personally, 14 verbally, orally, or he would also prepare, as I 15 recall, a status report in which he listed customers 16 and the last contacts made and the progress they 17 were making. Mr. Gann was my principal source of 18 information. 19 Q Okay. Do you know whether he visited 20 the Massena Reynolds plant at any time? 21 A I don't know that. 22 Q Did you ever have any interaction with 23 a Monsanto employee named Dean Danzer? 24 A Yes. 25 Q What kind of contacts did you have CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063981 William Papageorge Protected Material 135 1 with Mr. Danzer? 2 A At what point in time? 3 Q Fair enough. At the point in time 4 when Reynolds was changing out its heat transfer 5 system. 6 A Mr. Danzer was assigned to assist Mr. 7 Gann's efforts in these Therminol changeovers. He 8 had located temporarily in the building that the 9 rest of us were located, so I would meet him in the 10 hallways or he'd drop by the office, because we had 11 known each other previously, so he felt he could 12 drop in any time and tell me how things were going 13 and what, what had transpired. And that's how I 14 kept in touch, really, with the kinds of activities 15 that he was personally involved with. 16 Q Let me ask to be marked as Exhibit No. 17 27 a two page document with the heading Sales 18 Meeting, Tuesday, April 27, 1971, has a Bates number 19 of REY 000359 through 360. . 20 (Defendant's Deposition Exhibit 2 1 Papageorge 27 marked for identification by the court 22 reporter.) 23 Q (By Mr. Hausman) Mr. Papageorge, the 24 reason I show you this document is I see the 25 initials W.P. about two-thirds of the way down the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063982 William Papageorge Protected Material 136 - 1 first page after Environment and Pollution. ' 2 A I see that W.P. 3 Q Do you recall attending a sales 4 meeting on April 27, 1971? 5 A I've attended so many sales meetings, 6 this seems very typical. 7 Q Okay. 8 A Nothing stands out as being unique. 9 Q On the second page Reynolds Metals is 10 indicated, the name Reynolds Metals is indicated. 11 Do you recall -~ 12 MR. HARCKHAM: Can I just, for the 13 record, I take it this page is redacted, Carol? 14 MS. RUTTER: Yes. 15 MR. HARCKHAM: So there was actually 16 seven that were on the original list, the original? 17 MS. RUTTER: It's been a few months, 18 but it certainly appears so. 19 MR. HAUSMAN: And I think, from the 20 production, I take it that you redacted names of 21 other customers? 22 MS. RUTTER: Yes. 23 (An off the record discussion was held 24 at this time.) 25 Q (By Mr. Hausman) Okay, back on the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063983 William Papageorge Protected Material 137 1 record. Mr. Papageorge, do you recall discussions 2 of Reynolds Metals at sales meetings in 1971? 3 A Yes. 4 Q Do you recall what was discussed? 5 A I'm sorry? 6 Q Do you recall what was discussed? 7 A I recall in general that PCBs were 8 present at the sites, that communications were good, 9 that once the message was understood, that the 10 response was very sophisticated. They're right up, 11 up to it. 12 Q Do you recall seeing any report - 13 MR. HARCKHAM: Had you finished your 14 answer? 15 MR. HAUSMAN: I'm sorry. Please. 16 A The net result is that I felt, from 17 what I heard and gathered, that things were going 18 well and it didn't need my personal visit or 19 involvement or telephone calls. In other words, I 20 felt comfortable with what I heard, and I used my 21 time on the other problem customers that we were 22 facing. 23 Q (By Mr. Hausman) Do you recall what 24 measures Reynolds took in the early '70s in response 25 to the communications that were sent to it from CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063984 William Papageorge Protected Material 138 1 Monsanto? 2 MS. RUTTER: I would object to the 3 overbroad and vague form of the question. 4 A I don't remember details. I do 5 remember the general impression that I was left with 6 that they were aware of the environmental issue, 7 that leakage was and could be a problem unless 8 attention was paid to maintenance and the like and a 9 conversion did take place, there was some return of 10 old material to be destroyed, I remember that. 11 There was nothing in a, in a negative way that 12 stands out as being a real problem. So everything 13 appeared to be to me kind of impression. 14 Q (By Mr. Hausman) All right. Do you 15 recall receiving any reports of leaking heat 16 transfer medium system at the Reynolds Massena 17 plant? 18 MS. RUTTER: Objection to the 19 overbroad and vague form of the question. 20 A I just, no, nothing stands out in that 21 area. 22 Q (By Mr. Hausman) Do you recall 23 receiving any reports of a, an explosion of the HTM 24 system that took place in the 1950s at the Reynolds 25 Massena plant? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063985 William Papageorge Protected Material 139 1 A Explosion in the '50s. Reynolds 2 plant, no, I don't recall that. 3 Q Okay, let me ask to have marked as 4 Exhibit 28 a one page letter dated August 16, 1972 5 from W.B. Papageorge to Mr. B.P. Collins, Bates 6 number REY 000403. 7 (Defendant's Deposition Exhibit 8 Papageorge 28 marked for identification by the court 9 reporter.) 10 A I have read the exhibit. 11 Q (By Mr. Hausman) Do you recall 12 preparing this letter? 13 A Hmm? 14 Q Do you recall preparing this letter? 15 A Yes. 16 Q It states that, "In response to your 17 telephone request I am forwarding under separate 18 cover samples of Aroclor 1242 and Aroclor 1254." Do 19 you recall why you sent these Aroclor samples to 20 Reynolds? 21 A He asked for them. 22 Q Did he say why? 23 A Oh, you mean what hewanted them for? 24 Q Yes. 25 A I understood that his, he was going to CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063986 William Papageorge Protected Material 140 1 go to some laboratory somewhere and set up a program 2 for analyzing PCBs and he needed the, these samples, 3 virgin material as a standard to compare the unknown 4 against, and the 1242 and 1254 gave him the right 5 range of types that his analyst might want to look 6 at. 7 Q Did you talk to -- I'm sorry. You 8 didn't finish. 9 A I do not know the specifics regarding 10 exactly what he was looking and where. 11 Q Did you talk to Mr. Collins or did he 12 send a letter? 13 A Oh, he, he called me on the phone. 14 Well, actually he called Monsanto and it eventually 15 got transferred to my phone. 16 Q I see. Are you familiar with the name 17 Larry Tropea from Reynolds? 18 A Larry, how do you spell his last name? 19 Q Tropea, T-r-o-p-e-a? 20 A I've seen it in print. I don't know 21 the man personally. 22 Q You don't recall talking to him? 23 A No. 24 Q Let me ask to have marked as Exhibit 25 29 a four page document from W.B. Papageorge with no CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063987 William Papageorge Protected Material 141 1 addressee indicated on the front, dated April, 1972, 2 Bates number REY 000062 through 065. 3 (Defendant's Deposition Exhibit 4 Papageorge 29 marked for identification by the court 5 reporter.) 6 A I have scanned the exhibit. 7 Q (By Mr. Hausman) Do you recognize 8 this document? 9 A I do. 10 Q Is this a form letter? 11 A In a way, yes. We just type in the 12 addressee. 13 Q Okay. And I refer to the third and 14 fourth pages? 15 A I'm sorry? 16 Q The third and fourth pages of this 17 exhibit, there are various addresses, do you know 18 whether that indicates that Reynolds was sent copies 19 of these? 20 A Yes, it does. This is a copy of the 21 labels that were typed, and before they were affixed 22 either to the letter or to the envelope, they were 23 photographed to give us a record. 24 Q And why did you prepare this letter? 25 A Well, as it says in the letter, I got CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063988 William Papageorge Protected Material 142 - 1 a call, one of many calls from EPA representatives ' 2 wanting to know names of our customers, the types of 3 PCBs they bought, how much they purchased, when, all 4 those details, and Monsanto resisted that, but the, 5 I sensed that the pressure was building and I wanted 6 the customers to know that we were trying to avoid 7 disclosing a customer list, for many reasons that 8 are understood by industry. Anyway, I just wanted 9 them to know that the day may come when we would be 10 forced to divulge such a list, and that was the 11 purpose of this, as well as I took advantage of the 12 opportunity to again say don't get it in food feed 13 and so on. Next to last paragraph. 14 Q Okay. That was my next question. 15 Thank you. 16 Was there a point in time after 1972 17 where Monsanto -- let me start over. 18 Was there a point in time after 1972 19 where you became aware that a single changeout of a 20 heat exchange system would not eliminate all PCBs in 21 that system? 22 MS. HUTTERs Objection to the vague 23 form of the question. 24 MR. HARCKHAM: Join. 25 MS. RUTTERs If you understand it, you CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063989 William Papageorge Protected Material 143 1 may answer. 2 A I'm having difficulty understanding, 3 the degree of success in changeout to totally 4 eliminate the presence of PCBs will vary with the 5 care and attention given to the changeout. Just 6 opening a spigot and draining doesn't do it. You 7 got to change gaskets, you got to clean out and 8 flush the system, if there's any residue in it it's 9 going to retain the PCBs, which will be loosened or 10 freed by the new fluid. Is that the, is that the 11 answer? I don't know that I understand your 12 question. 13 Q (By Mr. Hausman) Let me show you a 14 document. Let me have marked as Exhibit No. 30 a 15 three page document from D. Wood, no addressee 16 indicated on the front, August 7, 1978, Bates number 17 REY 000073 through 75. 18 (Defendant's Deposition Exhibit 19 Papageorge 30 marked for identification by the court 20 reporter.) 21 A I have read the exhibit. 22 Q (By Mr. Hausman) Do you recognize 23 this document? 2 4 A I have not seen it before. 25 Q Are you aware of whether Monsanto CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063990 William Papageorge Protected Material 144 1 instituted a program of advising its customers that 2 they may have to further change out systems to 3 eliminate or reduce residual PCBs? 4 MS. RUTTER: Object to the form of the 5 question. 6 A I'm aware of communications to 7 customers undergoing these changes in the Therminol 8 systems that covered the need for a thorough 9 flushing, circulating, running the system for weeks 10 before you drain the flush, sometimes it took a 11 second flush. I'm aware that they talked about the 12 degree of contamination in the vent tank they called 13 it, the storage tank, the degree of material that 14 deposited on the walls of the tank as well as within 15 the pipelines and how they could be loosened by the 16 new fluid. I'm aware of the pump packing, that's 17 the soft material that keeps the liquid from gushing 18 out off the, away from the pump, how that has to be 19 changed and the proper type selected for the future. 20 All these things are just very necessary, and they 21 were communicated, to the best of my knowledge. 22 Q (By Mr. Hausman) And let me ask to 23 have marked as Exhibit 31, stepping back a little 24 bit in time, a letter dated August 31, 1970, from 25 W.B. Papageorge to Mr. Bruce S. Hulcher, Bates CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063991 William Papageorge Protected Material 145 1 number REY 000395 through 396. 2 (Defendant's Deposition Exhibit 3 Papageorge 31 marked for identification by the court 4 reporter.) 5 A I have read the document. 6 Q (By Mr. Hausman) Do you recognize 7 this document? 8 A Yes, I do. 9 Q Do you know why you prepared it? 10 A I'm sorry? 11 Q Do you know why you prepared it, 12 excuse me. 13 A I think it's Dr. Hulcher? 14 Q Yes. 15 A He wrote to the Marketing Director, 16 Don Olson at that time, in which he asked questions. 17 Mr. Olson asked me to respond, and this is my 18 attempt to respond to those areas of interest. 19 Q Okay. And what is Pydraul usedfor? 20 A Pydraul is the PCB containing 21 hydraulic fluid. 22 Q Okay. Let me ask to have marked as 23 Exhibit 32 a series of consecutive documents with a 24 Bates range from REY 000001 through 036. I 25 represent that I put these together one, because CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063992 William Papageorge Protected Material 146 1 they're consecutive, and two, they're similar 2 documents for easy reference. I'm introducing them 3 in one exhibit so we don't have 36 different ones. 4 (Defendant's Deposition Exhibit 5 Papageorge 32 marked for identification by the court 6 reporter.) 7 A I have scanned through the exhibit. 8 Q (By Mr. Hausman) Thank you. While 9 you were employed by Monsanto, did you have occasion 10 to see sales summaries such as these? 11 A Oh, yes. 12 Q Is this somethingthatMonsanto 13 prepared in the normal course of business? 14 A Yes. 15 Q In what department were those 16 prepared? 17 A It was a service provided by accounts 18 receivable, I believe, department for the marketing 19 group. 20 Q And is that in St. Louis or elsewhere? 21 A St. Louis headquarters. 22 Q Let's look at the first page. Let me 23 again give the proviso, if you don't know the answer 24 to this, please let me know. I don't want you to 25 guess or anything, but only if you if you have CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063993 William Papageorge Protected Material 147 . 1 specific knowledge. ' 2 Note that the date is, in the upper 3 right hand corner is indicated as December '59? 4 A Yes. 5 Q Do you know whether the numbers 6 indicated as Sales This Year to Date, whether those 7 indicate total sales of that product to that company 8 for the full year? 9 A For the year '59. 10 Q So it wouldn't be an individual 11 shipment, it would be a total of all the shipments; 12 is that correct? 13 A Correct. 14 Q All right. Okay. I'd like to go 15 through the various products that are indicated 16 here. The first page reflects Pydraul F-9, is that 17 a hydraulic fluid? 18 A Yes. 19 Q And does that contain PCBs? 20 A Does it what? I'm sorry. 21 Q In 1959,did that material contain 22 PCBs? 23 A Yes. 24 Q Okay. Do you know what type of PCB it 25 contains in terms of, again, the four digit number? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063994 William Papageorge Protected Material 148 1 A One of the 40s, but I, I'm not 2 certain. 3 Q Okay. What is the appearance of 4 Pydraul F-9 at room temperature? 5 A I would say, as I remember, it's a 6 purple colored liquid that looks like about the 7 consistency of, let me say, mineral oil, baby oil. 8 Q Was it soluble in water? 9 A No. Well, I, everything is soluble to 10 a degree, but it's not like salt is soluble in 11 water. 12 Q Okay. 13 A It will, some components will 14 dissolve, some components might sink if agitated and 15 all, and the PCBs would sink if they're separated, 16 and some would float. So depending on the, the 17 conditions that it finds itself in, it could react 18 with water in any of those ways. 19 Q All right. If any Pydraul F-9 were 20 exposed to the air, would any PCBs volatilize? 21 A No. Very few. You could probably 22 measure with the sophisticated instruments today, 23 but for all practical purposes, no. 24 Q And did the PCBs in Pydraul F-9 have a 25 tendency to bond to soils? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063995 William Papageorge Protected Material 149 1 A Yes. 2 MR. HARCKHAM: Objection, lack of 3 foundation. 4 Q (By Mr. Hausman) Okay, let's turn to 5 the second page, Bates number I think 2? Is Pydraul 6 A-200 also a hydraulic fluid? 7 A Yes. 8 Q And how did that differ from Pydraul 9 F-9? 10 A It depends on the type of PCB used as 11 well as other ingredients. They're a little, 12 slightly different. 13 Q Do you recall what type of PCB was 14 used on that Pydraul? 15 A No, I'd have to see the recipes again 16 to refresh my memory. 17 Q Was that also a purple, oily liquid? 18 A Yes. 19 Q Same solubilitycharacteristics that 20 you described for F-9? 21 A Well, the solubility varies with the 22 type of ingredients, so since they're not identical, 23 there, there will be a difference. 24 Q Do you knowwhether it was more 25 soluble or less than F-9? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063996 William Papageorge Protected Material 150 1 A No, I wouldn't. I'd have to see the 2 ingredients again. 3 Q Okay. Referring to the third page, 4 Aroclor DIST 1248, I take that to mean that's a 1248 5 PCB; is that correct? 6 A That's right. 7 Q Is that a heat exchange fluid? 8 A Yes. 9 Q What were the characteristics, what 10 was the appearance of Aroclor 1248? 11 A Well, it's a little bit heavier than 12 baby oil that I used the reference earlier. In its 13 pure condition it's clear as water. It may have a 14 tinge of yellow occasionally. In use it could 15 darken after years of use, it could have a deeper 16 tinge of yellow. 17 Q And what are the solubility 18 characteristics of Aroclor 1248? 19 MR. HARCKHAM.* Objection, lack of 20 foundation. 21 A As I remember, the solubility of 1248 22 is less than 200 parts per billion in water at room 23 temperature. Less than that. 24 Q (By Mr. Hausman) If water and Aroclor 25 1248 were in contact, would those two substances CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063997 William Papageorge Protected Material 151 1 separate? 2 A Yes. 3 MR. HARCKHAM: Objection. 4 Q (By Mr. Hausman) And which is denser, 5 water or 1248? 6 A Sorry? 7 Q Which is denser, water or Aroclor 8 1248? 9 A 1248 would sink to the bottom. 10 Q So there would be water on top? 11 A Water on top. 12 Q Okay. Turning to the document in this 13 set with the Bates number ending 10? Therminol FR-2 14 I believe we spoke about, could you remind me, what 15 was the Aroclor number for FR-2? 16 A 1248. 17 Q Is the appearance of Therminol FR-2 18 the same as Aroclor 1248? 19 A Yes. 20 Q And the characteristics that we 21 described are the same? 22 A Identical. 23 Q Turn to the page with the Bates number 24 ending 18, it's somewhat difficult to read but it 25 seems to indicate Pydraul 135? I'll let you get to CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063998 William Papageorge Protected Material 152 1 that page. 2 A That's what I, that's what I read. 3 Q Is Pydraul 135 a product that Monsanto 4 sold? 5 A Yes. 6 Q And for what use? 7 A Hydraulic fluid. 8 Q And what was the correspondingAroclor 9 number with Pydraul 135? 10 A I don't remember all those Pydraul 11 recipes. 12 Q Okay. So you don't know off the top 13 of your head? 14 A I don't recall it, no. 15 Q Let's have marked as Exhibit 33 a 16 multipage document with the legend New York PCB 17 content, 1968 to 1969, Bates range REY 000262 18 through 278. 19 (Defendant's Deposition Exhibit 20 Papageorge 33 marked for identification by the court 21 reporter.) 22 Q (By Mr. Hausman) That's I believe to 23 be another document with customer names redacted 24 except for Reynolds. 25 A I have scanned the exhibit. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000063999 William Papageorge Protected Material 153 1 Q Okay. Mr. Papageorge, understanding 1 2 that the names of customers have been redacted out 3 of this document, have you seen documents in this 4 form before when you were at Monsanto? 5 A This is the first I've seen. 6 Q Okay. So you don't, you can't tell me 7 what the numbers refer to? 8 A I don't even understand it. 9 Q All right. Fair enough. Let me ask 10 to have marked as Papageorge Exhibit No. 34 a 11 multipage document, the first page reads, "Exhibit L 12 (Revised)," second page reads "PCB Waste Returns," 13 Bates number REY 000279 through 285. 14 (Defendant's Deposition Exhibit 15 Papageorge 34 marked for identification by the court 16 reporter.) 17 A I have scanned the exhibit. 18 Q (By Mr. Hausman) Okay. Again with 19 the proviso that customer names appear to have been 20 redacted, do you recognize this form of document? 21 A I have seen similar documents. I 22 don't remember whether I saw this specific version. 23 Q I understand. Under what 24 circumstances have you seen similar documents? 25 A That was part of my attempt to keep up CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064000 William Papageorge Protected Material 154 1 to date on what was going on regarding return 2 material for incineration. 3 Q All right. Let me show you another 4 similar document I'm going to ask to have marked as 5 Exhibit 35, a document titled Item 5, Attachment B, 6 PCB Returns, Bates number REY 000286 through 291. 7 (Defendant's Deposition Exhibit 8 Papageorge 35 marked for identification by the court 9 reporter.) 10 A I have scanned the exhibit. 11 Q (By Mr. Hausman) Okay. And again, do 12 you recognize this form of document? 13 A Yes. 14 Q Is this something that Monsanto kept 15 in the normal course of business? 16 A Yes. 17 Q For both of these documents, Exhibits 18 55 and, or 35 and 36, who was responsible for 19 preparing these documents? 20 A I don't know. 21 Q The heading of 35 is PCB Waste Returns 22 and 36 is PCB Returns, you see that? 23 A I see that, yes. 24 Q To your knowledge is there a 25 distinction between those two items, a PCB return CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064001 William Papageorge Protected Material 155 1 and a PCB waste return? 2 A I interpret both of those as being 3 material return for incineration. There's nothing 4 to tell me that these are PCBs unused, still in the 5 original container being returned for other reasons 6 other than incineration. 7 Q Based on your knowledge of how these 8 charts were set up, if a company were to return 9 unused PCB fluid pursuant to the program in 1971, 10 would that amount be reflected on either one of 11 these charts? 12 A It would be reflected in this summary, 13 yes. As return material for dispose, for 14 incineration. 15 Q Okay. If a company also returned used 16 material that was taken out of its system, such as a 17 heat transfer system, would that amount be reflected 18 in these reports? 19 A Yes. Yes. 20 Q So there would be no distinction 21 between the two? 22 A That is true. At that year, 1971 and 23 on. 24 Q Okay if you refer to, yeah. Exhibit 34 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064002 William Papageorge Protected Material 156 1 (An off the record discussion was held 2 at this time.) 3 Q (By Mr. Hausman) Okay. Exhibit 34, 4 which is the first one that starts Exhibit L, if you 5 look on the page 283? 6 A 282? 7 Q 283. You see the quantityindicated 8 for Reynolds Metal, Massena, New York, indicated at 9 7,655? 10 A For Massena, yes. 11 Q Okay. And if you refer to Exhibit 35, 12 page 289, that same number, 7,655 is indicated. Do 13 you see that? 14 A Yes. 15 Q Do you understand thosenumbers to be 16 referring to the same returned PCB material? 17 A Yes, sir. 18 Q Okay. The customer-returnedmaterial 19 that was used for flushing out a system as opposed 20 to the PCB material itself? 21 A Yes. 22 Q Would that quantity bereflected in 23 either one of these charts? 24 A Yes. It would be part, it would be 25 considered a waste PCB, or incineration material. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064003 William Papageorge Protected Material 157 1 Q So that as well would be included in 2 this 7,655 number? 3 A That's right. 4 Q Are you familiar with a process of 5 biodegradation of PCBs? 6 A I'm sorry, the bio what? 7 Q Biodegradation? 8 A Yes, sir. To a degree. I'm not a 9 biologist. 10 Q Okay. Is that something you ever 11 studied when you were at Monsanto, how PCBs 12 biodegrade? 13 A Yes, I was involved in monitoring, 14 staying close to Monsanto studies, both in Wales, 15 England, United Kingdom and in the United States, 16 St. Louis. 17 Q And based on your monitoring, what is 18 biodegradation of PCBs? 19 A Biodegradation refers to the situation 20 where bacteria that are acclimated to a PCB type 21 environment start to consume the PCBs as a food 22 source, and in so doing, they break up the PCB 23 configuration to the point where an analyst looking 24 for PCBs doesn't see PCBs any more. It's some other 25 material now. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064004 William Papageorge Protected Material 158 1 Now, the rate at which this change in 2 PCBs takes place depends on how many chlorines are 3 associated with each PCB. The more chlorines 4 involved, the more difficult it is for the bacteria 5 to get into the, to get to the carbon. 6 So we find that the lower chlorinated 7 PCBs are more apt to disappear in such a situation 8 than the higher chlorinated. 9 Q Okay. 10 A So the residual that the analyst sees 11 is a distortion of the virgin material. All the 12 analyst sees is the higher chlorinated types, and by 13 the protocol set up by the analytical community, he 14 has to identify that as one of the Aroclors. And so 15 he takes a standard and says, well, it more matches, 16 it looks more like 1260. It may well have started 17 out as 1242. And that match that he's describing is 18 not a perfect match. It's the closest he can get to 19 it. The analyst on the next bench may decide to 20 call it 1254 because that's the way it looks to him. 21 Q Based on your knowledge in reading 22 information and also your knowledge as a chemist, 23 does this change in detection go in the other 24 direction? You just described the possibility of a 25 lower Aroclor being identified as a higher number. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064005 William Papageorge Protected Material 159 1 Does it go in the other direction? For example, 2 could a 1260 be misidentified, that start -- let me 3 start again. 4 Could an Aroclor that started as 1260 5 over time be misidentified as a 1242? 6 MR. HARCKHAM: Objection, lack of 7 foundation. 8 MS. RUTTER: I object to the vague 9 form of the guestion. 10 MR. HARCKHAM: I join in that 11 objection. 12 THE WITNESS: I'm not aware of any 13 studies that demonstrated that that could happen. 14 Nothing has been found where bacteria will take a 15 PCB and remove chlorine from it to get it to look 16 more like the lower chlorinated. I know, I've heard 17 nothing along those lines. The opposite has been 18 demonstrated. 19 MR. HAUSMAN: Let's go off the record 20 for about two minutes. 21 (A brief recess was held at this 22 time. 23 MR. HAUSMAN: Mr. Papageorge, I don't 24 have any more guestions. I thank you very much for 25 your patience. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064006 William Papageorge Protected Material 160 1 THE WITNESS; Thank you. 2 EXAMINATION BY 3 MS. REIMER: 4 Q Good afternoon, Mr.Papageorge. 5 A Good afternoon. 6 Q As you know, my name's Nancy Reimer 7 and I'm from Mintz Levin and I represent Liberty 8 Mutual in this case. I just have a couple follow up 9 questions for you. 10 My first question is during the course 11 of your tenure at Monsanto, did you ever visit the 12 Reynolds corporate headquarters in Richmond, 13 Virginia? 14 A No. 15 Q Did you ever have any communications 16 with anyone from Reynolds corporate headquarters in 17 Richmond, Virginia, while you were at Monsanto? 18 A Yes, Dr. Hulcher and Mr. Collins, this 19 was over the telephone, and Dr. Hulcher was both 20 telephone and letter communications. 21 Q You testified this afternoon about 22 certain communications you had with Dr. Hulcher, 23 correct? 24 A Yes. 25 Q I don't want to revisit that, so my CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064007 William Papageorge Protected Material 161 1 question is in addition to that topic which you had 2 conversations with with Dr. Hulcher, did you have 3 any other discussions with Dr. Hulcher? 4 A Oh, I had several. Today I don't 5 remember the specific topics discussed, but it was 6 certainly more than just one contact. 7 Q Do you recall in general what you 8 discussed with Dr. Hulcher and can you put it into 9 the context of a time frame? 10 A In general? In general of course it 11 had to do with heat transfer alternatives and what 12 our experience had been. The topic was so, so 13 common amongst many calls that I got that nothing 14 stands out as being distinct to Reynolds. 15 Q Were the discussions with Dr. Hulcher 16 during the 1970s? 17 A No. 18 Q Did they predate the 19 - 19 A They were, no. It seems to me they 20 were in '72? As best I recall, it wasn't in early 21 '70s, it was either late '71 or early '72. 22 Q Do you recall if in that time frame in 23 1972 you had any discussions with Dr. Hulcher 24 concerning the changeover to the HTM system at the 25 Massena plant at Reynolds? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064008 William Papageorge Protected Material 162 1 A Would you repeat that little part? My 2 hearing is going on me. 3 Q Let me have the reporter read it back. 4 (Last question read back by the court 5 reporter.) 6 A HTM? 7 Q (By Ms. Reimer) I mean the heat 8 transfer medium fluid system. 9 A Oh, I thought it was a special fluid. 10 Yes, that was part of our general discussion. As I 11 remember, Dr. Hulcher was really trying to assure 12 himself that the information he was getting from 13 others in Monsanto kind of all fit together. 14 Confirming that he, what he had heard from others. 15 That's the impression I got, and I also got the 16 impression he felt that since I was the guy that was 17 flying into Washington and all, whether I heard 18 anything new that was coming down the pike at him, 19 and he wanted to be tuned in on that. 20 Q Did you have any discussions with Dr. 21 Hulcher concerning the specific system up in the 22 Massena plant that used the H -- the heat transfer 23 medium fluid, the specific process that was used up 24 in Massena? 25 A I remember the reference to the pitch CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064009 William Papageorge Protected Material 163 1 and the carbon. But I did not get details as to 2 exactly how the system was designed and so on. 3 Q What do you remember about the 4 conversation you had with him about the pitch? 5 A Other than he described what they used 6 the heat transfer medium for, to soften or fluidize 7 the pitch and, so that they could process it and go 8 about their business of making anodes. 9 Q Did you have any discussions with him 10 concerning whether there were any leaks in the 11 system that was used at Massena? 12 A Leaks. I don't remember specific 13 mention of leaks. 14 Q Do you remember any general 15 discussion? 16 A In general we talked about the need to 17 prevent leakage, maintain the equipment, as soon as 18 a leak occurred, to address it immediately, take 19 care of it, either put a pan under it or put a 20 wrench through the pipe or whatever it takes to stop 21 it. We talked about those kinds of things in 22 general. 23 Q Did Dr. Hulcher ever convey to you 24 that the Massena plant had a problem with leaks or 25 the, with the wear in the system or anything of that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064010 William Papageorge Protected Material 164 1 nature? 2 A No, I did not get that impression, no. 3 Q And this was in 1971, '72, right? 4 A Late '71, '12, as best I can place it. 5 Q Did you discuss any other part of the 6 Massena plant with Dr. Hulcher? 7 A No. 8 Q Did you have any discussions with him 9 about whether the pitch ever interacted with the 10 material containing PCBs at any point in time in the 11 process? 12 A I don't remember that at all, no. 13 Q Now, I believe you stated you also had 14 conversations with Mr. Collins? Did I get that 15 right? 16 A I remember Mr. Collins' telephone call 17 where he asked for the samples. 18 Q Which, that's what you talked about 19 this afternoon with Mr. Hausman, right? 20 A Yes. 21 Q Right. Did you have any other 22 conversations with Mr. Collins? 23 A I don't recall any other. 24 Q Okay. Who was Mr. Collins? 25 A He was with Reynolds, of course, and CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064011 William Papageorge Protected Material 165 . 1 I, I jumped into a conclusion, assuming that he was' 2 a chemist, asking for samples to work in his 3 laboratory. I didn't feel I had to ask him, "Are 4 you the President," or anything like that. 5 Q Do you recall what the time frame was? 6 A The time frame? 7 Q Yeah, that he asked you for the 8 samples ? 9 A I don't remember right now, no. The 10 letter that I wrote to him responding to his request 11 ought to place the timing. 12 Q Contemporaneous with the letter, it 13 would be - 14 A Oh, yes, within 24 hours. 15 Q Okay. When you were testifying this 16 afternoon, and I believe you were talking about 17 Exhibit 27, which was a sales meeting on April 27 of 18 1971, and you were asked how Reynolds, and I don't 19 want to put words into anyone's mouth, so I'll just 20 paraphrase the background question, how Reynolds 21 reacted when they were told that there were the 22 problems with the use of PCBs and they were being 23 phased out, and you responded by saying once the 24 problem was understood, it was resolved in a prompt 25 manner. Do you recall that? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064012 William Papageorge Protected Material 166 1 A Yes. 2 Q What do you mean by "once the problem 3 was understood," and understood by whom? 4 A Well, by the people within the 5 Reynolds organization who were approached and 6 informed by Monsanto, either by mail or personal 7 contacts. 8 Q Did youknow who those people are 9 specifically? In other words, was it Dr. Hulcher or 10 was it Larry Tropea or was it somebody else, if you 11 know? 12 A Oh, gee, I don't know the names of the 13 people, no. 14 Q And when you said "once the problem 15 was understood," do you know how long it took 16 Reynolds to understand the problem? Was this 17 something that went on for a few months or - 18 A Oh, I have no feel for the timing. 19 Q Okay. Do you know if Reynolds 20 challenged Monsanto's directives in any way? Did 21 they say, well, you know, maybe this isn't exactly 22 right and there's not a problem with these, or - 23 MR. HARCKHAM: Objection. 24 A I've never been, I have no feel for 25 that. Never heard anything along those lines. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064013 William Papageorge Protected Material 167 1 Q (By Ms. Reimer) Is that something we 2 should ask Mr. Danzer? 3 A Oh, I don't know. Of course you can, 4 I just 5 Q Did I understand you correctly when 6 you said that Mr. Danzer assisted in this, in the, 7 with the customers and the process of discontinuing 8 the use of PCBs? 9 A I think we're, at least I see two 10 different issues here. One is the awareness that 11 PCBs are an environmental problem and the need to 12 prevent it from getting to the environment. The 13 other program is the notice that said starting as of 14 this day, we will no longer be able or were willing 15 to supply these PCB type heat transfer fluid. Two 16 different things. 17 Q Which one was Mr. Danzer involved in, 18 to your knowledge? 19 A He was involved with the conversion 20 program. 21 Q Thank you for clearing that up for me. 22 I'm just going to ask you a simple 23 background question. You testified that you've 24 earned a Bachelor's Degree and a Master's Degree, 25 have you also earned any type of certificates, CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064014 William Papageorge Protected Material 168 1 professional certificates of any type? I saw the 2 initials P.E. after the name on your card. What is 3 4 A Oh, Professional Engineer, I'm a 5 Registered Professional Engineer in the State of 6 Missouri, and in order to get that I had to pass an 7 examination, a written test. 8Q 9 just -- Is the P.E. a series of tests or is it 10 A I'm sorry? 11 Q To earn a P.E. do you take a series of 12 tests, or is it just one test? 13 A Mine was an all day affair, it could 14 have been a compressed series. There were different 15 documents handed to us throughout the day. Two in 16 the morning and one in the afternoon kind of 17 approach. 18 Q Did you have to take a course to study 19 for your P.E. exam? 20 A I did. I did. 21 Q Who did, who sponsored the course? 22 A The course was offered out at 23 Washington University on Saturdays, and it took 24 several Saturdays to complete. 2 5 Q When did you earn the P.E.? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064015 William Papageorge Protected Material 169 1 A About 1963 or 4. 2 Q Pardon my ignorance, but is a P.E. 3 awarded in a specific area? Like you're a 4 Professional Engineer in the area of, or is it a 5 general type thing? 6 A It's a general registration. There 7 are some caveats about what you should really be 8 practicing in and where you can use your seal and so 9 on. 10 Q And just with respect to the P.E. that 11 you earned, were there any restrictions? In other 12 words, you're not like a civil engineer, right, you 13 wouldn't be designing roads and highways? 14 A No, I wouldn't do that because I'm not 15 trained in that. 16 Q Right. You relate moretowards - 17 A Chemical engineering. 18 Q So when Mr. Hausman asked you about 19 the components and the makeup of certain Aroclors 20 and various chemicals, your knowledge was based on 21 your course of study? 22 A Yes. 23 Q Now, earlier you testified that 24 employees, when you were I believe the, in 1957 I 25 guess you were, became a plant, in charge of CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064016 William Papageorge Protected Material 170 1 engineering and maintenance at the plant? 2 A '57 -- 3 Q Is that - 4 A Yeah, I was in maintenance, either a 5 supervisor or a superintendent, and I forget the 6 exact timing. 7 Q And you said that at that time you 8 were aware that any material handled in the plant 9 should not get in waterways? Did you make that 10 statement? The material handled in the plant 11 should, there were efforts made to keep it out of 12 waterways, water streams? 13 A As a Maintenance Supervisor? 14 Q Right. That one of your things was to 15 oversee the employees and make sure that the 16 materials at the plant were handled properly and 17 that they didn't escape into the waterways? Is that 18 19 A Not as a Maintenance Supervisor. 20 Q Then when was that? 21 A That thought followed all my 22 assignments, depending on how much waste my 23 activities were generating, and as a Maintenance 24 Supervisor, we didn't generate too many 25 opportunities for leakage. The production people CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064017 William Papageorge Protected Material 171 1 were supposed to drain the systems and get it ready' 2 for us to go to work on. 3 I was involved with this group that I 4 had mentioned that supports the operations with 5 delivery of goods and utilities and all that. 6 Q Let me, let me rephrase the question, 7 okay? And I'll take it out of the time context. I 8 believe you made the statement that any material 9 handled in the plant should not get into the 10 waterways, and employees were trained for the proper 11 handling of the material to prevent that from 12 happening. 13 A Yes. 14 Q And I believe you stated that every 15 employee knew that they should take steps or efforts 16 to avoid getting the product and the material into 17 the waterways? 18 A Correct. 19 Q Okay. Why wasthat? Why were such 20 efforts made to keep material from escaping into 21 waterways ? 22 A It just strikes usthat work with 23 chemicals that we don't want to see oil slicks in 24 water, and I think I mentioned the impact it would 25 have on the community's waste treatment plant, and CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064018 William Papageorge Protected Material 172 1 you can't ignore the fact that when you dump some 2 unknown chemical and it goes to a waste treatment 3 plant where the workers down there don't know what 4 you're sending them, you may be creating some health 5 problems. You don't know what others are sending 6 into that plant, and the mixing may create further 7 problems, so there's always this thought in mind. 8 In addition to upsetting the operation you can 9 introduce some health problems, and you can't ignore 10 the fact that economically it's wise not to lose 11 stuff down the sewer. 12 Q What if the sewer drain and waterways 13 led to a river or an ocean, not to a waste water 14 treatment plant? 15 MR. HARCKHAM: I object. I don't know 16 what you're asking him about, it's vague and 17 ambiguous. 18 A Well, we at Monsanto believe that you 19 cannot dump into the waterways because you don't 20 want fish kills, for example. You don't want 21 children swimming or wading in contaminated waters. 22 It just isn't good, not a good neighbor when you do 23 that to the community that you're operating in. 24 That's another thought that occurs to us. 25 Q (By Ms. Reimer) Is there anything CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064019 William Papageorge Protected Material 173 1 else you'd like to add? 2 MR. HARCKHAM; Objection. 3 A I don't know how to express it in 4 words except that this is perceived as being an 5 irresponsible act, if you just don't care and flush 6 it down the sewer. 7 Q (By Ms. Reimer) Okay, now, when you 8 say "it," are you referring to, let's say, materials 9 that have PCBs in it? 10 A Any material. PCBs included. 11 Q Whether it's PCBs or chlorides or 12 cyanides or fluorides or those chemical things? 13 MR. HARCKHAM: Objection. 14 A Even the materials you might perceive 15 as innocuous, they still shouldn't be flushed down 16 the sewer. 17 Q (By Ms. Reimer) Could I direct your 18 attention to Exhibit 2? 19 A Exhibit 2? 20 Q Yes. Now, I believe you testified 21 that you had seen documents like this one, not this 22 one in particular, but you had seen documents of 23 this nature? 24 A Yes. 25 Q Is that correct? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064020 William Papageorge Protected Material 174 1 A Yes . 2 Q And when you were employed by Monsanto 3 starting in 1951, I believe? 4 A Yes . 5Q 6 this? Monsanto generated documents like 7 MR. HARCKHAMj Objection. 8 Q (By Ms. Reimer) Of this nature, and 9 they did that through the course of your tenure at 10 Monsanto, correct? 11 A Correct. 12 Q And I believe you testified that this 13 particular document, to the best of your knowledge, 14 was passed around to the list on page 2? There's a 15 list of people it was distributed to, but that it 16 also could have been distributed to customers of 17 Monsanto? 18 A Yes. 19 MR. HARCKHAM: Objection, first of all 20 I object, I think it mischaracterizes earlier 21 testimony, and there's no foundation for the 22 underlying question. 23 Q (By Ms. Reimer) Well, the record will 24 speak for itself. Attached to the document on the 25 second to last page is an appendix. Do you see CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064021 William Papageorge Protected Material 175 1 that ? 2 A I see it. 3 Q Is it your understanding that the 4 appendix would also be distributed to customers of a 5 document of this nature describing, this particular 6 one describes a Monsanto drawing from the phosphate 7 division for the detailed construction of a storage 8 tank for Aroclor 1254? 9 MR. HARCKHAM: Objection, lack of 10 foundation. 11 Q (By Ms. Reimer) While you were 12 employed by Monsanto through from 1951 through, I 13 believe you said 1986, so during your tenure, were 14 documents like this also prepared and disseminated 15 to the general public, customers? 16 MR. HARCKHAM: Objection, lack of 17 foundation. 18 A Yes, on a perceived need basis. It 19 isn't for every chemical, for every tank or, it does 20 change, but the intent was the same. 21 Q (By Ms. Reimer) Do you have any 22 knowledge as to whether Monsanto ever distributed a 23 document of this nature, not this particular one but 24 something like this, to the people up at Reynolds? 25 MR. HARCKHAM: Objection, lack of CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064022 William Papageorge Protected Material 176 1 foundation. Vague and ambiguous. 2 Q (By Ms. Reimer) Well, the first 3 question is do you have any knowledge. 4 A I don't have personal knowledge. 5 Q Who would have that type of knowledge? 6 Who is responsible for passing out this kind of 7 information when the requests were received? What 8 department or group or - 9 A Primarily the marketing representative 10 out in the field who calls on the customers with his 11 briefcase full of brochures and so on. 12 Q From 1951 to 1960, do you know who the 13 marketing representative of Monsanto was with 14 responsibility for Reynolds? 15 A I don't know that. 16 Q Do you know that for any period of 17 time during your tenure at Monsanto? 18 A No, golly. Unh-uh. I just don't 19 remember. 20 MS. REIMER: Thank you very much. 21 That's all I have. 22 THE WITNESS: Thank you. 23 (An off the record discussion was held 24 at this time.) 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064023 William Papageorge Protected Material 177 - 1 EXAMINATION BY ` 2 MR. HARCKHAM : 3 Q Mr. Papageorge, my name's Finley 4 Harckham, I' m representing Reynolds Metals in this 5 action and I 'd like to ask you a number of 6 questions. Just so we're all clear, it's 5 now, I 7 imagine I'11 be done probably in a half an hour to 8 an hour, do you want to continue with this at this 9 time? 10 A Sure. Yes. I'm ready. 11 Q I'd like to mark as Exhibit 36 a 12 multipage document with Bates numbers REY 001424 13 through 29. 14 (Defendant's Deposition Exhibit 15 Papageorge 36 marked for identification by the court 16 reporter.) 17 A I have scanned the exhibit. 18 Q (By Mr. Harckham) Do you recognize 19 this document? 20 A I do. I've seen it before. 2 1 Q Do you recall when you, when you first 22 saw it? 23 A Not vividly, no. It's just one of 24 hundreds of documents that are similar. 25 Q Okay. Do you know, was this, do you CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064024 William Papageorge Protected Material 178 1 know whether you saw this document in connection 2 with your work for Monsanto before 1970? 3 A Yes. 4 Q Do you know what this document was 5 used for? 6 A It was used to promote the use of 7 Monsanto's Aroclors and heat transfer systems. 8 Q And do you know to what groups or 9 categories of people this document was disseminated? 10 A Of course our marketing team, and in 11 turn their customers, both potential and current 12 customers received this. 13 Q Now, this document is dated September, 14 1949. Do you know how long it was in use by 15 Monsanto? 16 A Not specifically. It was at least ten 17 years, but I don't recall exactly when it was 18 revised or reissued. 19 Q Okay. On the first page, the very 20 first line references Aroclor 1248, and then the 21 second paragraph begins, "This bulletin describes 22 the physical properties of Aroclor 1248," and then 23 it goes on. Is it a -- we can strike that. 24 I'd like you to look, please turn to 25 page that's REY 1427? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064025 William Papageorge Protected Material 179 1 A 27? 2 Q 1427, yeah, in the lowerright hand 3 corner that's - 4 A I have it. 5 Q Okay. Do you see on the left hand 6 side of the page there is a, a heading, Freedom From 7 Toxicity Hazard? 8 A Yes. 9 Q Now, this, thenthere's a, there is a 10 series of four paragraphs below that. Have you seen 11 that language in other Monsanto documents? The 12 language that appears in these paragraphs below 13 Freedom From Toxicity Hazard? 14 A Yes. 15 MR. HAUSMAN: Object to the form of 16 the question. You're referring to the whole passage 17 or a specific part? 18 MR. HARCKHAM: The whole, the whole 19 passage. 20 A I have seen similar wording. In fact, 21 one of the exhibits from Dr. Kelly has that. 22 Q (By Mr. Harckham) Okay. And was, was 23 there a period of time that you recall in which 24 Monsanto promoted Aroclor 1248 as being free from a 25 toxicity hazard? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064026 William Papageorge Protected Material 180 1 MR. HAUSMAN: Object on foundation. 2 A Yeah, the promotion involved not only 3 the material but the use in a heat transfer system 4 and in, under the proper conditions of use, the 5 toxicity hazard is substantially reduced, really 6 eliminated. 7 Q (By Mr. Harckham) I'd like to mark as 8 Exhibit 37 a multipage document with Bates number 9 MONS 078201 through 214. 10 (Defendant's Deposition Exhibit 11 Papageorge 37 marked for identification by the court 12 reporter.) 13 MS. RUTTER: Do you have a copy of 14 that for me, Mr. Harckham? 15 MR. HARCKHAM: I'm sorry. This is one 16 of the ones that we sent out before, but I do have 17 other copies. Here. 18 MS. RUTTER: Sent out for copying? 19 Thank you. 20 A I have scanned the article. 21 Q (By Mr. Harckham) Do you recognize 22 this document? 23 A It's been a while, but I, as I read it 24 or scanned it, it brought back some recollections, 25 yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064027 William Papageorge Protected Material 181 1 Q First on the front page, it's kind of 2 hard to read the title. Can you take a shot at 3 that? 4 A It's Aroclor Resins and Plasticizers 5 for Chlorinated Rubber. 6 Q And then down below that it says 7 "Technical Bulletin" - 8 A "Technical Bulletin," and I just 9 cannot read the bulletin number. 10 Q Okay. Then it appears to say "May, 11 1959" below that, correct? 12 A I see that, yes. 13 Q Now, up, up at the top there is in 14 handwriting the word "obsolete." First of all, when 15 is it that you saw this document for the first time, 16 do you recall? 17 A I don't recall. 18 Q Was it during the period prior to 19 1970, do you know? 20 A I don't recall specifically, but I was 21 aware of many of these Aroclor brochures while I was 22 at the Anniston Plant, and that's as close as I 23 could get to the timing. 24 Q Okay. Now, this says "Technical 25 Bulletin" on the front and it's got a number. Was CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064028 William Papageorge Protected Material 182 1 there a series of Technical Bulletins published by 2 Monsanto? 3 A Oh, yes. Yes. 4 Q What was the purpose of publishing 5 these bulletins? 6 A Primarily to supply information to 7 customers and potential customers of Monsanto 8 products. 9 Q Do you know whether, whether these 10 bulletins were directly given to customers? As 11 opposed to the information, as opposed to being 12 given to Monsanto employees who then would 13 communicate with customers? 14 A Well, it varied with the Business 15 Director of the product involved. Some them would 16 have mailings when the brochure was just printed and 17 revised. Others would take the approach of sending 18 it to their field representatives, and the field 19 representative was expected to drop off the copies 20 personally and have a discussion with someone at the 21 site that he visited. 22 So it varied, but in any event, the 23 intent was to get it into, out there in the hands of 24 people who might find it interesting. 25 Q In 1959, did Aroclor resins and CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064029 William Papageorge Protected Material 183 1 plasticizers contain PCBs? ' 2 A Some of them. Because some of the 3 Aroclors were not chlorinated biphenyls. They were 4 not PCBs. 5 Q But some did contain PCBs? 6 A Yes. 7 Q I'd like to mark as Exhibit 39, 38, 8 I'd like to mark as Exhibit 38 a multipage document 9 bearing Bates numbers REY 000875 through 890. 10 (Defendant's Deposition Exhibit 11 Papageorge 38 marked for identification by the court 12 reporter.) 13 A I have scanned the exhibit. 14 Q (By Mr. Harckham) Okay. Do you 15 recognize this document? 16 A Yes, I have seen itbefore. 17 Q Do you recall roughly when you first 18 saw this document? 19 A Sometime about the period '65 to '70. 20 Q Do you know when this document was 21 generated? I didn't see a date, but if there's 22 anything about it that -- well, let me, let me ask 23 you, refer you to page 888, page at the bottom? 24 A 888 . 25 Q Got that page? REY 888 in the lower CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064030 William Papageorge Protected Material 184 1 right. 2 A I see it. 3 Q Okay. Do you see under the heading 4 Take Ordinary Personal Care, it says, "Transformer 5 askarel has been made, handled and used for over 30 6 years without causing toxic or other ill effects." 7 Do you know when transformer askarel was first made? 8 A 1929 was the first application. 9 Q The year, with this reference to 10 askarel having been made and used for over 30 years, 11 does that mean that, does that date this document in 12 at least 1959 if that - 13 A The late '50s. 14 Q What, what was this document used for, 15 do you know? 16 A It was intended for the users and 17 owners of transformers with PCB type dielectric 18 fluids in them, especially for those who did their 19 own servicing of their transformers instead of 20 having someone come by and do it for them. It was 21 also intended for those service companies that were 22 involved in transformer maintenance, upkeep. 23 Q And when, when you saw this document 24 you think in the later part of the 1960s, it was in 25 use at that time by Monsanto? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064031 William Papageorge Protected Material 185 1 MS. REIMER: Objection. 2 A Yes . 3 Q (By Mr. Harckham) So this document 4 had not been superseded by another document at that 5 time? 6 MS. REIMER: Objection. 7 MR. HAUSMAN: Without foundation. 8 A I don't recall any document that 9 covered this subject that superseded this document. 10 Q (By Mr. Harckham) And just so I'm 11 clear, this was a document that was given to 12 customers of Monsanto who used askarel; is that 13 correct? 14 MS. REIMER: I'm sorry, could you read 15 that back? I missed the question. I'm sorry. 16 Q (By Mr. Harckham) The question was is 17 this a document that was given to customers of 18 Monsanto who used askarels? 19 A It was given to customers of Monsanto 20 as well as customers of Monsanto's customers. 21 Q So for example, if GE sold a 22 transformer to customer X, this would go to customer 23 X as well as going to GE? 24 A If customer X was on Monsanto's list 25 of entities that purchased PCB fluids from Monsanto. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064032 William Papageorge Protected Material 186 1 Q Okay. I understand. I'd like to mark 2 as Exhibit 39 a two page document bearing Bates 3 numbers MONS 098018 and 19. 4 (Defendant's Deposition Exhibit 5 Papageorge 39 marked for identification by the court 6 reporter.) 7 Q (By Mr. Harckham) The document 8 appears titled Data Sheet for Toxicological and Safe 9 Handling Information. 10 A I have read the document. 11 Q Do you recognize this document? 12 A I do not. 13 Q Okay. You see in the bottom of the 14 second page this document is dated March 31, 1961, 15 and it indicates that information was furnished by 16 Mr. Elmer P. Wheeler, Assistant Director, Medical 17 Department, Monsanto Chemical Company. I believe 18 you indicated before youknow Mr.Wheeler? 19 A Yes. 20 Q Turning back to page, the first page 21 of this document, Item No. 4 says, of the form says, 22 "Procedure in Case of Breakage or Leakage," and then 23 the, what appears to be typed in is, "Clean up as 24 with any lubricating oil or hydraulic fluid." 25 Now, you understand this to be a CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064033 William Papageorge Protected Material 187 1 reference to Pydraul 150, which is listed up at the 2 top of this document? 3 A That's my understanding, yes. 4 Q Now, as of March 31, 1961 -- strike 5 that. 6 In 1961 did you have an opinion or a 7 practice as to how Pydraul should have been cleaned 8 up in the event of breakage or leakage? Breakage of 9 equipment or leakage of equipment? 10 MR. HAUSMAN: Objection, foundation. 11 MS. REIMER: Objection. You mean 12 Pydraul 150 or any kind of Pydraul? 13 MR. HARCKHAM: We'll say Pydraul 150. 14 A In 1961, the perception and 15 understanding was such that the advice typed there 16 in line 4 was appropriate. 17 Q (By Mr. Harckham) As Pydraul 150, in 18 1961, did that contain PCBs? 19 A Yes. 20 Q In 1961, in terms of your 21 understanding at that time, was this same procedure 22 appropriate with respect to any PCB containing 23 fluids? 24 MS. REIMER: Objection. 25 A Yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064034 William Papageorge Protected Material 188 1 Q (By Mr. Harckham) I'd like to mark as 2 Exhibit 40, is it? A two page document bearing 3 Bates numbers MONS 071293 and 294. 4 (Defendant's Deposition Exhibit 5 Papageorge 40 marked for identification by the court 6 reporter.) 7 Q (By Mr. Harckham) Mr. Papageorge, 8 have you had a chance to review Exhibit 40? 9 A I have reviewed it. 10 Q Do you recognize this document? 11 A I have never seen it before. 12 Q Okay. Do you see in the bottom of the 13 second page it's dated January 15, 1963, and like 14 the last exhibit, it indicates that information was 15 furnished by Mr. Elmer P. Wheeler of Monsanto. In 16 1963, now, actually let me refer you back now to the 17 front page, where you see this document is dealing 18 with Pydraul AC? 19 A I do. 20 Q In 1963 did the Pydraul AC contain 21 PCBs ? 22 A Yes. 23 Q And you see under No. 4, it says, 24 "Procedure in Case of Breakage or Leakage: Clean up 25 as with lubricating oil"? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064035 William Papageorge Protected Material 189 . 1 A I do see that. 1 2 Q In 1963, was it your understanding 3 that that was an appropriate way to clean up Pydraul 4 AC that may have spilled? 5 MR. HAUSMAN: I object on foundation 6 and also vagueness. 7 A Based on the knowledge of 1963, that's 8 an appropriate statement. 9 Q (By Mr. Harckham) And was that an 10 appropriate statement based on 1963 knowledge with 11 respect to any PCB containing fluid? 12 A Yes. 13 MR. HAUSMAN: I'll object to the 14 question on breadth and vagueness grounds. 15 Q (By Mr. Harckham) I'd like to mark as 16 Exhibit 41 a multipage document with Bates numbers 17 REY 000919 through 950. 18 (Defendant's Deposition Exhibit 19 Papageorge 41 marked for identification by the court 20 reporter.) 21 Q (By Mr. Harckham) And this document 22 on the front says, "Monsanto, Monsanto Askarel, 23 Inspection and Maintenance Guide, Revised September, 24 1963"? 25 A I have scanned the exhibit. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064036 William Papageorge Protected Material 190 1 Q Do you recognize it? 2 A Yes. 3 Q Do you know what, is this a Monsanto 4 publication? 5 A It is. 6 Q Do you know what it was used for? 7 A It was used to again share with 8 customers of Monsanto, or the customers of 9 Monsanto's customers who were involved with PCB 10 containing dielectric fluids, and it relates to the 11 maintenance of electrical equipment. 12 Q Do you know what, over what time 13 period this document was disseminated by Monsanto? 14 A Not specifically. I know that 15 periodically this subject was addressed in revised 16 issues of this type of brochure. 17 Q Do you know whether this brochure was 18 revised before 1970? 19 A Yes. Yes. 20 Q Do you know howmuch earlier than 21 1970? 22 A I really don't. 23 MR. HARCKHAM: Can we go off the 24 record for just a minute? 25 (An off the record discussion was held CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064037 William Papageorge Protected Material 191 1 at this time.) 2 Q (By Mr. Harckham) Mr. Papageorge, do 3 you know when Monsanto first informed its customers 4 of a possible environmental hazard associated with 5 PCBs ? 6 A Monsanto in March of 1969 informed its 7 customers of huge volumes of PCBs, so it was a, it 8 was not all customers, it was a, a list of those who 9 purchased the most. They were informed of the 10 evolving evidence as it existed as of March 1969. 11 That was the first attempt to communicate the PCB 12 environmental issue. 13 Q Did that group include Reynolds 14 Metals, do you know? 15 A I don't believe so, no. 16 Q Were, was that group in March of '69 17 told, if you know, that there was an environmental 18 problem associated with PCBs, or was it just told, 19 I'm trying to get a sense of what they were told 20 about the situation. Were they told there was a 21 problem or were they told there were allegations or 22 what, what were they told? 23 MS. REIMER: Objection. 24 A The, as I recall the letter, it 25 informed them of the recent findings by some CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064038 William Papageorge Protected Material 192 1 laboratories throughout the world that a material 2 that was PCBs -- at that time it was not referred to 3 as PCBs, it was polychlorinated biphenyls -- were 4 found in samples taken from the environment, that 5 care should be taken not to let the PCBs escape to 6 the environment, and in essence, we'll let you know 7 more as we learn more. That's what that particular 8 letter indicated. 9 Q (By Mr. Harckham) Okay. What was the 10 next communication from Monsanto to its customers, 11 do you know? 12 A The next formal communication took 13 place in February of 1970 to all customers on record 14 with Monsanto of PCBs. 15 Q Let's mark as Exhibit 42 a two page 16 document bearing Bates numbers MONS 090210 and 211. 17 I don't know if the copies have already been given 18 out to everybody, or did you - 19 MS. RUTTER; I think I put them all 20 over there. 21 MR. HARCKHAM; I'm going to take off 22 what was stapled to the last page of this, numbered 23 non-consecutively. 24 MS. REIMER: Is it just a two page 25 document ? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064039 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 193 MR. HARCKHAM: I don't know whether this additional thing belongs or not, but since it's not in the same Bates range, I'm taking it off for purposes of this exhibit. (Defendant's Deposition Exhibit Papageorge 42 marked for identification by the court reporter.) A I've scanned the document. Q (By Mr. Harckham) Do you recognize it? A I do. Q Is this the letter you just referred to, February, 1970, to Monsanto's customers? A This is one of similar letters, and this particular one addresses the hydraulic fluids sold by Monsanto that contained PCBs. Q Was there more than one form of letter that was sent out in February of 1970? A It's, I don't know about the use of the word "form." The subject was essentially the same except that for the dielectric use, it referred to the dielectric application. For the heat transfer use, the different one, and for the, what Monsanto called the plasticizer use, which was in essence miscellaneous use, had another version. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064040 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 194 Q Okay. Did you participate in drafting the letters in their different versions? A I did. Q Do you see, well, can you, can you read the letter and indicate what sections of this, if any, were identical or substantively identical among the different letters? MS. REIMER: Objection. A I don't propose to recall each and every word, but -Q (By Mr. Harckham) Right. A The first paragraph for sure. My reason for hesitating, I, I don't know how to include in my comments or answer the reference to the dielectric, the askarels that we talked about earlier. Q Maybe I can, maybe I can shortcut this. Do you see the section, the paragraph that begins on the first page, "We would like to point out the following additional facts," and then No. 2 says, "PCBs with a chlorine content of less than 54 percent have not been found in the environment and appear to present no potential problem to the environment." Was that paragraph or that message conveyed in each of the letters, if you know? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064041 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 195 - MS. REIMER; Objection. ' A I'm trying to, I can't find it yet. Q (By Mr. Harckham) Bottom of the first page, numbered paragraph 2? A Oh, okay. All right. MS. RUTTER: By your question - A That was included in all of the versions. Q (By Mr. Harckham) Of the February, 1970, letter? MS. RUTTER: Yeah, I was just trying to confirm on the record that you're talking about February of 1970. Q (By Mr. Harckham) Right. And that's what you understood me to be talking about, was all versions of the February, 1970, letter? A Yes, that's my understanding. Q And was that your under -- and is the information stated in paragraph 2 here, was that your understanding in February of 1970? A Correct. Q Just so I'm clear, Aroclor 124 -- does Aroclor 1248 have a lower, have a chlorine content of less than 54 percent? A Yes. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064042 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 196 MS. REIMERl Objection. Q (By Mr. Harckham) It has a chlorine content of 48 percent; is that correct? A Yes. Q Mr. Papageorge, when did Monsanto first indicate on its product labels that there were potential, there was a potential environmental hazard associated with PCBs? MS. REIMER: Objection. MR. HARCKHAM: Your basis? MS. REIMER: Foundation. Q (By Mr. Harckham) Do you know when Monsanto first indicated on labels, its product labels that there was a potential environmental hazard associated with PCBs? A I do. Q How do you know that? A Well, I'm really the one that worded the paragraph that was eventually placed on a, a label that was affixed to the containers of material that was shipped out. Q Okay. And do you recall when that label was affixed to containers, first affixed? A The labeling program was implemented in May of 1970. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064043 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 197 Q I'd like to mark as Exhibit 43 a one page document bearing Bates number MONS 098183. (Defendant's Deposition Exhibit Papageorge 43 marked for identification by the court reporter.) MS. RUTTER; Am I supposed, let's see, I think I already have a copy of that. MR. HARCKHAM; I think I gave out copies of all these. A I have reviewed the document. Q (By Mr. Harckham) Do you recognize this document? A I do. Q Is this a memorandum that was authored by you? A Yes. Q And circulated to the individuals listed at the top on orabout April 13, 1970? A Yes. Q In the middle of the page there is a, there's quoted language for a paragraph to be added to the existing, it says to existing wording. Is that, is that language to be added to the labels for Aroclor packages? Is that what you were referring to here in the letter? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064044 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 198 A Yes. It's, the next paragraph says which of the packages we had in mind at that moment. Q Okay. A Which was a partial list, really. Q Okay. And do you recall whether the quoted language here is in fact the language that was placed on the labels in May of 1970 that you referred to earlier? A There was an additional word, the word "extreme" was added before the word "care." MS. REIMER: Can I just note for the word that the document says there's an attachment but the attachment isn't attached? On the bottom left? MR. HARCKHAM: Okay. Okay. It appears that the attachment was going to be a copy of the typical label, right? All right. That's not a question. MS. REIMER: Not a big deal. Q (By Mr. Harckham) I'd like to refer you back to Exhibit 31, please, that was marked earlier? A I have it. Q You have it there? I'd like to refer you to the first page, the second paragraph, the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064045 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 199 second sentence that begins, "Our studies to date have confirmed our suspicions that the higher chlorinated biphenyls are more persistent than those containing less chlorine." Do you recall which, which chlorinated biphenyls by number you were referring to as the higher chlorinated biphenyls? A That's the 1254 and higher. Q In 1970 what, what were the different uses of Aroclors? You mentioned heat transfer, fluid, dielectric fluid, hydraulic fluid, what were the other uses at that time? A As an ingredient in paints and varnishes and lacquers, an ingredient in adhesives, an ingredient in caulking, as a plasticizer in various plastic, and we saw earlier chlorinated rubber application. The carbonless copy paper that was popular back then had PCBs in it. It was involved in some printing inks. That's all that comes to mind at the moment. Q And with respect to heat transfer applications, was, were Aroclors used as a heater for buildings, heating fluid for buildings? A Yes. Q They would go in a radiator? CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064046 William Papageorge Protected Material 200 1 A Yes, some buildings, yes. 2Q 3 in 1970? And it was still used for that purpose 4 A Yes. 5 Q And was Aroclor used in food 6 processing? 7 A Yes. 8 Q In what ways, do you know? 9 A Primarily as a heat source to heat 10 cooking oils that are used in, say, potato chips and 11 fried fish and fried chickens, those kinds of 12 applications. 13 Q When you were in the plant in Alabama 14 in the late 1960s, did that plant have a waste water 15 effluent stream? 16 A Yes. 17 Q Was there any testing done of that 18 stream during the period you were Plant Manager 19 there to determine whether there were PCBs in that 20 waste water effluent? 21 A The analytical methodology available 22 then would never have picked up the small amount of 23 PCB in that water. The PCB, being heavy, would sink 24 to the bottom of the settling pond and combine with 25 the limestone bed that it was exposed to. Then that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064047 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 201 - bed, along with the PCBs, would be bulldozed out and taken to a landfill. So the water that left would be the water that sort of decanted off of this pond, and there was no methodology that would have picked up the PCBs in that water. Q Did there come a time later when you learned that there were PCBs in that water? A Yes. Q When was that? When did you learn that? A I, the best I can say, about 1970, after, after getting the methodology in place and the instruments and taking samples and confirming it, about 1970s. Q How much, do you know how much PCB was released in that waste water? A No, I don't. Q We have looked at a couple of documents which, well, let me be specific. Let me refer you back to Exhibit 42, please. You see that, and again, back, the numbered paragraph 2 at the bottom of the first page? A Yes. Q The sentence that says,"PCBs with a CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064048 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 202 chlorine content of less than 54 percent have not been found in the environment and appear to present no potential problem to the environment," for how long was that your understanding? A Oh, I would suggest that it lasted for about a year. During 1970 more and more information was coming in, so by the end of '70, early '71, the lower chlorinated types were found in samples near the users' plants. As distinguished from the pine tree needle and the child's hair approach. Q Right. Did you communicate that information to Monsanto's customers? By you I mean Monsanto. A Not in a formal letter like this. That was passed on in the normal course of a followup on the PCB issue and used the, we used the marketing people as our primary spokespeople. Q And if I understand you, is that, would that have begun in 1971? A Late '70 for sure, and early '71, yes. Q And do you know if that was communicated to Reynolds Metals? A I have an understanding that it was. But I personally did not tell them myself. Q What is your understanding of how it CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064049 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 203 was communicated to Reynolds? A It seems that I, I recall that the marketing team out of New York area calling on Reynolds Metals, along with other customers, not specific, not just, it's not isolated, just Reynolds Metals, but they called on them and did mention the latest, the status of the findings of all these laboratories. That was being done so, so frequently with customers that it became one of, nothing stands out any more in my memory. Everybody was in on the information chain. Q In your job beginning in 1970 as the Manager for Environmental Control, did you have an occasion to give advice to any plant personnel either at Monsanto plants or other plants as to what to do in the event of a spill of a PCB fluid onto a concrete floor? A That was a frequently discussed subject, yes. Q What was your, did you give advice as to how to handle that? A I would give him what Monsanto was doing. If it ended up on the floor, the primary objective was to contain it so you maintain some control of it, to avoid the impulse of grabbing the CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064050 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 204 hose and hosing it down the sewer, to use some absorbent to capture it, and then to take that material, whether it be sawdust or clay or sand, take it to an approved burial site. The approved sites, of course, varied from county to county and state to state at the time. The emphasis that I personally placed was to avoid using detergents to scrub your floor clean, and where possible, block your sewers and preferably put curbing so that if there is a spill, that it's contained in this miniature bathtub so you can manage to control it more effectively. That's the kind of discussion that came up many times. Q I'd just like to follow up on some questions that were asked before about when Monsanto stopped producing PCB materials. Can you just give a sort of a short chronology of, just so we, I'm sure we have the complete story as to when the different PCB containing materials were discontinued? A Shall I cover all of the uses, or just those of interest to you? Q I'd like all of them, please, if you recall. A All of them? I'll try. My dates will CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064051 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 205 not be pinpoint accurate, but. As of August 30, 1970, all sales to these uses that I am going to call miscellaneous uses, the paint, the varnish, the caulking, were terminated. Q Okay. If I can interrupt you for a second, were those the open uses you referred to? A Yes. Q In other words, not within a close, the material was not used within a closed system? A That is correct. The carbonless copy paper took some technical effort to find a replacement, so that didn't terminate until early 1971, about six months later. Starting in '71 also, as I recall, the, the use in heat transfer systems relating to food was addressed and it was decided to stop selling to a food applications and to convert those units with a non-PCB replacement. In late '71, '72 period the program for finding alternative hydraulic fluids was in place and the PCBs were replaced initially, because we wanted quick action, with polychlorinated terphenyls, which was the other member of the Aroclor family. Q Was this, you're saying it was late CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064052 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 206 '71 or '72, when were they replaced in terms of your production? A I think it was '71, '12 for a period, about that time. There were some successes in finding a phosphate esther for hydraulic fluids, and therefore, Monsanto was able to drop the use of chlorinated anything in its hydraulic fluids about, about the middle of '71. See, I'd have to look up some documents to get those dates exact, but that was kind of the transition. So we ended up really with hydraulic fluids being replaced by phosphate esther type formulations, the heat transfer fluids essentially were successful in the food application conversions. The program was started then in later '71 to convert all heat transfer systems. So '72 was an active year for the conversion of heat transfer systems to the replacement fluids that were not fire resistant. Now, this involved, of course, many technical changes in facilities, sprinkler systems, dilute systems, and so on. The dielectrics, a lot of effort was placed by Monsanto and others to find a replacement fluid, and the efforts were not successful. So the dielectrics application continued up until Monsanto CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064053 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material just stopped selling PCBs in '77. 