Document a1JQ9BKb15NMDapVZRNQrEOeB

STATE OF ALABAMA IN THE CIRCUIT COURT OF CALHOUN COUNTY j MARS HILL MISSIONARY 1 BAPTIST CHURCH, et al., Plaintiffs, VS . MONSANTO COMPANY, et al Defendant. CIVIL ACTION NUMBER CV-9 6-243 COPIES PLAINTIFFS' EXHIBITS 1-23 and 26-34 to the VIDEOTAPED DEPOSITION OF MICHAEL A. PIERLE Taken on behalf of the Plaintiffs June 2, 1998 (314) KRIEGSFAUSER REPORTING & VIDEO REGISTERED PROFESSIONAL REPORTER 314 NORTH BROADWAY, SUITE 810 ST. LOUIS, MISSOURI 63102 621-4408 FAX (314) 621-4533 HARTOLDMONO017960 BB aiBDLiio or aboclobs fgaoRnrArro oiraarTL) Do not heat iroclor* in open vessel* above the tanperatur* at which funs a appear (approximately S007,) unless efficient ventilation is provided to naori the vapors* Rx Aroelors ara dlortnated Diphenyl and* a la charac teristic of chlorinated organic compounds, their wapors are irritating to the eyas, noaa and throat* Pro- looad and ropoatad exposure to such ftuaaa nay, la addi tion to causing irritation. interfare with the aoraal akin funotiona and result indireetly in physiological disturbances* If rantllation la not possible, than at a tanoorarr Jreoaution, wear a gas aaak and oover tha skin Vita a lberal application of eold erase before exposure to the vapors* Cold Crean prevents fin# pertielta of Iro clor fron enterInc the skin pores and faoilltatas thair reneval with soap and eater* Application of eold crean to exposed parts of the body is a preoaution reoqm ended to anyone eorkinc constantly with Aroolora* Zhaae pre cautions apply to dust fron solid Aroelor aa wall as to vapors fron heated aaterlals* [jAss s treatnent for Irritation of the eyee* first vesh the eyee well with, a saturated solution of Borle Aold thm treat with a lOJf solution of Argyrol* Treet burns frai hot Iroolor the mm ss any ordinary burn* Aroolor adherlnx ta the burned area need not be rawed ineedlately unites treatment ef the burn daaanda it. In ahloh see# use soap and vater or repeated vasftlngs with a vegetable oil (linseed oil)* Personal cleanliness is of utaost Importance* fork clothes should bo changed dally and mat not be worn aemy fron the plant* Before changing to street elothee at tha and ef the day the eorknen diould bathe vlth plenty of soap and vain eater* Begleot of these staple precautions say result la heIn infections* ill health* diseoaforst* in efficiency and lass ef tine* - HOWS 05735^ liytsM. .Mi. HARTOLDMONO017961 This document h** been retyped far clarity. from Monsanto Chemical Company a:: St. Louis, Mo. Mr. H.X. Nason-M.Q. Mr. R.K. Soden-Nitra Mr. L.C. Weger-Nitro D4te June 12, 1956 To Dr. R. Emmet Kelly _ At Medical Dept. Heferenca subject CHLORACNB CASES AT BADISCHEN ANILIN DDE TO TRICKLORPHZNCL Person Present: Dr. H. Oettel Dr. H. T. Hofmann A. Palm (Ph.D.) W. Soenksen (Plant Supt., part-time) On the 17th of November, 1953, Badiache vaa producing a batch of trichlorphenol from tatrachlorbenxene when the process exceeded control pressure and temperatures similar to our incident at Nitro. No one was injured at the time. Within one week, as clean-up wa being carried out, the first cases of chloracne developed. Pifteen or sixteen cases (6 serious) developed within the next 1-2 months and additional cases showed up during the next 10-12 months until there was a total of 50-60 cases. I did not see our moat severe Nitro cases nor have I seen photogr aphs of eu. Tha photograph* of the worst Radische cases show horrible skin eruptions with nearly blister-like welts and some ulcera tion where infection ensued. Areas involved included the face, neck, arms, and upper half of the body. It is my impression that th<sir severe cases were much worse than ours. In addition to the skin mani festations, their men reported all the additional symptoms as exper iences in our workers, i.e., fatigue, vertigo, loss of libido, painful joints, -etc. About ten days following the incident, and after initial clean-up, Dr. Oettel was asked to expose animals to the workroom atmosphere. Rab bit* (in open wire cages) were placed in the operating area for 24-48 hours. There were no obvious symptoms which developed in the animals until one week after exposure - when they died. Autopsy showed liver necrosis. Oettsl thought there might be virus infection or some other cause for death until he exposed additional animals in the department, others in cages suspended inside the "decontaminated" autoclave, and some in the adjacent department. All died within 1-2 weeks following exposure. -Subsequently, animals placed in the cagee which had pre viously been in the department died of liver necrosis. A thorough systematic investigation has isolated impurities in the trichlorphenol procsss (or residues) which will cause the same effects in rabbits. Liver necrosis will dsvelop in rabbits at the following doses of the indicated materials: 15-20 mg. of pentachlor naphthalene 1 mg. of chlorinated diphenyl oxide . . 