Document MGL9vOdkpkbZb3kRZjz6xL9yy

O1 THE PCD-POLLUTION PROBLEM January 21 and 22, 1970 St. Louis Meeting With General Blectrie Co. OBNERAL ELECTRIC REPRESENTATIVES: Mr. Edward L. Raab, ge Pittsfield, Mass,, representing all QE locations Mr. H. Qerade, GE toxicological consultant Dr. K. Murphy, GE Schenectady, New York, Environmental Pollution Control MONSANTO REPRESENTATIVES: H. S. Bergen, D. A. Olson, S. P. Wheeler, Dr. W. R. Richard, Dr. R. H. Munch, Dr. R. Keller, Dr. S. Tucker, W. B. Papageorge, j. Q. Bryant, P. 0. Benignus A. Presentation and Discussion of Published Articles About Chlorinated Aromatic Hydrocarbon Insecticides, [DUf etc,) and PCBs Mr. Wheeler presented to Mr. Raab a booklet containing most of the pertinent publications, to date, and indicated that additional articles will appear shortly. He mentioned that manufacturers of DDT and chlorinated aromatic hydrocarbon insecticides will tend to emphasize the finding and interference of PCBs as the Government hearings limiting or banning use ef the insecticides are held. This lead 01 to seek understanding of the scope, reproducibility, reliability and validity of the analytical procedures used by various investigators who reported finding PCB in concentrations as lew as parts per blllien. ' B. The Analytical Procedures Drs. Keller and Tucker presented details ef Monsanto's QLC - Mass Speotrometric analytical capability and apparatus, as portrayed in Table 1. The sophistication ef our analytical capability was emphasized te assure that our approach is the ultimate and is not surpassed, on this basis our views of the validity of results given in various publications are Indicated in the attachments to Table 1. General Electric were Impressed and completely satisfied with the scope ef eur analytical capability and werk. COMPANY ^ CONFIDENTIAL TRAN 023509 DEPOSITION EXHIBIT Pfr ft -<JL- 'S3? WATER PCB-SD0000009114 o 2 J C. Biodegradeabl11ty of pcsa Mr. Wheeler related that while Aroclor 125^ and 1260 are being found* especially in aquatio environment, the lower ohlorinatod biphenyls are not being observed. It is anticipated that the lower ohlorinated members may be largely biodegradeablo. Dra. Richard* Keller and Tucker discussed biodegradeability studies by Monsanto at Ruabon and elsewhere. . These studies appear preliminary and not conclusive. Much more needs to be done in this area to allow QE to draw conclusions. Since the literature indicates that trichlorobenzene and tri te trachlorobenzene are not susceptible te biodegradation* OB are intrigued with the absence of reports about finding these materials in the environment. The obvious implication is that since these materials are used with the higher chlorinated PCBs found -- the source of the latter is not from dielectric fluids. However, it was reasoned that chlorobenzenes may net remain due to their relatively higher vapor pressure or may not be found to date because they have not yet been zeroed in to the analytical spectrum. D. Status of Aroclor Studies At Industrial Bio-Test. Table 2. In essence results reported by Mr. Wheeler on chronic animal toxicity tests and animal reproducibility studies underway are not as favorable as we had hoped or anticipated. Particularly alarming is evidence of effeot on hatchability and production of thin egg shells regards white leghern chickens. The studies involved Arecler 12U2*125^ and 1260. Some of the studies will be repeated te arrive at better conclusions. . B. The Location of Askarsl Transformers. Table 3* Messrs. Raab and Benignus f emulated Table 3 te pertray the use and locations ef askarel transformers throughout industry and our commercial and residential areas. On discussing these askarel transformer applications Mr. Raab was most Impelling and forceful about the nen-replaoeability of transformer askarel fluid and the crltloal or essential use and need for askarel transformers* whioh have safety from fire as - their outstanding virtue. Wltheut dwelling on details and instead oarried to the ultimate* the concensus Is that without availability ef askarel transformers large cities like New Yerk would be shut down with no pewer. Certain Industries that rely mainly n askarel transformers would go down with ne power. Without Aroclor capacitors most ef the lights across our country would ge out and motors in air conditioners and many Industrial applications ' would not run. COMPANY CONFIDENTIAL TRAN 023510 WATER PCB-SD0000009115 o - 3- 3 Frankly# no on could think ef a suitable replacement for transformer askarel fluid. Fertunately, Aroclor 1242 with premise about biodegradeabl11ty Is used In meet all of the . Arecler type capacitors. Moreover# possible favorable Isomer rearrangements are foreseen in the case of