207 Q In that time period of 1970 to 1977, did any government entity ever ban the sale of PCB fluids for any application? MS. REIMER: Objection. MR. HARCKHAM: Basis? MS. REIMER: Foundation. A No. Q (By Mr. Harckham) If they had done so, did you make it your business to know what the government's position was during that time period about the sale of PCBs? A Oh, yes. That was one of my major projects was to get some guidance with government, didn't see fit to do so. They condoned or encouraged the continued use in electrical equipment. Other than that, I found the government was not very helpful. That's my personal evaluation. Q They didn't ban the use for any application at that time? A They did not ban until they passed the Toxic Substances Control Act in 1976? I think that was the date. And that act specifically mentioned PCBs and called for a termination of manufacture and CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064054 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 208 sales in 1979. But Monsanto was able to terminate in 1977. Q When you were a Plant Manager in the 1960s, did your plant use chemicals produced by other manufacturers, manufacturers other than Monsanto? A Oh, yes. Yes. Q Did you expect at that time that if there was a potential hazard associated with those materials, that the manufacturer would bring that to your attention? A That was the - MS. REIMER: Objection. THE WITNESS: That was the expectation, yes. MR. HARCKHAM: Did you object? MS. REIMER: Yeah, I did. MR. HARCKHAM: What's the basis? MS. REIMER: Vagueness, "potential hazards," what does "potential hazards" mean to him and you? I mean - MR. HARCKHAM: If, for example, there was a problem with a potential hazard of toxicity associated with a chemical that you purchased in that time period, would it be your expectation that CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064055 William Papageorge Protected Material 209 1 the manufacturer would provide you with information 2 about that hazard? 3 MS. REIMER: Objection. 4 THE WITNESS: That was the practice in 5 the industry. You expected some guidance. If you 6 didn't get it, you asked for it. 7 MR. HARCKHAM: Why don't we go off the 8 record for a minute. 9 (An off the record discussion was held 10 at this time.) 11 MR. HARCKHAM: Mr. Papageorge, I have 12 no further questions at this time. Thank you very 13 much. 14 THE WITNESS: Thank you. 15 EXAMINATION BY 16 MR. HAUSMAN: 17 Q Mr. Papageorge, I just have a few very 18 brief redirect questions, then I think we can all go 19 home . 20 Could you refer back to Exhibit No. 21 39, please? 22 A 39? 23 Q Yes. 24 A I have it. 25 Q Okay. Mr. Harckham referred you to CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064056 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material 210 Entry No. 4? A Yes. Q You see that, where he asked you, I think he used the word "appropriate," and that was whether it was appropriate to clean up Pydraul 150 leaks or breaks as with any lubricating oil or hydraulic fluid. Do you recall that testimony? A I do. Q Let me ask you this. In the time period of 1961, were there, was it appropriate to clean up lubricating oils and hydraulic fluids? A Well, I can only speak for Monsanto's practice, we would never flush lubricating oil or baby oil, even, down the sewer. Q Okay. Would you consider it appropriate to allow lubricating oil or hydraulic fluid to drain into a body of water? A No. Not if you could avoid it. Q Would you consider it appropriate to allow lubricating oil or hydraulic fluid that had been spilled onto the ground to remain there without any cleanup? A Are you talking about a pool of it or a stain? Q A stain. CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064057 William Papageorge Protected Material 211 1 A A stain? Monsanto would remove it if 2 it was a situation where storm waters would wash 3 through there and transfer that soil and move it on 4 into a water stream. If it was not that type of 5 situation, just leave well enough alone. Don't 6 disturb it because you're going to create problems. 7 Q Okay. If you could refer to Exhibit 8 4 2, please? 9 A 42? 10 Q Yes. 11 A I have it. 12 Q Mr. Harckhamreferred you to Entry No. 13 2 at the bottom of the page? 14 A Yes. 15 Q Okay. Is yourunderstanding of the 16 statement under paragraph No. 2 that the reason that 17 PCBs with chlorine content of less than 54 percent 18 did not present a potential problem was simply 19 because that had not to date been detected in the 20 environment? 21 A Correct. 22 Q Okay. At any time either before this 23 letter or after this letter were you aware of 24 Monsanto communicating to any of its customers that 25 it was okay to release PCBs with less than 54 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064058 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 William Papageorge Protected Material percent into the environment? 212 A No. It was never okay to release even baby oil, if you want to make a comparison. Q Okay. Thank you. Final question, are you being reimbursed in any way for your testimony today? A I'm sorry? Q Are you beingreimbursed in any way for your testimony today? A No. Q No consulting fees or anything? A No, not in this situation, no. Not for a fact witness. MR. HAUSMAN: Okay. Thank you very much. done. MS. REIMER: I think we're finally MS. RUTTER; He'll read and sign. (TIME NOTED; 6;12 P.M.) CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064059 William Papageorge Protected Material 213 1 CERTIFICATE 2 STATE OF ILLINOIS 3 4 COUNTY OF WILLIAMSON 5 I, TARA SCHWAKE, Registered 6 Professional Reporter and Notary Public within and 7 for the State of Illinois, do hereby certify that 8 the foregoing deposition of WILLIAM PAPAGEORGE was 9 taken before me on the 16th day of July, 1997; 10 That the said witness was duly sworn 11 before the commencement of the testimony; that the 12 said testimony was taken stenographically by me and 13 then transcribed. 14 I further certify that I am not 15 related by blood or marriage to any of the parties 16 to this action nor interested directly or indirectly 17 in the matter in controversy; nor am I in the employ 18 of any of the Counsel in this action. 19 IN WITNESS WHEREOF, I have hereunto 20 set my hand this 28th day of July, 1997. 21 22 OFFICIAL SEAL Tara Riley Schwake 23 Notary Public, State Of Illinois My Commission Expires 8/25/97 24 TARA SCHWAKE 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064060 William Papageorge Protected Material 214 1 2 3 I, WILLIAM PAPAGEORGE, 4 have read the foregoing transcript and hereby 5 certify that it is a true and accurate transcript of 6 my testimony. 7 8 9 WILLIAM PAPAGEORGE 10 11 nd subscribed to before me 12 13 14 15 NOTARY PUBLIC-STATE OF MISSOURI 16 ST LOUIS COUNTY MY COMMISSION EXPIRES AUG. 18,2000 17 18 19 20 21 22 23 24 25 CARDINAL REPORTING COMPANY (212) 227-9490 WATER PCB-SD0000064061 Corrections: Page - Line Pa etc oc) Line, to pa go /6/ l-tne,, / 3 PP C/& ZoQ l-- m Cs ^ / Word or phrase: n t c-in lorob^^z.e.-'i Corrected to: D-e n La cJn loso oh c ,n o I Word or phrase: Corrected to: / m p rt -56/ a ^______________ t tanp re 6 6/ i>e-______________ Word or phrase: Corrected to: di I <y d e (. u __________________ _________________ Word or phrase:__________________________________ Corrected to: Word or phrase: Corrected to: . 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Vol. 1, July 16, 1997 0 DoOOOl 1 -f S: 2-1 000062 M [ .2 000073 113:17 000262 152:17 000279 153:13 000236 154:6 000359 1.35:19 000395 I (5:1 000403 139:6 000875 183:9 000919 189:17 001424 177:12 022 100:5 036 145:24 041633 131:8 043483 132:22 058519 110:22 060030 63:25 064725 96:2 065 1412 071021 100:4 071293 188:3 074772 108:6 076158 81:6 07C165 57:3 07G584 93:6 0770380 84:10 078201 180:9 079843 1303 079962 91:1 079995 92:20 079997 9 l:l 080871 118:19 090210 192:16 095193 77:24 095204 75:15 09520571:21 09520768:16 095218 102:17 098018 186:3 098174 124:7 098182 122:7 098183 197:2 098533 128:1 099633 126:4 1 1 56:24; 57:8, 63:24; I 12 3: 1 27: 24 10 88:19, 25; 151:13 II 90:14.22;91:3 11/51 71:19 12 77:22; 93:4,8; 95:20 1200 101:8 124 195:22 1242 101:10; 139:18; 140:4; 158:17, 159 5 1248 84:18:90:24,91:21; 94:4; 1 50 4, 4, 10,18, 21, 25; 151 5.8, 9, 16, 18; 178:20, 22; 179:24; 195:23 1252 87:3:94:4, 14 1254 63:23;64:22;65:5. 21); 68 5; 101:13; 139:1 8; 140:4; 158:20; 175:8; 199:8 1260 158:16, 159:2.4 12:35 90 16 13 95:25;96:6; 101:3; 120:17; 122:7; 197:18 1342 57:2 135 151:25; 152:3,9 1468:13; 100:1,7; 101:4; 102:11; 1317 1* 14/12/49 68:13 1427 178:2 5; 179:2 15 102:12, 13. 19; 188:13 150 187:1, 12, 13, 17, 210 5 1 6 108:3, 8, 1 10 4, 8; 1 39:4 161 HI .6 17 96:3:98:2; 1 10:19,25; 1 18:16; 124:5 17/51 75:14 1 70 57: 3 175 124:7 177 7:3 18 100:1, 10, 1 18:1 6, 21; 15124 1 BO 7:6 1837:8 106 7:10 188 7:12 189 7:15 19 120:15,20; 122:18; L 61:18; 186:3 1929 184:8 1937:17 1933 76:3 1936 59 20, 23 1940 88:1 1941 63:2 1 1943 14:25 1947 14:25; 15:18,20 1949 178:14 1950s 23:1 1; 28:1 1; 138:24 1951 15:16; 17:1; 174:3; 175:12, 176:12 1954 18:15,77:23:78:15, 16; 79:5; 92:22, 23; 102:16; 103:15, 16; 104:1 1, 105:19; 107:22, 25 1957 20:21; 24:16, 169:24 1959 84:6; 85:6, 14,23; H6:6, 1 !; 147:21; 181:1 1; 182:25; 184:12 211 192:16 1960 20:9, 25:25; 28.12, 214 180:9 30:22.88:1; 176:12 22 126:1.6 1960s 184:24; 200:14, 223 102:17 208:4 23 127:22; 128:3 1961 186:14; 187:4,6,14, 24 129.24; 130:5, 165:14 18, 20; 2 10:1 0 25 131:5, 10 1962 33:18 26 102:16, 132:20,24 1963 7:15; 33:18; 169:1; 188:13, 16,20; 189:2, 7, 26.11.54 102:15 10, 24 i 27 135:17, 18, 21; 1,36:4, 1965 3517:68:10 : 165:17, 17; 179:1 1966 96:4; 98:2 1968 117:10; 152.17 ! 278 152:18 28 139-4,8 1969 40:16; 100:1, It); 282 156:6 152:17; 191:6, 10 283 156:5,7 197 7:20 285 153:13 1970 48:1; 60;H; 62:4; 289 156 12 69:7, 22, 73:13, 20; 74:12, 29 140:25; ) 11:1; 177:13 22; 78:8, 15, 18; 79:4; 291 154:6 80:12, 22,83:8,9, 15. 17; 107:12,25; 1 11:13; 294 188:3 115:17,22; 118:17; 119 24; 120:1, 17; 122:7; 121:5, 24, 125:18, 144:24; 178:2. 181:19; 190:18,21; j 3 33:14:681 2, 18, 192:13; 193:1.3, 18; 195:10, 13, U>,20, 196:25; 197:18; 198:7; 199:9; 200:3; 201:12; 202:6; 102:23; 10.3:8 30 84:6, 85:6; 107:16; 143:14, 19; 181:5, 10; 203:12; 205:2; 207:2 205:1 1970s 117:11,20; 30s 60:13; 90:12 161:16; 201:15 31 144:23,24; 145:3; 1971 126:3. 127:24; [86:14; 187:4. 198:21 128:20; 130:1; 131:1,7; 32 145.23, 146:5 135:18; 1 36 4; 137:2, 321 8:2, 12 155:9, 22, 164:3; 165:18; 33 152:15.20 202:19; 205:13 1972 46:8; 129:15; 1311; 139:4; 1411; 142:16. 18; 161:23 34 ! 53:10, 15, 155:24; 156:3 35 154:5,8, 18,21; 156:1 1 1973 46:15; 48:5, 16 1974 110:16 36 7:1; 146:3; 154:18, 22; 177:11, 15 1976 48:24; 50:9,19. 51:10, 20, 24; 52:17; 207:23 1977 207:2; 20H 2 1978 1 13:16 1979 208:1 360 135:19 377:4; 180:8, 1 1 38 7:7,63:25; 183:7,8, 1 1 39 7:9; 183 7; 186 2, 5; 209:21,22 1 396 145:1 198181 120:18 1983 52:24 1985 53:5, 10 4 1986 5.3 20; 175:13 2 4 10:17; 71:1 ft, 23; 72:3; 73:9; 71:22; 169:1; 186:21; 187:16; 188:23; 210:1 2 63:2 I; 64:2; 65:1; 87:2; 103 8, I 19.5; 173:18, 19; 174:14; 191:20; 195:4, 19; 201:22. 21 1:13, 16 2/9/70 7:16 20 122:5,9 200 150:22 4/13/70 7:18 40 7:1 1; 188:2, 5,8 40s 56:20; 60 I 3; 89:17; 90:12; 148:1 41 7:13. 189:16, 19 42 7:16; 192:15, 193:0; 201:21,211:8,9 20671:21 43 7:18; 197:1,4 21 124:5,9 47 15:21 48 196:3 496 1,32:22 5 5 10:17; 75:13, 17;15 l:5; 177:6 50s 22:4; 24:16; 25:15, 19; 56:20,67:0; 92:1 I. 18; 1390; 184:13 51 15:19 52 94-14, 15 528 110 22, 22 534 128:1 54 94:15, 16, 17, 191:21: 195:24; 202:1; 21 1:17, 25 55 15 1:18 57 20:10; 170:2 59 28:12; 85:1 5; 147:3,9 6 6 77:22;78:l 60 79 2 60s 1 17:8 62 32:3,33:14 63 32 3 63141 8:3 63141-8039 8:13 644 126:4 648 131:8 65 183:19 69 19! 16 6:12 212:19 7 7 79:2; 81:2,8; 143:16 7,655 156:9, 12; 157:2 70 183:19; 202:7, 21) 70s 1 1513, 1 178, 15; 137:24, 161:21 71 46:8, I 29:21; 161:21; 164:4; 202:7, 20, 205:1 I, 19; 206 l. 3,8,16 72 46.8; 1 14:25, 129:18, 21; 131:2, 16i 1:2(1, 21; 10-1:3,4; 206.19; 206: l, 3. 16 726 96:2 73 16:19; 48:1,3 75 143:17 76 50:13; 52:3 77 207 :1 8 8 82:1,8; 8 I 2, 120.5, 130:1 80s 103:24 82 52.24; 53:0___ _ CAKDINAT. 'RF-POR'IING CO. 1 -212-227-9490 Min-tf-Script (H 000001 - H? WATER PCB-SD0000064063 WILLIAM PAEAGEOKGE Vol. 1, July 16, 1997 REYNOLDS METALS COMPANY V. AETNA CASUAL!A' & SURETY COMPANY,et al 83 53:6 85 53:7 8GG l .10:3 872 118:19 888 183:23,24,25 890 18,3:9 9 9 84:2, 12 950 189:17 995 92:1 A A-200 149:6 n-n-h-y-d-r-i-d-e 18:9 A-r-o-c-l-o-r 36:1 ABC 31:10; 10-1:21 able 167:H; 206:6; 208:1 absence 31:7 absorb I 23:6 absorbent 201:2 AC 188:18,20; 189:1 Acceptability 16:19; 17:10, 17; 18:1,6,12, 17; 53:8 acceptable 17:! 1; 19:12; 67:2 accident 104:25; 10(1: J acclimated 1 57:20 accommodate 9:25 Accordingly 97:21 accounts 146:1 7 accumulate 126:2,3 Accumulalion 108:1; 11.3:11 ' accurate 205: l ACGIH 66:21 acid 35:10,11 acne 58:20 acneform 58:9, 59:22; 60:18 across 25:1 2; 31:16; 90:10 act I 27:2; 173:5; 207:23, 21 action 106:5; 1 12:22; l 1,3:7; 177:5; 205:22 actions 11:12, [6, 21; 12:18 active 206:17 activities 18:21; 18:9; 126:20; 133:11; 170:23 actually 79:21;8I:18; 90:18; 91:1 5; 101:15; 127:23; 136:15; 110:11; 188:16 add 173:1 added 18 1 2, 101:15; 197:21,23; 198:10 addition l6i;l; 172:8 additional 16:21,25; 17:16; 117:12, 21; 193:2; 191:20; I9:9 additives 19:19, 20 address 8:11; 97:9; 131:22; 163-18 addressed 12:3; 190.15; 205:16 addressee 111:1, 12; 113:15 addresses 111.17; 193:15 adhesives 199:11 Administration 118.U advantage 112:11 advice 31:25; 38:3, 15, 20; 86:9; 187:15; 203:11, 20 advise 39:7; 85:21; 99:1 I advised 86:7 advising 85:7; 98:3; 1 12:22; 113:7; 120:2; 111:1 affair 168:13 affected 13:8, I6;76:21; 117:25; 118:2,3 affixed 111:21; 196:20, 23, 23 afternoon 10:15, 18,19; 160.1, 5,21; 161:19; 165:16; 168:16 Again 8:18; 22:22; 21:11, 15; 29:17; 31:21;37;I3; SI: 1; 61:1; 6)8:3; 69:25; 72:15; 85:23;88:1;91:23; 98:8; 122:5; 112:12; 116:23; 117:25; 119:15; 150:2; 153:18; 15-1:11; 159 3; 190:7; 201:22 against 8:20; 28:2; 99:12; 110:1 agencies 13:11; 12:1 Agent 81:9 agents 97:7 agitated 148:14 ago 32:6 air 16:1; 118:20 Alabama 35:21; 56:1; 125:11; 200; 13 Alden 58:7, 17; 59:18 alert 112.1 . Alexander 63:21; 61:Id, 15 alive 103:13 allegation 13:5; 62:12, 19 allegations 58:23; 59:1, 22; 60:7, 18, 22; 62:13, 23; 86:5,7;191:21 alleged 59:23:80:13 allow 210:16, 20 allowable 78:25 almost 23,23 alone 211:5 along 70:1-f; 129:22; 159:17; 166:25; 201:1; 20.3: -1 already 117:13; 132:4; 192:17; 197:7 alternate 51:19 alternative 1 14:18; I 15:7; 1 16:8, 22; 129:4, 12; 205:20 alternatives |61;11 although 114:17 always 23:20; 86:9; 172:7 ambiguous 40:7; 52:12; 56:6; 62; 15; 68:7; 99:5; 113:11; 172:17; 176:1 American 54:24, 25; 55:3; 66:24; 110:15; 131:21 among 58:9; 194:7 amongst 62:8:63:8; 161:13 amount 33:19; 43:1 5; 66:8; 98:18; 99:1.7, 8; 104:5; 105:21; 155:10, 17; 200:22 amounts 29:3 analyses 86:13 analyst72:5; 140:5; 157:23; 158:10, 12, 19 analytical 158:13; 200:21 analyzing 140:2 anhydride 18:8 animal 1292 animals 79:2; 118:3,7,9 Anniston 35:20; 37:6, 12; 38:2,19; 39:1,7; 40:15, 56:3:59:4; 68:9;80:19. 22; 107:15; 125:13; 181:22 anodes 163,8 answered 117:4 answering 9:20; 123:14 anticipated 98:13 anybody 38:2; 42:13; 44:16; 132:16 anyone 160:16 anyone's [65:19 Anyway 119:9; 142:8 anywhere 117;16 apology 102:1 3 apparent 81:3; 108:5; 110:23; 132:21 apparently 131:6 appear 16 5:79:25; 82:11; 88:23; 90:24; 91:23; 100:3; 126:14; 153:19:194:23; 202:Z appearance 89:25; 148:3; 150:10; 151:17 appeared 129:6; 138:13 appears 56:25; 57:16; 59:20; 68:14,15; 70:11; 71:19; 81:4; 84:5,7; 88:21; 93:17; 102:14,15; 120:15; 128:16; 136:18; 179:12; 181:10; 186:8, 23; 198:16 appendix 174:25; 175:4 application 118:14; 123:24; 18-1:8; 193:22; 199:17; 206:14, 25; 207:4, 21 Applications 92:22; 103:18; 115:1,24; 116:24; 199:22; 200:12; 205:17 applies 123:25 apply 123:24 appointed 40:18; 46:17; 50:15:131:20 appreciate 8:25 approach 26:15; 126:25; 168:I7,182:17;202;10 approached 166:5 appropriate 24:19; 35:3; 70:6; 86:22; 187:16.22; 189:3,8, 10; 210:4,5, 10, 16, 19 approvals 118:11 approved 11518; 204:4, 4 approximate 92:13; 110:12 Approximately 11:4 April 111:13; 115:16; 135:18; 136:4; 141:1; 165:17; 197:18 apt 158:7 area 23:16; 28:19, 25; I 13:20, 138:21; 169:3,4; 203:3 areas 145:18 Aroclor 7:1,4,19; 36:10; 63:23; 64:22;65:5, 20; 66:4; 68:5; 70:1 2; 73:18; 75:5;78:25;79:9; 84:17; 87:3; 90:24; 91:21; 94:9, 21; 95:9, 13,16; 101:9, 13, 23; 104:1; 113:9,139:18, 18, 19; 150:4, 10, 18, 24; 151:7, 15. 18; 152:8; 158:25; 159:4; 175:8; 178:20, 22; 179:24; 181:4, 21; 182:25; 195:22, 23; 197:24; 200:5; 205:24 Aroclors 36:3, 14;37:4; 38:4,21; 39:8,25; 70; L1; 72:18; 85:9, 25;86;1, 12, 14; 88:21; 93:20,23; 94:3; 95:1,6; 101:5; 104:6; 121:16; 158:14; 169:19; 178:7; 183:3; 199:10, 22 around 30:22; 41:8; 47:9; 83:18,19; 85:14; 174:14 arranged 30.18 arrived 55:25; 115:15 article 57:15; 59:18; 72:4; 180:20 articles 73:7 aside 102:10 Askarel 7;8, 13; 108:5; 109:5,7, 10; 184:5,7, 10; 185:12; 189:22 askarels 109:13, 16, 24; 185:18; 194:15 assigned I 8:18; 31:19; 33:8:35:19, 46:21,24,25; 49:2; 51:3, 13; 53: l; 73:5; 135:6 assignment 17:7; 32:16; 43:5; 48:10; 49:4; 50:6; 56:18; 108:17 assignments 170:22 assist 30:1 1; 32:10; 135:6 assistance 24:13; 32:12, 23; 33: l Assistant 21:22; 69:23; 74:9; 186:16 assisted 33:10; 167:6 assisting 30:17 associate 59:17; 63:11; 1 13:25 associated 12:3, 19; 48:9; 58:21,24; 59:6; 66:3; 101:25; 102:1; 158:3; 191:4, 18; 196:8, 15; 208:9, 24 association 54:3; 55:3 associations 54:1 assumed 48:5 assuming 165:1 assure 121:18, 22; 162:1 I atmosphere 125:11 atomic 102:7 attached 17:12; 84:23; 174:24, 198:13 attaches 72:4 attachment 72:6; 1 54:5; 198:12, 13, 16 attempt 29:8; 130:12; 145:18; 153:25; 191:11 attempts 108:19 attend 43:9 attended 132:13; 136:5 attending 1 36:3 attention 51:16.; 138:8; 143:5; 173:18; 208:11 attorney 10:4 attributed 76:12 audible 9:4 August 96:3:98:2; 115:21; 124:5; 125:18; 139:4; 143:16; 144:24; 205:1 author 84:6 authored 102:14; 120; 16; 197:14 availability 114:18, 20 available 24:25; 51:20; 61:25; 110:14; II 5:8; 200: Z1 avoid 120:10; 129 3; 142:6; 171:16; 203:25; 204:8;210:18 awarded 14:24, 169 3 aware 25:1; 59:21; 60:21; 61:8; 65:9; 66:3; 77:3: H;3 - aware (2) Min-LLScript CARDINAL REPORTING CO. 1-212-227-9490 WATER PCB-SD0000064064 REYNOLDS COMPANY v. AETNA CASUALTY & SURETY COMPANY,et al WIIXlAiU PAPAt.POUuP VoL 1, July 16, 1997 104:4; 138:6; 142:19; 143:25; 144:6, ! 1, 16; 159:12; 170:8; 181:21; 211:23 awareness 22:5; 25:1-1; 103:19; 167:10 away ti6:2; 144:18 B B 8:10; 50: 14, 15; 154:5 B,P 139:5 B.W 122:6,22 baby 148:7; 150:12, 210:1 4; 212:3 Bachelor 1 -f: [ 5 Bachelor's 01:2-1; 167:2-1 back 9:10;-fl:8;-16:5; -18:3; 50:8; 56:20; 67:2; 87:2;95;20; 104:22; 106:3,3; 123:15, 17,20; 136:25; 144:23; 162:3, 'i; 180:2'1; 185:15, 186:20; 188:16; 198:21; 199:18; 201:21,22; 209:20 background 11:12; 165:20; 167:23 bacteria 28:22; 157:20; 158:4; 159:14 bad 23:16 ban 207:3, 20, 22 Barrett 71:2, 3 bars 90:10 Bartlesville 15:23 based 40:9; 61-1,79:11; 80:1 1; 99:21; 128:25; 155:7; 157:17; 158:21; 169:20; 189:7, 10 basis 43:;86:2l;99:l6; 106:14; 175:18; 196:10; 207:6; 208:18 batch 36:6 Bates 57:3; 63:24; 68:15; 71:20; 75:14; 77:24; 81:5; 82:4; 84:9; 90:25; 93:6; 96:2; 100:4; 102:16; 108:5; 110:21; 1 18:18; 120:18; 122:7; 124:6; 126:3; 128:1; 130:2; 131:7; 132:22; 135:18; 139:5; 141:2; 143:16; 144:25; 145:24; 149:5; 151:13, 23; 152:17; 153:13, 154:6; 177:12; 180:8; 183:9; 186:2; 188:3; 189:16; 192:16; 193:3; 197:2 bathtub 201:11 bearing 1839; 186:2; 188:2; 192:16; 197:2 became 42:4;48:17; 49:14, 51:8; 56:13; 69:8; 142:19; 169:25; 203:9 become 48:3; 51:22 bed 200:25; 201:1 began 17:2 beginning 113:5; 123:16; 203:12 begins 58:3; 84:21; 178:21; 194:19, 199:1 begun 202:19 belatedly 77:5; 104:13; 11 1:9 believe 48:24; 59:5; 63:3, 10; 66:15; 69:4; 81:18; 92:7; 93:13; 99:11; 103:14; 110:19; 146:18; 151:14; 152:22;164:13; 165:16; 169:24; 171:8, 14; 172:18; 173:20; 174:3, 12; 175:13; 186:17; 191:15 believed 121:25 belongs 193:2 below 90:9; 179:10, 12; 181:6, 1 1 bench 158:19 Benignus 103:9,9, 16, 25 benzene 62:9; 101:14, 19,25 besides 8u:2l best 20:7; 38:17; 46:15; 59:3; 67:6; 68:8, 69:4; 73:18; 111:8; 133:7; 144:21; 161:20; 164:4; 174:13:201:12 better 42:6; H4:5; 115:1 beyond 15:1; 39:1; 87:17; 124:20 bibliography 92:3,8 big 43:5, 12, 14;73:21; 198:19 Bill 64:15 billion 150:22 bills 45:14 bio 157:6 biodegradation 157:5, 7,18, 19 biodegrade 157:12 biologist 157:9 biphenyl 1021 biphenyls 58:14; 183:3; 192:3:199:3,6,7 bit 50:7; 51:21; 70:15; 101:15; 121:6; 144:24; 150:11 bits 82:15 blend 10142 blended 20:24; 49:10 blends lt>9:3 block 204:9 body 210:17 bond 148:25 book 57:1, I 5, 24; 67:9; 81:3, 13, 20, 24, 82:2, 19, 23; 83:1,4,6, 12 booklet 67:11;68:2 boss 20:1 both 8:23; 14:11, 20, 20; 55:22; 79:13; 95:5; C-o-r-l-e-w 122:6 154:17; 155:2; 157:14; 160:19; 178:11 bottom 84:20; 151:9; 183:23; 186:13; 188:12, 195:3; 198:13; 200:24; 201:23, 21!; 13 bought 62:6; 142:3 boxes 116:9, 15 Boy 104:21 brand 36:11; 109:12 breadth 189:14 cabinet 73:24 cable 62:20 calculate 102:8 calculated 101:24; 102:1, 3 calculations 16:8 California 114:2 call 16:14; 18:19; 24:12; 28:24; 66:10; 91:17; 99:22; 104:18; 106:6; 115:15, 19; 131:25; 14'2:l; break 40:24; 157:22 158:20; 164:16; 205:3 Breakage 186:22; 187:8, ! called 16:3; 46:16; 62:21; 8; 188:24 1 93:24:95:5; 140:13, 14; breaking 90:17,20 144:12; 193:24; 203:6; breaks 9;23,26:19,210:6 207:25 breathe 23:15;80:3 breathed 80:2 breathing 22:18; 66:4; 77:13; 79:8 brewery 14:3 brie) 14:11; 4l:2;71:25; 127:18; 159:21,209:18 briefcase 176:11 calling 61:17; 205:5 calls 137:19; 142:1; 161:13; 176:10 came 24:10; 4 1:8; 51:24; 76:7; 114:25; 204:13 can 9:9; 13:2; 15:17;22:2, 10; 27:15; 49:10, I 1; 54:2; 60:-l;61:3,9,66:13,21; 69:15, 81:1 5; 86:2; H9:t I; briefly 14:13; 1547;61:5 91:25; 95:14; 99:18; bring 132:2,6; 208:10 102:5, 8, 10; 110:1 1; brittle 18,13 broad 55:15,22; 59:12, 15; 74:17 114:6; 115:2; 1 16:1,3; 128:11; 136:12; 158:18; l6l :8; 164:4; 167:3; 169:8; 172:8; 178:23; broader 95:16, 17 181:2; 190:23; 194:4,4, Brochure 7:7; 89:9,10; 17, 17, 198:1 I; 201:1 2; 91:9,11,12,21;93:18; 204:12, 16; 205:5; 209: 18; 130:12, 14, 24; 182:16, 210:12 190:16, 17 Canham 120:16, 17; brochures 24:25; 25:4, 121:12, 13 9; 30:21,23; 47:7; 85:12; capacitor 17:24 88:13; 176:11; 181:21 capacitors 12:10 brought 133:8; 180:24 capacity 8:16 Brown 75:9; 102:14; 103:5 browsing 76:10 Bruce 144:25 Bs 50:14 capture 204:2 carbolic 35:10, 11 carbon 158:5; 163:1 carbonless 115:20; 199:17; 205:10 buck21:24 carbons 102:7 building 114:4; 135:8; ! card 168:2 142:5 buildings 199:23, 23; Care 7:7; 143:3; 16.3: t^; 173:5; 184:4; 192:5; 200:1 198:10 bulldozed 201:1 career 15:) 2 Bulletin 7:1,4; 92:22; 130:2; 178:21; 181:7,8,9, 25 Bulletins 182:1,5,10 burial 204:4 careful 31:9; !4:l Carol 136:13 case 13:10,14, 20; 14:5; 86:24, 24; 100:19; 160:8; 186:22, 188:24 business 44:21; 106:4; 116.6, 25; 121:17; 146:13; 154:15; 163:8, 182:14; 207:10 cases 1 1:24, 25; 12:4,6, 25; 13:15; 34:6; 58:8; 76:12 casting H:2 categories 54:5; 178:9 c category 47:17, 59:15; 95:17 C-a-n-h-a-m 120:17 cattle I 3:9 caught 116:11 caulking 115:20; 199:15; 205:4 ` cause 62:24; 63:2, 4, 16 caused 13 5; 61:12; 113:7 causing 184.6 caveats 169:7 CC 128:17 center 90:6; 11 5:3 Central 36:25; 37:2; 10:1, 11; 121:14 certain 64:21; 82:1,4; 111:23; 114:11; 148:2; 160:22; 169:1 9 certainly 23:7; 24:19; 61:3; 72:19, 98:20; 114:13; 136:18; 161:6 certificates 167:23; 168:1 chain 203:1 l Chairman 131:20 challenge 114:22 challenged 166:20 chance 23:15; 18K:8 change 46:2,3,9; 143:7; 144:2; 158:1,23; 175:20 changed 46:2,7, 14, 89:25; 144:19 changeout 51:18; 142:19; 143:3,5 changeouts 129:18, 134:7 changeover 161:21 changeovers 1 29:6; 138:7 changes 90:3; 144:7; 206:20 changing 135:4 characteristics 84:24; 85:9; 1 16:4, 149:19; 150:9, 18; 151:20 characterization 99:13 characterizing 67:21,23 charge 169:25 charts l 55:8, I 1; 156:23 check 104:1 Chemical 7:2; 14:16,17; 304 9; 4946,2l;51:9; 52:9, 23; 54:21,2 I, 24,25; 63:1; 76:2; 84:4; 90:10; 1 184 3; 1694 7; 172:2; 1734 2; 175:19; 186:17; 208:24 chemically 93:21,22,23; 109:1,2 chemicals 17:6; 18:6, 1948, 21; 23:6; 28:21; 29:3; 31:8; 46; 17; 49:3. 6. 13,24; 50:2, 4; 81 4 3; 5 2:10, 14; 53:1,3; 5940; 02:21; 67:12; 83:3; 88:22; 109:20; 171:23; 2l)8:4 chemist 71 3; 72:5; 158:22; 165:2 CARDINAL REPORTTNO CO 1 -2U2-2?7-9-4.90 U-S-t i 63) awar<*fi;\ss - WATER PCB-SD0000064065 WILLIAM 1`APAGEOKGE Vol. I, July 16, 1997 REYNOLDS METVTS COMI'ANY V. AETNA CASUALTY & SURETY COMPANY,et al Chemistry 8 I :3, 13 chest 66:1), 10; 67:25; 71); l1) chickens 117:25; 200:11 Chief 21:21 child's 202:10 children 172:21 chips 200:10 chloracne60:3, ] i, !9, 6i;12;62:7, 10; 63:3, 11, 16; BO: Of; 86:5 chlorides 173:11 Chlorinated 7:6; 58:8, 13, H, 17.22; 59:12, 13, 17; 76:13; 101:18; 118:1; 158:6,8, 12; 159:16; 181:5; 183:3; 199:3, 5,7, 16; 202:8; 206:7 chlorine 9A: L 2,1 3, 18, 20, 101:21,2'!, 25; 102:2, 3, 8; 159:15; 193:21; 195:23; 196:2; 199:3, 202:1; 21 1:17 chlorines I 58:2, 3 chlorobenzenes 59:9 choice 115:16; 116:7 chronology 20'!:I7 circulated 197:17 circulating l-!3:9 circulation I 16:10 circumstances 61: J 7; 69:2:72:9. 10; 89:6,8; 93:1-I. 15; 96:12; 100:13; 108:1 5. 1 1 1:6, i0; 119:2, f; 133:5; 153:23 citation 92:21 cited 92:21 City 7 5:9 civil 169:12 claimed 13:8, l6 clarification 9:19; 28:7 clay 20-1:3 clean 13:12, 22; 27:16; 99:23; 193:7; 186:23; 188:29; 189:3; 203:9; 210:5, 1 I cleaned 187:7 cleanup 210:22 clear 28:6; 60:6; 85:1,2; 90:5, 105:19; 106:13; 107:19; 128:8; 15U:I3; 177:6; 185: i 1; 195:22 clearing 167:21 clearly 112:18 clerical 23:5 close 52; 15; 60:3; 128:1 1; 157:13; 181:22; 205:8 closed 97:19; 98:9; 115:29; 1 [6:9; 205:9 closest 158:18 clothing 70:5 coached 23:8 coaching 19:9 coating 62:20 cold 66:10 college 13:19 Collins 139:5; 130:11; 160:18; 163:H, 16, 22, 29 colored 119:16; 138:6 combination 53:19 combine 200:29 comfortable 116:8; 137:20 coming 162:18; 202:7 comments 30:9; 119:8; 133:13; 199:19 commerce 39:11 committee 131:21, 25 common 16:19; 23:21; 27:10; 99:19; 161:13 commonly 88:12 communicate 39:29; 121:21; 182:13, 191:1 l; 202:1 l - communicated 122:1; 125:18; 133:2 l; 202:22: 203:1 communicating 39:10; 21 1:29 communication 192:10, 12 communications 103:19, 137:8,25; 193:6; 160:15, 20,22 community 6395,18; 158:13; 172:23 community's 171:25 companies 23:23:33:18; 183:21 Company 8:19, 20; 10:1 1,2 I, 23; 13:25; 15:23; 25:17;33:ll; 91:12; 9 6:17, -19:3. 16, 19, 2t; 51:9,25; 52:9,17,23; 53:1,8, 13; 62:6; 83:3; 90:10:95:25:97:9; 109:21; 105:2; 137:7; 1 55:8, I 5; 186:17 Company's 76:2 comparable 121:8 compare 13():3 comparing 33:13 comparison 212:3 complete 168:23; 209:18 completed 123:18 completely 51:3; 98:22 completion 117:17 components 138:13,13, 169:19 compressed 168:13 compromise 115:8 concentration 78:25 concept 116:18 concern 79:12, 23,25; 1 16:25 Concerning 63:23; 87:3; 161:23; 162:21; 163:10 concerted 33:5 concluded 63:1 5 conclusion 61:1; 165:1 conclusions 6l :7 concrete 27:16,203:17 condition 58:19,21,23; 59:5; 6(): 19; 63:2; 65:9, 18; 150:13 conditions 26:23:38:18; 138:17; 180:3 condoned 207:15 Conference 66.23; 126:23 Confidential 110:21 configuration 157:23 confirm 195:12 confirmed 1183; 1992 Confirming 162:13; 201:13 confusing 50:H;63:6 connection 178:1 consecutive 135:23; 136:1 consider 16:13; 123:25, 210:15, 19 considerations 16:15; 37:3,3, 13 considered 67:2; 156:25 consistency 138:7 constantly 23:8 construction 32:23; 175:7 consultant 8:17; 53:21 consulted 25:11; 108:19 consulting 39:2; 212:11 consume 157:21 contact 77:13; 97:22; 150:25; l6S:6 contacting 125:23 contacts 139:16,25; 166:7 contain 19:21; 121:16; 137:19,2i;183:l,5; 187:18; 188:20; 203:23 contained 18:9; 193:16; 203:11 container 33:3; 155:5 containers 196:20,23 containing 20:23.25; 21:2; 35:13, 23; 37:19; 39:I9;63:22; 108:21; 131:23; 135:20; 163:10; 187:22; 189:11; 190:10; 199:3; 203:19 contains 137:25 contaminants 29:23 contaminated 125:8, 172:21 contamination 133:12 Contemporaneous 165:12 content 73:23; 152:17, 193:21; 195:23; 196:3; 202:1; 211:1'7 contention 13:12 22- 169:21; 173:9, 178:10; context 161:9; 171:7 continual 129:8 continue 127:7,177:8 continued 52:1; 76:20; 107:25; 206:25; 207:16 continues 76:22 continuing 106:13 contribute 32:13 202:15; 203:5; 206:19 ( courses 15:3,7, 9 court 57:8; 63:2,68:18; 71:23; 75:17,78:1; 81:8; 82:8; 83:12; 88:25;91:3; 93:8; 96:6; 100:7; 102:19; 108:8; 110:25; I I 8:21; 120:20; 122:9; 123:2(1; 123:9; 126:6; 128:3; contribution 127:i9 contributors 127:1 control 26:16,17;29;6; 38:12; 30:19; 31:6, 16; 35:1, 2J,25;96:5; 55:6; 56:13; 69:9; 73:3,6; 73:3; 108:18; 111:15; 127:8; 131:22:133:5; 203:13,25; 203:12: 207:23 controlling 27:10 conversation 163:3 conversations 39:13; 161:2; 163:13, 22 130:5; 131:10; 132:23; 135:21; 139:8; 141:3; 143:19; 135:3; 136:5; 152:20; 153:15; 153:8; 162:3; 177:15; 180:11; 183:11; 186:5; 188:5; 189:19; 193:6; 197:3 cover 82:3; 139:18; 203:21 coverage 11:8, 12,16, 25; 12:18, 20 coveralls 26:21 covered 22:22; 37:11; Conversion 130:2, 13; 138:9; 167:19; 206:17 133:8; 185:9 covering 83:23 conversions 206:1 5 covers 95:18 convert 205:17; 206:16 create 37:3; 172:6,2! 1:6 converted 130:23 created 3) :22 convey 363:23 creates 125:8 conveyed 193:25 creating 113:7; 172:3 cooking 2oo:io credit 15:3 coordinate 35:5 critical 99:9 Coordinator 133:12 cubic 79:1 copies 73:6:83:21, 23; 191:18; 180:17; 182:19; 192:17, 197:9 copy 111: LI; 115:20; 119:10; 129:25: 131:20; 180:13; 197:7;198:16, 199:17; 205:10 copying 180:18 Corlew 122:6, 22,23 Cornell 113:3 corner 137:3; 179:3 corporate 36:22;3I:11, 13; 78:13, 22; 160:12, 16 corrective 10(3:5 correctly 101:13,1 <>7:5 correspond toi:7 corresponding 152:8 cosmetic 118:13 coughing 66:9; 80:3, 15 couldn't 33:8; 36:5; 107:2 counsel 10:13;73:13; 87:22 county 203:5, 5 couple 11:6; 20:7, 20, 22; 32:2; 33:21; 117:17; 160:8; 201:19 course 15:12; 17:7; 37:10; 51:1; 53:23; 65:23; 70:3; 98:18, 23; 136:13; 153:15; 160:10; 16 J:K); 163:25; 167:3; 168:18, 21, curbing 203:10 Current 8:1 1; 97:6; 178:11 currently 8:13 customer 26:3: 32:8; 33:23; 33:3, 10, 19, 22; 37:13, 21; 39:16; 35:8, II, 16, 18, 22; 37:12; 105:10; 106;5, 25; 109:20; 120:10; 132:7; 152:23; 153:19; 1B5:22, 22, 23 customer's 38:16; 106:6 customer-returned 156:18 customers 23:1,8,18; 30:21; 32:23; 33:2;38:3; 39:8,13, 19, 21; 32:9, 20, 22, 25:39:8; 52:1; 53:17; 85:8; 86:7, 12: 87:1 1,21; 8H:l6;91:10, 13, 21; 96:18; 97:3, 6, 7; 98:3. 11; 99:12; 100:22; 110:5,9; 111:9, 112:3,23;113:8; I 16:2, 19; 119:12, 19; 120:2; 121:9, 11,21; 122:2; 125:18,23; 130:15; 132:12;133:19,25; 133:15; 136:21; 137:23; M2:2,6; 133:1,7; 153:2; 167:7; 173:16; 175:3, 15: 176:10; 178:11, 12; 182:7, 7, 10, 13; 185:12, 17, 19, 20, 20; 190:8, 8,9; 191:3, 7, 8; 192:10, 13; 193:13; Chemistry - customers (4) Min-U-Script CARDINAL REPORTING CO. 1-212-227-9490 WATER PCB-SD0000064066 REYNOLDS METALS COMPANY v, AETNA CASUALTY & SURETY COMPANY,et al WIIXIAM PAPAGEOUGE Vol. J, July 16, 1997 202:12; lJ; 21 L:2 i cyanides 173:12 cyclic 57:l6 D D 57:2, 15; 1 '13:15 D.A 84:7 dairy 13:8 Dale 8:18, 57:4 damage 22:7; 77:1; 793, 12, 24; 80:9, 16; 118:7,8 damaged 80:1 damages 76:15 danger 70:9; 98:17 dangerous 65:6;82:2,20 dangers 24:17; 70:12; 98.13 Danzer 134:23; 135:1,6; 167:2,6, 17 darken 150:15 Data 7:9, 11; 126:24; 186:8 date42:l2,59:20; 63:24; 68:13; 71:19; 74:1; 78:16, I7;88:23; 89:13;90:25; 91:24:92:1, 13; 96:3; 98:1; 100:4,9; 102:15; 108:5; 110:23; 118:16; 119:25; 122:18; 126:3; 131:7; 132:3,7,21; 147:2,6; 154:1; 183:21; 184:11; 199:1; 207:24,2! 1:19 date-wise 60:4 dated 7 5; 13; 77; 22; 84:5; 92:22; 100:1; 120:17; 122:6; 124:5; 127:24; 139:4; 141:1; 144:24; 178:13; 186.14; 188:13 dates 25:18; 32:4; 50:8; 60; 14; 92:8; 204:25; 206:10 dating 60:16 day 86:17; 107:16; 142:9; 167:14; 168:13, 15 days 79:2 DDT 114:17 deal 53:16; 57:l6; 198:19 dealing 188:17 deals 57:16 dealt 54:6, 9. 15; 56:15 Dean 134:23 0ear7:17 decades 32:6 decanted 201:4 December 63:24;68:13; 71:19,75:13; 130:1, 147:3 decide l 58:19 decided 42:6; 46:4; 114:5; 126:20, 24;128:12; 129:9. U; 205:16 decision 44:3, 6, 9; 74:10; 115:13, lA; 128:20; 129:14, 17 decompose 28:22 deeper 150:15 Defendant's 57:7;64:1; 68:17;71:22; 75:16; 77:25; 81:7; 82:7, 84:11; 88:24;91:2; 93:7:96:5; 100:6; 102:18; 108:7; 110:24; 118:20; 120:19; 122:8; 124:8; 126:5; 128:2; 130:4; 131:9; 132:23; 135:20; 139:7; 141:3; 143:18; 145;2; 146:4; 152:19; 153:14; 154:7; 177:14; 180:10; 183;JO; 186:4, 188:4; 189:18; 193:5; 197:3 define 66:21,23; 112:19 definition 67:16 definitions 67:14 Degree 14:24, 25; 15:4, 8; 98:17; 99:2; 143:3; 144:12, 13; 148:10; 157:8; 167:24,24 degrees 14:13,23 deliberately 16:20; 115:25 delivered 105:21 deliveries 45:13 delivery 33:11; 34:2; 171:5 demonstrated 159:13, 18 denser 151:1,7 density 65:24 Department 16:1,7; 18:19; 20:14, 15; 21:14; 25:23; 26:18; 28:10; 30:4, 5, 6,7, 8, 17, 18; 31:13; 33:9, 37:1,2; 40:5, 1 1; 45:22; 60:2; 62:4; 69:6, 24; 72:11, 17; 74:9, 16, 18, 20; 75:9;86.19;96:i6; 103:17; 121:14; 122:25; 146:15, 18; 176:8; 186:17 Departments 30:12; 45:6 depending 104:25; 148:16; 170:22 depends 27:15; 65:24; 149:10; 158:2 deposited 144:14 deposition 8:21; 10:3,8; 11:1; 57:7; 64:1; 68:17; 71:22,75:16; 77:25;81:7; 82:7; 84:1 1; 88:24; 91:2; 93:7;96:5; 100:6; 102:18; 108:7; 110:24; 118:20, 120:19; 122:8; 124 ;8; 126:5; 128:2; 130:4; I 31:9; 132:23; 135:20; 139:7; 141:3; 143:18; 145:2; 146:4; 152:19; 153:14; 154:7; 177:14; 180:10; 183:10; 186:4; 188:4; 189:18; 193:5; 197:3 depositions 11:10 dermatitis 58:9,20; 59:22; 60:18 | 22; 76:13 i direct 42:19;44:15; dermatological 84:23, 85:8; 86:13 describe 24:25;43:3; 73:22; 99:19, 24; 106:24, 24; 123:1 described 13:21;33:9; 58; 19; 60:12; 69:12; 106:17; 114:11; 123:6; 149:20; 1 51:21; 158:24; 163:5 describes 175:6; 178:21 describing 14:13; 60:18; 158:17; 175:5 Design 16:7,8, 20; 17:18; 18:2 173:17 direction 125:10; 158:24; 159:1 directives 166:20 directly 182:10 director 44:21;49:4, 15; 50: ] 6; 51:1,8; 52:21,25; 69:24;70:21; 73:3; 74:4,9, 10; 78:13, 22; 100:18; 106:4; 133:12; [45:15; 182:15; 186:16 disappear I 58;7 discarded 27:16 disclosing 142:7 designate 36:5 discomfort 67:25; 80:3 designated 94:22 disconnect 27:13 designation 53:14 Discontinuation 132:20 designed 15:8; 18:7; 121:18,22; 163:2 designing 17:5; 1690 3 designs 115:25 desire 29:2 desks 83:20 destroyed 138:10 discontinue 44;3 discontinued 89:22, 24; 204:20 discontinuing 167:7 discourage 29:7 discuss 76:14; 105:22; 164; 5 detailed 175:7 details 45:12; 133:16; 138:4; 142:4; 165:1 discussed 79:8; 104:20; 117:22; 1 18:6; [23:4; 137:4,6; 16l :5, 8; 203:18 detected 211:19 detection 158:23 detergents 204:8 determine 200:19 determined 105:2, 11; 114:16; 115:9 developed 26:9,22; 62:25; 67:25; 129:4 developments 42:12 dialogue 34:22, 25, 106:7 discussing 70:12 discussion 22:20; 77:17; 136:23; 156:1; 162:10; I 163:15; 176:23; 182:20; [ 190:25; 204:13; 209:9 discussions 10:4; 24:7; 13:9; 69; 11; 70:1; 74:23, 23; 76:17; 106:19; 107:5; 137:1; 161:3, 15,23; 162:20; 163:9; 164:8 disposal 29:12; 30:1,25; 31:7; 51:18; 125:8 dictate 1 !5;1 1 dielectric 108:23, 24; 109:3,6,11; 1 10:1; 114:21; 1 16:6; 131:22; 184:17; 190:10; 193:21, 22; 194:15; 199:11 dielectrics 206;22, 25 differ 149:8 difference 93:I9;95:9; 101:2; 149:23 different 30:5,6;63:1; 94:24; 95:14, 19, 101:5; 108:24; 115:4; 123:14; 127:1; 146:3; 149:12; 167:10, 16; 168:14; 193 23,194:2,7; 199:9; 204:19 difficult 63:10; 126:23; 151:24; 158:4 difficulty 143:2 digit 36:4;94;23; 147:25 digits 94:11 dilute 206:21 dispose 27:19; 155:13 disposing 28:2 disseminated 175:14; 178:9; 190; 13 dissolve 148:14 dissolved 53 3 DIST 150:4 distillation 17:8 distinct 16i: 14 distinction 77:16, 19, 154:25; 155:20 distinguished 95:13; 112:16; 118:13;202:9 distortion 158:11 distribute 97:3, 5 distributed 88; 17; 96:18; 110:5,9; 174:15,16; 175:4,22 distributees 87:18 distributing 87:20 distribution 87:15; 97:10; 100:21; 133:19 diphenyls 58:8,13,17, 1 disturb 2] 1:6 division 175:7 divorced 51:5 divulge 142:10 doctor 86:20, 21 Document 7:16; 56:24, 25; 57:5, 18; 58:20; 63:22; 6-1:6; 65:1; 68:12, 20, 22, 24; 69:3, 12, 17; 70:2; 71:8, 18; 74:2 1; 75:13, 21, 22; 76:7; 77:22; 78:3,5; 82:15; 84:2, 5, 16; 87:6,6, 10, 10, [6; 88:20; 89:2, 4; 90:19, 23:91:5,7, 23, 25; 92:12, 22; 93:4, 10, 12, 15; 95:21,25:96:8, 10,13; 98:1; [00:1, 12, 15, 20; 102:14,22,25; U)3:i; 108:3, 13; I 10:8, 13, 14, 16,20; 1 I 1:4,7,8, 18, 22, 25; 118:16, 23, 25; I 19:3, 25; 120:15,22,24; 122:5, 11, 13, 15, 21; 124:5, 13, 16; 126:1, 10, 19; 127:22; 128:6, 18; 129:23,25; 130:9, 10, 18, 23; 131:5, 12, 14, 17; 132:20; 13.3:3, 18, 20; 135:17, 24; 140:25; 141:8; 143:14, 15, 23; 145:5,7;15I;I2; 152:16, 23; 153:3, II , 20; 154:4.5. 12; 174:13, 24; 175:5,23; 177:12, 19; 178:1,4,9, 13; 180:8, 22; 181:15; 183:8, 15, 18, 20; 18-1:1 1, 14,23; 185:3,-1,8,9, 1 1, 17; 186:2,7, 10, I 1, 14,21; 187:2; 188:2, 10, 17, 189:16,21; 190:13; 192:16,25; 193:8; 197:2, ID, 12; 198:12 documents I0;7,10; 69:5; 72:17;73:8;78:7; 79:7;80:11,86:23; 145:23; 146:2; 15.3:3,21, 24; 15-1:17, 19; 168:15, 17.3:21,22; 174:5; 175:14; 177:2-1, 179:1 1; 201:20; 206:10 Don 57:2, 15,21; 1-15:16 Donald 7:16 done 15:12; 77:1; 79:5; 105:1, 106:10, 11,1 18:12; 177:7; 200:17; 203:8; 207:9:212:17 down 29:4; 80:19; 90:7; 102:5; 135:25; 162:18, 172;3,11; 17.3:6,15; 181:6; 204:1; 210:14 dozen 11:6, 14, 15; 12:24,24,24 dozens 11:10 Dr 70:8,13. 19,20:71:3, 6;77:23;81:16; 10.3:9,25; 1-15:13; 160:18, 19,22; 161:2,3,8, 15,23; 162:11, 20; 163:23; 164:6; 166:9; 179:21 draft l 30:1 1; 13.3:8, 14, 16 CARDINAL THT" PTINO CO. ! P 'Tipi Mio-U wonMes - dr.il't WATER PCB-SD0000064067 W J t.lsUILM ti'* Vol. 1, July 16, 19^7 m; t imm.iji old 1 * v. AETNA CASUALTY & SURETY COMPANY,et al drafting 19-1: l effluent 200:15. 20 entering I 24 4 9, 1 25:7 evidence 29:22; 191:10 j existing 26:9,56:1 2; drafts I 19:7, 10 effort 127:1 5. 205:1 1; entities 4240; 185:25 evolution -194 1 | 197:22,22 drain 27: It; 10'S: 2^, 1 206:22 entitled 7317,81:13; evolutionary 1)7:5 | expand 874 3 ^ 111:10, 171.1, 172:12; 210.17 drainage 1 29-11 drained 27 11; 10-1:21 ' efforts 121:5, 127:7, I I; 82:2, 19; 88:20,9.1 5, ' 115:7, 170:1 1; 171:15, 20, | 108:3; 1 10:20; 131:5; 206:2-1 j 132:20 eggs 11-12; 118:1 j entity 207:1 I evolved 274 2; I 29:21 evolving 29:19; 47:9,14; 1 1647, 19140 exact 1113; 60:1; 1 expansion 97:20 I expect 208:8 expectation 2084 5, 25 expected 18:25; 18249, draining 143 6 drawers 73:23 drawing 171:6 drilling 16:2 drip 29:-I Drives: 2, 12 driving 10:19 cither 29:10. -19 9, 57:2-1; 72 -1,6; 74:9; 80:4, 1-1,21, 22; 86:20; 105:25; 11-1:11; 1-11-22; 155:10; 156:21; 161:21; 161:19; 166:6; 1 70:4; 201:15:211:22 Electric-11: l 5; 109:20 electrical -11:6, 4-1:21, entry 111:22; 210:1; ! 21142 { envelope 141:22 1 environment 16:21; ' 42:1;46:6; 112:16, 17, 19, J 20:11; 1 24:21; 1.11:21; j 116:1; 157:21; 167; 1 2; 192:4,6; 194:22, 24; drop ft:11; 101:22; 109:8; 1 I 5:1; 190:11; 202:2, 3; 21 1:20, 21 2:1 1.11:10, 12; 182:19, 200:6 207:16 Environmental 404 9; Drug MS;l 1 electricity 10:16 41:6, 15:454,21, 25; due 11 1:17 eliminate 98:22, 1 24:19; 46:7, 13:474,9, 22, 21; duly 8:1 128:1 1; 142:20; 144:4; dump 172:1, 19 I- 14:1 during 55:20;62:1; OS S; eliminated 180:6 76:6; 77:16; 78:8; 81:7; Elmer 69:20; 186:16; 160:10. 161:16; 171:1.1; 188:11 176:17. ISMS; 200: IK; 1 else 67:9; 79:1.4; 99:24; 202:6; 207:1 1 ' 166:10, 171:1 duties -18:7 elsewhere 1 -16:20 duty -18 1 Emmet 77:21; 78:10 emphasis 20-1:7 E emphasized 114:25 48:7, 10; 49:4, 15; 5046; 51:2,S;52:22,25, 54:9, 15; 55:6,7,9; 56:8, 14; 69:9; 73:4, 5; 74:4; 10848, IS; 111:15; 1 12:5, 7, 21, ! 113:8; 12840; 134:5,5, ' 118:6; 1674 1, 191:4, 12, 17; 196:7, 1-1; 20141 EPA 1424 equipment 16:8,12.20, 17:5,8, 19; 18:2; 27:8; 17:22, 24,41:7; 44:21, 21; employed 811, 15; 5149:99:21; 109:8,9, E 71:20, 75: l i each 9:1. 101.6,7, 102:7, 126.21, 21; 127:1. 1.15:1 I; 158:1, 191:9, 25 earlier 10:21; .11:10; .17:19, 51:15; 72:12; 71:-f; 76. I; 79:7;86.-1; 105:2-1; 1 I 1:20; 1 17:21; I 18:6; 119:7; 129:19; 150:12; 169:21; 17-1:20; 190:20; 15:1 5, 64:18; 146:9, 1 7-1:2; 175:12 employee 6725, 71:9; II- 1:21; 171:15 employees 10:24; 2.1:1, 4,6. 51:17, 18;81:24; 169:24, 170: t 5; 171:10; 182:12 employment 51:24 enable 95:21 16347; 187:9,9, 190-11; 207 1 7 1 erroneous 11415 escape 17017; 192:5 ! escaping 171:20 especially 184: IS essence 1 16:9; 192:6; 193:25 essentially 191:20; 2064 4 19- 1:16, 198:8, 22; 199:16 encouraged 207:16 earliest 7-1:1; 81:5, 21 J encouraging 12;i:9 establish 6142 esther 206:5, 12 early 59:21; 60:11; 62 -1; I end Ki: 11; 40:16; 49:9; 66:1 I; 89 10, I I; 107:22, ! 51:20; 1 1 7:1H; 202:7 1 19:1-1; 1 15:11; I 17:8, I 1, 1 ended 201:21; 206:11 15. 20; I 19:8, ];il:2; 137.2-1; 161:20, 21, 202.7, j j ending 151:11, 24 20. 205 12 ; ends 84:25 esthers 116:21 estimate 894 2,95:22; 1104 2 estimation 91:25 European 70:22, 71:4 earn 1681 I, 25 earned 167 2-1, 25; 169: I 1 easily 114.22 easy 1-16:2 economically i72;io educate 121:5; 1 216; 127:7 Educating 121:8 education 1 5 1 Engineer 17 11,12,16, evaluation 2074 9 18, 18:15, 11:17, 64:20; even 22:2, 29:7,18:2.1; 122:21, 168:4,5, 169:4, 12 61:6; i 11:21,25; 114:21; engineering 14:16, 17; 117:2; 153:8, 17344; 20: I f, 42:15; 54:21; 21044; 212:2 64:21; 1 21:14; 122:25, 169:17; 170.1 event 112 21; i 1.16, 14; 1 182:22; 187:8; 201:16 engineers 1148; 554; 121:14 eventually 1641,1948; 12941; 14044; 19619 England 15715 Every 2120; 125:10; enjoy [ 16 5, 12 17144; 17549, 19; educational 1-1:1 I enough 24:1 1; 27:25; 194:10 effect 11 ;8; i 12:16 effectively 128:1 1, 184 6;-1011; 55:22; 61:2; everybody 51:4; 1924 8, 115:1, 153:9; 211:5 203:10 20- 1:12 'entail 10543 everyone 1.12:3 M 1 40; 170:6; 2064 0 209:5 exactly 14010; 1632; i expenses 1 3:11 166:21; 178:17 exam 16849 EXAMINATION 8:6; 160:2, 168:7, 1774, 209:1 5 experience 17:8; 40:10; 58:4; 614 1; 62:7; 76:2; 16112 experiences 75:1 experiencing 80:2 examined 8:4 explosion 138:23; 1394 example 31:6; 75:2, 10, 8542; 100:17; 106:7; I 1-1:20, 1594; 172:20; 185:21, 208:22 explosion-proof Il6:4, 13 explosions 114:7 expose 85:20 examples 1064 except 94:8; 152:2-1; 17.1:4, 193:21 exceptions 1 284 5 excerpt 56:25; 72:4; 81:1.821 I. 16 excess 66 s excessive 66:15. 18; 67:15. 21,684,4; 76:20 excessively 65:6 exchange 107:21, 108 25; 1 20:1; 12.1:7, 25, 1-42:20; 150:7 excuse 2044; 47:24, 84:2; 1 10:22, 14512 executives 11 548 exposed 2.34 1;98:20; 1-18:20; 200:25 exposure 18:22; 25:2; 26:17:604 5;6l43; 6;i:ll; 66:16, 19; 671,5, 12, 15, 21; 75:5:764 3, 19, 2 1; 77:13; 85:21; 86:10, 949; 133:9 exposures 68:5; 80:23 express 173:3 expression 474 0; 5-1:2; 86:2; 109:10; 124:21 extent 594 5; 60:25; 6 117 extreme 1984 0 extremely 29:5 Exhibit 56:24:57:7; 63:21;64:I;6812. 17; F 7146, 22; 72:1; 71:9; 74:22; 7511,16; 77:22, 25; 81:2, 7; 82:1,7; 84:2, f 1; 87:2; 88:1 2, 19, 24; 9044, 22:91:2,93:4,7; 95:20, 25;96:5,99:25; F-9 14746; 148:4, 19,24, 149:9,20,25 facilities 42:25; 70:22; 124:20; 206:20 100:6, 1 I; 101:1,4; facility 43:23;62:7; 1021 I, 18; 101:2; 108:3, 74:18; 134:8 7, 1 I; I 10:4,8, 19, 24; I 1 1:2; I 18:15,20; 12015, 19; 122:5,8, 18, 12-1:4,8, 1 I, 126:1, 5,8, 1 27:22, 128:2; 129:24; 1.10:4; 111:4,9, 1.1249, 21; 1114; 11546, 20; 1.19:4, 7, 10, 1-10:24, 141:1,6, 17; 14144, 18. 21, 1-14:23; facing 137:22 fact 254 1; 80:1; 97:8; 98:21; 104:17, 111:11, 17 24, 10, 179:20; 198:6, 21241 factor 994 facts 194:20 failures 106:25 1-15:2, 2.1, 146:1,4, 7; fair 22:21; 27:25;404 1; 1524 5, 19, 25; 15.140, II, 61:2; 80; 12; 85 4,994 2, 14, 17; 15-1:5,7, JO; 135:1,151:9 1 55:24, 156:1,4, II; fairly 381;51:22; 1 19:8 16547,17148, 19; 1774 1, 1-1, 17; 180:8, 10; ' fairness 874-1 18.1:7,8, 10, 11; 186:2,4; falcon 114:3, 1 5 188:2,-1,8, 1-1; 18946, 18, j fait 32:15; 5944 25; 19245; 193:4,5; j false 6243 197; 1,3, 198:21; 201:2[; j familiar 5749; 584,21, 209:20; 211:7 i 23; 81 4 1,20, 23; 82; 19; effects 8614; 117:21, 21; | enter 284 9 everything 1384 2; Exhibits 15447; 179:21 ! 834; 14016; 157:4 18-1:6 . ! entered 50:5 148:9 . existed 8919; 19140 I familiarize 102:25 drafting - familiarize (6) Mi-U-Scri|tt CARDINAL REPORTING CO, 1-212-227-9490 WATER PCB-SD0000064068 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMPANY, et al WILLIAM PAPAGEORGl: Vol. 1, July 16, 1997 family 13:9; H3; 18:11, 59:12; 205:24 far 23:10; 56:20; 80:12, 15; 12V: 22 farmer 13:8 fatal 76:12, 24 February 50:9, 13, 19; 51:24; 52:17; 69:7; 77:22; 192:13; 193:13,18; 195:9, 13, 16, 20 feed 129:2; 142:12 feel 9:9, 18; 24:1!; 39:4; 165:3; 166:18,24 fees 212:11 fell 52:7 fellow 32:10 felt 74;7; 106:4; !l 6:8; 135:11; 137:16, 20; 162:16 few 8:21; 57:12; 64:6; 126:9; 136:17; 148:21; 166:17; 209:17 field 24:10; 47:8; 105:22; 106:23; 1 10:20; 133:22; 176:10; 182:18, 18 fifth 64:25 file 73:8, 16,21, 25; 74:1, 6, n files 72:17 fill 105:25 final 130:12, 24; 131:2; 212:4 finally 9:23; 114:17; 212:16 find 43:3; 63:10; 104:25; 158:6; 182:24; 195:2; 205:11; 206:23 finding I 17: l; 205.20; 206:5 findings 191:25; 203:7 finds 148:17 finish 8:24; 140:8 finished 30:14; 37:20; 123:12; 137:13 Finley 177:3 fire 109:8, 10; I 14:21; 1 15:4; 1 16:4; 129:5; 206:19 first 8:3, 22; 14:12; 15:14, 15; 17:2, 4; 23:15; 39:20, 21; 41:18; 43:4; 50:5; 57:1. 14; 58:2; 60:15; 65:4; 66:7; 6S:3;70:H;75:25; 78:23, 23; 82:18; 83.16; 84:16, I7;86:10; 92:17,19, 21; 97:2, 17; l 15:14; 1 18:9, 12,17; 125:6; 127:5, 6, 21; 128:7, 17; 131:24; 133:9, 16; 136:1; 146:22; 147:16; 153:5, 11; 156:4; 160:10; 174:19; 176:2; 177:21, 178:19, 20; 181:1, 14, 15; 183:17; 184:7, 8; 186:20, 191:3, 11; 194:12, 19; 195:3; 196:6, 13,23; 198:25; 201:23 fish 113:21; 172:20; 200:1 1 fit 9:16; 162:13; 207:15 five-drawer 73:23 flexible 18:13 float 148:16 floor 27:17; 29:7; 203:17, 23; 204:8 Fluid 7:8; 12:2; 13:11,21; 21:4; 27:23; 28:3; 29:9; 64:23; 97:18; 99:2, 114:21; 115:23; 143:10; 144:16; 145:21; 147:17; 149:6; 150:7; 152:7; 155:9; 162:8,9, 23; 167:15; 186:24; 189:11; 199:11, 11, 11,23; 203:16; 206:24; 210:7, 17,20 fluidize 163:6 fluids 11:18; 12:1,6,9; 14:6, 8,9; 16:2; 17:20,22, 25; 18:3; 20:23; 21:8; 22:6, 12; 23:12; 24:23; 25:16; 26:25; 27:19; 30:2, 25; 35:13, 23, 25; 36:9; 44:3, 22; 47:19; 49:19, 22; 50:20; 5E19, 108:5, 23, 24, 25; 109:3,6,9. 11; 1 10:1; 1 16:20; 1 17:2; 127:25; 128:14,22; 129:2, 4,10; 131:23; 184:18; 185:25; 187:23; 190:10; 193:1 5; 205:20; 206:5,7, 12, 13, 18; 207:4; 210:11 fluorides 173:12 flush 143:8; 144:10, 11; ! 73:5; 210:13 flushed 173:15 flushing 144:9; 1 56:19 flying 162:17 focal 42:7 folks 32:18 follow 160:8; 204:14 followed 36:4; 51:13; 170:21 following 105:10,10; 194:20 follows 8:5 followup 202:10 food I 16:24; I 17:1; 118:11,14; 129:2; 142:1 2; 157:21; 200:5, 205:16,17; 206:14 footnote 59:19 force 25:12; 26:16; 1 14:24 forced 142:10 Foreman 21:22 foremen 19:1 forget 85:19; 111:10; 170:5 forgot 14:1; 17:11; 119:8 form 55:11; 58:20; 60:24; 61:1, 16; 63:6; 67:8, 18; 69:14:77:6; 79:17; 88:5; 105:5; I 19:15; 130:12, 14; 138:3, 19; 141:10; 142:23; 144:4, 153:4, 20; 154:12; 159:9. 179:15; 186:21; 193:17,20 formal 15:1,3;6l:24; 1 19:15; 192:12; 202:14 formed 41:16; 61:22 formulation 26:6 formulations 206:13 forwarded 86:23 forwarding 139:17 found 79:3;83:3; 114:17, 22; 159:14; 192:4; 194:22; 202:2,8; 207:17 foundation 22:9; 23:3; 28:16; 29:16; 31:2; 38:6; 59:25; 62:15;71:11; 79:15; 82:14;88:6;89:16; 91: l(>; 97:12; 98:7, 16; 100:25; 104:14; 105:15; 106:14; 112:9; 149:3; 150:20; 159:7; 174:21; 175:10, 17; 176:1; 180:1; 185:7; 187:10; 189:5; 196; 11; 207:7 four 36:4, 73:23;94:22; 140:25; 147:25; 179:10 fourth 141:14, 16 FR 93:5; 1 18:18; 121:16; 127:8,25; 128:14,22; 132:21 FR-0 96; 1; 101:2, 12, 21 FR-1 100:3; 101:3.9,22 FR-2 151:13, 15, 17 frame73:20;86:6; 105:16; 110:13; 161:9, 22; 165:5,6 frankly 1334 5 free 9:9, I8;97:19;98:5; 179:24 freed 143: l<> Freedom 179:6,13 freely 88:17 frequency 43:4 frequent 107:14 frequently 38:1, 203:8, 18 fried 200:11,11 front 57:25; 76:7; 90:23; 129:25, 141:1; 143:16; 181:1,25; 188:17; 189:22 fulfill 26:21 full 147:8; 176:11 fumes 23:l6;65:4, 16, 20, 25; 66:4,8; 79:9; 80:2; 85:21 function 19:8,9; 30:10; 34:1; 36:18, 2i; 45:9,17; 47:1; 74:17; 112:4 functioned 106:23 furnished 186:15; 188:15 further 18:10;49:8; 82:14; 1 14:9; 144:2; 172:6; 209:12 future 97:6; 129:3; 144:19 ground i6:23; 21 8; 22:25; 210:21 grounds 104:14; 189:14 G G 127:24 G-a-n-n 134:13 group 30:11; 31:16; 34:24; 35:5, 9; 43:18; 44:21;45:10; 49:13; 50:2; 51:2,3; 52:10; 106:4; 108:22; 126:23; 132:10; G.L 124:6 gain 118:2 gained 114:10 Gann 134:13,17 Gann's 135:7 garage 29:6 Gardner 71:5,6,7 133:12; 146:19, 171:3; 176:8: 191:13, 16 groups 54:1 5; 107; 13; 178:8 guess 95:2; 130:18, 146:25: 169:25 guidance 1H`2I; 207:14; 209:5 gaskets ] <3:7 Guide 7:14; 108:4; gate 1 24;20 189:23 gathered 137:17 gave 140:4; 197:8 GE 185:21,23 guidelines 8 21 I gushing 144:17 ! guy 162:16 Gee 99:18; 166:12 general 22:5; 30:23, H 32:12; 33:8; 34:12, 14; 39:6; 43:14;63:22; 85:7, | H 162:22 10, 24; 87:2; 91:13, 17, 20; 104:9, 10, 109:20; 137:7; 138:5; 161:7, 10,10; 162:10; 163:14, 16,22; 169:5,6; 175:15 generally 109:17 generate 170:24 generated 110:13; 174:5; 183:21 H-a-y-w-o-o-d 71:20 H.R 77:23 hair 113:21; 202:10 half l 1:14, 15, 12:23, 24; 15:25; 16:6; 177:7 Halfway 58:6 hallways 135:10 halogenated 57:17 generating 170:23 Halowax 62:21 generic 109:10 gesture 9:3 gets 29:5 given 11:l, 11,16, 24; 12:5, 13, 17,22; 13:1; 19:14; 46:19; 49:3; 61:10, 88:14; 143:5; 182:10, 12; 185:11, 17, 19; 192:17 hand 42:15; 147:3; 179:2, 5 handed 168:15 handle 22:1; 34:6, 8; 51:3; 85:17; 203:21 handled 22:12,37:22; 45:12; 170:8., 10, 16; 171:9; 184:5 gloves 70:5 Handling 7: to, 12; 26:7; goes 80:16; 172:2; 178:23 golly 89:13; 176:18 good9:22; 33:4:34:6; 38:15; 51:20; 85:12; 90:20, 124:22; 137:8; l60:4, 5; 172:22, 22 27:11; 58; 10; 63:23; 84:24; 87:3; 93:6; 100:3; 108:20, 171:11; 186:9 hands 23:15; 182:23 handwriting 130:17, 19, 20; 181:14 handwritten 128:17 goods 171:5 Gosh 14:1 Gossage 127:25; 133:1(1, 11 Gossage's 133:7 government 42:3; 47:13; 114:23; 115:11; 207:3, 14, 17 government's 207:11 governmental 42:10; 66:25 grabbing 203:25 greatest 70:9 Grooming 7:7 happen 34:2; 107:18; 125:2; 159:13 happened 37:25; 46:8, 59:3; 86:25, l 11:13 happening 171:12 happy 9:25; 37:24 HARCKHAM 22:8, 23:2; 28:7, 15; 31:1; 38:7; 39:9; 40:6, 22, 47:24; 52:1 I; 55:17; 56:5, 57:4, 59:24; 61:5, 14; 62:14; 65:11,22; 67:19, 68:6, 71:10, 17; 734 l;77:15;79:14, 82:1 3; 83:13; 86:1 5; 87:1 2, 24; 88:7; 89:15; CARDINAL REPORTING CO Min U S ("0 family - HARC.K11AM WATER PCB-SD0000064069 WILLIAM PAPAGLOKGL Vo I. 1, July 16, 1997 KLYNOUXS MLTALS COMPANY v. A IVINA CASUALTY & SUIUVI'Y COM l*A NY,ct a l V(J: 1 1 1:1 S; `,>2:2, *; 25; 65:2; 66:3, 6; 616-1; hol 22:3 ! important 56:17; 99:3: j 182:6, 1 1; 186:0, 15; 96. 19:97:1 1 ;08:6, 1 5; 1 79 8; HO: I 3,20:85:25; hour 177:7.8 | 1 15:2, I 16:3 ! 188:15; 105:10; 202:6, 12; ')'M; IDO 25, 102:1 2, 86 3, 98:1 3, 208:20, 20 hours 165:1-1 I impression "0 5; 138:5, 20.3:11:209:1 ini i.v 105 6, i f, lo(,;9, 12. 1 12:8. 1 1.2 Si 1 I LID; l 17 11, I 20 5: I AO 12, I 5, I I'.l 3; 1 12 2 1, I 10 2; 150.10; 151.3: 150 0. 10; 100:25; 17215: 175:2, 15. 17-L7. 10, I 75:0, 10, 25, 177:2, 1, I 8: 179.18, 22, Head 118:17; I 52:13 heading 65:2; 1 27:6; 135 17, I 5-1:21 ; I 79 6, J 8 5: 3 headquarters -11 1 3; 1-16:21; 160:12, 16 1 heal 76:23 house 97:5 j 13, 162:15, 16, 16-1:2 ! HTM 99 2; 105:3, 138-23: impressions 26; 15 ; 161:21; 162:6 impulse 20,3 25 huge i9L7 ! inches 7.3:21 Hulcher 15-1:25: 115:13: incidences 129 l, 3 160:18, 19.22: 161:2,3,8, Incident 62:5, 76:1, 5, 15.23; 162:11, 21, 16.3:2.3; 1(H): 16 informational 88:1 3 informed 13:11,22, 62:25; 166:6; 101-3,6,9, i 25 informing 120:9 ingestion 771-1 ingredient 101:23; I HI): 7, M, 15, 21; 183; 15, health J 3:9, K<; 53 15, 16-1:6, 166:9 incineration 51:17; 199:13, 15.15 185:3. 1(1, 10; IH0:7, 187 15, 17; I UK-1, 7; 17; 56:15, 21, I 72: U 9 hear 9:8; ] 1,5: 5 Human 58:3, 8 hundreds 177:21 1 55 :2, 15 5:3, 6, l 5; 156:25 ingredients 20:25; include I 1:7; 16:22; 100:3, 159:11,22, 150:2 180:9, 15, 21, 100:25; 101 2; 102:0, 21, 10,5:1.0; 195 I I. 105 5.0. Lf, 100:2. ID, 1 2; I 07.H, 1 I, I OK: I 5, 20,2(17:0,0, 20K: l 6, 1 H, 22; 200:7, I I, 25; 211.12 hard 29:5;-15:5, 1.5; Oil 6; I 1.5:1 H, 1H1: 2 harm 15:5 hatchabiiity I 17:25 hatching 111:2 hauling .55 11 HAUSMAN 8 7, |K. 22 10; 25 9. 28 0. I 5, 1 7, 20 17. 51 5; 58 8, 50.1 I. fO 1 5, 25; -1 t -1; 18-2. 52 15: 55: [1, 21, SO 10; 57 0. 10. (>0 5, (>l :2, (>, 19: (i2 17. (i 5:1 2; fi-i05 15, 25: 07:20, OK: I 1,21; 00:1 5; 7 1.1 2, 1 5, 18, 72.2: heard 59:5:70.20; 132:5; l.C:17,'2(), |59;16; 162; LI, 17, 166:25 hearing 162:2 heat 12:1,2; 1-1:5; 17:10; 1 27:1 t, .32;24, .36:8, II; I .38:21), 22; 39:2; 95: 1; 07: 18; 9H:3; 105-3; I 108:25; 1 15:23; 1 16:23: 120:3; 121.18,21; 123:7, 25.25; 128:12; 120:1,8; | I3S--I; 1 38:1 5; 1-12:20, I 51) 7; 1 55:17, 161:1 1; i 162.7, 22; 163:6; 167:15; I 78 7; 180:3; 103:22; ; 199:10. 21,200:9.9; j 205.J5; 206 ! 3, 16, 17 ] heated 107 21 Heater 7.2; 109.22 heating 11:2.3; 100:23 heavier 150 1 I heavy 76.1 3; 11 3:20; hydraulic 12:6, H:9; 17:22; 21 :-l, 8; 22:6, 12; 23:12; 25:22,25:16; 26:25,27:19; 28:2;33.3,' 55:25; I 15:23; 1 16:20, I 17:2; 155:21; 15717; 150:6; 152:7, 186:25; 193:15; 199:11:205:20; 206:5,7, 12:210:7, 1 1, 16, 20 hydrocarbons 57:17; 59.12, 15, 17 hydrogens 102:8 Hygiene 55:3 1 hygienist 86:21.22 1 Hygienists 66 25 1 i.e 15:8 I 30:25: 35:25, 36:8;57:18; 55:22; 191:1 3; 195:15 included 53:18; 62:2.3; 88:12, 157:1; 173:10; 105:7 Includes 07:8 including 76:12,82-3; 100:21; 105:1 I incomplete 85:5 increased 33 22 Increasing 1 28:9 Indemnity 8:19 indicate 9-1.8,97.9; 157:7, 151:25, 195.5; ' 106:6 ' indicated 37 : L`l; 87 : I H. 1 06:1, 3, 102.15, 128:1". 129-25, 1.30:1; 1.32:21; L36-IO, 10. 151.1, 1-13:16, 157.3,6. 15; 156:7,8, 12, 186 18; 192:8; 196:13 inhalation 68:5; 70:io, 12; 80:16 inhaled 65:6; 66.9 initial 17:7 l Initially 5;3:10;62:23; 205:21 initials 135:25; 168:2 initiate 128:13, 21 inks 119:17,19919 Inn 116:15 1 innocuous 173:1 5 j insisting 121:17 ; Inspection 7:13; 189:23 installations 97:18, 98:5 instead 18:1 5. 19 15: 185-19 Institute 55:25, 1 10:1 5, 120:2; 131:21 i instituted 120 8, 155:1 instruments 38:11; 7.5-1 I, 75.20, 77;H, IK; 200.2,3 idea 115:6, I [6:21 | indicates 0 f 11; 151:18; 158:22:201:15 78.8; 70:21,81:10, 82 10, hold -11 2. 71 :'25; 9.3:1; identical U)9:2; 159:22, 186:15; 188:15 insurance s:2(), 11 7, 12, 17, 85:1 5:8-1:1 -I; 87.1, 17, 127:18, 156:23; 156:1; 151:22; 195:6,6 Indicating 1 i":l 2 16,25; 12:3,5, 17,20 25,88:18; 80:5. IK; 00: IK, 150 21, 176.23; 190:25; 22; 91:0, 19,92:'!, 6, ID; 209:0 identification 57:8,65:2; indications 92:11; 95:21, intend 119:11; 128:15 68:18;7I:23; 75:17; 78:1; I 2,3 intended 07:10; 100:21; 0.5:5, I 1,06:9,22; 97:15; 08:8,25:99:10; 100:0; 101:1; 102:15, 21; KM: 15; 105:7, IK; 106:16; 108:12; 111.5; 112:1.5, 11.5:2; I 1-10; I 17:10, 1 18:2-1; 120:6,2,5; 122 12; 125 17; 12-1:2, 12; 126:0; 127:20, I 2)5:5; I 50."; 151:1 5; 15.5:2, 1.55:25, 1.56:10.25; 157;15, 2.3; 158:1-1, 22; I 30 1 I; H 1:7, I 13:13, 22, I I I 22; 1-15:6, 156:8; 159:5; 150:2-1. I5l:-i, 1 52:22; 155 IK; 1 S-f II; I 56:3; 1 59:19. 25, 161:19, 169:18; I 79 15, I KO J; 185:7, 187.1(1; 189:5, 13, 209.16; 2l 2:1 -I hnven'1 I02:,3 Haywood 71:20, 75: M hazard 79; 12; 98:17, 179:7, 1.3, 25; 1KO:5; 191:5; 196:8, 15; 208.9, 23; 209:2 hazardous 65 6 Help 15:5; 16:8; 31:19; 5-1:2,81:15; 86:2; 107:2; 1 53:23 helped 1 LL19 helpful 8.5:3; 207:18 herd 13:9 Here's 38.17 hesitate 59:1 2; -16:1 hesitating 51:10; 101.1.3 high 70: 10; 10-1:2; 105:1 1 j higher 101:21, 23; 118:1, I 158:8. 1 2. 25; 199 2, ", 8 highways 16913 himself 162:12 hislory 76:11 Hmm ] .39:1 3 hold -11.18 Holiday 116:1 I home 106:7; 125:23; 209.19 hope 101:13 hose 20--f: 1 hosed 29:5 81:8; 82:8; 85.12; 88:25; 9L;3; 93:8; 96:6; MX):7; 102:10; 108:8; 110:25: 1 18:21; 120:20; 122:9; 125:9; 126:6; 128:3; L30:5; 131:10, 132:25; 135:21: 139:8; 151:5; 153:19; 155:3,156:5; : 152:20, 153:15, 155:8, : 177:15, 180:1 I; 18.3:11; 186:5, 188:5; 189:10, i 103:6; 107:5 \ identified 158:25 j identify 158:15 identity 11316 ignorance 160:2 ignore 172:1,9 1160:3,6,15 ill 185:6 illegible 85:7, 8; 127:23 Illinois 122.25 Imagine 177:7 immediately 163:IB impact 171:25 Indirect 7:1 individual 66:1 l;80;l,6, 157:10 individuals 25:12; 56: i 8; 127:1, 197:17 Industrial 56:17; 50:1,5; 52:10. I 3, 53:1; 55:,3; 66:25,25.815, 15;H2:2, 20; 86-21,22; 1 1.3:20, 25, 1 18:1 3; 129:8 industries 52 5 industry 55.22: 152:8, 209 5 Inerleen 109:21 infant 11 3:2 l inform 98:10 Information 7:lu, 12; 25:1; .30:25; 32 19;5l>\3: 52:13; 5"; 19;60:16; 61:25; 62:1, 3, 10, 25; 63:22; 75:23, 25,85:23; 86:18; 87:3, 88:1 l, 17; 100:17; 105:25; 107:2,7; l 12:18; 1 I 3:15; 1 15:5, 10, 15; 117:1 1; 1 19:12, 18; 1 10:5,0, 10; ! 8-5:16,21 intent 9:15; 16:25; 29:18; 97:1;98:10, 12,22:99:11, 15. 17; 132:6, 175:20, 182:23 intention 98)21 interacted l65:9 interaction 1.35:22 interactions 5 2 20 Interagency 115:25 interest 75:8, 75 5.6, 155:18:205:22 interested 85:22, 97 5, 102:6 interesting 182:2 1 Intermediate 59:3,6, 12, 16,21,21,51:9,52:8, 22; 53:2 internal 97:15 interpret 155:2 interrupt 90:15,106:10, 205:5 into 16:23; 21:8; 22:6, 13: 23:16; 26:19:28:3,21; hazards 2-1:17, 22; 3-f:lO; hosing 29:8; 20-1;! implemented 196:25 1.30:23; 132:8; 1.35:18; 29:3. 5: 36:15, 15: 51:25; 35:1 ;.3(>: LI; 37:3; .59:8, 2-1, . host 107:15 imply 955 r 158:22; 162:12; 176:7; 52:7; 59:15; 72:22, 25; hard - into (8) Miii-U-Script CARDINAL KRPOKHNG CO. I-212-227 9490 WATER PCB-SD0000064070 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMPANY,et al WILLIAM PAPAGEOUGE Vol. 1, July 16, 1997 73:1 1; 76:10; 98:25; W3:22; 110:1(5; 113:19; 1 16:20, 23; 117:1; 120:11; 123:1!), 20; 128:7; 129:2; 130:2-1; 131:23; 132:9; 158:5; 161:8; 162:17; 165:1, 19; 170:17; 171:9, 16, 20, 172:6, 19; 182:23; 210:17; 21 1:3; 212:1 introduce 172:9 Introducing 28:20; 1-16:2 investigated 103:3 invited 33:8,9 invoicing 35:12 involve 11:17,25; i-C5 involved 12:6; 13:13,17; 23:7; 33:25; 33:2, 5, 7, 22; 35:15; 50:7; 52:5; 53:7; 71:3; 101:5, 106:6; 107:11, 17; 119:6; 129:1; 135:1 5; 1 57:13; 158:3; 167:17, 19; 171:3; 180:2; 182:15, 183:22; 190:9; 19919; 206:19 involvement 33:9; 52:1, 16; 83:2; 137:19 Irish 57:2, 15,21, 21 irresponsible 173:5 Irving 82:3, 21 isolated 203:5 issue 31:25; 32:2; 96:16; 131:22; 132:6; 138:6; 191:12; 202:16 issued 23:16, 22; 37:7 issues 23:10; 55:9; 167:10; 190; 16 Item 153:5; 186:21 items 153:25 itself 26:23; 76:23; 109:23; 122:21; 138:17; 1 56:20; 173:23 J________ J-e-s-S-e-e 123:6 J.A7L5 J.C 50:12 J.W 71:2 January 69:6, 21; 83:6; 85:6; 126:3; L88:13 Jessee 123:6; 1 25:12 job 15:23; 17:9; 26:3; 36:1; 38:1, 1; 130:1; 203:12 join 31:3; 30:8; 56:7; 71:13; 105:17; 1 12:10; 132:23; 159:10 Jones 58:7, 16; 59:18 July 100:1, 10; 120:17; 122:7 jumped l(35:1 June 118:16 jurisdiction 52:8 K keep 23:19; 29:18; 32:7, 11; 98:23; 99:23; 118:17; 125:7; 153:25; 170:11, 171:20 keeping 35:13 keeps 103:1; 133:17 Kelly 77:23; 78; 10; 179:21 kept 11:5; 72:17; 73:1; 83:12, 13; I 13:13; 135:13; 153:13 key 113-A kills 172:20 kind 26:21,21,29:19; 31:21; 32:17, 21; 33:5; 75:3; 86:18, 99:22; 100:17; J06:7; 1 13:3. 3; 117:5; 118:10; 133:25; 138:13; 162:13; K>K;l6; 176:6; 181:1; 187:12; 203:13; 206:11 kinds 37:22; 3 5:15; 53:1 1,85:22; 88:10; 96:15; 123:1,23; 123:18, 22, 132:3; 135:13; 163:21; 200:1 1 Kingdom 157:15 knew 23:11; 39:17; 80:18,21; 171:15 knowledge 1137:3; 65:19, 20; 83:22; 85:3; 87:5,9, 19. 88:2; 97:23, 98:9; 106.18; 118:12; 133:21; 137:1; 153:23; 155:7; 158:21,22; 167:18; 169:20; 173:13; 175:22; 176:3,3, 5; 189:7, 10 known 18:1 1; 22:25; 35:9; 1 17:13; 1 18:3; 135:1 1 knows 123:18; 127:3 Krummrich 59:7 L L 153:11; 156:3 label 25:2; 109:6; 196:20, 23; 198:17 Labeling 7:20; 37:6; 196:23 labels 25:3, 9,30:22; 85:19, 131:21; 196:6, 13, 13; 197:23; 198:7 laboratories 32:3; 192:1; 203:8 taboralory 130:1; [65:3 lack 22:8; 23:2; 28:15; 29:15; 31:1; 38:6; 59:23; 62:15;7l:10; 79:13; 82:13; 88:5; 89:16; 91:1 5; 97:11; 98:6, 15; 100:23; 105:13; 1 12:8; 139:2; 150:19; 1 59:6; 175:9, 16, 25 lacquers 199:13 landfill 29:12,13,20; 31:10; 125:11; 201:2 language 179:11,12; 197:21, 23; 198:6,6 large 29:3; 53:18;99:2 larger 56:25;93:5 Larry Uo: 17,18; 166:10 last 58:3;83:7,21;92:7; 93:11; 97:16, 17; 103:25; 123:20; 126:12, 15; 133:16; 130:18; 132:13; 162:3; 173:25; 188:13; 192:22 lasted 32:2; 202:5 late 22:3; 23:11; 23:16, 25:15, 18; 28:1 1; (50:13; 117:8; 161:21; 163:3; 183:13; 200:13; 202:20; 205:19, 25 later 36:12; 50:l6;55:6; 62:25; 77:I9;92:23; 103:23; 183:23; 201:7; 205:13; 206:15 latest 203:7 latter )6:6; 27:25 lawyers 10:21 lead 63:3,9 leak 116:10, 11; 163:18 Leak-Free 118:18 leak-proof 121:7 leakage 26:16; 27:3, 10; 120:3; 121:19,23; 125:5; 127:8; 129:8; 138:7; 163:17; 170:25; 186:22; 187;8,9; 188:23 leaked 125:19 leaking 105:3; 115:25; 138:15 leakproof 98:11 leaks 97:19; 98:5; 99:3, 12; 128:12; 163:10,12,13, 23; 210:6 learn 30:3; 76:3; 99:15; 107:21,23; 117:20; 192:7; 201:10 learned 58:25; 59:21; 68:3; 77:8; 80:13, 22; 107:19; 117:11; 121:7; 201.8 learning 18:22; 76:25; 77:11, 19; 79:3; 113:13 least 29:8; 60:13; 83:3, 17; 83:21; 92:23; 130:15; 167:9; 178: l6; 18-1:12 leave 211:5 leaving 30:13; 98:23; 99:8 led 112:21; 113:13; 1 13:11; 126:2; 172:13 left 17:5; 32:15, 15; 138:5; 179:5; 198:13; 201:3 legend 97:9; 152:16 legible 128:6 less 11:13, 15; 12:23, 23; 139:25; 150:22,23; 193:21; 195:23; 199:3; 202:1; 211:17, 25 letter 111:9; 112:3, 11, 12; 121:20; 139:3, 12, 13; I 92:2; 97:16; 102:22,25; , 103:22; 130:5; 136:22; I 156:5; 159:15; 178:23; 206:9 ! looked 23:8; 1 23:2; 201:19 130:12; 131:10, 22, 23,25; 133:23; 160:20; 165:10, 12; 191:23; 192.8; 193:12, 17; 193:5; 195:10,16; 197:25; 202:13; 211:23, 23 letterhead 83:3 letters 193:13; 193:2,7, 25 level 67:1,3,5 levels 67:12, 22; 11 5:3 Levin 160:7 Liberty 160:7 librarian 73:17,19 library 72:21,23; 73: i,9; 73:12; 83:12 looking 88:11;89:13; 130:10; 1 57:23 looks 138:6; 158:16,20 loop 128:1 1 loosened 13 3:9; 133:15 lose 172:10 loss 27:10; 121:19, 23; 125:6 lot 113:19; 1 16:19; 206:22 Louts 8:3, 12; 13:19; 17:13, 15; 20:3. 5, 16; 28:19; 31:22; 33:16; 37:1; -10:20; 31:7,8; 75:9; 88:22; 136:20,21; 157:16 lower 158:6, 25; 159:16; lies 70:9 liked 123:23 limestone 20U:25 limited 22:11 line 90:8, 106:15; 118:17, 178:20; 187:16 179:2; 183:25; 195:23; 202:8 lubricating 186:23; 188:25,-210:6, I l, 13. 16, 20 lunch 90; 17; 93: l lines 70:13; 159:17; 166:25 M liquid 27:11; 953 2; 99:7; 123:25; 133:17; 138:6; 139:17 liquids 51:17 M.D 77:23 machinery 18:7; 26:25; | 27:3; 32:23; 38:3, 10; 39:3 list 136:16; 132:7,10; 173:13, 15; 185:23; 191:8; 198:3 listed 67:11; 127:1; 133:15; 187:1; 197:18 lists 67:11 literature 56:15,20; 76:10,92:21 litigation 8:20 litigations 11:8 little 76:10; 97:21; 121:6; 133:23; 139:1 1; 150:1 1; 162:1 liver 76:11,15, 21,22; mail 55:25; 73:7; 88:16; [ 166:6 j mailings 182:16 | main 80:25 I maintain 99:23; 163:17; l 203:23 | maintained 73:12,13 Maintenance 7:13; 20:1-1, 15, 15; 21:6; 23:23; 25:6, 10,20, 23:26:18; 28:10; 29:25; 31:13; 51:17; 138:8; 170:1,3, 13, 19, 23; 183:22; 189:23; [ 190:11 77:1,9, 12; 79:3,12, 23; j major 207:13 80:1,9, 16; l 18:7,8 I majority 33:6 livers 118:3 j makeup 169:19 located 28:18; 33:15; making 8:22; 19:1; 33:6; 37:1; 115:5, 135:8,9 [ 62:8; 101:6; 1.33:17; 163:8 location 31:12 man 63:17; 130:21 logo 89:19.21,23:90:5; 92:11, 17,19; 119:16 long 10:16; 17:16; 19:11; 20:6, 19; 25:23; 35:15; 30:13; 35:23; 37:21; 38:23;52:2I; 53:3, 19; 73:25; 80:8,8; 166:15; 178:13; 202:3 longer 50:17; 66:13; 167:13 manage 203:1 2 management 133:21; 133:1,2 Manager 21:23; 35:19; 36:12,37:6, 12,39:10; 10:13, 18,-11:5, 15;-15:1, j 20, 23; 36:7, 13,-17:16, 22; 38:3,6,7, 17; 53:12, 55:5, (>, 7; 56:3,9, 13; 69:8; [08:17, 1 M:i5; 125:13; look 58:1,2; 82:18; 83:20; 133:3; 200:18; 203:13; fARDINAL *''`PORTING CO 7 12-277 Mi CO) iotrodneo - Manager WATER PCB-SD0000064071 WILLIAM PAPAGEOKCE Vol. 1, July 16, 1997 REYNOLDS METALS COMPLY v. AETNA CASUALTY & SURETY COMPANY,Ct al 208:3 materia! 18:10; 19:3; Managers 46:!8 manned 74:19 manner 99:24; 165:25 manual BI:If>;82:1 1 20:25; 21:2; 22:1 2; 23:18; 25:3, 13; 26:20; 27:14; 29:1 1; 30:13. 13; 36:6; 43:16; 47:6; 51:20; 58:10; 74:7;85:17,98:18; 99:1; manufacture 176, 19; 105:21; 1 13:16; 139:10; 18:3; 19:19;35:22;36:1; 140:3; 144:13. 17; 147:21; 207:25 154:2; 155:3, 13, 16; manufactured 59: If; 156:16, 18,20,25; 157:25; 90:9 manufacturer 208: K); 209:1 manufacturers 44:7; 109:8: 208:5, 5 Manufacturing 30:12; 31:20, 20; 34:15, 24; 35:6 I58:N; 164:10; 170:8, 10; 171:8, l 1, 16, 20; 173:10; 190:3; 192:1; 196:20; 204:3; 205:9 materials i;3:17; 16:21; 1B:12; 21 2; 22:1,24; 23:7; 26:7; 33:11; 49:7, 10; 74:6; 82:3, 20, 108:21; 1 14:19; many I I :4, I 1; 12:21; 1 15:2U; 129:13; 170:16; 21:13, IS; 28:21; 67:12, 173:8, 14; 204:16, 19; 12; 80:2:8.3:2, 18, 19; 208:10 95:14, 14, 18, 18; 126:22; 136:5; 142:1,7; 158:2; 161:13; 170:24; 181:21; 204:13; 2(K>:20 March 111:13; 186:14, 187:4; 191:6,10, 16 mark 63:21; 177:11; 180:7, 183:7,8, 186:1, 188:1; 189:15; 192:15. 197:1 Mather 71:20;75: 14 matter 37:9; 105:23 matters 54:9, 11, 15; 56:21; 69:12; 123:4 maximum 67:2; 78:25 may 9:13, 16; 32:16, 20; 55:25; 66:1; 79:19; 1 15:16; l 16:14; 123:13; 142:9; 1-13:1; 144:2; 150:13; 158:16, 19; 172:4, marked 56:23; 57:8; 6; 181:10; 189:4; 196:25; 64:2; 68:12, 18; 71:16, 23; 198:7 75:12, 17; 77:21; 78:1; 81:2, 8; 82:1,8;84:1, 12; 88:19. 25:90:13:91:3; 93:4,8; 95:24; 96:6; 99:25; 100:7; 102:11, 19; 108:3, 8; 1 10:19, 25; 1 18:15,21; 120:14,20, 122:4,9; 124:4,9; 125:25, 126:6; 127:21; 128:3, 129:24; 130:5; 131:4. 10; 132:19, 24; 135:16,21; 139:3,8; 140:24; 141:4; 143:14, 19; maybe 81:12; 1 27:25; 166:21; 194:17, 17 mean 29:14; 38:1 1.24; 66:22; 68:13, 78:15; 86:3. 93:21;99:1; 106:9; I 19:22; 134:2, 139:23, 150:4, 162:7; 166:2; 184:11; 187:11:202:12; 208:20,21 means 29:10; 94:17 measure 55:16; 148:22 144:23; 145:3,22, 146:5; measures 137:24 152:15.20; 153:10, 15; mechanic 26:19 154:4,8, 177:15; 180:1 I; media 94:1 183:11; 186:5; 188:5; 189:19; 193:6; 197:4; 198:21 marketed ;36:11; 44:21; 133:12 Medical 36:25,37:2; 40:4, 1 I; 60:2; 61:1, 17, 20. 23; 62:4; 63:15, 18; 69:6, 24:70:21:72:11, 17. 21,23:73:1,9:74:8, 16, marketing 24:6, K); 18, 19; 78:1 3, 22:83:12, 40:20; 88:14; 104:19; 20; 86:19, 20, 21; 96:16; 106:20,20; 107:12, 13; 100:18; 186:16 108:23; 125:22; 127:6, 10; 145:15; 146:18; 176:9, 13; 178:10; 202:17; 203:3 medium 17:20; 36:9; 38:21; 39:3; 138:16; 162:8,23; 163-6 ' Marsh 1 26:2 meet 10:13; 42:22; 47:13; Massena 43:22, 134:8, 135:9 20; 138:16,25; 156:8, 10; 161:25; 162:22, 24; 163:1 1, 24; 164:6 meeting H):l6; 107:13, 17, 131:7, 24,25; 132:13, 16; 135: 18; 136:4; 165:17 Master 14:16 ; meetings 19:5;22:22; Master's 14:25;15:18; I 104:20; 106:22; 107:14; 167:24 j 136:5; 137:2 match 9:13, 158:17, 18 i member 26:18; 53:25; matches 158:15 i 54:5,8, 12, 13, 20, 24; 55:2; 103:16; 205:23 memo 78:17; 123:2,5 Memorandum 7:18; 72:3,6, 75:19,78:16, 129:21; 197:14 memory 59:16; 60:15; 101:10; 149:16; 203:10 memory's 32:3 mention l63:13;203:6 mentioned 70:15; 72:12; 76; 1; 79:23; 81:21; 82:12; 1 14:15; 171:4,24; 199:10; 207:24 message 23:19; 25:2; 137:9,194:24 met 19:2, 3; 64:17; 70:20 metal 14:2; 73:23; 156:8 Metals 8:21; 10:11, 21, 24; 25:17:43:11, 23; 51:25; 52:17; 53:8; 136:9. 10; 137:2; 177:4; 191:14; 202:22; 203:4,6 meter 79: l method 31 ;7 methodology 200:21; 201:5, 13 methods 30:25 metropolitan 28:18,20 middle 92:14; 119:24; 197:20,206:8 might 112:12; 116:21; 125:23; 133:25; !4():5; 148:14; 173:14; 182:24 milligram 79:1 Milwaukee 14:3 mind 13:18; 29:19; 50:8; 172:7; 198:2; 199:20 mine 88:7; 168:13 mineral 148:7 miniature 204:1 1 minimize 98:21,22 minimum 121:19,23 mink 13:5,6 Mintz 16)0:7 minute 40:24; 87:13; 1 16; 1; 123:11; 190:24; 209:8 minutes 159;20 miscellaneous 193:25; 205:3 mischaracterizes 174:20 mlsidenliflod 159:2, 5 missed 13:18; 185:1 5 Missouri 8:3,13; 168:6 mixing 172:6 mixture 36:5; 62:21; 94:9; 102:9 mixtures 36:2,8, 10 Mm-hmm 38:2 molecular 102:6 moment 13:IB; 32:! 5; 198:2; 199:20 monitor 104:5; 107:20 monitoring 157:13,17 MO NS 57:3; 63:25; 68:16; 71:21;75:I5;77:24;8l:5; 91:l;93:6; 96:2; 100:4; 102:16; 108:6; 110:22; 1 18:19, 120:18; 122:7; 124:7; 126:4; 128:1; 130:2; 131:8; 132:22; 130:9; 186:3; 188:3; 192:16; 197:2 Monsanto 7:13; 11:17; 12:1,7; 13:12; 15:15, 19; 17:2; 22:5; 24:9, 16; 25:15; 30:24; 32:10; 34:15; 36:3, 21; 41; 14; 42:6,8; 44:2; 45:9, 10; 46:16, 17;47:13; 49:1,2,5.8, 19; 50:10,20, 51:14; 53:13, 17, 18, 25; 54:13:59:14; 62:6;64:19; 71:9: 75:3;78:12, 18;81:4; 82:5; 83:2, 12, 19, 23; 84:3,4:85:7,24,86:6, 11, 17;87; 10, 20;88:21; 89:19; 90:6,9, 10, 24; 91:10, 13.20; 93:18,95:5, 25; 96:16; 97:9, 24; 98:2; 99:20; 100:2, 18; 104:8; 105:9; 108:22; 109:5, 12, 15, 23; I 10:1,9; I 12:22; 113:7, 18, 24; I 14:5, 10; 115:10. 18; 117:8, 12, 16, 20; 119:11; 120:1; 121:6, 13, 21; 125:15, 17; 126:22, 128:20; 129:9; 132:13; 134:2, 23; 138:1; 140:14, 142:4, 17; 143:25; 146:9, 12; 152:3; 153:4; 154:14; 157:1 1, 14; 160:1 1, 17; 162:13; 166:6; 172:13; 174:2,5, 10, 17; 175:6, 12, 22; 176:13, 17; 178:2, 15; 179:1 1,24; 182:2.7, 12; 184:25; 185:12,18, 19, 25; 186:17; 183:15; 189:22, 22; 190:3,8, 13; 191:3,6; 192:10, 14; 193:16, 24; 196:5, 13; 202:13:203:15, 22; 204:1 5; 206:6, 23, 25; 208:1,6; 211:1,24 Monsanto's 26:25; 35:20,36:25:69:24; 70:21; 86:19; 97:4; 103:17; 112:3; 121:16; 122:24; 131:5; 166:20; 178:7, 185:20, 24; 190:9; 193:13; 202:12; 210:12 month 126:21 monthly 126:25 months 50:6; 136:17; 166:17; 205:13 more 37:24; 51:16; 99:2, 3; 116:11, 16; 1 17:17; I 19:15; 121:6; 149:24; 157:24; 158:3,4,7, 15, 16; 159:16, 24; 161:6; 169:16; 192:7,7, 193:17; 199:3; 202:6,6; 203:10; 204; 12 morning 168:16 Most 10:18; 27:9, 10; 128:6; 191:9 mouth 165:19 move 21 1:3 moved 115:10; 116:20 movement 30:12 moving 29:23 much 42:5;45:14; 80:7; 90:19; 99:7; 125:10; 142:3; 159:24; 170:22; 176:20; 190:20; 201:16, 16; 209:13; 212:15 multipage 56:24; 63.21; 88:20; 90:23; 108:3; 1 10:19; 126:1; 129:24; 131:5; 132:20; 152:16; 153:11; 177:12; 180:8; 183:8; 189:16 multiyear 118:10 must 27:1 5; 97:19 Mutual 160.8 myself 42:14; 54: J2; 70:8; 121:6; 123:8; 202:24 N N 82:3, 20 N.G.H 68:15:70:24 name 8:8, 18; 14:2; 57:21, 22; 84:7; 94:4,7, 109:20,21: 127:23; 128:17; 136:10; 140:16, 18; 168:2 name's 160:6; 177:3 named 100:2; 134:23 names 1 1:20, 5 1:23; 70:24; 95:9; 109,12; 136:20; 142:2; 152:23; 153:2. 19; 166:12 Nancy 160:6 National 110:15; 131:21 nature 12:25; 15:24; 18:6, 23:26:12; 35:4, 5; 37:16:44:8,51:6: 164:1; 173:23, 174:8; 175:5, 23 near 23:6; 29:21; N3:21; 117:17; 202:8 necessarily 97:14; 109:1 necessary 19:4; 26:10; 121:10; 144:20 need 9:24:38:9:43:8; 57; 11; 98:1 1; 99:21; 137:18; 144:8; 163:16; 167:1 I; 175:18 needed 121:22; 140:2 needle 202:10 needles 113:19 negative 138:11 neighbor 172 22 net 1.37:16 Nevertheless 115:6: 116:17 new 23:18; 40:23; 42:12; 43:22; 47:8, 14; 53:14; 59:16; 104:23, 105:25; 128:13,21; 129:10:132:5; 143:10; 144:16; 152:16; Managers - new CIO) Min-U-Script CARDINAL REPORTING CO. 1 212 227-9490 WATER PCB-SD0000064072 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMPANY,et al WILLIAM R-VPAO LOIU,,. Vol. 1, July 1(\ 1*W7 156 8; 162:18, 203:3 28:1 5; 29.T5;31:[; 3:5, 7; once 90:18; 116:18; 1.32:5; 162:1.3, 1-1, 172:5; j 1-29:25; 135:17; 136:1,9, newly 11: Ki `10:6; 52:1 1; 55:10; 56:5, 137:9; 165:23; 166:2, I f 182:17; 206:23 ! 13; 139:3; 130:25; 1-1.3:15; Newman 70 8, 19,21; 59:2-1; 60:2-1: 61:5, 15; one 17:5; 28:23; 29:21; otherwise 6.3:10, 111.19 ! 1-16:22, 137:16,1 M9 5, 77:23 62:1-1; 6;3:5; 65:11,22; 3-1:23,-13:1 1:'1-1:9: -17:3, ought 87:1 5; 99:3, 150:3, 151:23; 152.1; next 20:22, 25 21; 10-1:1 6; 1-12.13, M, 138:19; 192:10, 12; 198:1 nitrochlorobenzene 39' 10 no-no 28:21 Nobody 115:25 nod 9:3 non-consecutive!y 192:23 non-medical CiO:2S; 61:18; 63:6; 79:17 non-PCB -10:22; 203:18 noon I0:|7 67:19; 68:6; 69:13; 71:10, : 50:1-1, 15,51:25:57:12. 165:11 153:11, 12; 156:5, 12; 13:73:1 I; 77:6, 15,79:1-1; 82:13, 86:15; 87:1 2, 13, 66:23; 67:20, 68:12; 69.5; ours 38.25 72:3; 75:13:77:12,22; ' OUl 16:1, 21:9; 26:20; 17-1:13. 25; 178:19. 25; 179:6, 181:1, 183:23,2 3, 91:15; 9619. 97:1 1; 98:6, 78 7, 25; 80:1 -1; 81 ! 2; ! 25. 186:2, M. 20, 20. . 15; 99:-1, 100:2-1; 105:-i,6, 83:17,8-1:2; 86:9; 93:1, j -11.6, 7, -18: U, 52:16; ! 188:2, 13, 17, 192.1 5. 22, 1-1; 106:1-1; 1 12:8, 25; l 13:10; 1 17:1-1; 120:5; 1.38:18, 1-12:22; 1-19:2; ISO: I 9; IS 1:3, 159:6, 1 1; 166:23; 17.3:2, 13, 17-1:7, 19; 175:9, 16, 25; 185:1,6; 187:10,11, 2-1; 191:23; 19-1:8; 195:1; 196:1,9; 207:5; 208:13; 209:3 96:20; 101:25; 102:5; 119:10. 120:15; 121:13, 122:5; 123:1-1; 125:7, 21. 1.39:5; M2 1, I 15 25. 1-16:3; 1-18:1, 155:10, 156;-1,23; 158:1-1; 161:6; 167:10, 17; 168:12, 16; 170:1-1; 173:21,22; 175:6, 23; 177:2.3; 179:21; 93: 17; 100.18; 101:15; 10-1:25; 106:2.3; 112:19; 1 M 3, 25; 115:1, 11, l-l; I 16: 10. 15, i 17:6; I 2-1: 20, 1,35:-1, 1.36.8, 138:12, 20; 1-13:7; 11-1:2, 18; 153:2; I55T6; 156:19; 158:17; 161:1-1; 165:23, 168:22; 170:1 1; 171:7; 176:6, 10; 180:16, 18; 182:23; I 2-3; 191.19; 195:3; 197 2. 20, 198:25, 201 23; , 211:13 pages 82: l,-1; 131:11, 16 paid 138:8 pain 66:9; 67 25; 70:1 5 paint I 15:20; 205:3 paints 199:13 objections 79:18 180:15; 193:1-1, 15, 17,23; 192:18; 193:18; 19-1:20; pair 23:18 objective 22:15,16, 2-1; 196:18; 197:1; 203:9; 196:21; 197:8; 201; 1; pamphlet 67:9, 10 normal 16:15; 10-1:18; 203:2-1 207:13 203:3, 10 pamphlets 88:13 1-10:13; 13-1:13; 202:13 obnoxious 65:5, 21; 66:1 ones 80:25; 1-16:3; outdoors 97:20 pan l63:19 northeast 13:0 observations -10:10 180:16 Outside -15:8; 97:10, Papageorge 7:19,8: l, note 128: U.; 133: 21; observe 12-118 only 3-1:7,-12:8; -17:12; II 6:1 3 10, 28:9, 315; 56:25,57:8. 1-17:2; 198:11 NOTED 212:19 Nothing 23.! 3, 136.8, 138 11,20, 155 3: 159:1-1, 17, 161:13; 203:9 notice 167 13 noticeable 66:8 November 15:16, 19, 17:1; 102:16 observed 58:9 obsolete 18i:i-i obtain 10618 obvious -19:9; 1 18:8 occasion 2-1:6; 3-1:1,21; 37:7, 15;-12:2-1,-13:1, : 72:22, 25, 106:8; 109:17; 1-16:9; 203: l-i occasional 29:5 51,12,62:9,8-1:15; 98: 21; 1-16:25; 180:2; 210:12 ' onto 16:23; 21:8; 22:6, ; 25; 203:16; 210:21 ooze 116 1] open 115 19, 1 16:18; 205:6 opening 1 13 6 operate 38:20,99:21 oval 90:5, 8 j over 9:1; I 1:5; 15:12; ! 22:22, 22; 26:20; 36:7; 12:18,-18;-(l M;-19:23; 50:1; 52.2; 53:2-1; 97:25; 1 17 9, M2: 17; 159:5, 160:19. 181:5, 10; 190:12; ; 192.20 ] overall 70:1 10,63:2), 63.2, 5; (> 18, 22; 71:2.3; 72:3,75:17; 78.1,79.19; 8 I 8, 10,82:8. 10,8-1 12, 11, 88 25, 91: .3, 7,93:8, } l; 96:6; 100,7, 102:19, 21; 108 8; 1 10:25; 1 18:21, 120:16, 20, 122 6, 9; 123:6.9; 126'1,6; i 127:21, 128:3, 5, 18, ' 130:5.7, 131-6, 10, number 1113; 36:1, 5-1:18; 57: I. 3; 63:25; 65:1; 68 16; 75:15; 77:2-1. 