Document MJqKavRjD6D814G1kX28KDQz9

h. s. anon - sr. udu avrMBnt 12, 1969 sonsi or ardclor wctipmal rLPica R. N. JCOUHTZ Plaaaa rind attached a rough draft froa Or. Richard to Elaor Wieeler regarding Aroolor toxicity. I would approolato your rn-->nta to both Or. Richard and agrsolf regarding this draft. H. S. B8RQSN MONS 097283 luciaru) /' S ?/?& /\. c) .&W U*V >/ cj~tuio<, rV,"- ft***} . Rii~i<. a. ,f~cA<^rj /2Sm f^U^j MONi 097284 It*Ik tllft.ll it Ml t I Ml MCI TO oc..">., Richard - Research Center September 9, 1969 ' DEFENSE OF AROCLOR FT" FLUIDS 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?) l'or ArocTor tin Water- Which compoundsh 1 Govt. [in Animals "^Interfere? j Agencies Keep track of how much contamination - which sources. Prove Bloharmful - Let Govt, prove Its case, on case by case basis. Monsanto Vlslt-Govt. 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 fnan level for < mammals via [fish Rats Seek evidence of Blodegra- Chlckens datlon Flsh Question evidence against us. Question shri.-_p toxicology especially other toxic chemicals. If Aroclor bad, others must be worse. Probable Outcome We can prove some things are OK at low concentration. Give Monsanto some defense. We can't defend vs. everything. Some animals or fish or cots will be harmed. Aroclor degradation rate will be slow. Tough to defer; ,;ai.ist. ._gher chlorination compounds will be wore.- - . .v';er chlorine compounds. Therefore we will have to rescript uses and clean-up as much as...we. pan, starting immediately. /<, > I n ... - t,,;-` MOWS 097285 -2- Tnerefore we will have to work for alternate products In end use applications; for Aroclor production facilities. Clean Up Aroclors and substitute products where necessary and when required, before threats of publicity and competitive activity 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 Qulf 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 Oulf 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 - Oreat Lakes Warf studies on DDT Aroclor 1254 will be found! Aroclor 1242 will be found? Air Pollution - Possible spread - but less of an issue right now. Analytical work more difficult. Direct Contact with Product Doesn't seem to be an issue - except for food heat transfer. We don't believe Aroclor is being used as carrier for insecticide - sprayed around - We are not positive but most uses are "closed" systems or products used in solid plastics, or adhesives, or sealants. ' MONS 097286 -Im F. Fluids Product Hydraulic Fluids Air Compressor Fluids Heat Transfer Capacitor Fluids Transformer Fluids possible Pollution by Possible Pollutior Customers Plant Operation by Customers Procv Yes, leakage external Yes, leakage external Yes, leakage external Yes, leakage from plant - Scrap materials. No, Should be clean. Yes, Reworked trans formers Possible - See Johnson Motors Castings. Leakage into produc Leakage into produc In product but closed for end use* In product but closed for end use* * Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ** Need to take 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. MONS 097287 We will have to take action before that time. Gulf Coast - Action Richard Be able to replace Aroclor 1254 and Aroclor 126o In Pydraul AC and 625 In 2 month's time before Nov` W, 1969. Fallon/ Richard Have trial product in hands of Gulf Coast accounts and distributor before Dec. 15. Fallon Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS____ for Insurance. Richard/ Suggest possible substitution of Aroclor 5442 for Aroclor 1254 In hydraulic and compressor blends. E. Wheeler Judges lower order of toxicity and solubility for 5442 series. Have to test product In pump test for deposits. Fallon/ Richard Suggest field trials of our own all-phosphate ester. Fallon/ Kuhn/ Kountz Work with large customers to clean-up streams. Bring in Findett as mfg, partner in the recycle business. Get money out of recycle operations. Inland -Waterways - './heeler/ Richard Be close enough to Great Lakes studies to Judge situation. Are there animals which are being affected by the concentrations found? iRlchard ! Be prepared to replace Aroclor 1254 and Aroclor 1260 In 4 months in hydraulic fluids and in air compressor fluids. IRlchard I Be prepared to replace all Aroclor 1242 or 124P In 6 months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. Heat Transfer MQhS 097288 Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. Fallon/ Roush Need to replace FR especially in food or sensitive product aroao wh<.-. rho product Is nettlns into water. Scn. Jit... washer compounds. See letter E. Wheeler to V. Fallon. We have possible rep cement product; i . Therm:r Therm i... Action Kuhn Kuhn/ Fallon Try to assure adequate production of Thermlnol 66 In face of decreased Aroclor production. Ha and terphenyl supply may become short. Switch customers to Thermlnol 55 or Thermlnol 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 F_Iu__IS__S_ Capacitor plants have re purification and recycle systems but up to 5% of product can be lost by poor plant producers and off-quality material. Mkt. Benlgnus/ Bryant 5$ of production could be Eng, -Kountz/ Mfg-Hodges Iff lbs/year. This is a big loss for the type of pollution we are trying now to guard against. Capacitor prjducts Enclosed in Al or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product for a time. Action Eng.,TSBPlant 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 pr 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 customer pl.j.ts u>.cantation, coalescin';. a icer-rilo'.'., dis pose.! of ud-c.-be;.t cr recycle of kous,::neo badly needs "know-how" for clean-up. Monsanto should seek Govt, contract money for clean-up research, (See MRC R. Binning, D. Kelson) HONS 097289 -6- Transformers Action Benlgnus/ 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 yr Should try to retain business by clear.-up; by education of cus tomers. Action Benlgnus/ 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 Plndett? Need rework facility here + disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Krummrlch or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. Action - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try to reduce to ppb level. P.Hodges-Seek a Govt, contract on adsorption and incineration TSD cycles - MRC. Engrg.- Kountz Take samples of streams and river water and mud evidence for before and after clean-up. Samples can be stored for further analysis if we can't keep up current with analytical determinations. Apply Mor.nprto d <-!an-> methods to customer plant U,,-> .. jji'wliliuUI'ie, MONS 097290 -7- Actlon - Engrg. fc Kfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling Incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at l-4fT lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. Hydraulics 20% of 4f7 lbs Heat Transfer 10# of 2ff lbs Capacitors 5% of 20fT Transformers 5% of 15ff 8oo,oco 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 Aroclor dls- v posal - preferably one which will handle solids such as muds - slurries as well a3 liquids. Have in operation within 12 months, Ideally have Incinerators available different sections for disposal. , j *r< / l - fr 1 Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio Test Continue studies to establish FDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Aroclor In tissue. Try to see 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 Aroclor levels of toxicity, then we will have to have biological studies on these species to con firm or deny adverse findings. HONS 097291 -8- Blodegradatlon Studies Set up rate of biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 Aroclor 5442 vs. Aroclor 5460 Swisher Chlorinated diphenyl ether Chlorinated paraffin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 Baxter Contact Baxter and Lldgett at MCL regularly for results on Lidgett Aroclor degradation. They are reported to be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. WRR:ras W. R. Richard HONS 097292