0.2 mg. of residue from trichlorphenol distillation 0.01 mg. of residue fraction from trichlorphenol (above 230C) This document has been retyped ior clarity. HARTOLDMONO017962 nsJj darjBMC h*a b**n entyp*d for clarity. Dr. Oettal believes that the most,potent chloracnogen is a compound scnewhdt similar to chlorinated diphenyl oxide, ' probably with additional oxygen atoms in the molecules. He has cor responded with Don Irish at Dov who either reached the same conclusion independently or, in mentioning the potential of chlorinateddiphenyl oxide, influenced Oettal's reasoning. Oettel believes, further, that this impurity can shew up in the production of any chlorinated phenol allegedly to"chlornapthalenes, pentachlorphenol, chlorinated biphenyl. etc. Dr. Oettel has no faith in any animal akin testa for isolating chlor- acnogens. He was very interested in Kettering's war* and was not aware of the publication referred to in Dr. Suskind's first report and ~ which describe* the cyclic skin development in new-born rats. (Refer ence: Parnell, J.P.: Postnatal Development and Functional Histology of the Sebaceous Glands in the Rat, Am.J. Anat., 85:41, 1949). fla is convinced that the Bromsulphalein test reported in the attached reprint is significant. In this rsgard, Badische routinely uses this test on each batch of trichlorphenol which they now purchase from Sayer, and refuses to accept material which fails to pass the animal tests, (I also learned at Bayer that they have experienced chloracne during the production of trichlorphenol but "have now licked the problem" . j according to Dr. Hansen (chemist - Research Director At Elberfeld). ^ Badische has been able to reproduce in the laboratory the conditions which lead to the incident such as theirs and ours at Hitra and was quite surprised that we had not been able to do so. I was not given the Nitro process information, i.e., temperatures and pressures, but if I had had this information I am sure that I could have obtained Badische's. One of their chemists, a Dr. Palm, sat in on our dis cussions and was prepared to go into details. He did mention that "with 3 mols of trichlorphenol, methyl alcohol, and alkali, and a tem perature of 1S0C" the process gets out of control. His remarks axe in quotes because he does not speak English and I'm not certain of his remarks. Dr. Oettel would be very happy to receive samples of any of our materials for investigation. H-: vould like particularly: (1) Samples of any of the materials involved in our 194 9 incident including tetrachlorbenrene, trichlorphenol, or Na salt and any residues from the autoclave or material cleaned from the equipment and structural members. (2) Trichlorphenol (or Na salt) from regular production. (3) Any samples from raw materials, intermediates, and final product which may have been involved in our cases which developed during our normal 2, 4, 5-T production in the yeaxa following the initial incident. nUi do cun*n c b+*n retyped for cljrily. HART OLDMONO017963 Tbla document bs* bean reeypmd tar clarity. Ha would ba happy to exchanqa fraely any and all information with us and Kettering. It was nry suggestion that this be direct with Or. Suakind to eliminate "third parties." He would routinely send carbons a any correspondence to us and we could request Dr. Suakind to do likewise. It ia my opinion that this might save unnecessary duplication of effort and expense. In addition, Kettering might obtain valuable information to further their investigation involving human volunteers. I left with Dr. Oettel copies of the following: (1) The five (5) reports from the Industrial Hygiene Foundation which discuss their rabbit ear tests. (2) Kettering's report - "Clinical and Environmental Survey at Nitro, 1953." (3) Kettering's report - "Environmental Survey Carried Out In Building 30, Monsanto Chemical Company at Hitro, February 2 1956." We reviewed thoroughly Mr. Weger's excellent "History of Chlcracne" which he sent to me with covering memo dated May 15, 1956, and which included descriptions of Kettering's reports on