Document MGMEV4VQ4QkROKrwgr1j7QMyy

,,m,, ioution! y;, R; 'Richard - Research Center UaH ct t( t4 m nci September 9, 1969 DEFENSE OF AROCLOR FTTEimiS----------------- ' TO E. Wheeler - EWHEE P. Hodges. PHODG General Policy Make the Govt., States and Universities prove their case, but avoid as much confrontation as possible. Comply and work with public officials to meet or'exceed requirements ahead of time. .Adverse publicity and competition are the real weapons. Analytical In Air ' - Which Aroclors are present? Where? ' for Aroclor In Water- Which comnoundso Govt. In Animals ^interfere? Agencies Keep track of how much contamination - which sources. Prove Bloharmful - Let Govt, prove'its case, on case by case basis. i Monsanto Vlslt-Qovt. Blolabs - in search of toxicological experiments and evidence vs. Aroclors to keep up with progress. Monsanto Prove Bloharmless - Limited work at Ind, Bio-test "Safe" toxic level for man Rats Seek evidence of Biodegra- mammals via thickens dation fish Fish Question evidence against us. Question shrimp toxicology . especially other toxic chemicals. If Aroclor bad, others must be worse. Probable Outcome We can prove some thingB are OK at low concentration. Give Monsanto some defense. We can't defend vs. everything. Some animals or fish or insects will be harmed. Aroclor degradation rate will be slow. Tough to defer.; gainst. A-gher chlorination ccir.pouads will be worse . . _v -..'er chlorme compounds. Therefore we will have to restrict uses .nd clean-up a ich ns._we. can, starting immediately, a, |t . NEV 027584 1^, 00 CO CoO N* WATER PCB-00049788 -2- Therefore we will have to work for alternate products in end use applications; for Aroclor production facilities. Clean Up Aroclors and substitute products where necessary and when required, before"'THreats of pub1 i'clt~y~and competltlve activity over whelm us. Water Pollution seems to be first issue Aroclor product is refractive, will settle out on solids sewerage sludge - river bottoms, and apparently has a long life. Florida or Gulf Coast - Aroclor 1254 - Aroclor 1260 present issue. 40-200 ppb - causing problem at Pensacola (Monsanto) in plant effluent-causing " with shrimp. - can't risk shut-down of plant. Federal and State can extrapolate to other plants in , Gulf area. San Francisco - Aroclor 1254 and 1260 Reported Aroclor to be present in San Francisco Bay. Reported to be thin egg shells in birds Lot of screaming - Great Lakes Warf studies on DDT Aroclor 1254 will be found 1 Aroclor 1242 will be found? 't Air Pollution - Possible spread - but less of an issue right now. Analytical work more difficult. *4r-'v- ' ' V/r ' ;,,(t~ ,1"' , ' .. /.:.N ' Direct Contact with Product A 'r-v Doesn't seem to be an issue - except for food heat transfer.- Iv We don't believe Aroclor is being used as carrier for / insecticide - sprayed around - v' ;: \tf 7 We are not positive but most uses are "closed" systems; . , or products used in solid plastics, or adhesives, or ; J^ sealants. ' 740839 NEV 027585 WATER PCB-00049789 -3- F. Fluids Product Hydraulic Fluids Air Compressor Fluids Heat Transfer . Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutio Customers Plant Operation by Customers Prod Yes, leakage external Yes, leakage external Yes, leakage external Yes, leakage from plant Scrap materials. No, Should be clean. Yes, Reworked trans formers Possible - See Johnson Motors Castings. Leakage into produc Leakage into produc In product but closed for end use- In product but closed for end use- * Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ** Need to take care of Aroclor in discarded transformers. Product' could be drained and reworked. Probable Conclusions Hydraulic Leakage Air Compressor Fluids Product could be caught at machines but will take a lot of clean-up work with customers. Will have to have replacement product - with less-sensitive components. Work from this base on clean-up to prevent more pollution problems. II Hydraulic Fluids Must expect "shrimp" experiments. West Florida State, to be "aired" sometime soon; next few months. This will lead to bad publicity and competitive action vs. all Pydrauls. We will have to try to confine to Aroclor 1254 and Aroclor 1260. 