82:5; 8-1:9,93:6;9-l:23;96:2; 98:19; 101:8; 102:6; 108:6; 1 10:21; 1 20:18; 122:7; 12-1:7; 126:2; 128:1; 132: 22; 135:18; 139:6; 1-11:2; 1-13:16; 1-15:1; l'17:25; 1-19:5; 151:13, 15, 23; 152:9; 153:13; 151:6; 156:12; 157:2; 158:25; 177:5; 180:8; 181,9,25, 197:2; 199:6 numbered 192:22; 195:-l; 201:22 occasionally -15:23, 150:1-1 occasions 1 1:-1; 12:16, 21:39:18, 20, 23 Occupational 53T3, 16 occurred 62:5; 76:2; 163:18 occurring 60; 12 occurs 172:2-1 ocean 172:13 off -10:22, 25, 50:8; 88:15; 92:2-1; 1 1 1:1; 117:2; 127:17; 136:23; I-1-1:18; 152:12; 156:1; 159:19; 176:23; 182:19, 190:23, 25; 192:21; 193 3, 20i:-i; \ Operating 30:17; 51 22, ; 172:23 operation 18:19; 3<>: 11, 15; 38:16,71:3; 172:8 Operations 7:3;-13:16; -19:-1, 15; 50:1 6; 51: 2, 8; 52:22, 25, 171:1 Operator 21:22 opinion 6l :10,12,17, 20, 22; 62:! 2, 16, 18; 70:9; 187:6 opportunities 170:25 opportunity 97:22; 1-12:12 Opposed 156:19; 182:11, II overbroad 38:5; 55:t 1; 61:15,67:18, 77:6, 79.16, 88:5; 105:5; 138:3, 19 overexposed 66:12 oversee 170:1 5 overseeing 19:8; 36:13 oversight 19:2-1 own 19:M; 25:12; '26:25; 18-1:19 owners 18-1:17 P P 186:16; 188:15 p-h-t-h-a-l-i-c 189 ; 132:23, I 33:3; 1 35 21, 2.3; ; 137:1, 139:5,8, 1-10:25; 1-11:3; 133:19; 133:25; 135:3; 1 16:5, 152:20, 153:1. 10, 1 5; 153:8, 159: 2.3, 160: 1; 177:3, 15, 180:1 1; 18.3:1 1. 186:5; 188:5,7; 189:19, 191:2, 193:6; 196:5; 197:3; 209:11, 17 paper 8:23; 11 5.20; 199:17; 205:1 1 paragraph 58:3,3,6; 70:7; 75:25; 76:9; 78:23; 83:17; 97:17; 102:2 3, 10.3 8, l 12:2; 121:15; I 132:13; 178:21; 193.12, numbers 68:2,71:21; 81:5; 90: 25, 9-1:3, -1,7, 8, 1 l; 100:5; 102:16; I 18:18; 209:7, 9 offered 168:22 1-17:5, 15.3:7; 1 56:15; offering 26: H 177 12; 183 9, 186 3, , office 106:7; 125:23; 188:3; 189:16; 192:16 133:8; 135:10 o official 1 li . often 3-1:2; 13:2, 107:18 o'clock 10:17 object 61:15; 67:17; 77:6; 79:16; 82:1 -i; 87:2-1; 88;-!; 89:16; 10-1:13. 105:1 5; 123:10; 1.38:2, M5:5; 159:8, 172:15, 17-1:20; oil 16:1,-1.29:6,1-18:7,7; 150:12; 171:23; 186:2-1; 188:25,210:6, 13,1-1,16, 20; 21 2:3 oils 200:10; 210:11 oily 1-19:17 Oklahoma 15:2.3 opposite 1 59:17 oral 8:23 orally 13-1:11 order 121:17; 129:3: 168:6 ordered 109.19 orders 15:12 Ordinary 18-1:1 organization [66:5 organizations 51:5,8 orientation 22:21 oriented f 5:8 original 136:16, 16; 155:5 P.E 168:2,8, II, 19,25, | 169:2,10 1 P.J.A 1 26:2 P.J.C 71:20; 75:13 P.M 212:19 packages 197:21, 198:2 packaging -17:6 packing 1-1-1:16 page 57:1, l; 58:3; 63:25; 68: J 2; 71:18; 72:3; 75:13; 77:22; 82:3, 18, 8-1:2, 5, 15, 16, 21; 87:1 5, 15, 19; 90:7, 23:92:3,7, 19,20; 93:3, 17; 95:25; 96:3; 97:17; 100:1; 102; 1-1, 2-1; ! 18,23; 195:3, 19; 19619: 197:21; 198:1.25; 201:22; 211:16 paragraphs 2-i 25; 179:10,12 paraphrase 165 20 Pardon 169:2 part 19:10; 21-25; 22:20, 21.21, 15:16; 56:17; 72:1 1,21; 107:6,9; 120:9, I 123-5, 1 5.3:25; I 56:25, 162: 1, 10; 165:5; 1 79:17; 1 185:25 , partial I 98:5 participant 26:8 179:15, 180:1; 189:5, 13; old 103:23; 129:12; originally 31:17 103:8; I 1 1:2-1; l 18:16; I participate 130 3; 21:7; 208:16 138:10 others 66:1-1; 75:-!, 7, 11; 120:15; 122:5; 123:5; I 26:1 I; 32:1 1.21; 5 3:9; Objection 22:8; 23 2 Olson 7:16, 1-15:16. 17 100:21; 109:22, 1 27-1; 126:12, 15; 127:6,22; I 5-1:15; 195:1 , <:/ '"SINAI. R'ov'pnTNr r'C\ ' T i - AIEn-U-ScWoO"' C f O iiowlv - part h'i pair* WATER PCB-SD0000064073 WILLIAM PAPAGLOUGL Vo I. 1, July 16, 1997 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMPANY, ct al participation 26:13 11)6:20; 107:1 2, 13; particular 34:24, 36:5; 91 I8;0 4:0, 21. 22; 0*i: l '2: 100: r0, I 17.S:22, i7-1: i 3; 175:5, 23; 192:7; 195:15 108:22; 125:22, 23; 126:2, 22; 12.7:1 I; 132:4, I 66:4, 8, 13, 176:25, 17-1:15, 175:24; 178:9; 182:24; ! 202:17 particularly 75:8 I per 32:9:79:1; 150:22 parties 97:6 parts I 50:22 pass 168:6 passage 57:15, 24; 58:11; 179; 16,19 passages 64:7 passed 76:8; 174:14; 202:15; 207:22 passing 176:6 past 60:9; 90:19 paste 127:5 patience 159:25 Paul 105:12, 16; 154:13 PCB 13:11, 17, 21; 20:25. 25; 21:1; 35:15. 22; 56:2; perceive 31:2); 116:3; 173:14 perceived 113:20; I 15:24; 173:4; 175:18 percent 94:14,17, 102:9; 194:22; 195:24; 196:3; 202:1; 211:17; 212:1 percentage 94:12, 25; 101:21 perception 187: |4 ! peregrine 114 3, 1 5 perfect 158:18 performed 126:22 perhaps 116:17 period 15:25, 16:6, 44:3; 47: IS,49:19; 50:10, 24:16; 25:15; 28:8; 30:22; 17, 20; 56:21; 61:15; 33:18; 53:6; 55:19, 20; 6,5:1 l;64:22; 80:23; 101:19; 108:20; I 14:12; 125:24; 124:25; 128:9; 129:10; 151:5,23; 145:20; 147:24; 149:10, 13; 150:5; 152.16; 153:12; 154:6,21, 22,25; 155:1,9; 156:16, 20, 25; I 57 20, 22; 158:3; 159:15, 167:15; 184:17; .185:25; 187:22; 189:1 I; 190:`J; 191:11; 200:23, 23; 201:16; 202:16; 203-16; 204:16, 19; 207:3 PCBs 13:5,8; 18:4, 19:22; 40:21; 4 t :25; 42:10; 43:6; 46:20; 48:1 l, 15; 50:7:51:3,5,7, 12, 17, 52:2; 56:16; 58:24; 60:23; 62 8,21:63:1,4,15; 76:1 5, 19:77:2, 9; 80:14; 86:5; 101:17; 103:17, 18; 59:1;60:3; 68:9; 85:24; 88: l; 89:12;96:21/97:25; I 15:12; 1 17:7, 10; 176:16; 179:23; 181:18; 183:19; 190:13;200:18; 205:19; 206:3:207:2, 11; 208:25; 210:10 periodically 1 90:15 periodicals 55:23; 56:2, 8 persistent 1993 person 21:15, 20; 41:18; 50:10:61:1, 18; 63:7; 66:12, 12:71:9; 79:18; 84:8: 127:3 personal 26:15; 40:9; 61:4; 97:4; 1 10:21; 137:18; 166:6; 176:4; 184:4; 207:18 personally 43:21; 52:5; 111);2; 112:20; 113:19, 25; 55:24; 6 1:21; 134:13; I 14:17; 1 16:25; 1 17:22; 135:15; 140:21; 182:20; 118:2; 120:12; 124:19; j 202:24; 204:7 125:20; 129:1; 137:7; personnel 45:6; 83:20; 140:2: 142:3.20; 143:4,9; ! 203:14 144:3; 147:19, 22; 148:15, 20. 24; 155:4; 157:5, I l, 18,21,24.24; 158:2,7; 164:10; 165:22; 167:8, 11; 173:9, 10, 1 1; 183:1, 4,5; , perspective 113:24 pertaining 72:18 Petroleum I 5:22; 16:9. 23 187:18, 188:21; 191:5,7, pharmaceutical 118:14 18: 192:2, 3,5, 14; 193:16; | phase U5:14 194:21; 196:8, 15; 199:18; 1 phased 165:23 200,19; 201:1,6, 8,25, 205:21; 207:1, 12, 25; phasing 117:5 211:17, 25 phenate 35:10 Pebble 8:2,12 phenol 35:9 pelican 114:i Phillips 15:22; 17:5 pelicans 114:16 phone 73:7; 140:13, 15 people 21:13, 18; 24:5, 31:20. 21; 33:10; 45:11; phosphate 116:21; 175:6; 206:5, 12 66: 13; 84:22, 87:18; photocopy 126:13, 14 88:14; 98:19. 104:19, 20; photographed 141.23 phrase 112:6, 14 phlhalic 18:8 Physical Jtft:20; 178:22 pick 29:9; 107:2; 124:25; 125:19 picked 17:7; 29:9; 200:22; 201:5 picking 29:23 pickup 30:19 picture 54:12 pieces 82:15 pike 162:18 pine 113:19; 202:9 pinpoint 205:1 pipe 163:20 pipeline 26:19 pipelines 144:15 pitch 162:25; 163:4,7; 164:9 place 193; 36:24; 51:21; 53:1 1;86:10; 97:2; 99:23; 106:8; 107:22; 115:12; 125:6; 138:9, 24; 158:2; 164:4; 165:11; 192:13; 201:13; 205:21 placed 196:19; 198:7; 204:7; 206:23 placing 64:16 plant 18:20,20:5, 18, 21, 22, 24; 21:20,24;22:13; 23:1; 24:4, 5, 13; 25:17; 26:24; 27:24; 28:18, 22, 25; 30:10; 31:22; 34:15, 17, 18; 35:19, 20, 20,22; 36:12, 19,20; 37:6. 12,21; 38:3, 14, 19; 39:7, 10; 40:10, 14; 41:1 J; 43:10; 56:3,9; 59:4,7; 68:9; 75:4, 107:1, 15; 122:24; 124:18, 20; 125:13, 15; 134:20; 138:17, 25; 139:2; 161:25; 162:22; 163:24; 164:6; 169:25; 170:1,8,10, 16; 171:9. 25; 172:3,6, 14; 181:22; 200:13, 14, 18; 203:14; 208:3, 4 plant's 20:13 plants 51:2, 13,202:9; 203:15, 15 plastic 199:16 plasticizer 193:24; 199:15 Plasticizers 7:5; 18:11, 20; 19:16; 181:4; 183:1 plastics 18:12 played 54:10 please 8:9; 9:9; 13:3; 87:13; 137:15; 146:24; 178:24; 198:21;201:21; 204:23; 209:21; 211:8 pliable 18:13 plus 101:14 point [6:19; 18:24; 31:9; 38:23; 42:7; 43:25; 44:2, 17, 20; 49:14, 17,1H; 52:6; 57:12, 20; 64:7; 76:22; 77:19; 83:4; 87:14; 80:10; 20; 145:9, 11; 146:13, 16; 89:20; 90:20; 103:21; 175:14 114:5, 23; 135:2,3; 142:10, JK; 157:23; 164:10; 194:19 policy 128:13, 15.21 pollution 16:17; 112:5,7, 23; 113:8; 136:1 polychlorinated 192:3; 205:22 pond 200:24:201:4 pool 210:23 poor 62:9; 115:16 popular 199;I8 preparing 97:1; 121: i, 122:15; 139:12, 14; 154:19 presence 42:1,2; 62:24; 112:17; 143:4 presences i 1 3.25 present 107:4; 109:4; 112:20, 132:17; 137:8; , 194:23; 202:2;2)1:18 J Presentation l ]0:20; II 1:11,12; 132:2 President 44:12, 14; position 16:11,16; 17:2, 4; 25:6, 10, 21; 26:19; 32:1,7; 34:12, 20; 35:16; 38:14; 41:16, 19. 21; 45:5; 52:21; 69:21; 78:20, 21; 103:15; 108:19; 207:11 positions 23:5; 55:8; 74:5 possibility 158:24 possible 29:8; 66:21; 76:20; 1 10:12; 115:10; 1 17:12, 191:4; 204:9 165:4 pressure i6:4;27:l l; 116:10; 142:5 pressures 1 28:10 pretty 50:12; 90:19; 91:18; 129:22 prevent 16:25; 21:16; 27:2; 99:3, 12; 120:3; 163:17; 167:12; 171:1 I preventing 16:22; 21:7; 86:9 possibly 57:1; 92:1 I prevention 16:17 post-graduate 14:14 preventions 16:18 potato 200:10 previously 47:19; 135;H potential 34:10; 35:1; 36:14; 39:25; 68:4; 76:15; 77:1,9;79:. 12; 85:25; Primarily 2I:4;43:6; 128:25, 176:9, 182:6; 200:9 112:5,6, 15, 17,23; 1 13:8; primary 67:16; 112:4; 117:21; 118:7; 178:11; 202:17; 203:23 182:7; 194:23; 196:7, 7, principal 134:17 14; 202:3; 208:9,19, 20, 23; 211:18 practical 148:23 principles 27:9 i print 85:13:93:5; I 10:16, 140:20 practice 30:23; 39:6; 85:7, 24; 86:7; 87:20; 91:13, 20; 96:18; 98:3; printed 182.1 6 printing 199:19 104:5,9, 10; 105:2,12, 13, prior 1 1:1; 73:6;H2:24; 20; 125:1; 187:7; 209:4; ' 107:12; 181:18 210:13 I probably 148:21; 177:7 practiced 16:18 I problem 31:21; 34:8; practices 27:12; 105:9 practicing 169:8 preached 23;20 precautions 23:10, 14; 26'6 . 80:9; 112:5,7, 24; 125:8; 137:21; 138:7, 12; 163:24; 165:24; 166:2, 14, 16, 22; 167:1 I; 191:18, 21; 194:23; 202:3; 208:23; 21 1:18 precursor62:6 problems 31:19; 80: 14; predate l6l:18 113:9; 125:9; 165:22; predominantly [6:2; 172:5,7,9:211:6 107:1 I procedure 27:24; 120:2; prefer 125:1, 5 186:22; 187:21; 188:24 preferably 204:10 premises 98:24 preparation 10:8; 96:23; 1 11:18, 119:7; 132:9 prepare 10:2; 134:14; 141:24 prepared 40:4; 71:9; 88:21; 89:12; 92:1; 108:21,22; 111:21; 121:3; procedures 23:2l;27:2, 5,7,9, 18, 107:20, 22,25 process 14;2; 17:10, 1 2, 16, 18, 18:15; 31:17; 49:8; 106:17; 157:4; 162:23; 16 3:7; 164:11; 167:7 processed 18:10 I processing 200:6 produce 132:2 122:17; 124:15; 126:19; produced 57:5;81:3, 18; 131:6, 16, 132:2; 133:18, 82:5; 84:3, 16; 208:4 participation - produced (12) Miii-U-Script CARDINAL REPORTING CO. 1-212-227-9490 WATER PCB-SD0000064074 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMPANY,et al WILLIAM IVU'AGIXMU ,1: Vol, 1, July 16, 1997 producers 12:10 producing 19:14; 201:16 product 25:1,2; 30: M; 35:1; 37:20; drt:IK; 17:10. 16; .18:3, 6, 11, 17; 19:9, 11; 55:7; 59:6,8; 91:18; 91:9; 95: H; 1*17:7; 152:3; 171:16; 182:15; 196:6,13 production 19:2,17; 33:10; 136:20; 170:25; 206:2 products 16:23; 21:5; 30:21; 31:23; 35:5,13; 16:21,22,25,17:2, 17,18; 18:11; 85:20; 95:5, 19; 96:16; 99:20; 1 11:12; 117:1; 129:2; 117:15; 182:8 professional ll:12; 15:8; 99:22; 168:1,1, 5, 169:1 program 26:8,9, 22; 107:7, 9, 10, 115:18; 1 17:2,3; 1 18:10; 120:8, 9; 130:13; 131:6; 131:12; 110:1; 111:1; 155:9; 167:13,20; 196:21; 205:19; 206:15 progress 123:2; 131:7, 16 prohibited 28:5 prohibition 28:11 prohibitions 28:1 projects 207:11 prolonged 85:21 promote 129:11, 11; 178:6 promoted 179:21 promotion 180:2 prompt 105:21 proper 29:1 1,33; 30:25; 17:6,7; 51:18; 85:16; 108:20; 111:19; 171:10; 180:1 properly 21:12; 170:16 Properties 82:2, 20; 88:20; 116:5; 178:22 propose 35.7; 191:9 proposed 26:1 5; 31:7 proposing l6:!3;32:17 protect 16:6 Protection 16:7, 11; <17:1,22,23; 18:8, 10; 55:7; 108:18; 131:6 protocol 1 58:13 prove 76:23 proved 111:11 proven 60:22 provide 32:13; 38:3, 20; 86:12,91:20; 1 19:11; 133:13; 209:1 provided 91:10; 119:19; 116:17 provides 92:8 providing 2*1:1; 32:22; 33:1 proviso 116:23; 153:19 Public 75:10; 175:15 publication 132:9; 190:1 publications 55:9, 15 published 67:1,1,7,8, 182:1 publishing 182:1 pump 32:17, 17; 111:16, 18 pumps 33:3; 38:11 purchased 112:3; 185:25; 191:9;208:21 purchasers 85:25 Purchasing 81:9 pure 150:13 purple 118:6; 119:17 purpose 112:11; 182:1; 200:2 purposes 118:23; 193:1 pursuant 1 33:19; 155:9 push 16:1 put 29:3; 32:17; 97:25; 100:18; 108:20; 130:12; 132:9; 115:25; 161:8; 163:19,19; 165:19; 192:19; 201:10 putting 127:3 puzzled 65:1 5 Pydraul 115:19,20; 117:16; 118:1, 19, 21; 119:5,8, 11; 151:25; 152:3, 9, 10; 187:1,7, 12, 12, 13, 17; 188:18, 20; 189:3; 210:5 Pyranol 109:20 Q qualified 39:1 quality 19.3; 17:5; 62:9; 88:22 quantity 156:7,22 quick 205:22 quickly 12:5; 102:21; 116:12 quite 9:l6;65;5, 20; 70:6; 76:1 1; 83:3; 1 16:8; 121:22 quoted 197:21; 198:6 R R 77:23; 78:10 R-i-t-c-h-i-e 68:11 radiator 199:25 rags 29:10 ranches ) 3:6 range 55:15, K>; 126:3; 130:2; 131:8; 110:5; 115:21; 152:17; 193:3 rate !0l:2; 105:11; 158:1 rather 9:5 raw 30:13 received 11; 13,15; Re 7:19 reach 31:9 reaches 76:22 react 118:17 reacted 165:21 read 9:10; 56:15; 57:11; 63:9, 13,11,16; 68:20; 75:19; 78:3;81:l 1;9310; 96:8; 100:11; 103:25; 108:10; 111:21; 118:23; 15:18;55:19; 176:7; 178:12 receiving 138:15,23 recent 191:25 recently 10:23 recess ll:2;71:25;93:1; 127:18; 159:21 recipe 109:19 recipes 119:15; 152:1 I recipient 81:6 1 20:22; 121:2; 122:l i; j recognize 75:23,21; 123:17, 20; 121:11; 128:7, | 91:7; 93:12; 96:9; 100:12; 19; 139:10; 113:21; 115:5; 151:21; 152:2; 162:3,1; 180:23; 181:2,9; 185:11; 186:10; 191:5; 212:18 reading 56:19; 1 58:21 reads 58:7; 65:1; 70:8; 76:10; 78;21;97:)8; 1! 2:2; 1 18:17; 121:15; 127:7; 153:1 1, 12 ready 171:1; 177:10 real 32:3;79:21; 1 ll:21; 130:18; 138:12 really 10:19:31:16; 12:M; 13:8; 16:5; 50:18; 59:16; 115:15; 121:5; 133:20; 135:11; 162:11; 169:7, 180:5; 190:22; 196:18; 198:1; 206:11 103:3,1,7; 108:13; 111:3; 118:21; 120:23; 122:12; 121:12; 126:10; 128:18; 130:9,11, 17; 131:13; 133:3; 111:7; 113:22; 115:6; I 53 20; 1 51; 12; 177:18; 180:21; 183:15; 186:11; 188:10; 190:1; i 193:9; 197:11 recollection 11:23; 12:7, 10;33:1;53:7;72:5; 73:19; 101:20; 129:16 recollections 180:21 recommendation 11:10, 11; 115:17 recommendations 125:22 recommended 67:13 reask 61:7 recommending 33:2 reason 9:21; 51:10; 95 8, 10; 1 11:6; 135:21; 191:13; 211:16 reasonable 115:7 reasons 28:11,23; 112:7; 155:5 recall 11:13; 12:2,8,12, 19, 25; 13:2, 15,23; 20:7; 21:21; 25:18; 31:6; 32:22, 25; 33:l;13:l; 16:16; 52:16, 56:19; 57:11,20, record 8:9, 23; 9:10, 21; 10:22; 11:1; 90:1; 92; 25; 100:13, 11; 127:17; 128:8; 136:13, 23; 137:1; 111:23; 150:1; 159:19; 171:23; 176:23; 190:21,25; 192:13; i 95:12; 209:8,9 recovery 16:3 red 80:6 redacted 136:13,20; 152:23; 153:2, 20 23; 58:16,25; 59:3;61:10, 12, 18,67:6,8, 10; 68:3,8; 69:1,3,1, 11,16; 70:1,3, 11; 71:1; 72:9; 73:18; 71:22,25:75:20,22;76:5, 17, 25; 77:11, 18; 78:1; 79:1; 83:5; 86:8; 89:3, 7; 93:11; 100:15, 16; 1 I 1:7; 119:3; 121:1,2,3; 122:15; 121:15; 1 25:17; 126:18; I 28:19; 131:36; 132:12, 17; 133:7; 131:15; 136:3, 11; 137:1,1,6,7, 12,23; 138:15, 22; 139:2, i I, II, 19; 110:22; [19:13; 1 52:11; 161:7,20, 22; redirect 209:18 reduce 121:19; 125:9; 111:3 reduced 180:5 refer 21:19; 65:16; 70:11, 87:2; 109:15, 18; II 1:21; 127:5; Ml: 13; 153:7; 155:21; 156:11; 183:23; 188:16; 198:20,21; 201 ;2J; 209:20; 211:7 reference 59:5, 1 l, 20; 60:11; 62:5, 23; 81:21; 83:1.6; 85:1 6; 1 i 2:15; 116:2; 150:12; 162:25; 181:9; 187:1; 191:11 - 161:23; 165:5,25; 177:21; 178:17; 179:23; 181:16, 17,20, 183:17; 185:8; 191:21; 191:9; 196:22; 198:5; 199:5; 203:2; 201:21; 205:11; 210:7 receivable 116:18 references 57:19; 178:20 referred 10:10; 18:20; 36:3; 15:10; 59:19;85:20; 101:2,3; 192:2; 193:12, 21; 198:8; 205:6; 209:25; 211:12 receive 11:22; 37:9; 55:9, referring 27:23; 67:22, 11,23; 56:2; 131:6,10 70:23; 7 5:7,8; 7 6:1; 82:21; 90:5; 100:19; 102:1; 107:10; 113:1; 126:12; 150:3, 156:16; 173:8; 179; 16; 197:21; 199:6 refers 60:6; 65; 10; 81:8, 17; 103:8; 110:11; 112:7, 11; 157:19 refine 28:1 Refinery 16:7 refining 16:8 reflect 127:10 reflected 109:19; 155:10, 12, 17; 156:22 reflects 92:18; 117:16 refresh 119:16 regard 21:22; 17:1; 51:7; 52:2; 60:22 regarding 25:2:26:15; 31:23; 38:15;62:10; l 13:15; 110:9; 151:1 Registered 168:5 registration 169:6 regulations 51:11 regulator 13:22 regulatory 13:11;97:7 reimbursed 21 2:5,8 REIMER 160:3,6; 162:7; 167:1; 172:25; 173:7, 17; 171:8, 23; 175:1 1,21, 176:2, 20, t85:l,(., 11; 187:1 1,21; 191:23; 192:21; 191:8; 195:1; 196:1,9, l l; 198:1 1, 19; 207:5,7; 208:13, 17, 19; 209:3; 212:16 reissued 178: 18 relate 169,16 related 11:25; 51:1 2; 98:18 relates 18:1 I; 190:10 relating 16:20; 93:18; 105:21; 205:15 relations 26:3 relayed 86:18 release 16:20; 21 1:25, 212:2 released 201:17 releases 21:7,16 releasing 22:5,21 relevant 71:8 remain 2J0:2i remember 10; 18; 11:20; 17:10; 25:19; 33:5; 35:2, 8, 8; 52:19, 20, 51:16, 23, 55:12; 56:1, I l; 57:22; 60:1,2. 13; 6 1:15,71:6; 71:2; 79:10; 96:11; 101:12,13; 111:9; 129:22; 133:15, 16; 138:1, 5, 10; 118:5; 150:21; 152:10; 153:22; 161:5; 162:1 I, 25; 163:3, 12, 11; I 61; 12, l6; 165:9; 176:19 remind 151:11 reminded 23:8 cardinal ro, i (M9'i (I O jirmlut'rrs - reminder! WATER PCB-SD0000064075 WUXI AM PAPAGLOKGL Vo). I,July If>, 1997 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COMl'ANY.et nl remove 159:1 5, 211:1 respect 22:1; 85:17, reorganization 49: l; 1.1:2, i l repeat 25:8; 162:1 169:10; 187:22;I89:11; 199:21 respectable 43:15 rephrase 9:9:38:9; 171:6 respirator 23:17 replace 47:18 replaced 205:21; 206:1, 12 respond 24:11;79:19; 133:24; 145:17, 18 responded 165.23 replacement 104:2, 5; responding 165:10 101:1 I; 201:12, 18; 206:18, '23 response 137:10,24; 139:16 replacing 129:12 report 44:16; 18:17; 19:18, 61:23, 24;62:2, 6,1:18, 19:64:9, 1 1; 106:2; 114:24; 126:21; 134:15; 137:12 reported 44:20; 58:7; 74:19 reporter 57:9;64:3; 68: 19; 71:24; 75:18; 78:2; 81:9; 82:9; 84:13; 89:1; 91:4,93:9; 96:7; 100:8; 102:20, 108:9; 111:1; I 18:22, 120:21; 122:10; 123:21; 124:10; 126:7; 128:4; 130:6; 131: M : 132:25; 135:22; 139:9; 141:5; 143:20; 145:4; 146:6; 152:21; 153:16; 154:9; 162:3, 5; 177:16; 180:12; 18.3:12; 186:6; 188:6; 189:20; 193:7; 197:5 reporting 40:19; 44:13 reports 37:3,7; 40:4, 1 1; 63:14, 17, 86:12; 87:20: 114:1; 134:6, II; 138:15, 23; 155:18 responses 9:9 responsibilities 16:11, 17; 21:21; 23:25; 26:2; 30:1; 32:8; 34:20; 37:14, 17; 46:9,13, 20; 50:3, 10. 17,20, 23,24 responsibility 21:7,12, 16,25; 24:4; 26:5; 32:9; 33:23; 36:13; 47:16; 51:7, 10; 74:3; 196:14 responsible 40:20; 108:23; 1 14:6; 122:25; 154:18; 176:6 rest 43:7; 135:9 restate 105:8; 110:7 restrictions J 69; 11 result 22:7;62:22; 66:9; 77:12; 105:23; 124:17; 137:16 resulted 20:25; 21:1 resulting 8<>;22 results 117; 1 tt retain 48:6; 50:25; 143:9 retained 46:20; 47:15; 52:24 retired 53:20; 103:19, 2) represent 8:19; 84:! 5; 145:25; 160:7 return 138:9; 154:1,25; 155:1,3,8,13 representative 24:9; 176:9, 13; 182:19 returned 155:5, 1 5; 156:16 representatives 24:7; 34:2.3; 42:9; 1 13:18; 142:1; 182:18 representing 10:21; 54:13; 177:4 reprinted 119:14 request 7.3:6; 86:17; 1.39:17; |15;I0 requested h6:23;88:16 requests 176:7 Returns 153:12; 154:6, 21,22 reuse 27: j 5 reveals 76:11 review 10:7, 10; 14:1 1; 133:9; 188:8 reviewed 26:10; 188:9; 197:10 Revised 7:14; 26:10, 153:12; 178:18; 182:17; Research 16:1; 36:14, 15; 71:4; 103:17 189:23; 190:15, 18 revisit 160:25 residing 8:2 REY 135:19; 139:6; residual 16:4, 144:3; 141:2; 143:17; 145:1, 24; 158:10 152:17; 153:13; 154:6, residue 143:8 177:12; 178:25; 183:9, 25; Resins 7:4; 181:4; 182:25 189:17 , resistance 129:5 i I Reyn 43:25 resistant 109:9, 10; I Reynolds 8:20; 10:11, 1 14:21; 206: t 9 21, 24;'25:17; 43:11,23; resisted 142:4 51:25; 52:6, 17; 53:8; 84:3; 132:15, 17; 131:7, 20; resolved 165:24 135:4; 136:9. 10; 137:2, resource 24:8 24; 138:16, 24; 139:1,20; 140:17; 141:18; 152:24; 156:8; 1*0:1 2, 16; 161:14, 25; 164:25; 165:18, 20; 166:5, 16, 19; 175:24; 176:14; 177:4; 191:13; 202:22,203:1,4,5 Richmond 160:12, 17 rtd 30:15, 1 16; 18 Right 9:1 5; I0:)3; 11:23; 14:10; 15:14; 22:14, 19; 23:9; 24:3, 14; 26:24; 31:12; 32:22; 34:3, 4; 38:19;39:11;42:16, 24, 46:24; 6(1:17; 63:20; 64:13; 66:2; 71:17; 75:12; 76:9; 78:17; 80:10; 83:11; 88:7;90:2,21;92:5; 93:25; 94:10,95:2; 100:23; 101:10, 22; 108:2; 112:13; 124:2; 127:13; 133:23; 134:4; 137:10; 138:14; 140:4; 147:3, 14; 148:19; 150:6: 153:9:154:3; 157:3; 164:3, 15, 19,21; 165:9; 166:22; 169:12, 16; 170:14; 179:2; 184:1, 194:11; 195:5, 14; 198:17, 17, 202:11 Ritchie 68:14; 70:16 river 34:16; 172:13 RLD 84:9 roads 169:13 role 19:7,7, 24; 22; 17: 23:24; 26:22; 36:1 2; 39:2; 42:1 1, 17, 19; 44:5,8, 13; 45:20:51:24; 54:11; 111:17 room I 16:14; 126:24; 132:3; 148:4; 150:22 Roughly 18:16; 183:17 routine 37:23; 51:22 Rubber 7:6; 19:19, 19; 70:5; 181:5, 199:17 rule 85:10 run 25:12; 79:2 running 144:9 Rutter ]0:5; 29:15; 31:3; 38:5; 40:8; 55:10; 56:7; 60:24; 61:3, 15; 63:5; 67:17:69:13,71:13; 73:12; 77:5; 79:16; 87:22; 88:4; 105:4, 17; 112:10; 123:10; 136:14. 17,22, 138:2, 18; 142:22,25; 144:4; 159:8; 180:13, 18, 192:19; 195:6, 11; 197:6; 212:18 s S 144:25 sacrificing 129:4 Safe 7:10, 12; 100:2; 186:8 safety 16:10, 14; 19:5; 22:21; 23:10-26:6; 37:24; 54:6; 56:16, 21; 93:5; I 15:8 j sections 85:1 5; 127:2; sale 44:3; 207:3, 12 194:5 sales 45:6,6,8, 16, 19; ! seeing 57:1 5. 23; 58:16; 104:1, 21; 1 l 0:20; 132:21, l 64:10; 67:10; 69:3; 72:6; 133:1 I; 135:17; 136:3.5; 137:2; 146:10; 147:6,7; 75:21; 78:5; 89:3; 100:15; 111:7; 119:3; 137:12 165:17; 205:2; 208:1 seems 75:25; 136:6; salesman 32:io, 13; 151:25; 161:19; 203:2 105:22; 106:2 sees 15840, 12 salesmen 47:8; 106:21; 107:16; 133:22 selected 29:20; 144:19 Self 8:15 salespeople 33:2 sell 95:5; 110:1; 129:10 salesperson 32:23 selling 205:1 7; ^<>7:1 salt 35:11; 148:10 same9:l; J 2:9; 20:5, 18; 38:7; 58:13; 6l :5; 67:19; 94; 5; 122:18; 14949; 151:18,21,156:12, 16; 175:20; 187:21; 193:3, 21 seminars 5444; lo6:21; 107:5 send 4544; 74:7;87:11; 1404 2 sending 74:5; 172:4, 5; 18247 sample 11347 Senior 17:1 1; 18:21 samples 42:2; 11346; sense 50:21; 19149 1394 8, 19; 140:2; 164:17; sensed 142:5 165:2,8; 192:4; 201:14; sent I 1140: 1324 5; 202:8 sand 124:25; 125:6, 9, 19; 204:3 Saturdays 168:23, 24 Sauget 344 7,18; 122:24 137:25; 13949; 141:18: 180:16, 18; 19348 sentence 58:7;65:4; 70:8; 78:24; 84:21; 103:25, 127:7; 199:1: 201:25 saw 25:5,9;4244; 56:12; sentences 9747; 128:7 72:lO;74:21;78:8; 83:16; II 1:8, I 1, 14; 124:22; 133:17; 15,3:22; 1684; separate 13947; 1514 separated 1484 5 177:22; 178:1; 181:15; September 74 5; 127:24; 183:18; 184:23; 199:16 129:21; 131:7; 1784,3; sawdust 2940; 204:3 , 189:23 Sax 81:16, 16. 23; 82:3, 11,21; 83:6 saying 7844; 99:16; 165:23; 205:25 series 36:2; 1134 2; 12146; 145:23; 168:8, 11, 14; 17940, 1824 serious 1324 scalding 22:2 serve 42:6 scan 5748; 64:5 served 3147 scanned 64:9:89:2; 91:5; serves 1014 0 103:2; 108:10, 1 I 1:2; service 146:17; 184:21 126:8; 131:12; 1334; services 3049:31 4 5; 141:6; 146:7; 152:25; 15347; 15440; 177:17; 32:8;33:7, 23,24,34:20; 3743:45:9, I 1,17, 18, 22; 180:20, 24; 183:13; 189:25; 193:8 122:25 servicing 18449 scheduled 19:2 Science 144 5, 16 set 794; 102:10; 1404, 15143; 155:8; 15843 scissors 1 27:2 settling 200:24 score 11:5; 4543 seven 136:16 scrub 204:8 se 32:9 seal 169:8 ' second 40:23, 70:7; 76:9; 8745,19; 90:16; 96:3; 102:24; 112:2; 121:15; 136:9; 144:11; 149:5; 1534 2; 174:25; 178:21; several 35:7;73:21, 23; 109:22; 1 1345; 128:7; 132:3; 161:4; 168:24 severe 6640; 7045 sewage 28:20 sewer 29:4; 98:24, 172:11, 12; 173:6, 16; 2044;21044 1864 4; 18843; 198:25; 1994:205:6 secondary 16:3 secretary 133:8 sewers 204 9 Shall 204:21 share 3248; 37:25; 3946,42:12; 1074, section 194:18 121:10; 126i: 24; 190:7 remove - si rare (14) Mi U-Seript CARDINAL REPORTING CO, 1-212-227-9490 WATER PCB-SD0000064076 -tt% ivnUAl.S CO.wt'AiNV V. AETNA OVSUALTV & SURETY COMPANY,et al WIIHalo i'APAGliOKiiil; Vol. 1, July 16, 1997 sharp 32:3 Sheet 7:9, II; 186:8 shipment 37:19; 81:17; 108:1; 117:1 1 shipments 117:11 shipped 105:21; 196:21 shipping 31:1; 17:7; 101:19 shoes 23:17, 18 short 33:19; 201:17 shortcut 191:17 shortly 110:17; 119:21 shot 181:2 shouldn't 173:15 show 81:25; 102:9; 107:16; 1 12:1 2; 127:21; 135:21; 113:13; 151:3 showed 69:16; 79:7; 117:21; 1 18:1 showing 39: t shown 69:5; 75:2,1, 6; 119:25 side 179:6 sign 212:18 signature I 26:13, 11 similar 9:6; 17:1; 10:2; 56:2; 66:10; 71:5, 116:1; 153:21,21; 151:1; 177:21; 179:20; 193:11 simple 167:22 simply 81:1); 211:18 single 81:1; 113:11; 112:19 sink 118:11,! 5; 151:9; 200:23 sit 102:5 site 182:21; 201:1 sites 137:8; 201:5 sitting 116:13 situation 12:3; 13:1,7; 29:19,12:1;60:12, 86:20; 101:2; 157:19, 158:7; 191:20; 21 1:2,5,212:12 situations 113:13; ill: 16 six 50:6; 102:13; 205; 13 skin 23:11; 58:21; 63:2; 76:11; 77:13; 80:7,7, 11, 85:22, 25; 86:3 skyrocketing 101:21 slicks 171:23 slight 115:8 slightly 119:12 small 200:22 smile 16:1 soaked 23:18 societies 51:21 society 17:12; 51:25 sodium 3510 soft 111:17 soften 163:6 soil 22:6, 7:211:3 soils 118:25 sold 25:15:30:21; 109:16; 152:1; 185:21; 193:16 sole 18:19, 21 solid 29:11; 51:18 solubility 119:19,21; 150:17,2! soluble 118:8,9,10; 119:25 solve 3H9 somebody 21:11; 21:3; 30:1; 39:7,15; 12:6; 19:12; 106:6; 166:10 someone 32:16; 12:11; 60:16; 182:20; 181:20 something 9:5; 13:19; 15:11; 22:16; 25:5,9; 35:9; 79:13; 101:8; 110:1,8; 116:12; 151:11; 157:10; 166:17; 167:1; 175:21 Sometime 183:19 Sometimes 9:13; 37:19; 105:23; 111:10 somewhat 1 51:21 somewhere 12:21; 33:11; 110:1 soon 163:17 sophisticated 137:10; 118:22 sorry 25:7; 27:6; 33:16; 18:20; 66:17; 68:23; 72:21; 87:8; 89:23; 103.20; 106.10; 1 10:6, 120:7, 122:19; 137:5,15; 110:7; 111:15; 115:10; 117:20, 151:6; 157:6; 168:10; 180:15; 185:11, 15; 212:7 sort 11:10; 18:22; 26:11; 30:11, 16; 127:2; 201:1; 201:17 source 82:6; 131:17; 157:22, 200:9 sources 113:15 south 111:1 speak 23:1; 171:21; 210:12 speaks 122:21 special ]62:9 specific 12:12; 21:21; 27:18, 22,23, 23:32:11; 35:2; 70:1; 89:7; 91:18; 91:19; 100:16,19; 112:21; 130:8; 117:1; 153:22; }6l:5; 162:21,23; 163:12; 169:3; 179:17; 201:20; 203:5 specifically 12:17; 57:21; 166:9; 178:16, 181:20; 190:11; 207:21 specifications 19:1 specifics 86:8; 96:11; 119:9; 110:9 speed 92:3 spell 110:18 spent 16:5 spigot 113:6 stops 21:21 spill 27:16; 20316, storage 111.13; 175:7 201:10 storm 211:2 spilled 189:1; 210:21 Story 201:18 spills 16:23,26:20 ; strange 113:21 spite 68:2 strangeness 113:23 Spoke 30:21; 39:18, 20; 151:11 spoken 10:20,23 spokespeopte 202:17 sponsored 117:16; 168:21 spot 29:6 spread 18:11 sprinkler 206:20 St 8:2, 12; 11:19; 17:11, 15; 20:3, 5, 16; 28:19; 31:22; 31:16; 3V: l; 10:19; 11:7. 8; 75:9,88:22; 116:20, 2l;157:l6 staff 31:6; 39:13; 11:25 stain 210:21,25; 2! 1:1 standard 110:3; 158:1 5 Standards 110:15; 131:21 Stream '200:15, 18; 21 i:l streams 170:12 strike 63:13; 178:23; 187:1 strikes 171:22 Stroh 11:1,3 strong 125:2! strongly 111:25 studied 157:11 Studies 6l :8, 11; 62:2; 73:19; 76:25; 77:3,79:5; 117:21; 157:11; 159:13; 199:1 study 1 11:3; 168:18; 169:21 studying 103:17 stuff 172:11 subgroup 16:16; 51:11 stands 136:8; 138:12, 20; subgroups 53:15 161:11; 203 9 subject 27:17; 35:3; stapled 192:22 start 11:12; 36:7; 12:18; 13:25; 18:1; 69:25; 72:1 5; 97:25; 105:18; 117:9; 10:23; 59.16; 79; 18; 127:21; 185:9; 190:15; 193:20; 20,3:19 subjective 65:25 112:17; 157:21; 159:2,3 submit 10:12 started 15:19; 123:11, 11; 158:16; 159:1:206:15 starting68:10; 83:1; 115:21; 167:13; 171:3; 205:11 starts 127:23; 156:1 State 8:8; 168:5; 201:6,6 stated 161:13; 171:11; 195:19 statement 96:17; 170:10; 171:8:189:8, 10;211:16 statements 96:15 states 111:1; 128,13; 139:16; 157:15 stating 90:23 status 126:25; 131:7, 15; 203:7 stay 121:17 staying 157:11 steam 30:16 steel 116:9 step 18:2; 19:13; 115:15 stepping 111:23 steps 171:15 subscribed 55:21 Subsequent 121:20 substances 21.18; 95:17; 150:25; 207:23 substantially 180:5 substantively 191:6 succeeded 125:11 success 129:7; 113:3 successes 106:21; 206:1 successful 129:7; 206:11,21 suggest 89:17; 111:12; II 3:12; 123:15; 202:5 suggestion 59:13 suggestions 51:11;70:5 summaries 116:10 summarize 112:3 summary 155:12 summer 13:1 Superintendent 21:23; 25:22; 29:25; 31:13, 16; 33:7,9, 21; 31:13, ll; 170:5 Still 19:16; 20:3, 5. 16; 28:1 I; 31:23, 21; 50:6, 22; 78:18, 22; 87:21; 103:13; 1 16:3, 12; 155:1; 173:15; 200:2 stop 163:20; 205:16 Stopped 201:16; 207:1 Stopping 125:5 superseded 185:1,9 supervised 19:1 supervising 18:25; 31:18 Supervisor 1:21; 20:15; 21:6,22, 213; 23:25; 25:6, 10, 21; 28:10; 106:3; 171\>*. * I 11 )A supervisory 21:21 supplied 12:6 supply 88:11; 167:15; 182:6 supplying 30:15 supported 15:19 supports 171:1 supposed 171:1; 197:6 sure 9:19; 13:18; 17:12; 19:2; 38:13; 50; 12; 51:1; 59:1, 1; 68:1; 81:22; 86:1, 87:17; 91:5; 1 10:7; M 1:21; 123:13; 170:15; 177:10; 191:12; 202:20; 201:18 surprise 39:15; 118:1 surprising 12:1 suspicions 199:2 Swan 76:2 Sweden 113:19, 22 swimming 172:21 sworn 8:1 symptom 66:7, 11 symptoms 63:8; 79:25 system 27:13; 28:20; 138:21,23, 21; 62:20; 97:19; 98:1 l;99:2,7,8; 101:23,21, 105:3, 3, 25, 25; 115:25; 1 18:18; 125:7; 135:5; 138:16, 21; 112:20, 21; 113:8; 111:9; 155:16, 17; 156:19; 161:21; 162:8, 21; 163:2, 11. 25; 180:3; 205:9 systems 27:11; 33:3, 11:21;95:12; 98:1; 107:21; 1 15:21; 120:3; 121:7, 18, 22; 123:7,25; 121:1; 128:12, 11.21; 129:9. 10, 12, 15; 111:2, 8; 171:1; 178 7; 205:1 5; 206:16, 18,21,21 T T-r-o-p-e-a llo: 19 T.L 127:22,25 talk 87:25; 123:23; U0:7, 1J talked 53:1 5; 80:15; 83:7, 86:1; 91:23; 1 fl 11, 163.16,21; 161:18; 191:15 talking 9:1; 23:11; 39:9; 11:18; I7:25;6l:21; 73:12; 86:20, 22; 91:5; 96:21; 1 16:16; I 23:12, 110:22; 165:16, 195:12, 15,210:23 tank 97:20; 111:12, 13. II; 175:8. 19 Task 111:21 teaching 26:16 team 178: ] l), 1. ~f.i. tl. I . (ARDINAT TfTiI'OUTfNG CO. 1-? V>-2 27-^/*90 Mim-TT-Srrf (Hh)5> O S') shnmi - Trch'jh'al WATER PCB-SD0000064077 WU.UAW I'AI'AYiiOJK Vol. 1, July 1 Ci, 1997 ivi-. 1 iscn.iAs ivnn aco Vjcmji'jvtN 1 v, ALTNA CASUALTY ik SURTTY COMPANY,et al 31 IS, 19,33:7,23; 181:7, I 13 1 I 3, 16, 150:3 ! training 18:22; 19:5, 8,8 86:9; 87:6. 10,91:12, 93:8; 76:7; 79:1; 92:3, 105:10, 9. 2-f; 182: L; 205:1 I; I Thomas 68.15:70:23 | transfer 12:1,2; i3:5, 129:3,8, 10; 132:9, 10; 106:19, 22; 107:3, 16; 21 If>:ZU thorough 1338 : 17:19,32:23:36:9, 1 I; M 1:1 I; 1-1-1:19; 137:2-1; 113:21, 1 1-1:3; 1 15:3; lechnicinns 3I i H telephone 137:1 9; 139. J 7; 160:19. 20, 16-1:16 telling 5| 1, 92:1 2 thought 22:1 I; 102:9, : 38:21,23;39:2;93:1; 170:21, 172:7, 23 97:18;98:3; 105:3; thoughts 132:5 : 115:23; 1 16:23; 121:18, 22: 1231; 128.12, 129:1. three 13:15, 17:17; 25:25, 32:2; 55: 8, 78:23; 80:1 3, ' ! 9; 135:3, 138:16; 155 17, 161:11; 162:8, 22; 163:6, ! 139-10, 13,22, 157:20, 1 167:1 5, 2S, 168:1. 169:5, ; 176:5, 18-1:17; 190:16; , 206-I3, 211-1 typed 1-11:21; 186:23. 1H7TS 116:7, 123:25; 125:19; i 132:3,6, 137:10, II, ! 130:1, 15.3 25; 155:8; 157:22; 158 13; 160:8; 162:21,23; 167:21; 175:2-1; 181:13, 13; temperature 138.3, 150-2.1 temperatures 70:lo 16,21,25. 107.16, 1-13:15 throughout 23:1; 55:19, ! 130 18, 168:15; 192:1 167:15, 178:7. 180:3; 193:23; 19910,21; 205:15; 206:13, 16, 18, types 21.2, 38: 3, II), I 18:2; MO'5. 132:2; 158.12; 202:8 186:23; 187:1,8; 188:23, 189:3, 200:22; 201:5, 203;23; 203:13, 13. 206:9, temporarily 1.35:8 ten 178:16 tendency 138:25 times I 1:6; 37:20, 39.23; 79:2. 20-1:13 timing 165:11. 166:18; 21 1:3 transferred 20:13; 38:11; 50:9, 130.15 typical 58:9, 20,90.12; 96:15, 136:6; 198:17 11, 25, 210:5, I I upkeep 183:22 Upon 23:8, 56: i 3 tenure 160:1 I; 173:9. 175-13: 176:17 170:6, 181:23 tinge 150:13, 16 Transformer 7:8; 17:23; 116:13; 183:3,7, 22; : U Upper 133:21; 133:1,2, 137:2 tcrm66:15, i 8; 95:1 6; 109:5,7 terminate 205:12; 208:1 terminated I 1 5:21; 205:-1 termination 207:25 > title 17:9; 21:1 5; 36.: 2, 3, 6, 18, 19; 3H:J 2, 17, 19, | 21; 52:23; 53:1 2; 63:22; | 81:3, 21; 96:1| 181:2 | title-wise 93:21 titled 100:2; 15-1:5; 186:8 titles 55:1 3; 85:16 185:22 transformers 12:10; 1 13:7; 1 15:5; 183:17, 19 transition 206:11 transpired 135:13 trash 30:15. 18; 33; 11 travel 33:22 ultimately 113:11; 130:23 umbrella 36:22 under 13:2; 18:21; 26:22. 23; 27: II. 1 I; 32:15; 36:1 I; 38:18, 38:1 I. upset 28:21, 25 upsetting 172:8 use 11:25; 16:3; 20:1; 23:17; 26:23; 32:18; 38:3, 18; 32:13; 33:22; 39:10; 66:18, 23; 67: I5;95:l I; 97:5; 1 1 509; 1 23:25; terms 37:23; (>5.25, 1(7:25, 187:20; 206:1 terphenyls 205:23 test I 18 2, 10, 168 7, 12 today 103:19, i 17.23: I 38:22; 161:3, 21 2:6, 9 together 127:3, 135:25, j 16 2 13 Travelers 8.19 treating 59:10 treatment 28:20, 22, 25, 63:16; 69:3, 72.10,89:6, 93:1 5. 96:12; 98 12, 100:13; 108:15. 109:18; I I I 6; 1 17:15, | 19.2, 3; 125:19; 126:25; 150:13, 15: 152:6; 165:22, 167:8, 169:8; 178;6, 1-1; 180:3, 5; 183:25; 193:19, 21,23, 2-1, tested 118 9 testified 8:1; 160:21; 167:23, 169:23, 173 20, 17-1.12 told 22: 17; -II :21, 23; 72 20; 76:19; 165:21, 191 17, 18, 19, 26. 21, 22 took 19:5, 53.11; 1 17:2; 171:25; 1722, 13 tree 202:10 tri 101:13, 16 trial 12:13, 17, 22, 1 3: I 1 27 6; 133 5; 139:17; 153-23, 163:19; 180:3; : 183:3; 188:2.3, 195:18; . 211:16 25; 203- I; 205:15; 206:6; 207:16, 20; 208:3 : used 9:12; 12:9; 17:6, ' 19:18:37:23,38:21: testifying 165:15 testimony 9 21, 112, 17, 2-1; 12-5, 1,3, 17, 22; t 3.1; 82:2-1; 17-1:21,210-7; 21 2:5,9 testing 201U7 Tests I 17:1 5; 169:8, I 2 tetrachlorobenzene 101: I f, 17 that'll 90: ly theirs 107.8 theme 21:25 1 37-2-1; 13-23; I 32:1 1; M3: 10. 166:15; 168:23; 192:12. 205:11 top 57:2; 65.1; 70:23; 96:1. 100:2; 115:17; 126 3, 151:10, I I, 152:12; 181:13; ] 87:2; 197:18 topic 161:1, 12 topics 1 61:5 total 101:23, 102:2, 3; 137:7, 11 totally 132:5; 133:3 touch 135:13 tried 32:15 Tropea HO: 17,19; 166:10 troubles 76:11, 12; 77:9, 12 true 52:19,f)0:22;6213, 8310; 155:22 truthful 921 try 9:2; 26:21; -12:7, 1 I; 203:25 trying 95:2; 121.5; 125:9; 132:6; 162:11; 191:19; 195:2, 11 undergoing 1 26,21; l-i-l :7 underground 29:22 underlying 173:22 understands 123:19 understood 62:22; 86:16; 121:9; 123:13; 127:16; 137:9; 139:25; 132:8; 165:23, 166:3,3, 15; 195:15 undertake I 27:11 undesirable 29:23 Unexpected -12:2 - 37:18. 19:39:7, 1 1,60:17; . 62 :1 1, 20; 66:1 5; 7( 1:3, i 93:25;93:21,95:1 I, 12, 13; 97:19.99:2; 109:5,7, 8; I 18:10; 1291; 137:20, 135:19; 139:16, 13; I 50:1 2: 1 55:1 5; 156:19; 162:22, 23; 163:5, 1 l; 178:5.6; 183:5, 10, 13; 185:12, 18; 190:6,7, 1 99:22; 200:2, 5, 10; 202.16, 16; 205:9: 210:3 user 133 0,21,23 users 11:17; 33:5, 12; thereabouts 20:11 tour 3.3:5 Tuesday 135:18 unforlunalely 128:6 127:8; 183:16,202:9 thereafter 11(>:17 therefore 206:6 toured 33:18 lours 33:10 tuned 162:19 turn 19:1,63:25, 106:3; Unh-uh 176:18 unhappy 11619, 19 I uses 25:1; 28:22; 1 15:7, , 19, 21; 116:18; 199:1 0, 12; therein 69:1 2 thermal95:l2 Therminol 93 5,9122, 951 1,96.1; 100 3, 19, 101:2, 3.9,21, 1 18:18. ' towards 1 5:3; 16936 toxic 117:21,21, 183:6; ' 207:23 toxicity 72:18, 73:19; 107:8, 139:3. 151:23; 178:11,23 Turning I 51:1 2, 186:20 tutored 23:8, 60:2, 7,8 unintentionally 99:9 unique 99:20; 1 36:8 Unit 7:2; 191-1.17, 25; 20:2, 3o: 19, 39:2, 5; 53:3 203:21; 205:2,3, 6 using 82:13; 125:6; 20-3:8 usual 23:13 utilities .33:11; 171:5* I 127:8, 25, I28:M, 21; 1.30.1; 132:21, 133:12, 100:2, l 17:12; 179.7, 13, , 25: 180:5; 208.23 tutorial 62:3, 22; 69.6; 72:12,76:6, 13;78:8, United 1 28:13, 157:15, 15 V 135.7; ) -1-1:7; 151.13, 17 Toxicological 7:9. 11; 80:1 3; 83 7 units 203:18 Therminols 9.3:18, 20, 23, 25; 93 19, 2-(; 95:6, 9, 99:21. 101:6; 121:16, 133:12 they're 2.3:16; 137 (0; 83 23; 85:8; 186:8 Toxicology 81:5, 13, 23, , 86:13 ' traced 62:9 ' trade 53:25, 53:3; 55:9; Two 25:25; -10:23; 50:1 -(; 71:18; 73:5; 80:1 5; 81 1 2; 93:11,95:25,97:17; 100:1; 107:16; 1 18:16; 123:5, 127:22; 135:17; 136:1; 150:25, 15-1:25; University H: 19; 32 3; I 13:3; 168:23 unknown l (0:3, 172:2 unless 138:7 unused 1 55:3,9 vague 30:6, 5211,55 11, I 56:5; 6 ] ;16; 62:1 3; 63:5; 67:18, 68:6; 69:13; 77:6; 79:17; 88:5:99:3; 105:5; 113:10; 138:3, 19; 132 22. 1-16:), I; 1 -18:1 5, 139:1 l, 21 l 15:3 trademark 1090 8 155:21; 159:20; 167:9, 15, unusual 105:20 168:15; 186:2; 188:2; unusualness 113:17 159:8; 172:16; 176:1 vagueness 189:6,13; They've 103:23 trademarks 109:23 192:15, 23 up 13:6,12, 22; 13:3; 208:19 thin 101:15 trained 18:23; 23:8; two-thirds 90:7; 135:25 16:13; 17:7; 20:9; 23:10; Valley 8:2,12 thinking 38:11 169:15; 171:10 type 13:H;2I:15,23:19; 27:16; 28:12; 29:9, 9, 23; | vaporization 121:19,23 third 82:6,92:6; I 1 1:2-1; trainee 19:15 27:17:32:12; 36:5; 77:12; 39; 16;-12:7, ! 1.73:10; I vapors 70:10, 12;75:5; technicians - vapors (16) Mi-U-Script CARDINAL RLPORTING CO, 1-212-227-9490 WATER PCB-SD0000064078 REYNOLDS METALS COMPANY v. AETNA CASUALTY & SURETY COM PANY,et a 1 97:23 varied 37:18; 182:1-1, 22; 204:5 varies 66:12; 149:21 various 26:7; 85:15; 90:3; 141:17; 147:15; 169:20; 199:16 varnish 205:3 varnishes 199:14 vary 143:4 vehicle 34:4 vent 144:12 vented 97:20 ventilation 70:6 verbally 134:14 version 130:12; 131:2; 153:22; 193:25 versions 194:2; 195:8, 16 Vice 44:11, 14 vintage 92:23 virgin 140:3; 158:1 l Virginia 160:13,17 visit 37:21;43:22;88:15; 124:17; 137:18; 160:11 visiled 13419; 182:21 visits 42:25; 105:23 visualize 115:2 vividly 177:23 volatilize 148:20 volume 83-17 volumes 1917 w W-h-e-e-l-e-r 69:20 W,B 7:18; 102:14; 103:5; 120:16; 122:5; 124:6; 126:1; 131:6; 139:5; 140:25; 144:25 W,E 63:23; 64:13 W,G 120:16 W.H 68:14; 70: i6 W.P 135:25; 136:2 wading 172:21 wait 8:23; 115:10; 116;! Wales 157:14 walls 144:14 War 60:3, 6, 14 warning 30:22; 66:11 warnings 24:17,21; 85:22 wash 23-14;211 ;2 Washington 14:19; 162:17; 168:23 waste 28:19,21,23; 30:18; 108:4; 153:12; 154:21; 155:1; 156:25; 170:22; 171:25; 172:2,13; 200:14,20; 201:17 wastes 51:18 water l6:3, 24; 22:2,7; 29:5,22:30:16; 125:7,11; 148:8, 1 1, 18; I 50:13, 22, 24; 151:5,7, 10, 11; 170:12; 171:24; 172:13; 200:14,20, 23; 201:3,4,6, 8,17; 210:17; 211 waters 28:19; 172:21; 211:2 waterway 29:21 waterways 21:9; 22:6, 13,25; 28:3; 170:9, 12, 17; 171:10, 17, 21; 172:12, 19 way 8:25:21:23; 51:3, 21; 52:18; 53:8; 55:16; 66:23; 67:21,22,24;68:1;80:8, 85:16; 90:7; 92:12; 106:22; 109:9; 117:1,15; 125:7; 135:25; 138:11; HI;11; 158:20; 166:20; 189:3; 212:5, 8 ways 38:20:95:15; 148; 18; 200:8 wear 163:25 wearing 23:19 Weber 50:12 weeks 144:9 weight 94:17, 20; 102:6, 7, 9; 118:2 weights 94:25 Welfare 75:10 wells 16:1, 5 weren't 124:22 Westinghouse 109:21 what's 99:16; 208:18 Wheeler 69:20,25; 70:2, 13, 13:72:13,16; 74:23; 186:16, LB; 188:15 whenever 26:8 wherever 31:20 whole 57:1 1; 72:4; 102:22; 179:16, 18, 18 whose 130:21 WILLIAM 8:1, 10 willing 167:14 Wisconsin 14:4 wise 172:10 wisji 54: l6 withdraw 1 i4:i i; 115:6; I 22:20 within 42:8;49:8; 51:14; 114:6; 126:22; 144:14; 165:14; 166:4:205:8,9 without 114:7; 184:6; 185:7; 210:21 withstand 66:13 witness 82:16; 106:11; 123:18; 159:12; 160:1; 176:22; 208:14; 209:4, 14; 212:13 Wood 59:10; 143:15 word 9:12; 15:3; 17:11; 20:1;60:17; 62:11; 95:11, 13; 113:4; 181:14; 193:20; 194; 10; 198:9, 9, 10, 12; 210:4 worded 196:18 wording 179:20; 197:22 words 31:8;70;4;99:t6; 115:16; 137:19; 165:19; 166:9; 169:12; 173:4; 205:8 work 16:22; 17:13; 18:18; 25:12; 26:16; 32:20; 41:6; 45:2]; 165:2; 171:2,22; 178:2 worked 15:22,25:38:23; ! 45:3 worker 16:10; 23:10; 26:6; 54:6 workers 13:15; 19:1,5; 58:10;62:8; 63:9;97:22; 172:3 working 16:1; 58:8; 131:25 workings 123:6 workplace 67:3 works 32:2o world 47:9; 60:3, 6,14; 115:3:192:1 wrench 163:20 writing 108:20 written 27:5,7, 8; 95:22; 168:7 wrote 145:15; 165:10 , ! X X 185:22,23, 24 Y Yeah 20:1; 30:9; 32:10; 45:23; 48:2,9; 52:4; 90:18; 92:6,9, 14; 103:10; 106:16; 119:23; 155:24; 165:7; 170:4; 179:2; 180:2; 195:1 f; 208:17 year 19:12; 50:16; 60:1; 83:6; 119:22; 147:6,8,9; 155:22; 184:9; 202:6; 206:17 years 14:22; 17:17; 20:7, 20,22; 26:1; 31:25; 32:3; 33:12,21;67:I;90:1; 117:17; 150:15; 178:17; 184:6, 10 yellow 150; 14, 16 Yesterday 10:15 York 43:22; 152:16; 156:8; 203:3 CAE DINA. I. REPORT* [J" 1-2T2-2?"' '>490 MUt-tl-ScrmOO WILLIAM PAPAGEORGE Vol. 1, July 16, 1997 0 74 varied York WATER PCB-SD0000064079 Lawyer's Notes WATER PCB-SD0000064080 1342 DON 0. IRISH chlorine and that an allowable concentration of 1 mg./eu. meter woulil be rc.i-.mable (or the ehloiinuted diphenyl containing approximately 55 per ernt chlonin- Oral Toziri!y. Drinker'* reported oral toxicity studies on chloriuaiol .j(. phenyl containing W |>er cent chlorine. Feeding rats at 0.3 g /day, the first atu-,,...i died in 0 days; 4 more by the end of the month. Liver lesions were found in ihc-e animals similar to those teen from vapor exposure. Miller'* fed chlorinated diphenyl to animals. Ilis diphenyl contained 12 pu cent chlorine and was approximately equivalent to 3 atoms of chlorine per mlvculc. Two doses, each dose 0.03 ml. (GO mg.), were given to guinea pigs 1 nock apart Death occurred in 11 to 29 days. The liver* showed mctamoiphoii. and central atrophy. Rats received 25 daily doses of 0.1 ml. (139 mg ), Tin.-" animals survived the administration and were killed at 10-day intervals from to 90 days after the beginning of the feeding. They showed the typical liver injury seen in the other animals. Skin. Miller1* also applied the same chlorinated diphenyl (o the skin of guinea pigs, rnts, and rabbits. Guinea pigs rcecivcd 11 daily skin applications o, '/( of 1 ml. (34.5 mg.) of undiluted chlorinated diphenyl. The animals died at various intervals up to 21 days after the first application, Hislopathologirnl examination of the liver showed fatty degeneration mid central atrophy. The kidney was essentially normal. There was a thickening of the epidermis nt the site of application. ' Rata were given 25 daily applications of the same dose, */i ml. (31.5 mg.> of undiluted chlorinated diphenyl. They survived the application, The animals were killed at 10 day intervals beginning with 30 days and ending nt 00 days nflir ilainitial treatment. Histopathologienl examination of the liver showed only slight changes. The treated skin was much thickened and hair follicles were swollen. Rabbits received skin applications at 2-day intervals. They were given Sr> mg,/day for the first 7 applications and 172 mg. for the Inst S applications of undiluted ehlorinatcd diphenyl. Death occurred between 17 and OS day*. Fait.*, degeneration and central atrophy of the liver were more striking in those animalthan in live previous animals. The treated skin showed a thinning o( the prirUlc cell layer and a relative thickening of the outer cornified layers. Human Erptritnee. A number ol the references recorded under chlorinated naphthalenes nlso discussed chlorinated diphenyls. It is difficult to determine the role played by the chlorinated diphenyls as, in most instances, they were mix'-I srith ehlorinatcd naphthalene. Jones and Aldcn'* reported on human cases "oi'.;i-: with ehlorinatcd diphenyls. They observed n typical acneform dermatitis annv : workers handling this material. As these workers wore manufacturing the material from crude eoal Ur distillates, these authors were inclined to foci that other chlorinated aromatic materials present which were considered to be more uiitnh'" might be the more important cause of the dermatological response. The worU. Miller, Pvhlk lUnlih lUpli. t/.S, , tOSS (tOUt. J, W. Joan tad B. 8. Akira, dneA. DarmaleL and Syphilol, IS, 1022 (1014). HONS 076165 WATER_PCB-SD0000064081 CYCLIC 1MLOCLNATCD II\ imOCkRUONS 1343 did not get a typir.il ncncforin dermatitis from patch tests. This is not surprising a* a number of author? recognize that it is neresfary to have a long-term exposure to (Ins material in order to get this typical response. It if quite potsible Hint high chlorinated aromatic materials from the crude coal tar distillates may also cause neneform dermatitis. It is quite probable, however, tlint the dermatitis can also Ik: observed following exposure to llio highly chlorinated diphenyls. 4. //* fictn'c StnnJwnh / PrrnWutMe Expottare The threshold of chlorinated diphenyls wns established by the American Conference of Governmental Indm-triu) Hygienist*, in April, 1939, at 1,0 mg./cu. meter for chlorodiphcnyl (42 per cent chlorine) and 0.5 mg./cu. motor for ehlorodiphenyl (54 per cent chlorine). CIII.OUINATED NAPHTHALENES, C,,H(|.,,CI. l. the* nnj tnJutfrtmt Expmamraa The chlorinated naphthalenes do not occur in induitry as individual com pounds. They will, therefore, be treated as e group. Any one product is i mixture but will hav a specific range of chlorine substitution. Those with three or less chlorine equivalents arc much less toxic than those with four or more. These materials are used In electric wire insulation. They have also been used a* additives to special lubricant!. The first problems were encountered in the use of these materials in wire in-ulntion. Skin problems may nrisc from contact with the cold material. The hot m. 'iieria) nnd, particularly, the vapors, may cause serious systemic poisoning as veil ns acne. Injury to farm animals has occurred when lubricants containing the ehloroiinphtlialcnes were ingested. This may occur when cattle (cod becomes contami nated from the machinery in which it is processed, or from similnr lubricants ;i>-cd in farm machinery. ?. rhyilft'mxi Chtmltnl frep*ralea Phykirnl stale: Waxy solids Properties very with the degree of chlorine substitution Solubility: insoluble in walcr; soluble in organic solvents .1. Phyt!*lofi*n1 When lltc higher chlorinated naphthalenes arc absorbed they cause severe injury to the liver characterized at acute yellow atrophy. The systemic injury appears to be exclusively one of liver injury. Injury may occur from ingestion or iioin breathing hot vnpors. Some autliors have indicated that chlorinated naph thalenes may alio be absorbed through the skin. MOMS 076166 WATER PCB-SD0000064082 I1 1314 DON D. LRISU The oilier most striking response lo contact wiih the cldm mated n.r,'h(!-..-.!euv; is chlornrnc. This usually occurs from long-*"rm contact wit It the ui.ucn ! or !ioin s much shorter contnel with hot vnpors, The reaction ia usually slow to o['(' !r v>.| may take months to return to normal. The third problem tlmt has arisen from industrial uac ol chlorinated n 'i htiuleni has been hyperkeratosis in entile. Special lubricimu containing the chln.oi lene were used in machinery for pelleting feeds. Externally, there i, a thick U; itinited layer on the skin of the neck, shoulders, and the it her?. The g di IiIkM.t, liver, pancreas, and kidneys are affected. The condition is often fatal. \YI,;lc the i most common cause has been from grease that contaminated pelleted feed? hum the pelleting machinery, the same condition can occur from the injej-uon of special oils or greases used on farm machinery if they contain the chloronaphthalene. Vapor Expoture. Drinker et at.1* exposed rats to vapors of chlorinated naphthalenes. As the material has a high boiling point and had to be heated to vaporise, it is possible that a certain amount of material may be concicn-cd either * on the cop or on the animal so that there may hate been some ore! intake. Animals were exposed for 16 hours/day, In a case of lower chlorinated material l represented largely by a mixture of tri- and tctrachloronaphlhaienc, an average concentration of 1.31 mg./cu, meter of nir essentially produced no effect oilier th .u a possible slight enlargement of the liver. The same matcriul at a concentration of 10.97 mg./cu, meter resulted in a slight liver injury. Exposure was repeated daily for up to 4'/ months. Similar exposure lo the vnpors of a mixture of pontn- snd hexarhlo'onnphtkv lene at an average concentration of 1.18 ttig./eu. meter produced definite lucr injury. At a concentration of 8.63 mg./cu. meter, there was some mortality, poor growth, and revere liver injury. The higher chlorinated material showed a g-e iter toxicity than the lower chlorinated material. ' Clinics! cares of systemic injury from this material have been reported by a number of authors. Sometimes the illness ws, preceded by skin lesion? and 'omctimes it was not. It is implied that tire systemic poisoning was largely due to breathing vapors. The following references are pertinent.l'':j Oral. Drinker et at.1* fed a mixture of penta- and hcxochloron oTp. \h m e rate of 3 g./dny to rats for 1 month. Nine out of 10 anim;.',.- died. They all led. weight, were sick, snd showed revere liver injury. When a mixture o; tc'.r.i- and penUehtoronaphthatene was fed at a dose of 0.5 mg./day for 1 month} they ob served some sieknoss, some mortality, and definite liver injury. L. Cmoberg, M. ft, Mayer#, soil A. R. 5mith,7. !*ri. Uvt- foncol, 21. -'J 110101. 8 M. R. Mayen* and A, It. Pniiih, ,V V. Sinfr 1*4. linfl. Jl. 30 < to12) 8 K. 0. Mrl.ntrliie sml D. RntirrHun, flrtV. Attil. J, 1,611 (1913). 8 E. C. Ritnv, ,V. )'. SUiti- l*,l. /Ml.. 33. W L. OrennltK.A 1*4, St al. tt. 530 (tUt. 81,. Grennlmra,/. !*!. Mnl.,SS. Wl (1013). . 8 L. EL Cutter, 1.4m. Alfl.Aw, tla.JTS MCNS 076167 WATER_PCB-SD0000064083 cvrur n.\i.ocF.\'ATTh iiMitiorvnnovsi 13-1.) l,in, Tlio most. commonly olwcrvrd problem from I lie use in handling of (lilorinalcd naphthaline* is llie clilorarnc. Tliis has boon observed on Iho skin of workers from a number of oiwralions where it lm< l>ecn used. Most of the clinical reports listed previously under vapor exposure also include studies of chloracne. A detailed discussion of dermatological problems has been published by Cood and Pcnsky," The clinical aspects of this skin problem were also discussed 1 y Schwarts.*1 Another extensive report was given by the special bulletin of the State of Pennsylvania.M Adams et nlV studied the nature of tlto response of rabbit's skin to this type of material. They concluded that the response takes the form, first, of epithelial hyperplasia, second, inflammatory and degenerative change*, arid, finally, re generative processes. This work is particularly interesting when we consider the nature of the hyperkeratosis observed in cattle. This is described in some detail in Leaflet Mo. 355, U. S. Dept of Agriculture, 1954. There is apparently a hyperplasia and a kcrntiniiation. It is noticeable in the neck, shoulders, and wither*. There are also growths on the gums of the animal. This is alto discussed by Bell," and was first described by Olafton." . This condition in animals is supposedly due to ingestion. The injury to the liver and obvious systemic effect certainly would indicate that it is an important factor. It it possible, however, considering tl>* reaction of the tissues of the mouth, cheek, and neck, that some of Use material may act by direct contact with the mouth and skin. Ahorpdon end Melabolitm. Cleary tl of." published an article on the ab sorption and metabolism of the chlorinated naphthalenes. They indicated that I he material was readily absorbed from an olive oil solution. They found no evi dence of storage in the lung, liver, skin, or kidneys. They did not find any cx- cretion via the urine and concluded that the rhlorine might be removed from the ring and excreted as rhloride. They observed a rinse in urinary ethereal sulfate. There was no change in neutral sulfur. 4. f/.'ttrnfa Standards / Permlwlhte Etpotun Drinker1* proposed the following limits for the chlorinated naphthalenes: trichloro--49.9 per cent chlorine (10.0 mg./cu. meter); totra and ponta--56.4 per rent chlorine (1.0 mg./cu. meter); penta and hexa--02.8 pcT cent chlorine (0.6 mg./cu. meter). The A.C.C.I.H. 1061 threshold for trichloronaphihnlene it 5 mg./ cu. meter; for pcntaebloronaphthalene is 0.5 mg./cu. meter. " C. K. Cood and H. Pender, dork. Drraiat*). ad Svnkihi., 4ft. Ml (IBIS). "L. Sehvsrlt aad 8. M. Perk, V. )'. State J.ilti., 4S, 1711 (IBM). CommonvcaHfc at Prna. Dept. Labor k lad., Sprr. Bull. No. 4S (1930). " E. XI. Adams, D. D. Irish, If. C. Spencer, and V. K. Rowe, Ini. Sled. Ini. Hn- Srrlitm, 1,1 (1941). tt. n. Brn, ret; xfed, 4, u non). P Olafaon, O-ra.rt IVt, JT, 1M (1(M7). "R. V.CVan , J. Maicr.anri O. II. Hitching*, / /Not. rksm. 117,403 <)*). 1 : : ' i I f HONS 076166 WATER PCB-SD0000064084 I'OTF.XTIAL EXrOSl'KLS IN IXDUSTWV 2251 Cement au<l Coucrete Cement ii made from cement rock or a mixture of finely ground limestone, or oilier form of- calcium curlxmutc, nith Hay, shale, flute, or blast furnace ilngj, r.-ii-cJy sandstone, olid certain accelerator* or retarders. The mixed |x>tvdcr> tre lientcd in a kiln, usually rotary, to about 1300 to MOOrC. The kilns arc healed by fuel jets of powdered coal, gas, or oil. Tho cement rock rarely contains more than 6 or 8 per rent quarts; the finished product usually less than 1 per cent, though occasionally it may contain up to 6.3 |>vr cent. The dusts are ordinarily classed as nuisance dusts but tlicir concentration may exceed the most lilscral ideas of pcrnmrible limits. Tliorc are several dml-produeing 0|>ernlions and they are amenable to control measures. Some of these sources are: stone quarrying, crushing, grinding, the rotary kiln, screens, bagging o|icrntions, and tho loading and unloading of ears. Dun cloud*, if uncontrolled, not only are conducive to undesirable working condi tions but also constitute an atmospheric pollution nuisance in the community. llleeli'oMnlic precipitation as well as centrifugal collectors have been used success fully to remove the dust from the effluent air from kilns ami silos, and the amount recovered is said sometimes to cseecd 5 |*er cent of total raw materials. A method (hat has been successfully applied to the rotary kiln elsewhere (see Sand Refining) is to exhaust the hot kiln gases through baffled water-spray chambers and conduct the water flowing from the sprays through a settling basin from which tho sludge may be recovered. Tltc important factors in evaluating exposures tre the degree of dust control and tltc free silica content of dust particles less than 5 p in diameter, l.tttvy injury from expoure to cement duet, however, hus not been demonstrated and the most frequent, harmful result of exposure is that of skin irritation from the alkaline action of cement. In the mixing ami use of concrete, the irritant, alka line action of the wet mixture is similar to that of the cement dust, and both warrant suitable control to prevent prolonged contact with the skin. . Chlorinated Waxes and Oils Synthetic Chlorourattt. The synthetic chlorowaxcs comprise n number of chlorinated hydrocarbons that ere derivatives of na)dithnlent or diphenyl. Halowax is the tmdo name of one manufacturer for the chlorowaxes. The damage that may oecur from inhalation, ingestion, and skin absorption of the fltlorownxes will vary with the degree of chlorine saturation of the com pound*. Tho amount of ilcniustitis and poisoning increases rapidly as the amount of chlorine in the waxes increases. Tito commonly accepted maximum permissible limit for atnKwqdmrie contamination with triehloronaphthalcne is 5 mg. per cubie meter of air. Pcntnchloronnphthalcnc, one of tltc chlorowaxcs eaiTying a high [HTcentage of chlorine is restricted to 0.3 mg. |>cr cubie meter of air, Systemic poisoning from tlse chlorowaxcs is generally characterised by damage to the liver. Serious exposure may produce acute yellow atrophy. The MOMS 076169 WATER PCB-SD0000064085 2202 ' HUNK A. TATry kin effects are commonly in the loim of acne, which is more widely di-triluiied on the Iwdy than coimnon acne. Among the recommendation* lor the prevention of cldoron ax poi-oning ,nL. (/) vn|r anil dust should be controlled by exhaust ventilation lu prevent cxponurc to amounts of the com|H>uml> in excess of the safe limit; incut iuih .1 above; (?) foremen ami worker* should ho told of the toxicity of the m Penal. tht they are handling and instructed to keep skin contacts with the m:\tcu.il in ( minimum; (3) preemployment and periodical physical examinations sliuuM !,<; given with ipecial attention to the skin and to the liver, liver function test.; U m ; performed periodically; and U) the l<e.*t hygienic conditions should pie; d, including Uie |>roviiou of clean work clothing, protective gloves, and protective cream*. Those manufacturer* who have had the most favorable results in p:eventing chlorowax |>oi*oning have provided iloiihlc locker looms, one for si roet clothes and one for work clothes, with a shower room in between. The workers should be required to take a shower every day Iscforc leaving the factory; it is well to provide supervision to make certain that this practice is complied with. Air analysis for the chlorowuxes is most commonly performed hy passing the ir over heated platinum in an electrically licuted quarts tube; the waxes decom pose and die effluent gas is scrubbed in a column of glass bends moistened with sodium carbonate; die chlorine is converted to sodium chloride which is recover.d by washing the'bends, and is usually determined ncplieloinetrienlly. The impinger, using amyl aectatc as the collecting medium, has also l>ccn employed for collection of sample*; afterward the sample? arc burned, products of combustion collected and chlorides determined. Chlorinated Oils. There arc two general ty|>cs of oils falling within this cl.i.-s; tltc first contains additive suktnnccs such us carlwn tetrachloride to improve cutting pro|*crtics; tin; second lias chlorine combined in complex organic structure T1c chlorine additive agents may Ik- recovered hy diflillntioii ami arc rclea.-cd from the oils in accordance with vapor pressure laws. The use of oil plus chlo rinated hydrocarlren may be hnsnrdous unless exhaust ventilation is provided. Kaueca and malaise are common complaints of workers handling the mixture-. The hapltasard method* u?ed in preparing the mixtures tend to increase the danger. Commonly live elilorine comiwunil is added in unknown proiwrlion a; an .mtulnte for outting difficulties. In some instances tlic mixture lias been found to com.,tin amuch # 40 |>cr cunt eat lion tetrachloride. Th ehlorine in tire second tyi>c of oil is firmly bound at lower tcmperalm -, upon benting, little decomposition occurs below 200*C.; near oml above 2>0'C. hydrogen chloride is evolved. It is known that tcmireratures in exec*:, of 300'C. are produced locally from heavy cutting operation*. This type of oil probably can be used safely fur light pre-vision machining. Animal cx|*orirocntation lias shown that chlorine eoin|>oumls in oil.- may io absorbed through tire intact skin to cause liver damage. Dermatitis from chlo rinated oils also occurs. H0NS 076170 WATER PCB-SD0000064086 outer, a iotoio/^ticn coi:c::Rini:c the fjandling OF AROCLQR 1254 By ff. E, Alexander Monsanto Chamlo&l Company Phosphate Division Engineering Department Asr.iaton s Alabam Deoentber 1, 1941 HONS 060030 irkf. n-i&V -- WAT ERJ DISTRIBUTION Twelve copies -vnre made of this report and distributed as follows : No. No. No. No. Mo. No. No. No. No. No. NO. No. 1 Z ) 4 5 6 7 8 9 10 11 12 R. S. 'Weatherly R. 3. Weatherly R. 3. '"eatherly R. R Col F, N. Williams H. ?. 'Weaver r r T. Durrett R. 1. Jenkins J. 1. Hcrerton J. Clegorn v.\ E. Aloxander Extra 3t. Louis St. Louis 3t. Louis e Anniston m Columbia Anniston Anniston Anniston Plant B - .ainiston /ami st on This is Copy No. 10 HONS 060031 WATER PCB-SD0000064088 INDEX Page No. A. General Characteristics ofAxoclor 1254 ... Hazards ............... Precautionsin Handling ........................... 1 2 2 5. Storage Tanks and Handling 2auip- ment ............................................................. .. 2, 3 G. Tank Cars, Their Unloading, Return, Etc........................................................................................................... 4 A P P END I X HONS 060032 WATER PCB-SD0000064089 A. CS2FPA1 Characteristics of Aroolor 1254 ?orm: Yellow tinted visoous oil* Color: A.P.H.A. 150 maxisusn. Acidity: (Vgja* KCH par gram) 0*01 maximum Coefficient of Expansion: 0.000661 oc/cc/deg.C. (25 deg. - 65 deg.c) 0.000367 ee/oe/deg.F. (77 -149 y) Density - Specific Gravity 25 deg./25 deg.C : 1*538 to 1.548 1.46 at 80 deg. 0 1.40 at 160 " 0 Pounds por Gallon: 2,83 at 25 deg* C. Distillation Range - aSTV-D-20 kod: 365 deg. - 390 deg. G 689 - 734 " F Evaporation Loss - A5TK-D-6 k'od: 163deg.C* - 5 hrs, - 1.06 to 1,28# 100 " C -- 6 * - 0.4/imaximum Flash Point: None Firs Point: Nona Pour Point: S deg. 46 " to 12deg. 0, to 54 * F. Viscosity - Saybolt Universal Seconds (ASTSf-D-88) 210 deg. F (96.0 deg. C) 43.5 - 48.5 130 " F (54.4 " C 260 - 400 100 " F (37.8 " C 1800 - 3800 Thermal Conductivity: 0.22 oal./gm./deg.C. at 0 deg. C 0.365 " /gc./deg.C. at 100 deg. C. Vapor Pressure: 7 mm.Hg. at 200 deg. C, 80 mm.Hg. at 275 " C. 520 znn.Hg. at 350 " . C. Solubility: Insoluble in water. Readily soluble in moot organic solvents. Slightly soluble in the cordon aloohols. Resistivity: 100 x 10^ at 100 deg. C. minimum. (Ohm Om.) Dielectrio Constant: 4.15 - 4.35 at 100 deg. C. Refractive Index: 1.6370 to 1.6390 ut 25 deg. C. HONS 060033 WATER PCB-SD0000064090 -2- Hazards The fuafli frer. Aroclor 1254 are quite obnoxious and are, v/hen Inhaled excessively, dangerous and hazardous, v/hen handling this material in relatively closed areas, ample ventilation (hoods in ex treme oases) should be provided for removal of the fuses from ths working area. The fumes attack the muooua membranes of the nasal passages and irritation of the manbranee and slight lung congestion may result from excessive Inhalation of the fuses. The handling of Aroclor iscarried out at tanperatures ranging from 75 deg, C. to 130 deg. C.. thus presenting a minor hazard of burns resulting from contact v.ith the hot liquid. Such bums require no special treatment. Precautions in Handling Aroclor 1254 will readily absorb traces of moisture. It is esoentif.l that the mntorial be kept from contact rith water. All air coming in contact with the Aroclor should be properly dried by passing through a dehumidifying unit-such as a calcium chloride breuther. activated alumina breothor, or other similar dehydrating agent units. Calcium chloride breathers on all storage and handling tanks have been found to be completely satisfactory. B. STOP ACE TAI.KS ,J'D TUI/PIIET, n,,UIR3TT Although Aroclor 1254 is but slightly corrosive to metals, it promotes corrosion!by oxidation) of iron and steel. Hence, no handl ing equipment should be of steel construction where it cooes in con tact with Aroclor. All process piping handling Aroolor must be galvanized. All wetted pump parts must be either stalnleos steel or bronze. (Worthington 'Vorthite pumps have been found to be canplotely satisfactory for thl3 service.) Storage and handling tanks nay be of steel construction if properly metallized v.ith zinctin, or aluminum on the interior sur faces coming in contact with the Aroclor. The metallizing should be done according to the following procedure: 1. Clean an area of the surface by sandblasting, or a similar method, to give a perfectly clean and roughened surface. The area oleaned should not be greater than oan be com pletely metallized within a few hours after cleaning. MOHS 060034 WATER PCB-SD0000064091 -3 2. If zino - tin metallizing 1b used, a ooatinc of zine 0.005 inches thick should be sprayed on the cleaned eurfaoe. This is followed immediately by a ooatlnr of tin 0.007 inches think. 3. Metallization with aluminum has been found acceptable. All storage and handling tank3 should be amply provided T.lth deViumldifying breathers such as calcium chloride, activated alumina, eto. units. This is essential in order to prevent moist air from coming in contact with the .iroclor. A moisture content above 35 p.p.m. adversely affects the dielectric constant and the resistivity of the Aroclor. Storage tanks must bo provided with ample touting ooll aurfaoe to supply sufficient haat to the material to bring it to the proper temperature for pumping, etc. Heating coils should be either metallized stoel, or, preferably, steel ooils which have been gelvunized ufter fabrication. It is reoonnended that the steum pressure on all boating coils ohould not exceed 100 pounds per square inch gage; lower pressures should bo used where practicable. It is essential that all steon coil3 be completely free of even minute leaks, since this would introduce water into the Aroclor. Before a newly oonstruoted storage tank is filled with Aroclor, it should be heated to a temperature of at least 100 deg. C to expel the moist air. The new tank should bo dried as much as is possible before charging. It would be beneficial to heat the tank, allow it to cool and pull in dry air through the dehumidifying breather, heat again, etc., until the tank is full of comparatively dry air before the initial filling of the tunk is started. Aroclor 1254 must be heated to 75 deg. C to 90 deg. C. for pump ing or other transportation through pipe lines, etc. When extremely rapid handling is desired, it is permissible to heat the material up to 130 deg. C. It io not advisable to hold the material ut such temperatures over extended periods of time, however. All handling pipe lines must be traced with steam lines and in sulation spoiled over the tv/o lines In order to keep the handling lines and the material up to the desired pumping temperature. MGNS 060C35 WATER PCB-SD0000064092 *4- C. TANX C,JiS. THTIK UHIQ,J>U:o. JJJTURN. ETC. Aroclor 1254 la shipped in two types of tank cars, both of whioh are either aluminum lined or zlno - tin aotallized. On type of tank has the heating oollo inside the tank which are in direct contact with the Axoolor, The other type of tank is a double shell tank with heating; ooils between the inner and outer shells* Doth types of tank are tested for 60 pounds pressure and their steam ooils are tested for 200 pounds. Beforo unloading the Aroolor, it is necessary to bring it to pumping temperature in the tank car* The steam coil outlet may be either trapped or throttled with a valve. It is recommended that steam pressures be limited to 100 pounds, particularly in the case of the coils being in direct oontact with the Aroolor. It will require from 6 hours to 12 hours to bring the material to pumping temperature (75 deg. C. to 130 deg. C.). depending on weathor conditions. .After the tank oar is emptied, the steam ooils must be blown clear of water and properly capped. Aroolor 1254 must be unloaded by displacement v>ith dry air; There are either two or three connections on the tank oar dome, de pending on the car type. r.Tien three connections are found, there is one 2 inch unloading connection which extends to the bottom of the tank, one 1 inoh air inlet connection, and one pressure safety vent v.hich is adjusted to release any pressure in exoess of 60 pounds. The vent connection is hooded for protection. V.'hen only two connections are found, one is a 2 inch unloading connection und the othor is the safety vent. In this case, it is necessary to re move the 3afoty vent and introduce the displacement air through that connection. When unloading la complete, all connections must be replaced as received. It is requested that the empty tank be sealed immediately aftor tho conneotlons aro broken Is order to keep the tanks flllod with dry air during return shipment. It is essential that the displacement air used for unloading be thoroughly dried by sane -dehumldifylng unit such as a oalolui chloride, activated alumina, or similar dehydrating agent drying unit. Required air pressures for unloading will depend upon the lay out of the unloading system* An unloading dock v.ith proper piping connections should be pro vided at the rallroud track v.here the Aroolor is to be unloaded. This dook ohould be provided with the connection to the discharge piping, the displacement air piping, and suitable steam connections for use on the steam colls. HONS 060036 WATER PCB-SD0000064093 APrrairax .U)DIT10IT,\I. IlT'ORJuiTlON CONCERNING -- --------------------------*--- - H.J.'DUir, Or^OClQR 12^ Attached to this copy of this report is llonsanto Chemical Comoany, Phosphato Division; Drawing No. 9U-8170-5 showing the detail construction of a 15,000 gallon storage tank for .;icclar 1254. This construction tojs beer found to be completely satis factory and is, to the beet of our knowledge, the best con struction for this aervice. The various nozzles on this tank are ueed as folia, a, con sidering them in order from left to right on the drawing: 3" nozzle 24" nozzle 3" nozzlo 36" manhole 3" nozzle 24" nozzle 3" nozzle 3" nozzle 1S"x26" Oral nozzle 3" nozzle Inlet for redrculatlon. For future agitator if required (not used). For oalolur. ohlorlde breather connection. For Inspectiont eto. Flont gauge located in center of this manhole. Not used. ' For future agitator if required (not used). Not used. Filling inlet oonneotion. For sump pump. For thermometer well (see detail). The two 24" nozzles v/ere originally Installed for installation of agitators if- required. Towevor, it has been found nnneeeasary to use agitators in the storage tank, and these nozzles oould be omitted from storage tanks whero extreme agitation is not required. It has been found that circulation of the Aroolor by the sump pump, and into the nozzle on the opposite end of the tank, for several hours gives satisfactory blending of the tank oontents* For pumping Aroclar 1254 from the storage tank, a Taber Tump Company all bronze 2-1/2" x 2" vertioal pump (Figure 1940) with monel shaft has been found to be quite satisfactory for the application. Further details and specifications for this pump will be furnished on request. HONS 060037 WATER PCB-SD0000064094 APHTDIX P.2 The liquid level gauge used In the storage must be gas tight. The konflanto Aroolor 1254 storage tanks are equipped with Vapor Recovery Systems Co. "Vareo", Fig. 253 gas tight automatlo tank gauge. Further details and specifications for this level indica tor will be furnished on recueat. It is reconx.onded that the stored Aroclor be filtered through a filter press using paper before using in order to remove any foreign matter auoh qs scale, eto. Details of a suitable filter can be furnished on recueat. The storage tank should be- provided with an operating platfom suitable to the customers conditions of operation* A dook for unloading should be provided at the tank oar unload ing location. This dock can be constructed to oonfora to other loading or unloading docks used by the customer. Detail prints of loading dooks used by Monsanto will be furnished on request. The dehumidifylng unit used as a breather on the storage tank oan be of any suitable construction. Calolta chloride breathers constructed as shown on Monsanto Chemloal Company* Phosphute Division, Drawing No. 9C-824S (attached) have been found satisfactory. The upper portion of the chamber is charged vith anhydrous olIoIub chloride. Periodic inspection of the oaloium chloride will show the formation of a cake of damp material on top about 1 to 1 1/2" deep. This cake should be removed and fresh material recharged. Any suitable construction similar to that shown on Drawing No. 9C-8248 may bo used for the breather units. '"TLA sms HONS 060038 WATER PCB-SD0000064095 < ' Vr. N.G.H. Thornes. Mr. W.H. Ritchie. 'VHR/JSj l4/l?/49 jRQCLORR-TOJICITY ARMSTRONGS PATENTS L"T. e.c. Dr. J.w. Barrett--' Dr. J. A. Oirdner Dr. H.R. Newman, It should be stressed to Armstrongs that. the use of Aroclors in die-castlng machines has been well established for some years In the States. Beyond the precaution? given In the bulletin oar e*lcol Department. In St. Louis has neter given any extra warnings or shown alarming concern over the use of Aroclors, . '. Dr. Newman end mvself are of the o-'inlon thet the greatest danger lie? In the inhelatln of the vaoou-s at high temperatures, and to thla end we suggest that you adtlst Armstrongs Patents as we did Armstrong Slddel.ey, ne-ely, (1) Lateral exhaust tentllatlon st the nolnt of usage, using a telocity of 1000 f.o.m. (?) Xdaquate tentllatlon of the room as a whole. (5) Strict rers^nal hygiene, For maintenance work on which the engineers may come in contact w'th the cooled liould we would adlvse good coterlng oteralls ( to be changed and washed as soon as the Job Is finished), rubber glores, and for the time be4 re a barrier cream. This should be as In the bulletin dr b?sd on a cream containing Lanollne uo to 70t, Dr. Newran Is uncertain as to the absorotlon of aroclors through the c-eam hurt fit' a. that the cream will give better protection thn the here skin. We do not adv1se the use of the cream after coming in contact 1th the Aroclor* Dr, Newman will write to Dr. Kelly N.D. Rt.Louis Immediately asking for further Information on this proven, and will communicate with you as and when he receives a reply, - \iA^ W.H.BPKHIB. HONS 095207 WATER PCB-SD0000064096 * J I /. Dec.11/51 Mr. P. J. C. Haywood Newport (Airmail) Hamer, Ruabon Mr. W. H. Ritchie, Ruabon Dr. H. R. Newman, Ruabon Mr. S. M. Kulifay, Krummrioh Dr. D. S. Weddell, Sc. Lou .1.3 Mr. ?. T. Marshall, St,Louis AROCLORS; TOXICITY Since writing to you on December 3rd I have come across a letter of mine to Mr, W. M. Cooper, London, June 24/48, (copies to W.D.S., W.H.O., and others), calling attention to an article in the J.T.Baker Conpany1s "Chemist Analyst", Vol.26, No.2, page 33, September 1947. I attach a copy of this article, and I think you will agree that the warning relates only to really bad exposure, not such as should occur in ordinary analytical work. On Oct.27/47 Mr. Barhre of the Krumrarich plant sent a copy of this Journal to IT. Jenkins at Anniston for comment, Dr. Jenkins did not make any comments at the time, but tho following extract from Mr. Barbra's letter is interesting: "During the 11 years of production here only one man evidenced dermatitis. He had also shown similar sys^toms in several other departments. When making Aroclor #1270 which is flaked, a noticeable amount of fine fume solidifies in the air. If men are exposed to it during hot humid weather, the skin is irritaood, but we have not had any dlff.iculiv ir. curing cases of dermatitis from Vt E. Mather WATER PCB-SD0000064097 The Chemist Analyst, Vol.36, No,2, page 33, J.T.Baker Chemical Co,, Phlllipsburg, N.J., September 19^7 On the Toxicity of the "Arochlors" (sic) Robert M. Brovm, Chief, Industrial Hygiene Section, Division of Health, Dept, of Public Welfare, City of St.Louie, Mo, A recently published article (Msglio, M.Martin, Chemist Analyst, ^5 91* (19^6) ), has recommended the substitution of one of the "Arochlors" as the melting-point bath liquid in preference to the customary sulphuric acid. As stated in that article "Arochlors" are a group of chlorinated diphenyls produced by the Monsanto Chemioal Company, , There is need therefore to give warning. For the toxioity of these confounds has been repeatedly demonstrated, both from the standpoint of their absorption from the inspired air as well as from their effects in producing a serious and disfiguring dermatitis when allowed to remain in contact with the skin. Since these effects have been repeatedly observed, industrial hygienists have taken care to see that the proper controls have been established wherever these products are used. For exanple, the maximum allowable concentration of chlorinated diphenyl for an 8-hour working day is 1 milli gram per cubic meter of air. It is probable that nothing like an uncontrolled industrial exposure will occur in the laboratory. However, whether an individual is subjected to a possible acute exposure to chlorinated diphenyl, and its serious consequences, will depend upon the else of the melting-point bath, the caution with which it is used, and the temperature to which it may be heated. Likewise, with careless handling of the material and the resulting contamination of the skin, clothing, labo ratory towels, work table surfaces, etc. the way is left open for the produolng of dermatitis. Scrupulous cleanliness must be insisted upon wherever this material is handled. The foregoing remarks have been prompted by the belief that in recommending tho use of & material with which is associated a potential hazard from the health standpoint, it is very important that the possible consequences be presented together with recommendations for correct handling. MONS 095206 WATER PCB-SD0000064098 St. Louie Mr. P. J. C. Haywood Newport (Airmail) (Airsail) . December 1177//5511 Mr.W.E.H&fflor, Ruabon ^Mr.W.H. Ritchie, Ruabon Ear*.H.R.Newman, Ruabon Mr-.