their human and animal research. I did not give Dr. Oettel a copy of this account because I did not have permission to do so. As a result of my visit, it may be desirable to edit this report somewhat and add further process information before forwarding this to Badische. ^ Any specific recommendations are implied in the above narrative account of my visit to Badische and must be based on an agreement that full and complete exchange of information with Badische is desirable and possible. BFW:dh Attachment . EPW Elmer P. Wheeler t'lJj doc'jireot bas barn retyped tor clarity. HARTOLDMONO017964 MoxiAjrro Chemical Compact At Anniitom, Alabaoa To Hr. I. 1. Vobui SC. Loaii At Xobarca lids. 0.i Sapt. 30, 1937 &*itrtnct XZl/JtC 2/2S/57 D. I. Sonar V. J. Doufbertj C. A. fvaeei H. I. Dunlap Jack Clafora J.V.Crarea-VCX ' X.XllaabBrj-Sata Offlca W.Daltom VCX . *. X. Xall7-Haln Of ilea tab j met: TOX1CITT 0? XJKTJJIS It tht rafereaea neao, Dr. Xally advised Chat ha had mo lnhortor7 Coxicolojlaal data on 6ha Honcara bat tale emrtala thep sonId eaoaa ohloraema aiailnr to the ehloriaatad aapbtkalamaa aad dipbaapls, aad, aeeotdlp, thep ooald eaoaa liver Croatia hr inhalation el tha iiaat llbaraead at elevated taaparaturei. la raen--ended Chat tha aaziava allowable fuaa eoacemcratloa ha aae at 0.3 ailllgrau par coble aaear ef air lor expoeure data Information to oar eastatari. At Imalatom, va drain Kentart at 3t0C. fro* our atilla an everaga of omea par da* haa eperatiag at maaclaum rata. Tha aparaeiom la performed mndar large hooda vhleh 1 had lava are affective in protecting oar peraotnal. lovevnr, It la paaalhla that aoaa foaaa map aaeapa late tha operating arna daa to vlmd earraaci or Inadequacies In oar hlover spate*. At asp rata, 1 mould Ilka to |#e a fov reading! la tha department to naka aura va are aafa. Cam 70a farnlah na a detailed prsaadura for determining tha eoteattn* Cion of Montara In alrt Alao, has U7 farther Inioraatien ralatira to tozlelt7 haan developed! CXZ/fb C. X. Xdalblut HChS 095660 HARTOLDMON0017965 Moniaxto Chemical Company At Aanteton, Alabama To Mr. 1. I. Vobua St. Louie At Roberta lldg. Data 8*P- 30. 1957 ItUrtrxt m/JtC 2/2S/S7 D. I. lontr V. J. Dougherty C. A. Sweet* V. 1. Dunlap Jack Clagora J.H.Cravee-VCX A.K<XllenbsTg-M*la Office T.V.Dalton - VCX *. X. tnlly-Hain Offlea SubJnet: T0X1CITT OF NOCTAXS la tha rafaraaea nemo, Dr. Xslly advised that ha had mo laboratory toxicological data am tha Kontari but fait certain ebay aould eauaa ahloreena similar to tha chlorinated aaphthalaaaa and diphenyls, and, secondly, they could eauaa liver trouble by inhalation of tha ftma liberated at nlcvaeed temperature*. la raop--ended that tha maxima allowable funa eoneaatratloa be aat at O.S milligram* par cubic aatar at air for expoeura data information to our customer*. At Aamlstoa, we drain Kontnri at SA0C. from our atllla an avnrag* of oaea par day vhes operating at aaxlmiat rata. Tha operation la performed under large booda which 1 ballara are affective in protecting our peraonaal. lownr, it la poealbla that none funa* nay aaeapa into the operating area dua to wind currant * or inadequacies In our blower ayatan. At any rata, 1 would Ilka to gat a faw reading* in the department to naka aura wa are aafa. Cam you furnlah na a detailed preeedure for detemimlmg tha concentre* ttoa of Heaters in air! Also, has any further information ralativ* to toxicity bean developed? CKE/fft C. H. Xdalblut MOHS 095660 HARTOLDMON0017966 ' . : - I citndk' oopy ^ * lottax xmcmLrmd fxon Ola Yolo La StuacJcholJu . X km fat aoyioo of tbio lottar aloo to tbo opjrrDpriato daptitau:. -. . -" vitbln omr otm oryaa-Lootianu la. oonoldormtlan of tba JLoporeaaeo . ' ' Vo in yliriaf on ilnrolopnngfc m tba Voodlob anrbrt for iraclcr ' onr tba onnfe fit* jiiti, on vonld bo yntafil If jom. aonld imaq . far hio fiftimtiai to bo aoaoidarod by tbo opyropriato Ap*r*oona . Btood on tbo rocanonodotinoo oodo by onr nodi rol doportoB&tx vadtoll. . . bom tot iVeido obvrbor to far yoblimt tan of dorr la 9mm In HARTOLDMON0017967 ( RISING &. S * Ft A N. Q; 0 P/50 AKTHiCLAQ 4IU STOCSHOWM |C4A4<M 4 7 MCV; :her Mcnsanoc Europe --"--a---* cr :~g actar.tlcr. of Hr. Q. WCCD Dear David, As tendered, there das beer sere publicity In Swedss ccrcerd-g investigations aade at the Institution cf Analytical Cieaistry at the StccJchais University. These have revealed that a group of* products called Polychlorinated 5i-Phenols r- ?C2 fcr short - accorrulitad Is. certain organs or