740840 NtV 027586 WATER PCB-00049790 -5- Action Kuhn Kuhn/ Fallon Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. Ha and terphenyl supply may become short. Switch customers to Therminol 55 or Therminol 66 ahead of pollution problems in customers plant. Work with customers on plant and dumping practices. Findett already set up to rework. Need to make them a manufacturing arm. We get sale of recycle-rework fluid.' Capacitor Capacitor plants have re Fluids purification and recycle systems but up to 5^ of product can be lost by poor plant producers and off-quality material, Mkt, Benignus/ Bryant 5$ of production could be Eng, -Kountz/ Mfg-Hodges 15T lbs/year. This is a big loss for the type of pollution we are trying now to guard against. Capacitor products Enclosed in A1 or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product for a time. Action Eng.,TSDPlant Pol lution Con trol Hodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. We have set-up to accept material for rework into hydraulic fluid but this relocation is not a satis factory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical Must start now to get con trol of off-grade material. Recommend replacement of future Aroclor business with other products. Have 2 years. Action Monsanto must help plant clean- ' up of cuotoucr plants uv.cnntation, coalescing., a.iscrption, dis posal of odnc-'be:.u or recycle of Monsanto badly needs "know-how" for clean-up. Monsanto should seek Govt. contract money for clean-up research, (See MRC R, Binning, D. Nelson) 740842 N V 027588 WATER PCB-00049791 6- - Transformers Action Benignus/ Bryant Transformer Plant can operate in a clean, efficient manner with recycle of off-grade Aroclor. Should advise disposal of filter element materials so as to minimize chance of water pollution. Incinerate or dispose. Reworked transformers pose a threat if the Aroclor Is dumped into a water stream. Product transformers can remain closed ar.c no exposure for 25 yrs. Should try to retain business by clean-up; by education of cus tomers . Action Benignus/ Bryant Should try to minimize chance of dumping "old" fluid by re working and by educating co. shops and collecting product for rework or disposal. Dalton is set up in England to rework electrical grade fluid. Kuhn/Kountz Flndett? Need rework facility here + disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Krummrich or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. Action - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try ' to reduce to ppb level. P.Hodges-Seek a Govt, contract on adsorption and incineration TSD cycles - MRC. Engrg.- Kountz Take samples of streams and river water and mud evidence for before and after clean-up. Samples can be stored for further analysis if we can't keep up current with analytical determinations. Apply Mor.rw'.nto cV>an-up methods to customer plant NEV 027589 740843 WATER PCB-00049792 -7- Action - Engrg. & Kfg. Kountz and Kuhn Evaluate liquid Incinerators vs. solids handling incinerators for disposing of Arocior and pentachlorophenol wastes. I estimate Arocior disposal at l-4flf lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. Hydraulics 20% of 45T lbs Heat Transfer 10# of 2FT lbs Capacitors 5# of 20ff Transformers 5# of 15^ 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. & Mfg TSD Kountz & Kuhn Set up an incinerator to handle Arocior dis-x f j ur- posal - preferably one which will handle - ^, solids such as muds - slurries as well as , liquids. Have in operation within 12 months. /v~' ' ' Ideally have incinerators available different , sections for disposal. Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.BioTest Continue studies to establish FDA type limits of toxicity on Arocior 1242, Arocior 1254 and Arocior 1260. Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Arocior in tissue. Try to see if Aroclors are changed metabolically. Does concentration level off, decline if feeding is stopped? Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Arocior levels of toxicity, then we will have to have biological studies on these species to con firm or deny adverse findings. NtV 0*7590 740844 WATER PCB-00049793 8- - Biodegradation Studies Set up rate of biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 Aroclor 5442 vs. Aroqlor 5460 Swisher Chlorinated diphenyl ether Chlorinated paraffin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 Baxter Contact Baxter and Lidgett at MCL regularly for results on Lidgett Aroclor degradation. I'hey are reported to be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. WRR:ms fyM2W. R. Richard NEW 027591 740845 WATER PCB-00049794 ` CONFIDENTIAL Product LJnAftX-- Test" Comfeu/rd i ^pilk4,lc, Kcid TTT CfeU ttthr*;' 'Sfrttt tore PctC jUre/(~f) Cytft. ' A fY0tA>-J/rti 7/mtf /?*fe (Vo) IS**0 ><i4.r IAS 2' t MTPB s HB-fo 6 S-7//M __ 7 :JCCB */J '^SctUt Q-0"pe^ cm^o 0;Afcj <2 f\$r*tcj Orf/;/te. lo >f^ S fy.st/.i. f~ * it> >945 /0 7S.2t3.z\ Jo z4 4s.iu.i\ /0 z4 43.317.7 \ z4*5- < 9 . 37SZ8.8 ( *j lo 2.H- jr |- Z4 y<Z5^2 j P-NCB 1 o t *1H- 51 ^ / 24 33742?! ............... * 1 LH %,nt.ei -i ft) flr0C.hr* /22/ <^0" #Xe/ . / 6Ho s It Suitor* Dift*rf/(it* .",jr;- 24. p.^2. i- > i" . PICS /0t?3 . /frt&nvcckr 1232 ngyp$rj%ct \s^^W (!%Br 5 < /. ' /" ~7*l aUHi 7 4b S&*/S.S S4.IH1.3 IM ms m ;. , / . . 48 3lf3/J.S r 15 Ik * 17 l<3 /1r*./as /2^2 AK*# C-fo * 11 `ttL Pi iC. /J f ^" 4fcec/ /' r ' flnef*!* /2S*/ &J&S0.O \ / | rcc Zo-MSQ. / t----------- ---------------------- ------------------------------------------------------ t YmtlftJ*/ Dt.vse&ps&A&e.e. fcfe. 7A3 ~ S.S X 4*- Zilt/si 1 69 ' 4s /So i3/7 2>l 0 NEcV\i r0\2?7t5fc9fi2 740846 WATER PCB-00049795