-S.M* .Kulifa-ryf ,/ tK\Aruvunuaurmu iicc Dr.D.3.Weddell, St.Louis Mr.F.T.Marshall, st.Loui Sine writing my not of Deo.ll/51 1 bare ehanoed to learn that Anniston people had quite serious skin troubles! boils, blackheads and the like, among workers in Aroclors, especially 1269, around 1933* A little browsing into the literature reveals quite a history of skin troubles and liver troubles (inoluding some fatal oases) attributed to heavy exposure to chlorinated diphenyls. The chlorinated diphenyls are stated to be worse than ehloroaphthalenes, and to be more harmful the more chlorine they oontaint I still think, however, that the exposure in ordinary analytical work should not cause any trouble. 1. Mather tm MOhS 0951CH WATER PCB-SD0000064099 OJLI Dr. HJt. Imu. levpert, England. February 12th, 1954 V* do not know what tbs aaxiaua allowable oonoentratlon of iroclor la. Dae aiHigraa per euble eeter has been set v^ We hare run animal for about 60 days at 7 Um this and found bom llrer daaage. We are no* naming this at a lower level. Ve hare neves* found any liver trouble la any of tbs workere La our plant, but ve vatoh the eootrel of the fUMe in our euetoaare1 plant* and always reooMend exhaust ventilation. X as sure you realiii that 1 mg per eubis meter 1j reooMeeded for m 6hour day for indefinite periods of time, la. paintin# a room ve have foassd 1 2 mg For a day or so, but after ihsi the lerel drops down t# nothing. What ve were really worrying about ves the possibility that a man would develop hepatitis, os as idiopathic. viral, or serum Win ami on questioning would reoail that he had painted a room with ireeler paint and state that he had eaallM it very strongly, X ah afraid than ve might be ocevieted by essoeiatioa even though ve were eure one eoald not get a level high enough to e&use trouble. Ve hare, however, bee eonoemed with the level of drooler during spray painting, but X think that level ean only be determined by astsal measurements. Fleas# do mat worry about asldmg me these questions beeause we eertainly went you to hare the entire plettse about drooler tesleity, 4s soon as X gat a report m the work at lettering, X will let you know. 1. fegiwt felly, MD. is/mi. HONS 095193 WATER PCB-SD0000064100 * "mi (HtMiiTir of inouuiiai roncotoor chku-ouaphlhiilioo per cubic mclcr of rir. Drinker and other* slwwcd (bat concentration* of this order damaged (ho liver* of rub, on long o.\|x>*iirc. When hot, these eoat|NWwU ilioold Ik? lumdlctl in closed system* or with very effective ventilation. In addition to serious systemic effects, these wa.se* nro bud dermatitis producers, causing a ildn con* dition known ns chlnrncnc. Occasionally such dermatitis results from belittling wirr* whose Insulation is Impregnated with this wax, but it ft more prevalent where tin? wax is handled In a molten state. T1k> concentration* of ehloronnphtlinlcnc fumes found In various processes in Massachusetts aro listed in Table 31. ) CfdniC ' COlfip'iti/. Ii\'( r Cf.nsi*-I. *. t f i < . t r. c:. !< literature Drinker's > A t mr,*, r-, in Mas> a. CoiMlrnwr impregnating Coadertarr tealing Contienarr oltiering Wire impregnating TAKI 3) NXLOWAX rUMS COHCCNTMATIONM r*f$ ef ll'ajt Number nf 84udms Cnftntrelinn (mjt/m1) Mas Arg TrifHInfonRpUf Ilfichlort>fU|>)ithtleiK 7 to 7.0 t S 1.4 TriehloronaplitlialrrM $ t 1.0 Hcxarbloronaph thalers* 11.1 j.n Ollier fatal cnurs of liver atrophy attributed to chlorinated naphtha* Itno flows arising from etmdcnwr.w'nling iwiHvwm uml coaling uf electric cabins Iwive Ikwii r!pnrti>d in lids country.1*' One dentil and several eases of dermatitis were caused in England by chlorinated naphthalene used for protecting metal* in chromium plating, accord ing to Collier.'*' An outbreak of dermatitis occurred in Missouri from tho employment of marking crayon, containing chlorinated nnplithalmc binder, on hot metal costings.'** /v Corvlriw r u Con*li p,. r in. Onnili'MM-r .... Oil miviiic nrcalalAr fu..: In none of the chlnrod'.; of 10 mg per 5. Chlorinate lu llic in. i `mistin',' it Sunn nf (In has. icliturnn. and ndirrv by (be same 4. Chlorinated Diphenyls, C|SH#CI,tI 6. DieMofod Harmful effects; Irritation: liver damage. I l>egrw. Can be serkm*. . Maximum allowable cnoccntrntioas 0.5-1.0 mg/m*. Evaluation: Air analysis. pi 1 {.*intfnl ( t' M.tMtilllllt KN .littU;i>' THe chlorodlphenyk, known as Arocloc or Dykanol, arc used as heat-transfer media and for the impregnation of dielectrics, wire in- nilaUoo, etc. Animal experiment* liave indicated that tome of these DDT at* |>n|>cfhV* . f MONS 076158 WATER_PCB-SD0000064101 Icoioor otluTS rats. k'StCIUS |t'tic i confrom |Ihi( l( admit frafmu ') A' 7.8 1.4 1.0 t.t Ittha- Is [ And k ford pmiri (cd u . in- OtQAHJC COMPOUNDS' PAST (Hi HAlOOtH COMPOUNDS m compotnMl.x arc rcliiiltvly non-toxic, wherein otlnrs apparently came liver damage.1** According to Trenn and co-wuikcri, Arnclor I2.ri, confuting chiefly of pctuacltlorndipltcnyl, is *ever.il timej m imic as tlvo (rirhbmxliphcnyl, Aniclor lSli*1* Some of (Ik- references in tKo literature regarding tlus toxicity of chlorinated diphenyl refer to Drinker's original experiments with chlorinated triplienyl. Atmoapltcnc concentrations of vnrions clilorodiphcnyl fumes found in Massachusetts plants are given in Table 32. TA*U S3 A DOCTOR WUB CONCKXTRATIONa CAtarWiyAmff Fame Canejntraii** (mn/m*) IW Coruirnaer impregnatiag Comlrnarr impregnating Cotwlroarr utklrriitg Oil mixing Regulator filling Max no.s 1 i* 19 IS 1.1 Of Avg IS u 0.8 0.R 0.6 0.1 In none of these plants was there any evklence of toxic effects from the chlorodiphcnyh hut tlte highest concentmlions found, of the order of 10 mg per cubic meter, were unbearably irritating. I. ChlaWnaiad Tdghanyi In the manufacture of chlorinated diphenyl, certain by-products, consisting mainly of a mixture of chlorotriphenyk, are produced. Some of these mixtures are even more powerful liver poisons than hexachioronaphthalene, according to the animal studies by Drinker and others. They have been used for similar purposes and are known by the same trnde name, Aroclor, as certain of the true chlorodipbenyls. 6. DlchlererfiphenyltWchJereelhena, (C^HjCI),--CH--CCJ, (DOT) Melting pomt; 108 C. Harmful effects: Damage to nervous system, liver. Degree: Can be tertana. Maximum altowalde cacentration: ft mg/m*). Evaluation: 1. Air analysis. t. UrisM anah'sk. - DDT achieved stidden prominence by remrm of Its remarkable properties as nn Inaecticide and its wide uso In World War 11 as a HONS 076159 IM Till CMMIStSV Of INOVtTSIM TOIICOIOOT OsGa/hC C0mo . li ljMtvIng iiimI In birce-nrva mawpillo control. p.;t'-Diclil4irn- i,lOKi(I< (ki: ,_ dl|ilM*nyltrfcltlnrnrt1imH* t* ll*o active Ingredient of DDT, lint (lie l<-w fvHilli Aii-*ri'. .> active ortlio-/Him Isoukt occur* as a major Impurity In |Ikj technical among s[r;,yrf,, , product. ir>g */npoijfn. At prevent, DDT I* pcidwldy tlw* most widely used In.occtMdr. In 4ijinnt;i, fi .MVf.j |>lle of llie fuel llmt It In tn\le to wurtn-fil< Nlcd luiinmls, tlwre Imve liven relatively few proven case* of ncrbais liimum (Masoning. In tlie majority of deaths fnllnsWng ingexllnn of DDT. solution*, tlie clinical picture lu\i been characteristic of solvent poisoning.*" Unless grossly tary j< rl.u,:; of , lo-.v l.f I l.i, .1 ..... til'll' l< iii,ii,.,Ii ! 'IlMAf: i If. i !, misused, (Ins Im/nril from DDT application i* not groat. Similarly die COW-TV, Inline., I mixing of DDT dust* prndners only a moslernto hnxnrd, provided a rcnsnuitlilo tk'gro*' of dust conlrol b tnolMtaimil. Sonic aln.nn:,,,, sproymr a '.v|.Ii v : DDT I* eservted In llte urine h* DDA (lH>/M:lilnro|>leuyl int'lle nefd). Analysis of fut for stored DDT lues aUo Iwcn immsI m.* a It A < I' ir Ii fCf | ui r* yi, ,t, I measure of alrsorption. illVCI til nil . Olln-r I lilnrii. 7. Chlerdone, C,,H.a, Chapter JJ. (l,2,4,5,fl,7,M-OctichloiT>-3a,4,7,7a-tetrahydro-4,7-mcthannfndanc) Harmful effects: Damage to nervous system, Hver. Degree: Can be serious. Maximum allowable concentration: (I mg/m1). EvahtalinM 1. Urine anatysfe. ft Air emdyste, . Allltough llto toxicity of chkirtlnno, as meMtwrd by Ingestion espiTI- ments with animals, is ten than tlwt of DDT and similar cbbwimilwl Insecticides, several human poisonings have followed its use or Inges tion. Of IS such coses reported by Conky, 5 were fatal Ingestion was responsible for 6 of these cases, skin absorption and inhalation for the rest.*1' Chlordane appear* to be absorbed through the skin more readily than DDT. ' *1, WeUMss, C,,H,a,0 (144,4,10,10-Hcxehlori>-epe*y-l,4,4adMl'733-octahydro-l,4-imlooso-54-dlmethaiwaaphthalene) HamfeJ effects: Damage to central nervous system. Degrees Can be serious. Wsilu-- affowabk concentrstion: (0.25 mg/m*). Although dkldrin is known as one of the most toxic of the chlorin ated fmeetfekks, its use in this country has not produced any notable HAIO 1. Ethylene Chi. Molct'iii.r w, . ii.nmfril t Ifi . i D* "!! V i. .. M ,s),, . Evaluation: This w.itcrtoxic .solvent, them fatal. h.. lion, otln r, i' suiting frnm ppm ` C A llllictl >\inp'. ethylene cl:!, dichloi idv \s.. There ,,c:c . months' i \pi ment of cil.' potatoes. HONS 076lh0 WATER_PCB-SD0000064103 toO MAC COMPOUNDS. f** HI. MAlOOtN COAtOONM |J{ litckk-tKc of intoxication. Numerous easts have been rcjtortcd lit South America, ltowcvcr. Hayes, in discussing 63 clinical case* among spraymen In Venexuela, Ecuador, and Nigeria, lists tltc follow ing symptoms: hcndaclte, blurred vision, twitching, sweating. insomnlrt. nntisra, nod general malaise.'** In oevero poisoning involtmtan' forking of musclo groups, sometimes causing falling, inomcntiiry loss of coiwIoumwm, nnd epileptic convulsions occurred. One such ease terminated fatally. Tlteso elTects were apparently doe to chronic Intoxication and re covery, following removal from exposure, was frequently slow. Some nlwnnnality in dectrocnceplialograms was noted in dicldrin sprajmen who were considered well clinically. It Is clear that dicldrin, and the closely related endrin and aldrin, require greater precaution in handling titan is customarily used with insecticides. Other chlorinated compounds used os Insecticides are discussed in Oui|cr 11. HA10OENATO MCOH0U, ITHISi, AND 1STPS 1. Clhylene CWomhydrb. CH,OHCH,a NiolecuUr weight: 80.S. Boiling promt: 132 C. Hannful effeeis: Uver, kidney, and brain damage. Degree: Serious, fatal Maximum alhmelAr concentration: (5 ppm). Evaluation: Air analysis. * This wntrr-solnlilo liquid, chlnroethyl alcohol, is among the most toxic solvents commercially available. Soveml poisonings, some of tlxxn fatal, lutvc Itrvu reported. Sotno were nttrilnslcxl to skin nlwnr|>- t it ms, iMIhts to inlwkathm. Dierkir nml llrmvtt report a filial case re suiting friHit a 2-ltour exposure to a concentration estimated at 300 ppm.'** Citklldutt and Chrtsman report dvonie effects, nausea, uml allied sympitans, in a plant where the average concentration of ethylene chlortthydrio vapor was found to he 18 ppm.'** Ethylene dichbride was abo present, In concentrations of the order of 00 ppm. TIkto were two fatal asses, one acute and one chronic, following 2 mtmths' espnsorc. Fata) poisotting Itas also resulted from tlsu employ ment of ctltylcno chlorohydxin vapor to stimulate tho sprouting of potatsca. HONS 076161 DANGEROUS PROPERTIES of INDUSTRIAL MATERIALS A Completely Revised and Enlarged Edition of HANDBOOK OF DANGEROUS MATERIALS Q <VJ / N. IRVING SAX Consultant on Industrial Safety Nuclear Development Corporation of America White Plains, N. Y. Assisted by LEONARD J. GOLDWATER Professor of Occupational Medicine Columbia University New York, N. Y. JOSEPH J. FITZGERALD Harvard University Cambridge, Massachusetts JOHN H. HARLEY Chief, Analytical Branch Health and Safety Laboratory U. S. Atomic Energy Commission New York, N. Y. WILLIAM B. HARRIS Chief, Industrial Hygiene Branch Health and Safety Laboratory U. S. Atomic Energy Commission New York, N. Y. MILTON S. DUNN Medical Director, Rensselaer Division General Aniline and Film Corp. Rensselaer, N. Y. REINHOLD PUBLISHING CORPORATION, NEW YORK CHAPMAN & HALL, LTD., LONDON WATER_PCB-SD0000064105 Copyright 1957 by REINHOLD PUBLISHING CORPORATION All rights reserved Library of Congress Catalog Card No. 57-13170 First Printing January 1958 Second Printing June 1958 Third Printing March 1960 Fourth Printing March 1961 REINHOLD PUBLISHING CORPORATION NEW YORK CHAPMAN & HALL, LTD., LONDON .a Printed in the United States of America THE GUINN CO., INC. New York 14, N. Y. WATER PCB-SD0000064106 226 ABBREVIATIONS USED IN SECTION 10 ACGIH . . . ..................................American Council of Governmental and Industrial Hygienists anh...................................................... anhydrous atm..............................................................atmospheres Autoign. Temp. ...........................autoignition temperature B. P.............................................................boiling point C. C.............................................................closed cup C. O. C....................................................... Cleveland open cup decomp..................................................... decomposition C............................................................ degrees centigrade F............................................................ degrees Fahrenheit Flash P.................................................... flash point I. C. C. ...............................................Interstate Commerce Commission L, . E. L.................................................... lower explosive limit MAC..................................................... maximum allowable concentration MCA..................................................... Manufacturing Chemists'Association M. - P.........................................................melting point mm ..................................................... millimeters Mol. Wt....................................................molecular weight O. C............................................................. open cup T. O. C....................................................... Tag open cup U. E. L..................................................... upper explosive limit Vap. D...................................................... vapor density Vap. Press............................................ ' vapor pressure WATER PCB-SD0000064107 CHLORINATED DIPHENYLS CHLORINATED DIPHENYLS Description: Colorless mobile liquid Constants: B. P. 340 - 375C Flash P. 383 F (C. O. C. ) Density 1.44@30C Toxic Hazard Rating: Acute Local: Irritant 2 Acute Systemic: Ingestion 3; In halation 3 Chronic Local: Irritant 3 Chronic Systemic: Inhalation 3; Skin Absorption 2 MAC: ACGIH (accepted): 1 milli gram per cubic meter of air. Toxicology: Like the chlorinated naphthalenes, the chlorinated diphenyls have two distinct actions on the body, namely, a skin ef fect and a toxic action on the liver. The lesion produced in the liver is an acute yellow atrophy. This hepato-toxic action of the chlorinated diphenyls appears to be increased if there is exposure to carbon tetrachloride at the same time. The higher the chlorine content of the diphenyl compound, the more toxic is it liable to be. Oxides of chlorinated diphenyls are more toxic than the unoxidized materials. The skin lesion is known as chloracne, and consists of small pimples and dark pigmentation of the exposed areas, initially. Later, comedones and pustules develop. In persons who have suffered systemic intoxication the usual signs and symptoms are nausea, vomiting, loss of weight, jaundice, edema and abdominal pain. Where the liver damage has been severe, the patient may pass into coma and die. Fire Hazard: Slight, when exposed to heat or flame (Section 6). Disaster Control: Dangerous; when heated to decomposition, they emit highly toxic fumes. Ventilation Control (use moderate rate): Section 2 Personnel Protection: Section 3 Personal Hygiene: Section 3 First Aid: Section 1 Storage and Handling: Section 7 Shipping Regulations: Section 11 MCA warning label. 462 CHLORINATED HYDROCARBONS, ALIPHATIC Toxicology: The substitution of a chlorine (or other halogen) atom for a hydrogen greatly increases the anesthetic action of a member of the aliphatic hydrocarbons. In , addition, the chlorine derivative is usually less specific in its action and may affect other tissues of the body in addition to those of the central nervous system; in many cases the chlorine deriva tive is quite toxic. Thus, chloro-j form, in addition to its narcotic qualities, may cause liver, heart, and kidney damage. As a general rule, the unsat urated chlorine derivatives are highly narcotic but less toxic than the saturated derivatives, i thus causing degenerative changes in the liver and kidneys less fre quently. In the saturated group, the narcotic effect is enhanced with an increase in the number of chlorine atoms. However, there is less relationship between the , number of chlorine atoms present and the toxicity of the compound. In dealing with these chlorinatec hydrocarbons, it must be remem bered that a toxic action may re sult from repeated exposure to concentrations which are too low to produce a narcotic effect, and which, consequently, are too low ) to give warning of danger. Indi vidual susceptibility is also im portant when poisoning by this group of solvents is being con sidered. Certain workmen may be seriously affected by concen trations that seem to have no i effect on fellow employees in the same exposure. Disaster Control: Dangerous; when heated to decomposition, they emit highly toxic fumes of phosgene; they can react with oxidizing materials. > Storage and Handling: Section 7 CHLORINATED HYDROCARBONS, AROMATIC Toxicology: In most instances it is difficult to predict the toxicity of these compounds. However, ) Toxic Rating Code: 0 = None 1 = Slight 2 = Moderate 3 = High U = Unknown WATER PCB-SD0000064108 SECTION 11 1400 truckloads or less-than-tnickloads when handled by a motor vehicle not requiring transfer from one motor carrier to another. When offered for transportation by carrier by water each package must show the name or mark of the consignor and/or consignee. (d) Each package of chemical ammunition, explosive, containing poisonous gases, solids or liquids, class A, class B or class C must also have securely attached to it labels prescribed by 73.409 (a) (1), (a) (2), or (a) (3) of this part. (1) Carload or truckload shipments of chemical am munition, explosive, containing poisonous gases, solids or liquids, class A, class B, or class C offered for trans portation by, for, or to the Departments of the Army, Navy, and Air Force of the United States Government are exempt from labeling requirements when shipments are loaded or unloaded by the shipper or his duly author ized agent and such shipments are accompanied by quali fied personnel supplied with equipment to repair leaks or other container failure which will permit escape of contents. (e) Each shipment of samples of explosives when of fered for transportation by carriers by rail express or water must bear the label prescribed by 73.411 of this part and each shipment of special fireworks in addition to the marking prescribed by 73.91 (i) of this part when offered for transportation by carriers by rail express or water must bear the label prescribed by 73.410 of this part. (f) Each shipment of propellant explosives when of fered for transportation by carriers by rail express must bear the label prescribed by 73.412. (g) Each package of explosives must be marked with the I.C.C specification number as prescribed by the spe cification, if an I.C.C. specification container is required. 73.401 Dangerous articles, (a) Packages containing flammable liquids, flammable solids, oxidizing materials, corrosive liquids, compressed gases, and poisons, as de fined in this part must be marked, unless exempted, with the proper shipping name as shown in the commodity list (see 72.5). For tank cars this marking must appear either on the placards or commodity cards. (1) Every portable tank used for the transportation of any dangerous article shall be conspicuously and legi bly marked on a background of sharply contrasting color with a sign or lettering on the tank with words as appro priate "CORROSIVE LIQUID," "COMPRESSED GAS," or "FLAMMABLE COMPRESSED GAS" and with the proper shipping name as shown in the commodity list (see 72.5); the height of all required lettering shall be at least 2 inches or 1/10 the diameter of the tank, which ever is the greater; every portable tank container shall be marked with the owner's name; in addition to the markings hereinbefore required, there may be marked on any portable tank container the trademark appropriate to the commodity being transported therein: Provided, however, That no such marking shall be of such size and character as to render inconspicuous the required mark ings. N'o markings either required or permitted under the terms of this subparagraph shall be in lieu of any other marking or markings required by the Commission (b) Each package of dangerous articles must show the name and address of the consignee except in carloads and truckloads or less-than-truckloads when handled by a motor vehicle not requiring transfer from one motor car rier to another. (c) Packages containing flammable liquids in inside containers of 1 quart capacity or larger, or corrosive li quids, acids, alkaline caustic liquids, liquid oxidizing ma terials and poisonous liquids in inside containers regard less of capacty, unless specifically exempted or otherwise provided in this part, must be packed with filling holes up, and except for carboys not completely boxed, the outside container must be plainly marked "THIS SIDE UP" or "THIS END UP" on the cover or top to indicate the position of the inside containers. This requirement does not apply to materials in inside metal cans of the nonrefillable type with spun-in head and base and having no replaceable cap or other closing device. (d) Each package must show the specification marking as required if a specification container is prescribed. (e) Additional shipping information not inconsistent with Parts 71-78 may be shown on a container if so desired but no such label or marking shall be of a design, or form, or size, as may be confused with the marking required by Parts 71-78. 73.402 Labeling dangerous articles, (a) Each pack age containing any dangerous article as defined by Parts 71-78 must be conspicuously labeled by the shipper as follows, except as otherwise provided; (1) "Red label" as described in 73.405 on containers of flammable liquids, except when exempted from the regulations by 73.118. If flammable liquid is also a class A poison or a radioactive material poison D, the "poison gas" label or "Radioactive materials" label must also be applied to the package. (2) "Yellow label" as described in 73.406 on con tainers of flammable solids and oxidizing materials, ex cept when exempted from the regulations by 73.153 and 73 183. If flammable solid or oxidizing material is also a class A poison or a radioactive material poison D. the "poison gas" label or "radioactive materials" label must also be applied to the package. (3) "White label" as described in 73.407 (a) (1), (2) and (-3) on containers of acids, alkaline caustic liquids or corrosive liquids, except when exempted from regulations by 73.244. If the acid, alkaline caustic liquid or cor rosive liquid is also a class A poison or a radioactive ma terial poison D, the "poison gas" label or "radioactive materials" label must also be applied to the package. (4) "Red label" as described in 73A08 (a) (1) on containers of flammable compressed gases, except when exempted from the regulations by 73.302. If die flam mable compressed gas is also a class A poison or a radio active material poison D, the "poison gas" label or "radioactive materials" label must also be applied to the package. (5) "Green label" as described in 73.408 (a) (2) on containers of nonflammable compressed gases, except when exempted from the regulations by 73.302. If the nonflammable compressed gas is also a class A poison or a radioactive material poison D, the "poison gas label or "radioactive materials" label must also be ap plied to the package. (6) "Poison as" label as described in 73.409 (a) (1) on containers of class A poisons. (7) "Poison" label as described in 73.409 (a) (2) on containers of class B poison liquids or solids, except whenexempted from the regulations by 73.345 and 73.364. If the class B poison liquid or solid is also a radioactive material poison D, the "radioactive materials label must also be applied to the package. (8) "Radioactive Materials" label as described in 73.414 (a) on containers of class D poisons, Group I and II except when exempted by 73.392. (9) "Radioactive Materials" label as described in 73.414 (b) on containers of class D poisons, Group W> except when exempted by 73.392. (10) "Tear gas" label as described in 73.409 (a) (3) on containers of poisons, class C. (11) "Bung label" as described in 73.119 (i) of this part on metal barrels or drums containing flammable li quids with vapor pressure exceeding 16 pounds per square inch absolute. (12) "Empty label" as described in 73.413 of this part must be applied to containers which have been emp tied and on which the old label has not been removed, obliterated, or destroyed. It must be so placed on the container as to completely cover the old label. (13) Labels prescribed for shipments of explosives and other dangerous articles by air between the United States, its territories and possessions, and other countries, as shown in 73.405 (b), 73.406 (b), 73.407 (b), 73.408 (b)> 73.409 (b), 73.410 (b), 73.411 (b), 73.412 (b) and 73.414 (e), may be used in lieu of labels otherwise prescribed and for local transportation to or from airport. (b) Labels when applied to packages offered for trans portation by rail express, rail baggage, or other forms ot transportation for which a certified shipping order, bill WATER PCB-SD0000064109 1401 SHIPPING REGULATIONS ading, or other shipping paper is not required, must v shipper's name in printing, stamping, or writing emeath the certificate printed thereon. (1) Labels prescribed for shipments of explosives or ;r dangerous articles by air between the United States, territories, possessions and other countries, as shown i 73.405 (b), 73.406 (b), 73.407 (b), 73.408 (b), 73.409 73.410 (b), 73.411 (b), 73.412 (b) and 73.414 (c) are lorized. Such shipments must be tendered with a led certificate, in duplicate, reading as follows: (one led copy shall be retained by the original- carrier): This is to certify that the contents of this package are perly described by name and are packed and marked . are in proper condition for transportation according he regulations prescribed by the Interstate Commerce nmission and the Civil Aeronautics Board. (For shipat on passenger-carrying aircraft the following must added to certificate: This shipment is within the limions prescribed for passenger-carrying aircraft.) (c) Labels and marking name of contents are not uired on carload or truckload quantities of dangerous icles, except class A, class C, or class D poisons, by freight, mil express, or highway, when such shipnts are unloaded by the consignee or his duly authord agent from the car or motor vehicle in which origlly loaded. (1) Carload or truckload shipments of class A, class class C, or class D poisons offered for transportations . for, or to the Departments of the Army, Navy, and Air rce of the United States Government are exempt from >eling requirements when shipments are loaded or unded by the shipper or his duly authorized agent and :h shipments are accompanied by qualified personnel rplied with equipment to repair leaks or other containfailure which will permit escape of contents. (d) Except on class A, class C, or class D poisons, >els are not required on less-than-truckload shipments motor vehicle by public highway when the articles i readily identifiable by reason of type of container when the container is plainly marked to indicate its ntents and; (1) When the shipment is transported from origin to stination without transfer between vehicles and; (2) When the shipper or its employees are in direct ntrol or perform the loading, transporting and unloadg. (e) When it is known that subsequent shipments of ese packages may be made by consignees in less-thanrolad or less-than-truckload quanties, or in carload or lickload quantities to a point where they may be handd by other than the original consignee, the original ipper should attach labels to the packages as would ; required for less-than-carload or less-than-truckload lipments. (c) Use yellow label only when yellow and poison labels are prescribed except when poison gas label or radioactive materials label are prescribed then both the yellow label and the poison gas label or the yellow label and the radioactive materials label must be used. 73.404 Labels, (a) Shippers must furnish and at tach the labels prescribed for their packages. Labels should be applied to that part of the package bearing con signee's name and address. (b) Labels must not be applied to packages contain ing articles which are not subject to Parts 71-78 or are exempted therefrom. (c) Shippers must not use labels which by their size, shape, and color, may readily be confused with the stand ard caution labels prescribed in this part. (d) Labels must conform to standards as to size, printing, and color, and samples will be furnished, on request, by the Bureau of Explosives. (e) A combination diamond-shaped label-tag of pro per size and color, bearing on one side the shipping in formation and on the reverse side the wording pre scribed in this part, will be permitted. (f) As certification of compliance with regulations is also required by other Government agencies, and to avoid multiplicity of certifications, there may be added to the certificate on labels "and the Commandant of the Coast Guard," or "and the Civil Air Regulations," or "and the Post Office Department," as is necessary. (g) The earner's name and stationery form number, or the shipper's name and address, may be printed on the labels, in type not larger than 10 point, if placed within the black-line border and in the upper or lower comer of the diamond. (h) Labels remaining on hand and which were author ized by regulations in effect on December 31, 1950, may be used until present stocks are exhausted. 73.405 Flammable liquids Label, (a) Labels for flammable liquids must be of diamond shape, bright red in color, and with each side 4 inches long. Printing must be in black letters inside of a black-line border measur ing 311 inches on each side and as shown in this section. RED LABEL FOR FLAMMABLE LIQUIDS (Reduced size) (Black printing on red) 73.403 Labels for mixed packing, (a) Use red bel only when red and other labels are prescribed ex;pt when poison gas label or radioactive materials label 'e prescribed then both the red label and the poison gas bel or red label and radioactive materials label must s used. (b) Use White acid (alkaline caustic liquid or corrove liquid) label only when white acid (alkaline caustic quid or corrosive liquid) and yellow or poison labels re prescribed or poison labels (class B) are prescribed, xcept when poison gas label or radioactive materials ibel are prescribed then both the white acid label and re poison gas label or white acid and radioactive masrials label must be used. WATER_PCB-SD00000641 SECTION 11 1402 (b) Red label for flammable liquids for shipment by air. (b) Yellow label for flammable solids for shipment by air. 73.406 Flammable solids and oxidizing materials label, (a) Labels for flammable solids and oxidizing ma terials must be of diamond shape, bright yellow in color, and with each side 4 inches long. Printing must be in black letters inside of a black-line border measuring 3Ji inches on each side and as shown in this section. YELLOW LABEL FOR FLAMMABLE SOLIDS AND OXIDIZING MATERIALS (Reduced size) (Black printing on yellow) 73.407 Acids, corrosive liquids, and alkaline caustic liquids labels, (a) Labels for corrosive liquids, acids and alkaline caustic liquids must be of diamond shape, white in color, and with each side 4 inches long. Printing must be in black letters inside of a black-line border measuring 31i inches on each side and as shown in this section. (1) WHITE LABEL FOR ACIDS: (Reduced size) (Black printing on white) WATER PCB-SD0000064111 1403 SHIPPING REGULATIONS (2) WHITE LABEL FOR CORROSIVE LIQUIDS: (Reduced size) (Black printing on white) (b) Labels for shipments of acids, corrosive liquids, and alkaline caustic liquids by air must be as shown in the following: (1) White label for acids for shipment by air. (Reduced size) White and black with (black printing on white) (3) WHITE LABEL FOR ALKALINE CAUSTIC LIQUIDS: (Reduced size) (Black printing on white) (2) White label for corrosive liquids for shipment by air. (Reduced size) White and black with (black printing on white) WATER PCB-SD0000064112 SECTION 11 1404 (3) White label for alkaline caustic liquids for ship ment by air. (2) GREEN LABEL FOR NONFLAMMABLE GASES: (Reduced size) White and black with (black printing on white) (Reduced size) (Black printing on green) 73.408 Compressed gas labels, (a) Labels for com pressed gases must be of diamond shape, bright red in color for flammable gases and bright green for nonflam mable gases, and with each side 4 inches long. Printing must be in black letters inside of a black-line border measuring Sli inches on each side and as shown in this section. (1) RED LABEL FOR FLAMMABLE GASES. (Reduced size) (Black printing on red) (b) Red label for flammable gases for shipment by air. (Reduced size) Red and black with (black printing on red) WATER PCB-SD0000064113 1405 SHIPPING REGULATIONS (1) Creen label for nonflammable gases for shipment by air. (Reduced size) Green and black with (black printing on green) (2) POISON LABEL. (Reduced size) (Red printing on white) 73.409 Poisonous articles and tear gas labels, (a) abels for poisonous articles and tear gases must be of iamond shape, white in color, and with each side 4 iches long. Printing must be in red letters inside of a id-line border measuring 3J4 inches on each side and s shown in this section. (1) POISON GAS LABEL. (Reduced size) (Red printing on white) (3) TEAR GAS LABEL. (Reduced size) (Red printing on white) WATER PCB-SD0000064114 SECTION 11 1406 (b) Labels for shipments of poisonous articles and tear gases by air must be shown in the following: (1) Label for poison gas for shipment by air. (Reduced size) White and red with (red printing on white) (3) Label for tear gas for shipment by air. (Reduced size) White and red with (red printing on white) (2) Label for poisons for shipment by air. (Reduced size) White and red with (red printing on white) 73.410 Special fireworks label, (a) Labels for spe cial fireworks must be square measuring 4 inches on each side and bright red in color. Printing must be in black letters inside of a black-line border measuring 31s inches on each side as shown in this section. RED LABEL FOR SPECIAL FIREWORKS (Reduced size) (Black printing on red) 4 Inches SPECIAL FIREWORKS HANDLE CAREFULLY KEEP FIRE AWAY DO NOT DROP NOR THROW xs o This package must not be loaded or C stored near steam pipes or other source of heat ThU Lb to certify that the content* of thi* package are properly described by name and are packed and marked and are in proper con dition for transportation according to the regulation* prescribed by the Interstate Com* merce Commission. (Shipper's Name) WATER PCB-SD0000064115 1407 SHIPPING REGULATIONS (b) Explosives label for shipment of Special fireworks by air. (Reduced size) (Black printing on red) (b) Explosives label for shipment of samples of explo sives by air. (Reduced size) (Black printing on red) $ 73.411 Explosives samples for laboratory examina tion label, (a) Labels for samples of explosives for labiratory examination must be square measuring 4 inches 3n each side and bright red in color. Printing must be in black letters inside of a black-line border measuring 3)1 inches on each side and as shown in this section. RED LABEL FOR SAMPLE OF EXPLOSIVES (Reduced size) (Black printing on red) ---------------4 Inches ----- EXPLOSIVE Sample for Laboratory Examination xsoe HANDLE CAREFULLY KEEP FIRE AWAY This is to certify that the contents of this package are properly described by name and are packed and marked and are in proper con dition for transportation according to the regulations prescribed by the Interstate Com merce Commission. (Shipper's Name) 73.412 Propellant explosives label for express ship ment, (a) Label for propellant explosives must be square measuring 4 inches on each side and bright red in color. Printing must be in black letters inside of a black-line border measuring 3H inches on each side and as shown in this section. (1) RED LABEL FOR PROPELLANT EXPLOSIVE FOR EXPRESS SHIPMENT (Reduced size) (Black printing on red) I1 -4 Inches 1I PROPELLANT EXPLOSIVES FOR EXPRESS SHIPMENT s HANDLE CAREFULLY KEEP FIRE AWAY This is to certify that the contents of this package are properly described by name and are packed and marked and are in proper con dition for transportation according to the regulations prescribed by the Interstate Com merce Commission. (Shipper's Name) WATER PCB SECTION 11 1408 (b) Explosives label for shipment of Propellant explo sives by air. (Reduced size) (Black printing on red) 73.414 Radioactive materials labels, (a) Labels for radio-active materials (class D poisons) Group I and Group II must be of diamond shape, white in color, and with each side 4 inches long. Printing must be in red letters inside of a red-line border measuring 3'A inches on each side, as shown in this section. LABEL FOR RADIOACTIVE MATERIALS GROUP I OR II (Reduced size) (Red printing on white) 73.413 Empty container label, (a) Labels for emp ty containers must be not less than 6 inches on each side, white in color, and printed in letters not less than 1 inch high in black ink and as shown in this section. WHITE LABEL FOR EMPTY CONTAINERS (Reduced size) (Black printing on white) 6 inches- NOTE. This label must be duly executed by the shipper and the number of radiation units must be shown. For purposes of these regulations 1 unit equals 1 miliroentgen per hour at 1 meter for hard gamma radiation or the amount of radiation which has the same effect on film as 1 mrhm or hard gamma rays of radium filtered by 'A inch of dead. (b) Labels for radioactive materials (class D poisons) Group III must be of diamond shape, white in color, and with each side 4 inches long. Printing must be in blue letters inside of a blue-line border measuring 3Yt inches on each side, and as shown in this section. LABEL FOR RADIOACTIVE MATERIALS GROUP III (Reduced size) (Blue printing on white) EMPTY WATER PCB-SD0000064117 1409 SHIPPING REGULATIONS (c) Label for Radioactive Materials Groups I and II for shipment by air. (Reduced size) Red and white with (red printing on white) SUPART I --SHIPPING INSTRUCTIONS 73.425 "Order-Notify," "C. O. D.," and "Stop-off" shipments, (a) Except on through bills of lading to a for eign country, shipments of explosives, class A and blast ing caps in any quantity must not be offered for trans portation by carriers by rail freight or rail express when consigned "to order notify" or "C.O.D." Shippers must not consign these shipments to themselves at points where they have not a resident representative. (b) Explosives, class A must not be offered for trans portation by carriers by rail freight or rail express sub ject to "stop-off" privileges en route for partial loading or unloading. 73.426 Cars containing lading which has been fumigated or treated with flammable liquids, flammable gases, poisonous liquids or solids, or poisonous gases, (a) Delivery to carrier of cars containing lading fumigated or treated with flammable liquid or flammable gas is prohibited until 48 hours have elapsed after such fumi gation or treatment, or until car has been ventilated so as to remove danger of fire or explosion due to the presence of flammable vapors. (b) Cars containing lading which has been fumigated or treated with poisonous liquid, solid, or gas, such as carbolic acid, liquid or solid, chlorpicrin, hydocyanic acid, methyl bromide, etc., must be placarded on each door or near thereto with placard reading as follows (for cleaning cars, see 74.568): (Reduced size) (Red lettering pn white cardboard) (1) Label for Radioactive Materials Group III for shipment by air. (Reduced size) Blue and white with (blue printing on white) ..................K) INCHES................. DANGER The lading of this car has been FUMIGATED or TREATED (Kama of poisonous liquid, solid, or gw) BEFORE UNLOADING, opes both doors asd GO HOT ENTER until ear U free of gas. REMOVE AH, POISONOUS MATERIAL before release of empty ear. 73.427 Shipping order and bill of lading description, (a) The shipper when offering for transportation by car riers by rail freight, rail express, highway, or water anv class A, class B, or class C explosive, flammable liquid, flammable solid, oxidizing material, corrosive liquid, com pressed gas, or poison, as defined by this part, must de scribe such article in the shipping order, bill of lading or other shipping paper by the snipping name used in 72.5 (see commodity list) and may add a further de scription not inconsistent therewith. Abbreviations must not be used. For shipments of blasting caps and/or electric blasting caps the shipper must, in addition, show the number of caps in the shipment. NOTE 1: In commodity list (72.5) shipping names are shown in roman, not italics: 73.428 Label or placard notation, (a) The shipping order, bill of lading or other shipping paper must also show thereon in connection with the entry of the article as prescribed in 73.427 of this part, the color or kind of label applied, and for cars containing such articles WATER PCB-SD0000064118 1451 INDEX TO SYNONYMS "B" blasting powder. See Explosives, low. Beeswax, yellow. See Beeswax. 1, 2 - Benzendiol. See Pyrocatechoi. 1, 3 - Benzendiol. See Resorcinol. Benzene carbonyl chloride. See Benzoyl chloride. Benzene diazoanilide. See beta-Diazoamido- benzol. Benzene diazonium chloride. See Diazobenzene chloride. Benzene diazonium chromate. See Diazobenzol chromate. Benzene diazonium nitrate. See Diazobenzene nitrate. I, 3-Benzene dicarbonitrile. See orthdDicyanobenzene. Benzene dicarboxylic acid. See Phthalic acid. 1,4-Benzenediol. See p-Hydroquinone. Benzene - 1, 3-diphenyl. See m-Ter phenyl. Benzene-1,4-diphenyl. See p-Terphenyl. 1,2,4, 5-Benzene tetracarboxyiic acid. See Pyromellitic acid. Benzene tetrachloride. See l, 2, 4, 5-Tetra- chlorobenzene. 1, 2, 3-Benzentriol. See Pyrogallol. Benzidine base. See Benzidine. Benzoate of soda. See Sodium benzoate. Benzoflex. See Ethylene glycol dibenzoate. Benzohydrol. See Benzhydrol. Benzoic acid anhydride. See Benzoic anhydride. Benzoic acid a-methyl benzyl ether. See a-Methyl benzyl benzoic acid. Benzoic aldehyde. See Benzaldehyde. Benzoic ether. See Ethyl benzoate. Benzol. See Benzene. 160* Benzol. See Naphtha (coal-tar), 1,2-Benzopyrone, See Coumarin. BenzosuLfimide. See Saccharin. trans-beta-Benzoyl acrylic acid. See beta-Benzoyl acrylic acid. Benzoyl hydroperoxide. See Perbenzoic acid. Benzylbenzene. See Diphenylmethane, Benzyl carbinol. See Phenethyl alcohol. Benzyl chlorocarbonate. See Benzyl chloro- formate. Benzyl dichloride. See Benzal chloride. Benzyl isoamyl ether. See Amyl benzyl ether. Berlin green. See Ferric ferricyanide. Betel. See Areca nut. cis-Bicyclo(2, 2, l)-5-heptene-2, 3-dicarboxylic acid dimethyl ester. See Dimethyl carbate, Biformyl. See Glyoxal. Bimethyl. See Ethane. Biphenyl. See Diphenyl, p-Biphenyl amine. See p-Aminodiphenyl. o-Biphenylene methane. See Fluorene, l -(4-Biphenylyloxy)-2 - propanol. See Propylene glycol-4-biphenyl ether, 1, 3-Bis(2-benzothiazolyl mercapto methyl) urea. See Di-(2-benzothiazyl-thiomethyl)-urea. 2, 2-Bis-(p-chlorophenyl)-1, 1 -di-chloroethane. See DDD. Bis-dimethylarsenic sulfide. See Cacodyl sulfide. Bis-dimethylthiocarbamyl sulfide. See Tetra- methylthiuram mono-sulfide, 2, 2-Bis-(p-fluorophenyl)-1,1,1 -trichloroethane. See DFDT, Bish, See Aconitum ferox, 3-3-Bis(p-hydroxyphenyl)-phthalide. See Phenolphthalein. 2, 2-Bis-(p-methoxyphenyl)-1,1,1 -trichloro- ethane. See Methoxychlor. Bis-o-methyl benzyl ether. See Methyl benzyl ether. Bismuth glance. See Bismuth trisulfide. m-Bismuthic acid. See Bismuth pentoxide, Bismuthine, See Hydrogen bismuthide. Bismuthnite. See Bismuth trisulfide. Bismuth oxycarbonate. See Bismuth carbonate, basic. Bismutospherite. See Bismuth carbonate, basic. Bis(trifluoromethyl) benzene. See Xylene hexa fluoride. Bitter apple. See Codocynth, Bitter cucumber. See Codocynth. Bitter wood tree. See Quassia. Bitumen, See Asphalt. Black blasting powder. See Explosives, low, Black lead. See Graphite, Black precipitate. See Mercurous nitrate, ammoniated. Blasting oil. See Nitrcglycerin. Blistering beetles, See Cantharides, Blistering flies. See Cantharide9, Blue stone. See Copper sulfate. Blue vitriol. See Copper sulfate. Bone ash. See Calcium phosphate, tribasic. Boracic acid. See Boric acid. Boric acetic anhydride. See Boron acetate, o-Boric acid. See Boric acid, Borneo camphor. See d-Borneol, Borneol thiocyanoacetate. See Bornyl thiocyanoacetate, Borobutane. See Dihydrotetraborane; Tetraborane. Boroethane. See Diborane. Boron bromide. See Boron tribromide. Boron chloride. See Boron trichloride. Boron ethyl. See Boron triethyl. Boron fluoride. See Boron trifluoride. Boron methyl. See Boron trimethyl. Bottle gas. See Liquefied hydrocarbon gas. Brass powder. See Brass scrapings, Brazil wax. See Carnauba wax, . Breithauptite. See Nickel antimonide. Brimstone. See Sulfur. British anti-Lewisite. See 2, 3-Dimercapto-1 - propanol, Bromochloromethane. See Chlorobromomethane. Bromellete. See Beryllium oxide. Bromic ether. See Ethyl bromide. Bromine analog of DDT. See 1-Trichloro-2, 2-bis(p-bromophenyl) ethane. Bromine cyanide. See Cyanogen bromide. o-Bromoaniline. See Bromoaniline. Bromoazide. See Bromine azide. 1 -Bromobutane. See Butyl bromide. 1 -Bromo-2-chloroethane. See Ethylene chlorobromide. Bromochloromethane. See Methylene chlorobromide. ar-Bromo cumene. See Bromoisopropyl benzene. Bromoethane. See Ethyl bromide. Bromoethene. See Vinyl bromide. Bromoethylene. See Vinyl bromide, Bromoethyne. See Bromoacetylene, Bromomethane. See Methyl bromide, o-Bromo - 2-phenyiacetonitrile, See Bromo- benzyl cyanide. 1 -Bromopropane. See Propyl bromide. Bromotoluene. See Benzyl bromide. Brunswick green. See Copper oxychloride. Bunsenite. See Nickel monoxide. Burnt lime. See Calcium oxide. Butadiene. See Diacetylene. Butadiyne. See Diacetylene. Butanal, See Butyraldehyde. Butanal oxime. See Butyraldoxime. n-Butane. See Butane. I, 4-Butane dicarboxylic acid. See Adipic acid. Butanedinitrile. See Succinonitrile. Butanedioic acid. See Succinic acid. Butanedioic anhydride. See Succinic anhydride. Butanediol. See 1,4-Butanediol, 1,3-Butanediol, See 1,3-Butylene glycol. WATER PCB-SD0000064119 Monsanto Ciiumxcai, CoMRAIW y3 fffi 1 mi J&Miui SYUACUAR Q, jfKW 'WH January 30,. 1959 Kr. D . A . ' p r' "Tti, rV)'^-i 1 nr Agont Ri*y "in ' ' V*' 1 i ' 11 ^ u ~ , tlu.rs^r'i , !' ' : r 'I h* t" Pi\"n' Conf ("in ;n tr<3nt l on 1 /?9 , wo will rlan to ship your tank car ire-1 c.- 1?4H so that Lt will arrive your plant between Robr"v.y 13 and ]0. The car wLll be "trip leased" to you .o 111 < * will bo able to handle unloading the oar etc. at oonr-vi 1-?' Ij possible without having demurrage . occur. . . , . jus1 as -wr n f,* t'>-> cs- mov*n forward from our plant we will l v-* you b ! > r !c ' 'vi t / u . M on s . Wo will use car 0ATX 32l<.54, wh 1 vii* ' <i ' ' ^vll 'ip-, cup having an outlet of two-inches, and <-,-'nu > -> n, coil 1 n \ 61 - bo lit of standard pipe threads. 7 oje fin.-r `.'C. j -u Will be Interested In the attached Informa tion wh1 .-h .ovu'i M\o handling and unloading procedures roccn- icervled fi: Our peer' f < *' hot In cleaning the filters and in encounter ing liet A' oc'i> r -'7iks jor,workmen should voar an approved organic vro.- -sctrldge respirator, such as supplied by Htno Safety Apri l.an s Compsny under their catalog numbers CRlii>V3h boo"ing oup. cval by US Bureau of Minos 201. An alter nate mask wc M b tho type tied Into air line to feed air Into fac-! i>if - .ucM ps found In Mine Safety Appllanoe1 a bul l o 11 n Cr.-P". Mine fe t j * s . ms In office Is located at 201 North hcl-.i-ioV Avenue, Pittsburgh, Pa. A,r> additional rrereutton would be to carry on this filter v. Leaning opera* t on with an adequate hooded vent system to protMct c*th*r 'r.f.loyees In the area. I am sure that your p >ep1n will V' 1u* orosted In the attached Information covering Junoktolot.1 us; vk' toxicological characterlstloi of handling DEPOSITION EXHIBIT iI U CH ?-ci7 ECTED MATERIAL-Reynolds v Aetna NY RLD-0770380 WATER_PCB-SD0000064120 Physical Properties Of ^AROCLORS AROCLOR * 1242 AROCLOR' 1262 AROCLOR' 1248 AROCLOR # 1269 AROCLOR' 1254 AROCLOR' 4465 AROCLOR ' 2565 Manufactured by MSmmE OtmTeii Gmp&ji$p t Nsw FnncjjGS Clmbad--Kmia^iiii--Uaaral-Undon Attachment 3-^ HONS 08123? WATER PCB-SD0000064121 The iAroclors HE Aroclors have won a prominent place in the field of syn thetics with unique properties to fill requirements not met quite perfectly by materials heretofore available. They have found wide usefulness in fields where their properties are of especial value. Following' is a description of the properties of seven Aroclors. each of which is representative of a series. There are other Aroclors with slightly different characteristics in each of these series. A study of this brief description will suggest means of em ploying the Aroclor in perfecting still other products, develop ment of which has been delayed by the lack of a material that exactly fulfills particular requirements. zA Description of the Aroclors The Aroclors vary from water-white mobile oils and pale yellow viscous oils to light amber resins and opaque crystalline solids. For each of these light-colored Aroclors there is a cor responding gray or brown-black grade. The Aroclors are produced exclusively by Monsanto Chem ical Company. Non-Flammability The viscous Aroclor oils and the resins do not support com bustion when heated alone even at their boiling points--temperatures above 350*C. Most of the Aroclors flux readily with resin ous and pitch-like materials to give a product having a decreased fire hazard. When incorporated in nitrocellulose films the Aro clors retard the rate of burning. HONS 081238 WATER PCB-SD0000064122 Electrical Properties The Arodors have extremely interesting1 electrical character istics; high dielectric constant, resistivity and dielectric strength, and low power factor. Solubility The Aroclor oils and resins are easily soluble in most of the common organic solvents and drying oils. The hard crystalline materials are in general less soluble than the Aroclor oils or resins. All Aroclors are insoluble in water. For more complete informa tion see the attached table. Compatibility data on Aroclors in nitrocellulose lacquers will be sent on request. Adhesiveness The Aroclor resins adhere strongly to smooth surfaces -- to glass and metal or to smooth varnished or lacquered surfaces. The softer Aroclors are suggested for difficult adhesive prob lems where a flexible non-drying waterproof material is necessary. The Aroclor adhesives are thermoplastic; are readily applied hot without solvent; do not require high temperatures for easy application, and are set immediately upon cooling. Thermoplasticity The Arodors are permanently thermoplastic. They appar ently undergo no condensation or hardening upon repeated melt ing and cooling. The clear Aroclor resins are now being pro duced with softening points up to 110'C. The opaque crystalline solids are produced with initial melting points up to approxi mately 180* C. Non-Drying Properties The Aroclors arc non-drying, and when they are exposed to the air, even in thin films, no noticeable oxidation or hardening takes place. However, when used as ingredients of lacquers, they do not retard the rate of drying of the lacquer films. Quick drying varnishes and paints may be made with Aroclor resins. Vaporization Loss The Aroclors have low vaporization losses as shown in the data in the table of physical properties. MOHS 081239 WATER PCB-SD0000064123 Table of `Physical Properties of the roclors MUNi O U i^ u WATER PCB-SD0000064124 Toxicity Experimental work in animals shows that prolonged exposure to Aroclor vapors evolved at high temperatures or by repeated oral ingestion will lead to systemic toxic effects. Repeated bodily contact with the liquid Aroclors may lead to an acne-form skin eruption. Suitable draft ventilation to control the vapors evolved at ele vated temperatures, as well as protection by suitable garments from extensive bodily contact with the liquid Aroclors, should prevent any untoward effect. Odor and Taste The solid Aroclor resins are almost without odor and taste at ordinary temperatures. Stability The Aroclors are remarkably resistant to the action of either hydrolysing agents or high temperature. They are not affected by boiling with sodium hydroxide solution. Because of their sta bility to heat, the Aroclors are useful heat-transfer media. Aroclor 1254 and particularly the less viscous Aroclor 1243 are recom mended for this purpose because they may be heated at tempera ture up to 325'C. (617*F.) in a closed system for long periods without appreciable decomposition and are at the same time non flammable. Action on Metals The Aroclors are non-corrosive. Mild steel exposed to the action of Aroclor 1254 or Aroclor 1248 in a closed system at 325*C. (617*F.) for 848 hours showed no pitting and the corrosion rate, as measured in inches of penetration per year, was 0.0021. Water and Moisture Proofness The Aroclors are water proof. When impregnated into orous rigid bodies they are effective water and moisture proofen. pecial Aroclor compounds are available for moisture-proofing such articles as paper and radio resistors and for water-proofing articles such as abrasive wheels. STANDARD CONTAINERS 50 got. Drum r Aroclor------------------------ ------------------- ---- --- 1241 500 lbs. net Ameior ------------------------------ ------ --------Aroclor.................. .................. ............... ........... 300 lbs. net 300 lbs. net Aroclor_________________________ _________ l*t 300 lbs. net Aroclor---------------------------------------------------Aroclor......... .......................... ........................... WM 500 lbs. net 2586---drums, 398 lbs. to 428 lbs. net. Arorlor................................. .... ................. 1269--hags,200 lbs. net. barrels, 400 lbs. net. HONS 081241 WATER PCB-SD0000064125 Solubility of the zAroclors In Various Solvents (Fifurej Represent Creme ol Aroclor per 100 cc. Solvent) Tvr* or Solvent Aaocio* Hit Colo 1 iOT Chtoro Dtnvsiivts Chloroform_______ __ ........ S` Carbon Tetrachloride..... ......... S Ethylen* Dichloride.. .... ......... S Trichloro Ethane--------- ........ Trieholoro Ethylene___ S s Tetra Chloro Mixed Amyl Ethane -- Chloride*..- ___ ___ s s Mono CWorobetuene-.... . ... .. s s* s s s s s 3 S Ktimes ActionS S Aeoctot I2J4 Coon Hot S ss s s s s s sS' s s s s s s SS Aldehydes Formaldehyde (40%)------------- I* FurfuralS I* I* [ sss A mints Aniline____________________ S 3 Pyridine----------------------------- 13l.5<g30*C. UOtgW'C. S S 48@100*C. Drying Oils Tung Oil _____ S LmaeedOil_______ =____ 3 s s ss Acids Aeatfc Acid_ _ -- S 0WeAe*d-------------------. . S ss 3 S Mtesdkmmm Nfere Sesansa------------Carta Dftelfkk______ _____ ...__ S s 3 S s s Water _. I II Not*: S tifmfm very tolubk or mteibk in ill proportions. I rigntfiei iasoluW. P.S. lignifie* partially aolubt*. s s ss s s 1 HONS 0812^2 WATER PCB-SD0000064126 Solubility of the <iAroclors In Various Solvents (Figures Repreaent Grama of Aroelor per 100 cc. Solvent) Trrt or SotVint Aroclob 1241 Cold Hot Aroclor 1254 Cold Hot Hydrocarbon! Minrrtl Spirits........................ S* Goline___ ___________ --. S Kerosene______________ ___ S Paraffin...------ ------------------ -- Bentene.___ _______________ S Toluene...____ ____________ S Xylene____ _________ -- S Turpentine ........................ .... S Pine Oil____________ ______ S S* s s S@B0*C. s s s s 3 S` S S -- s s s s s s* s s S<S50`C. s s s s s Hydrory Dtrrvatkti Methyl Alcohol_____________ 4*.5<at,C. Ethyl Alcohol (Formula 3A)... Normal Butyl Alcohol........... S Amyl Alcohol-------------- ------- 3 Glycerine------------------------ .-- I* 20* Phenol____________ ___ 194@30*C. Kg.stseo'C. io.o@?oc. s s 1 sott'C. ISfffiWC. ltxfsrc. s s 1 P.S.* 2*.W'6J,C. 28 @T*C. S s I Slowly Soluble Ethm Ethyl Ether------------------------- S s s S Ceiloaolve Acetate-------------- -- S s s S Ethrr Alcohtit Celloaoive--------------------------- S Carbltol*431*C. p-p' Dihydroxy Ethyl Ether-- 18.!<M*C. s 30T@src. 19@9*C. s 17S<SJSC. 8@S0*C. S tS9<S *C. 1<X100*C. E-flirt Castor Oili------------- 3 ssS Methyl Acetate----------------------S sss Ethyl Acetate-----------------------S sss Botyi Acetate----------------------- S s s s AkjjH Acetal^---------------------- 3 sss Ethyl Lactate----------------------- S sss Diethyl Phshateta-------------------S ss3 Dibatyl Phthalate---------- ------- S s s S Trkfetyl Phosphate_________ S sss Cotton Seed Oil_____________ S ss s Ethykae Glycol DUeetste_____ S s s s HONS 0812A3 WATER PCB-SD0000064127 / Monsanto VI Z O rmr VJLVM. WATER PCB-SD0000064128 Ste. U. S P- Off. <Oy* 2 O WATER_PCB-SD0000064129 ................................. has been used successfully since 1941 as a liquid phase heal transfer medium al atmospheric pressure and temperatures up to 600*F. The compound, essentially tetraddorohiphenyf, is a fire-resistant and non corrosive liquid, which does not crystallize at low temperatures. Handled properly, in well-designed fenced circulation heat exchangers which avoid localized overheating damage, the fluid gives satisfactory continuous service for many years without Most significant, Aroclor 1248 is practically non-flammable. In one in stallation of record, a ruptured pipe spewed the hot fluid into gas flames: the fluid failed to ignite! For general heat transfer, Aroclor 1248 has several other important qualities: it is highly mobile and can he readily pumped at temperatwes as km as SOT. If cooling is necessary, the heat transfer fluid can be put through a water cooler and used as a coolant. Aroclor 1248 transfers heat (up to 000*F.) as a liquid. This liquid phase heat transfer makes it unnecessary to use the expensive pressurized equipment required by a heat transfer medium that operates as a vapor. Aroclor 1248 operates safely and efficiently with gas-fired, oil-fired, or electrical heat sources. It is used successfully in the following types of applications .... MOhi ClWbH WATER PCB-SD0000064130 *fW* U s Far- Off- P*9***^ eijaipaMni, fMrtknlariy for reacting flamonable materials Coofcing el e&yd resssw, vansis&es, wares Plastics --a**wg_ otadi^, 0 lubktf pgcwhg m Bmh& mgfesM Fwd pwwiafc fachslhg potato dup oxt dou(boat frying at vegetable oils Fabrication of BraginaMro aad alusaimas Saosrey-camb structures for aircraft Jadfeoct beating it dyertaff smo'rfecture H--tirBg of corrugating rolls ladfcect beatiag of dfstiBatioa ergaipaasrst Sagnoifacatioa of fats - CnScrmfeig ureas frafliregaeHau and IreaftaaSiMiyr of fblUO artanJl I HONS Q7996S WATER PCB-SD0000064131 Afessfete feaatg. g./t Ifessese? te./kr./)'. It/f./ll Spec. VeSaas. al/g. TABLE *Capi* 1.44 30 1.41 (0 1-37 121 1.17 117.0 175 47 0.9) 0.4/ 0.0571 0.0564 0.0555 0.0534* 100 200 MO 30 0 200 m30 0 m100 *00517 *EjtnpitoM Dels tm ft 140 212 397 577 ft 140 212 392 572 ft 140 212 392 572 o.ess 0709 0771 0 787 0.160 30 0 100 TOO 300 ft 140 212 392 572 connnuio HUNS 0?S)S)66 j WATER PCB-SD0000064132 (Tabic 1, U Spec. Ht aL/g./*C. Vapor Pressure. ml 1% Dssttiabos Stage. AST88 0-20 Flash Pi. Cteedaml Opes Ct@. ASTH 0 92-45 Fire PL. OevetoiMl Opts Cep, ASTN. 052-45 Ptrnr Pi. ASTM. 0 97 Awrage CoolSbeal o! iipssasoss cc./ec./*f. 0.2S3 0297 -SS 6255 ' 0.08037 0.16 22 18.0 350.0 so 100 2m 3 37.8 100 150 2m 300 345-38S 122 212 392 572 100 212 302 392 572 652-725 193 196 379 384 done -7 19.4 0.00037 0.00038 0.00041 0.00044 0.00047 0.00052 --17.8 to 37J 37.81093.3 93.3 to 149 149 lo 204 204 lo260 260 to 316 OlolOO 100 lo 290 200 to 300 300 to 400 400to500 5001 60S PHYSICAL CHARACTERISTICS of AROCLOR 1248 A eoaspiste Issewledge of the physical f heat transfer media is li|Uy nmwimtial to their latirfectery application m a heat exchanger. These physical constants have a major beeriag on the erguapraMa* design, As msatcBCTBta, and its opcratna. The Mewing Bgrnes and c&arts |*re Inafe physical d* am Ard<w i48. KGhS 07VS6? WATER PCB-SD0000064133 OENSITT OF AROCLOR ms (Tap an, SiaVcB. ft.; WiWaiim na, pmjad.) nRSirr%s./cB.n B ID TIMKRATUIC f.' J. 3MJM3JH31 FiRurt I 1.100 mmmmmmPimmmm mmnmni oiNSirv pm./mL ^IIBBSSRIS, -iwmmmmmwmmm' HUN* C7SS>6d WATER PCB-SD0000064134 yisoosm or aboquosi vm Fifiw* 2 6 HUNS 0 7996$ WATER PCB-SD0000064135 VISCOSITY Off* AffSOCLOR IS4 (SayWfo UrinjffBinB SoadM VISCOSITY, SAYSOLT UNlYtMM. SICONOS rigw 3 umiunist kcbccs famahcit MUfcS 70 WATER PCB-SD0000064136 HEAT CAPACITY rad Its BUtlon*hlp Co Donolty Systematic aron exist in the various accepted pro cedures for making specific heat determinationsConsequeatly values may vary depending upon the procedure used. In practical operation, H frequently appears that the values for Aroclor 1248 shown in Figure 4 are somewhat low. Consequently, although these values have been accurately determined, they may be regarded as conservative. When comparing the specific heat values of Aroclor 1248 with corresponding values for other heat transfer fluids, it is important to note that the density of Aroclor 1248 is much higher, relatively, than the density of other liquids used for heat transfer. Accord ingly, when comparison of heat capacity is made on a vohane beats (which a most pertinent in equipment design and efficient operation) the heat capacity of Aroclor 1248 shows itself to better advantage than by direct comparison of specific heat values. Although specific heat values are important, they represent only one of several important constants that enter into the dotations for calculating over all heat transfer efficiency. Through the use of these conservative heat capacity values, it is possible that equipment engi neered from such data might be slightly "over designed.' This may be one of the factors that accounts for the exceptionally good operating performance of a number of highly successful commercial applications. MCNS 079971 WATER PCB-SD0000064137 I. 3my3<w3J SPECIFIC HEAT OF AROCLOR 1248 (Sta. per b. per 4pw f.) ESEQBBRBSE^mi mmsmmmmmmmTmmm SHSOTKltMnBBraiSraB* ___________ !WBK9BC!MBemRB^^E3 imBBBRKSIBIBORBRBiiRiiiS^RB. _________JR*?gSR mrnmmm&mmmmmmmmmmmmw ` fNmMMaHnSHBHI QRBBBEBBBBRiraBIBBa . ,JOTBRB2BEP3**35SJa ISjSu^SS mmmmmmmm ipjli wmtv* m wmMfQ&mmmmmiFSR sKuanaR^iRcsBRf m^ r,)t 01/ OJfc 0* 0 3* 0 3) 0 37 o)t o jo on %n on I" a(tirr 4 SttCIflC NCAr 6l -ft n HUNS 07S9 72 WATER PCB-SD0000064138 Twspmtw *C. f. 0 32 10 50 38 100 66 ISO 93 200 121 250 149 300 177 3S0 204 460 232 4S0 ------------- m 500 288 550 316 600 TABLE II HEAT CONTENT of Aroolor 1248 Specifc Bast Bts./lb./f. 269 272 2m .288 795 MS 31! 319 .327 335 343 .351 359 Heat Content Btu./lb. 0.0 485 18.65 32.85 47.43 62 38 77.58 93.48 109.66 12621 14317 160.52 178.27 HUNS 0 79973 WATER PCB-SD0000064139 THERMAL CONDUCTIVITY and VISCOSITY The tknMl conductivity values of Aroclor 1246 are shown in Figure 5. The curve shows this value over the operating temperature range, from 50*F. to00*F.. of Aroclor 1248. As freshly charged into a beat exchanger. Aroclor 1248 has an initial viscosity of 74 (S.U.S.) at 130*F. which corresponds to a viscosity of approxi mately 5000 (S.U.S.) at 50"F. - which temperature is assumed for practical purposes to he about the limit at which Aroclor 1246 can be conveniently pumped with a centrifugal pump The following table shows a comparison of the initial viscosity and the viscosity after a year's con tinuous service at 800*F. in a LaMont forced circu lation beater: Wnw Smufic Gravity, fit* C. Vtaamly. $. U. S. at l*f. CdariasUqvO 1410 0W& IffM* 1.410 os Although Aroclor 1248 tends to darken in use. this darkening is not harmful and does not indicate decomposition. In actual use at Monsanto, it has not been found necessary to replace the fluid after seven years of continuous use; additional fluid is only added as necessary to make up spills or leaks. In Figure 8. the horizontal line indicating vis cosity limit of pumpability at 50F. shows that the rate of viscosity increase based on a year's continuous service should permit Aroclor 1248 to serve approxi mately four years before increased viscosity may inter fere with its pumpability when cold. In practice. Aroclor 1248 has given satisfactory prmipahility for much longer periods. A simple S.U.S viscosity deter mination by the ASTM-D-88 method can be used for periodic checks on the fluid HUNS 079979 11 WATER PCB-SD0000064140 thermal ooNDuenvrrs of aroclor me 5 12 HCNS 0 WATER PCB-SD0000064141 viscosity. satsckj l Titsccohos, EXPECTED MINIMUM SERVICE LIFE IN A FORCED CIRCULATION HEATER RUNS 0?SS>?6 WATER PCB-SD0000064142 STABILITY Arodor 1248 ix an extremely stable chemical com pound. Tests over long periods of time have shown that 8B*F. is a safe maximum temperature for continuous operation la hostess that are properly designed and operated to dimfeate intense, localized overheating. At this temperature the fluid b 52*F. below the initial temperature of its boiling range, and consequently re mains a liquid. Near its boiling point Arodor 1248 leads to dehydrohalogenate to a very slight but measurable degree. If this occurs as a result of accidental over heating. the small amount of HC1 gas evolved tends to pass through the vent tank without harm to the equipment provided that the system is dry. Experimental observations using ideally-suited beat exchangers operating at a temperature of 050*F. with imposed nitrogen pressures of 30 and 70 psig. showed that application of pressure did not prevent this small amount of thermal decomposition, which also occurs when the material is heated above at atmospheric pressure. When heated continuously at 650*F. under nitrogen pressure a gradual increase in the viscosity of the fluid occurs indicating that its service life would be limited to about 6 months to one year. Results of operating at <300"F.. however, with out imposed nitrogen pressure indicate Aroclos 1248 can be heated continuously at this temperature for about 4 years before any viscosity increase could be expected to interfere with its pumpebility at 50" F. which is slightly below normal room temperatxses. Provision should be made to prevent water contamination of the system. If the system becomes contaminated with water, any HC1 liberated by local ized overheating may dissolve in the water film which will float on top of Aroclor 1248 in the expansion tsni. The acidic solution thus formed can cause common. It is recommended that moisture be eliminated from the expansion tank by installing a moisture trap or by sealing the tank and applying 15 to 30 psig. of nitrogen gas. With exception of the expansion tank, the system should be kept full of Aroclor 1248 at all times to pre vent formation of air pockets where moisture may condense when the system cools off between periods of operation. Many years of practical operating experience have shown that Aroclor 1248 b virtually non-corrosive to valves, piping, tanks, and jackets made of cast steel, steel, or stainless steel. In actual use. brass valves have been used satisfactorily. HONS 07997? WATER PCB-SD0000064143 T SAFETY of OPERATION Arocior 1248 cu be considered a non-flammable liquid; no fire point is obtained by the Cleveland Open Cup method oo heating to its boiling point (850*F.). The spontaneous ignition temperature**' is 1^88'F. In actual use. the following reported accident in a heating system demonstrates the fire resistance of Arocior 1248 and the freedom it offers from the hazard of fire propagation. An operators failure to start the circulation pump when the gas heater was on resulted in excessive coil temperatures. The tine containing Arocior 1248 sagged into the fire chamber. A wekJ rup tured and Arocior 1248 poured into the red-hot fire chamber in contact with the flame. Dense smoke end fumes arose from the heater but there was no external fire. After the gas flame was cut off, the smoking *tops*S- Insurance authorities allow the use of Arocior 1248 heaters in many locations with a minimum of protection. No fire walls are required to isolate the heaters. Arocior 1248 has a low vapor pressure, in sys tems that employ a vented expansion tank, the loss due to evaporation is not measurable. If Arocior 1248 in the expansion tank would reach a temperature of 208*F., the vapor pressure of the fluid would be only 1 mm. of Hg. SAFETff OF HANDLING Arocior 1248 is an inert, unreactive liquid. If it is spilled on the skin, there are no noticeable ill effects. It is advisable, however, to wash the skin with soap and water after contact. A skin bum resulting from accidental contact with hot Arocior 1248 should be treated in the tiorm.il manner for hot oil bums. Any liquid adhering to the burned area need not be removed immediately unless treatment of the bum demands it. if (lie burn must be cleaned, soap and water or repeated washings with a vegetable oil (olive oil) may be used. The vapors emitted by Arocior 1248 heated to elevated temperatures are injuriom on prolonged ex posure and should not be breathed, ft is indicated th.it 2.0 mg. of Arocior 1248 per cubic meter of air is the maximum safe amount permissible in workrooms. In oomiractcia! heat transfer installations, it is presumed that Arocior 1248 will be used in a closed system free from leaks. Accordingly, there should be little or nu opportunity far workers to come in contact with Arocior 1248 vapors. A habUogngihjr appears oa page 32. HGhS 079938 WATER PCB-SD0000064144 design features HEATER T&e most significant (actor to remember when selecting or de- ' signing a heat exchanger for Arodor 1248 use is this: Arodor 1248 trmsfers heat whale in Kquirl form, at the maximum recommended temperature of 600F. for continuom opefatkm, which is approximately 50* F. below the boiling point. Corac- Arodor 1248 does not form vapor to accelerate convection ctoculatfcm. Ordinary fee-tube or water-tube heaters which depend solely upon oomtdion perform satisfactorily only at relatively low temperatures. When temperatures of 5(W-0OO*F\ are rwpiirrd. a forced circu lation type heater is recommended. A satisfactory tvpe of Itenter deMgri would consist of a specified number of tubes in gnralM. pro|**rly onhail to provide a high velocity fluid flow of S to 10 fort per second. Tlioc should be spaced tv permit uniform heat absorption throughout (hot enttov length. A typical construction is shown in Figure 7. In its fabrication, the heater should be ASME Code all-welded construction, conformmg to state and local ordinances. Tube joints, which in an ordinary sfieam heater would be the expanded type, must be sealwelded to prewat leakage. All connections larger than V should be flanged connections, since ordinary threaded pipe connection is not suited for Arodor 1248 service. Spiral-wound stainless steel and asbestos com bination is recommended for sealing joints and plugs. Drain valves should be installed at all low points on the heater and the valves must conform with ASME requirements for "blow down' valves. MCMS 079979 WATER PCB-SD0000064145 Since a beater operating on Aroclor 1248 is completely filled with liquid, costly liquid-level controls and condensate return gapes, fittings, traps, etc. are completely eliminated. Heaters can be provided with any desired kind of firing. Portable and small size stationary units are frequently elec trically heated; larger units may be gas- or oil-fired. In installa tions where an ogien flame presents a fire hazard, to meet iasraance requirements the beater may be installed in a sepa rate building with pigling carrying the hot Aroclor 1248 to the point of use. Properly constructed transmission pipes may ex tend for hundreds of feet. HEATEB EFFICIENCY Forced circulation heaters with integral economizers will show an efficiency of from 75 to 80%. Heaters of the straight con nector type show efficiencies of 65 to 75%, depending upon (he discharge temperatures. HEATER CAPACITIES Heaters using Aroclor 1248 (gas- or oil-fired) are available m output cagncsties ranging from agrproaimateiy 250.000 Btu. per hour to large units rated over 10 million Btu. per hour. A heat flux density (or heat energy input) of ajiproaimatcly 5.000 Btu. pet hour gier square foot of tube surface ts regarded as satisfactory. For lower output rate, electrically-heated units arcfavored. employing watt densities of 12 to 16 watts |irr square inch of element area. HUN5 02V9BO 17 WATER PCB-SD0000064146 THE USERS Tbs "nm* or el dx beet at the peeet el peeceswng cm be era? rp el SmoBAbs pM, pletera, fmtrtBl fc*b, or csib el etad e t&e pewmm hrapeesuB era the Arader BS49 eeMuw enceeds 59 prig. In Iirwiwi 1SSU iVU WWW M0*0 lti HUNS 07Wb l WATER PCB-SD0000064147 THE PUMP For most systems, cast-steel centrifugal pumps with water- cooled stuffing box and bearings are to be preferred. However, high temperature centrifugal pumps with mechanical seals are now available which give excelfeet performance. In some in stallations, immersion pumps have been used. Whatever type is selected, the pump capacity and pressure head must be sufficient to circulate the volume of fluid at the rate the particular installation demsiMls. ' To avoid shaft trouble and leakage at the seals, it is important to provide adequate expansion joints and to support the piping in a manner to avoid stresses on the body of the pump. Direct-connection pumps (kiven by 1.750 rpm. motors are most commonly used. Each pump should be fitted with a positive differential control to switch off the burner in case of pump failure. When a new system is first put into operation, a slight leakage may be noticed at the pump. It is not advisable to tighten the pump gland, however, until the system has heated up close to the temperature of operation. PIPING LAYOUT The most important factors in the piping layout for Aroclor 1248 systems are fa) proper sizing for the required flow rate and (b) minimizing pressure drop. Because the sys tem will undergo temperature changes, adequate expansion joints and loops to relieve expansion and contraction stress are Preferably, all pipe lines and connections should be of extra heavy or Schedule 80 welded construction meeting A.S.M.E. requirements. However. Schedule 40 welded pipe construction is often employed. Flanged joints should be used as sparingly as possible to minimize potential leak points. All valves and controls should be cast steel construction with stainless steel seats. Pipe lines should be well insulated and those exposed to temperatures below 70'F. should be steam jacketed. All high points in the piping system should be provided with vent valves; all low points should have drain corniest ions. Piping should be well anchored at frequent intervals, particu larly near expansion loops, to prevent vibrations. Figure 9 shows a typical piping diagram that illustrates the important features of an Aroclor 1248 piping system. These may he varied to suit the installation. MOWS Q199UZ is WATER PCB-SD0000064148 THE EXPANSION TANK The npnuion tank should be large enough to accom modate about 20% of the total volume of the entire system, including the fluid content of the heater, piping, and all heatusers. Tank should be sized to be %-fult when system is cooled to 70 F. and %-full when system la at maximum operating tem- l>eraturc. Expansion tank should be fitted with a sight glass at the "full* range and a float-operated low-level switch to shut off burner in case of accidental fluid loss in the system. The expansion tank should be mounted on a platform high enough to support the liquid reservoir at least six feet higher than the highest point in the piping system. THE FEED and DRAIN PUMP To eliminate manual filling and draining of the heating system, it is recommended that a small 2-to-S gpm. positive displacement pump be installed at some convenient point to pump the Aroclor 1248 into or out of the system. CONTROLS Controls for heating systems using Aroclor 1248 should i>e installed both on the heater itself and on the heat-using units. A wide variety of thermo-operating controls are available and any reliable standard equipment is satisfactory. Heater controls should be installed to regulate the firing mechanism in direct proportion to the required output. These controls should increase or decrease the heat in-put to main tain the Aroclor 1248 at the operating temperature required by the heat-demand of the user. Small units may be operated satisfactorily by relatively simple "on-off* Off "high-low" con trollers; larger units may operate more uniformly if equipped with modulating temperature controls. User Controls should be installed to regulate the flow of the heat transfer fluid in direct proportion to the heat-con sumption of the heat-using equipment. In a multiple-user sys tem. separate controls should be installed on each consuming unit, to assure the proper heat-delivery. Safety Controls. In addition to activating continls. the heater must also be fitted with the proper safety cunlioh to meet the A.S.M.E. requirements. Safety controls should include: I. A high kmpnalurr limit control operating .l (hr heater outlet to shut oil the burner m (Ik* etent of an ftcosi*e tcn^rieluir me S. A suitable low-limit tm^kcraturc umlrol to hold the liumrr at low fke until the Aim ! I24A in the system reaches a te>pera(w<lesel of The low limit temperature control is essential I>cc"uisc the viscosity of Aroclor 1248 is rather high at norma! room tem perature. To avoid localized overheating upon start-tip, it ts not advisable to apply full heat from the burner until all the fluid in the system has attained a viscosity that allows good flow ami unimpeded circulation. Cold start-ups require slow up-hcats Burners should be equipped with automatic ignition controls lad flame failure controls. In wide-range firing opera tions, an over-fire draft control will increase the economy uf operation. Induced draft fans are another factor which should be considered as a means of avoiding the expense of high chimneys. Where they are needed through<*it the system, good quality recording or indicating gauges should be installed COOLING EQUIPMENT Where fast reduction of temperature is required, suitable air- or water-cooling installations may be used. If the cooler is to be a water-type unit, it is suggested that stainless steel tubing be used for the coils to avoid corrosion on the water side If a cooler is installed in the system, low temgierature limit con trols should also be installed to avoid excessive cooling that might raise the viscosity to the point of impeding the circulation in the system. hGN$ 0 WATER PCB-SD0000064149 FILTERING EQUIPMENT Whm heatmg systems operated on Arodor 1248 are ran continuously near the lecoauDondeil Mdrani temperature of operation (flOO'F-X ft Is advisable to provide a titering device that can be attached ft the drain line of the storage tank. In this way discrete pastadcs of dlst that may get mto the system can be filtered out peraodacaliy. Thte b an advisable maintenance step since it will eliminate the danger of dirt clogging the valve seats or lodging in pasts of the control mechanisms. A small portable Stef such as those manufactured by HonanCraoe CosparaOoa (Lebanon, Ind) or Spottier Manu facturing Company (Muttdelate, 111.) is quite satisfactory. CONNECTIONS aa4 GASKETS To minimize the poreiMUty of Arodor leakage, welded rather than threaded screw connectloas should he used. All connections K-mch and over should be of the flanged type, fastened with alloy bolts; spiraJ-wound gaskets of corrugated stainless steel and asbestos should be nsed with flanged con nections. For three-inch lines, 300 pound flanges fitted with eight three-quarter inch holts should he employed. As a joint compound, a product like ~Q~ Seal* has been found useful. In all cases, steel connectors are recommended for all instruments and controls. TESTING THE ST8TBM When a new system has been installed it is essential to test for leaks. Testing with air should be avoided because of hazard of rupturing pipes or jackets. Testing with water is not recom mended because at is difficult to remove residual moisture from the system which should be kept dry. Halogen Testing for leaks Is the recommended pro cedure. Introduce one pound of Freon F-12 or F-22 for each fifty cubic feet of volume of the heater and sys tem. Carefully iatroduce air not exceeding 10 psig. of pressure. With up to 10 psig- of air pressure, the con centration of Freon will be sufficient to give sensitive lest results. Attach a halide torch to an acetylene tank and light it. Using the % inch hose as a probe, explore for leaks by passing the end of the hose along seams ami joints. If a leak is present, the escaping Freon will be drawn " A pnxlaii i>4 Quh.klcy Co . Bnc.. 5fl W B 15th St.. New York. N. Y into the acetylene flame turning it green. A large leak will produce a violet color. CLEANING THE SYSTEM After testing for leaks and making any required repairs, the system must then be cleaned. A new system will contain dirt, mill scale and other foreign particles. Unless removed, these particles will be sus pended by the Arodor. They may then lodge in valves, con trols and mechanical equipment and cause faulty operation. Purchasers of the heating equipment should request then aippliers to dean the equipment as thoroughly as possi ble. uabg brushes and wiping rags. Where state or local codes require hydrostatic testing and cleaning with water, the procedure described by card No. I may be used. However, it is not easy to remove residual mois ture from the system. Since moisture is not desired in the system, testing and cleaning with water should be avoided whenever it is possible to do so. Terting la leaks shoukl be done ee described ibovc nmg Frees- After repairing any leaks, 131 the system sntk Arodor 1S4S, wares dsa flasd sad circulate it thorougkfy. The Arodor writ serve bettor thee mto for hydrostatic test ing and cleaning and trill keep tha system free front eutn asobsturc- Sistc-e the Arodor will pack up del and ealtancous parUcie*. it will be necessary to dean the fland by filtration. To piHnnaimii falser aavaaagcaaacaias, hchd&s screens Iran interfering with (be reqvifcd low of Arocfiar tbnxigb the system, (he filters muet MX ha Hi--itwHIrifl permanently m the Bine of flow. Temporay ttranen in the suction nk of the pump should be iiwpecfad frequently during imrfflwB start-up and removed when the system has proven dean. The Amchr should be cleaned thoroughly using a by pas filter, cither a platiee frame press ffled -with dry filter paper and a t&n bed of Attapu%ns earth, or a cenveasent portable tewAm cartridge type Her. Periodic use of tha filtration equqMBcafi should assure C&eS the Arodor and the hcactog sys tem are dean at all tw*cs- fn She evens that the engineer chooses to carry out testing and cleaning using water, it is very important that all moisture be purged from the system during the early hours of operation- Details are given on Card No. I. Following hydro static testing, periodic use of the filter equipment referred to above it desirable to keep the fluid and system clean HONS n WATER PCB-SD0000064150 GENERAL RECOMMENDATIONS for Operation and Maintenance The following recommendation* are primarily guides for the manner of using Arodosr 1248 in an operating system. They are supplemental to the equipment manufacturer s own recommendations for operation and maintenance that relate to the beaten or the hrrt-rrhg hxtallatkms themselves. The recommendations for start-up. shut-down, precautions in event of power failure, and periodic check-ups on the fluid and equip ment apply as generally accepted practice on all types and sizes of systems. By foSowmg these recommendations, the troublefree service life of the beat transfer fluid will be increased. START-UP When systems have been shut down for week-ends or over-night and the fluid is cooled to room temperature, follow this start-up procedure: I. Start She cvcwlatfabg pum and dardt tfw cipMrian tank to naU certain the Ayoctor 1246 is at tfce cold-start level (Tank akonM be 1 Start burner at mninum flame setting and continue ful drosUtfcm until Aiador 1246 is brafcd to IW*F. wKre measured on the uiuit^wi side o Ike Nealrf. 