masala. They-are said to b related to DDT and equally poiscsucus. ' The find tigs were discussed at a seating ad scientists at sde Vecrer-Gren Centre in Stcckholr cn Jfcvetcer 223elcw please died a transiaticn of ar. article in etc Swecisn daily paper "Dagers Hyneter":- "It Is found in salaca and in pike. .It is found in sea eagle living on fish. It is found cn che^sur- face of the needles of the fir treesthat isvV,n tie air. It it found in the hair cT five norths baby... ' * `J % The scientists verging with biocides have for 7lcng tine seen this scaething as unknown "peeks 7 cn/their gas chreaatographs and at a ne<tingv4C the Werner- ' Grer Center, Research Assistant S'dren tfenaen of the Institution for Analytical Ctmistry at the Stcck- boln Dhiversity cculd reveal the identity of these peeks. It has been found that they consist of a group of poisons, Polychlorinated *- (Tor snort ?C3) which art closely related to, and equally poisonous as, DDT. FC3 is broken born considerably slower than DDT and t gives rise to dacagyof liver and skin. ?C3 is not S7R 017391 i-- \ / * HARTOLDMONO017968 used is a. herbicide. Id is- not; ranuracsured. Is. * Sweden bus is supposed do- use-d by the industry quite some extent. Mo steels! industry ess- so be accused of belr.r r.ta -------- ^.. He seared. Asat. S- Jensen h*_g pasted. 2CC blades. .-- & sunder cd birds. 3s baa taice- several tarried cd n * -- --* !- *r --. ^ T *- i-t ---T- ye i - equally ccmcr is. Mature as chlsridsrad hyerddarrenn or the type cr EDT, DEE, add Lindane. Sven fisn id Labdjojaure id Lapland contain PCS. t*r. Jensen bar also round that PC3 dees not appear id anidals living on a vegetarian dies, sued as she elk. Id she course or bis work, Hr. k* a * 'm idg iddieasidg sbas tbe source cr ccdtarida- Ciod esses rrces agricultural additives. Zt is, however, obvious already new sbas PCs is scan frequently round id organisms living id water or reeding 'da water adidais. srd- aL!_1 -- > PCs was round. Id a sea eagle round. dead cuds Secckhsir is was rcudd sbas sbe liver ccdtaired TOjtd or =grsuz-r_ser_:<ilo, J6. ag SET add ecssider- desemined. Sr PC3 is round in water and id air, and net only id tbe Swedish air, bus also id e-g- London, air. Kr. Jensen. has. nos yes been in Lender rer sarpling bus could ider-dir7 Sde poisen by studying a gn idd^rsm cT air published id a British seenni- Mr. Jensen bar also csarir.cd sbebair or bis ranily add binaeIr and bas rcudd PC3 cn all saeples. Most ?C3 waa rcudd in She Lair or bis wire bus boss sensational was sbas the girl aged 5 tenths bad nor* ?C3 in bar bair Shan bar breeders and sisters or 3 asd 6 years. Probably She girl bad got tbs poison ria tbe seeder's silk. In She State Muraua Mr. Jensen bas examined She wnola collection or sea eagles dating baeir so iSSC. 2y tasting it could be established teas PC3 was present only in birds rrca 15*-* and tberearsar while birds collected berore 194Jl were quita free frees PC3. Tile use or PC3 in Sweden is net essablimed in detail. According so American scurees these types or products are used in Sbe tsanuracture or a variety or heat- resistant ratarial*. They are used for electrical inrulaticn, rcr rire-preer beat trsnspors in hydraulic oils, in lubricating oils used as high -^ ' --w1 ST* CIT292 HARTOLDMONO017969 temperature and pressure. in pair.c & and as pig ments la various plastics. ?C3 is- not- imported- onl7 an such. It is also part of several finisned- products. Nothing is 'ccwi as to the way la, which it reaches the water and the air. According to. Mr. Jensen, products containing PCs ! -*- have this openly declared. PCs Is equally harmful whether absorbed: via. me sicln, through the feed, or by inhals.rl.cn. In con tact with the smn it can cause oedema. For DDTthe highest permissible concentration in the air has beer, set ac 0-5 - 1 ag/cu.metre. Fcr ?C2 ic has been mentioned to be 0.