Areclor 1242. Need t control# accumulate and preperly dispose of scrap askarels Is unquestionable In light of the PCB pellution problem, and essential toward maintaining the use of askarel dielectrics, At OS alone apparatus in which askarel fluid is used represents 100 millien dollars annually. About 6056 Is In the capaclter area and 40$ represents transformers. OE requested and we were pleased to give Dr. Murphy their Envirenmental Control man, a list of all OE and other locations receiving Pyranel shipments in 1969. This amounts to about 16 million pounds ef askarel fluids with economic worth of near 2.5 million dollars. This listing included 244 different locations of which 115 were OE plants and servlee shops soattered throughout our country. Of course in addition te dielectric use in hermetically sealed capacitors and transformers majer amounts of PCBs are used as Plasticizers# Industrial Hydraulic Fluids and Heat-Transfer media. F, Environmental Seurces of PCBs Frem Dielectric Applleatlens 1. Spills 2. Dispesal ef waste ` 3. Ultimate disposal of product -- for failed apparatus 4. Ventll&tien of eperatlen for employe proteetlon 5. Waste from eontainers 6. Field on servlee failures 7. Repair and return apparatus "servlee shops" 0. considerations of Degradation Disposals - 1. PCBs up to and Ineluding 3 hlorlne atoms appear biedegradeable in preliminary laboratery work. 2. Thus far thero is no video that higher ehlorinated biphenyls will biodegrade. COMPANY CONFIDENTIAL TRAN 023511 WATER PCB-SD0000009116 o - It - 3 3 According to the literature TCB and TTCB biodegrade at a very slow rate. 4. Chemical, catalytic breakdown would probably require high temperatures. 5. Incineration will require 800*C. and 5 second sojourn time, HC1 scrubbing would be required. H. Estimated Annual Amounts of Contaminated and Scrap PCBa Prom TfieHSIectrlcal~Tndustry 1, From The Transformer Industry; a) In plant and field spills are small and controllable with adsorbents, which should be incinerated. b) Near 2 million pounds a year of transformer askarels are sold to service and repair shops. These people do not manufacture new transformers, although on eccasion they may fill new transformers sent into the field without fluid. As these service sheps are deveted primarily to repairing faulty transformers, we can assume that as much as 1.0 million pounds annually of "scrap" is generated. Most of this has been dumped or disposed of in streams. e) We estimate that probably 150,000 pounds ef this is aroed beyond reworking and needs to be incinerated. The remainder may be reworkable by distillation. 2. From The Capacitor Industry* a) Collectable waste from normal oapaciter impregnation operations amounts to about 850.000 pounds annually. Most of this should be reworkable via simple take-over distillation. b) Scrap, badly contaminated with polypropylene, epoxides, solvents, oil. grease and "junk" is generated at not over 50,000 pounds a year. This material should be incinerated, along with the 150,000 pounds of scrap from transformers, e)` Power capacitors are designed to last over 30 years. Modern motor runs may last 10 years and the small lighting ballast usually last not over 10 years. Eventually and cumulatively there is a large potential of field-failed capacitors. Fortunately Arocler 1242 has been used almost exclusively sinoe about 1950. COMPANY CONFIDENTIAL TRAN 023512 WATER PCB-SD0000009117 o -5- 0 The failed units are disposed of in Industrial dumps. In case of ballasts the Aroclor oapaoitor along with the transformer imbedded in asphalt or encapsulated in epoxy resin, all encased in a metal box are discarded as a unit. This is emphasized to indicate that incineration of such apparatus is not applicable. 3. From Containers: Most askarel moves in bulk, tank cars or tank wagons, which de not present a preblem. > It is questionable that drum shipments may present a problem. The drums can be used far returning scrap. X. Monsanto's Program To Handle Scrap 1. QE asked what is Monsanto's plan about reclamation ef scrap PCS from OE plants, service shops, utilities, industrial users, commercial users, etc.? 2. What is our view about a "Buy-Back" arrangement? 3. what arrangements will Monsanto make for incineratien? Disposal in suitable land-fills? Reclamatien by distillation at Mensanto? . 