3. Tmt heater up to full krai. SHUT-DOWN The following procedure will eliminate overheating of the fluid when shutting down: I. Shut off bunrr completely with ctituhting pump still (pcs* alias. Contiaue to fun ihr cinvUtOi nne at full hnd ins at Inst M hour to cUoiontc high reudual heat in the consbustfam choisher of Ike hunter. 2 Shut oil ccuktiM| pump at the end of H knur and switch nil alt healer electrical controls. PRECAUTIONS IN COLD WEATHER When heat exchanger is exposed to ambient tempera tures below 50 F.. it is recommended that unit not be shut down. It is recommended that the burner be turned low and the fluid circulated continuously at about 200*F. The unit will then be "at ready' for immediate high temperature operation. PRECAUTIONS IN CASE OF POWER FAILURE In case of power failure, the burner circuit w intrmigXnl by the heater controls. When power comes on. the cuculating pomp should first be run for a few minutes to eliminate any vapor pockets that might have been formed by the fluid's being held static in the hot combustion chamber. If there is no knock ing In the piping system, full-fire stay be resumed immediately, if the Buid temperature is above 180*F. PERIODIC CHECK-UPS The regular maintenance inspection schedule should Include the equipment manufacturer s recommendations anJ abo inspection of the heat transfer fluid. The following is a listing of check points. I. Lubrication M moving parts. S. Operating fstrlilv and AccuTdtT o( rcadtap <4 oftiy ttmtmli and (pmpcniiire limit orntfub. 3. Inprctkn of healer Iwbus. Iwmrr. it-lmtiory linmp 4. faiojic dnmne of hnttit wrf.Hrv 5. liwpectfan of water ttNJinf at tl*r orvwlatmt ptiaip. 2 ftqpiiar repaduog of Hulling hnn M\ivdin|t to the manu fteturrr t rmunmemlilinw. 7. Semi-AMMul or anmu! untplinK Ami .analyses <4 Anivlof I24H Under normal operating conditions not affected by fre quent power failures or accidental overheating, when Aioclor 1248 is operated at 0OOF. it should not be necessary to check on the condition of the fluid more often than once or twice a year. The analysis for fluid condition is a simple determina tion of viscosity. The information given in Figure 6 serves as a guide to estimate the condition of the fluid, according to vis cosity values. Most users do their own testing; some have the viscosity determination made by an outside laboratory. Customers can have their fluid tested by Monsanto free of charge. A one-quart sample is required, and sample should he carefully packed to avoid breakage in shijiment. Samples should he shipped to: Mmuato CWmkal Omymp Ol^aic Clwmcafa Dimian EiAbSimI Thud Sdrs St. Lw U, Mwvwi ABOVE IN FORMATION APPEARS ON POCKET CARDS INSIDE BACK COVER n HONS 079985 WATER PCB-SD0000064151 engineerintf ^Hdata (Ksipimg or puidoiiiig equipment for a Stealing system to be operated with Aroclor as a medium to deliver heat into a process requires consideratiom of heat transfer characteristics of both the over and the heater. The actual heat which can he absorbed by a user, for example. depends upon the over-all heat transfer coefficient, heat transfer area, and a mean tem perature difference between Aroclor and tbe materia! being heated. Both overall beat trader coefficient and mean temperature difference are. in turn, affected by the flow rate f the Aroclor. This inter-relation of flow rate, heat, and temperature is usually solved by a trial and error procedure as covered in standard reference texts. The approach of Cranet(') may be used to minimise or eliminate trial and error. The following tables and grajahs of physical properties and engi neering data are provided as an atd in layout and design calculations for systems to be operated with Aroclor 1248 as a heat transfer fluid in the liquid phase. Table IV lists properties useful in heat balance-calculations by which the flow rate is related to the heat transferred and the tnngieiaturi- change of the Aroclor. This relation is also shown graphic-alls in f iguu- 10 The over all heat transfer coefficient for ilie beater or user may be estimated by tbe methods outlined in the texts of McAdamsf) or Keriif1) This is usually done by combining the individual film coefficient of the Aroclor with other coefficients and conductivities to yield the over-all coefficient. Table V contains physical properties of Aroclor as a function of temperature which are needed for calculating the Aroclor film coefficient. Tabic V| gives typical film coefficients for Aroclor flowing through a 0.81 inch i d. tube. These are listed as a function of temperature and flow rate in a tubular heat exchanger. Other tube sizes would, of course, require a correction for the diameter in tbe Reynolds and Nusselt group of the equation (horn McAdams) given at the top of Table VI Correlations for estimating film coefficients for various materials that might be processed by indirect heating may he found m the tests cited <*). (*) and elsewhere in the literature. For sizing pipe lines and pumping requirements. Figure II shows pressure drop vs. flow rate and pipe size for Aroclor 1248 at temperatures over 30O*F. Above this femgieratiire Aroclor 124B flows freely like water. A lHhkra|4ir d|iwi (M(ic 32 hCNS 07S<ftt6 WATER PCB-SD0000064152 TABLE IV mtMOOYNAMIC NIFESTIES OF AftOClOR 1241 MGNS 0 7 9 9 8 7 siSSSISSs2S2isSK5sa28282SgS52i58gs5a5ssasss!sa3gss;s>sx S2H5Sg221H32ii2sg25523si5!3^-sxscsa~^5;3Ss^sn^-s:sKSwS5s~~i. t pi >OOOOOoOOooooo =* U| W MW ^ 53SSSS^35SSi333888=!:=CanS3StEC338RS:"SSSS323SS-i 0 0>*OO o O OOOOO o OOoOOooOOO-- -- ----*- -- -- --- ---- --' -- -- ---'-- s^scs-5SSSss=sa38Kacsi;^ct=as8S885:=7:a!ci:2SS25n5ig8eg=s^ SissssiSsISigl-aSSSHsassSasaiSilS^sSSSgSSggSSSHHSiSi^SS^sS-c-- O OOO ----00000000000000000000 --~ ------- - >s WWW -- -^w*gi-3wfio5 ssa^C5;i5^s5s:^Sf:iBlb:i:5;8St:^8a3^casa8C8tt'*^^w^"` WATER_PCB-SD0000064153 FLOW KATES FOR ABOCLOK 1248 TEMRERATUW DlffERtNTIW. -f Of AHOCLO# ENTERING AHO (.LAVIMQ T * USER 2 fr i(\wv 10 <&6!0 20 40 GO 0) 100 200 400 600 KUO 2010 4000 6900 flow MIC CAiS Ptt Mlfl. MUAiS 0?59bb M WATER PCB-SD0000064154 ig s g ig s iiiis s s ig is iiS s TABLE V THE^MODTNAMIC PKOPKRTIBS of AROCLOB 1248 9 &27 4 JUS 19 IS 2898 21 sm Vm am s 149 43 114 49 175 54 89 SO 05 IS QJ n 2S.S ti 22 u 192 m 152 91 12S 99 MS IM 945 lie 911 IIS 22S 121 949 122 5.26 137 SOS ns 475 143 448 149 492 154 VO eiif 9524 JS23 9522 9529 9569 ms am 9565 9564 .9561 .9562 esm 9559 9559 9552 9535 9554 .9553 9552 9559 .9549 9541 .9542 CMS .9544 0M3 9944 448 2353 1381 m 56S 3SS m m m nt 115 95 m St si 51.1 441 391 35.9 SI 292 269 251 234 22-2 B.S 29.2 22J 12-9 14.4 126 198 97 17 7.88 2 15 SM 18 129 5-39 595 491 455 431 4.19 180 Ml m 163 V45 f. -c. "5? c*<- OJ Or. R. ft fc 9 & SB 190 38 M 349 121 38 122 m 162 329 m 89 m 89 18 <88 294 4M 219 <28 216 <38 221 <48 222 a 232 <88 238 <78 241 4 249 <S8 254 388 299 5M 246 529 221 58 222 MS 282 560 2 MS 233 *78 239 3 384 389 310 89 314 351 6542 1J4 S54I 114 asm 2J5 .9539 2.29 9531 26S asm 254 J6525 242 .6534 2J2 9532 229 9511 219 0530 293 .6523 193 9521 111 aim 116 9525 111 0524 104 0523 151 0521 151 9520 143 0511 138 0518 in 9516 129 9515 \IZ 0514 1 16 0513 1 11 0512 109 0510 104 0509 101 0508 208 335 19 6 329 195 322 125 315 161 308 18 1 304 15 4 239 14 8 294 141 230 in 285 m 2D 121 276 12 3 2 73 117 2 68 11 J 254 110 261 191 258 10 3 254 100 2 51 3 67 246 328 2 43 300 240 8/2 2 31 1 38 2 3 1 14 2 31 7 85 278 /&] 225 711 222 7 16 220 HUNS GV9<}d9 WATER_PCB-SD0000064155 n ani. ira. *F. u u lit 2S 44.1 m OS MS m mi nu m na m m e.s se 51J S3 SOS XJ M 558 Oi t@S m h; 117 TABLE VI HEAT TRANSFER DATA for AROCLOR 1248 (III CMffiaUTS EMyrrer 6 W llMi||'Uil]|i) amm iM 0-/&./T. IS 614 1 57 MS 111 ITS IX 145 ISS 4S m 107 122 1JJ 145 162 171 Id ISS SJ SIS 122 146 l in in 204 215 20 &J 812 MS 14| m m m 224 2X 2SI m 1M m 124 155 111 715 212 2SJ SI m JSS u ns IX 177 zu 2S 2SS 262 257 311 339 95 103 1S1 155 233 262 284 389 07 350 373 GAaMm to tas m> *a oa to arts atog as Ma Iml * Ttote. re erf f. 100 114 164 217 254 256 309 m 256 381 185 110 123 ITS 225 2/4 305 334 3S3 383 li 417 120 130 191 245 294 331 35 389 491 441 469 HUNS 0799V0 n WATER PCB-SD0000064156 m a s loss, r r .p u io o n, FRJCTION LOSSES IN SYSTEM flUNC AROCUOfi 1248. ABOVE WF. M MCMS OJSS^l WATER_PCB-SD0000064157 TTPICAIi ft HAT||I8 USING ABOCLOR 1248 HUNS 0')999^ WATER PCB-SD0000064158 Iiumrtiiai iwffiir Lacfc haAaa tamtttl fart bndi baod 4Bs and battww <atf8 a 40 jMS (ti ataet baffles So fevce Ite Jsaf rnwi wanna gam am Ifa Arodar cat fa* Mm puma*, tfa K^m M pt&a CmM: ftiage sfacS and M amlivcbM *Bi liw Afodo |?| n (he mfaflfAtfafat iffatM ]UpaMtcr<}^dIM(MJ>igcCBafautf efi 0Ob A*cta bade* or batfe aJagci can be eyed on attar Atecta het MOfUS 0?999j WATER_PCB-SD0000064159 IIBBT A <0.080 Bta pm lam rtadroB; BaaM parade An) odaagw aw8 te las! naatxt atoH MgsBan mtagca^Ktf. TBa M nes BnB (a s wn#y 4 and sate (tmmat iwlaa. R on aatiaBy Basket to nam JggaeamM|t 2GB IBe./B. at an argaac canpaaaB toeA Bass Baal at man nihi at ISO tea. pa paaaB; a taa! Ini an aBamat ter. Capanaaa aaSl 8a Beam atoimet 8wt a tanteaSB non Baa 8a laBcal aaaaiial8aaaa- aaa Baton (a epatow'sMQ a8ftwa Bata eaie uBtoacteif. (u attar A 4.080.000 Bta /ttt. (afcat qagAaftim BISBI Coaled ad ta i 3000.080 8B./IV. Manutaiul Lattoas Baala Bat apa4ei IBB J.SJO IBM. 0anlaws BaMa iOe*a aa 8a taR. Ita Banta a 8a b(M at <a BwB a Ua Oalit Slaws. t BB BISBT Coaanaool htwi apaatia) aa Amta l2<GaawalaBlaiaaayqpmH8aiMa Iho a a 1.208108) Ma /la. a*sM. HUMS 029994 WATER_PCB-SD0000064160 mi u(i A prbrt pUn( Iran procromf (tod opened ** >n<fercl bcat Iranderred by Afwiwr l? Vessel and feesS-sr b*s moMted tegethq ms ene an*. Ilf T Tfss 300 QDO Ota /hr forced ewerieferss haatcr cj exactness? heeted end dunsim! tar a liqasd traceratere et 50tTf. ft* cavshscton n wmi* !e a daaWe pape heM mcfniangei *th the etectnc beating (dininuitt m the mnes pipe, the Atode 1 ?4S ortaUa throng* the ananiiim spec* between wsnee end at prpe fbehewd Areder 1240 is ddnrctcd from the heater at a (empOTeterect MOf and hoots the qimtmats ^ 0 ectaed kettle mO a hatch opacity d 1.089 giPo*t Its* Iwfiiii ler 6 tercel csr ceSg&ge Mnr sa degtftgiarf If Ctoiw Sreefts CW. IJTKRATL'RE ClTS*:i) g. Monsanto Chemical (o., St- Loim. Mo . A|>j>Iic^(ion Data Bulletin 0-P-1I5 (1954). 2. Sullivan. M. V.. Wolfe. J. K.. ami Zitman. W A.. "Indus. Eng. (liens.." 39. 1607 (1947). 3. Cranet I., Heat Transfer Performance Corves . Chemical Engineering, P. 187-190. March. 1955 4. McAdams. W. ||., "Ileat-Tranunnsnm*'. Mc(qw Hill Book Co., fine.. New York, (1942). -5. (cm, D. y.. "Process I (cit Transfer". McCraw Hill Bonk Co.. Inc . Nov York; ( 1950) MCNS G?999i WATER PCB-SD0000064161 aroclor LIQUID HKAT TBAN8TIB MKD|D^ Fa? lasogtcrsewcs sp to MQ*F. Lmg4tstiB( SsmsMs-h&s service Fme-emhUmS, mm-emsmive gwrates m M-pcms-ed, mmmmm oast MOhS 0?999<> WATER PCB-SD0000064162 WATER_PCB-SD0000064163 f i ^hermljrLciJk fr SAFETY OF HANDLING i i i i i : On the basis of animal toxicity studies, THERMINOL FR may be considered only slightly toxic from the standpoint of acci dental massive skin exposure or accidental ingestion. Similarly, single exposures to high concentrations of vapors (when heated suffi ciently to volatilize) or high concentrations of decomposition products (if the fluid is accidentally discharged into the tire chamber) are not serious hazards because the irritating character of such concentrations preclude vol untary exposure. Repeated or prolonged skin exposure should be avoided since THERMJNOL FR acta as a solvent for fata and oils of the skin. Re moval of these natural, protective barriers can lead to drying and chapping such as occurs with exposures to paint thinner*. More important, THERMINOL FR may be ab sorbed if it is allowed to remain on the unbroken skin. For these reasons, we recom mend that the skin be wsshed with soap and water if there is contact. A skin burn resulting from accidental contact with hot fluid should be treated in the normal manner for any thermal burn due to hot oils. Because of its low vapor pressure, there is no significant vapor inhalation hazard when THERMINOL FR is at room temperature. For example, there is no vapor exposure prob lem while transferring the fluid from its ship ping container to the heat transfer system. On the other hand, the vapors emitted by THERMINOL FR heated to elevated tem peratures are injurious on prolonged exposure. It is indicated that the "threshold limit value" or atmospheric vapor concentration which cannot be safely exceeded (on a daily basis) is 0.5-1.0 milligrams of THERMINOL FR vapor per cubic meter of air in the workroom. In heat transfer installations, the fluid must be used in a closed system free from leaks with the expansion tank vented to the out doors. Accordingly, there should be little or no opportunity for workers to com# in con tact with vapors. HONS 076584 nDEFENDANT'S DEPOSITION EXHIBIT WATER_PCB-SD0000064164 6- - 19. ISQCIARATES Or. Kelly will be visiting Bayer will pass on an/ information he aoqulres, According to I.C.I,, 1,5 naphthylns diisocyanate is a strong asthma produoer. 20, SAUTQCIL AH> SHOI Sari/ tozioit/ evaluations of Santooels with rats had given misleading results. It is now reasonably oertain that Santoel does mot oause sillooeis in animals although it does cause soee degree of fibrosis and irritation in ths lungs. On Pont now label their product "Caution - harmful dust* and M.C.C. use a siailar phrase to time effect that the aaterial should be handled with car and users should not expose themselves unnecessaril/ to the dust. Although 3/ton does not' produo silloosis, it has been shown that it tends to aggravate tuberculosis. Animals who have been givm a sublethal dose of tuberculosis from which the/ would nomail/ rtoovsr, die when subjected to doses of 3/ton spra/. &etensive stapling teste of the air of numerous 0.3. factories using S/ton, failed to detect the preaenoe of S/ton. In India the condition* in the factories are very favourable to the formation of 3/ton dust and the aills should be cautioned to take greatw.c*" in their processing end to supply their workers with masks. 21. AR0CL0R3 U6S UP 5160 II AORIOULTORAL TORMPUTIOMS. Thee# Aroolors sot a* lnssotioide bonding agents on the leaf and inornate the aotivlty of the preparations. The/ are aostl/ chlorinated terphen/ls and have greater toxiait/ than the lower mashers. It is difficult to decide whether there is eay hasard in using these eospotmds in greenhouse sprays as the conditions as to quantity sprayed and time else of the droplets is so indeterminate. Aerosol sprays giving fine droplets will have a long suspension tine in the air. WB8/MH 26.11.54. HONS 095223 WATER PCB-SD0000064165 A Guide tn Accumulation and Shipment of ! WASTE ASKAREL FLUIDS SAFE HANDLING OF ASKARZfT FLUIDS Improperly handled, Askarel fluids could be harmful to you and to your environment. Because of this, the following statement appears on all containers of Askarel fluid shipped by Monsanto. J ,, statement carefully: Please read this old) "Askarel fluids contain Polychlorinated Biphenyls (PCBs). Care should be taken to prevent entry into the environment through spills, leakage, use, vaporization, or disposal of liquid or containers. Avoid pro longed breathinp of vapors or mists. Avoid contact with eyes or prolonged contaict with skin. If skin contact occurs, remove by washing with soap and water. Following eye contact, flush with water. In case of spillage onto clothing, the clothing should bo removed as soon :al, sLin washed, and clothing laundered." as practice Each time a flu id is transferred there is chance some will be spilled. Therefore, accr mulate waste fluids in the same drums you will use for shipping to rec uce this hazard. DRUMS TO USE ' 55-gallon drums i Must be 18-gauge steel or heavier and have a 2-bung head. 5-gallon druxn^ : Must be 24-gauge steel or heavier, (Drums must me it DOT 17-E specifications) cont. MONS 074772 2 DEFENDANT'S DEPOSITION EXHIBIT fupkycrqt- lb TS WATER_PCB-SD0000064166 .. do not use Old drums Rusted drums Corroded drums Damaged drums Drums with weak walls or seams ' LAPEL DRUMS Drums should be labeled "WASTE ASKAREL FLUIDS" and with the above "Safe Handling", statement or its equivalent. , | Liquid Waste Only FILLING DRUMS . Keep all solid ^naterials out of drums used for waste Askarel liquid. Solid materials| (sludge, rags, paper, sawdust, metal parts, floor sweeping chemicals, etc.) must be accumulated and disposed of separately. Contact your environmental department for proper disposal methods for solid materials. Keep Water Out of Drums Waste Askarel fjluids shipped to Monsanto for incineration must not contain more than 1% water, or damage to the incinerator can result. Do Not Overfill Drums Airspace is needed to allow for possible thermal expansion of the fluid: Minimus) a rspace: 55-gallon drums - 1-V - 2 inches 5-gallon drums - 1 inch Failure to leave sufficient airspace can result in possible fluid leakage or sean failure due to pressures caused by fluid expansion. cont. HONS 074773 WATER_PCB-SD0000064167 Seal the Drums ^ Uso t proper bung. Inspect the bung and the drum opening to insure tight, lcak-proojf seal. ^ 'i Do not use damaged bungs, rags, pieces of wood, or other inappropriate materials to sea{l drums. MUVTNC~lTrrEtr~PHTMg Use Proper Drum-fHandllng Equipment Askarel-filled <jirums should be moved only with a proper drum-grabbing device. A parrit beak type of drum-grabbing device will reduce the possibility of damage to drums, A common drum handling device of this type is the Lift-O-Matic**, manufactured by Marvel Industries. Pallets Not Rec bmmended Askarel-filled drums should not be palletized. However, if proper drum- a handling equipment is not available and pallets must be used: * Be sure pallets are properly constructed and undamaged to reduce tfhe chance of the drum falling from the pallet when being moved. Steel-band all drums to their pallets. Drums should be banded together horizontally as well as vertically to the pallet. So that four drums can be loaded across the width of a truck to prevent shifting in transit, multiple (2 or 4) drum pallets should be no more than 46 inches wide. .. If Askarel-filled drums must be stored prior to return to Monsanto: Inspect Drums for Leakage Inspect drums (for leakage around seams and bung, making sure all . Trademark of Marvel Industries, Inc. HONS 074774 WATER_PCB-SD0000064168 Beals are tight arid leakproof. I C lean UP Spillage Clean the outside of the drum of any spilled fluids, following approved cleaning methodsj. clean drums. j Properly dispose of materials and any water used to Store In Protected Area Drums should be stored in an enclosed area where they will be protected from possible damage and inclement weather. In Exposed Areas Store On Sides If drums must b4 stored in an exposed area, store drums on their sides with both bungs jbe low the fluid level so that rain water will not accumulate on the top of the drums. Otherwise, as drums "breathe", water can be dr.iwn into the drum through the bung seal. Use blocks or other device to keep drums stationary. Do Not Stack Do not stack drliras, whether stored on their sides or on end. 'SEFURE~5HTgHEKT Following this [procedure For EACH Shipment to Monsanto: 1. Contact t Customer Services Supervisor Attention: Mr. C. R. Field Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63166 (314) 694-3024 Give tlje following information* Number of drums in the shipment Name and address of person to receive drum labels Purchase order number, if a specific number is to be used Anything out of the ordinary about the fluid or the shipment *GN$ 074775 WATER_PCB-SD0000064169 You wi1| then receive: j setter or authorization with Monsanto i identification number for the shipment .Pra-addressed shipment/warning labels for each drum Carrier's Advisory Note to be attached to the bill of lading Terms of shipment and charges, if any Upon receipt of|above materials: I 2. Fill in EACH label with Monsanto identification number, product description and YOUR company name and telephone number. 3. Label R\CH drum. 4. Put Monsanto identification number and your telephone number on Carrier's Advisory Note and attach to bill of lading. LOADING AND SHIPMENT Perform a finajl check for leakage, damage, and to assure bungs are tightly sealed. , 'Load and secure drums to prevent shifting in transit. If shipment is to be part of a mixed consignment, waste Askarel fluids are not to be jshipped as mixed loads with raw materials for animal feed, food grajde chemicals, foods, food packaging materials, or pharmaceuticals. Contamination of such goods may subject them to embargo or destruction. Be certain dr j^ver is aware of Carrier's Advisory Note and telephone numbers in ca4 e of leakage or other problems. Do not ship v a piggyback. Please notat M snsanto checks all shipments upon arrival. Failure * t ) follow the above guidelines could result in fluids b sing returned to you and additional charges assessed, Tie above instructions are intended only as a shorthand guide. For complete instructions refer to the ANSI CI07 document, "Guidelines for Handling and Disposal of Capacitor and Transformer Grade Askarels, Containing muns c m ? }*. WATER_PCB-SD0000064170 Polychlorinated Biphenyls"', available from the American National Standards Institute, 1430 Broadway, New York, New York 10018. MONSANTO logo HONS 074777 WATER PCB-SD0000064171 ') PRESENTATION TO FIELD SALES PERSONAL AND CONFIDENTIAL 1. Introduction As moot of you are aware, there have been several newopaper and magazine articles published in the U. S. In 1969 indi cating that jjolychlorinated Jjlphenyls (PCDs) have been discovered in some marine, aquatic and wildlife environ ments . The quantities detected are said to be in the ports per million or parts per billion category. It is claimed that the PCBs found strongly resemble chlor inated biphenyls containing and 6(Jfi chlorine by weight. As you know, Monsanto sells such products under the trade names of Aroclor 1234 and 1260. 2, Letter to Monsanto's Aroclor Customers As a result of this publicity and because Monsanto's name has been mentioned In at leust one of the articles, it was felt that Monsanto as a responsible member of the buc.lncM; community hud a duty to alert its Aroclor customers to a potential problem of environmental contamination. In no alerting our customers, let me emphur.ize that thlu iiocr. NOT mean that wc are agreeing v/J th the contents of any MOWS 058519 WATER PCB-SD0000064172 2. _ - published articles on PCBs, nor are we necessarily disagreeing with the articles. It does not mean that we accept that Aroclor 1254 and 1260 have caused any environmental problems. We are merely fulfilling what we consider to be our moral and our legal responsibility to our customers. When you consider the present public concern with pollution and the environment (witness Newsweek'a recent article headlined "The Ravaged Environment"), I think you would agree that it would be foolish and imprudent to ignore the PCB articles. But let me repeat that notification to our customers does nat-imply guilt on the part of Monsanto. Accordingly, a letter has been cleared by our Legal Department for mailing to each one of our dlrect Monsanto customers. This letter goes to Plasticiser customers only. A very similar letter will be mailed by the Functional Fluid/; Croup to thoir customers. The letters will be mailed from St. Louis; about the end n" February, it will be addressed to: . Office of the President XY/i Company Account:: HocclvuMo Address HONS 058520 WATER_PCB-SD0000064173 The Plasticizer letter will be signed by W. E. Schalk. A copy of this letter, together with a cover letter, will be mailed to the head office of each of our Aroclor dis tributors. The cover letter will indicate the action Monsanto is taking with regard to its direct Aroclor customers. We will recommend that our distributors mail a similar letter promptly to each of their Aroclor customer;;. Copies of our letter will be made available I. to our distributors in quantities sufficient to meet their necd3. It is not our responsibility to alert our distributors' customers. To explain the action to our < distributors we have visited the head offices of Central Solvents and American Mineral Spirits. Let me summarize what Monsanto's letter says: 1) Its primary function Is to alert cuatomero to a potential environmental pollution problem. Con fidentially, our Legal Department believes thl;; will minimize and, hopefully, eliminate claim:: made against us ior environmental pollution damage. 2) it does not imply quilt by Monsanto. At thin thin, HONS 058521 WATER_PCB-SD0000064174 I) we are taking a neutral stand on the controversy. There are real problems of analytical identification of PCBs, how accurate the levels observed are, how PCBs affect marine, aquatic and wildlife environments over the long-term. We have active programs in all these areas to better define the problem but a lot of work needs to*be done before definite scientific conclusions can be drawn. 3) It points out that not all Aroclors are PCBs. This is on important distinction. Don't call the PCD pro blem the Aroclor problem. We sell Aroclors such as 5060, 5442 and 5460 which are NOT PCBs. They, there fore, should not be regarded as potential environmental contaminants. 4) Furthermore, it says that not all PCBs appear to be potential contaminants. Aroclors 1221, 1232. 1242 and 1240 have NOT been found in the environment. Neither have Aroclor:: 1262 and 1260. We can only theorize mi to why this should be. At tb):i ulugr, we prefer not to Indulge in theories. The oallent MOWS 058522 WATER_PCB-SD0000064175 -5- polnt Is that since they have not been found - In ' spite of Intensive Investigations by scientists both here and abroad - indicates that they are not per sistent contaminanto and, therefore, do not pose a lonG-term threat to the environment. 5) By including a copy of the Federal Water Pollution .i Standards established for all states of the Union,1 we are pointing out that care will be needed in preventing environmental contamination from other raw materials and products not Just Aroclor 12p4 and 1260. We feel this Chemical Weelc reprint will' be useful information for many of our smaller customers. , Customer Reaction We expect thin letter will lead to customer reaction. Our competitors are sure to learn of it arid some of them may even be kind enough to capitalize on it or at leant try to. We can't anticipate all the wayr: in which our customer:; HONS 058523 WATER_PCB-SD0000064176 l ) 6- - \ react. Remember this letter is going to the "Office of I the President" so it may get down to his subordinates in a variety of different ways leading to a variety of re actions. Why send it to. the Office of the President? Because our Legal Department feels in this way we have really notified a company officially of the potential problem. If there is any legal litigation later, the courts might feel that sending the letter to Joe Doe, Plant Purchasing Agent, was not legal notification because Joe Doe may not be an officer of the company. So we must be prepared to expect hearing from customer employees we've never met nor heard of before. They may call anyone in the district office, many are likely to call Mr. Schalk, some may call executives all over the St. Louis campus. Let us concern ourselves with what happens when a customer calla your regional offices about the letter or raises the matter during a sales call. Por your guidances, wo'vc prepared some aide: MOMS 050524 WATER_PCB-SD0000064177 (1) A list of DOs and DON'To for Regional Managers. (2) A list of "likely" customer questions together with answers approved by Jim Springgate and our Legal Department. HONS 058525 WATER_PCB-SD0000064178 U 8- - Decreased Sales Beware of decreased sales to any account after the letter is sent out. If you suspect this, your plan of attack could be: Monsanto: Customer: "I see your purchases of Aroclor XYZ are ^ down. I hope it doesn't mean your business ' Is having a tough spell . I 1 i "Ho, business is O.K. but it's that so-and-so letter you sent". ; Moncrnto: "Does this mean you've switched to a replacement for XYZ?" Customer: "Yes". Monsanto: Probe to find what it is. Is it Inferior to Aroclor. Is it really not a contaminant too. Point out our range of products. Uco Monr.ont'i bullotinc/niuc hook to get him to evaluate one of our products. OH CnM'.onu r: "Mo but J'm living off inventory till my I. cun get a replacement". MOWS 058526 WATER_PCB-SD0000064179 ),) -9- Monnanto: Competition: "Let me help you with some suggestions If I can. In the Blue Book here, we oover over eighty possible products---", ,A Remember that Aroclor plasticizers are outstanding products. They are inert, oxidatively and chemically stable, give good adhesion In adhesives, sealants and coatings, moisture resistant, give low vapor transmission in coatings. In other words, they are used because of PERFORMANCE. Competitors will suggest chlorinated paralTinr. but they are not so good. Every salesman who has gone through the Training School in the * past year - and over 90# have - hove been given the advantages of Aroclor over chlorinated paraffins. Use it if you have to. You might ack the customer: "How sure are you tlu t chlorinated paraffins arc not onvironmuitnl contaminants. What proof do you have". Dlurit the competitive attacks by get tin.-, them to be defensive. MOWS 058527 WATER_PCB-SD0000064180 VJ ) -lo Future: ir the customer Is going to evaluate replacements, make sure he gets samples of plenty of our standard plasticizers. There may be some panicky reaction to start with. Your Job will be to calm it down. To do that, you have to be confident Our Aroclor sales have increased every year for ten years - in boom or recession. We want 1970 to be no different. Let's not enter a new decade with a down-turn. HONS 058528 WATER PCB-SD0000064181 DATE JOB T,n- 1? U'70 HEAD: How To Keep Your Thermlnol FK System Leak-Free COPY: Your Thermlnol FR heat transfer system 1 a a closed system. Thus fluid leakage Is easily controlled. Hero are some suggestions that will help you control leaks and dis pose of any fluid taken out of your system. Check These Sources For Leakage Centrally, there are four sources of leaks In a system: Fittings. Weld all connections. Flange fittings where accessibility is desired. Pump Seals. Canned pumps are the best protection against leakage. If mechanical seals art used, enclose them or provide a drip pan with a drain to a collection sump. User Seals. Direct all drains to a collection sump. Install drip pans at rotary Joints. Expansion Tank Vent. Direct vent to eithor a cold seal tank, catch pot or drum to contain vapor condensation and light ends. When your system is under design or construction, specify check valves at selected points. This will minimize fluid discharge In the rare case of a rupture at the using equipment or J" heator coll. HONS 080871 WATER PCB-SD0000064182 DATE J03 y, 'T-O How To Dispose Of Thormir.ol ."R If leakage does occur, collect the fluid and place It in durms. Return material for disposal to: Monsanto W. 0. Krummrich Plant Saget, Illinois Attns Supervisor, Department 2^6 Please advise your Monsanto fluid spoolallat that material is being returned for disposal so the proper papers can be prepared. The charge Tor this disposal is $.03/lb. (not including drums and freight costs). Follow the same procedure for change-out of your fluid charge. Or, you may wish to reclaim this fluid under our regular policy. Your investment in a heating system using Thcrminol FR fire-resistant fluid shows you care about safety; safety for personnel and equipment. The above suggestions are made to help you keep your system leak-free and pro tect this valuable investment. If you have any questions about fluid leakage, disposal or reclamation, please contact your Monsanto fluid specialist. HONS 080872 _^ . *' a r i ' WATER PCB-SD0000064183 W B PAFAGS3R01 S?B WVJS, JOLT 13 1970 If* G* CANHAH - P4-30i H. S. BEW2B! J. R. FALLON S6 Ae OLSON o e amisi feu asm protafely aware of our eemaean rttfitrtfiag Hi eont sainatioa of the wirenasnt with pelyehlortjaattsfl biphenyls (Monsanto* Aroolors). Monsanto* tberainol (m Series) eataia Aroelers. In order to star in tM business* urn or 4nslUa that heat transfer sytw h designed to assure ainiaam loss by leakage or I a interested in reviewing Monsanto* eymtesa design and eeeparim it td,th the design m propose to our uatoasrs. kill your offlee please send as a copy of P2,l 6td 19 "Selection Guide - Flplng for Heat transfer Fluids" * a well as any other infonation &Y&ilahls V. B. PAPAQEOROI HONS 098181 Irj WATER PCB-SD0000064184 V* Be PAPA03DR0B - ST, MOTS JULY 13, 1970 Bo Wo CORLW - WK Ho 8, BROTH 0 * ERATSCB WX, t, j. bolzaffsl Jo r, smos Our ?GB pollution control discussions tost Mli; were, for , vesy iotomUft, Z tus with the intpdfe muI ewm tspmti by yw plant pwele . Step* i control tseap# of teMloys to the environ^ Mat have been 8u*ifttl ss deaenstratod by do crossing mounts 4ett@4 is yen effluent. ffegrtis on eoapietiea of tint catch femia in draniil Z wi, hosevcr. dlBJCint4 that those nw& which could experience spillage. Xnakagt. etc. to & high degree fir oot fifi yet tied to the mm emfeeh basin. gpeeifieaUy. Z as referring to the dinwiiRg station* tank ear and tank true* loading spate* th storage tank area, the residue handling are* sad th trash collecting tin. tt feu fereaches Z noted in seas of th ares as not tied in to any collection eystea. Host of the surface is covered dth crushed Hmatww, mm of which is oovered with drooler mere & m control of surface drainage through the outdoor areas. Z rtooamcnd that these areas he pared, curbed and drained through your new catch basin or possibly a second basin If the drainage systes layout requires it. Z encourage your interest in controlling ateospharie missions and recoieaead you accelerate your efforts in convicting your eaisaicn audit. Consideration should be gieea to the use of condensers, entralnasat separators, drowning Jets and intercomieotion of 'rents to provide for transfer of vapor from vessel to vessel rather than free exhaust te th atmosphere* With the interest Z noted among your people. I as confident hat you will succeed in preventing the escape of Arfilers to the environoent to the extrtotly low levels required. If Z eon help, let no know. HONS 098182 W. B. PAPA02QROE WATER PCB- W. B. PAPAOBOROS - ST. LOUIS AUGUST 17# X970 0. X*. JESSEX - ABWBTO1 H. S,, BERQI3I ,F. B. RODOES P. J. HOLZAPFtt Jc R. SAVAO* The FGB wmm 6nd the isspstefeiett of the Aroelor fmelXiU# mi JUly 31 m to m very ififenwtin tmd I hope ytrnr plant personnel benefited 1* Progress on carbon adsorption studies* the latest cuptor basin* analytical capabilities and reduction of PB in the plant effluent asm very isaa^ur-aging. I me* however* disappointed that we are 8till using osasiderabl qvmatifci* of sand to keep tot floors in toe department partially dry. This long standing practice creates sand disposal problem as wen as a difficult floor scraping and cleaning problem. Our efforts should be directed at preventing Aroelor from getting on the floor. Spill and leeks should be under extremely tight control so that toe department has a "boa dry" appearance. If leaks do occur, they should be very rare and some evidence of containment such as sand, a bucket* or oil absorbent should be visible, these should be considered as tet^oraxy measures until permanent correction is made and should net be tolerated for long periods. 1 recognise that this poses a very challenging objective* but it can be achieved as demonstrated by both the Bewport and Sextet operations. 1 believe it would help psychologically if toe sand boxes at the base of all stairs were removed. the interceptor basin being installed will remove toe Aroelor from water streams originating in toe chlorlnation and distillation areas. have concerns regarding toe containment of Aroclors from the bulk storage* dnwsdag, tank ear and tank truck loading areas. The crushed rock areas should be replaced- with concrete pavement* curbing end drainage to the interceptor basin. The amount of Aroelor on the drumming area floor appeared excessive and could overload toe small sump which la in toe present drainage channel from this area. HONS 098174 WATER PCB-SD0000064186 tte should strife for an operation in idhlch no Aroelor is Risible and one that m would not healtat* showing to a sever eritie auch a* engr#s Ryun* W B PilPAOBOM* HONS 098175 WATER PCB-SD0000064187 Monsanto o TO O O W. B. PAPAGEORGS - ST. LOUIS January 8, 1971 PCB ENVIRONMENTAL PROBLEM DECEMBER STATUS REPORT. P. J. A,, Marsh - BRUSSELS W. S. Clark J. R, Durland- TOKYO M. W. Farrar - 2nd Street E. V. John R. E. Keller - 2nd Street R. M. Kountz T. L. Gossage , P. S. Park W. R. Richard J. R. Savage E. P. Wheeler H. S. Bergen J. Mason MARKETING; Efforts continue to educate Thermlnol PR users to control leakage. Consulting visits to JFQ and WGK plants have brought results - all but one system at JPQ converted from Thermlnol FR/Aroclor to Thermlnol 66. At WGK, two systems converted and four in process or converting from Thermlnol FR/Aroclor fluid to Therminol 66. A U.S. Dept, of Agriculture press release announcing the banning of both polychlorinated biphenyls and polychlorinated terphenyl3 in pesticide formulations has generated a considerable number of inquiries from our chlorinated terphenyl customers. Inquiries made to representatives of the U.S.D.A. to establish reasons for including terphenyls have been answered with vague generalities. Formal protest is being prepared and will be forwarded. ENGINEERING: . Liquid Incineration - Krummrlch - CEA 2415 Pinal drawings of the incinerator system from John Zink Company were received as _well as their fabrica tion schedule. All additional equipment is on order and design is proceeding on schedule. HONS 099633 WATER PCB-SD0000064188 2 MCS 1016 - Krummrlch - CEA 2417 Additional evaluations with Manufacturing led to a decision to revise the scope of this project. The revised Data Transmittal is now scheduled for midJanuary. . Definitive design continued on elements not effected and pile driving work for foundations was started. Tributyl Phosphate - Queeny - CEA 2371 Pre-approval funds were provided to start definitive design and work is in progress. N-C Phosphate - Queeny - CEA 2451 The preliminary project scope was developed, a safety review was held and the scope was reviewed with Research and Manufacturing. A capital estimate is in progress and the Appropriation Request Data Trans mittal will be issued in mid-January. Solids Waste Disposal - Krummrlch - CEA 8042 Analysis on the samples collected during the EnviroChem test are still in progress. Meanwhile, a system specification wa3 developed for facilities to remove PCB's from solid waste. V/ork continued with marketing in an attempt to better establish what we can expect for disposal from our customers. JAPAN; No new developments reported, EUROPE; No new developments reported. MEDICAL; The 18 month status reports on the two-year chronic dog studies with Aroclors 1242, 1254 and 1260 were received. There has been essentially no change in the animals since the 12 month reports last July. The teratology studies with these same compounds have been scheduled and* will be underway shortly. HONS 099634 WATER PCB-SD0000064189 -3- PUBLIC RELATIONS: Three new sources of PCB news appeared during the month. The American Chemical Society syndicated an article, based on Carl G. Gustafson's article in Environmental Science and Technology. The ACS feature appeared mainly in East Coast and New England weeklies. The College Press Service distributed a PCB story to campus newspapers which rounded up previously published material. So far, it has appeared in the Washington University and SIU student dailies. A third article, quoting oceanographers meeting in Rome, criticized Monsanto for refusing to release production figures on PCB. RESEARCH: ' Carbonless Reproduction Paper Solvents Process assistance was provided Dixie Chemical Co. during initial phases of MIPB-2 production. Opera tions proceeded well and satisfactory crude reaction product was made which was further refined in the J. P. Queeny Plant. A process modification proposed by Dixie was shown to be satisfactory regarding performance of MIPB-2 in dye color development. ` i As a result of an exchange of visits between Nashua and Monsanto, two candidates appear promising as Aroclor 1242 replacements: XS-276 (HB-4o/Aroclor 5442) and XS-310 (MIBP/ chlorinated paraffin). XS-276 has received a partial plant trial and a drum of XS-310 has been ordered for more testing. Other coded samples are alao under test at Nashua. 0.E. Samples A second set of plant and stream water samples from 0.E.-Pittsfield, Mass, were analyzed for PCB's. The results (< 1 ppm) were similar to the first set anal yzed in early December. Additional samples of milk have been received from G.E. for PCB analysis. J. F. Queeny The monthly monitoring of the JFQ Plant composite ef fluent continues. The PCB level found for November was 19 ppb calculated as Aroclor 1248. This level is lower than found for September and October by a factor of about 4X, part of which can be attributed to the current very low laboratory blanks. , HONS 099635 WATER PCB-SD0000064190 o o o -!)- Solid Disposal - Pyrolysis Unit The analysis of all samples taken during the recent Envlro-Chem PC solid waste disposal tests have been completed and the results reported for correlation with engineering data. A second sampling of the pond associated with the Biviro-Chem incinerator demonstrated that the PCB disposal tests did not contaminate the site {<10 ppb), Aroclor 5442 Composition GC/Mass analysis of a composite sample of materials extracted by water from eleven current Aroclor 5442 lots has been completed. No.highly toxic components, furans, dioxins, etc., were identified which could account for the reported higher toxicity of Aroclor 5442 to Daphnia over chlorinated biphenyls. Chlori nated biphenyls and terphenyls were identified as the major constituents of the composite. Previous work had shown that an impurity in Aroclor 5442 gave a lowresolution mass spectrum similar to the spectrum of tetrachlorodlbenzofuran. It was later found that tetrachloromethylblphenyl has a similar mass spectrum. To determine which of these compounds is present, a high resolution mass spectrum was obtained at the Physi cal Science Center on a concentrate containing the impurity. This spectrum indicated the empirical for mula of the impurity to be 0^0^1202014, The empirical formulae of tetrachlorodlbenzofuran and tetrachloro methylblphenyl are C12H3OCI4 and C13HRCI4, respectively. No reasonable structure haB been found for the indica ted empirical formula. Another sample has been con centrated and is scheduled for high resolution mass spectrometry to verify the empirical formula of the impurity. Biodegradation Testing The expansion of the semi-continuous activated sludge (SCAS) testing facilities from 16 to 26 units was completed. This will allow us to study 24 products, including 10 new ones. Additionally, early in January a fractional replicate of a factorial experiment will be Initiated, This preliminary experimental design will be used to determine the effect that seven variables have on the observed SCAS disappearance rates of three model compounds. The model compounds to be studied during the eight week duration of the test are bi phenyl (degradable),`2,4'-dichloroblphenyl (intermediate degradable), and 2,2', 4,4', 6,6'-hexachlorobiphenyl (non-degradable). HONS 099636 WATER PCB-SD0000064191 -5- A staggered schedule for all SCAS units has also been laid out which will allow one-third of the 24 units devoted to degradation to be sampled and analyzed (20 data points) during each month of operation. The compounds to be studied during January include TCB, MIPB, HB-40, 2,21-dichlorodiphenyl ether and Aroclor 1221 as well as the three units devoted to the statisti cal experiment. The other compounds being fed (but not sampled and analyzed) to the remaining units are MCS 1043, MCS 1016, Aroclor 1242, Aroclor 1254, Arobromoclor 1232, ONCB, PNCB, p-chloroaniline, nitrated orthene. S-711M, hexabromobiphenyl, Aroclor 5432, Aroclor 5442, Aroclor 5460, and Arobrom 5^65. Analysis and sampling of these units will begin in February and March. In the meantime, the effects that these materials have on the normal characteristics (pH, growth rate, and settling time) of the activated sludge will be monitored on a daily basis. The two remaining units are being used to maintain special cultures, a Cg biphenyl culture from MCL, and a biphenyl culture grown in our laboratories. Very rapid growth on biphenyl' as the sole oarbon source has been observed with the MCL-C2 culture. River Die-Away , River die-away tests with Aroclor 1242, Aroclor 1254, MCS 1016, MCS 1043, Arobromoclor 1232 and TCB at the 100 ppb level were discontinued after several weeks. The highly scattered data obtained Indicated that the loo ppb level wa3 too low to achieve meaningful dis appearance rates due to procedural problems and/or losses by non-degradation routes (volatilization, ad sorption, etc.). Further experimentation Is planned during the first quarter. HB-40 and MIPB Biodegradation A brief sampling period of the HB-40 and MIPB semicontinuous activated sludge (SCAS) units was completed 11/28/70. UV analysis of the hexane extracts gave mean disappearance rates of 58#/oyole for MIPB and 44#/cycle for HB-40 based on the total material present. A 3X cycle gave disappearance rates of 66# and 55# respectively while a 5X cycle gave 77# and 62# respectively, SCAS work with .these materials will be concluded with an extended sampling period In January. MOMS 09963? WATER PCB-SD0000064192 River die-away tests on HB-40 and MIPB are nearing completion. After a three week exposure at the 1 ppm level to the normal level of micro-organisms in Meramec river water the MIPB concentration has decreased by a total of 85$ of which 54$ can be attributed to microbial degradation. Similarly for HB-40, the total concen tration has decreased by 66$ of which 57$ can be attributed to microbial degradation. Aroclor 1221 Feeding of the Aroclor 1221 SCAS unit continues but with only limited sampling of the unit. No quantita tive data.is available yet but qualitatively there appears to be a rapid disappearance of the lower homologs with a build-up of the higher ones. This unit is scheduled to be sampled for an extended period in January. Aroclor 5432 Liquid-Liquid Chromatographic Analysis The liquid-liquid chromatography method for the analysis of SCAS samples containing Aroclor 5432 has been optimized. The liquid-liquid system consists of a 3 ft, column packed with Zysan Permaphaze as the stationary phase and water/methanol (75$/25$> v/v) as the mobile phase. The ultraviolet detector Res ponse is linear between 0 and of Aroclor 5432, absolute, with a lower detection limit of about l>*g absolute. Analysis time is 40 minutes. Optimization of the system to other halogenated terphenyla will be made. Carbon Adsorption Studies The pilot unit continues to operate with minimum diffi culties at an average flow rate of 6 gpm/ft^. Effluent quality, at the present flow rate, is <10 ppb Aroclor for average influent concentrations in the range 100-2000 ppb and for occasionally high concentrations of up to 11,000 ppb. There has been no indication of a breakthrough. Present plans are to operate the unit until 12/30 at the present flow. If there is no indication of a breakthrough at that time, all data will be compiled for an evaluation and recommendation by a Pittsburgh carbon consultant. Filtration Studies HONS 099638 The study conducte*d to remove the Aroclor contain ing solids from the effluent of the new neutralization pit by filtration through a sand bed has been completed. At flows greater 200 cc/min the filter tended to blind with the fine solids. The solids could not be success- WATER PCB-SD0000064193 -7" fully washed from the filter. A report will be issued by 12/28 on all the filtration studies. Sollds-Aroclor Removal by Flocculation and Flotation The clarifier unit from Biodize has been received. Plans are now being made for some necessary alterations on the unit. The complete installation is scheduled to be com pleted by 1/29/70. Denver Equipment has completed their study on the removal of solids by flocculation and flotation. The most satisfactory flocculation results from these studies were obtained by conditioning with (200 ppm) CAO, and (10 ppb) Alp (SOij)3 to preflocculate the solids and then intensi fying theJfioc with (4 ppm) Separan MGL. Initial solids concentrations in the range (100-1000 ppm) were reduced to 19 ppm in a 120 min. settling time. Flotation of the same material using 56 ppm of Armac T and 30 ppm of Aerofroth 65 produced a final effluent of 34.5 ppm of solids. Solids removal is more dramatic by flocculation, however, the froth may be more effective in removing the organics. Betz is scheduled to complete their evaluation and recom mendation by 12/21 on the floe study. , A tentative work plan will be issued by 1/4/71. Pydraul Reformulations Pydraul 312A The new Pydraul 312A was formulated using 750 SUS mineral oil with Santlcizer 711 as solubilizing agent. Production quantities will be sent to GM Central Foundry in January. Pydraul 54OB We added 2.5# tributyl phosphate to minimize pump wear in oil gear equipment. We expect satisfactory per formance. Pydraul 135A and Pydraul 2 30A We will use 750 SUS petroleum oil plus small amounts or TCB Tor improved fire resistance in these new formulations. Pump tests were satisfactory. Pydraul A200B The V-105C Vickers pump test had excellent wear character istics. A Tentative Process was issued. HONS 099639 WATER PCB-SD0000064194 8- - Pydraul 150A We do not have a satisfactory candidate. Fire resistance i8 insufficient. MANUFACTURING: W. Q, Krummrlch Plant PCB Levels in Sewer 1. Aroclor losses from the Aroclor Department averaged about 0.6 lbB/day and ranged from about 0.2 to 1.4 lbs/day. Losses from the Sauget Village Treatment Plant for the period 11/17 - 12/17 averaged 3^ lbs/day (177 ppb). Range ror 7 samples was 9 to 53 lbs/day (47-200 ppb). Samples taken during the 3-day neutralization test (12/15 - 12/17) are not included. Average for this period was 27 lbs/day. 2. Program to monitor the various plant Bewers was begun the last week of December. Plans are to com posite samples twice per week for analysis. 3. Sewer samples were taken from the effluents of the other industrial plants. These included: ' Midwest Rubber American Zinc Cerro Copper & Brass Mobil Oil Dead Creek Village 54 " 18 " 2110 " The only significant quantity is the PCB's from the Village sewer. This amounts to about 2 to 3 lbs/day. Probable source is Aroclor trailer washes at Rogers Terminal. Projects To Reduce Sewered PCB's From Aroclor Dept. 1. Design package Tor project to pave and trench load ing areas is 95% complete and will be Issued by 1/15/71. Program To Eliminate Sewered PCB's From Using Depfca. \* The Plant manager has requested by memo that all General Superintendents proceed at once to change out all Thermlnol FR units to non-Aroclor heat transfer fluids. MONS 09964Q WATER PCB-SD0000064195 -9" Removal Of Soluble PCB's Prom Sewer Stream (Reach 10 ppb) A 3-day test was run 12/15 - 12/17 in which the entire plant effluent was neutralized with lime. Results indi cated no change in the average level of PCB's In either the influent or the effluent at the treatment plant at the 9Oft confidence level. At this point, it appears possible to reach the goal of 10 ppb without secondary or tertiary treatment by doing the followings . 1. Change out of all plant Therminol PR units to non-Aroclor fluids. 2. Continue control of losses at the Aroclor Department at less than 1.5 Ibs/day 3. Clean all contaminated sewers and sewer boxes. 4. Monitor and control Rogers Terminal. PCB Levels in the Atmosphere A project premise and estimate for $6,000 were prepared to replace the nitrogen purge with a nitrogen blanket at the mix tanks and to re-route the chlorinator rupture disc lines to the pad. . A sampling station will be shared with the Chlorine Department to monitor PCB content of air downwind from the Aroclor Department. Samples will be taken every other week starting the week of 1/11/71. PCB Rework Project (Estimate 2095) . Project package is essentially complete and will be issued the week of 1/4/71. Replacement Products (CEA 2417) Ground was broken for the fractionator project for pro duction of MCS 1016, replacement for Aroclor 1242 in capacitors. Newport Plant(October/November) Removal of Suspended Aroclor From Plant Effluent Now that all Jobs have been completed, a careful- check was carried out to ^correlate PCB content at the interceptors compared with the final effluent discharge tank. MONS 099641 WATER PCB-SD0000064196 10- At the interceptor, the pcb content was 22.6 parts per billion. Simultaneous sampling at the main effluent plant gave 54.0 parts per billion. Difference of 31.4 parts per billion is arising from spillages from internal heat transfer fluid systems, and from drum leakages from Aroclor stored on drum flats. Evaluation is now in progress to change all in ternal Aroclor heat transfer fluid systems to Santotherm 66, The two areas involved are Santolube 900 and 4-NDPA. The expansion project for 4-NDPA has been requested to use a Santotherm 66 system. Incineration Contact has been made with Dr. J. B. Lewis, Chemical Engineering Division, A.E. R.E., Harwell, and Mr. Hlgginson who is in Division Engineering Design and Development, Refuse Disposal Branch of the Public Engineering Dept., Greater London Council. Dr. Lewis is considering offering an incineration service to Industry for the disposal of highly toxic wastes. Vodden and Macdonald are scheduled to meet with Dr. Lewis in the near future, Mr. A. E. Hlgginson is very much in faVor of industrial waste disposal services carrying highly toxic wastes for incineration through speoial systems provided by the Greater London Council. This appears to be a logi cal step forward and should be of significant advantage to our customer disposal problems. We intend to follow up with Mr. Hlgginson following our discussions with Dr. Lewis. Atmospheric Bnlsslon This investigation is proceeding and T.S.D. Bhould assemble data in progress report issue. Esturlal Dilution The Monsanto effluent discharge of approximately 1.4 million gallons per day is further diluted in the Severn Estuary by the several rivers discharging into this area. Average daily flow for these rivers have been obtained and are as follows! HONS 099642 WATER PCB-SD0000064197 -11- River Usk. River Wye River Severn River Stour Bristol Avon Somerset Minor discharges 535 1319 H7Q 38 million H 11 11 galluons it w Ger it it dan y ii n 353 45 If tl ii ti it it n it The average dally flow corresponds to 3,670 million gallons per day. The lowest dry weather flow for all these discharges has been established at 44$ million gallons per day. These volumes should be looked at in relation to the current discharges from the Newport location. Used Drum Disposal Blagden's drum reconditioning plant at Barking, Essex is acceptable for reconditioning used Aroclor drums aB a customer service, but is not approved for the incineration and disposal of the washings, and this problem is being further investigated. Anniston Plant Current Level - Aroclor Wa3tes Aroclor losses during Dec. averaged 1,5 lbs/day (321 ppb), The breakdown of the numbers is: 26 Day average 182 ppb 0.8 lbs/day 2 Day pumping from old Limestone Pit 39 0.2 1 Day detergent wash of 58 0.3 Aroclor Dept. 2 Day removal collected PC & solids in first part of new Limestone Pit 42 0.2 Total average: 321 ppb 1.5 lbs/day From this it is obvious that we can no longer detergent wash the Aroclor department. When the second Limestone Pit is completed, the losses from digging and pumping should be eliminated. Two pits will allow switching to a clean pit when one becomes saturated with PCB. Spills Shutting the Aroclor department down for the New Years MONS 099643 WATER PCB-SD0000064198 -12 Day holiday caused the Therminol system surge tank to overflow when a valve leaked. The Therminol wa3 caught in the department sump and no Therminol entered the plant effluent. i Projects and Evaluations ^ 1^ Supplied information to R. P, Seifert of CED cover ing solids containing PCS generated at Anniston for use in evaluation of PCB/sollds incinerator tentatively located at WGK. 2. Laboratory tests conducted by Betz Laboratory repre sentative in our Anniston laboratories indicates that Bentonite Clay and Betz Polymer 1175 combination is very effective in removing solids from Limestone Pit effluent. Some mix will be tried by Denver Equipment Laboratories and then clarifier size recommendations will be developed. Pilot scale unit utilizing Blodize clarifier under con struction. Startup is targeted for February 1. 3. Construction of No. 1 Limestone Pit 90$C complete, will meet 2/1/71 construction completion unless delayed by weather. 4. Approximately 20 tons of inert material pumped from effluent end of pit (along with 260 pounds of PCE ad sorbed on tlie inerts) on 12-18-70. This approach has added one month to the effective pit life at this time and can be repeated several more times. ---W. B. PAPAQEORQE ms HONS 099644 WATER PCB-SD0000064199 T. L. Z mwmm mpmmm, mam to to HUM ms la inm&mv *m pa>lfela 6 ft^sstel S) m #4B 3. Mtii# m mt fmm mdMto mm@, s appUfisilG, mi p*o4et tS*f fmMmmt mi tea fesmt? mi V (M la tt i i /ffc t. I.. HONS 098533 WATER PCB-SD0000064200 vt rum I, 1971 0a tm, 4*MtM? A HUMt aafltaLJttM Mm BmSm fmm aSrai fmm Wmmk iri J*fe fesre fe Mb UtMt iIwm. itm M fcta Alf toaffie la AsmmliM Mi M Uf4*a @ait4#8i Ml. fta flail la fill la m m Its k#s teal ttaf> a* efanti^, 'fm imU ta fessate at Svm tt item?* 1 Immskmf eg e#fwd aatalf 41 <tffw ef f&i la eatp feifih it? 6t tetffie f@ tae airlsd eear A laai tea f*m. MUafi ifewM tea ahla to gia m ttesiv ewMetmmi mrn&m *, Sa^msMmi m IMe, I tall will vswa fa e ieaa m itaUfif few Mswte. T.U. /f* MQNS Q9853<* WATER PCB-SD0000064201 INTRODUCTION Theralnol FR^J flre-reelstant heat transfer fluids have Ions provided safe, dependable, eeeeaeade*! performance for hundreds of users in dotens of appli cations, The presence of poly-chlorinated biphenyl (PCS) in the Theralnol FR formulation provld^ fire-resistance, living Theralnol FI an added margin of safety which was especially desirable in hatardous applications. Host recently, PCI has been identified as a potential haeard to the environment. Monsanto hat accordingly elected to discontinue the manufacturt_Jui<Ljsaln-.of Theralnol FR fluids for heat transfer eppllcetlons, end has undsrtsksn the rather substantial task of converting Theralnol n users over to the non-PCI - containing foraulstlona, Theralnol 55 and Theralnol 64, a These products offer most of the excellent heat transfer characteristics of Theralnol FR fluids, and even a few additional advantages, such es a lower ffiewet^ for Improved puapebility requiring lees horsepower, gut In feet, Theralnol 55 sad 66 are not flre-reeletant to the excent the Theralnol FR fluids A ('-/u yy itl were, and due consideration must be given this fact 1reconverting to these Theralnol fluid#. iCJ +.UJMJ Conversion fro Theralnol FR `eyaram to s Theralnol 554#6 *iaBa will be a relatively slaple, low-cost procedure In the meet majority of cases. In ' corporation of proper fire protection equipment will be the only consideration HONS 079643 . Monsanto WATER_PCB-SD0000064202 i of any major consequent^ Sue even chi modification becomes eeademie, for with the discontinuation of Thermtnol FR fluids, fire protection equlpnent becomes necessary for any and all heat transfer media available today, A since the Thermlnol FR fluids were unique in their fire-resistance. ib This bulletin la to aaslst you in making the conversion to Thermlnol 55/4# as quickly, efficiently end economically as possible. Should queetlons arise, or if you run Into difficulty, Monsanto's Specialty Products Croup invitee you to cell upon its staff of qualified systems engineers for con sultation at any time. Call... (314) 694-1000 collect, and aak for a Monsanto Heat Transfer specialist. Thank you. I HONS 079844 WATER_PCB-SD0000064203 Thennlnol 55M4 and Your Host Transfer System Table I. shove the typical physical, chemical end thermal properties of I'll*. ,, i .-f 4(r j, Thermlnol FR-l,jmd Thermlnol As you will note, the'eh&^products are quite similar except v^th regard to AIT, Fire Point and Height per Gallon. The substantially lover weight per gallon of Thennlnol 66 means that pumps used ,, skf-U t*J in a Thensinol FR-l system 4-H be mess then adequate for a TherlnolA66 system. most eases, pumping rates will be Increased with a re sultant saving In horsepower requirements. Thensinol,66 ha .-tearis,heat transfer properties ^ ( 7r in rl fl il fmn Li` n n -- In a change from Thermlnol FR-l. The specific heat and thermal conductivity of Thermlnol 66 are shown, along with other physical properties. In Tablet^. The lower pour point!of Thermlnol ^66 siliXesttfrthe system,t r4tt S3 lJU Generally (peaking, then, a veil designed system currently operating on Thermlnol it~ FR-l can be converted to Thermlnol 66 with few. If any, basic changes In da- A sign -- end without sacrifice to heat transfer efficiency. With the similarity of the heat transfer properties of theJei<'fluids thus established, let us turn to the important differences between Thermlnol FR-l end Thermlnol namely, fire-reslsteace and oxldetion-resistance. (,C ! Flrs-Raslstaacm As stated Is the Introduction to this bulletin, the Thermlnol FR fluids were unique la their inherent flre-reslstaaca. Mo other commonly used heat transfer acdltai could be.se classified. Even so, the Thermlnol FR fluids could be made to burn under certain conditions, ea Indicated by their AIT of something around 1200F. -1HONS 079845 WATER_PCB-SD0000064204 7^^/T 2 I THERM1K0L FR-1 VARIATION OF PROPERTIES WITH TEMPERATURE Tempe rature Density Specific Hfc Thermal Conductivity Viscosity > c lt/ 1 Bis/3 mu/it Bcal/kfc *v c BTO/ft Kcal/n hr *F hr *C cp 50 10 11.68 1399.6 0.272 100 38 11.46 1372.7 0.282 150 66 11.22 1343.7 0.291 200 93 10.99 1316.7 6.3047 250 121 10.76 1289.1 0.3151 300 149 10.53 1261.3 0.3255 350 177 10.30 1233.5 0.3359 400 204 10.07 1205.8 0.3464 450 232 500 2^0 9.83 1178.0 0.3568 9.60 1150.2 0.3672 550 268 9-37 1122.5 0.3776 6oo 316 9.14 1094.7 0.3880 650 343 8.91 1066.9 .0.3985 700 371 8.68 1039.3 0.4089 0.272 0.282 0.291 0.3047 0.3151 0.3255 0.3359 0.3464 0.3568 0.3672 0.3776 0.3880 0.3985 0.4089 0.06098 0.0907 0.06060 0.0902 0.0602J O.O896 0?Q397* 0.0089 0.05927 0.0882 0.05&75 0.0874 0.05815 0.0866 0.0576< 0.0857 0.0569i 0.0848 0.0563( 0.0838 0.0556c 0.0827 0.0548 0.0017 0.05405 0.0005 0.0532 0.0793 308 23.2 6.6 3.4 2.3 1.4 1.0 0.8 0.6 0.5 0.4 0.4 0.3 0.3 Cs 220 16.9 4.9 2.6 " 1.8 1.1 0.8 0.7 0.5 0.4 0.4 0.3 0.3 0.3 vapor Pressure msnHg Kg/cm2 absolute - --- -- --10 0.0136 27 0.0367 65 0.0884 143 0.1945 291 0.3958 550 0.7480 l8.8psla| 1.3218 31.9pslaj 2.2429 WATER PCB-SD0000064205 THKRHIHOL 55 VARIATIONS OP PRomiTIlS MITH mpEMITTOH Tepemtuw Density Speclfio Heat Thermal Conductivity Vlecoelty f c lb/ Kg/3 bto/14 Keal/fcg BTO/ft Seal/ Cp mi r c hr *F hr ; C o -18 .7.62 100 38 7.31 200 93 7.00 300 149 6.69 400 204 '6.39 500 260 6.07 6do' 316 5.76 915 0.420 8?8 0.472 84o 0.522 003 ' 0.572 766' 729 0.620 0.670 691 0.71 0.420 ' 0.0813 0.1210 1472 1610 0.472 0.0784 0.1167 25.4 30.1 0.522 0.0753 0.1121 4.20 5.0 0.572 0.0724 0.1077 1.69 2.10 0.620 0.0692 0.1030 0.904 1.18 0.670 0.0661 O.0984 ' 0.583 0.80 0.718 0.0630 0.0938 0.415 0.60 Vhpor Pressure mmm Kg/c2 absolute - .5 3. 10 ho _ 100 -250 `. 0.001 0.004 0.014 0.054 0.136 0.330 .Xr * .e* ' V moms 02984? 11__________________________ _______________________ WATER PCB-SD0000064206 rc c THEBfUISOL 66 VARIATION OP PROPERTIES WITH TEMPERATURE Teape- ntan Specific Heat Theraa1 Conductivity Viscosity Vapor Pressure w c 14/ gal BTO/lt Keal/kg r c 6 tt.6? lo4o o.^o"" o.3io 50 io 8.51 1020. 0.350 0,350 100 38 8.34 1000 0.380 0.300 150 66 8.14 975 0.405 0.405 200 93 7.91 950 0.430 0.430 250 121 300 149 7.7? 7.59 930' 0.455 910 0.480 0.455 0.480 350 177 7.39 885 0.505 0.505 400 *04 7.17 860 0.530 0.530 450 233 7.04 840 0.555 0.555 500 ?6 550 >88 6oo. Jl6 6.75 6.62 6.42 810 793 770 0.580 0.605 0.630 0.580 O.605 0.630 650 .700 J43 6.24 2I1_ 6,99 .. 750 0.655 0*655 739- 0.680 1 0.680 00 RR 0 1 re BTO/ft Kcal/a hr *F hr *C 0.0720 0.0711 0.1058 0.0703 0.1046 0.0695 0.1034 0.0687 0.1022 0.0678 0.1000 0.0670 0.0997 0.0662 0.0985 0.0653 0.0972 0.0645 0.0959 0.0637 0.0948 0.0628 0.0935 0.0620 0.0923 Cp Cs 62000 50000 255 28.0 250 28.0 9.75 10.0 4.18 4.40 2.42 2.60 1-55 1.70 1.06 1.20 0.77 0.90 0.58 0.45 0.69 0.55 0.36 0.46 0.34 0.27 0.20 0.44 0.36 0.20 anHg absolute 0.1 2.0 20.0 50.0 100.0 200.0 350.0 760.0 IOOO Kg/ca^ 0.003 0.027 0.058 0.136 0.272 0.476 1.034 1.360 & 00 HONS 079048 WATER PCB-SD0000064207 udi to emphssltt that, although ThnainolK66 jSfcertalnly Uii l J * jf* fire-reiisttnt than tharralnol FR*4, K Should be viewed in that pertpective} nd--aat--la^'fl tenable". On a seals of flrs-reslstance vhara watar would he raced aa "0" and ether "100"; Thenalnol FR-1 would be rated "3", and Therxlnol % S 66 would fall eonewhera between "15" and "20". it la Important to realise that Thermino*! 