~ n^cu.netre. Mr. Jensen will new cry to get sore complete analytical naterial. He hopes eventually to be able to disclose the source of the ccr.tanlr_ao.lcn and will also increase his cccperaclca with rcxcccicglsts and genealogists." An.ocher dally paper, Svenslca Haghladcc, has a shniisr article. Hers it Is mentioned Chat Mr. Jensen* weru< -g under Laccracor (Professor) Guttar Widrsrk, has disclosed facts which will have far-reaching Importance since the findings have proved a mew acurce of pollu tion- of che nature. c-- cf the participants at the meeting was Dr. A.7. Holden, cf Scotland, scientific contact man between the twelve a^H.C.H. ccuntrlea, who has estahllshed cccrdlnated analysis cf ehsssicals uaed and found In nature. I suppose there is no douht that whac has been termed Poly chlorinated 31 phenyls is equal to Arcelor. There la also no dcuht Chat thm publlahed facta will cause ccnslderahle unrest in several quarters. We prcbabi7 will have Co have Aroclor registered wich Che Swedish. Hoard of Pclsoncus Substances and che industry will have to be particularly careful in handling che material. The problem in seme cases of course may be Che disposal of used material. I understand that there hardly exists a convenient method of destroying Aroclor and thac ~ possibly burying unuseabla material may be che only answer. We aha11 be glad to bear from you seen. Tours sincerely, REWa 1 Sim------- jJiAG HARTOLDMONO017970 oo By Wesangttoo-- From ft. Louis - General Office* On Itay 29, 1987 *, ELaer Wbaeler -o. Charlaa Casper! - 5. 1951 Mr. *. . Xinteer General Office* PTEfUOL ULBKLIM Dfr Bcbf ' \ 7 In order to comply with recent change* la labeling las* CSCtod by wreril state legislature** th* aubjdet of correct 1*baling for th Pydraul* has boon a groat eoocern to aa. Thla situation was brought forcibly to our attention bjr a specific request froa ' that a caution staap b aff iaed to all Pydraul which they purchase froa Monsanto for resale. Ve believe the wording which they use on this trap Is not In th* best Interest of Tydranl sales* and la such that our competition could uae to greet advantage. The language of the Socooy Hobil label la aa followwi C AT I0I Contains Chlorinated Hydrocarbons. Avoid prolonged breathing ef vapors or data. Avoid contact with eyes or prolonged contact with skin. If skin contact is had* restore by washing with . soap and water. 7or eyes* flush with water.' If elothlng becomes soaked with fluid* remove promptly, and launder before wearing again. Thla la in comparison to the caution label used for Aroclors* which Is as followat C A T I 0 I . Avoid prolonged and repeated eontaet with akin. . Avoid prolonged breathing of vapors aod durt. It la our deeire to oeg>ly with the neceeeary regulation*, but to eoeply with the minima aod not to give any unnecaasary Information which could very well damage our sales poaltloe in the synthetic hydraulic fluid field. NPC010S279 FGL 09]Z77q HARTOLDMON0017971 By Jtr. JL. 0. Xintaar From U On May 29, 1887 * - Dacaabar 5# ig5S By ecpy of this nmao, I aa raquaating that you and Hr, Caaparl discuss what la naeaaaary fret tha la baling riawpoint and tba lagal aida, la ordar to aoaply, but yat aaintala our axeallant poaltloa la this ftald It aould ba appraalatad If you ooald glr as an aoawr by Pacer.bar 15* to wa may taka poaltlra atapa to ooaply with tfca Soccoy Mobil raquaat. .. SFStb^t D. F, Saith I FGL 0917771 NPC0106280 HARTOLDMONO017972 at. Louis - Osnaral Offlai Mask dlahols - Cleveland Septsabar 3. 1965 AROCICB 1242 -- lallance gleo trio * Zhgiaeering Caapany, Cltvtim, Richard Daris RDAVT Aa I told you an tbs telephone ttr. Hared* called at tarlltr this wtJc quits disturbed aa a reoult of ay lattar of August 27. TDls lattar apparently alerted hla ttir to the potential toxla hazards of the uam of Aroolor 1242 at lavatad tsapermturea. Ba told aa that tha Jtocaanto literaturs furnished hla had been aafd reasaurlng la tana of utiat probleaa sight arlsa la Chair application. I guaaa that raally Shook hla ass whan I aantlCDed that with taaperatures groatar than 150 aaohaaloal axhaust ventilation should ba provided to raaora rsport. For tha raoord Hr. Haradoa' application lnrolYts tha usa of Aroolor 1242 as a coolant In alaetrlo sotort. Two sotors ara aountad on aining equipment usad at tha fsea of a drift. Total voIubb of Aroolor for tha two sotora is approacisately twa. gallons. Haradoa astlaataa that four quarts par day of this quantity would ha lost in tha alna -- prosimfaly all of it by volatilization. Z told his Z douhtad that tha rontllatlon provldad in alnat would ba aufflelant to lowap this asount of Aroolor at tha threshold Halt value of 1.0 ac/eu. aatar of air. Ha told so thara had boon sens complaints In alnoo idiora tho aotors wars balng usad. Ha wasn't apaolflo but Z undsntood that tha easplalnts wars of odor and Irritation. ttMthar or not tha lorals ara aotually Irritating I don't know. It nay ba that tha alaars bars Just raeognlxad that thara la kh- thlng In tha air nos that wasn't thara bafora. Rr. Haradoa want an to say that la his own plant hot Aroolor spills on