4. Te date Mensante's posture is: a) We have taken "goed quality" scrap from QE's capacitor plant at Hudson Palls and had it reworked by simple filtratien at Pindett. This Pindett arrangement is not practical ner ecenemical. We paid QE 1 ^/lb. far this "quite good" A roc lor, plus ,-1.9 ^/lb. freight. Pindett charged 2.1 ^ to filter this material, making eur cast 5 */lb. b) 130,000 pounds of somewhat lewer quality scrap from Vestlnghouse capacitor plant has accumulated at Pindett for laok of distillation equipment, c) Scrap from QE's Ft. Edward plant appears to need reprocessing by distillation. d) Abeut | mi Hian pounds of "bad scrap" from QE Hudson Palls, has been disposed to a land-fill in New Jersey. Monsanto paid half of the freight cost. e) A car load ef scrap transformer askarel from Westinghouae, Seuth Boston, Virginia is being sent to W. 0. Krummrich for repreoessing. COMPANY CONFIDENT^-.'. TRAN 023513 WATER PCB-SD0000009118 o -6 3 f) We advised Westlnghouse, Sharon to Incinerate 12,000 gallons of oi1 contaminated askarel, g) We talked with Sangamo, Plcken, S. C. and strongly urged them to discontinue present disposal, 5. The above "take-back" arrangements have been made on an individual and experimental basis, We have no fixed "buy back" arrangement, regards answering OS's question. 6. We have no established process for reclaiming either capacitor or transformer scrap. 7. We have no incinerator for disposal of totally unreclaimable material. . 8. To date and for the foreseeable future our only effective disposal is to a land-fill. While this is not dealreable, it is better than indiscriminate dumping. j. Transformer Askarel Blends Discussed With OS. Table 4. Table 4 lists the transformer askarel blends reviewed with OE. 1. oE Rome has discontinued use of Blend A due to combustibility of arc formed gas. For this same reason, as dictated by their legal people they will not use Blend B. 2. Today both OB, Pittsfield, Mass, and Rome, Oa. use Blend C (Pyranol A13B3B), which they mix themselves. 3. Blend D optimizes the Aroclor concentration in conformance with OS's requirements for non-combustibility of the are formed gas and with the pour point requirements. The price is in direct conformance with our previous quotation for Aroclor 1242, when 01 was using this at a concentration of 80}S by weight. COMPANY CONFIDENTIAL TRAM 0**51* WATER PCB-SD0000009119 o -7- 3 Accordingly Blend D meets GE's requirements, although containing Jl.o% of the higher chlorinated Aroclor It does not conform with Monsanto'a concern with the PCB pollution problem. 4, Por all practical purposes Blend B (Inerteen 70-30) is identical properties with Blend D, which latter GE, Rome, Qa. proposes to use. In the interest of standardization, we seek to have QE, at Pittsfield and Rome, Qa. use Blend E, which is used by Westlnghouse for low temperature applications and is used by many other askarel transformer manufacturers for general application. 5. Although Westlnghouse USA uses Blend P (100 Aroclor 1242) for all applications, except for low-temperature application, GE does not accept this use of 100$ Aroclor 1242 in transformers. OE'will not accept Aroclor 12^2 or any other blend with less than a 1 to 1 ratio of chlorine to Hydrogen atoms, a ratio significantly lower than 1 to 1 tends to yield combustible arc-formed gasses. QE feels strongly that this does not conform with the original definition of an askarel. Accordingly their legal people stress that this presents potential liability in case of an accident for which various precedents have already been set in court actions. Mr. Raab points out that this precedent for liability regards combustibility is already set, in contrast with the PCB pollution situation which thus far is void of legal actions. He reiterated that the pollution problem thus far is a source of technical publications and warnings and emphasized that in the case of electrical applications which involve only hermetically sealed apparatus, adequate control should be possible. K. Pacts As Agreed By Those In Attendance 1. CI5 - C58 Biphenyls -- found in aquatic eco system in populated and industrial areas. 2. DOT 4- Cl hydrocarbon Insecticides have effect on fish-eating birds (reproduction) leading to possible extinction of some species. .. 3. PCBa (some) are definitely suspected along with polychlorinated hydrocarbon Insecticides. 4, Research data being developed seems te oenflrm Incrimination of PCBa subject to rechecldng. 5. Public, political and government pressures stopping some ' uses of chlorinated hydrocarbon insecticides (PCHI). COMPANY CONFIDENTIAL IRAN 02*15 WATER PCB-SD0000009120 u -8- 3 6. PCBs have been brought Into hearings proposing restrictions or elimination of DDT, PCHI. 7. Aa manufacturer of pcHI's fight for their life# attention will be directed to PCBs. 8. To our knowledge PCBs are not being found in terrestrial birds or animals, but DOT and PCHI'8 are found. 9. PCBs are not being found in the eco system without the presence of DOT or PCHI'. 10. PCHI's residue are found without PCBs. 11. We have no evidence that anyone has found lower PCBs except that Dutch researchers found PCBs in roaches. 