66 Sr'ltt* firs-raalstant chan Thenalnol FR-1, and to modify the heat tranafer system accordingly: It la equally Important to understand that Thenelnof`*66 not volatile, highly flaanabla fluid)JJL Hi by* f/Y* a*-/ Protecting the System There are two major fire protection consideration In changing to Thenalnol /'/' 66 -- system leakage and possible tube rupture (In the heater). The former la actually part of the larger subject of good system maintenance, and should be considered regardless of the heat transfer medium employed. A tight, veil- maintained system la usually a good, safe systeml Following are some specifle J*e- rseossaendetlone to prevent leakage when yen convert to Thermiool 66. e. O - \ rirtt. If your ijritn hC*fsnothinicsi ialiy you should enclose thta, s* s._ _ _ or st leeat provide a drip pen with a drain to a collection Sump. Canned and sealless ptnps offsr excellent protection against leakage. The beat way to prevent piping leakage la to weld all connection#. Where you must have acceaa, use raised*face flanges with appropriate gasketing end high*temperature bolt# Controli4 piping leaks is especially Important, since fluid*soaked insulation poses a more serious hasard then the leaking fluid, Itself. . -2- HONS 0798*9 WATER_PCB-SD0000064208 J Organic compound# auch a* Th#rmlnol^66 appaar- tn frait> ( glow exothermal, oxidation reaction with tha air trapped Inside the voids of the Insulating material when system temperatures reach about 500f. Saturated Insulation offers a large fuel surface In the face of poor heat dissipation conditions, and this, along with-possible catalysis fron the Insulating material (magnesia, silicate-bonded asbestos or calcium silicate) can causa a temperature build-up ,, in the mass. This temperature build-up can m.C J of the flnll i--1 when the space between the piping and the saturated insulation la exposed to air.(i,e., should the Insulation be broken for repair, etc.)# This phenomenon la not fully understood, but appears to occur less with closed cell Insulation then with the insulating materials mentioned above. Closed cell materials, then, are preferred, especially where leakage Is a possibility despite all precautions. The principle problems areas are near' connections, valve packing glands, flanges, and wheeavge ineulatlen ensaete-liui'Tflmtit f^at-furioeesr-euch' "W. aa_liooa-plaeaa. Jo J/ < / /rrL. . To obviate this problem, eliminate any source of leakage promptly. Replace leaky gaskets, re-pack valve stems. Cover Insulation where leaks might occur with a hydraulic-setting, oil-resistant cement. In stall valves, where possible, with the stems in a horlaontal position so that leaks will drip away from the Insulation. And sgaln, use closed cell insulating materials on suspect piping areas. -3- M0N5 079650 WATER_PCB-SD0000064209 Tube Rupture In Fired Heaters Generally speaking, where fire protection is concerned, it is best to consult your insurance underwriter for guidance and oounsel, Likewise, you will want to discuss your fire safety equipment requirements with suppliers^ia^^^Set^*, _ Selection and sizing of fire protection equipment ase Vr^tTaalT'^ ^ %t-jic ^ 'J'Aa. t * /**> . In the case of tube rupture in fired heaters, we recomend jibe piping Mt* either steam or C02 aa a snuffer into the com- bustlon ohaaber of the heater. A minimum ne-inoh line with a remote manual valve for activation sheald a fire erupt internally Is the preferred arrangement. This snuffer system oan be automated by the use of an exhaust stack temperature switoh. This swltoh would energize, a solenoid valve^upon excessive temperature rlse^!floodi*m%he ohamber wi It is advisable to set the temperature switch about 100?. over the normal exhaust temperature to prevent nuisance shutdowns. If a steam snuffer system is used, it is a good idea to employ a steam trap to avoid slugging the combustion ohamber with water when the system motivates, or is motivated manually* Tou oan obtain a baaio guideline In the selection of C02 proteotlon equipment (again, It is best to consult your lnsuranoe underwriter) from the National Fire Proteotlon Assn,, HONS 079851 WATER_PCB-SD0000064210 Booldet Number 12, dated 1963 In this publication, It Is stated that a minimum C02 conoentration of 46 In the oombustlon ohaober will extinguish a Thermlnol fire. A The following table will be useful in determining the volume of COg required! Volume of Combustion Chamber - Cublo Feet Caloulated Quantity* Temp. Corrected** C2 Pounds C02 Pounds 0-140 141 - 500 501 - 1600 1601 - 4500 15 30 15 30 53 106 150 300 * Caloulated quantity of C02required to maintain 46Jt conoentration by volume at temperatures of 200?. ; X4.I' or less* , ** Temperature oorreoted quantity of COg required to maintain l*6% oonoentratlon by volume at temperatures of 700?. (Rule of thumb! lnorease volume of COg 8? 1% for every additional 5?. over 200?*) COg oyllnders are available from Cardoz Division of Cheaetron, Chisago, Illinois* Standard sizes available and approximate oosts arm as followsi CO2 Pounds Cylinder Slue Single Automatic Double Automatic 50 $410 $610 75 $460 $710 100 $650 $980 These units and prloes lnolude drawings of the units* fully*. M0NS 079852 WATER_PCB-SD0000064211 oharged cylinders, flexible piping conneotors, spray nozzle, pressure switch, alarm and automatic control. provided C02 release signal is supplied b cuitoner devlos. Piping, wiring and installation labor is provided by the customer. Recharging of cylinders is available at a cost of $15.00 to $25.00 from a variety of "Plre St Safety Equipment Suppliers" listed in the Yellow Pages of your phone book. In the normal installation a single cylinder would be released to extinguish the fire, with a second unit available as standby. The second cylinder could actually be used for extended dis- ' charge to maintain maximum oonoentratlons, slnoe some 003 will obviously be lost by leakage from the oombustlon ohamber. This arrangement could prevent re-ignition while the heater Is cooling. The Baloiyf Fire Suppression System is a possible alternative to a GOg arrangement, and can be used in dosed spaoes with personnel in the area. Par less concentration Is required than with the CO| system, but the Halon^f system Is more costly to reoharge, faollitlem to do so art not as readily available, and the latter system im a "fire suppression" arrangement as opposed to a "fire extinguishing" system. Again, we strongly reoommend that the advice of fire proteotlon 00mpanlee be solicited In either case to insure proper equip ment seleetlon and installation. frabls** / shows the amounts of snuffing steam required in the - oombustlon chamber for control. If steam Is to be used rather than the other alternatives suggested above. HONS 079153 WATER_PCB-SD0000064212 ( 1000 lb./hr. Flgur / -- Eat of Stee Introduction in 1000 lb,/hr. MONS 07985* WATER PCB-SD0000064213 Orlrtatlon-Rcslatanoe <>-- With a ThermlnolA66 system, some provision should be made to preTent oxidation oaused by air oontaot at fluid temperatures exoeeding 200P. This was not the oaee with Therminol PR fluids, but must be observed for the newer-generation fluids. Oxidation o&n result In sludge formation, eventually leading to 4eeee carbonaoeous deposits on heat transfer surfaces Ut+mfijltilI Mr4**4*m A. fF'i'iM&tC 1 tank be blanketed with an inert gam*____A___________ A. ** _ _ VIAf thisA.L. i1 -_ Ais- not possible, 66 doer not require presuriration. lou oan design the cold seal arrangement quite simply by piping eemtaeti in the^vapor spaoe. In converting from Therminol FB to Therminol^66, it is Important to remember that many Therminol ?7l systems were designed with a hot bleed line Into the expansion tank to eliminate moisture aoouaulatlon. This bleed line should be a. rfjk. Therminol*^ system. Carbonaoeous deposits oan also oecur at the pump seal faoe due to leakage at high temperatures. The use of a sealgmemd flush system or a double meohanioal seal is helpful in preventing IN#*. '' HONS 079655 WATER PCB-SD0000064214 . F16 v/ C ^ SV6C/SS r*O fa A* &??**>**** 7~rtfStt.i r MOMS 079856 WATER PCB-SD0000064215 Sji E-miW) 5 T i--- ~ P'LL P COLD . . SEAL. I TAKLk PUMP X *??.. /c noA* J Svft/fi //.'^ fto cW 4 /i/t /3+*r*>trJ 'TDfhtZ '. /ks*'<tr~ *.* " HONS 079857 . WATER_PCB-SD0000064216 S' CONVERTING TO THERM INOL 66 With flre-proteotion and ozldatIon-rest stance procedure* well In mind, let u* turn to the natter of preparing the Thermlnol PR system t^aeoepV Therminoi 66. The aoat expedient procedure would be to simply drain and change the system to Thernlnoi 66f frlowever, expedience is not always the best alternative, and certainly not in this oase. Debris^ aoouaulated over the years in the system^dould cause eedous problems, especially to mtohanioal seals, rotary Joints, eto, heat .transfer systems should be dmslme* end cleaned from time to time as a part of normal preventive maintenance. Slnoe a fluid change is necessary at this time, it would seoa to use the downtime to^ol^a^Tjp the system ^S^startWfresh Vs woold strongly advise you Qgt to simply drain and change, but to take this opportunity to olean your system. Many potential problems will be preempted by so doing. Tht rthsr rssson for cleaning your system at this time is that ywgWisfc grgs^wrt a system oleaaout is the only sure way to do so. How to -go about the oleanout is a matter of choioe, but here are some alternatives for your consideration! v A. CHEMICAL CLBAMINQ . This method is particularly effeotlve-in oleaning heavily-fouled heating surfaces. HONS 079850 WATER PCB-SD0000064217 Cleaning eenrioe may be purchased from Dow Industrial Servioe Company or Halliburton...or, it may be done in-houae using OaJcite cleaning products or cauatio soda and soda ash. Consult the fellow Pages of your phone book for the above serrioee and suppliers. Cheaioal oleaning prooedure with oaustio soda and soda ash followst contact Oaklte for detailed information on their prooedure Chemical Cleaning - Cauatio Soda and Soda Ash 1. fill empty system with cleaning solution containing 5 lb. oaustic soda and 5 lb, soda ash per 120 gallons of water. 2. initiate circulation* and heat liquid to 10O*F. 3. circulate 24 hours, periodically drain fluid from a low point and replace with clean water. Do this until fluid in system le clear (about 24 hours). 4. When fluid in system is clear, raise temperature to 215*225*F, stop pump and heater. 5. Quickly drain system, open all vents, and allow residual heat to dry system. ' 6. Assure system is dry. ^ 7. Fill with Therminol fpiW setssSedT"66 , . May be desirable to pack pump with Teflon filled asbestos packing to prevent damage to oeohanioal seal faces. . . .. . HGNS 079859 WATER_PCB-SD0000064218 B, FLUID FLUSH CLEANING ' This 'eyoOea is probably the fastest and most effective where heating surfaoes are not heaTlly fouled, It also offers the advantage of hot having to Intro- duo foreign oheolcels Into the system. With this method, the system Is drained of Theralnel FH, refilled with Therm ins 1 I-*" i^HUTJlifUl^^-uey rtwu bfmeed). 66/ operated for a reasondle period of time', drained once again; and finally, ' xs*. rohared with fresh Thtminol 66, Both the drained Thermlnol FI and the Theralnol 55/66 used to flush the system may then be returned to Monsanto for disposal at so oost to you, assuring you of a PCB-free system* and a fresh start. 0. SOLVENT CLEANINO This method is satisfactory for cleaning a slightly soiled system* but ehlorlnated solvents must be avoided. Typleml solvents used are aoetone* benzene* kerosene and xylol. Do not use trlehlorobensene or perohloroehtylene. (CAUTIONt ALL SOLVENTS SHOULD BE COMPLETELY HEM0VED PfiOM TBS SIST PRIOR TO CHARGING WITH THERHINo*66) MOMS 079860 WATER PCB-SD0000064219 Fluid Disposal All drained Theroinol FR and Therolnol $5/66 flushing fluid should b returned to Mortsanto for lnoineration. This serrioe Is provided at no eoet to you, and assures proper elimination of PCBs from the environment. All tuoh material should be shipped tot Monsanto Company V. 0, Krumarioh Plant Sauget, Illinois ATTMi Supervisor, Dept. 246 Please make oertain that shipped materials are properly.identified. A As stated earlier, Monsanto maintains a staff of qualified engineers who will be available for consultation should you have questions or run into difficulties. The number to call, again, is (314)694-1000i ask for a Monsanto Beat Transfer Speelalisfc. Thank you. MOWS 079661 WATER_pcb-SD0000064220 J a THEHHINOL ' ^ SAF5TY OF HAJiDLIlIG Theralnol virtually nente%ie and non-Irritating, posing no special handling problems. not absorbed through the unbroken skin in significant quantities, non- irritaiing to the skin and only mildly irritating if eye oontaot occurs. Immediate flushing of the eye with copious amounts of water will avoid irritation or after-effects. It is suggested that Therainolv be washed off the skin with soap and water, as soon as possible after contaot, but no serious irritation should any other industrial chemical, Theralnol^ Handled like it quite safe to store and use. ' y^ieraln^?^J^_ are not dxngExsaslxxtoxlc, but may oause dlsooofort if coming off of heated fluid. There lo no vapor exposure problem when transferring the fluid from its shipping container to the heat transfer system. On the other hand, vapors emitted by Thernlnol^ te> (a heated to elevated temperatures may be mildly irritating upon prolonged exposure. In heat transfer installations, the fluid is used In a oloeed, unpressurized system free from leaks and with the expansion tank vent trapped so as to oondsnse any vapors. Consequently, there should be little or no opportunity for workers to come in isnzsl contact with vapors. -jp^nrfrfc'33tzrtayi~.re8r^rovrft?T-JjeL^^ HONS 079862 WATER PCB-SD0000064221 While Thernlnol posef no serious probleas with raspcot to the environment, as a conoerned supplier to industry, Monsanto urges the user to maintain a tight system, to oorreot leakage promptly, and to exercise oare in the handling and disposal of this and all other auoh products* A tight maintenance program not only protects the environment, but keeps employes oomfortscble, the working area clean, and the system running smoothly. HGNS 079*63 t WATER_PCB-SD0000064222 ^P V tT I tn V P THEBMINOI, FR-1 PHYSICAL PROPER TIES WATER_PCB-SD0000064223 VISCOSITY -- CUsTISTCXSS j(T ??" ' iaJEBMDK)L55 i ' PHYSICAL FB0PE5TIES WATER_PCB-SD0000064224 SPECIFIC KE/iT VISCOSITY -- CS'iTISTOXSS A" raESHHOL 66 I gIS?*fr VLUAie. i WATER_PCB-SD0000064225 Monsanto MONSANTO INDUSTRIAL CHEMICAL CO. 900 N imdbirgft Bouitvard St Louu. Musou" 93196 Phon* ;3I4) 694-1000 August rr 44 0 1 0J^CCUC CMCW/C .J V J; 19-3 Dear Sirs: EPA Proposed Rule: Polychlorinated Biphenyls (?C3's) Manufacturing, Distribution In Commerce and Use 3ans. On June 7, 1978, the United States Environmental Protection Agency ("EPA") published a proposed rule in 4 3 Federal Register oeg-ir.nir.g on page 24,802 covering Manufacturing, Processing, Distribution in Commerce, and Use Bans of Polychlorinated Biphenyls (? C 3'o 9. We attach a copy for your information. We believe that your company may have used Therminol' PR series heat transfer oils prior to their replacement by non-PCS f1.1 is. If adopted, the proposed rule, on its effective date, would tar. the operation of heat transfer systems containing resiiual PC3 concentrations above 50 part3 per million. Monsanto is submitting to the EPA the attached comments whicr. suggest and/request alternatives to the proposed rule and a specific authorization for the continued operation of heat transfer systems containing residual PC3 concentrations. Since there is very limited reference to PCS's in heat transfer systems in the proposed rule, we wished to ensure that you were aware of its potential impact on your operations. In the event that you converted systems from Therminol PR heat transfer fluids to our non-PCB fluids, Thermi'nols 55 or 66, continued . ^"Registered Trademark of Monsanto Company" umt ol Monsanto Comoiftv RIY 000073 * EXHIBIT ^ I IlfjmijD 1 Him1 rs I WATER PCB-SD0000064226 Page 2 August 7, 1973 we attach copies of methods for determination of ?C3 levels in these fluids. We hope that our comments will be helpful in your own assess ment of the potential impact of this rule. tmc enclosures Heat Transfer and Process Phone : 31^-69^-2623 RY 000074 WATER PCB-SD0000064227 :cmfa:;y .'jam 5U3 `ZAP,'{ Z. Reynolds Metals Company Reynolds Metals Building Richmond Virginia 23261 REV 000075 WATER PCB-SD0000064228 August 31* 1970 Hr. Bruce S. Huleher 5nvfronmen t&1 Control &kgnttr Reynolds Metal Company Richmond* Virginia, 2321$ Dear Mr. Huiehtrt . four letter dated August 20* 2970 addressed to Mr. Donald Olson was forwarded to oe for response since 2 have been given the responsibility for studying the PCS environmental*-. problem. i We do not have speciflo research data on the persistence . ' of Pydraul products in the environment but w have studied the PCB'e that are principal components in Pydrmuls. Our studies to date have confirmed our suspicion that the higher chlorinated biphenyls are more persistent than those containing lea* chlorine. Because of this persistence we strongly recommend that liquids containing PC be kept away from water systems, e.g. sewers* creeks, rivers, lakes, etc. Pydrmuls which are no longer usable should be destroyed by incineration at tes^eratures exceeding 800C. Stack gases from the incineration must be scrubbed and neutralised to prevent HGl from escaping to the atmosphere. If indn ration facilities are not available, you may wish to send the scrap liquid to Monsanto Company, W. 0. Kruamrich Plant, sauget, Illinois, Attention Supervisor Department 246. Ito# cost of incineration has been tentatively set at 3 cents per pound of material received and does not include freight and container costs. 5 DEFENDANT'S DEPOSITION i EXHIBIT ' fXp^O^OrO^L 31 75iirHC^rr RiY 000395 WATER_PCB-SD0000064229 a- Water contaiminated with Pydraul should be treated t remove the free Pydraul and finally passed through a bed of activated carbon to lower the PCB content to leas than 10 ppb. . Solid contaminated with POT should b segregated from other plant waste and burled in a properly operated landfill located away from water bodies. . Tht disposal methods described above apply specifically to Pydrauls formulated with persistent PCB'e. As you probably know we are reformulating our Pydrauls to reduce . the persistence problem.. Some reformulated Pydrauls are now available with othezs scheduled for availability within the next few months* Regarding your request for a list of firms marketing fire-, ' resistant fluids, it appears that because of the number involved, 20 30, you might achieve your objective more 7 quickly if you refer to those firms with which your purchasing organisation normally transacts business* I have enclosed copies of technical articles related to the PCB environmental problem which you may find helpful* If i can be of further service, please let me know, ' Slnoerely, /Jk Enclosures CCt Mr* Donald Olson Monsanto Gop^any BCC: N. T. Johnson W B Fapageorg Manager, Environmental Control RY 000396 WATER_PCB-SD0000064230 MONSANTO'S PCB PROGRAM W. B. PAPAGEORGE Presented at ANSI Committee C-107 Meeting - September 14, 1971 I appreciate the opportunity to share Monsanto's PC? experience with you and I hope the Information I have can help'this committee plan end achieve its objectives. We at Monsanto first heard of PCB'a as potential environmental contaminants In early. 1967 when we received copies of a talk given*ln 3weden by professors Wldmark and Jensen of the University of Stockholm. In their paper they described how they were able to identify a material which had been interfering with pesticide analyses as being polychlorinated biphenyls. < Our la! boratories began work on the development of analytical methodology to confirm that PCB'b Indeed were being round In the environment. During 1968' and 1969 as methodology improved the evidence continued to indicate that the higher chlorinated biphenyls were being identified in the tissues of fish and birds. During this period Monsanto mounted an extensive program aimed at acquiring more knowledge about PCB's and their effect on the environment. We perfected our analytical methods, we started" S animal toxicity studies, began biodegradation work and evaluated alternative materials for thoee applications we felt were con tributing substantially to contamination. HONS 041633 WATER PCB-SD0000064231 -2- Our animal toxicity work was Bimilar to the type we would have undertaken if we had wished to. have PDA approval for food uBe. Chronic toxicity and reproduction studies were made on leghorn chickens. Two year chronic feeding studies were started on rats and dogs. Three generation reproduction studies were made on rats, * The PCB's used in the tests were Monsanto's Aroclor 1242, Aroclor 1254. and Aroclor 1260. These were selected since .they represented 5,, the more commonly used PCB mixtures. The animals were fed con centrations of 1 ppm, 10 ppm and 100 ppm in.their normal diets, , The results to date Indicate that at the levels used the rats C -J and doge showed no effects with Aroclor' 1242. At 100 ppm both the rate and dogs exhibited decreased weight gains and enlarged ' livers. The chickens were affected by Aroclor 1242 at the 10 ppm level. The hatchabillty of the eggs was significantly reduced. ' To summarize what I've said about Monsanto's sponsored animal toxicity work the- highly chlorinated polychlorinated biphenyls at 100 ppm In the animal diet doers have some errect on mammals. The lower chlorinated polychlorinated biphenyls at 10 ppm in the *' diet some effect on leghorn chickens, and I say speciflcallj- leghom chickens because there is mounting evidence that there X are definite species variations as determined by the Pautuxet Laboratories here in Maryland with four types of wild birds. There is a species variation noted which frustrates many scientists HONS 041634 WATER PCB-SD0000064232 -3- I was asked what we know about the effect on marine life, Monsanto did sponsor static fish toxicity work and we were completely frustrated because these PCB's have the tendency to plate out on surfaces. Our information was garbled because in the static testing we were really exposing the fish to PCB environments a lot less than we thought we were. The data was so distorted it was meaningless. In the meantime, we found that there are many competent laboratories looking at fish and the effects on fish that we decided that maybe this is an area that is best left to the experts. . - ; ,r We have been in touch with laboratories such as the. Water Quality Laboratory of Duluth, Minnesota. They have conducted studies which indicate there in some effect on some species. There has been some work done in the Columbia, Missouri Bureau of interior Fish-Pesticide Laboratory which indicates, for example, magnifi cation about 50,000 times. By that I mean that the amount of PCB detected in the fish tissues was 50,000 times that present in the water environment in which this fish was exposed, . There have been reports of fish kills and some very drastic effects attributed to PCB'a. I've tried to get evidenoe that these .things have occurred. I have not been able to confirm < any reported incident. ' ,/ We have talked with scientists at the Qulf-Breeze, Florida Commercial Fisheries Laboratory, They have conducted studies HONS 041635 WATER_PCB-SD0000064233 4 ~ with crab and shrimp. This is the laboratory that did detect a build-up In crab and also the lethal effect on Juvenile shrimp. Very, very low concentrations - 5 ppb in the water - do destroy Juvenile shrimp. - There is a growing thought among many of the.responsible scientists that this environmental problem is most complex and it 1b not really any one insult that is the demise of any particular species, but it could be the cumulative effect of all insults a creature :. is exposed to and usually the last Insult is the one that gets blamed.. Dr. Tom Duke of Gulf-Breeze ia a proponent of this tf theory and he is conducting studies to substantiate, this. It could<be the lack or presence of oxygen, the lack or presence of proper nutrients in the environment, the lack or presence of the proper temperature conditions, the exposure to a DDT or a cadmium or a mercury or an arsenic, and along comes a PCB and the fish dies. PCB might get blamed. This is the kind of thing-that does happen in the environment. There Is a growing concern that we should be considering to a greater degree chronic effects of all these materials rather than relying on the old acute studies that used to serve as a screening*' for many, many chemicals. I have sketchy data on marine life. We know that It does build up in the marine environment and ' there is, of course, the published evidence that it does affect the fish eating birds. HONS 041636 WATER_PCB-SD0000064234 { There Is some indication in the Duluth studies that reproduction and survival of the frye is affected. There seems to be minimal affect on adult fish. It was suggested earlier that I might want to review the manufac ture of PCB's, the many applications in which it was used and what our present program is. To the best of' my information, it was 1929 that these materials were introduced as very attractive fluids for use in transformers, and there are many In this audience J. that are more familiar with this development that I am. PCB's were used in transformers as an insulating cooling .fluid because tr they are more resistant to breakdown, less apt to explode and burst-into flames and cause property damage and human Injury. : Through the years, additional uses were found for these materials because of these properties that I mentioned earlier. They gradually at first, and of course with increasing amounts, ended up in applications that Monsanto through its in-house usage 1 referred to as plasticizer usages. That is not a very good description, but 4.t fit our needs for many years, and you'll find us using that expression. These are uses such as in paint formu lations, the specialty Ink uses, the plasticizer in sealants, *' adhesives, and paper coatings or all sorts. 'y There was a use that was a real thorn in our side and you'll see at least some of the earlier articles on PCB.'s referring to pesticide use. There were some studies conducted by the Department of Agriculture in which PCB's were used to extend the effect of ! f HONS 041637 WATER PCB-SD0000064235 -6 - Ufa of pesticides such as lindane, It was never intended for broadcasting as we.visualize DDT was on food crops, cotton crops, or orchards. The only widespread use that I could find was a limited trial to help prevent or curtail the dutch elm disease, and that proved to be a failure. The other uses were extremely small in private formulations that were used to spray or coat hard surfaces - shelving, corners or floors and all for the typical crawling type insects such as the roach and sllverflsh. In fact it was so small that .Monsanto did not market directly to pesticide formulators) we gave this business to Our distri- , <* butors. On the other hand, this use did cause considerable emotion and was used by some to explain the-presence of FCB's in remote areas. We wrote to the Department of Agriculture suggesting that during 1970 when pesticides were being re registered that PCB's not be approved. .Finally in October they did put out a notice to that effect. We have had questions raised, "is it in my shower curtains at home?.' Is it in the draperies? In the Carpeting?" The answers to those is "not very likely". And 1 use those words because we really don't know. If it was put into these applications. It was so small we, Monsanto, were not aware of it. It was not used in automobile tires] it was not used in brake linings, Other major uses Include the use in hydraulic fluids which are fire resistant. Monsanto marketed these fluids under its trademark Pydraul, I am sure some of you remember the Livonia, HONS 041638 WATER PCB-SD0000064236 -7- Michigan fire? This was a disastrous fire in termB of property damage and was really a high mark in terms of convincing industry that there was a need for fire resistant hydraulic fluids. But the application is not the type that is maintained to a degree where everything is leakproof. Many of these connections leak, hoses burst, and the tendency is to keep producing by adding more fluid. So it is conceivable that many of these hydraulic fluids ended up in the sewer. I do not intend to criticize the customers of our products, From the knowledge that we had at. that time of the material the practice was considered acceptable, ,* Another fairly widespread application of PCB's is the use of these iflulds as a heat transfer media to achieve high temperatures, have a fire resistant transfer fluid, and avoid the Installation of high pressure equipment. These materials were ideally suited for this application. We thought at one time that these were adaptable to close control and proper maintenance where we could logically call them closed systems. Some recent evidence indi cated `that we were wrong and I'll get into that when I discuss , our present applications. One. application that was a fairly significant one and one that ' In our thinking is associated with coatings is the use in car bonless reproduction paper.Vith the emphasis on recycling paper.-' wastes and with the persistence of PCB's there Is a problem developing in that PCB's are being found in many paper products and many of these paper products end up in food packaging, MONS 041639 WATER PCB-SD0000064237 Initially the evidence we were getting seemed to point to the higher chlorinated materials as environmental pollutants. As soon bb we were aware of this, we. sent a letter to all of our customers telling them that what little we knew indicated that these materials could be an environmental problem, and care should be exercised in handling. When the results came in on our chicken toxicity studies they Indicated that the lower chlorinated materials might be a problem regarding birds. We decided, as a company, that we better place some restrictions on these materials because there were to us some uses that deserved to be kept in spite of the problems that Wfe saw facing us, t * We decided that we've got to get out of those applications where we felt there was no earthly chance or it was beyond our ability to control the introduction into the environment, so we got out of all the so-called plasticizer applications. August 30, 1970 was the targeted effective date. We then went into-a very active program of reformulating the hydraulic fluids. There!again, it required a lot of testing. We had to run these new materials through the Underwriters Laboratories for approval on fire resistance. They had to be compatible with the machinery then in use. This is not easll'y X done, but it was done. ' We decided that we could and must continue to supply the trans former manufacturer, the capacitor manufacturer, and at that HONS 041640 WATER PCB-SD0000064238 -9- time closed heat transfer systems based primarily on our concept that fire resistance was important in heat transfer. To pick up the point that was raised earlier about foreign im ports, we are to the best of our ability trying to monitor imports. To this day, we have no Information that any.have arrived in this country. On the other hand, we are getting some reports that some of our former customers have made inquiries of the foreign producers. I am also told by some Canadian provincial 5_ agency people that thpy had heard and were going to further investigate that PCB's were entering Canada.and from there ,r moved .into the United States. I have talked to representatives of the Japanese producer, the Kanegafuchi Company., and I am led to believe that they are most reluctant to enter this business. On the other hand, the Japanese producers are the producers that are being accused of entering the U.S, market. X have talked to representatives of the French companies. They assure me that they don't want any part of this business. In May, 1970 Congressman William Fits Ryan Introduced a proposed bill which would In essence place into law the very things that Monsanto had proposed doing on a voluntary basis. The bill provided that PCB's be banned except for those situations where the Secretary of HEW would give special permission or license. We went through the latter part of '70 and early part of this year feeling, however, that we were still walking on thin ice. HONS 0416^1 WATER PCB-SD0000064239 t But we thought that we had made some tremendous strides in the right direction to preserve those usea which we thought were essential while eliminating those uses which were grossly con taminating the environment. This summer our hopes of control in the heat transfer business vanished when we found that a user of PCB did not appreciate the problem, did not 'maintain his equipment and created the recent chicken, egg, fishmeal problem. !_ Because of this incident. Congressman Ryan withdrew the first ' bill that was submitted .and has now placed before the same com mittee a bill which totally bans PCB and does not provide for any use whatever. And there are, of course, penalties for the marketing, manufacture, or use of PCB in this country. A very drastic measure which does cause or can cause a lot of concern among.those of us who feel that PCB has a place in our society under proper conditions, As a result of this incident, we were forced to ro-evnluat* our position. We decided that,although heat transfer systems could be closed units, we are still at the mercy of the attitude of the operator of the equipment and we continuously faced the. situation where even a pinhole leak can oreate tremendous pro blems before it can be discovered. So we have taken, again, ' an arbitrary position and informed all of our customers in the food (whether it's animal or human food)j packaging business, and the pharmaceutical business, that we will no longer supply them heat transfer fluids which contain PCB's. HONS 041642 WATER PCB-SD0000064240 11 In addition, we will no longer market to any new heat transfer applications. Our efforts will be concentrated on reducing those that We market today. This business should decrease as time goes on. - To get back to legislation ... as many or you probably know, there is before Senator Phillip Hart's committee a bill referred to as the Toxic Substances Act of 1971. The purpose of this bill 1b to prevent the introduction into our society of hazardous materials. It also provides"for the review of materials now in our society and the curtailment of the use of the more hazardous t* ones,, Initial hearings were held in August, to which a select few individuals were invited to testify. PCB waa brought out a8 an example of a material Introduced into society and thought at one time to be most valuable, but 1b now considered a serious threat to all of us. The meetings will be resumed in October; I do not know the exact date as yet, and I'm led to believe that this would be the opportunity for industry to speak up in its behalf. .1 am assuming that since PCB's were brought up as an example of the type of substance this bill is supposed to prevent that Monsanto as sole producer in this country will be either Invited or we may choose to ask to be invited (we don't know at this point Just what is the proper approach here) to speak on the merits of retaining PCB's in transformers, capacitors and fire resistant heat transfer systems, non-food applications. MONS 041643 WATER PCB-SD0000064241 12 I mention this hill because It is our opinion, and we could be wrong, that rather than act on Congressman Ryan's bill, which is specific toward PCB's, we suspect that the Toxic Substances Act will have in it provisions which will refer to such materials as PCB's, We feel we have good technical data to Justify our staying in the business for limited applications. But we cannot overlook the emotions that have set in. And believe me there are many and they are deep. It is difficult to combat emotions, as you know, _and the references in the popular press to hazardous poisons and birth defects, which have not been substantiated, are most difficult to overcome. Although we talk about per sistant versions of PCB and degradable versions of PCB I sus pect, and this is a personal opinion, that there would be many who Jut st discount* this kind of Information. This la a very real problem; in my opinion it is a difficult problem. As a little* more background let me describe what I understood from a meeting we, held last week with representatives of the Food and Drug Administration. It is my personal opinion that the Food and Drug people are as conscientious as can be in trying to cope with the PCB problem. They are objective people trying to work with a minimum of data, I suspect they are as frustrated as any group of people can be as to what is the right way to go. There are tremendous pressures on the Food and Drug people today as well as the Department of Agriculture brought about by critics. HONS 041644 WATER PCB-SD0000064242 I These agencies are trying to objectively cope with the problem and at the same time trying to somehow live with these pressures that are being applied. . The PDA people really don't at this point in time have much infor mation that will lead them to a regulation as to how much PCB should be tolerated in food. They have established some guide lines based on what little Information they have from their own laboratories and the information that Monsanto has shared ' :_ ' with them. The PDA will permit fish at 5 ppm on the market- place;- milk at .2 ppm or less; eggs .5 ppm; -pountry- (they have a double standard) 5 ppm in the fatty tissue and 5. ppm in the muscld tissue, ' Another problem that is disturbing to the FDA> is the recycle paper problem. The cereal boxes, the cracker boxes, all of r these boxes that are made from what is known as chipboard, t are made from recycle paper. Fairly high levels of PCB'8 are being.found in this recycle board. It probably comes from about three or four different sources. It may come from some ink application in the past, some adhesive application, some coating application, as well as the carbonless reproduction paper appli cation. There have been some pilot studies made by the American Paper Institute to isolate the carbonless reproduction paper' from' the recycle batch. They still found PCB'a in that batch. They are probably looking at maybe the second or third genera tion of recycle. And with the emphasis on recycle, I cannot see any way out of this dllema except that there will be more and more PCB1s in these cartons. HONS Cm 645 i WATER PCB-SD0000064243 14 A thought we must all keep In mind, too, Is that we've got to live with the PCB's we Introduced into the environment for the past 40 years. They have not disappeared overnight} they will not disappear overnight*. We do not have any tests that tell ub how long it will take. We can only made an educated guess and we might Bay they will be out there for another'generation, 25 to 30 years yet, Hopefully, it will be a decreasing amount as time goes on. 1. Monsanto haa conducted,biodegradation tests on its products. We have three programs that are now active. One program we are conducting in our laboratories in Ruabon, Wales in- which we are making what 1 would refer to as scientifically basic studies In terms of which isomers are most degradable and with what type of microbe. ThisIs a little bit on the impractical side at this point in time.We have as a consultant, Professor Charles Evans of Bangor University in South Wales, who is a noted authority worldwide in this kind of activity. He has isolated at least three microbes that seem to thrive on polychlorinated biphenyls. These microbea he developed from soil that he obtained from his garden. What this tells us is that there are microbes out there t. in the environment that will eventually destroy these materials. In the St. Louis area, we have two types of testa going. One ^ is the use of river water with its normal biota in it, in which we introduced these polychlorinated biphenyls and look for the disappearance rate. It is a very quick and rather unsophisticated type of study. The other type of'test is the one that simulates HONS 041646 i WATER PCB-SD0000064244 - 15 - those conditions which are apt to be found in a normal municipal sewage treatment plant. It's an aerobic teat using an activated sludge from a St. Louis waste treatment plant. As a standard, we use a soft detergent 'because it .is well known to other laboratories. What we are doing, really is using our expertize that we established back in the days when the hard versus soft detergent controversy was quite common. And we are using these soft detergents that do degrade as our controls and comparing the PCB's to these con trols. The studies so far show that there are isomers within each of these mixtures -that do degrade. The lower the chlorine level/, the faster they disappear, the higher the chlorine level the more resistant they are. Which only confirms what many of a, us had suspected. We were not. too surprised by this data. . I will attempt to summarize ... I think we can conolude that PCB's.are in the environment. There is no question about it. Many of these PCB's are manmade and were introduced to the environ ment because of our lack of understanding of what these materials can d6 to the environment, In this country Monsanto, as sole producer, has attempted to improve the situation by limiting the applications to which these materials are used. studies today would indicate that these PCB's are not. and cannot be classified as highly toxic. There is still a lot of information */ that is needed to help us determine the long term erfect on human beings. We feel that the properties of these materials make them, at least as of today, the most suitable material for use in trans formers, capacitors and heat transfer systems. We also believe that under proper conditions we can control the amount of these HONS 041647 WATER PCB-SD0000064245 - 16 - that do enter the environment to the point where the adverse effects are not great and that the benefits we derive Tar out weigh the minor adverse effects that we might notice. Now there are many of us in the transformer and capacitor application that have made tremendous strides in controllng these materials. I suspect our objective is to further Improve our ability to control this material. In my personal opinion the emotion that is now prevailing regarding PCB's is something that we must contend with. Whether we believe in It or not, there :_ , are many people that sincerely believe PCB's should-be totally banned. } 0Ufa<*a *QHS WATER PCB-SD0000064246 DISCONTINUATION OF THETOHNOtf FK SALES * Would go to Vies Presidents/Businesa Group Direotore only plus Specialty Products aroup field sales/Regional Managers. 1. Q. 'Why has Monsanto decided to discontinue Therminol FR heat transfer fluid sales? A, We have previously written to all Therminol FR heat transfer fluid customers alerting them to the precautions necessary in handling and using these PCB-containlng products. Earlier this year we stopped selling Therminol FR fluids for new heat trans fer fluid systems. We also discontinued sales of make-up Therminol FR fluid to food-related applications and worked with these customers in converting FR fluid to non-PCB heat transfer liquids (e.g., Therminol 55 and Therminol 66), We have now de cided to discontinue all Therminol FR heat transfer fluid sales in the U.S.A, and Canada because there are serious problems associated with the possibility of accidental leakage of PCB from heat transfer systems. ` 2. Q. *Who within Monsanto decided to discontinue Therminol FR heat transfer fluid sales? A, This decision was made by Monsanto* s corporate management and affirmed by its Board of Directors at their monthly meeting in December, 1971 3. Q. *Does this action mean Monsanto is getting out of the heat transfer business? A, No, The sales ban applies only to the FR series of fluids (Therminol"' FR-Lo Temp, Therminol FR-0 and Therminol FR-l), The FR series _ is the only one that contains PCBs. All other Therminol heat trans- HONS 0*3A88 WATER PCB-SD0000064247 2- fer fluids (Thtnalnol 55, 66, 77 and 88) are PCB-free. 4. Q, *Are you banning sales of all Therminol fluids? A, No, Not all Therminol fluids contain PCBa. Therminol PR series (i.e., FR-Io Temp, PR-0 and PR-l) are the only ones containing PCBs. All other Therminol1* fluids (i.e,, Therminol 55, 66, 77 and 88) are PCB-free. 5. Q. *What replacements are available from Monsanto for Therminol fr fluids? A. The most likely Monsanto replacements are Therminol 55 or 66. We roust advise you that none of Monsanto's remaining Therminol heat transfer fluids are fire resistant. We suggest you v/ork closely with your insurance company in converting from Therminol PR fluids so that you make a carefully considered Informed de cision. As stated,in our letter of December 15, 1971, Monsanto has a team of engineers available to be of assistance to you in making your decision. They may be contacted by telephone at (314) 694-2514 or by writing Dr. Cummlng Paton, Monsanto Company, P.O. Box 14617, St. Louis, Missouri 63178. 6. Q, *What other fire resistant heat transfer fluids are available from Monsanto? A. Unfortunately we have none available and will not have one availa ble in the foreseeable future. 7. Q, *What other fire-resistant heat transfer fluids are available in the U.S.A. cr Canada? HONS 043<*89 WATER PCB-SD0000064248 -3" A. The only fire resistant heat transfer media we know of are high pressure water and molten salts. Both of these systems have dis advantages which may rule them out as replacements for many existing Thenninol PR systems. CD X> Could I obtain PCB fluids outside the U.S.A. or Canada? PCBs are manufactured in Prance, West Germany, Italy and Japan. The decision on imports is yours to make. We would suggest, however, you consider such a course of action very carefully. 9. Q. A, Will Monsanto'3. ban on PCBs for sale in heat transfer systems apply world-wide? Yes, as soon as the decision can be implemented. 10. Q. A. Will a world-wide ban on Thenninol PR sales go into effect immediately? As promptly as it can be implemented. 11. Q. Have any of your competitors in PCB manufacture announced a similar ban? A. Not to our knowledge. However, we believe they are considering restrictions on PCB sales. Bayer has already made an announcement to this effect. Furthermore, certain European countries (e.g., Sweden) have taken action limiting the imports of PCBs. Other countries could well follow suit. 12. Q. Why has Monsanto acted so precipitately on Thenninol PR sales? A. We do not consider our action precipitous. HONS 0^3^90 WATER PCB-SD0000064249 -4- 13. Q. Why la Monsanto giving overseas customers longer to convert than its U.S.A. and Canadian customers? A. Implementing a decision of this kind on an International basis takes time. 14. Q. This latest policy on Therminol PR sales is not consistent with Monsanto's previous differentiation between "open" and "closed" PCS systems. Why is Monsanto changing its policy. A, We are concerned about accidental leakage over which we have no control. Our policy ha3 not changed. 15. Q. By banning Therminol PR sales, is Monsanto admitting that PCBs are the toxic, dangerous chemicals that many scientists, ecologists and writers have been suggesting for over two years? A. The extent to which PCBs are toxic and dangerous is a relative and complex matter. We believe this aotion and our previous actions concerning PCBs have been reasonable and rational. We believe we have acted as reasonably as any manufacturer could on learning an increasing amount Of previously unknown information about one of its products. 16. Q, The FDA recently stated (PDA Press Conference September 29, 1971) that the alarm over PCBs is greater than the facts Justify. PDA also rejected an outright ban on PCBs as some critics have called for. The PDA does not believe PCBS are an imminent hazard. In view of these FDA statements why has Monsanto acted so precipitately in apparent contradiction of FDA? HONS 0^3^91 WATER PCB-SD0000064250 -5- A. We respect the opinion of PDA and are aware of it. The FDA, however, is not a corporation engaged in the manufacture and eale of products, and its ODlnion on this subject does not govern our decision. Again, we do not feel we have acted precipitously. 17. Q. * We do not dispute Monsanto' s reason for Its decision on Therminol PR fluids; our strong criticism of Monsanto con cerns the lack of warning by Monsanto that they were going to ban Therminol PR sales. Why were we given no warning. A. Our previous comrrunl cat ions should have alerted you to the possibility of this decision on our part. We believe warning's were given. We communicated our decision that no new heat transfer systems would be sold Therminol PR. Sale of Therminol ' PR to food-related applications was discontinued. In addition, we have encouraged remaining customers to consider converting to a non-Thermino1 PR fluid either before or at the time for the next "make-up". . 18. Q.* We believe it is impossible to oonvert all Therminol PR systems in the U.S.A. and Canada on the day your decision was received. That means heat transfer systems are still operating on PR fluid; why can't we have another drum or two to last until such time as we can shut down our plant for conversion? HONS 0<*3<*92 WATER PCB-SD0000064251 -6 . Monsanto believes that lee-way In the matter of filling Therminol1^ FR orders after Its decision was communicated could lead to stock piling, which we believe is unwise under the present circumstances. One of the key reasons for establishing a team of engineers at Monsanto is to give advice and assistance to aid customers in arriving at informed decisions on how to handle such situatior.3. Assistance may be obtained by calling (3l4) 694-2514 at Monsanto'3 St, Louis headquarters, 19. Q,. A. From recent PCB production figures given out by Monsanto, there are other applications besides heat transfer for PCBs. What action has Monsanto taken on PCBs in these other applications? Simply enumerate the actions. 20. Q , We see that dielectric applications are by far the biggest user of PCBs. Shouldn't they be the ones to be shut down? A , Based on the information available to us at this time we believe the risk of accidental escape from this use is slight. Our opinion on this may change. . 2i Q , I buy PCB for both dielectric and heat transfer uses. Why can I get one but not the other? A . Because, In our opinion, the risk of accidental leakage and possi ble resulting contamination is less in one U3e than in the other. mons o^93 WATER PCB-SD0000064252 "7 22. Q.* How long will the engineering team be available to help on conversions? A, We would hope most customers will have converted to non-PR fluids in the first four months of 1972. However, the engineer ing team supplements the ongoing team of Monsanto heat transfer fluid specialists. Monsanto's heat transfer fluid specialists are always available for reasonable periods to assist customers. 23. Q. Is there any possibility Monsanto's replacement heat transfer fluids may be discontinued as abruptly as Therminol FR? A. We do not consider our decision abrupt. We have no present plans for discontinuing sales of replacement fluids, but our customers should anticipate that we will react responsibly to new information about our products as we have with PCBs. 24. Q.* What evidence do you have that Therminol 55 and 66 will not give similar problems to the ones that have arisen with Therminol FR? A. We will send you bulletins on Therminol 55 or 66 which contain relevant data on this subjeot. ' . 25. Q. What is the attitude of FDA and USDA on Therminol 55 and 66 as replacements for Therminol FR? A. * WATER PCB-SD0000064253 -8 26. Q. Your letter of December 15, 1971 states that refunds on returned Therminol PR fluids will not be given after March 1, 1972. Does this mean I must convert to another fluid by then? A. The decision on when and. to what to convert is yours. The re fund policy applies only to unopened drums of Therminol FR you may be carrying as inventory in your warehouse. 27. Q. I Just filled my TherminolFR system in early 1971. The fluid is in excellent condition and could probably be reclaimed by Findett to be as good as new. Will you allow me credit if I return the drained fluid by March 1. 1972? A. No. 28. Q. Are you banning TherminolFR fluids because Monsanto admits liability In the HoliyParma lawsuit? A. We admit no liability in the Holly Farms lawsuit. We point out that Holly Farms sued the user of PCS heat transfer fluid as well 29. a. as Monsanto. I have read of the Holly Farms lawsuit against Monsanto. Have you other lawsuits pending on PCBs. If any, what are they about? A. Questions concerning lawsuits should be directed to our Law Dept. 30. Q, Does Monsanto know of any cases where plant employees have suffered Illness or harm because of PCBs and Therminol FR in particular? A. . rtONS WATER PCB-SD0000064254 -9- 31. Q. What should I tell my employees if they ask why we are switching from Thenninol FR to a more hazardous fluid as far as fire safety is concerned? A. The decision is yours. Perhaps you might indicate that the material is no longer available. 32. q. Does Monsanto consider PCB to be a toxic and dangerous substance to humans and wildlife? A. The question is not susceptible of a simple yes or no answer. We can refer you to scientific information from which you may draw your own conclusions. 33. Q. Monsanto has made great play in its press statements on the safety aspects of PCBa with respect to their use in dielectrics. In heat transfer, we chose Thenninol FR solely on the grounds of safety where we could protect the lives of our employees, neighboring citizens and valuable property. Why does Monsanto discriminate on safety? Why use safety as an excuse for continued PCB sales . in one area and not in another? A. Because, in our opinion, the risk of accidental leakage and possible resulting contamination is less in one use than in the other. 34. Q. Was any pressure put on Monsanto by government agencies, environ mental groups or other quasi-official groups to ban Thermlnol sales? A. The decision was the Independent internal decision of the top management of this company. HONS 0<t3^ WATER PCB-SD0000064255 SALES MEETINO Tuesday, April 3|[, 1971 8:30 - 9tOO 9:00 - 10:00 10:15 - 11:00 11:00 - 12:00 1:00 - 1:45 1:45 - 3:00 3:15 - 500 Introduction - Hydraulics and Lubricants Pydraul Reformulation A. Status B. New literature C. Comparison of Old vs. New D. Promotion of Refomulations Santosafe W/0 A. Business Review B. Future Plans C. Pricing Policy D. Low Cost W/0 Pydraul/Santosafe Competition A. Competitive Oil - P.E.'s 1. Technical review 2. Marketing aporoach: Pricing 5. Competitive Water/Glycola 1. Technical review 2. Marketing approach: Pricing Envlronment/Pollutlon A. Immediate Situation B. Monsanto vs. Competition C. Possible Future Action - Defense Coolanol: Products/Marketing Plan Santovac: Products/Marketing Plan Turbine Lubes: Products/Marketing Plan OS - MCS Products Skydrol A. Products B. Competition C. Marketing Plan 1. Goals 2. Accounts c lb dwf pz JHD JHD . CLB JHD JHD JHD JHD/WP REH FHL REDACTED REY 000359 i DEFENDANT'S DEPOSITION " EXHIBIT _ f^qeorff / 1-ILp^I rS WATER PCB-SD0000064256 - e- 8:00 - 10:00 Pydraul/Santosafe Major Potential Accounts - Status and Ooals 1. 2. 3. U. 6. Reynolds Metals Sheffield, Massena, McCook, Richmond, Longview 7. i REV 000360 WATER PCB-SD0000064257 August l6, 1972 Mr, B, ?, Collins Reynolds Metals Company 10th and Byrd Streets Richmond* Virginia 23219 Dear Mr, Colllnsi In response to your telephone request I am forwarding under separate cover samples of Aroelor 1242 and Aroclor 1254, If I can be of further service please let me know, Sincerely* --I WBP/bt W, B. Papageorge Manager Environmental Protection _ -/6sy 000403 WATER_PCB-SD0000064258 Monsanto MONSANTO INDUSTRIAL CHEMICALS CO. 600 N. lindbrgh Boulevtrd St Louli, MUiOuti 60166 Phone: (314) 664 1000 ' April, r972 Dear Sir: Since early 1970 we have been advising your company of signifi cant developments relating to the polychlorinated' biphenyl (PCS) environmental situation. As you know, many pollution control agencies conduct monitoring programs to evaluate the presence and impact of many materials on the environment. Some of these programs Include PCS. Recently a representative of a governmental pollution oontrol agency contacted Monsanto requesting information concerning PCB sales. Specifically, he asked for names and addresses of PCB customers In his area, with the quantities of PCB product sold to each. He stated that this information was being requested because significant amounts of PCB were being detected in the discharge from sewage treatment facilities in his area. __ He was informed that Monsanto considers Information of this type confidential and, therefore, does not disclose it outside the Company. He subsequently informed us that the request for information was being sent to the local federal dlstriot attorney for appropriate action. As we have pointed out on numerous occasions to representatives of government and of private groups, Monsanto has long had a policy, whloh it continues to follow, of treating information concerning its customers as confidential information. However, you. should be aware that, because of governmental or Judicial orders or requirements or because of a change in circumstances resulting from the unique nature of the PCB problem, Monsanto may at some future date be obligated to dlsoloae such informa tion to qualified persons. REV 000062 WATER_PCB-SD0000064259 2 We wish to strongly re-emphasize with you the Importance of avoiding direct or accidental PCB contamination of feed, food and packaging material and of preventing PCB'a from escaping into the environment. We direct your attention to the recent PDA notice of proposed rule making on PCB's published in the Federal Register, Vol. 37, No. 54, pp 57Cp and following, dated March 18, 1972. If PCB1s are still present at your locations you are urged to thoroughly review your procedures and lnspeot your facilities to insure that extreme care is taken in the handling, use, storage, and disposal of these materials. Sincerely, W. b. papageorge Manager Environmental Protection REY 000063 WATER PCB-SD0000064260 plant Manager Reynolds Metals 4th & Canal Richmond, Va* 23218 f I ; i t. ii t i; >s ;l u r! Plant Manager Reynolds Metals Co. South Grasse River Rd. .Massens, N.V. 13662 WATER PCB-SD0000064261 ZJ'Cat; u;r=.r i.'iii-r, vre.- , ,r i f1 n h ti i 'i l\ ~'\l m: Office of the President Reynolds Metals Company 6601 Broad Street Richmond, Virginia 23218 . 'LTi.r.vr'vT-ir-- t 9 *r r". **. "t n n arzV f WATER PCB-SD0000064262 SALES f'M M A R Y i; m* s I- ft;' if SsS -V vo -5* -* lh* fas* ;<5l 'Jj! 0* * S 1< 1 <N $ 51 | z z UJ U1 i o UJ a j i> UJ o o * REY 000001 ^ DEFENDANT'S DEPOSITION | EXHIBIT I (kpMfor^c 32 1-vk^t rs WATER PCB-SD0000064263 NO // 0 SALES ' IMMARY 24,, A. 8I f 6* *CO4aNKIIUAiItuOtAVtOItKAIIIKWI UColiHhIUM(*iMAKIIiOPUmM(UOWurM^ |1 i ; >7aftoI'O.ujmIuaiii.vAjM*Ui.aO\nnuiiNilv'ui*aV*OiUi>sM>. 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UP(, 1 MIVKNi Mil It (MIOMM | f I riUKH 1 VMI \ I* (U\I(M 2 A G6IM MIKI A 6 ^MIMtUUNn 1 | a IOia dCM Vuli B UMMOUNi) (HI - am mams os cusiomsb oe reoouci IAVI flAB WKV // 4Jy/> fin&cfak. tiny M<A F11 OAIIKI noovd VAU l> <uvi(M (UllO(l Mti B* WKMK IV A OtMtBAl (MtIMO ft MM< M(OUM\ J A All OBCAMC KIOIMIV MM ACCOUNil (Ml W><4t KMOtl MUiMM AM IAN MB AkAfi Aft MAT mut **o At MA| LI i AUG 1 ri OCI fACI NO NO 10 Ml M^ll BEYNQLO MU CQ MASSfMA MY_____ 1___Lk&J________|____ Ut_i |J- -12 REY 000006 6 i WATER PCB-SD0000064268 * 1 kr c \ mm SAIBS SUMMAAV -- Pot>**S Bv MOMH gTMOW8AiS| e i vuimn i utn a* (usio(i * OINIlAt MIKI 0 KAMI ACCOUNIi 0 ) reoouci wuet by cuiiomcb a ioui o*camc um a iuwi accomu ot HAMS Of CUilOMtl oa FftOOOCI si; VUH 0i oisotci ptocHXf Am av cuiiomcb A GtNCBAl (MllBsCf a BuaSM ACCOUNT* UiAIOBOM IMtKwMA Oa UMI JAH Hi 04 (UtlOMH SAUi By raooucu A Ail CMOaaaC ACCOUNTS a BUtn accounts oev MAS ATS MAY tout monia l>L l_ ilXY AUO YAB 1 /6c YI OCf ** / ) NOV oec I i e I lovjuif A|t> 17466 REYNOLD Mt I CO MASSENA NY \ | 12~] i4~ I j-^n i r~ \ ~ REY 000007 WATER PCB-SD0000064269 (XM no //*o SALES S'MMARY cj i v*m cuiiomib I A CtNllAt MIKI MMII ACCOunII n , r I A' // /o^o ato Adoelon. fAoooci iA4is a* <uiib4a * I04A1 OICamC ' O.st njo nti ) niiiKi raoouci * <umomi a UftMtAt (Htltrtl C (UMI A((OUNll * O HA1K1 OwiWM Chbamlaa omMii SAKS fH4S MOnIH rouNM OOilAAS 1 p* CuvloMia VA1IV a* 'aooucii A At OICAMl ACCOONll ? auoaaa 1 | j SAUS IHIS YfiAfi 90 OAlt POUNDS DOtlABS ULC lu Oh A 617*66 HtYNOLO He.I CO MASbtNA NY | | | 6.0OO | 1.133 | YlAl 1 v<. i h t> / IOIAI SAKS tASI flAfl FOor*OS DOUABS l 3.600 J ovJ | eooooo Ars WATER PCB-SD0000064270 S*us SwauaAST -- P"-oss6 l Month |thouiawi| IH//// 1a I a UNttM MIMI 6t (MIOmiI e MMI *C(OW<n NAME Of CUSIOMte OC reOOOCI /<?*> -3*6 1>'T I MHn 1 \*V Si < ivlOWI A IO*A* iACAT< 1AUS 8 tutMAiWI<n(M1 | tf*lA%ki /*yr ucnin DECE MflFR tun AUG MAC 1964 urt IX t A.t H.O 470 NQV ME i REY 000009 |lflj05j Jljbl74t>6 RLYNOUO HT CO rtASSENA^NT | 6 | WATER PCB-SD0000064271 $AUS SUMMAtV -- Pr'MOl V MOMTM (THOUSAMOS) | (i QIHECT ip * B A UNIIM {kVIMI | M (miOMii I ) rt<MM>4 \aii s > < MMIMUMJNl> 1 A tOlAi OK.M( VAH\ | 1 MNIA|IWNlV(Nf 3 1 until, t flOMI \Atl\0l IUtW|l A t.lNlAI(.>VIKI ft ftutM* At(CH*.l\ . * < ft \AU \ f*OUU< i a All ixi.ANX luiunl\ , ft toMtft A((OUN(UNi PECEHBER ** " - 06name cusiOMtfi oa noooci VI(AIWVAIttl IAN MS MAS Aft MAY IUNE JUII AUO !Ttf&fnT*iOL 1964 S*ri OCI I f*U 140 475 NOV U41 I ' tig|D9t A|bl7466 REYNOLD NET CO MASSENA NY | | if 7I I | REY 0 0 0 0 1 0 [// /6>y& WATER PCB-SD0000064272 * SALSS SUMMABV -- P' -'MOl BV MONIH (iMOtltANOt) DIKECT R 4 a t V*ilMN \ MIV (UMMUI OIMIM (MtUM I S MW MlOUNh nam( ot (uiiCMi oa noouo M '4iicW~M r > rn>0*M. I %AU% i iaIumU * IOA( (JtUAMI Uil\ B IMMl UjnIV<i IAU\Il SJUIV tAH MB Aft DECEMBER j ..A. 1965 i >ri <KI .......... 463 f(>V IH ` 1 110194 .flKMift-IiBPWlfl wet, CO Hftsscm N fiSOSjl____ si II REY 000011 I WATER PCB-SD0000064273 Saks Summmi -- fr not l< Momih (ihouiahoi) DIRECT D | . iMIMi t 1 2*|l * UNIIM laMMI k<MII A<(UUNU 11 .iiimx .1...... A Hl4llM*ltOAIlIU.A^MinIlS% ..... :r. nami Q4 cuMO**tt oe reoouci // /WO J/rS- i f -2 SAtlS * II <AI 1 '1'raI(44 ,.M I Sa.IV I ..AVCI .... | j ......... . ... .. .......... 1 l A I UUMlN ; 1 .... , I DECEMBER l *" | l*N .... 1 l| | MAI 1 1 ... i ... 1 ItIf41 | lull 1 11 1 !1 *k i 196^ \l ri ot l I 468 Ll> |l0j05j A)bl7466 REYNOLDS MET MASSENA NT '| 7| | 24 12 I I i 6| ?TO O 00 WATER PCB-SD0000064274 ^Alli MMMAII -- rr HOS BV MOMIH |IHOUiANOS) I biHECT * Ot A I MinxIHUMlMlIiAllMIt MliK I 8 luMtt I i i nun,! I -.AM . IA NAM1 04 C USlOMt* OS flOOOt I // vs-?s' mxj Py&mut A jtoc> OECEMBER 1965 I 4A0 REY 000013 |10|0S| A|61T466 REYNOLDS MET MASSEN* NV | | I 1 I I I I I I I | | | | 1 | WATER PCB-SD0000064275 JOM NO //AU SALES ' 1MMARY aORGANIC CAC|tNamaKI\MMI*ItOMIOmiSAlIimIKvIVh\hai_i(O_\_*lh_u_Ml<_Mv_U>IM_\O*_(Om_(O4l_>_tUM_HO_lN_> a > nooM vmi> ii (umoii A lIuOM(*Il lUUICOainmMiVVOimNi // -r'A*rA*+t*>o/ a ai,C3l(NoniiCt(tMiluMiVitlIuAOaA.tOtavOiPrtMVAIOOl KOlivXI 1(p*1(iI1uiav>mU7iuvlViCOIOOtvioVlMNMV SAUS IHO MONIH fOONfli | DCHlAtV afM(lllM<IMt)>MlN|IVa*iIdIMKiinMlVOOU4IV 1| ( luMtlMUtONlVONI 'I S*Ii 1HIS TlAfl JO DaK POUNDS j OOUAOs DEC. 1966 i98 IOIAI SAI \ IAVI llAl fouNin | OOt APS i REY I to 37 A AllAAA KVNOUIS HH MASSEMA MV A.000 | 14AA0| 30,000 | 0.400 | 24,000 I ft, J2C | O O O O I WATER PCB-SD0000064276 SALES S MMARY --------- r Lr.Iu*urAi^L'1l fL m*43 * *bCIHmIuIMhuMiuIMO <o TMnM<**lWA*50p*Mw*w* 111 l2*0mIO0mU<iiK<Mli*bmAMi.t5u4*15(5M'0i-ll 14 *0,*I11H1tItMU>*MMI*U1*KX1lM*iOlHnl45o5iOmu15(l 5<o*41lM5u!WvU*5l5<i5i4Jr 5AIIS ItllS mONIH rOOMOi | DOUAB5. 4*. 4(|tU0V4CIO.4MNIMI 544**115*50*4't*o5OK 15 |I < URM 4ftO*M-*l5 0*4* 1 Vai|* iMli VtAB IO DAit fOUNOS | DOUAR5 tt c. 1966 615 IOIA* 5AII5 IA5I liAt rtKJNOV | OOtt AB5 i S' || 492 1M rvoaaut. is fUT I |i IT & IHI6I RIYMOIDS T HASSfcMA MY | ,OU I 2T5 I 1 .014 | 215 i I REY 000015 WATER PCB-SD0000064277 1m nO "6 0 SALES f MMARY rLuru.AsKv e1 Ct Bm 2aJ1 a* A.,(.aHH*IMU**,4iuAtIlMlH\IiAl4l <o riA,iMv*uwvoi>.uiNu I i|j - i*amrtilo>4(>u.<il.l1(M>AU(,l,l-H.mm\ ,l,..o iwMi lk // itTflr ADD 'PiD&AOL A in 37 617466 IUVMQLCS HEI HASSENA NV l( * ai.*i<m*.Hi<iUAuKtiniA.mit.u0ir>ka->oiiohiMisi (i> i.it*M> ito-.iOMia SAIIS IMIS MOCmIH FOUNDS DOMASS C luMU MOllNlV<IUf 1 SAllS IMIS ft AS to OaI| rouNOs ikjiiass 13.5A5 otc. I96t 6 61 IOIAI ,AI(i IASI l|A* rtMiNlis do* aBs It 290 34l i 9TOOOO A M WATER PCB-SD0000064278 Salii Summaay -- iv Monih (thousands) 1 -- - UKGAM4C BA i vuiwMNVSuu it (uiicxui 1' I * j roc*>< i vu\# (iniOMi [+H nawi o (u^iouit oe rtooud uvi TIAt vuit m CXM* rtiHMx i vm * <uvi >M41 . 1 * *(tl fiuout n IAN fie MAR Aft MAT IUN( ....... OEC. JUI I AllG II A* 1967 MM <.M 1 NOV 522 ou I l&ojilj *17466 REVNULOS REE HASSENA NV 30 | 1^ * | | 6| I | | I I REY 0 0 0 0 1 7 // A?YZ>^<r Tk**se*i*jal WATER PCB-SD0000064279 MW I'M 1 JMGAh I C 9 J uIIluI1 Suit SUMMMIf -- POI`"t It MOMIH jlHOUtANOt) 1 1 SAllSMiN V SAIIS ll (USIUMl 1 J flown 1 UtlS It 1 USlituH NA*4 ot (UllOMt o rtOOUi 1 I| /** 1 J 1 WVllHt fhAMM 1 SAHS (1 UnliMMI | *'*. 11 E ,an 1 ,i# 1 ma 1 rKWuUS 1 ma> JUKI OfcC. .... | .... .... 19*1 VI'I | H 1 ........ NUV Mt I REY 0 0 0 0 1 8 | & rvMUMM. ass |lc|j/| a| 6i /Itoo KtVNUlUS. Ni l MAbStNA NV | 1| 5I tI I I I 1 *I I ^ I WATER PCB-SD0000064280 KMM 1i r ii/m ukgamic k m I VMIMN i (I cuviomu 7 rtOOoO SAUS < UlWOM(> name ot cu&iomu oe rtoouu l*SI MrixtKt -- Pot"1## By Month (thousands) oivitin raotHXi SA-mei cuhomu ------------ .. -................. < usio*m a VAin at raouu< is | MAS | Aft | MAT JUN! MOMlM DEC. JIUIY AUG 1967 j>trl lx i fAt.l MO 533 nOv UK liojsil A| 617466 REYNOLDS NET NASSEMA NY 111 14 1 l4 10 I 2 I 3 I 3 I I III I I III REY 000019 7/ VS'-Pi" A&O PubAtll A &4A WATER PCB-SD0000064281 ^AUI MIMMA8V - TO' Dl muMtn (inwwAMOS| MMIU( I Ull\ II IA*I iUi VWll 1 IkMIM 1 rititiM 1 VAU\ |l 1 UVIUMII j * 4 t U^IUM* t rtUtKK l> JAM Me MAS Are MAI JIJMI ....... OIC. AVC. - 1967 uri (M 1 MCI rt> 720 MOV D*C i RY 0 0 0 0 2 0 tj Mi^fe-WfcywuLyS-wt i *AHtHja______1I1___________________i |J. . ||.___J_ | | s| \ Ljsa saa TaiS /yt**ial A/34J& WATER PCB-SD0000064282 J(It l>Al'l i L M [1 // /o V<9 ) UnKlMI | # J fKMKW 1 i*ll\ /7*A./m4 t*J& ^^ SALES UMMARY C 1 iNVIlll 1 fllKXH 1 Uin ' (USKMI SAl| S rOUNO^ MONlH | lK)llAl`i -.......... Mini' nui' is 1 Ut L . Saks imis ia* io oau ruuNOi j iK>tiAas | | "* -- l,.. | 19 68 653 Ioiai \ai 1 ASI flAH r mi u>s | IHlIUtt !1 1 J / A ill *i.-i -i t .4* L-j.i t.i 9 MAj ji K4 KY 6, COt | 1.6Ul | 6 9 l Lrts i >6du REY 000021 WATER PCB-SD0000064283 SALES "IMMARY j( A ,Il (. * < miimum \ vmii < uviOMia j imXMimAiivtuuvii>Mii ll 4591 US /?**' US' c l msiiu t rtouiM i \<ui\ SAMS IMIS MONlH POUNDS | OOllAffS m * u^iiwii sahs > rtiHmt is I SAltS IHIS IIAB to UAIt POUNDS J IXJUAfiV I960 662 UVlAl SMlS IASI 11 At foilllin | LKH1ABS i ;i j m a 6i / u n..; MAS Si 6A MT I S.i46| 2*33 | 5.J8L | !><!*> | REV 000022 I WATER PCB-SD0000064284 KMH NOmi MV 1/*/ ^. SALES 'IMMARY UK GAN 1 L f * 1 5*H5AMi lAiiv *> iiniowta | mi PCOOU* i S*U5 ( (uiionIi U. ^ <L Mid JBxmjmil A ZOCl___________ C 1 (NVIIK 1 riOOM 1 SAUS at ( uMOMlI SAKS IHIS MONlH fOUNOS | OOtlABS c(usiOMiiunvt> riooum I SAIIS IHIS AB lO 1>A 11 POUNDS | DOllARS utc. ini | 06 ! IASI IIIOIAI %*U5 AC POUNDS IK HIAC5 113 11 J 61 lUu K| V til ULUS Ml I HASStKA NV iq 5.005 | 1,603 | I 9.615 I ^,602 I REY 000023 WATER PCB-SD0000064285 ,'aE.Vho]/n/ SALES r'IMMARY UHGANlL ft 1 *1 Mil I' (.U3IOMII I > fBOOUtl 1AIIJ tUVIOH AS. /AT<5 s?0O -T/t*Aks Py/lRfiia/ /?J3'4L2JS 1 1C 1 WillK noOK 1MI) II < USIOM/I SAKS IH4S MOHlH FOONOS J OOilASS g tusiUMtt iAiii a rnnHn i) | SAKS IHIS ftAB IO 13aIt rooNOS | oouabs tlit - | S>6tJ | 9)3 VIOIAI SAI IASI I AB t< H1HUS 1 CHHI AIS i |13 il A t.l /`.i t hi Y.l. Iljj HI I HA:,:>i M NY 1 | 891 | *70000 A f* WATER PCB-SD0000064286 i*** 11^ '' MAMt l* PMOUUCI/I U^IUMIH Theamimol fa-a rs ,l| 1 IMAi |aU TaTTCTTEm ron M<M > lu IAN frte MAM APH MAY IUN1 IUIY AOO PI i M 1 ia v u l ....... 1040-263-1 f f | amxos hetaus messena my f | *.oo| . | *.oo| [ 1 rri S 1 i || | I I.If. / /7II | REY 000025 I WATER PCB-SD0000064287 f *AMl t N PKOIMM I linhiMIM i-rnRAiH A 200 I 969 ................. --rro-- OTTTTCm --WR' It**.. .** . li* IAN its MAR ARM MAY HJNt JUIY AUO UPl i it 1 1* *v i*l \ 66 `.-.Mm KEY 000026 j | j KtYNOLOS MtTAUS HESSEN* Jff | . j *.1 | j| l WATER PCB-SD0000064288 I 96 4 --i ] | mr p*ir%ro*ii ran | | | I I J ffcB j j > H 1` MAMl Ot RMOtMK l/l U^IOMtH | .....1.1,A, H.. <>> 1 t.M 1 JAN 1 MAR APR | MAY JUNt JUIV | AUt, blPI 1 fc >V Irrwftyfc in ;'V9| |-| I I | | II II 1 72 I | I EVNOLDS METALS HESSENA NV | | 9.151 | 12.| | II- I I - I I I ' I.fdi I REY 0 0 0 0 2 7 WATER PCB-SD0000064289 Htl'UHl tt|4 Jt-A Ol/ls// I UHUANIt DtV - I UNLI IdNAt tllilDS NO.4 I.U\lumK/PH()l)Ull SAILS MlPUJtl I UK -IN AL I UAL POUNDS ANU 1)01 i AKS~ UtC. I 9IU PALI /*. flOfAt NON I It SAL I S POUNDS dollars V-l-0 pounds SAILS dollars IUIAL IASI Yt AH SAILS POUNDS OOLLAHS IUIAL VI AH CUSI 10 UJAL LOS HAJH-ORO-OP I HI Y^JLOS HL I AL S NfcSStNA N? IOS^ liltKfllNOL I A-2 6*000 *800 6*000 I*680 AR 611466 10061 t*iO 6*000 104l|-^6S-10 920000 WATER PCB-SD0000064290 HiPUH| 61676-A o 01/16/M ORGANIC I>l V - FUNCUONAi ItUIOS NO.6 COS I UHt H /PKODUC1 SAltS KtPOHI LUR -IN AClUAL POUNDS AND DOLLARS- IHt 1910 PAG! ZZ \ 1UIAL HONIK SALES POUNDS OOi.fi.AKS V-I-0 POUNOS SALIS OOLLARS IOIAL IAS? VtAH $ALt S POUNDS 001 LARS I01AL VtAH CUSI 10 GOAL Li>S HAJM-GRO-GP \ REY 000029 Hi YNOLOS Hi I At S HESStNA Nt 1(30 PfORAUL 13S_____________ 23f6 72 6, 362 I2*?t2 3*699 AH 611466 |006 7 790 6S92-U5-11 WATER PCB-SD0000064291 rttPOftT ai^?6'A O &inxax URGANIC 01V - FONCIIONAL FLUIDS NO*A CUSIOMEA /PROOOCI SAILS REPORf FOR OLC 1910 _______-in ecivM. town w> pollan-________________ fACt 42* IDIAL NONIH SALES POUNDS HOLLARS y-i-o POUNDS sales dollars ideal lasi tear sales founds dollars ioial year cusi io coal lds ha^r-gao-gp I REYNOLDS MEIALS NESSENA NY I AST IRANSEURN PYRANOL IMM1*11111______________________1*111__________ HI AR AllAAA |OOA?I90 ___________ IQSP-SOO-IA REY 0 0 0 0 3 0 WATER PCB-SD0000064292 1968 0.9 0.6 0.6 0.3 3.3 0.6 1.2 0.6 NEW YORK PCB CONTENT 1960 - 1969 M POUNDS 1969 0.1 0-1 2-4 k Total 0.9 0.1 0.6 0.6 0.4 5.7 0.6 1.2 0.6 s r-i r\9 <0 M Ooo a REDACTED WATER PCB-SD0000064293 NEW YORK 1966 41.9 0.2 0.1 41.3 0.1 10.8 1.2 16.8 -2 - 1969 40.6 0.9 0.1 6.7 0.6 2.1 0.2 b . ' *W'| 3.6 1 Total 82.5 1.1* 0.1 0.1 48.0 0.1 10.8 0.6 3.3 0.2 16.8 3.6 W v i? oo o >m o WATER_PCB-SD0000064294 HEW YORK 1968 0-2 16.8 0.6 0.7 28.5 13.8 42.3 2.4 0.1 3 1969 0.1 0.2 4.8 1.2 0.4 31-0 8.4 40.6 0.5 1 -8"\i Total 0.3 0.2 21.6 0.6 1.2 0.7 0.4 60.3 22.2 82.9 . 2.4 0.6 1.8 -r & . m WATER_PCB-SD0000064295 MEW YORK 1968 10.2 3.3 ITT? 0.5 0.3 123.6 123.6 5.5 0.2 2.0 7.7 0.1 2.1 41969 1.2 1.2 3.0 5.4 0.1 5.8 177.3 183.1 1.1 0.1 0.2 1.4 103.5 >) Total 11.4 4.5 3.0 18.9 0.5 0.1 0.3 5.8 300.9 306.7 6.6 , 0.3 2.2 9.1 103.5 0.1 2.1 o rvs O O O ui o WATER_PCB-SD0000064296 HEW YORK 1968 0.2 0.2 0.3 0.3 2 .9 2.9 0.1 1.8 0.6 99Z000 A3U 5 1969 2.4 0.2 0.8 0.1 0.2 1.4 1.6 0.2 1.8 1.8 0.6 1 Total 2.4 0.2 0.4 1.1 0.4 3.1 1.4 4.5 0.1 0.2 1.8 3.6 1 .2 WATER_PCB-SD0000064297 HEW YORK 1968 0.2 6.3 0.7 0.2 21.6 21.8 0.7 0.6 0.1 1.8 4.3 REV 000267 6 1969 7.9 0.5 0.9 26.4 27.3 Total 0.2 14.2 * 1.2 1.1 , 48.0 49.1 5.0 1.8 1.2 1.8 3.8 U * ( 1 5.0 2.5 1-0 ` 0.1 3.6 8-1 WATER_PCB-SD0000064298 HEW YORK fcfY 000266 I960 8.4 150.0 0.3 0.3 0.6 89. 7 39.4 7 1969 3.0 100.0 0.3 0.3 1.0 2.1 0.2 33.5 161.0 Total a.4 3.0 258.0 0.3 0.3 0.6 1.0 2.1 0.2 0.6 33.5 2 50.7 39.4 WATER_PCB-SD0000064299 HEW YORK 1968 5.2 134.3 0.1 0.1 1.1 36.0 0.5 0.5 t .2 R if 8 1969 6.5 201.0 2.4 0.2 0.2 34.8 Total 11.7 33S.3 0.1 0.1 2.4 0.2 1-3 70.8 0.5 0.4 0.3 ii 3.0 1 . 1-0 0.9 0. 3 4.2 oo <N9 O O O WATER_PCB-SD0000064300 NEW YORK 1968 0.1 0.1 1.2 7.6 61.3 0.1 0.1 2x1 0.2 0.1 3.6 REY 000270 CD 9 1969 0.1 0.6 0.7 3.0 1.2 92.6 4.9 0.9 5.8 3.1 it Total 0.2 0.6 0.8 3.0 2.4 7.6 153.9 0.1 5.0 1.0 6.0 3.1 0.1 14.4 WATER_PCB-SD0000064301 NEW YORK 1968 0.1 0.1 1.1 0.1 0.3 KEY 000271 10 1969 0.6 0.2 0.1 0.2 11.4 0.1 0.1 2.0 0.3 '* 1 Total 0.6 0.1 0.3 1.2 0.2 11.4 0.2 0.1 2.8 0.6 WATER_PCB-SD0000064302 HEW YORK 1968 0.4 1.1 0.8 0.6 284.9 4.2 2.4 8.4 11.0 0.5 R6Y 000272 11 1969 2.4 242.2 4.8 9.0 1.3 b O'.'3 1 Total 0.4 1.1 0.8 3.0 527. L 4.2 2.4 13-2 20.0 I-3 0.8 WATER PCB-SD0000064303 HEW YORK 1968 0.1 0.6 2.8 0-1 113.4 2.4 0.9 3.3 0.2 REV 000273 12 1969 0.1 0.1 0.1 0.6 0.2 1.2 85.3 0.1 1 Total 0.1 0.2 * 0.1 1.2 0.2 4.0 0.1 198.7 0.1 2.4 0.9 3.3 0.2 WATER_PCB-SD0000064304 NEW YORK 1968 0.3 9.1 1.2 15.2 0.1 0.6 3.1 0.3 13 1969 1.2 Total 1.2 0.3 ' 9.1 6.0 0.1 * . . w. |- 7.2 1 " 7*2 15.2 0.1 0.6 o*1 3.1 0. 3 7-2 -e- <ooo\s Ul OL WATER_PCB-SD0000064305 HEW YORK Reynolds Metal Messena 1968 0.4 16.0 Sub-total Sub-total 0.5 0.1 0.4 0.6 1*0 3.6 0.1 3.7 16.2 14 1969 0.4 11.9 0.6 2.4 0.2 Total 0.8 27.9 0.6 . 2.4 0.7 6.0 6.0 9.6 1.8 b 1 0.1 0.4 0.6 1.0 9.6 0.1 9.7 9.6 18-0 o Q O v^ ui at WATER PCB-SD0000064306 Vendor 1971 TOTAL ITEM 1 - ATTACHMENT B -ContIn u ed- 1971 PC B RETURNS Pounds 914 5,000 1.149.645 lbs. , rf 6< I -m REY 000291 WATER_PCB-SD0000064307 --/ Monsanto Ciibmjcaw "Plastics ...... vi______ AN INDIRECT AROCLOR HEATER for UNIT CHEMICAL OPERATIONS Montonlo Tschnicol Bulletin No. P-130 September, 1949 Mon *onto Chemical Company St. Louie (4), Missouri Aroclor* 1248 (chlorinated biphenyl) is an ideal nonflammable ljquid phase heat-transfer medium for temperatures up to 300C. ' This bulletin describes the physical properties of Aroclor 1248 and illustrates the design and operation of heaters that have been used successfully by Monsanto plants during the past seven years, The units described are gas fired and the capacities are in the range of 200,000 to 400,000 R.t.u. per hour. Other larger commercial installations using Aroclor 1248 have capac ities ranging up to 2,000,000 B.t.u. per hour. Also small electrically heated stationary and portable units with capac ities around 40,000 B.t.u. per hour,using Aroclor 1248 as the heattransfer medium,are in service. Several leading manufacturers of heating equipment are in position to build or offer Aroclor heating units to meet specific requirements. > 2 c 22 O n X) m x m D -t n > X) >o n o o m r oxs X >m > O 2</> -t m n O I % * nO 6 5` ? T) -, u. a. om* r1 S -o TKf I* ft I a fcaaflMt* U. la 9W b*(l <v4 Wt if *r iufHiltni Ht made wlihMil fu*vsnie, tlnrr tK* ttndlllsM ( ue mt btpvnrf * OMftl. Thf an* Crwnftny 4lrUH*s my lisfellll? Ntt4 It* *wwrl*rt rlh lh * si lhM Ills M )'wlhrm*tf. J hrriln thill b ttnilrvitd rf^w*rwlN*i I* ** titling |>tltMl e*v*ft*f Mf wsltfltt ** It* . p<4wl I* # *HH REV 00142* i DEFENDANT'S DEPOSITION i EXHIBIT g& WATER_PCB-SD0000064308 Iteprinw-d Irnnt INDUttTlUA], AND ENOINEKRINO CHEMISTRY, Vol. 41, Page 1341, July 1949 Copyright 1049 by the. American Chemical Society and reprinted by permission 0! the copyright owner Aii Indirect Aroclor Heater for Unit Chemical Operations Ml'.ADK MCAKDLFA L. C. GAKItETT, AND P. G. BKNIGNUS* Mormon (o Chemical Con>t>any, AnnUton, Ala. Xhr clierselerUtlce of Aroclor 1144 Indicate that it Is in Ideal llqiiii' phase liral-rtclini|c medium for temper* I lire* up to 300* C, This article dfscustes its properties anil Illustrates the design end operation of heaters that hare Ixen usetl successfully hy Monsanto plants during the pssl seven years. IN CERTAIN manufacturing prooetacs of U10 Monsanto Clicmleal Coiii|Miiy, it was ncoeaeary to employ a noneonrbustible hnat-lranafor medium at pressure* of 80 pounds per square Inch or leas ami tein|>eraturc up to 800* C. Tho following general projicrUoa of a heat-exchange medium were required: Freedom from fire liatarda. Viscosities to permit pumping at room temperature*. 