tha floor wora eanaoa and that hla own awployoo had soaplain*d of dlsooafort. Z waa brutally frank and told hla that this had to atop boforw ba Riled acsobody with liver or kidney -1*--t* -- not baoauss of a alnglo axpooura nocaaaarlly but only to eapheel ra that 8~hour dally exposures of this typo . would bo pletely unaafa. Haradoa oallad a aaeood tlsa to lnquir* about tho deccwpoaitlon products with apaolflo roforanco to daeoapoeitlon products rasultlng frow olaotrlo arcing. I told hla that wa had Underwriters' Labaratorlaa report* on boat transfer fluids which war* partlnant. Ho recognized that tha chief dacotposltlon MCNS 097873 HARTOLDMONO017973 Richard Davis Page 2 9/3/65 product would likely be HC1. I atphuixtd that this in itmIT la ft good "warning agent" which serves to Halt voluntary sxpoeure to high concentrations or deeoapoaltlcn nateriala. 1 told Hr. Haredoa further that th Nodical Department m skeptical ahout tho um of droolers la elalng operations bteauM wo had not Mn data to shoe ataenee of toxic levels. I emphasised and re-eephaslsed that tho droolers aro excellent product a Out mist bo used la closed ^fstooa ir they aro to bo hsatsd. M Implied in his second conversation that his engineering grouf aa looking at redsstci >0 provide a "sealed" system. . ZPWimJb Elmer P. Wheeler P.3. Mr. Harodoa pointed out that in his aapileatloc the droelar could be heated up to nearer 400y than the 150? figure which I had mentioned. m HONS 09 78 7<t HARTOLDMONO017974 PRCCZ22 7CR THZ PRCTCmCif 0? AR.OCLCRS, PTHAJiCLS, STS . AT THZ A.TOI5TCH AJC AT THZ VX. 0. ER7*CI0I 7LA.VT A-rii I955 S. Xxtber < Slat rriutlsr. Hat (trended July 13, 135=) *- _ 2. ~3 , -r- ( Lender .<; Ee*. K. 3. D73CH, He^rpcrr * Kevpcr: T.I.'Z.' Oils 3. Xr. G. T.'TxTiar, Keirpc-- ** Xr. a. V. Txylar, Nevpcrt - Re^pcrr pracaaa Sup e nr. Pi .-a 5. XT. V. 2. Eiar, Suiter. 6. Xr. 7. Stlcidey, Sr. Lrdia * L-=-1 :h ?li.r. 7 . Xr. J. 7. Stlcidey, Sr. Lrala -* St. Lraia HSnrr 3. XfL Olle .r St. L=uda 9 . Xr. D. 3. Hcaser, Amiatcr. 10 Spire held 1- X.C.L. ic St. Lcuia V. A. Hj.7v1.ri ' a file Ful 0Z5OG56 llac Settler. IT, SpeclflcxPler.a trd : a : Xe P had 3 it .VeY-pcrr AralTtipil Oepirrz-ar.P. HARTOLDMONO017975 f ??.CCZSS TN DETAIL, ccr.ti. p-- 3e Packing <m,e Aztcclers are run c77 .---? ^ j, cloth being tied on the pipe curler for the lighter Arcs? arc. a piece or fine gauze for the heavier Arcclers, wnich have - = pe handled her. . This, or course, is to arrest stray hits or pipe scale ere., Cut the precaution la new emitted at the Krumnrich plant when =ateri = ; are being rilled' directly Iren the delivery cl the niter. Newmci arrangements rcr rilling and weighing Irena are discussed in lent: Engineering Pinal Repent, September 19=1, page IDS and 1 7Z-'~2, also in the start-up reports, July 2r, and September 27, 1951. The drum nua: be clean and dry, especial care being needed with electrical grades. Newport complaint N?/ci, Ncvenber 1951, cr turbidity in 12*6 was traced to the presence or water In the drums Apparently, in presence cr water, the Arsclcr reacted on the galvanising or the drum. Newport plant report, December 1951, ( mentions the installation cr equipment for drying the droms . Care is taken not to do any packing ir there is EC1 rune in the ai: The gaskets ror the bungs or the drums have to bo correctly chosen A sample cf the gaskets supplied by the Heiratn Supply k Gasket Cc to the Kr--.mloh plant was sent to MCI, April 19-7 See also the ,,. diinussioz .cdLgaaka-cs-ccv-paga. -2 o -Seetl-cn *2Cy Mr. Pemberton, December IS50> collected samples,cf The labels used at -the Krutrr.rloh plant; cne a patent list label, and the ether a warning label or. tonicity. The erfect or exposure or Aroclors to metal contact It discussed 1: Secticn VIIcomments, page 17 below. Gene rally speaking, the distilled Aroclors are packed in galvanized drums, the undistilled cr.es in black steel drums. Flaked or rilled solids were packed in barrels or Leverpac containers, bulk solid or resinous Arcelor: go out ir. friction type ill drum, (galvanized fur the distilled grades). Storage and V. 1 ' - - of the distilled Aroclors is done 1 c steel vessels sprayed with tin or zinc, or aiunindn lined. HARTOLDMONOQ17976 3 tt. pp.ccz^s ry ah ?i=3drjr, ecr.ti. ce the Arcclcrs are such eTrectlve solvent: **- d.-_ ar ........ **a - -* Mv '. wa *rC4 ~j J --a-'-*-'"*-* -<* --* --C_ 3 , -T-SU--i-----_--_r ---- - - a . s Teat-ure is irpcrtant in connection with hydraulic riuids * Mi M cc taining Artclcrs. See, Ter enarple, MCI Re searor. Prcgress r11 1, 3? 