12. There is no ovidence of natural sources of PCBs nor any source other than industrially produced and used. 13. pcbs in a single dose have a low order of acute toxicity and are no significant problem to rats, dogs, chickens, fish and humans. 14. Based on six months of chronic studies in rats and dogs some PCBs are "moderately" toxic and more so than DOT, but less toxic than some of the other chlorinated hydrooarbon insecticides. 15. Some PCBs affect rat reproduction, {10 ppm. apparent no effect levels). 16. Some PCBs affect leghorn chicken reproduction (100 ppm.). PCBs have no affect level for chickens, estimated 10 ppm. 17. Some environmentalists are claiming that the PCBs pose a threat to humans, are so "philosophizing" in publications. 18. One published page indicates that PCBo are as bad (or worse) than DOT in microsomal enzyme effect. What le significant? Since many ohemlcal compounds react similarly.' 19. Human experience in production of PCBs and their use has been favorable. Less than 20 Instances of illness known to Monsanto Company lines 1940-45. Proper precautions were net always followed. 20. as Company1s use of PCBs as dielectric fluids, has been extremely favorable without illness throughout 40 years. 21. Monsanto Company is convinced that analytical techniquoa and data fro seme laboratories investigating PCBs are reliable and that conclusions being formulated are valid. COMPANY CONFIDENTIAL TRAN 023516 WATER PCB-SD0000009121 o -9 22. Monsanto Company has not run duplicate analysis on samples roported In the literature. L. What QE Desires 1. GE seeks that Monsanto take n precipitous reaction to the PCB problem that would result in withdrawing supply of Aroclor 1254 or 1260 to QE. 2. The consensus is that no suitable replacement for transformer askarel fluid is foreseen. 3. In event of development ef a suitable fire-resistant fluid replacement for askarel# Mr. Raab emphasized that a minimum of 2 years testing work would be required before commercial use could be adopted. 4. In reply to Monsanto's legal questlen whether with continued use of Areclor 1254 and 1260 GE would assume sole and complete liability -- Mr. Raab answered, NoJ To substantiate his reply, Mr. Raab cited case examples invelving QI where damages were sought and collected, even though QS was only the third party. He further stated that any arrangement seeking to delegate and confine liability to as relative te the PCB preblem would be worthless. 5. QE seeks te know the magnitude and time f Aroclor price increase that weuld result if Mensanto dlscsntlnues sale of Arecler for nen-electrical uses, er if pellution oontrel expenses warrant a price increase (as anticipated). 6. GE seeks te send a letter te their plants and service shops and major users of transformer askarel, such as the utilities giving notioe of the-PCB problem and guidance abeut the most suitable controls. 7. In the ease ef OS service sheps scattered throughout our ceuntry it la unrealistic that these people would assume any expense to return scrap te Monsante. The minimum we can expect is that Monsanto pay the freight charges, and reimburse fer a suitable container to avoid addltienal and exoesslve centamlnation. This emphasizes need fer Monsanto to have an effective reclaiming prooess. otherwise, the best we tan expect frsm servioe shops and many ether users is to oontlnue to dump in a land-fill and step discarding into the sewers. COMPANY CONFIDENTIAL TRAN 023517 WATER PCB-SD0000009122 0 10 - J 8. 01 realize* that Monsanto is caught between the explosiveness * 0f are-formed gasses problem and on the other hand the PCB pollution problem. Realizing possible unfavorable outcome of the-are-formed gas problem, OE desires to withhold the PCB problem from involvement at NEMA, ASTM, IEEE, Ell and ASIA at this time, (making it an industry-wide problem) pending . better in-depth understanding of the PCB problem, 9, qe strongly seeks to continue manufacture of askarel type transformers, because in many applications this apparatus cannot be replaced with mineral oil nor open dry, nor seal gas dry type units. Mineral oil burns. Open dry accumulates dust, lint, moisture and can then fall with explosion and burning. Sealed gas dry types are very expensive, space eonsuming and very difficult to maintain sealed. Transformer design and applleation is governed by National Electric Codo, by looal building codes, Fire Underwriters, NEMA, IEEE, ASTM, IZC, ASA, Insurance companies and others. Beoause of the diversity of erganlzatlons involved a directive to discontinue askarel transformer manufacture would assume highly oomplex proportions. P. 0. Benlgnus January 26, 1970 COMFANY CONFIDENTIAL TRAN 023510 WATER PCB-SD0000009123