1 toiling point cuflictrully above 800* C. to assure a liquid 000ditioti at all time*. liability against heat, with enough safety factor to iceonimodat accidental ovcrlkcating. ControlUldc vajkoritetion tosses. Krccdoin from corrosive action agahaK valves, piping, tank jackets, etc., made of east Iron and stools, braots, sad tlainlees atcel. Freedom from toxicity hazard. Aroclor, chlorinated biplmnyl (registered in U. 8. Patent Office), wa* selected. The pertinent phytiea) eharaeteristiea relnlivc to its use as a heat-transfer medium are given in Table 1. ntKMIOM FROM FIRE HAZARDS Flash i'oiKT. UmiUtioM of (hit test for the prediction of tire fire hazard of relatively nonvolatile organie fluids have been recognised by the American Society for Testing Materials 00mmittce (3, 4)- Fhk Point is a more aigitilleant meamirement. The Under writer*' laboratories {JO) stale that fire Wats more truly reflect the (lack of) fire hazard of Aroclor. BroHTAttaotis lonmoH Tempbhavuhk. The eombuationrnualing qualities of Aroclor 1348 are indicated by its high spon taneous ignition temperature of 704* C. (1393* F.) determined by Sullivan, Wolfe, end Zkmma (B\ using the convenient apparatus described by Snrtmsa, Baity, and Heron (). Under conditions af Waatrial use the spontaneous ignition tcni|icrniurn will be determined by faetore including the nature of Urn hot surface, the amount <fl liquid impinging ou it, the volume of enclosed apace, and the ventilation. An accidental failure in a boating system demonstrated the nonflammaliility of Aroclor 1348 an<f its freedom from the Imiard of fire propagation. An operator's failure to start the circulation of tiic heatctransfer medium when the gas beater was on resulted In excessive coil temperature* and caused the tower coil to soften and tag into the fire chamber. A weld ruptured and Aroclor 1348 poured into tho rod-hot fire chamber in contact with the flame. lJciise smoke arose from tho heater but there was no externa) fire. After the gas flame was eut off, the smoking atopjwd. > I'rrwnl addrsu, Mvomhio Chemical Company, Orgonio Chrmlcslc IK.liion, 8t. Louie, Mo. I'rrwM sddfrsa. Monuoto Chrmleal Cospsor, Pbwphsto Divides, Bt. Uulo. Mo. Ssaat Flammasiuty. When a lul>e ruptures io a liquid heattransfer ayatem under higli pressure, a epray or mul forma. The possible fire hasard under theso oonditiona require* oontideratlone not oovered by the foregoing discuaaiooe relative to the ma teria) in the liquid form. In thoir oompreheneive study of flammability of the higher boiling liquid* and tbeir miets, Sulli van, Wolfe, and Ziiman (9) determined tho spray flammability limit of numerous materials in accordance wilb the peroeotage of oxygon required for combustion. This value was then oorrelated with tire results of ineondiary firing testa of the fluids oohdueted at tho Naval Proving Ground, Dahlgren, Va. The oxygen re quirement for Aroclor 1248 oombuetion in the epray flammability limit studies was found to be 04%. Fluids requiring over 43 to 50% oxygen in the spray test failed to cause a fire in the Incendi ary test. These results eeUhlieh the nonflammable and nonoombustible qualities of Aroclor 1248. VISCOSITY CONSIDERATIONS Colo Flow. For most inside installations centrifugal pumps will handle Aroelor at reduced rates without preheating. Experi ence. confirms tiki*. Outside itkstallatiooa have beon tierlad at 0* C. by heeling tike pump and feed line until circulation through Tadls I. Physical Paorewns* or A hoclor 1348 A|fAFftfk4 Pradically catorlass mobtl. liquid *C. (*F.| ALmJuU tfifnily, g./ml. 144 >41 (1(8480)) 1.97 till I.IT ten I. IT mo art) AhaoluU vfModty, .tsUpsiM* Thermal cesdeeUvitr, B.l.s./bssr/tg. tssl/ r./lvt DiiUnaUae nun. A.8.T.M. D JO, * C. Huh tart#**. Qtvttaftd or* cur. A.8.T.M. D 13-44, * C. Fir poUl, open Uf>, A.fi.T.M. foot psiat, A.8.T.M. D-7, C. Ce4>tA* tct.a>il Hpnii3>. fni./wni./* C. (14 'Hlit Oft 0 47 o.oeit o oe o oeoo IIO-J74 195- 199 Nam -7 o (worm 0 M ViU 0.717 o.soo to mJ& lili !m> Mi) is (te> (MO too (Hi) to (40) 40 100 (t1o40) 400 100 <47J> Wit, t&f./g./* C. 9*4) M USD 1107 UM 144 (tft m 159)' 394 am Vpf preset*. cam. H* 0 OOU37 0.14 100.0 17.1 noo) $100 Ini) (>0J) >00 REY 001425 WATER_PCB-SD0000064309 1342 INDUSTRIAL AND EHQINEERINQ CHEMISTRY Fob 41, No. T Table II. Btaeiutt or Aeocloe 1248 Heated roa 30 House Ttn^ersluts, C. MO WO >10 MO mo M>. d RCt oar Grim ol Aroclor 00.0U79 00 . >19)>9 o its Table III. or 12488tamuti Aroclos Comtinoovelt Heated at 280* ano 330* C. Hour* M|. ot HC1 pr Oram of Arolr 210* C ---------- IfFTT 30 0 07# 0 111 eo out 0 410 #0 0.169 0 411 m 0 194 1.141 160 0.291 !.m Tablb IV. Qas Ahaltsi# of Aroclor 1248 Heatbd 4 Hour# AT 260* C. AHD 210 POUND# PIR 8QUARS JKCH PR#88Ufie Om CCiirrUboofat diotid* Oijtmb (4rir4 fre ilr> MRin AUH<? (% Wighl HC1) PrUt U *ip0ur Altet tspoevre Hom Nom 9O0..tt NNooem* 0.0071 0.007# the heeler had been effected to that the sydera could operate normally. WIIJNC FOIST Operating experience has shown tliat the boiling point of Aro olor 1248 (340* C. at 780 nun.) is enough above the 300* C. operating limit to prevent trouble from this came. At the maxi mum operating temperature the vapor pressure is teas thaa 0.5 atmosphere. HEAT STABILITY In order to establish a maximum practical operating tempera ture, the stability of the material when heated to elevated tem peratures in the presence of Iron waa noted. A alow stream of nitrogen was passed over tbe bot Aroolor to sweep tbe decom position products Into a caustic trap. The amount of acktis material was determined and calculated as hydrochloric add. The results given in Table II indicate the stability of Aroeior 1248 when individual camples were beaUd for 10 hours at the gives **>mprature. The deeom* podUon is very low at temperatures up to 300* C. The liability of Aroolor 1241 in contact with L iron continuously heated at 280* and 830* C. is indicated by Table III. These test results Indi cate that Aroolor 1248 in con tact vHb Ires caa be used laUAsterOy at Uatperaitne apwWC. The National Board of Fire UedswHteraf/0) reported that "dceotepodlion of tbe product (Aroeior 1248) was not appreci able at temperatures below 400* C., but became lacreae- ingly apparent at higher tem peratures." 4t 3t C. " mtcrtiAl ju burner so that the (U fljune impinfcd directly on the surface of the A- . Anslysts ol the |>M produced under these conditions ic i oSdic?b?n monoxide, 0.17% oxygen (derived from tb,. ./ u-W% hydrogen ehlorido, 2.1% combustibln jm calculated u methne, 0.002% ehlorinr, snd no phosgene. The same workers studied the stability of Aroclor when betted for 4 hours In an iron pipo at 280* C. under an internal pressure of 210 pounds per square inch, resulting from the ml reduction ol comprsssod air. Following this treatment and cooling, the rases removed from tho system were analysed. The aridity of tbs Aroeior was determined prior to and after exposure to these cooditions. 1 he reeulle given in Table IV reflect an extremely small amouot of decomposition under conditions similar to thoec selected for the practical use of Aroolor 1248 aa a heal.transfer medium In actual practice using the type of heating unit described below thero has been no evidence of hydrochloric acid effect and oo car bon deposits have been noted in the heater, pipex, nr valves. Tbe heaters have boen operated successfully with combustion ga*e at approximately 600* C. in contact with the coils. At one time, a spiral coil type of heater was built am) through faulty design a burner tunnel was located 1.5 inches from the 2ineh steel pipe eoll. The radiation from the white-hut refractory tunnel and the dlrectHmpincement of the flame on the pipe caused the pipe to glow a dark red tor a epace of about 2 inches. This unit was operated almost 3 months before a circulation stoppage occurred. When the line was opened lumps of carlron were fouod to have come loose and moved forward to lodge in the glebe valvos. Tha lumps measured about I X 3.5 cm. and one fac* wai formed to At the pips curvature. No hydrochloric acid effect was noted and the system was put back Into operation after tbe burner location was changed. CONTBOLLABLC VAPORIZATION LOSSES The heating eyeterns In which Aroclor 1348 is wed are ceded except for the expansion tank, which has a loose cover or a veai pipe. Because this tank is separated from the ilream by a cub- ctentiel length of pipe, the temperature in the tank reinr' low. in the light of the relatively low vapor prenure v lot Aroclor 1248 (T\ and as it is unlikely that the expansion U..A will ever reach even the 1-mrn. data (130* C.l, there should not be measurable loss of Aroclor from the system. Aclunl experienci hears out this contention. Oman Losses. Although Aroclor darken on uec, its chares tcrietios remain the came and replacement has not I>ood (ouoi; necossary after 7 years of continuous use. Accidental leeks o< spills constitute the only observed losses. PLAN AND PART SECTION H' -tit J Their workers analysed the decomposition products of Aroolor 1248 heated In the pres ence of hot Iron at 450* C. and also heated in an iron cylinder er ELEVATION SCO TON "A-A* Figure 1. Heater REY 001426 WATER_PCB-SD0000064310 oJy 1849 INDUSTRIAL AND ENGINEERING CHEMISTRY 1343 Table V. ItEtlleTANCE OP STRUCTURAL Materiaia to Aroclor 1248 u*uu AUbIdub Cop por Mut^uru Nlokfl 611am Tib At ti* C. KR Ult RH R U At li* C. *V R M nR Mvtels lint MHd *t*i .PliODiiJvor bron<* Red brmiB 6YueillnolwrMbrs At 45* C. R BR R D RR R Al IM` C. RHnu RnH, RFl. Eieelfeot rr{Utxt, Ibm U>b 1.0 X I0~* m. p*r d*y peetr*tioo or 0 0R0,0)4OIeb*pwfJe rpeUyufnro.e, penrtr*Uon between 1.0 X lO^ftad 10 X 10"* m. per 4*y f beUeea 0.00014 tt\d O.OOU irtoh prr ytor. D. Doubtful rtuliUrtPO, pehtlrttioo bt)wf* 10 X 10^ om. pr day tod 100 X 10`* tB>. )* dv or betweea 0.0014 and 0.014 lofb per y*r bfi-lUarK>thJBdalanIoUIvrrinwnIfotuf IUIM'dtWtlIrfoftfonVtaaef*lfll*y(aftfIrmipmfetm|rauka#dUr,Unaelaov,seilrf.ihpinloi*" lU`Aten*! f"u*y tx> la brUovtd lo convo DESIGN AND CONSTRUCTION Heatino Syhtem. The heating system required to utilue Aroelor 1248 a* (he exchange medium includes a heater (Figure 1), ooolcr, pump, and expansion tank (Figure 2), and control and safety circuits (Figure 3). Hlt:hlK>.M FROM COKROS1VE ACTION Tho resistance ot various metals (7) &t 26* and 12S* C. it giveu In TrIiIc V. Similar studios made t 325* C. ($) indicate that the penetra tion, in iuolu* per year, for mild steel l 0.0028; fpr yellow brass, 0.00047; for eojijicr, 0.00145. Many year* of practical operating experience with Aroelor 1248 a* a beat-transfer medium have thown dial the material it prac tically nonoorroaive to valvet, piping, tank jacket*, etc., made of oaat iron and steels, hronre, and stainless tire). hu.lpom t KOM toxicity hazard Aroelor 1348 I* a very stable, unreactive liquid. If the material la tpllled on the skin, tlvere are no noticeable ill effect*; however, it i* well to wash tlie tkin with aoap and water after contact. A tkin burn resulting from accidental contact with hot Aroelor thouid be treated in llie normal procedure used for hoi oil bums. Arookrr adliering to the burnod area need not be removed inn mediately unless treatment of the burn demand* it; in this esse toap and water or rr|>CNlod washings with a vegetable uil (linseed oil labouid boused. Tbo vapor* emitted by Aroelor 1248 healed to elevated lemItoraluree are injurious to tho liver on prolonged exposure and lliould not be breatliod. Drinker (5) indicated that 0.5 mg. of Aroelor 1248 per culuc meter of air is the maximum safe amount pcrmiiwible in workrooms. Ill commercial heat-transfer installation*, the presumption i* thsl the Arock* is in a dosed system five from leaks. Accord ingly, tliefe should bo no opportunity for workers lo come in con tact with vapors from the hot iical-tranafrr medium. rh TA1A ETCAAAOA Heater Demon. The general requirements of tha heater are compactness, case of construction and service, and avoidance of direct flume impingement on the tubes. Direct flame impingement is prevented by directing Die gat flame through an enclosed channel with half-thickness fire bnck protecting Uie tube* above until the high tein|icraturc of' the flame is reduced bv heat cqpductcd through these bricks Md radiated to the two bottom coils. The site of the heater ia redused to minimum by using nnlv 4.5 indies of insulating fire brick is the hottest areas and 2 incites at Nagle .Vo. 86 insulation on the cooler spots. Two site* of units arc turd: One lies a maximum capacity of 200,000 li.t.u. per hour, as sliown in Figure 1. The larger has a range of 200,000 to 400,000 H.t.u The small sise consists ot 90 fvet of 1-lneh standard weight steel pipe made into Uimo coils of six pipes each and connected in series. The larger site eondsta of 144 feet of 1.5-inch standard weight steel pi|ie arranged in the same fashion. Iteeult* of tests un the small-siie heater covering temperatures from ISO* to 840* C. show temperature rises to 10* to 30* C. in l!>e Aroelor whilo circulating at a rate of 15 to 20 gnlloiis per minute. The outlet gas temperature ia consistently within 75* C. of the outh'l Aroelor temperature. It is observed that live bottom two coils ab sorb Die major part of the heat. Thr small unit indirnlct 50 to 60Cc rfiieR'neics for capacities up L> 300,000 U.t.u. per hour hen a natural gas of 1000 B.l.u. per cubic foot is burned. A Surface Combustion Comps",v high pressure inspirator and tuunel burner set it used in this installation. Over-all hrat-cxcliangc coefficient* ((') for the furnace are in the range of 7 to 10 li.t.u. per hour per aijuarc foot per degree FahrenlH'il. Over-all hcat-exclungi; coefficient* for Aroelor 1248 to water in a double pi|*e heat-exchanger made from 1.35-ineh pipe with a 2-incli |M|io jacket are in the 130 to 180 range. These figures arc calculated from test results on uii# inttallalion. AROCLO& r AOU HtATtft <0 0WTttT^7 J&CMTCO Wt COOUA etna ectT -OH KATER maim --CXj-rtxJ JTA9ArOCO*O1SUt 2. 0A t |-------- ---e*t- *UTI.WWT T3 hCATER PIPING Figure X. Cooler, Pump, ed Cxpeasloa Teak Cooler. A very useful adjunct to the system is a double pipe oooier on the outlet of the heater shown in Figure 2. By turning water into the jacket, the Aroelor can be cooled sod the temperature of Uie eyelem lowered. This la lielpful when it ie necessary to cool a batch before removing it or when an exothermic reaction Claris to get out of control. Pump. The pump for circulating the Aroelor 1248 may he any one of a number of standard centrifugal units designed for hot liquid service. REY 001427 WATER_PCB-SD0000064311 U1 IJl-A OIKtll 2 01/12/22 fij"j NAM[ Of PfiOOUCI/CuSIOMlfi 1 1 1 III. MM INCH, fll-1 0A0AM1L 01M1S1UM SPRIUK PHOOUCIS pooouu/cusroNcn sal is aEPoa f OH ucL IS II I h)KMim 1 uTM ftMFttt. AMn 01l 1 ___________ llAl toacuM | am | jan S ffcfi j ILfL 1 1_ *a B Ape E may I rjn* j >m\r | aog I im | oo 111 1 11 1 NOV Ott ooi UA PA(.t btt uU 111 / aaAj LAO Of 10*Q-2*4- K I .hl/moaos iitiALS *** mi j I|| iwi__________ 1_ l 1 I ! 1 I ! | 1 iooaimo ( RY 0 0 0 0 3 1 WATER PCB-SD0000064312 A Oo ftY @00032 J| 1 31 ~ A UlHtCl 62 oi/i zni " Ml NAMt O PMOOuC I/CuSIOmLS 1 IlLrfJHNJi- f-i UHGAMC Dl VI S1UN tkPk.ClAI.IV PkOOUCf tk pgOOUCI/CUS10*K SALES At POM _ roit^iuk li niaIsHi I1 fCMCLea ii> nkinn*. hiil\ fWU 1 AUKJAM ftfi MAS APft iitui_ ... I IQ__ MJK ^it iY/1 MAY RJMt JUIY AUG St PI (X 1 MOV DfcC /A PAGL /a u(uU4V<caiuo c/ *f !04Q-^6i- Si I tKHrMlM-US WElAt-t WtSktWA HI____ I I *.00| j ii.ol __ 1_____liij;?!L___ 1 _ l _ l S 100*1190 | WATER PCB-SD0000064313 U113I-A OMlLI 92 01/12/ 12 1AANS9Q9M UftCANIL DIVISION SPtClALa* PkUOUCI S PNOOUCI/CtiSlUMK SAILS 969091 POM ,,cC IV/I PASt 2Sb `i REV 000033 Il4)| Mvas.0$ C96IALS KSStM MV i 7iir I 1" h-ns - i r i i i i i s rr 100*7790 I ( t WATER PCB-SD0000064314 U31-A oIntel u 01/12/12 c ill nam Of raoouu/cu&iOM&a PrOMAUi. 1)1 Mtiwcrfoioiwouisciio/cnusiimaneuniisat&nsutrtKmis i fern otc i9?i P*fct 134 RfelMAjiisimum m mmiflBim urn ffhfliai __________________________ KHtNiui ffK KM CUM CUM Mft IAN FES MA& AM MAY KiN JUIV AUG Sfc*l OCI NOV DtC <-Wi O / C> CP OOS >2A 4JIJ-U1-II I I REY 0 0 0 0 3 4 III 100*1)90 WATER PCB-SD0000064315 HtrOMI U1A76-A 01/09/73 nice #iv- smcialiv pmoucis U.4 CU-SIOM*EsAi/P*MkIOUeoCwI ieSsALES 1m11s0(&1mH=M__O_E_C_1_97_2 IOpoIAuLtms SOLLASS MmB-- MEVNOLOS METALS HESSENA MV 1237 tAADSroilM PBRAM8&. A&S89S PAtfc 3*0 .LASS IOIAL COAL Hi CMS SO rajs-shd-cp 4.121 I.Mi .Ji AM I17M4 10047790 I REV 00003S I WATER PCB-SD0000064316  Ft HI Hl4?6-A 1/JS/fJ PICC 0 I V-02 SPKUilV PPOOUCIS NO.A LuSlOMiR/PftUOUCI SALES SEPUKI foM DEC 1912 -IK ACTUAL FOUNDS AND DGLLASS- fr'At.i 10 SAL MONTH SALES POUNOS OOlLASS tf-l-0 POUNDS SALES DOLLARS TOTAL LAST yea* sales POUNDS DLLLAPS l(IAL YEAR OUST 1M GOAL LdS PAJS-OMO - u` I 9COOOO A REYNOLDS METALS MESSENA NY 1213 DISC PCS PCI U?3 IHEMM1NDL fft-S 74.410 I2.SOO 1.14! 3.9*0 AS S1TU4 006?/V j ^sas-aua-ii 1043-245-1 I 1 WATER PCB-SD0000064317 00027* HEW YORK 1968 27.0 0.2 0.1 39.6 3.0 42.6 0.1 1.9 15 1969 3.0 21.6 0.1 9.0 26.4 35.4 0.5 4.5 0.6 0.1 Total 3.0 48.6 0.3 0.1 48.6 29-4 78-0 0.5 0.1 6.4 0.6 0.1 2- WATER PCB-SD0000064318 MEW YORK 1968 0.6 0.2 0.3 3.6 0.1 0.2 0.6 - 16 1969 0.6 0.8 1.0 0.2 0.1 0.1 Total 1.2 0.8 0.2 0.3 5.4 0.3 0.2 0.6 0.1 0.1 O o o Ul ac WATER PCB-SD0000064319 HEW YORK TOTAL 1968 0.2 0.2 14.C 0.2 10.0 24.4 0.6 0.5 103.0 1492.1 17 1969 0.2 0.6 4.2 0.6 4.8 3.6 0.5 126.0 u 1549.5 * ' 1 Total 0.4 0.6 0.2 18.2 0.2 10.0 0.6 29.2 3.6 0.6 0.5 0.5 229.0 3041.6 5 <\8 O O O Ul e WATER_PCB-SD0000064320 EXHIBIT L (REVISED) *j REDACTED Rif 000279 ^DEFENOANTS DEPOSITION 1 | EXHIBIT ^ f i aptifwp' ~^11 } WATER_pcB-SD0000064321 Vendor -- PCB waste returns 1971 Pounds 8,775 2,208 3,400 3,000 622 2,739 1,800 1,870 83,300 5,503 ' 9,570 ' 11,400 '* 2, 700 460 84,090 RY 000280 WATER_PCB-SD0000064322 Vendor Cone inudPCB WASTE RETURNS 1971 Pounds 2,040 11,826 718 17,500 4,050 1,110 39,683 1,646 99,462 1,200 1,650 9,264 5,020 1,200 R6Y 000281 WATER_PCB-SD0000064323 Vendor "Continued- PC B waste returns 1971 Pound 7,425 14,143 5,135 2,016 333 3,354 1,916 51,500 520 6,500 1,794 1,605 6,086 6,180 5,370 1,924 29,988 7,200 1,800 1,840 1,185 REY 000282 WATER PCB-SD0000064324 Vendor Reynold* Metal (Massena, H. Y .) (Loncvlow, Wash.) -ContlnuedPCB WASTE RETURNS 19 7 1 Pounds lf 106 750 1,912 586 16 000 10,747 2,352 3,250 3,000 1,200 2,710 600 3,410 1,200 5,101 7,655 3,370 REY 000293 WATER_PCB-SD0000064325 Vendor "ContinuedPC B WASTE RETURNS 19 71 Pounds 66,547 5,392 90,000 1,125 3,900 786 4,782 2,7 50 57,880 1,790 ** 135,167 16,600 18,822 75,800 7,425 16,484 ftO 000284 i WATER PCB-SD0000064326 Vendor Monsanto Company j.P. Queeny Plant 1971 Total Continued" PCB WASTE RETURNS 1971 Pounds 914 5,000 93.300 1,242,945 *I REY 00028$ WATER PCB-SD0000064327 Vendor 2TEH 5 -- ATTACHMENT I REDACTED 8,775 V ^ 2,208 3,400 3,000 622 2-73* f 1,800 1,870 83,300 5,505 9,570 11,400 2,700 460 84,000 REY 000286 WATER_PCB-SD0000064328 Vendor ITEM 5 ATTACHMENT B Contlnued- 1971 PCB RETURNS Pounds 2,040 11,826 718 17,500 4,050 1,110 , 39,683 1,646 99 , 462 1,200 1,650 9,264 5,020 1,200 REY 000287 WATER_PCB-SD0000064329 Vendor ITEM 5 -- ATTACHMENT B -Continued- 1971 PCS RETURNS Pounds 7,423 14,143 3,135 . 2,016 333 3,354 1,916 51,500 520 6,500 1,794 1,605 6,086 6,180 5,370 1,924 29,988 7,200 1,800 1,840 1,185 key 000288 WATER PCB-SD0000064330 Vendor ITEM 5 -- ATTACHMENT B " Cott ft rrued- 1971 PCS RETURNS ' Reynolds Hoe a 1 (Maeeena , N . Y . ) (Longview, Wa*h.) Pounds 1,106 750 1,912 586 14 000 10,747 2,352 3,250 3,000 1,200 2,710 600 3,410 1,200 5,101 , , f' ' ~ 7,655 3,370 RfY 000289 WATER_PCB-SD0000064331 Vendor IfEM 5 -- ATTACHMENT B "Continued- 1971 PCB RETURNS 66,547 5,392 90,000 1,125 3,900 786 4,782 2,7 50 57,880 1,790 135,167 16,600 18,822 75,800 7,425 * if' r 16,484 REY 000290 WATER_PCB-SD0000064332 1344 INDUSTRIAL AND ZNQINIIRINQ CHSMISTBT Vri. 4), Mo. 7 VI.Tails Pipiho Detail Plpa CorutUutUoB R)>r*.dutaea*arx. *f>d VBaUlni*ga llniana Dop* C**k*la flhnl-afl vtlvaa CoMrol v*ltpa valve* Ff*ly valve* 1 <>h valve* ' *Um (;( 8n4 fllrainarx (D4ma&aioaa la inabaa) VI *tkirkafauwgbghft Us 'I/*UIirharwag^gk */ flL*<iul* ). A.g.T.M. AM or AIM Sahtdula 40, A.fl.T.M. AM or AlOfl Berow*d FtooirU Bind Id ihop led field whir# po*. lbl. Muii lv* <le*n*4 Vo rtmovi itaJa V iJifoygh */ Forgid *tw*l aartwod. Crana JOOd irnr* I through fl 1 through 0 Welded fitting*. Cram 300* Bari** 00 (Vo matah vaivia) M**Mn* bait# A.S.A. H-lfi.2 with h*i< agonal nut* (or orviea below 500* F. AUov* ua# alloy itaal. Cram tri* pin A.B.T.M. AM V through / V* Utrotilk */ I through 9 3</t through 9 / through */ m* A through V 1 through 2 t through A V. 1 Vi through 9 Vi |Agt Cram 2S2h Iorgad aWt Craoa 421 high tam* paraturo thread composed Soft Iroe ri flat or aormtaUd CCrraamm 33oOlft0WW,, aflaaraagwaa, d|,iUgate Cram 93XR. flan**. gate C'raaa 9040 XR, arawed, gioba Cram Crana 9I0I8I0XXRR, .flalannggea, .glgolboebe Cram 9074 X. aorewed CritK fiflflfl X, ftaagod CCroamneoli1d9a9UXd, 1fl0a7n0geBdW. a<rewed CorvMolidaUd 101? W, Ranged Crwia* 9400 Of DurahveUIUe [> UO T.VIO 100 PCPR Mareb 0-100 Il*7a0> imH |i| aipHei with Cram ttt\i Ur atoakvalva. IJIr.irmgmiwI elawvef!tegtlaagea R?0 Reflex type Vi-Vi 1 through 9 t?l Varway threaded 82? Yarway flanged The Dayton Dowd Type C pump is an example of the type required. It cJiould be made of cast steel and Hava a watercooled (luffing box and water-cooled bearings. The (luffing box thouId have room for at least six rings of peeking and a lantern ring. Durametallic No. D-110 or Garlock No. 234 may be used for packing the pump. An open impeller is desirable, m It will handle the cool, more viseoue liquid on starting tha system better then will a closed In)poller. Enough horsepower lor the most vlsooue ooedltioos Is required. I 'imho SrsrsM amp Extanuom Tam*. The detail of tbe piping ,vim for Aroelor 134* used up to temperatures of 100* C. (i;2* F.) and 100 pounds per square inch pressure is given In Table VI. The valves and (poolallies given indicats ths type re quired. Alt piping larger than 0.75 inch is flanged or welded; ex perience Has shown that hot Aroelor penetrates screwed joint* of the larger dies. Stool aad east etc) are used throughout. Tha system requires ea expensioa tank located at tbe highest level of the InsteUaUoa. The dee of this tank is normally about 35% of the capacity of the Aroelor system. Coaoeotioos with valves, mad oa sitbsr ride of the pump, enable the operator to connect a ftasfck hate and to pemp in or out as required. For opsnftlsa la Vocations where the Aroelor temperature may drop to wfcsse the attendant viscosities may make pumping iropraotksi la the system as designed, it may be desirable to steam- jacket the Aroelor circulating lines to facilitate rapid start-up. Suitable safety provisions, such as safety pop-ofl valves, must be Installed in the steam jaeksl system to prevent pressure ruptures which would develop U any condensate remained in a dosed sys tem during high temperature operation. In order to establish operating conditions and to cheek the operation of the beater itself, it is often desirable to measure the temporalutes of the Aroelor in and out of the heater and cooler. Items 9, 10, and 11 (Figure 2) provide for Ibis. They may be dial thermometers or mercury bulb thermometers of any commercially tvsJIablo type recommended for the service. Tabu VII. SAriTT and Control EqoiruxHT I. Hl,h prewurv alarm Mtrcoid DA-3), ofwo wreuit oo High pr*g*Ur* s. o(df .Dlalpeola) .loppes* Low prrtaurr alarm Actual tliaga d*pnd aa individual |*yt|i M*reotd DA-31-9. opaa circuit oa low prwu, 9(di epteucmtsp) .topp,,, Actual cctUaga dapand ae tadtvidual layout i Thtrmoaut (det*et* ieMive Itfii4ft| )>roe* ob*trueUo ranwal tftOOJ. Inert aca CoDlacU opao oa Uraparalurt of Bow) riowtiwiioK (dt*eta lUemak)ai* froiD y- Mvrcoid Fifur* 40. $.P. awiuh. Opto at low Flam* falluro avtlam (pcituoui folaflm*tat|o?Ifi Comb.tillow CoMrol Corp. Flravt FFfl. Flam* lailura control (or manual Ignition gaa burner put) 0. Cm ralv (atiu ofl Id cm* pr*tf*dlna dsvicea *cl) Oentral Control Cofp currant ofl K-10-f. Clo* witb T. 5. Rtd tight (alarm) Hprn (*pund* alarm) Alarm relay Slop hor r*iay Stop horn bottoa Tharniomavar well Kitlark VA-I 90 Edward* 3)2 V, or Baojamin 70lf-V Tri-a C-lib, I .NO. I NC oalartlaM In nR 4 *04 ''N' ,NC <" 0-3CO* h. mrreurv H.ilb Iharmomatar (Wttiai cheek of hoatrr parfem- anra) 10. Th*fni*w*lff w*J) (vkwa) ahaak 4 0 300* ('. mrstury bulls lltermonvrtr htato* perform- II. THormomatar weR 0 -390* ,. mirouy, bulb thartnomter (viiytl check of eooiar parforwtv anev) I). Sotrrvoid vaJra Central Control K-10-2. Control* Aroelor lamparatura to matt dam*tula of ayitcm For sutoinatie temperature control s solenoid valve, item 12, is indies tod In s by-poss arrangement with s msnuslly operated needle velvo. The needle valve is adjusted to give almost enough heat to meet the requirements and the actual control is carried on by tlio rolenoW valve, which opsns aed eluees as (ttreett-d by a trm. ^crature-eontro) instrument connected to tho equipment being One unit wee set up with torepersture control using s t^cds A Northrop Model 3 ell-elec trie ooatrol with droop corrector. Very close control over s wide range of beat demand resulted, when s throttling range adjustment of 4 was used on this control device. SArrrr Ctncurr. Figure 3 shows a safety circuit which auto matically protects the system by closing off the gas supply in the event of faulty operating conditions. Provision Is made for shutting off the warning horn while tho system is bring put beek into operation after a safety shutdown. A detailed list of ths safety and ooolrol equipment is given in Table VII. Tits equipment named indicates ths type required. ACKNOWLEDGMENTS Tbe authors art grateful to A. M. EUcnburg of Mousanto's Re adereh Laboratory at Anniston, Ala., for furnishing many of tlte technical data about Aroelor 1318 and for assistance in preparing the manuscript. UTUtATURB CITED (t) Allen Bradley Co.. Milwaukee, Wls., Bull. 700. (3) MJ,, Bvli. 500. (3) Am. 8oe. Testing Materials, Free. Am. Bet. Tutinq MateriaU. 34, M (1934). , (4) Am. Boo. Testing Mstsrlsla "Standards cm Petroleum Prod ucts and Lubricants," IMS. (5) Drinker, C. K.. /. /red. Hyf. TtzitM.. 21. ISS (1939). (6) Mousauto Chemical Co., Anniston, Ala., private communica tion, April It, 1944. (7) Mooeanto Chemical Co., Bt. Louis. Mo.. Mentente Tec*. Bell. P-I1S (August 1947). (8) Boatman, C., Bsalty, H.. and Heron, 8., Ind. Emo. Cbiw.. 33. 367(1941). (9) BulHvsn. M. V.. Wolfs. J. K,, and Usman, W. A.. /Md.. 39, 1607 0947) (10) Underwriters' Laboratories. Chicago. III., "Miscellaneous Hasards." No. 3498.1934. Receivss Ausuet 37. IS4S. Preeess4 bMcre tbe MeeUei te-Mieieiure. Alabama SeeUos. Ausucsir CssmoeL Soovrt. Deeetnbei 4. 1046. Penrrss in U. 8. A. RY 001428 WATER_PCB-SD0000064333 Monsanto Chemicals "Plastics KAL______ _____ MONSANTO CHEMICAL COMPANY IT. L 0 U S AKRON e BIRMINGHAM e BOSTON CHARLOTTE e CHICAGO CINCINNATI CLEVELAND DETROIT e HOUSTON e LOS ANGELES NEW YORK e PHILADELPHIA SAN FRANCISCO e SEATTLE MONSANTO (CANADA) LTD. MONSANTO (AUSTRALIA) PTY LTD. Montreal Toronto e Vancouver Melbourne MONSANTO CHEMICALS LTD. London Representative* in the Principal Cities of the World POBiMAO>tO--4* Pflnt.d In U.t.A. REY 001429 WATER_PCB-SD0000064334 (,'4-aJk-^ . *.. , ; ,/ li '' v'. .AjV wv! .: *i.` A'V *i'* (* \i JA'iiIia'i: 9' i *' * *'* I vOwJi/ * * >' 1 *k * ' t| * V* ?*V* # >vv V* ( r - I w *** i ( V** r.t \J ( O I v/ V* i i i \J S I * I * . i \,f trf k 4* *4 t ChJ^ak%.'* *M~**'* .i.S.S^U ^ aU! ' !.' L ,7 I' ! * /' i. /> 0 L .C / t // .*. L . rv"i Monsanto; _M >// \ -V : v.: > f MONS 078201 WATER_PCB-SD0000064335 Some Important application* for protective and decorative coaling* platticiied with AROCLOR compoundt--- . Wood and metal used in yachts, barges and other marine cratt. Structural steel for bridges, buildings, roofs and power-lines. Structural materials at chemical plants, pulp and paper mills textile mills, petroleum refineries and gas works for protection against acid fumes, alkalies and gas. Tank cars and other rolling stock and construction machinery for protecting against corrosive materials and weathering. Equipment and stop-off lacquers used in electroplating. Masonry floors and walls. Concrete swimming pools. Highway markings. Cable coatings requiring fire resistance, chemical resistance, and excellent electrical properties. Textile coatings resistant to chemicals, fire and water. 1t HONS 078202 WATER PCB-SD0000064336 TABLE OF CONTENTS Page Naming of Arodor Compounds.................................................................................... 3 Properties of Chlorinated Rubber General................................................................................................................. A Physical.................................................................................................................. 4 Chomicel Resistance.................................... 4 Electrical................................................................................................ A Mechanical............................................................................................................ 5 Thermal...................................................................... 5 Physical-Chemical................................................................................................ 5 Viscosity Types......................................................................... 5 Solvent Compatibility.................................................................................................... 6 Formulation end Properties of Chlorinated Rubber Formulation for Aroclor Resins......................................................................... 6 Formulation for Aroclor Plasticirers................................................................. 6 Properties of Formulated Films.............. 7 Applications Alkaline-Resistant Coatings............................................................................... 8 Chemical-Resistant Finishes............................................................................... 8 Marino Finishes........................................................-............ -.......................... 9 Emulsion Paints.................................................................................................... 9 Adhesives....................................................... 10 Paper and Tenlile Coalings...................--................. ........................-- -.10 Electrical Coatings......................... ....................................... -.......................... 10 Printing Inks.......................................................................................................... 10 Resins for Chlorinated Rubber........................................................................................ II Monsanto Plasticizers for ChlorinatedRubber................................................................It Toicity................................................................................................................................. 12 Shipping Information................. .'........................................ ............................................12 Trademark ........................................................................................................................... 13 0 /* HCNS 078203 WATER PCB-SD0000064337 I \\ *: ARODLOR . . ,. J resins and plasticizers for chlorinated rubber INTRODUCTION Monsanto produces a scries oi chlorinated biphenyls and polyphrnyls identified by the trade mark Aroclor* for use as plasticizers and resins for chlorinated rubber base lacquers, varnishes and paints. These protective coatings are fire resistant, corrosion resistant, chemical resistant (to acids, alkalies and water), and have good electrical insulating properties. When properly pigmented, these coatings have unusually good weatherability. Chlorinated rubber films plasticized with an Aroclor grip common structural materials in strong adhesive bond? and the addition of an Aroclor improves the flexibility and life of chlorinated rubber and plastic coatings. The formulations suggested in this bulletin are common in commercial practice today. They arc given as a starting point or guide in developing formulations that expand the outstanding 0 qualities of these com|>ounds, Naming of Aroclor Compounds The last two digits in a numbered scries refer to the degree of chlorination by weight. Aroclor 1248 is a biphenyl with 48 per cent chlorination. Aroclor 5460 is a lerphenyl with 60 per cent chlorination. Two special mixtures are: Aroclor 4465--a 60:40 mixture (biphenyl to lerphenyl) with 65 per cent chlorination. Aroclor 2565--a 75:25 mixture (biphenyl to terpheny!) with 65 per cent chlorination. The physical properties of the Aroclor plasticizers vary gradually with the degree of chlorination. At low [icrcentages of chlorine, such as Aroclor 1221 and 1232, the compounds are dear and very fluid. At 42 per cent they resemble vegetable oil; at 48 per cent they thicken slightly and look more like a medium-grade mineral oil. At 54 per cent.chlorine, the compounds are quite viscous; if a bottle containing them is turned upside down, the bubble rises slowly to the top. At higher percentages, the biphenyls become gumlike, and a fingerprint on the surface lasts several days. Then at 68 per cent chlorine, the range is complete; Aroclor 1268 is a white powder. The tcrphenyls (Aroclor 5442 and 5460) are both yellowish solids. Thegradual change In physical properties often allows a processor to select a plasticizer particularly suited for his deration. For example, if he wants to dry mix the plasticizer, Aroclor 1268 could be used. It melts at higher processing temperature and can act as a solvent-plasticizer. 'Aroclor: Monunto Trdcmtk, Rtf. U.S. Pit. Off. 3, MOSS 0 782 WATER PCB-SD0000064338 Properties of Chlorinated Rubber "I'arlon" is a mixture of two polymers with an average chlorine content of 67 per cent made by chlorin ating nalural rubber. The typical properties of "Parkm" as given by the manufacturer, Hercules Powder Company, Wilmington, Delaware, are listed in Table I. Table I. Typical Properliet of "Parlon" General Form as shipped....................... Color of film.............................. Odor............................................ Clarity of film........................... Taste........................................... Moisture, per cent as shipped, ..White, granular powder ..Water white ..None ..Good ..None ..0.5 maximum Physical Specific gravity.......................................................................................... 1.64 Specific volume, as shipped, in cubic inchesper pound........................ 16.9 Hulking value, gallons per pound..,.'..................................................... 0.0735 Index of refraction....................................................................................1.S54 11 Chomieal resistance 'to: Acids, weak................................................................................................ excellent Acids, strong.............................................................................................. excellent Alkalies, weak............................................................................................ excellent Alkalies, strong.......................................................................................... excellent Salt spray................................................................................................... good Alcohols.......................................................................................................excellent Ketones....................................................................................................... soluble Esters............ _............................................................................................ soluble Hydrocarbons, aromatic........................................................................... soluble Hydrocarbons, aliphatic........................................................................... good Oils, mineral....... ....................................................................................... good Oils, animal........................................................ ....................................... poor Oils, vegetable........................................................................................... poor Electrical (dear unplaslicired film4) Sjsccific surface resistance, ohmsXlO14................................................. 2,000 Dielectric strength, volts per mil (ASTMmethod)................................2,300 Dielectric constant at 25C. and 1,000 cycles......................................3.1 Power factor at 25C. and 1,000 cycles.................................................0.0015 to 0.0030 Power factor at 25CIC. and 1,000 cycles, after immersion in water for 140 hours and surface wipeddry....................................0.0027 Film* u>cd in testa were laitl down from i toluene aolution. / A 018205 0 0 WATER_PCB-SD0000064339 Properties, cont'd. Mechanical (clear unplasliclied dim*) 20-cp. type Tensile strength, pounds per square inch, dry.............................44,,227700 Tensile strength, |>ounds per square inch, wet.............................44,,110000 Elongation, per cent, dry................................................................ 3.6' Elongation, per cent, wet.....................................................................3.8 Modulus of elasticity, pounds per square inch....................................11..44XX1100"' Hardness, Sward index, per cent of glass........................ ..... 90 Note: rieiibilit)' of "Pjrlon" film incresses with viscosity of "Psrlon" used. 1,000-cp.type 4.850 4,360 3.3 3.4 - Thermal (clear unplasticired film*) Burning rate......................................................................................nonflammable and at 1'5C. : 135" to 150"i Phyricel-Chemical (dear unplesticired film*) Effect of sunlight............................................................... Effect of aging.................................................................................Very slight Effect of hot water.........................................................................Blushes Effect of cold water....................................................................... None Moisture absorption (80# relative humidity for 24 hours), per cent........................................................................................0.27 Moisture vapor permeability of 0.003-inch film (grams wate:rr/ square ceniimcler/0.01 centimeter/hour at 2 1 C.)............00..22XX1100** embrittles Viscosity Types Viscosity Type 5 cp....... 10 cp....... 20 cp....... 125 cp....... 1,000 cp....... Tabla II. "Parlon" Yitcosify Types Vljcosffy Range (centipoises) . 5 to 7 8 to 12 16 to 25 110 to 190 800 to 2,000 Examples of actual or suggested applications of the several viscosity types are given below: Type Example of Use 5 cp. In printing inks and as a fortifier for alkyd resin enamels. 10 cp. In high-solids finishes and as a fortifier for alkyd resin and oleoresinous varnishes and enamels. 20 cp. As a film-former in protective coatings andas a fortifier in enamels and varnishes. 125 cp. As a film-former in protective coatings, in paper lacquers, adhesives, and textile ' finishes. 1,000 cp. As a film-former in adhesives, textile finishes and other finishes where flexibility is important. Titnu used in tests were laid down ftom I toluene solution. HONS 076206 / WATER PCB-SD0000064340 Solvent Compatibility Solvents and solvent mixtures suggested lor u<* in preparing formulations with Aroclor and "Parlon" artgiven in Table III: Table III. Suggeiled Solvents lor Compositions with Aroclor and "Parlon" "Amsco Solv," H and E Amyl acetate Hulyl acetate Carbon tetrachloride "Cellosolve" Diacelone alcohol Diethyl carbonate Ethyl acetate Ethylene dichloride Hi-Flash naphtha Methyl acetate . Xylene Methyl ethyl ketone Methyl isobuty) ketone Methyl salicylate Notol . Octyl acetate "Sovasol"'N'os. 74, 75 "Solvesso 100" "Tollac" Toluene "Union Aromatic Solvent" 3553-10 "Union Solvent N'o. 30" Formulations and Properties of Chlorinated Rubber Chlorinated Rubber Films Arochr 1262 and 5460, resinous types, show good compatibility in chlorinated rubber films laid down from toluene solution containing 20 per cent of the plastic in ratios of 2:1 and 1:1 ("Parlon" to Aroclor). The plasticizer tyjses, Aroclor 1242, 1254 and 1260, also show good compatibility. Formulations and proportion of films derived from both resin- and plasticizer-type Aroclor arc listed below. Table IV. Formulations for Aroclor Resin Ingredient Parts by Weight "Parlon," 20-cp..................... ....................... 16 16 16 12 12 Aroclor 5460......................... ....................... R 8 8 12 12 Dibutyl phthalate................. ........................ - 4 ---- 3 Tung oil, Thcrmolyzcd, 976 5--- Xylene or butyl acetate...... ........................ 76 72 71 76 73 12 12 -- 3.75 72.25 . Table V. Formulations for Aroclor Plasticiier Ingredient "Parlon," 20-cp.................... ....................... 20 Aroclor 1254 or 1260......... ........................ 4 Xylene................................... ........................ 76 Parts by Weight 20 7 73 20 20 70 t, MCIVS 078207 WATER_PCB-SD0000064341 Films cast from these lacquers show improved characteristics due to Aroclor. Some of their advantages are listed below : Adhewon Unplaslicizctl chlorinated rubber films have very poor adhesion. The lacquer film containing Aroclor 5-460 pave pood adhesion to aluminum, bare steel, primed steel, galvanized iron and "Transite" surfaces. Othea commercial resins, particularly oil-modified alkyd resins, pave better adhesion to glass, tin, copper, scaled wood and cellophane. The lacquer films plasticized with Aroclor 1254 or 1260 pave pood adhesion to "Transite," cellophane, gal vanized iron and primed steel surfaces. Some of the other commercial plasticizers tested in similar films gave better adhesion to aluminum, tin, bare steel, copper and scaled wood surfaces. Though compounds with an Aroclor alone possess pronounced adhesive qualities, better adhesion to all of the surfaces results if mixtures of Aroclor or varied contents are used. Rctbfancc fo Aqueous Solutions Chlorinated rubber films with Aroclor 1254 or 1260 (plasticizers) and Aroclor 5460 (resin) show satisfac tory resistance to solutions of 10 per cent hydrochloric acid, 5 per cent sodium hydroxide. 5 per cent sodium chloride and water spot tests. Film Hardness Softer films were produced with Aroclor 5460 in ratios of 5:10 and 10:10 Mroc/or;" Parlon") than with other commercial resins in similar mixtures. Likewise, softer films result from Aroclor 1 254 or 1260 in ratios of 2:10 and 5:10 (drr>c/or;"Parlon") than with other commercial plasticizers at these concentrations. From these tests com|>ounds with Aroclor are shown to have strong plasticizing action on chlorinated rubber. Cold-Check Resistance Aroclor 5460 is superior to phenol formaldehyde resins in cold-check resistance imparled to chlorinated rubber films, but not as good as alkyds modified with long oil. Aroclor 1260 used as a plasticizer proved somewhat belter than Aroclor 1254. Wealhor Resistance Pigmented chlorinated rubber finishes containing Aroclor have consistently withstood outdoor weather tests, but unpigmented finishes do not stand up well regardless of the resin or plasticizer used. Poor resistance to ultraviolet light is also a weakness of chlorinated rubber. Most pigments (except ultra marine blue) are usable with "Parlon" and are recommended if the coating is to be subjected to outdoor weather or ultraviolet light. However, pigment protection varies considerably. Inspection of alkyd enamels fortified with "Parlon" showed weatherability varied from 65 months with chrome green to 4 months (or titanium dioxide--iron blue combinations. Sanding and Polithing Properties Plastic films compounded with "Parlon" and containing Aroclor 5460, 1254 and 1260 have shown satisfac tory sanding and polishing characteristics, 7 HONS 078208 WATER PCB-SD0000064342 Applications Altalinc-Resislant Coatings Products containing Aroclor and chlorinated rubber are highly resistant to alkalies and moisture, faints with combinations of Arcelor and chlorinated rubber are used in large quantities lor concrete floors, walls, swimming pools and other surfaces. A paint formulation is given in Table VI. Table VI. Paint Formulation for Altaline Surface (Parti by Weight) Ingredient Formula t (baiamant ftoorl) Formulation Formulo 1 (Fad. Sp.e. V-MI) 'Tarlon," 20-cp. type............................... Aroclor 1254.............................................. "Rezyl 869"............................................... Aroclor 5460 or "Cuniar P10"................ "Heckosol 31"........................................... Tung oil, Thcrmolyzcd, 976......... Titanium dioxide....................................... Zinc oxide.................................................. Silica flour................................................. Carbon black............................................. Xylene........................................................ Hi-Flash naptha........................................ Totals............................................ 16 10 8 -- -- -- 16 2 3 0.2 " 42.8 (-- " 100 18 10 6 16 2 0.5 47.5 100 Formula 1 ((dimming pooli) 14.6 4.4 2.9 4.4 19.7 6.5 47.5 100 Chcmical-ReiMant Finishes Particular care is necessary in choosing resins and plasticizers for chemical-resistant paints. Chlorinated rub ber formulations with an Aroclor have proved outstanding for acid and alkali resistance. Five formulations are shown in Table VII. Table VII, Formulations for Chemical-Resislanl Paints (Paris by Weight) Ingredient I Inlorlor uio, ectdi and atlitial 2 EiUrlor use, ecidi Formulation i ' Exterior nu, altaliai 4 Mfttlmwm rttttUnc*. IWIici "Parlon," 20-cp. type........... Aroclor 5460........................... "Dakclite XJ-12895"............ "Rezyl 807" (solids)............ Aroclor 1254........................... Aroclor 1260........................... Tung oil, Thermolyzed, 976.. Iron oxide.................. ............ Titanium dioxide.......... '..7..... Zinc oxide............................... Zylcne...................................... Hi-Flash naphtha.................. Toluene....................................... Totals......................... 16 6.4 -- -- 8 -- -- 16 -- -- 53.6 -- -- 100 16 -- -- 6.4 4.8 -- 4.8 16 -- -- 52 -- -- 100 16 -- 6.4 -- 4.8 -- 4.8 16 -- ... 52 -- --, 100 18 -- -- -- 8 6 -- 18 -- -- 39 11 -- 100 s Soap Militant 12 6 -- -- -- -- 7.7 -- 18 6 28 10.3 12 100 I < * WONS 078209 WATER_PCB-SD0000064343 These formulations were applied to metal bars or panels and tested for resistance, Formula I showed good resistance to 10 per cent hydrochloric acid and 5 per cent sodium hydroxide solutions. Formula 2 gave excellent outdoor protection to metal surfaces on plants manufacturing acids. Formula 3 performed well on exteriors of plants producing alkali. Formula 4 had excellent resistance to acids, alkalis and salt solutions. It also showed good adhesion to glass and other surfaces. Formula 5 proved good for resistance to warm, soapy water. Note: No finishes with Arodor or chlorinated rubber are recommended for con tinuous exposure at temperatures above H0 F. Marine Finisher The marine industry makes great use of chlorinated rubber coatings plasticized with Arodor to protect wood and metal on boats, barges and other marine equipment. They possess good resistance to salt water and their hard finish deters algae and other marine growth. A suggested formula for a white marine paint is given in Table VIII. Table VIII. Formulation for a Chlorinated Rubber Marine Paint Ingredient "Parlon," 20-cp. type Arodor 1254.............. "Rczyl 869"....... ~...... Titanium dioxide....... Xylene......................... Ill-Flash naphtha...... Total.............. Paris by Weight ....... 20 ..... 6 ....... 6 ....... 25 ....... 23 ........ 20 ....... 100 Emulsion Paints If chemical resistance is required on porous surfaces, Arodor 1254 is often added to chlorinated rubber emulsion paints. The Hercules Powder Company reports that preferred water phases for such paints are either a 1 per cent distilled water solution of "Aerosol OT" or a 4 per cent distilled-water solution of sodium oleale. A lacquer-lo-water ratio of 2.5 to 1 (by weight) is suggested for the complete emulsion. "I'arlon" of any viscosity may be used. A typical paint phase for such an emulsion paint is given in Table IX. 9 HONS 078210 WATER PCB-SD0000064344 Table IX. Formulation (or Paint Phare of Emulsion Paint Ingredient Parts by Weight "Parlon"................................................................................... 28 Aroclor 1254............................................................................ 14 "Cumar P10".......................................................................... 10 Xylene....................................................................................... 24 Hi-Flash naphtha................................................................... 24 Total........................................................................... 100 Adhesives Chlorinated rubber adhesives with an Aroclor were developed originally for adhering labels to acid bottles because of their general resistance to chemicals. These adhesives are also of unusual interest because they arc fire resistant. A typical formulation is given in Table X. Table X. Formulation for Chlorinated Rubber Adhesive Ingredient ,, Parts by Weight "Parlon," 125-cp. type.......................................................... Aroclor 1254........................................................................... 20 6 Aroclor 1260........................................................................... 6 Toluene..................................................................................... 68 Total.......................................................................... 100 Paper and Textile Coatings Chlorinated rubber coalings with Aroclor are worthy of consideration for specific end uses in the paper and textile coating fields. In general, this type of coating is restricted by odor and taste. Unpigmented fin ishes seem suitable for certain fabrics used Indoors, but not for exposure to high temperatures or direct sunlight Electrical Coatings because of their desirable electrical properties, these compositions are useful for insulating and protecting electrical wire and apparatus from moisture. With selected fungistals and waxes, coatings of this t.vpc are used to protect electronic equipment in the tropics against moisture and fungi. The fire resistance of these plastics is an added dividend in the electrical field. Printing InVs Printing inks requiring a fast drying time and chemical resistance are often based on chlorinated rubber compositions plasticized with an Aroclor. These inks are especially useful on soap wrappers and boxes, bottle labels and many other commodities because of their alkali resistance. 6 0 10 ' MGNS 078211 WATER PCB-SD0000064345 Other Resins and Plasticizers Compatible With Chlorinated Rubber The resin? and Monsanto plasticizers given in Table? XI and XII arc compatible with chlorinated rubber but none gives the over-all desired qualities attained by using an Aroclor. The strong points and limitations of each are known. If their use is necessary for specific applications in chlorinated rubber, more detailed in formation on them may readily be found. Table XI. Retini Compatible with "Parlon1 "Ambcrol 801, R061\ ST-137, F7" Aroclor 1161, 5460 "Aroplaz 920, 930, 935, 940" "Bakelitc" XR-31P0, XK-4503, XK-4006, BK-2963, XJ-9868, HR-1329, BR-3360' "Itcckacitc 1112" "Bcckaminc P-138, P-254" "Super-Beckamine 3501" "Bcckapol 1400" "Beckosol 1 (solid), 18, 31, 34, 40, 1329" "Beetle" Resin 22 7-8 "Clorafin 70" Copal "Cumar 1'10" Dammar "Duraplcx C-45-LV, C-48, C-49, C-50-LV, C-Sl, C-62, D-61, D-62, E-71, E-71-A, E-73" East India gum Ester gum Ethyl methacrylate "Esterol 750" "Formvar" "Gclva 2.5" "Clyptal 1 247, 2450, 2454, 2458, 2464, 2466, 2500" "Lewisol 2L, 28, 33" Methyl methacrylate polymers "Neville R-3, R-10" "Pentalyn A, G, M, X" "Petrcx 1, 130H" "I'henac 633-M" "Rezyl 1 16, X315, 412, 775, 803, 807. 829, 869, 880, 1103" Rosin Santolitc* MPH (sulfonamide-aldehyde re<in) "Stabelite Ester 1, 2, 10" "Stabclite" resin "Super- Beckacite 1001" "Synlex HI, H3, H12, 17, 213, 22, 28, 29,32, 36" "Teglac IS, Z-152" "Velsicol AD6-3" "Vinsol" Tabla XII. Monranfo Pla ieiiert Compatible with "Parlon" Aroclor 1242 Aroclor 1254 Aroclor 1260 Dibutyl phthalatc Diethyl phlhalate Dimethyl phlhalate Satuichcr B-16 (butyl phthalyl butyl glycolate) Santhtecr M-17 (methyl phthalyl ethyl glycolate) Tricresyl phosphate Triphcnyl phosphate Sanlolitc, Sannriif t. Momanto Tradtmarlci. \n U.S. Pat Off. HONS 078212 WATER PCB-SD0000064346 Toxicity Animal toxicity studies and 20 years of manufacturing and use experience indicate that Aroclor compounds arc not serious industrial health hazards. If the materials are heated to volatilization, ventilation should lie provided to prevent inhalation of vapors. This is true of other major components of the formulation as well as the Aroclor compounds. Related or prolonged skin contact should be avoided although there are few instances of skin irritation. Human patch tests with finished products containing Aroclor compounds have shown no irritation. Mon santo will furnish information on specific Aroclor compounds upon request. Shipping Information Regulation* Standard Container* Rail Classification Chlorinated diphenyl (synthetic resin, liquid, NOIBN) Synthetic resin, liquid, N'OIBN Snylhetic resin, other than liquid, NOIBN Truck Classification Synthetic resin powder, NOI Synthetic resin, lumps or solid mass, NOI -- None -- Steel and Fiber (Aroclor 1268, 5460) drums. -- Aroclor 1142, 1 148, 1154, 1160, 1162, 1168, 1221, 1232, 1242, 1248, 1254, 1260, 1268 -- Aroclor 1260 mix, 1262 mix -- Aroclor 256S, 4065, 4465, 5042, 5060, 5442, 5460 -- Aroclor 2565 -- Aroclor 4065, 4465, 5042, 50GO, 5442, 5460 Th Information contained in this bulletin it, to our ball knowledge, trva end accurate, but ell recommendation! or luggaitioni ara made without guarantee, tinea the conditions of uie ara beyond our control. The Monsanto Chamical Company disclaims any liability incurrad in connection with the use of these dele or suggestions. Furthermore, nothing contained herein shell be construed et a recommendation to use any product in conflict with aiitllng patents covering any malarial or its uta. - vrv'ivri-- 12 HONS 078213 WATER PCB-SD0000064347 Trademark Index Trademark Company "Aerosol OT" "Ambcrol" "Amsco Solv" "Aroplaz" "Bakelile'' "Bcckacile" "Bcckamine" "Brckopol" "Beckosol" "Beetle" Resip "Cellosolve" "Clorafin" "Cumar" "Duraplex" "Esterol" "Formvar" "Gclva" "Glyptal" "Hcrcolyn" American Cyanamid Company Rohm & Haas Company American Mineral Spirits Co. U. S. Industrial Chemicals Co. Bakelite Company Relchhold Chemicals, Inc. Reichhold Chemicals, Inc. Reichhold Chemicals, Inc. Reichhold Chemicals, Inc. American Cyanamid Company Carbide & Carbon Chem. Co. Hercules Powder Company Barrett Division, Allied Chem. & Dye Rohm & Haas Company L. Sonnebom Sons, Inc. Shawinigan Resins Corp. Shawintgan Resins Corp. General Electric Company Hercules Powder Company "I-ewisol" Hercules Powder Company "Neville'' Neville Chemical Company "Pentalyn" Hercules Powder Company "Petrcx" Hercules Powder Company "Phenac" American Cyanamid Company "Reryl" American Cyanamid Company "Solvasol" Socony-Mobil Oil Company "Solvesso" Esso Standard Oil "Subelite" Ester Hercules Powder Company "Stabelile" Resin Hercules Powder Company "Super-Beckaclte" Reichhold Chemicals, Inc. "Syntex" Flintkote Company "Teglac" American Cyanamid Company "Tollac'' Neville Chemical Company "Troluol!'' Anderson-Pritchard Oil Corp. "Transite" Johns-Manvllle Sales Corp. "Velslcol" Velslcol Corp. "Vinsol" Hercules Powder Company riiiut ii t.i.i. 13 I MOHS 078214 WATER PCB-SD0000064348  WATER PCB-SD0000064349 LU YOUR "ASKAREL" TRANSFORMER SHOULD BE REt 000876 / WATER PCB-SD0000064350 LET'S TALK ABOUT THE M IN TRANSFORMERS OILS -- that can burn Thorn are quite a number of these. They are sold by oil companies; and those mineral oils aro used in transformers where, if they catch fire, no great harm tbesides the transformer itself) comes from the burning oil. If water gets into an oil-filled transformer, it tends to settle through the oil to the bottom. There are certain ways to cheek on the health of mineral oil insulation, too, but the "Check points" are somewhat different than for askarel. ASKAR ELS -- that cannot burn Although there aro TWO fj/prs of askarel fluids (supplied under a number of brand names), actually they all have just one and the same basic ingredient: Monsanto's Aroclor*' 1260. (If you want to know, Aroclor 1260 is he.xachlorobiphenyl). And THIS is one of the world's best liquid insulations! REY 000877 WATER_PCB-SD0000064351 don't worry about "different kinds' So, what. are the two types? What's the difference? Simply this; (hey have different pour points and the tiny amount of "scavenger" chemical added to each is different. The I'vranol N70 (General hilectrict type has the lower pour point; it will still pour at 17 below (F.i aero. Thu Inerteen ITU (Weslmghousoi type will pour down to 2GC below 1F.1 /.ero. These two types each contain a tiny amount of a dilferent additive; both additives are good and do their job. However, the additive in I'yranol type askarel can crystallize nut a bit at 14 above 1K.1 zero. It does no harm; the crystals disappear after a while when the transformer warms up. Other brand names, like (fhlorextol i Allis Chalmersi; Nollamol i Wagner Kleelrici; Ashcstol lAmertran Corp.i; Saf-T-Kuhl iKuhl- in;iii Klcctrici are either one type or the other. Some manu facturers simply call their lluid by the common descriptive name: askarel. Hut. transformer manufacturers who supply askarel fluids have sound reasons for favoring their own type. So, it's best to slay with your particular brand. However, since basically askarel is askarel, there will be no difference in the operation of your transformer if IN EMERGENCY you would interchange or even mix the two types! Hut askarel is NOT oil cannot, should not, must not be mixed with ordinary transformer oil. For one reason: the inside core materials used with mineral oil Tilled units get gooey with askarel. For another reason over 2'of mineral oil mixed into askarel "clobbers" its lire resistance. For another reason never mind! Don't mis or interchange utkarcl and ait. "Askarel" liquid insulation is a very carefully-manufactured, highly pure, chemically made fluid. It does not vary in composition like the range of oils. AND . . . askarel ia limner than water. If water gets into askarel insulation, only a smidgeon 1125 ppmi dissolves the rest flout* an tap. Ankuret is one of the maul Jire-rvxixtunt, chciiucalhj-incrl, heat-Mahlr tii/nuta crcr iterelopcii! You cun be sure of this: askarel dues not deteriorate when exposed to air, heal, hot metal; it does not break down over long use to form conducting or corrosive chemicals; it does not sludge or oxidize. Askarel will remain perfectly stable year after year after year unless broken down by exposure to severe arcing the kind that could set an oil transformer afire. The only real "enemy" of askarel is: contamination by water. REY 000878 / WATER PCB-SD0000064352 NOW LET'S TALK year to year oocrcl One of the most brain-y electrical engineers in the business once said: "The best 'maintenance' for askarel transformers is KEEP 'KM DRY, and leave them alone!" This business of "keep 'em dry," however, whether your trans former is EITHER an oil-type or an askarel type, is the watchword! It takes some care. In fact, anything MECHANICALLY you can do to stop moist air breathing and condensation will be the best health insurance for your liquid filled transformer. Here are some of the questions that come up when you want to "keep 'em dry." Is your transformer a welded shell or a gasket top? (even the tightest gaskets can "breathe!") Does your transformer run, stop; run, stop; run, stop? (This hot-to-cold temperature cycling makes the breathing faster and harder!) Is air around it mostly cold and dry or hot and moist? (Wouldn't it be great for automobiles and transformers if there wasn't any such thing as condensation!) When you have "breathing" and high humidity -- you can cut back on check-ups if you fit the transformer with a drying device tall transformer makers offer these) or you can bleed dry nitrogen into the shell. Any mechanical steps you take to stop inside con densation will be double insurance on trouble-free operation. Of course, if you are ordering a brand new transformer - - either oil or askarel type -- you can "design out" most of the moistureentry points. Basically, you call for all-welded construction, in cluding fins, pipes, and instrument connections AND a recessed gasket for the hand holes. (If you or your electrical equipment supplier would like more complete details on tips to keep innards dry, we can send you a copy of: "Design Details For Moisture Protection of Liquid In sulation Transformers.") So you'll be happy to learn that preventing moisture contamina tion is the only major health insurance you need provide for your askarel insulation. rEY 000879 WATER PCB-SD0000064353 CHECKING THE CHECKPOINTS Now you are well on your way (.u being an "expert." Since you know that keeping tabs on MOISTURE is the major checkpoint on your askarel transformer, let's ask: How do you keep tabs on moisture? You do this by a periodic test o( the askarel's dielectric strength. Do not bother to check -- or If you do -- do not be misled or dis turbed by relatively high power factor... or even a drop In volume resistivity. (If you want to know why, you can read the fine print on the following page.) The DIELECTRIC STRENGTH of the askarel is your major clue to the "health" (i.e. dryness) of your askarel transformer. Besides taking a good look at a sample of your askarel -- dielectric strength is the only "test" you need actually run! Here's why: the dielectric strength of askarel is sensitive to moisture; nof tensilm to other ordinary contaminants (like metal dust, salts, dirt, etc.). The dielectric strength is also hurt by severe arcing, but you'll know that arcing is the culprit if the askarel has gotten noticeably black or has particles of sooty carbon floating in it. Unless you've had severe arcing (lightning, accidental overload, back surge, etc.), the dielectric strength is your "moisture indicator." New askarel has a minimum dielectric strength of 35 KV at 25*C.; a maximum moisture content of 30 ppm. If you check the dielectric strength periodically, And that it is rapidly decreasing -- this is your "clue" to moisture pick-up, arcing, or both. When the moisture content rise to 100-120 ppm (or over) -- the dielectric strength will drop to 20 KV or less. That's your clue! INSPECT FOR WATER CONDENSATION IN THE SHELL, AND "REFINE" THE ASKAREL. As the operator, you will have to judge how oflen you want to check up on your askarel insulation. Steadily running, well-sealed askarel transformers have run as long as 25 years on the initial charge of askarel -- and the dielectric strength still checked out at above 30 KV. HOWEVER, if the dielectric strength drifts down ward to 25-20 KV at 25*C. -- then it is time to "clean-up" the liquid insulation and to get rid of any water accumulation in the shell, too. This askarel clean up is relatively simple; the askarel need NOT be discarded. BUT MOST IMPORTANT . . . if the dielectric strength drops rapidly over a short period of time, this shows rspid pick-up of water (or arcing). When you take your sample for check-up -- be sure to take it carefully (so it represents the surface) and handle the sample properly (so it doesn't pick up moisture in the sampling). R1Y 000880 / WATER_PCB-SD0000064354 REY 000881 WATER PCB-SD0000064355 You'll he able to "take tin: pulse" of your askarel insulation with the following five simple rapid tests, i Three are simply "inspectionby-eye!"i You can do these check-ups yourself or have the tests run by a local transformer service shop. COLOR (by inspection! New askarel is a clear, faint- vellow liquid. After long-term use. the color will gradually intensify to brown. Any color change, such as taking on a green, red or blue cast, indicates extraction. If you find a distinct change in color, the complete range of electrical characteristics should be checked to learn if the extracted color is the tell-tale for contamination. CLARITY l by inspection i New askarel is clear and should remain clear in service. Development of turbidity or cloudi ness indicates contamination from water, insulation par ticles, metallic dust or dirt. Cloudiness or turbidity calls for a complete analysis. The exception to this would be cloudiness in a cold sample of I'YRASOL 1 i70. This type askarel contains a scavenger additive which will "come out" of solution when cold (around 15F.i and cause white turbidity and perhaps show salt-like deposits on the trans former shell. If thi3 is noticed, heat the askarel sample to 150-200F. for several hours and agitate. Upon heating, the Pyranol's additive will redissolve, as it will in a warm transformer. BUCK COLOR AND SMALL CARBON PARTICLES (by in spection) - If the color of the sample is black, and especially 3 if suspended carbon particles can be seen, this shows lhat the askarel has arced and should be discarded. You can also detect exposure to strong arcing chemically, with indicator paper. Simply dip a piece of moist blue litmus papier into the askarel. If the blue litmus turns red. there is excess acidity from arcing beyond the limit absorbed by the "scavenger" additive. REY 000882 / WATER PCB-SD0000064356 skare.. insulation DIELECTRIC STRENGTH (by A STM l)<>01, 1)877, The dielectric sircnj'th is tin* most important; and it is a simple test to make. The dielectric strength of new askarel is 25 KV at 25(\ minimum. This value should not he allowed to fall below 25-20 KV. I onlammant.s twhich may have pronutincod efTecl on the power factor and volume resis tivity I itxnalh/ do not lover asknnl's dielectric xtrenyth. Reduced dielectric strength almost always shows exposure to strong arcing or moisture contamination. MOISTURE The moisture content of new askarel is 20 parts per million maximum. The moisture so/a ration level is about 125 ppm at ordinary temperatures. When the moisture content approaches 125 ppm (saturation level', the dielectric strength goes down. The moisture content of askarel should not be allowed to rise over 70 ppm; it should l)e held as near as possible to 20 ppm. NOTE: If your sample shows 20-25 KV dielectric strength, you need not cheek for moisture. However, if you do check moisture, use the Karl Fisher Method, ASTM IT-1522. IF ANY OF THESE FIVE CHECK-UPS APPEAR ABNORMAL, CON TACT YOUR TRANSFORMER MANUFACTURER FOR COMPLETE ANALYSIS. Those simple tests will show you the condition of your askarel insulation, but only indirectly the condition of your transformer. They can lie relied upon when the sample is carefully taken iso as not to "miss" water globules floating on the surface or adhering to the shell in the air space over the insulation/. So, if you have taken mechanical precautions against moisture entry into your askarel transformers and can "Keep 'em dry!" these tests will he your assurance that, between checks, you can "Forget 'em." `The American Institute ol Electrical Engineers has published a comprehensive and informative guide tilled ''Proposed Guide lor Maintenance of Transformer Askarel." AIEE No. 76, December 1958. This guide describes properties to be inspected and the ASTM method to be used Monsanto completely analyzes each production lot of transformer askarel hy these methods prior to shipment. However, these official tests are NOT ES SENTIAL to the user of askarel transloimers. When a complete analysis is re quired in a special case, the user should request it horn the transformer maker, who in turn can call on Monsanto if needed. REY 000883 i / ! WATER PCB-SD0000064357 GROOMING ASKAREL FOR RE-USE If strong arcing has blackened askarel, throw it away; it costs less to replace arceil insulation than to reclaim it. If there's been no arcing, but a low dielectric test shows moisture contamination, you'll find it is quite easy to refine the askarel back to good operating dielectric strength. Simply run the insulation through a dry. ab sorbent filter. Most operators prefer a portable refining apparatus, such as a plate press, fitted with a dolly, (available from Sparkler, Mundelein, III.); or the earthen cartridge filter type, (available from Industrial Filter Corp., Lebanon, Ind.). Filter paper liners for the plate press are available from Carl Schleicher & Schucll Co., Keane, N.H. Any flexible hoses and gaskets on the refining equipment should be lined with or made of materials that will not be softened by contact with askarel fluid. (Silicone or Teflon materials are suitable). If you use a filter press, before refining it is advisable to oven dry the filter paper at 100C. for a half hour to remove all moisture. If the askarel to be refined contains excessive moisture, circulate it hot (55-60C.) through the filter fitted with the paper liners only first. Then, refit press with dry paper and load it with the absorbent earth. The earth refining process is simple; 1. SPREAD DRY EARTH EVENLY OVER THE FILTER SURFACE. Fine-mesh Attapulgus clay or Fullers earth, dried and activated by heating tor 12 hours at 250"C. immediately prior to use, is highly efficient. The amount of earth used should be 0.1 to 0.2 per cent by weight of the askarel (askarel weighs about 13 pounds per gallon). To deposit the earth evenly, stir one-third of the earth with a small portion of askarel in a clean container. Pump the mixture through the filter and follow with tv/o more one-third portions. 2. PUMP THE HEATED ASKAREL FROM TRANSFORMER THROUGH FILTER. Circulate askarel taken from near the top of the transformer, pass it hot (55-60*0.) through the filter and feed back through the bottom transformer outlet. 3. CONTINUE CIRCULATING THROUGH THE FILTER UNTIL ASKAREL IS CLEAR. When the askarel is clear use the simple tests described earlier to check tor restored dielectric strength. 4. CHECK THE TRANSFORMER AFTER REFINING. After refining the askarel, the overall power factor and insulation resistance should closely approximate the values it would show with new askarel fluid. If the overall power factor is more than 30-35 per cent (at 20C. and 60 cycles) it is considered POOR and it is advisable to run a complete analysis of the entire insulation system. REY 000884 / WATER PCB- POWER FACTOR & VOLUME RESISTIVITY High power factor and low volume resistivity in transformer mineral oils are commonly regarded as "danger signals" that the ml lias deteriorated anti broken down chemically. This is NOT true of askarel liquid insulation. New, unused askarel shows these electrical values: I'owcr Factor: 0.05-0.2% ( 60 cycles. 20C. (about 1-2.0% (" 60 cycles 100C.) Volume Resistivity: X00-1000 x 10* ohm-cm (d 100C., 500V., DC., 0.1" gap i Used askarel from SATISFACTORILY OPERATING TRANS FORM MRS normally (and frequently) shows Lower Factor: 20 to 80% (" 60 cycles. 100C. Vuliiinc Resistivity: about 25 x 10 ohm-cm (( 100"C., 500 V., DC., 0.1" gap) This relHlively high powor factor nnd relatively low volumu re sistivity of used askarel ARK TO RE EXLECTED. Even at these levels, the askarel's dieloclric strength is STILL in the 30-05 K V range. The reason is simple: askarel, unlike "oil," is a relatively polar liquid. The volume resistivity is sensitive to traces of conductive contaminants. However, even in the presence of largo amounts of contaminants, the volume resistivity (loos not seem to fall below 10 x 10* (ohm-cml. Yet the dielectric strength remains high, be cause intrinsically askarel remains a non-conductor. To quote from Insulation Magazine, December 1961 DIELECTRIC LOSS YARDSTICKS by John C. Motts, Manager Insulation Development Section, and Graham Ixjo Moses, Manager Services Engineering, Weelinghouse Electric Corp., East Lillaburgh, La. "Dielectric loss is a good comparative evaluation for some characteristics of insulation. It may be used fur comparing similar samples of the same materials. It may not be used as an overall evaluation (or com paring different materials." ti.e. "oils" and askarclsi Lower factor is not an important criteria of askarel insulation efficiency IN A LROl'KKLY CONSTRUCTED TRANSFORM EH. However If improf>er construction materials or unpredictable foreign contaminants enter the system - high power factor tin t.ho absence of moisture in the shell) can indicate improper construction. REY 000835 < WATER PCB-SD0000064359 NOW . . . .since you know that Lhe 1)1 KI.KCTItK' STKKNGTI1 is lhe most important checkpoint, and tlul 'except for arcmgi MOISITKK is the villain that saps dielectric strength \mi want to make sure that your SAMI'LK truly represents your askarel insulation. TAKE YOUR SAMPLE AS CLOSE TO THE TOP OF THE LIQUID SURFACE AS POSSIBLE! (Many large askarel transformers have a built-in sampling tube near the surface for convenient sam pling. If additional sampling tube connections arc contrived on to valves for easier sampling, make the tubes of clean glass, stainless steel, aluminum or tin fur rigid types; and silicone or Tellon tubing for ilexilile types.) Wafer Jlouls on askarel. If there is any water in your transformer, it may collect in little puddles ON TUI' of the askarel. AND, therefore, more water will probably be dissolved in the askarel near the top, where it contacts any collected condensation. If you IIiid low dielectric strength and high moisture in the askarel, you will probably want to thoroughly dry out the shell and take some mechanical steps to keep it dry. When you take your askarel sample for testing, take the same precautions (but no more) that you take when sampling mineral oil: 1. Select a dry day. Do not sample insulation on a warm, moist day when humidity exceeds 75%, and 2 Make sure that the askarel is at least as warm as the sur rounding air. (Cold liquids can condense moisture from humid air.) 3. NEW containers (or fluid sample Your sample container should be a new and previously unused small mouth pint glass bottle fitted with a Bakelite screw cap fitted with an aluminum or tin bottle cap liner Make sure that the new bottle does not stand around open to collect dust or moisture. Rinse the sample bottle and cap lining two or three times with askarel from the transformer; then fill it. When sample will be tested promptly, a clear glass bottle can be used. If sample is to be stored indefin itely, use an amber glass bottle or wrap clear glass with aluminum foil. Whenever a sample is to be shipped to the transformer manufacturer (or to Monsanto) for complete analysis, the container must be a 5-pint amber glass bottle. For your convenience, various transformer manufacturers and Monsanto will send you the sample bottle tilled with new askarel. You simply empty out the new askarel and re fill bottle with your sample. REY 000866 i WATER PCB- df y" 0oloclfit Shoo^ll*. 