5V26/7 and 3? 5V277/6 and 1152 D? yic/7 and c*July*i ., also r.Me Section HZ, Physical & Chedcal data, ascv . C--_r. electrical grades cS Arcclcrs are act painted. Nevp Ac Plant sc -= ?rc was d a ret re rat s also ar dispatched A ected by a tarpaulin cent dur r Newport plant repert Cor July ner.tmns the installatlc ta.rlc-rilli.-_; radii ties. The L~rrr:ch plant operating ins rail cars fer Pyrancls and Ar a stean ceil cr a stear Jacks Ise sprayed with tin and tine. . KCC have a "Christnas Tree" HARTOLDMON0017977 xr. hatahts T^crs nxny literature rererences*rc hamTul tCTezzz cr ths ;-.- Thsrs was sene trouble of this icird anc.og the produced.- vc-ic-- Ar.-J.iccn in thfi early days cr the development' or the Arccic-'"" - cnac Cine higJly chlorinated Aroclors wars being rad <--dl-.^- ~ w-- ^ c=e l=v grade benzene. Since good b Arlene bnc'Tc'c- u2cd} <* 3A.--.* Az^ccLcr`3 Jiivs bcsn, rzjidf vit^ciit ?*Cwb7c it wa* rrpcrted that c** Ar--J.3:cr <--: 12 years without lost cine accident. t- ~ 7~`* ` --. ~ . ?rcr the scare cr Arcclsr ranuTaccure ac che Xrncr.cb plane ere operators have been supplied a clear, change. a? clothes every day, r and cine has beer, allowed ac che er.d cr Che shire fc- f*c**a' -w 1. ' Cperaccrs are advised Co wash hands and race beicre tn~` -- Anr.lsccr. cperaccrs da net have che sane issue or clean clochec . Percy hay, "Chenlscry or Syr.checlc Drugs" , 3rd edlcicr., page ; The Cherlsc , lyse", Sep tender i?-7, Vciune _3, He. 2 pace 3] ---and--a me-pcrn.---=hry-_?--^-rX-c^~--GX-.;--iescer-,--lrrJ?a=-or>^ plans, -i937y:--siv an cr.e tonicity cr diphenyl. f n** v 4 ** 4 1 KCC Bulletin ?-il5/enclone 'u o - = 1.0 rg. per cbn in air high.esc sale cccser.cr nion oi higher Aroolcrs, and 10 r 5 . rare highly chlorlnaced Aroclors . H. 2. IdU-ns "Chenlscry of Industria, Tl ----- - --1,,--- -3- 0.5 to 1.0 ng. as Che allcwacie llnic The KCC Bulled.-. "Physical Properties cr Arcclors" render.: CerJc erreecs arising iron Che era! i.njecdcn ci Arcelor;. See Che letters, 2. Hather tc ? . J. C . Hnyvocd . TecenCer 17, ; Kacher tc Newrar., January S, 1952, reviewing che lice rarer: May 17, 119C3U-, P^ig;isa 203c page VI-3* above. ' a * -- -- c che ardc.s and ch varr-ir-*-sS HARTOLDMONO017978 '"iXZArDZ, cent: S w* - - v-- p He r C 2 jr--* rC> ( \ i Decs-- -r /s V' 4 wV D; Xh s n. D Wj p -- Su. . a.y, V ail, 2" r-2.11, 2 - f li I H?ri IIII 'I (I he II years cf pr e vld.er.csd. derr-aci seve had alee Arc c 'laiced, a C the air. - e fx;::r -1 weirr. r we have r.c ~ -- * -- -o '-; s: oT derrac HARTOLDMONO017979 / e ~L r: v. -r ts'^tV-<c* / The Chemist: Analyst, Vcl. 36, Re. 2, pag. 33, J. T. Baker Chemical Co., Phillipsburg, H. ;\ September 19*7 O.H TsZ TCXICITY 0? THa "^RCCaLCRS" (n = ; Robert .M. Brown, Chief Industrial Hygiene Scotian, Division cr H-alrr Dept, or Public Welfare, City or St. Louie, he. ' A recently published article (.haglic, X. Martin, Chemist Analyst, 35 9' )i hat recommended the substitution cr cr.e or tr.t "Artchlsrs" as the relting-pcint bath liquid in prererer.ee to cr.e cuator-ary sulphuric acid. Aa abated in that article "Arochlcrs'1 are a group or chlorinated diphenyls produced by the Kcr.aanta Clerical Company. There is need thererore to give warning. ?cr the tonicity or these compounds has been repeatedly demonstrated, both Cron the standpoints or their absorption rror the inspired air, as well as from. their' effects in. predu o.ins a serious and diarisurins dermatitis vr.cn allowed to'renair. in contact with the skin. Since these errects have been repeatedly observed, industrial hygienists have taker, care to see that the proper controls have been established wherever these products are used. ?cr enanple, the naniren allowable concentration of chlorinated diphenyl Ter an 5-hour working day is 1 nillisran per cubic neter si air. It is probable that* nothing like an. uncontrolled Indus;rial expo sure will occur in the laboratory. However, vr.ether an individual is subjected to a possible acute exposure to chlorinated dipnsnyl, and its serious consequences, will depend upon the sits aC the surltlng-point bath, the caution with which it is used, and the temperature to which it nay be heated. Likewise, with careless-., handling of the material and the resulting contanira tier, cf the skin, clothing, iabcntcry towels, verk table surfaces, etc. the way is left open for the producing of dermatitis. Scrupulous cleanliness must be insisted