30 35 KV Moislwic Content: 30 50 ppm Moisture Condensation (Jiclcclnc Strength: 75-20 KV ot less Moisture Content: 125 ppm REY 000887 / WATER PCB-SD0000064361 THAT'S THE STORY: keep (`in (Iry... let cm alone! Uul you might want these storage and handling "tips" to make you a complete transformer askarel expert. STORE NEW ASKAREL IN A CLEAN DRY PLACE Keep the 5, dO, or 55 gallon drums dry; turn them over on their sides to keep water off the drum head. (It can be sucked in by the drum "breathing."i CLEAN UP SPILLAGE Askarel can, if left standing, attack paint, rubber, or plastics. Absorb it from floors with sawdust, sweep, and then wipe dry. Use a rag wet with mineral spirits if you want to make sure it's all cleaned away. TAKE ORDINARY PERSONAL CARE Transformer askarel has been made, handled and used for over :)0 years without causing toxic or other ill effects. Askarel can be handled in the same manner as insulating mineral oil. As with mineral oil, there may be some people allergic to askarel, so pro longed skin contact should be avoided where possible, When accidentally spilled or splashed on the skin, askarel does not present an acute hazard nor will it cause serious skin irritation. Simply wash it off with soap and water. If work clothes become impregnated with askarel, they should be removed and washed. K.ye contact may cause temporarily painful irritation but NO PERMANENT DAMAGE to the tissues or sight. Flush the eye with large amounts of water. A drop of castor oil may be put in the eye. As with all eye first-aid, refer to a physician who will treat the eye with an ointment. Ordinary, infrequent exposure to askarel vapors will not cause any ill effects. However, prolonged exposure to strong vapors should be avoided. If hot fluid is to be handled in a closed or confined area, provide ordinary exhaust ventilation. Harmful concentrations of askarel vapors are easily delectable by Ihe smarting of the nose or eyes. Should hot askarel (above 100C.) have to be handled in the open in a confined, unventilated area it is advisable to wear organic canister-type masks as supplied by Mine Safety (' '''Mshurgh, I'a. RY 000888 / WATER PCB- (AS FAR AS EQUIPMENT CAN BE I) best friend! Since "askarel" type transformers were first made in 1930, few pieces of electrical equipment have equalled these "juice controllers" in trouble-free service. The name "askarel" applies to the liquid insulation that fills askarel type transformers. And "askarel" is a general name for a unique kind of chemical classified as a halogenated hydrocarbon. But, don't let this chemical jargon bother you one bit. After you read this little pamphlet, you'll be an EXPERT on operating askarel transformers; you'll know all about this wonder ful liquid -- askarel insulation -- because it's all very simple. Since many engineers and maintenance operators work with BOTH askarel and transformer "oils," you will want to remember that askarel is different from mineral oil . . . and you'll want to know the simple ways to "check up" on the health of your askarel transformer. That's the reason for this pamphlet. First, to tell you that your askarel transformer, in addition to being FIRESAFE, can be the most trouble-free piece of equipment you operate. Second, to give you the few simple facts that will make you an expert on the "whys" and "wherefores" of the easy maintenance. Knowing the facts given on the following pages, you will keep your askarel (and transformer) operating at trouble-free, top performance, year, after year, after year.* *We own one thet hog been operating at faithfully at a heart beat for 28 years / REY 000089 WATER PCB-SD0000064363 Monsanto a/so supplies: Pydraul AC All synthetic fire-resistant compressor lubricant. Pydraul All synthetic fire-resistant hydraulic fluids. Thermal Fluid Fire resistant, non-vaporizing heat transfer fluid. Coolanol Dielectric coolants for high power electronic circuits. Fluid OS-59 Dielectric for high frequency power transformers. MONSANTO CHEMICAL COMPANY Aviation and Special Fluids Department Oigamc Chemicals Division St. Louis 66, Missouri Askarel transformer fluids can be ordere directly from any one of these Monsanto sales service centers Atlanta Boston Chicago Cincinnati Cleveland Detroit Houston Los Angeles Minneapolis New York Pittsburgh St. Louis San Francisco Seattle Syracuse Wilmington REY 000890 > 111M0 It llt` WATER PCB-SD0000064364 TuU^Aosm0,, Tl/ica./te*4e DATA SHEw , FOR TOXICOLOGICAL AND SAFE HAWDuHG INFORMATION (P 1 ee-so Cesl<?U A&ptUcMla 1. Product name, number, synonym:--Pydraul--150 2. Nanufactursr'a name:-. Mon!fHt0-^ginlc&1 Company 3. M&nufacturer'a address , 800 H. Lindbergh Boulevard, St. Louie 66, Missouri 4. Procedure In Case of freak age or Leakage:__Clean up >.8 With any lubricating oil or hydraulio fluid. 5. Transportation sod Storage Requirements: -- 6, First Aid Treatment: a gum N sgrJ.oug immediate effect, Wash Kith soap end we ter to avoid prolonged and repeated akin exposure, b. E>. gytact: for *fc le&Bfe lS.Rlnutfe with water, Q.et xdlcal tten ciSfi. Physicians hay# used 1% nontocaln# solution and^ophthalmic cortisone acetate solu. to relieve smarting and Irritation, inhaiin,fli Low degree of haiard due to low volatility at normal __ temperature. d. AnUdote m case or*s.allowing: Xnduoe vomiting and refer to physician. 7, Physiological Properties: a. Acute oral .iet,r Rts - lethal dose greater than 26,500 n&/R&, b. lxrcai effects upon &rilmalB - mild irritation,___ Wild, irritant to humar but with pain out of proportion to degree of irritation. c. Local effect* upon skin . Classed as mild skin irritant. and oils on surface of skin. Dissolves natural fat .Low degree of hazard due to low d. Estlmaattf pf acute hazard by InnsJatton (volaUle materials):.^" .V TM VOi a* ' tillty at normal temperature. Laboratory animals survived six hOUrTB exposure to atmosphere saturated .withvaiuiriL,--------------------------- (Be National Safety Council recommendation's fur toxicity evaluations) e. earning Properties (Odor, lrritatioD to eyes, nose, or throat);--^^harac te_rl Otic--odor, f. Estimated threshold limit value (If not on current lint by American Conference of OovmmweitaJ Industrial Hygienists):----------------------------------------------------------------------------------------------------------------------------------------------- I. Chemical and Physical Properties: a. Specific gravity (water 1)--^ . 12,3 9 5 .P. >x b. Vapor density (air - 1). c. Vx>r preaaure mm Hg aEBKJCX 0,1 01,111 200?. d PH_2*l.eutr*L I u i DEFENDANT'S DEPOSITION I exhibit HONS 098018 "ft WATER PCB-SD0000064365 @. Corroalva action on air '.materials wet) as; aluminum; magnealum; p glaix; rubber. laeguera; fabric.: HOC oorroslys.____________________________ f. Doee the material 6%<xm&ow rioleutly when exposed to air? Wstsr? Heat? Strong oxldleers?_____ No. g. For mixture* or inpurltie* girt the percentage composition of Ingredient.: CONFIDENTIAL - A phosphate ester base fluid containing chlorinated hydrocarbon*. Compound Percent HOT!: is. Pleaaa fet specific. For example: It la Important to kaovs Pettier or not fce alcohol portion ooaUina methanol; the aronaUc portioe, benune; the chlorinated portion; cirboo teU etc. Doe* (he material generate beat through polymerisation?__ ^IL:....................................... ........... i. "r wnrai ontwerinii. m rim.- Avoid repeated, prolonged Inhalation of vapors or mlete. Avoid contaot with eyte or prolonged oontact with skin,____________________ _________________________________________ h. aaoommonded Protective Eguipnaot: None, should.be, required,!f,,Pydraul 1^0.is used as recommended. n. a. Flanh point F: Closed cup tic, glee data: ... . lan If F. P. changes during evapors* b. Explosive limits (* vot. air): boner--: Upper--Z ~~ " o. SueoepUbiUty to tkjontaneou# Heating: Yea----------; No---------------- ------- d. Fir# point r rOlSltl/l^uto ignition temperature F---- Above , 1100, _ a. Vapor density------------ f. What proieetn might be formed In the event of fire or abnormal lemperatsres?__ PQj P0p phenolica, HC1. ____________________________________ , g. Suitable extinguishing agents: --FAF- - 8 ^.s It tafomatioa pvraiehed Br. Mr, Elmer F. Wheeler TUSe: Assistant Direotor, Medical Department oompaar: Monsanto Chemieal Company anm: 800 North Lindbergh Boulevard DtU: St. Louis 66, Missouri ' ' March 31, 1961 HONS 098019 ROTS: ^formation In regard to this material'a oompotitioa will he treated as oonQdantial end eeed only for tha pspoae of pfoteotiat the health m& mMs of ARO tloyes end the safeguarding of Its property. WATER PCB-SD0000064366 DXU SHUT f TOXICOLOGICAL AMO SAFE HAMOL i INFORMATION (Flseae Csmpieta Applicable SactlMi) t, Product name, number, synonym: _______AC........................... ............................................... 2. Manufacturer'* name: MONSANTO CHEMICAL COMPANY 3. Maatfacturer'a iddre..:___ St. Louis, Missouri________________ ______ 4. Procedure is Case of Dreakaje or Leakage! n\\ 5. Transportation and Storage Requirements: _ Ha jpacla.1 rehilLt&mabta 6, First Aid Treatment: a. Skin contact: WflJifa Wl fcfa_ SQftp, And--ifiLfcjer. fe, Eye eataeti PlUJlh With C QplOUfi. _QUAX)tAMA,,n^ ytMkMF____OMXumAL&&X~------ ------- Attention. PtoMGllina_Ard.uALl.nn end OOMMiaifl MXJMKmSy COrtlBQIll_JACfltAte_JLalJULbl^^ Jind .tjgiljSJbJL/yp) InhAlfetlMLt __Bujl to low volatilityf lnhajlAtlJan lffl nQ_kazjLPdL----------------------------------------- d. Aml date la cast el #elksHag: Induce V Qa.lM.ng and rafar hn phya 1-af pn.,------------------ 7. Pbysislogical Properties: a. Acute aid toaiclty: AppgjaxlmaAaiJ y Ul\ AQO-jag/kg------------------------------- RAbblta - xrj) to -----------_---------------------------------------------------------------------------- b. Uea! effects upon ryeai Id ------Mild IrrltJLttk-tO hUMsUl& hut with pain ruit. f proport<on -k*? di^iret- .lrrltAtiOH.---------------------- e. Local affects upsti tfcia: _CllJMIdL A.fl_BlldMa&ln ---- DlaJLaly.ai-.mt.UXAl----- tailB - BlMller to pelntifciilnngra---------------------------------------- ---- 4 . Estimate at acute be seed bf Wmlstie* (ealaUle materials): _ Lqm _degre.eL_jaf,,Jm^AFJl-JlUa_fca-----low volatility it normal temperature. laboratory &nlx _hre> fexponure to atmospheres saturated Wllb_lfJJ5arfl _ -----------^------- (See Natianal Safety Cowell tree--isdatlena for toxicity ceabsatises) . e, farnlni Prof ittlce (OtWs, ittltailen W> eyai, note, at ^eoat)t .MJJLd-JEtlfiMlILQt JOdfllL.---- M&JBBlAUA_ exposure to mist, aerosol or vapors Irritating to eyef.t------------------------ f. Estimated tfeeefeoid IWi wKw (if eet on current list If Ametken Conferenee et Ckeetamantsl Mtetilal Hygienists^ -------------- --------------------------------------------------------------- ------------- ------------------------------------- ,8. Chemical sad Plytka) Properties: a. Specific gravity (itr s I) 1.3^0 tO^l . "jSO b. Vapor density (air * I) 11.2 e. Vapax yoctxuit mm lip at 25C ^ ^________ A PH Neutrelltetlon Nbr . Ci.i& max. '(Ph not. determined on TuiT! i.nea.Rt HONS 071293 WATER PCB-SD0000064367 rm 2 t <inn nn tltntli matrtUli uch a*: aluminum; itagnenltani', plefljtUttl KjWxts Infmi; mamMa-. Not corrosive, . my s.oCt.eo. soqg i^pqyrt#_enatls or other, synthetic surfacee.._.. ---- ------------ ... _________________________ ______ Ufti'l dmimpon violently arhrn eipoapd to air! Vmett Meat! Strong naldUtraf... PYDRAUL AC la $ proprietary ^product and we are under obligation not to Jleclos its coapoaitiM)/ ' NOTE For aeompla, gonerolliotlom each 01 petroleum hydroccrboni, sfeeholt, ketanat, cfilorlnatad hyAafkane, etc. o*o not odoquota (or loalcologicol avoluotlan. Proper ckamlcof nemet ! b kneorn, li. I Mr * I hr Mitrlil grnrtete bent through polyrMfltatlen ot CWldriuetn? ___________________________ _ 9- IVcautioni (or Normal Conditio*. of Uaci Avoid repeated^ prolonged .. MS jalaJfcAL.__ Avoid oontact wltfr eyam nr pnftTnnga<i. With akin. <1. KrcommcnJed Protective Kquipwtgat: _ Mani_^JriQU.LdJbja FyrtF^n'l 1 * nffd . m .Mfiooattndfiii.________________________________________________________________________________________________ 1 I. a. Flarh point F: Closed Not Uted . QpB ceq> **70 ^ jive data;________ t If P.P, clM|i 4sIa| avapoeaelon b. EipUalvt lladu ( *f. akfc <- ITnlmown C. I Dppt UntalQWn (. *kt product. al|M ke Imm4 k As wie of (fee * obnoresl trrfwtwrJ CQf CQ^--phenol 1 r.g , HCL. *. Suitable estlnguloStihg tgmn Ssmb as ' for any fire rt8 lalEht-JAmthetle material. 12, Information Furnl.hed Bp Mr, Elmer P. Wheeler Titles Assistant Director, Medical Department Company: MONSANTO CHEMICAL COMPAMT Adrtreva: 800 North Lindbergh Blvd., St. Louie 66, Missouri Dau-. January 15,1963 NOTE: Information In record ka fhli rwtaaled't composition will b treated at confidontlol atd uaad Only fce A# purpoa* o( protecting tit* hrdMh nnd lahty ol Booing amployaa* aid tht ttdagu ending l lt propaety, Tko completed (orm ihould b* moiled to Induitriol Hyglana, Booing Airplon* Company, Soottl# 24, Woihlngton* t)taeagard If previoutly occomptlehad. HONS 071294 WATER PCB-SD0000064368 <5- :y W ato . AsSKA lift f. fuiib'.oHoa -ami mawtmw ar>ivwo iwy'ir. wm WATER_PCB-SD0000064369 r^/~i Monsanto L_M_ ASKAREL Inspection and Maintenance Guide / RY 000920 WATER PCB-SD0000064370 TABLE OF CONTENTS * . SECTION A TRANSFORMER ASKAREL Page I. Introduction............................................................................................................ I II. History of Trade Name Types............................................................................... ) Tabic I -- The Composition of Transformer Askarels III. Tabic II -- Official Transformer Askarel Shipping Specifications................... 2-3 A. General Electric Company's Transformer Pyranol AI3B3B B. Westinghouse Transformer Inerteen PPO (7336-9) IV. Interchangeability and Stability........................................................................... 4 V. Directions For Handling and Personal Precautions............................................ 4 VI. Expected Service Life............................................................................................. 5 Vli. Dielectric Strength -- Moisture Relationship..................................................... A. Table III -- Dielectric Strength vs. Amount of Dissolved Water in Askarel and Mineral oil B. Table IV -- Approximate Solubility of Water in Askarel and Mineral Oil. 5 VIII. Table V -- Typical Values Found in Askarel Fluid Under Various Con ditions of Use......................................................................................................... 6 IX. Check Points For Maintaining Askarel Insulation............................................ A. General Considerations B. Modern Scaling Procedures C. The Older Scaling Arrangements 9 X. Periodic Fluid Inspection...................................................................................... A. Visual Inspection B. Dielectric Strength II XI. Inspection Check List....................... ................................................................... 12 XII. Contamination in Transformers.......................................................................... A. Table VI -- Effect of Common Insulation Materials on Power Factor and Dielectric Strength B. Table VII -- Effect of Common Insulation Materials on Volume- Resistivity 12 XIII. Refining Askarel For Re-Use............................................................................... A. Filtering Through Dry Blotter Paper To Remove Moisture and Extraneous Particles. Table VIII -- Guide to Rate of Dissolved Water Removal By Filtration. B. Earth Treatment for Maximum Improvement of Power Factor and Volume-Resistivity 1. Procedure 2. Effect of Earth on Removal of Scavengers 3. Table IX -- Approximate Relationship Between Power Factor, Volume-Resistivity and Dielectric Strength of Transformer Askarel 14 XIV. Cleaning Arced Transformers.............................................................................. 13 XV. Sampling ASKAREL....................... '.................................................................. 17 REY 000921 WATER_PCB-SD0000064371 SECTION B ASKAREL FILLED SWITCHES AND TERMINAL CHAMBERS Page 1. Introduction.................................................................................................................. 18 II. Sources or Contamination................................................................................... 18 III. Scaling Switches and Terminal Chambers............................................................. 19 IV. Askarcl-filled Switches' Maintenance...................................................................... 19 SECTION C Monsanto Analytical Services on TransformerAskarel....................................... 21 Appendix A. Askarel Stability and Composition of Arc Formed Gas..................................... 23 B. Solubility of Gas in Transformer Askarel.................... ......................................... 23 C. Approximate Vapor Pressure vs. Temperature ForTransformer Askarel-- 24 D. Effect of Temperature on Dielectric Strength of Askarel................................... 24 E. Viscosity of Askarel and Mineral Oil...................................................................... 24 F. Density of Transformer Askarels............................................................................. 25 G. Thermal Conductivity................................................................................................. 25 H. Heat Capacity............................................................................................................... 25 I. Coefficient of Expansion....................................................................................... 25 J. Fire-Resistance............................................................................................................. 25 K. Seals, Properties and Procurement........................................................................... 26 ' REY 000922 WATER_PCB-SD0000064372 SECTION A TRANSFORMER ASKAREL I. INTRODUCTION: This manual describes the operating characteristics of transformer askarel liquid insulation and how it differs from mineral oil. The information given is based on facts gathered by Monsanto over 30 years as producer of askarel, plus knowledge gained from the experience of transformer manufacturers and users. This guide is provided to outline the very simple mainte nance required for askarel fluid in "modern" transformers and to offer suggestions for the sealing and maintaining of askarel in old units. By following this guide, users will obtain maximum service from askarel insulation with a reasonable minimum of maintenance. If questions arise relating to the designing and building of transformers -- these should be referred to regular transformer suppliers. Monsanto gratefully acknowledges the assistance, guidance, and the contributions of certain data by the following: Frank M. Clark................................................ General Electric Edward L. Raab............................................... General Electric James G. Ford........................................ Westinghouse Electric George Shombert, Jr......................................... Allis Chalmers II. HISTORY OF TRADE NAME TYPES "Askarel" is the generic name for non-combusliblc (fire-resistant) liquid insulation. In this respect, the insulation is completely different from ordinary transformer mineral oils. Transformer askarel is marketed by Monsanto. Whatever the trade marked brand, the askarel contains Monsanto's Aroclor (chlorobiphenyl). . . one of the best liquid insulations developed by science. This inert compound is chemically stable, fire-resistant, heat stable, non-corrosive, and has high dielectric strength under the operating conditions encountered in transformers. , REY 000923 i WATER_PCB-SD0000064373 Askarcl liquid insulation is made by thinning Aroclor 1260 with trichlorobenzene or tri-, letrachlorobenzene mix. The first transformer askarel was made in 1932, in accordance with General Electric Company's patents, and was trademarked Pyranol 1488. Westinghouse, too, offered this askarel insulation in 1936 under then trademark Incrlcen. In the mid-1940's, as shown in the following table, tin telraphenyl was added to General Electric's Pyranol to scavenge hydrogen chloride. Shortly thereafter, Westinghouse added phenoxy propene oxide to Inertecn for the same purpose. In 1963, General Electric replaced tin telraphenyl with a diepoxide scavenger. This new formula, which replaces previous Pyranols, is called Transformer Pyranol AI3B3B. Thus, today the two commercial types offormulations arc General Electric's Transformer Pyruno! A13B3B type and Westinghouse Inertecn PPO (7336-9) type The composition changes made in transformer askarel formulations are shown in Table J. Tbl I THE COMPOSITION OF TRANSFORMER ASKARELS Inerteen Pyranol______________________________ MM 1467 1470 AI3B3D Inertecn (7336-9) Year Introduced....................... 1932 1944 1952 1963 1936 1945 Ingredients: Aroclor 1260 .............................. Trichlorobcnzcnc...................... Tctrachlorobenzerve................. Tin telraphenyl.......................... Phenoxy propene oxide.......... Dicpoxidc................................... 60 40 60 40 0.123 45 40 15 0,125 45 40 15 0.125 60 40 60 40 0.20 PPO OTHER BRAND NAMES Various electrical equipment manufacturers use other trade-marked names for askarcl liquid insulation, such as Chlorcxtol (Allis-Chalmers); Nofiamol (Wagner Electric); Saf-T-Kuhl (Kuhlman Electric). These askarel insulating liquids are one or the other of the two standard formulations. Still other manufacturers, who designate their insulation only by its generic name, askarel. assign it a number or code. By this number, Monsanto knows whether to furnish Pyranol AI3B3B or Inertcen PPO (7336-9) type formulation to the user. III. OFFICIAL TRANSFORMER ASKAREL SHIPPING SPECIFICATIONS The official shipping specifications for the two modern transformer askarel formulations are shown in Table II. / REY 000924 2 WATER_PCB-SD0000064374 Table II OFFICIAL TRANSFORMER ASKAREL SHIPPING SPECIFICATIONS TYpteal Properties General Electric Co. Transformer Pyranol AI3B3B Color. A PHA Condition Water content, ppm (ASTM D1533-60) Acidity, mg. KOH /g. (ASTM D974-55) 150 max. Clear 30 max. 0.014 max. Dielectric Strength. 25*C.. 0.1 inch gap (ASTM D877-49) Dielectric Constant, 100*C., 1 KC (ASTM D924-49) Volume Resistivity, 100*C, 500 volts DC 0.1 inch gap, 10s ohm-cm. 35 KV. min. 3.8 to 4.3 100 Inorganic chlorides, ppm. (ASTM D1821 and G.E. Method E4C4IB) Refractive index, 25C. (ASTM D901-56) Viscosity at 37.8X. (ASTM D88-56) Saybolt Universal Seconds Pour point "C. (ASTM D-97-57) Specific gravity 15.5yi5.5C. (ASTM D287) 0.10 max. 1.6075 to 1.6085 41 to 45 --44 or lower 1.560 to 1.571 Bum point (ASTM D92) None to boiling Distillation range (ASTM D20-56) corrected for stem and barometric pressure 1st drop 35% 55% 65% 95% 2I0C. min. 240 to 256 290 to 330 385 to 400 395 to 415 Westingbouse Transformer Inerteen PPO (7336-9) 150 max. Clear 30 max. 0.014 max. 35 KV, min. 3.7 to 4.0 100 0.10 max. 1.6137 to 1.6147 54 * 2 --32 or lower 1.560 to 1.568 None to boiling 1st drop 40% 200C. min. below 270C. 90% 395 to 4)5C. Fixed chlorine Corrosion test Color. APHA Acidity, mg. KOH/g. Inorganic chlorides ppm. Condition Scavenger content Arc formed gases Coefficient of Thermal Expansion (ASTM DI9Q3). CC./CC./C. 60.5 *5% 59.1% min. After heating with aluminum for 6 hrs. at 200 to 220C., the aluminum must not be corroded on either visual or weight in spection and the askarcl should meet the following specifications: 200 max. 200 max. 0.014 max. 0.014 max. 2.0 (tent.) 2.0 max. Clear Clear 0.115 to 0.135% Diepoxide 0.18 to 0.22% phenoxy propene oxide Less than 1.0% of total combustible gases including carbon monoxide, hydrogen and volatile hydrocarbons. 0.0007 0.0007 The above two formulas are used in modern transformers. There are a number of units in service dating back to 1933 with askarels of somewhat different compositions. These will be compatible with the above modern formulations. I I l it i,* i REY 0 0 0 9 2 5 I WATER_PCB-SD0000064375 iv. INTERCHANGEABILITY AND STABILITY A. Interchangeability: The two general types of askarel insulation shown in Table II can be either mixed or interchanged and there will be no difference in the operation of the transformer. However, askarel insulation must never he mixed with mineral oil. Over 2% mineral oil in askarel begins to lower its fire resistance. Further, materials of construction in the transformer that are compatible with askarel may not be compatible with oil and vice-versa. For example: a significant amount of askarel in a transformer built for mineral oil will attack gaskets, adhesives, core bindings, impregnating varnishes, etc. B. Stability: . Askarel liquid insulation is highly pure, fire-proof liquid made under close chemical control. It does not vary in composition like the commercial range of mineral oils. Askarel docs not deteriorate when exposed to air, heat, hot metal; it does not break down over long use to form conducting or corrosive chemicals; it does not oxidize or sludge, Askarel will remain perfectly stable year after year unless broken down by exposure to severe arcing. The only real "enemy" of askarel is contamination by water. Keeping askarel water-free will insure long-time service. Askarel is heavier than water. If water gets into askarel insulation, only a liny amount (125 ppm) dissolves -- the rest floats on top. V. DIRECTIONS FOR HANDLING A. Keep Dry: In handling, storing, sampling, inspecting askarel -- and in operating askarel transformers -- take every precaution to guard the askarel insulation from exposure to high humidity and moisture contamination. Keep 5, 30, or 55 gallon drums of askarel dry; lay stored drums on their sides with the bung at (he highest point from floor to keep water off the drum head (which can be sucked into the askarel by the drum "breathing"). This precaution is not necessary when drums are stored indoors, which is the preferred way of storing. B. Use Ordinary Personal Precautions: Transformer askarel has been made, handled, and used for over 30 years without causing toxic or other ill effects. It can be handled with only minor precautions. If accidentally spilled on hands, no serious skin irritation will occur. However, liquid askarel has a solvent action (similar to paint thinner) on the fats and oils of the skin and prolonged contact may lead to drying and chapping of the skin. f ` REY 000926 WATER_PCB-SD0000064376 In case of contact, wash olT the skin with soap and water; remove and dry clean saturated clothing. Clean up spills with rags, sawdust or absorbent clay. Eye contact may result in painful irritation but no permanent damage to tissues. If askarel gets in the eyes, flush with large amounts of water. As with all eye first-aid, refer to a physician. To relieve irritation, physicians have used a '1% Pontocaine as well as opthalmic cortisone acetate solution, or castor oil. Infrequent exposure to askarel vapors will not cause ill effects. However, prolonged exposure to high vapor concentrations should be avoided. If hot askarel must be handled in a closed or confined area, provide the area with ordinary exhaust ventilation -- or -- wear an organic cartridge respirator approved by the U. S, Bureau of Mines. VI. EXPECTED SERVICE LIFE Properly designed and installed askarel transformers will give trouble-free service for a minimum of 30 years. Since their introduction in 1932, the manufacturers report finding the over-all failure rate to be less than 0.5% for all units under test and service conditions. The Edison Electric Institute's report (1956-1958) on their member utilities publishes the failure rate for askarel transformers as 0.13 per hundred banks per year. Even the rare reports of failure are invariably found to be due to improper sealing that allows moisture to enter. VII. DIELECTRIC STRENGTH - MOISTURE RELATIONSHIP The dielectric strength of askarel is highly sensitive to excess moisture; not sensitive to ordinary dissolved contaminants. While the dielectric strength can also be lowered by severe arcing, askarel turns noticeably black or has particles of sooty carbon floating in it if arcing has occurred. Then the transformer should be repaired and the askarel replaced. New askarel has a minimum dielectric strength of 35 K.V at 25; a maximum mois ture content of 30 ppm. If the dielectric strength is checked periodically and decreases significantly -- this indicates moisture pick-up, arcing, or both. When the dielectric strength has dropped to 26 KV or less, an analysis for water is necessary. If water is found in excess of 100 ppm at 25 C., its source should be located and corrections made. When the moisture content approaches 125 ppm (saturation level), the dielectric strength of askarel drops below the value required for efficient insulating. The moisture content should not be allowed to rise over 70 ppm; it should be held as near as possible to 30 ppm. Maintaining a low moisture level will assure high dielectric strength and top operating efficiency. Table 111 shows the relationship of dielectric strength vs. moisture and Table IV indicates the approximate water solubility limits in askarel and mineral oil. 5 REY 000927 WATER_PCB-SD0000064377 Table III RELATION OF "BREAKDOWN STRENGTH" TO AMOUNT OF DISSOLVED WATER IN ASKAREL AND MINERAL OIL Breakdown Vuliage (ASTM) Water Content (PPM) Askarel Mineral Oil 0 20' 40 60 80 no 70 KV 35 47 40 38 10 50 KV 39 30 26 22 5 Table IV APPROXIMATE SOLUBILITY OF WATER IN TRANSFORMER ASKAREL AND MINERAL OIL Temperature Amount of Water (TPM) Dissolved C. "F. Askarel Mineral Oil --30 -20 -10 0 10 20 30 40 --22 --4 14 32 50 68 86 104 8 16 28 41 65 94 128 170 8 10 13 20 33 58 85 130 TURBIDITY . . . may be the visual sign of undissolved water, or may indicate contamination from core materials, dirt, or deteriorating construction materials. Cloudiness may also result from cold precipitation of tin letraphenyl "scavenger'' that was used in the earlier Pyranols. This scavenger begins to come out of solution around I5F. above zero. To redissolve it requires heating to 150 - 200F. and agitation. High dielectric strength will quickly indicate that any turbidity present is not moisture; that the insulating efficiency of the askarel is still excellent. However, if the dielectric strength is below 26 KV, moisture should be determined, using the Karl Fischer method (ASTM D1533-60). The dielectric strength test for askarel serves primarily as an indicator for moisture. It is by far the most important maintenance test for transformer askarel. VIII. TYPICAL VALUES FOUND IN ASKAREL FLUID UNDER VARIOUS USE CONDITIONS Table V gives the entire spectrum of properties that are typical for freshly-made transformer askarel as it goes through the various normal and abnormal conditions of use. The data in Table V are in terms of only the askarel fluid and do not refer to insulation resistance or power factor measurements on the over-all transformer insulation. Several utilities studying the power factor values of the over-all transformer insulation system indicate that the unit power factor of a new askarel transformer should range from 1% to not over 5%. This would generally correspond -with the askarel fluid properties as given under heading "B". REY 000928 WATER_PCB-SD0000064378 Tabic V TYPICAL VALLES FOUND IN ASKAREL FLUID UNDER VARIOUS CONDITIONS OF USE A New askarel Inspection Check Points Color Light straw Clarify Moisture 25C. Clear, free from particles 30 ppm B Askarel in prop erly* built new or rebuilt units prior to use. CD After normal oper Non-arccd but ation; a survey of slightly contami 50 units, most 2-5 nated askarel in yrs. old; some 10. improperly* built units, new or slightly used. E Same askarel as in Column D -- after refining. Light straw Light straw Clear, practically Clear, trace of free from particles particles 30 ppm 10-70 ppm all dissolved water Can have foreign Foreign shades shades, blue, green, remain showing red cast. extraction of oil soluble color. Clear, slight Clear, free from amount of particles particles 20-100 ppm all dissolved water 30 ppm Dielectric Strength 25'C. 0.1'gap 35 KV minimum 35-48 KV 35-45 KV Volume Resistivity 100 x 10* ohm-cm. lOtrC.. 500 Volts. DC, minimum 0.1' gap usually 500-1,500 40 x 10* ohm-cm. minimum usually at least 100 x 10' Power Factor: IOOC. 60 cycles 25C. 60 cycles 2-5% 0.05-0.1 % 10-25% 0.5-2% 15-400 x 10' ohm-cm. 10 to near 80% 0.5 to near 10% 30-42 KV about 5 x 10' ohm-cm. 30 to 100% about 7 to over 15% 40-45 KV at least 1,500 x 10* ohm-cm. 2-5% 0.1-0.2% F. Heavily arced askarel due to neglect and internal electrical malfunction. Black Contains carbon particles Near 125ppm saturation level -- plus possible undissolved water 5-15 KV about 3 x 10' ohm-cm. 100% at least 25% * A property built transformer is defined as one in which the materials of construction are chemically and electrically compatible with askarel. REY 0 0 0 9 2 9 WATER PCB-SD0000064379 Starling ideally wtlh situation "B", it is normal to expect the power factor of the fluid in a satisfactorily operating askarel transformer to increase as shown under heading "C"'. The "over-aH" power factor of ihe transformer in normal service is expected to rise, but preferably not much beyond 5%. In this normal situation, the moisture level of the askarel fluid and its dielectric strength will be satisfactory, as shown in heading "C". Occasionally the power factor of a non-arced, satisfactorily-operating askarel transformer is found to be relatively high, i.e., 15%. In this case, the power factor of the askarel fluid will also be high, perhaps as high as 50% at 20C. and 60 cycles. It is not good practice merely to note that high power factor of the askarel fluid is to be expected. The important step is to check dielectric strength and note whether there has been a downward trend. A downward trend in dielectric strength very likely indicates moisture entrance and should be confirmed by a Karl Fischer test for water. The importance of any abnormalities in dielectric strength and moisture content of the askarel fluid cannot be overemphasized! Where abnormal values for the dielec tric strength or moisture content occur, the power factor of the transformer can be expected to be abnormally high; the expected high power factor of the askarel fluid will induce this. The indication that a high power factor on the transformer and on the fluid is due to contamination can be verified by earth refining the askarel fluid and noting whether after refining the test results correspond with heading Assuming no mechanical defect or arcing, if the power factor of a new askarel transformer is relatively high, the power factor of the fluid will also be high, giving the situation under heading "D". This reflects contamination that should have been removed by the manufacturer of the transformer. In absence of mechanical defect, where there are no abnormal losses in dielectric strength, and no moisture pick-up in non-arced askarel -- the use history shows that a relatively high power factor for the askarel fluid (as compared with mineral oil) is to be expected. Normally, high power factor is due to contamination and not deterioration of the askarel operation. As shown by F. M. Clark in his book, "Insulating Materials For Design and Engineering Practice," John Wiley & Sons, N. Y., 1962 -- activated alumina can be used in the circulating system to bring the power factor down and keep it as low as possible. REY 000930 WATER_PCB-SD0000064380 IX. CHECK POINTS FOR MAINTAINING ASKAREL INSULATION A. General Considerations: Modern askarel transformers with welded construction or silicone gaskets for hand hole-cover, switch and terminal compartment covers, with properly constructed bushings require little or no maintenance. With properly con structed transformers, annual or semi-annual visual inspection and dielectric strength test of the askarel fluid should suffice for routine maintenance checking over many years of service. However, many askarel units were installed in the early 1930's -- before the development of some of the better modern gasketing materials and before improved designs were developed for sealing out moisture. Such early units should be, and can be, modernized. Leaky or deteriorated gaskets should be replaced. If the askarel has become contaminated, it should be reconditioned. At the same time, a general clean-up of (he unit and possible refinishing may . be desirable. ' If it is not convenient to take an old transformer out of service for general repairs, leaky gaskets can be sealed temporarily by painting over the leaky area with epoxy cement. A survey of users indicates a good number of early-built askarel transformers (over 20 years old) are kept in continuous service in critical installations by the following steps (instead of modernization). The operating units are equipped with compound pressure gauges for reading pressure above and below atmospheric. Positive pressure is maintained on the shell by introducing nitrogen at 2 to 3 pounds above atomspheric. Regular workmen in the area daily record the temperature and pressure. If a sudend pressure drop is noted more nitrogen is introduced and the gaskets are checked for leaks with soap solution. Leaks are sealed by applying epoxy cement. B. Modern Seating Procedures: Transformer purchasers should specify the following modern techniques for sealing: 1. Welding Construction: Covers, radiator connections, switch and terminal housings, instrument connections, etc. should be welded. 2. Bushing Connections: The most satisfactory bushings arc the type with rolled-on flanges and two ring seals rolled into a depression in (he porcelain -- sealed with silicone rubber rings held under compression. Metal-lo-glass or melal-lo-porcelain sealed bushings are also satisfactory. If for any reason the above type bushings cannot be used then use a por celain or glass bushing with a silicone or Viton gasket retained in a groove. The gasket can be either rectangular or circular cross section, usually V* inch thick. 3. Small Size Connections: When not possible to weld, small size connection seals should be made with Flexitallic stainless steel rings. The surfaces must be machined and parallel. The filler between the steel laminations of the Flexitallic ring should be either silicone or Viton. ' REY 000931 9 WATER_PCB-SD0000064381 4. Gaskets For Hand-Hole Covers: Modern design specifies silicone gaskets. Such gaskets must be retained in a groove. The groove preferably is machined into the flange or cover. However, it can also be formed by welding concentric .steel strips to the flange or the cover. Generali/(he gaskets should be 5/lfi to Vi inch thick for covers, depending on the depth of the groove. A rectangular section is usually used. The silicone material should be Dow-Corning No. 50 Silastic or equivalent. This is a low compicssion set material. For best sealing 20 to 25r). compres sion is recommended, with ample clearance in the groove to allow for this compression. No cement is required. With reasonable care the gasket is removable without damage and is reusable. Silastic 50 is slightly swelled by askarel which contribules to the tightness of the seal. It is not deteriorated by askarel fluid or vapors. It resists weather ing and it is thermally stable and flexible at all operating temperatures. It is an excellent moisture barrier. Notes: a. Dow-Corning, Midland, Michigan will supply a list of Silastic 50 gasket fabricators to all transformer manufacturers or users. They will also furnish technical data. b. Any user of Pyranol transformers, made by General Electric Company at Rome, Ga., will receive prompt and generous help for converting to the modern silicone or Vilon gaskets by contacting the Gcneial Electric Company's Service Engineering Department at Rome, Ga. Sec Appendix K: Seals, Properties and Procurements. C. The Older Scaling Arrangements: '! he older type gaskets consist of cither cork or cork-nil rile rubber combinations or straight nitrile rubber. 1. Cork-Nitrile Combinations: Covers for the main lank, hand-holes, switch and terminal chambers, relief diaphrams etc. are held in place by sluds welded to the flange or by bolts. The gaskets are cut with openings and placed over the bolts. Often Shellac (Westinghouse Style No. 1150419, or General Electric Company's Glyptal 1276) is used to cement the cork to the flanges. The following is recommended for sealing with the cork -- nitrile rubber combination: Use Armstrong NC-757 cork-nitrile material or equivalent. The gasket can be CUt from a single sheet or by scarfing strips of the material. A convenient method for joining strips is to make a Keystone Type joint. For this, Westinghouse, Sharon, Pa., olTcrs their gasket cutler Style No. 328 B6I4 G0I, (about $15). The joints should be cemented and the gasket also cemented to the flange, using one of the above cements. Excess cement should nol be allowed to reach the interior of the transformer. ' REV 000932 to i WATER_PCB-SD0000064382 After installation and bolting, the outside edge of the gasket should be coated thoroughly with epoxy cement to increase weather resistance. This epoxy cement is a paste to which a curing catalyst is added immediately before use. Typical are; a. Epoxy Patch Kit tfl-C Hysol Corporation, Olean, N. Y. b. Scotchcast Resin #4 Minnesota Mining and Manufacturing Co. St. Paul, Minnesota c. Adhesive A-l and Activator Type B Armstrong Products Company Argonne Rd., Warsaw, Ind. d. Adhesive 9860-1, Synthetics Organic Company, Cleveland, Ohio, used with activator diethylene triamine (Carbide and Carbon Chem, Co.) 2, Straight Nitrile Rubber: When straight nitrile rubber was originally used, invariably the gasket was recessed in a groove. This was to prevent gasket flow and to protect the material against excessive compression. Although this type seal was nut cemented, the nitrile rubber gasket is not reuseable. Since grooves or slops have already been provided for the nitrile rubber seal, Silastic 50 can be easily substituted and is recommended. This conforms with modern practice. X. PERIODIC FLUID INSPECTION AND WHAT CHECKPOINTS MEAN On a regular schedule -- at six, nine, or twelve month intervals -- make a simple visual inspection of your askarel insulation and run a dielectric strength check. A. Visual Inspection: Askarel is a clear, faint-yellow liquid. After long-term use this color may gradually intensify to light brown. The fluid should remain clear and free from turbidity or cloudiness. Any color change -- such as to a green, red or blue cast -- indicates extraction of impurities from the solid insulation. If a distinct foreign color pick-up is noted, check the complete range of electrical characteristics and notify the transformer maker. The electrical characteristics may be found to be unim paired. Color change alone (except for black) is not a danger signal since the contamination is not likely to impair the dielectric strength. B. Dielectric Strength: If the dielectric strength has decreased significantly from the last inspection, or if it has gradually decreased below 26 KV range (at 25C.) -- RUN A CHECK FOR MOISTURE. Use ASTM D901, D877 (Karl Fischer Method). The dielectric strength of askarel is the major indicator to the operating efficiency of your liquid insulation and of the askarel transformer itself. Besides the "visual" inspection tests, dielectric strength is the only test necessary to run on a routine basis. Well-sealed askarel transformers have service records of 25 to 30 years on the original askarel. New askarel has a minimum dielectric strength of 35 KV at 35C., a maximum moisture content of 30 ppm. REY 000933 il WATER_PCB-SD0000064383 XI. INSPECTION CHECK LIST 1. If askarel is clear, even though darkened to light brown; has no sediment or turbidity; has dielectric strength over 26 KV ...give it the inspection "OK". 2. if askarel is clear; has foreign color of blue, green, red . . . it is "extracting color" from internal materials. This is not.of itself, an operating hazard when the dielectric strength stays over 26 KV and moisture remains low. However, this rare occur rence calls for checking into condition of the interior construction and consulting the transformer maker. 3. If askarel is clear; but dielectric strength drops to 22 or lower KV, and moisture rises over 80 ppm ... the askarel is ready for simple "refining". If the moisture is near the saturation level (about 125 ppm), a thorough inspection should be made for water droplets in the transformer tank, and even for "globules" or water floating on the askarel surface. If found, the transformer manufacturer should be consulted for reconditioning both the transformer and the fluid. 4. I f ask a re) is dark brown to black; if black particles of carbon are seen; and dielectric strength is low ... the askarel has been broken down by arcing. It cannot be refined and should be discarded. If any of these four simple inspection tests appear out of the ordinary, or the relationship between appearance and test values is abnormal -- contact your transformer supplier for a complete analysis. Whenever a sample is to be shipped to Monsanto, please follow the directions shown under: "SAMPLING ASKAREL". XII. CONTAMINATION IN TRANSFORMERS Unlike mineral oil which can oxidize, sludge and deteriorate -- askarel breaks down in transformer use nnly when strongly arced. Thus, while askarel does not decompose in normal use -- it can be contaminated more readily than the relatively non-polar mineral oil. For example the following Table VI shows how a small amount of synthetic rubber or a bit of varnished cloth markedly increases the power factor of the askarel. Please note, however, that such minor contamination has ho adverse effect on the dielectric strength. As explained, moisture entrance through faulty seals seems the only contaminant in normal use that lowers the dielectric strength of transformer askarel. / REY 000934 WATER_PCB-SD0000064384 Table VI EFFECT OF COMMON INSULATION MATERIALS ON POWER FACTOR AND DIELECTRIC STRENGTH ^ (HEAT AGED 96 HOURS IN ASKAREL AT 100C.) Material Immersed None (control)............................................... . .. Black varnished cloth................................... ... Copper.................................................................. Pressboard......................................................... .. Manila paper...................................................... Phenol formaldehyde resins...................... ... Shellac............................................................... ... Iron................................................................... . .. Synthetic rubber........................................... ... Askarel After Exposure Power Factor, Percent at 60 eye.. I00"C. Dielectric Strength 25"C. 1.0 85.0 1.5 Z.O 1.5 1.6 35 KV 42 40 37 39 41 6.0 5.0 70.0 36 39 39 Similarly, trace contaminants from commonly used construction materials can lower the volume - resistivity of askarel, without affecting its dielectric strength. Table VII shows this. Table VII EFFECT OF COMMON INSULATION MATERIALS ON VOLUME RESISTIVITY OF ASKAREL Sample 1. New askarel before heat aging.................................... 2. New askarel after heat aging 96 hours at IOO*C........ 3. After heat aging with 1 sq. inch specimens of: a. Phenolic resin tap changer material....................... b. Paper.......................................................................... c. Grade A press board (tan)...................................... d. Grade A press board (gray).................................... e. Grade A press board, laminated strip.................... f. Cotton wrapping............................. ......................... g. Glyptal 1276 cement, cured 48 hrs. at l IO*C.......... Volume Resistivity x 10' ohm-cm (at lOO'C., 500 Volts DC., 0.1* gap) 2,000 1.900 1,200 750 500 500 400 300 too While trace contamination easily lowers volume resistivity from high levels, it is important as previously noted in Table V Case F, that heavy contamination (as when arced) does not lower the resistivity below the order of 10' ohm-cm. at 100C. The different behavior of askarel vs. mineral oil in these respects can be summarized as follows: High power factor and low volume resistivity in transformer mineral oils are commonly regarded as "danger signals" that the oil has deteriorated and broken down chemically. This is NOT TRUE of askarel liquid insulation, unless the dielectric strength is low. REY 000935 WATER_PCB-SD0000064385 XIII. REFINING ASKAREL FOR RE-USE A. Filtering Through Dry Blotter Paper to Remove Moisture and Extraneous Partciles: Most operators prefer portable refining apparatus, such as a plate press fitted with a dofiy, (available from Sparkler, Mundelein, 111., Weslinghouse Main tenance and Repair Dept., Chicago, or General Electric Co., Pittsfield, Mass.); or the earthen cartridge filter type, (available from Industrial Filter Corp., Lebanon, Ind.). Filter paper liners for the plate press are available from Carl Schleicher and Schuell Company, Keane, New Hampshire and manufacturers of filter presses listed above. The filter paper must be dried immediately before use. For best results, spread the paper for maximum surface exposure in a hot air circulating oven and heat it for 4 to 6 hours at I I0C. If possible do not take the transformer out of service until ready to filter the fluid. This will keep the transformer coils relatively hot and dry. Processing the fluid should start immediately after de-energizing the unit. Circulate the askarel hot (but not over 55-60C.) through the filler fitted with . the dry paper liners. After filtration the dielectric strength of the askarel should be 35 KV minimum. 1. Precautions: Filtering should not be done when the relative humidity exceeds 75%. Any flexible hoses and gaskets on the refining equipment should be lined with or made of materials that will not be softened by contact with askarel fluid. (Silicone or Teflon-lined, or flexible metal materials are suitable.) Table VI11 GUIDE TO RATE OF DISSOLVED WATER REMOVAL BY FILTERING ASKAREL THROUGH A PAPER PRESS Patsei Thrxnsgh Paper Press 0 1 2 3 4 5 6 Water in Askarel PPM 115 35 22 18 12 10 10 e 14 R-gY 000936 WATER_PCB-SD0000064386 B. Earth Treatment for Maximum Improvement of Power Factor and VolumeResistivity: 1. Procedure: (The askare) liquid should be relatively dry prior to the following earth filtration.) Use finely divided Atlapulgus clay or Fuller's earth (dried and activated by healing for 12 hours at 300-350F. immediately prior to use) as a coating on the filter paper surface. The amount of earth used should be 0.1 to 0.2 per cent by weight on the weight of the askarel to be treated. (Askarel weighs about 13 pounds per gallon). To deposit the earth evenly, stir one-third of the earth with a small portion of askarel in a clean container. Pump the mixture through the filter and follow with two more one-third portions. Then circulate askarel taken from near the top of the transformer, pass it hot (not over 55-60C.) through the earth coated filter and feed back through the bottom transformer outlet. Continue circulation until the fluid is clear and test shows that the electrical properties are fully restored. 2. Effect of Earth on Removal of Scavengers: Only slight and insignificant loss (by selective absorption) of lintetraphenyl and epoxides occurs when askarel is refined by treatment with 0.1 to 0.2 per cent by weight of earth. To remove significant amounts of the scavengers requires repetitious treatment with much larger amounts of earth. 3. Table IX -- Approximate Relationship Between Power Factor, Volume Resistivity and Dielectric Strength of Transformer Askarel: Power Factor (60 eye.) lOO'C. 25C. 2% 0.05% 5% 15% 0.1% 0.7% 20-25% F50% 2.0% -- Volume Resistivity x 10* ohm-cm. (at 100C,, 500 Volts DC., 0.1' gap) 1500 500 too 60-70 25 Dielectric Strength 25C.. 0.1' gap 35 KV 35 35 35 35 If it is desired (although these factors are not generally considered important for askarel transformers), to keep the power factor as low as possible and the resistivity as high as possible, hang a container of anhydrous alumina or activated clay in the circulating system of the transformer. XIV. CLEANING ARCED TRANSFORMERS If a unit has arced so that the askarel is no longer fit for use, a thorough cleaning of the unit is necessary before refilling with new askarel insulation and returning it to service*. Follow this procedure: ' REY 000937 15 WATER_PCB-SD0000064387 A. Drain out all dark, carbon-contaminated askarel. (Discard by dumping or burying where it will not contaminate a water supply.) B. Carefully brush carbon deposits from internal parts and insulation, using a soft bristle brush making sure that insulation is not damaged. C. Flush thoroughly using new askarel (not an oil, nor a cleaning solvent). D. Flush a second time with fresh askarel; drain; then fill to the proper level with new askarel. E. Energize transformer to warm the fluid for 24 to 48 hours; then circulate the askarel through a filler, returning it to the unit filtered and ready for use. This assumes that the cause of arcing has been established and corrections made. When severe arcing occurs, major repairs are usually necessary and the unit rebuilt. This procedure can be applied for flushing out repaired units. i / REY 000938 WATER_PCB-SD0000064388 XV. SAMPLING ASKAREL Take a sample as close lo the top of the liquid surface as possible. (Many large askarel transformers have a built-in sampling tube near the surface for convenient sampling). Then, fo make sure that your SAMPLE truly represents your askarel insulation, take another sample from the bottom. If additional sampling tube connections are contrived on the valves for easier sampling, make the tubes of clean glass, stainless steel, aluminum or tin for rigid types; and silicone or Teflon tubing for flexible types. Use NEW containers for the askarel sample. A new and thoroughly pre-dried smallmouth quart glass bottle fitted with a Bakelite screw cap fitted with an aluminum or tin bottle cap liner is recommended for "quick on-the-site testing." (If complete analysis is to be made, a 5-pint size sample is required). Be sure that the new bottle does not stand open to collect dust or moisture. Rinse the sample bottle and cap lining two or three times with askarel from the transformer; then fill it. If the sample will be tested promptly, a clear glass bottle can be used. If sample is to be stored indefinitely, use an amber glass bottle or wrap clear glass with aluminum foil. A. Select a dry day. Do not sample insulation on a warm, moist day when humidity exceeds 75%, and . . . B. Make sure that the askarel is at least as warm as the surrounding air. (Cold liquids can condense moisture from humid air.) C. When sampling askarel from transformers, it is best to take the sample when the unit is warm and operating at average or maximum load. Especially as a check on moisture (as reflected by a dielectric strength test), sampling the warm askarel more truly represents its condition during operation. Experience shows that water will migrate from a transformer's solid insulation lo the askarel liquid and vice versa, depending on temperature. Therefore, when the transformer is hot, the moisture is most likely to be found in the liquid This accounts largely for periodic variations in dielectric strength. For example; a relatively high dielectric strength may be found during winter months and a relatively low dielectric strength during the summer months on samples taken from the same unit. , rY 000939 17 WATER PCB-SD0000064389 SECTION B askarel filled switches and terminal chambers I. INTRODUCTION: High voltage leads are usually connected to askarel or mineral oil-filled network transformers and power centers through terminal chambers and switches. In some cases terminal chambers are not used, and the high voltage leads are connected directly to the switch terminals. They may be filled with either askarel or mineral oil. Switches are usually rotary or drum type fitted with a revolving block and porcelain unit as the principal element arranged for three-phase service. (A cutaway view of a typical terminal chamber-switch combination is shown for reference.) Askarel transformers with attached switches have been in use for about 30 years. When they were first introduced, the availability of insulating and gasketing materials wits rather limited and even the best materials at the time had no service history. As a result, inadequate gasketing materials such as cork, nitrile rubber, and nitrile rubbcr-and-cork particles were used. While satisfactory for a limited period of lime, these materials cannot be depended on for the expected long life of the equipment. The terminal chamber is usually above or below the switch compartment and separated by a steel wall through which the bushings are inserted. When bushings are properly selected and correctly installed, there is no leakage from one compart ment Jo the other, With poor bushing seals, and the terminal chamber above the switch, potting compounds or cable oil can seep into the askarel. When the terminal chamber is below the switch, askarel can drain into the terminal chamber.11 11. SOURCES OF CONTAMINATION There are three possible sources of contamination for askarel in switches and terminal chambers; they rank in this order of frequency: (I) water entering through poor gaskets; (2) decomposition products from arcing when switch is used to break magnetizing current; (3) entrance of pothead or cable compounds through leaky bushing seals. Unlike an askarel transformer where the amount of contaminant is likely to be very small (probably only trace amounts) in relation to the volume of askarel fluid -- in switches or terminal chambers with faulty seals, the amount of contamination can be relatively large. t RY 000940 WATER_PCB-SD0000064390 Experience has shown that, based on the number of installed askarcl-switch units, the percentage of failures is extremely small. When investigated, it has been found that most failures originate in the switch chamber. Water is the chief source of contamination. However, heavy contamination of askarel with petrolatum and asphalt'matcrial, due to leakage, have caused a few failures. Petrolatum is used frequently for filling terminal chambers. When either cable oil or petrolatum seeps into askarel, no great harm results. The fire resistance will be somewhat decreased and power factor of the askarel will increase with an accom panying drop in resistivity. While highly undesirable, it is doubtful that failure of the unit results. Where asphaltic compounds are used in place of petrolatum, the danger is increased somewhat because asphaltic contamination may cause exces sively high dielectric losses in the askarel. When the terminal chamber is below the switch chamber, the potting compound can be contaminated by askarel if the bushing seals are leaky. This is undesirable because (he askarel will increase the power factor and conductivity of the potting compound or cable oil and develop heat from dielectric loss. If this mixture is drawn into the cable insulation, a cable failure is likely. This again emphasizes the impor tance of light bushing assemblies. III. SEALING SWITCHES AND TERMINAL CHAMBERS Proper bushing construction, use of Silastic seals and welding wherever possible is highly desirable (as covered in Section A). Where an elastomeric seal is to be used in contact with both askarel and petroleum oil, DuPont's Vilon is suggested. For new equipment the user should specify these modern sealing arrangements to keep out contaminants and minimize maintenance. IV. MAINTENANCE FOR ASKAREL FILLED SWITCHES A. Switches used for grounding after power source has been de-energized will not undergo arcing. B. Switches interrupting magnetizing current will be subject to arcing; the amount of decomposition will depend on power interrupted, time and frequency of oper ation. As a general rule, the liquid should be checked after 5 to 10 operations. REY 000941 WATER PCB-SD0000064391 1. On newly installed switches, check the askarel at 3, 6 and 12 month intervals; if found satisfactory, check once annually thereafter. With proper attention to the gasketing of covers and bushings, experience will probably indicate that less frequent inspection is warranted. 2. Check askarel for: a. Dielectric strength (ASTM D877): It should be 26 KV minimum. If dielectric strength is low, confirm presence of water by Karl Fischer method ASTM D-1533. Filler to remove moisture. Dielectric strengtn should then be 30 KV minimum. b. Presence of carbon from arcing: Fluid should be relatively free of carbon. If badly arced and very black, replace fluid. If only minute amounts of carbon are present, filtration is recommended. Check power factor of liquid (should not be over 5% at 25C. and 60 cycles). Flush out switch chamber with several gallons of fresh askarel before refilling. 3. If there is discoloration, high power factor, detectable change in specific gravity or refractive index, or if fluid flashes below 250F., there is a possibility of seepage of potting compound into the switch compartment. In this case, correct any leaky bushing seals with proper replacements and fill with new askarel. 4. If terminal chamber is below switch, check polling compound for presence of askarel (can usually be detected by odor or by an increase in specific gravity). If askarel is present, correct any leaky bushing seals with proper replacements, and renew compounds. 5. Cxaminc cover gaskets visually. Deterioration can be detected by swelling and cracking of the exposed edge. In cases of severe deterioration, liquid seepage is usually present. 6. Check for leakage at packing gland of switching shaft. If leaking, repack with a Silastic ring type gasket. REY 000942 WATER_PCB-SD0000064392 SECTION C ANALYTICAL SERVICES ON TRANSFORMER ASKAREL AVAILABLE . FROM MONSANTO Transformer users hot wishing to make their own fluid analyses can obtain the service from Monsanto, Simply contact Monsanto and specify what analyses are wanted. You will be sent the proper-sized sample container filled with fresh askarel. When you receive this, empty it and carefully take your sample (following the procedure for sampling in this guide). Send the container to Monsanto's laboratory. Charges listed include sample container, shipping, handling and laboratory costs. Types of Analyses Available Analysis 1) ROUTINE MAINTENANCE CHECK Total Charge: S20.00 To determine the general condition of the fluid and find whether further analysis is neces sary. (one-quart sample required) Properties Tested Color and Condition Dielectric Strength Moisture You will be notified of the results of this test. If further testing is indicated, and you want a complete analysis, you will be sent a five-pint sample container. This sample will be used for (he following scries of tests: Analysis 2) COMPLETE ANALYSIS Total Charge: S50.00 (a) To determine the extent of fluid contamination, (b) earth refinement to determine what degree of restoration of electrical and insulating properties is possible, (c) check test to see how the fluid responded to earth treatment. a) Complete Analysis: to determine the extent of contamination Properties Tested Color and Condition Specific Gravity Refractive Index Water Free Chlorides Acidity Dielectric Strength Power Factor, Dielectric Constant, and Resistivity REY 000943 21 WATER_PCB-SD0000064393 b) Earth Refinement Response: Consists of treatment for 2.5 hours at 50-60C. with 0.1 to 0.2 percent by weight of properly conditioned Attapulgus clay and then filtration through dry filter paper. c) Analysis After Laboratory Earth Refinement: Properties Tested Refractive Index Water Free Chlorides Acidity Dielectric Strength Power Factor, Dielectric Constant, and Resistivity You will be notified of the results of this test series on your sample. Then aftei refining your entire transformer fluid fill you can check on the results by requesting the following analysis: Analysis 3) ANALYSIS AFTER EARTH REFINEMENT i Total Charge: $30.00 (This charge will not apply when ! analyses 1 and 2 have already been made.) i To determine whether the entire lot of the askarel fill responded to the same extent as the j laboratory sample, (five-pint sample required) | Properties Tested ' Color and Condition jI Refractive Index Water 1 Free Chlorides Acidity i Dielectric Strength ! Power Factor, Dielectric Constant, and Resistivity To arrange for the tests described above write to the following address: Paul G. Benignus Monsanto Chemical Company 800 North Lindbergh Blvd. St. Louis 66, Missouri Sample* to be tested should be clearly marked for identification and sent directly to: Monsanto Chemical Company W. G. Krummrich Laboratory Monsanto, Illinois Attention: R. Kuster t 22 REY 000944 WATER_PCB-SD0000064394 APPENDIX APPENDIX A -- Askarel Stability and Composition of Arc Formed Gas: Askarel insulation is one of the most inert, chemically-stable heat resistant, non corrosive liquids known. It will not break down, oxidize or sludge when exposed to air and high temperatures, 150C, or even somewhat higher. Arcing, however, will break down the compound to liberate some hydrogen chloride and small amounts of carbon. APPROXIMATE COMPOSITION ARC FORMED GAS FROM TRANSFORMER ASKAREL Gas carbon monoxide......................... carbon dioxide............................. oxygen.......................................... inert gases.................................... hydrogen chloride....................... (note the absence of phosgene) Amount 0.3 per cent 0.3 0.6 1.5 97.3 This arc-formed gas is non-flammable and non-combustible. These requirements must be met in accordance with the Underwriters' Laboratory for permission to use the term askarel. Mineral oil evolves combustible hydrogen and hydrocarbon gases. For all practical purposes, the amount of gas liberated from mineral oil or askarel under a given set of conditions is about 100 cubic centimeters per kilowatt-second. APPENDIX B Carbon dioxide................ Air........................................ Nitrogen............................. Hydrogen chloride' .... I) In absence of scavenger SOLUBILITY* OF GAS IN TRANSFORMER ASKAREL Percent of Gas By Volume Corrected to:______ 25*0 760 mm 0C. 760^mm 25*0 100*0 25*0 100*0 71% 47% -- -- 5.7 4.9 5.8 5.0 6.0 4.8 5.5 4.4 37.8 50.9 ---- REV 000945 WATER PCB-SD0000064395 appendix c APPROXIMATE VAPOR PRESSURE vs. TEMPERATURE FOR TRANSFORMER ASKAREL Temperature C 40 60 80 100 120 140 Inerteen PPO, 7336-9 1 mm Hg. 5 9 30 60 90 Transformer Pyranol A1383 B 0.9 mm Mg. 3.5 8.3 18 32 53 appendix d EFFECT OF TEMPERATURE ON DIELECTRIC STRENGTH OF ASKAREL Temperature C. --60 --40 --20 0 20 40 60 80 Dielectric Strength 67 KV 63 57 55 50 50 48 45 APPENDIX E COMPARISON OF THE APPROXIMATE VISCOSITY IN SAYBOLT UNIVERSAL SECONDS OF TRANSFORMER ASKARELS AND MINERAL OIL Temp. * C. -20 0 20 40 60 80 100 Transformer PyTaaol AI3B3B 1,000 100 70 45 39 34 30 IOC Mineral Oil 1,000 150 85 49 40 34 30 Inerteen PPO. 7336-9 2,800 195 85 50 40 36 33 REY 000946 24 WATER_PCB-SD0000064396 APPENDIX F THE DENSITY OF INERTF.EN PPO 7336-9 AND TRANSFORMER PYRANOL AI3B3B Approx. Density gm/cc. Temperature *C. 0 20 40 50 80 Inerteen PPO, 7336-9 1.574 1.552 1.329 1.507 1.485 Transformer Pyranol AI3B3B 1.577 1.555 1.532 1.510 1.488 APPENDIX G The thermal conductivity values of transformer Pyranol AI3B3B at 27C. and 58C. are 26.2 and 25.8 x 10'1 calories centimeters'1, degrees centrigrade'', second '1, respectively. Or, approximately 0.06 BTU per (hr.) (sq. ft.) (F.) per fool. This same approximation applies to Inerteen PPO (7336-9). APPENDIX H Heat Capacity Over the temperature range of 25 to 125C. the specific heat of transformer askarel is close to 0.30 calories per gram per degree. APPENDIX I Coefficient of Expansion The average coefficient of expansion of transformer askarel over the temperature range 20 to 100C. is 0.007 cc/cc/C. One gallon would increase to 1.056 gallons on heating from 20 to IOOC. APPENDIX J Firc-Resistance To use the generic name "askarel," the fluids must be approved by the Underwriters' Laboratories as possessing adequate fire-resistance and freedom from forming explosive gases when arced. These liquids do not have a burn point (ASTM D92-33) (Cleveland open cup method) up to about 205C., at which temperatures they begin to boil. The significance of this is that (hey do not burn or support combustion under conditions encountered in transformer operation. Thus the danger of secondary explosion (or fire) is eliminated. 25 / REY 000947 WATER PCB-SD0000064397 appendix k Seals, Properties and Procurement Dow Corning Corporation, Midland, Michigan with District's at Atlanta, Roston, Chicago, Cleveland, Dallas, Los Angeles, New York City, Washington, D. C. and Toronto has available Bulletin 09-019, August 1962 entitled "Silastic Design Data". ! This lists the gasket fabricators throughout the country from whom the "Silastic j 50" gasketing can be purchased in sheet, extrusions or molded shapes. ' Generally Silastic 50 sheet goods are stocked by local die cutters, hence, could be . generally purchased locally. Usually, small quantities of gaskets are die cut. If larger quantities are needed, tools are made of the same type used to cut other elastomers. , Where the gasket is extruded for fitting into a machined groove or between gasket I stops, Dow-Corning advises use of a scarved joint. This joint is then cemented using Dow Coming's Silastic 140 (clear) or their RTV 731 (white) materials, which air cure. Dow Corning points out that the local "rubber" fabricators purchase the Silastic 50 in billet form. This is worked on a roll mill in preparation for sheeting or extrusion. Then to obtain the desired physical properties the fabricator must oven cure the Silastic 50 for 24 hours at 480F. SPECIFICATIONS* Color................................................ White Specific Gravity at 77*F............ 1.20 * 0,02 ASTM D676 -- Hardness, Shore A. Scale........... 45 to 60 A STM D412 -- Tensile Strength, psi. min............................. 800 ASTM D4II -- Elongation, percent, min...............................250 ASTM D395 -- Compression Set after 22 hours at 300*F., percent, max.................................. 30 * All physical properties measured on 0.075 inch thick samples molded 5 minutes at 240F., and oven cured 24 hours at 480F. General Electric Company, Redmond Circle, Rome, Ga., uses silicone or DuPont's Vilon wherever it is not possible or desirable to weld. For some small seals, where good matching surfaces are provided, Flexitallic stainless steel rings are used. By contacting the Engineering Services Department of General Electric Company, Redmond Circle, Rome, Ga., users of Pyranol transformers made prior to develop ment of these modern seals will obtain prompt assistance for conversion. liters of askarel transformers made by other manufacturers should contact the original transformer manufacturer, or Monsanto for assistance in converting to these modern seals. / 26 RgY 000948 WATER PCB-SD0000064398 REY 000949 WATER_PCB-SD0000064399 MONSANTO FUNCTIONAL FLUIOS DEPT. SOO N. LINDBERGH BLVD. ST. LOUIS, MISSOURI U1M The information herein regarding obtaining optimum resulti from askarel fluids in your transformer hat been accumulated by Monsanto for over JO yean fro the experience of makers and uteri of atkarei transformer! and it is befleved win be helpful. Nothin herein shall be construed at applying to other than asksrel insulation. Data and maintenance suggestions herein do not apply to the other components of the transformer. All operating and maintenance suggestions recommended by the manufacturer of the transformer should also be carefully followed. Because these maintenance directions apply only to the askarel insulation, Monsanto disclaims any liability for damage to properly or injury to persons arising from transformer operation. REY 000950 / Lllho In U S- A. WATER PCB-SD0000064400 Monsanto Monsanto Compsny 800 N. Lindbergh Boulevard 3t. Louis, Missouri 63100 Phone: (314) 694-1000 February 9, 1970 QMAMtC CHOACALS DfHSiOH Dear Sirt Recently several newspaper and magazine articles have been published indicating that Polychlorinated Biphenyls (PCBa) have been discovered at some points in some marine, aquatic and wildlife environments. The quantities detected are said to be in the parts per million and parts per billion categories. It is claimed that the PCBs found strongly resemble chlorinated biphenyls containing- 54% and 60% chlorine by weight. Products which are sold by Monsanto under the trade names of Aroclor 1254 and 1260 do contain chlorinated biphenyls. In addition to Aroclor 1254 and 1260, Monsanto sells certain functional fluids containing Aroclor 1254. These include Pydraul 625, Pydraul AC, Pydraul AC - Winter Grade, Pydraul 540, Therminol FR-3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. As your supplier of Aroclor 1254 and 1260 and formulated products containing 1254, we wish to alert you to the potential problem of environmental contamination as referred to in the newspaper and magazine articles. We would like to point out the following additional facts. 1. Products such as Pydraul 90, 135, 230, 312, A-200, F-9, 150 and 60, Turbinol 153 and Therminol FR-1 and FR-2 are not formulated with Aroclor 1254 or 1260. 2. PCBs with a chlorine content of less than 54% have not . been found in the environment and appear to present no potential problem to the environment. 10 WATER PCB-SD0000064401 2 We have developed, and are now testing, new formulations to replace the Aroclor 1254 and 1260 components in our Pydraul products. The new products appear to be equal in performance and to have similar physical properties. We feel that all possible care should be taken in the applica tion, processing and effluent disposal of these products to prevent them becoming environmental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969 regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good menufacturing practice in the future may require that no products used by any company should find their way into waterways. .* Sincerely yours. nlc Attachment /C (tr"r ( '*j.c ' Donald A. Olson Director of Sales Functional Fluids Group MONS 090211 WATER PCB-SD0000064402 W. B. PAPAQEORGE - ST. LOUIS APRIL 13, 1970 AROCLOR LABELING ' J. MASON P. S. PARK H. S. BEROEN H. V. FARRAR - SECOND STREET B. V. JOHN C. PATON . W. R. RICHARD . J. R. SAVAGE J. E. SPRDfOGATE E. P. WHEELER D. A. OLSON During our April 3rd meeting, the subject of modifying the labels on Aroolor packages was reviewed and Phoolan Park offered to work on the appropriate wording He suggests the following paragraph be added to the existing wordings "lftis product contains polychlorinated biphenyls, which some studies have shown may be an environmental contaminant Care should be taken to prevent any loss into the environment through spills, leakage, disposal, evaporation or otherwise." This additional wording is intended for packages containing Aroclors 1242, 1246, 1254, 12o0, ,1262, 1268, 4465 and Montars 1, 2, 3, 4 and 7 ' Attached is a copy of a typical label. The proposed wording would appear in the space below the present printing. We. are anxious to make this change quickly. May X have your comments? \ ms Attachment W. B. PAPAQBORQE HONS 098183 <55 WATER_PCB-SD0000064403