uper. wherever this material is handles The foregoing remarks have beer, prompted by the belief that in re commending the use cf 1 material with which is associated 1 peterti; ha card from the health standpoint, it is very important that the possible consequences be presented together with rrcomer.datiers - - ccrrsc* ^1 * ~ t* m HARTOLDMONO017980 c ?J2Z , C~ZZ - M_r. A. C. * . Perrlr^tcr. -- Newport, reportin---gs >** w --- _ "At Anniston, no special. protective clothing ij provided " the Tiphenyl ar-d. Aroclcrs operators. A dally charge cf elcthirr was provided In the past buz this practice ceased CeTcre the vaGaunriet leather sieves and race shields are, cr course, avalize as required or. the plant " Tins cr ccld ertas cir.tner.t, theatrical quality*, are tc . ir. the building, but the application cr the crear is left tc tr.e operator's decision cr the Jet in question. The ner. are expected take a bath, ir. their ovr. tine, at the end cr the 3 hi .ft. A seed quality acap, ar.d alcohol for rabbins down purposes, are provide: The operators are sufficiently trained ir the reed for personal cleanliness that a record of bath taking It not warranted. C "Emergency shovers are provided on eacr. floor of the Cipher, building and safety notices are widely used. . "At St. Louis, Plant 3, the Aroclors building is rated a tonic department. Each operator is provided with a ccnplete set of clothir.s comprising hat, coat, trousers, oonsiratior. ur.derclothes, seeks and rubber shoes. A clear, charge cf clothing, enoept shoes, is placed in the operator's looker in tire for the following shift. Men working esezra shifts are giver. a clear set Canvas gloves and goggles are provided ar.d ' Ply hand barrier ore an is available for use when r.e "Twenty nir.utes' paid tine is allotted for bathing at the end of the shift but, again, no record is kept mat batr.s arc, actually taker.. Theoretically, food is ret allowed tc be eaten within the Aroclors building. Instructions are issued tnat hands and face should be cashed well before eating. "Employees in tonic departments are giver, an annua- r.edlcaena-ni nation and a lung X-ray every three ye ant.''. C HARTOLDMON0017981 r r e >> I snir, 0: z'zZmZ'L^rt ccnti O 1, A good deal cC work has beer. done cr. detemp ------ -- _-..e '/a: pressure cC the Amclcrs, and. cn one detemp vs. I. cri c r / c cT Aroclcrs in air. See pages 9-, Section : IX, a-cv*. oj this work. Ir. 1550 (letter April 20, N. ?. Rapps to Z. Mather) th c Adjni. srz J. t * expressed interest ir. the desemination ad* nicrc-cuarnti- - ^ Arcclcrs. MCC have a cached Ter the de teminaci cr. ; - ~-5 -- * < -- air by r-ar.s of the "rlalidcreter". hr. Iller.burg, March 15, 155 ner.ticns work dor.* by 3. ?j.cha: Ir. , of MCC, Jure 17, 1553, on "he de semination ci the cencentr: cJ Aroclcrs in adr. Mr. Zllenburg also states: ''------------- work or. Che safe Units oJ Arttlor vapour concen tration in air it being carried cn by Che Medical Copartner, at the Kettering Laboratories in. Cincinnati. This work cr. aninals is well under way, and will help us ts ictcv a litti: bleett~te*~r Just what is the saie lirit ci Artclcr Vapcurs that cr.e nig: work ir.." A question has been asked about the possible hare tc plants iJ A: containing paints are used' in greenhouses. The reply is that r.c: paints are 3 one what hamTul, and there is no * f- ^ * stake then worse. Aroclcrs have beer, used as 3 -- * * - cu ic any ham tc vegetation. Care is needed in laboratories where Aroclcrs are used ir. heating baths; there should be very positive ventilation. The vapours of hot Aroolcrs are distinctly irritating to eyes an: noae above a concentration oi about 3 =5 per cbn ir. air. Newport plant report Tor December 1551 records bums by hot Arcelor -- a case cC a splash into a nan's eye -- without serious parage. Packages of Aroclcrs leaving the Kmmrich plur.t bear a label cal icsslbIs toxic efTeots HARTOLDMONOQ17982 r KXZX322, ccr.td. [atards a. s har.ilad ac if fi riddle oT the opera: gac flare a are freely color., dared Apr 2S, ig-a, caiia c.hcverc, fire e alas'. .cr.e 3S -4 A #4 or U-j< e: Flanged Jcir.ta or. Arcelor hsatlas ayater :e a :cur;* he r.otfic cr. sackstc, pas: Seeder. XII, tele*. t r la phosgene ray Pe gsr.e fe--.arc containing A r rick. al fla ar.d fire Safe tv Icuitr.er.t T--a= .. w r5--rcm--rii.--.-- --4 ---- -..C T------------- --- w A, ._-_---,-.--i ~ - r- --- -- ri . ^" - .'.-*-----W- 4_---a---s -: rut Per covered sieve c, car. vac slovea, rotter choec ar.d lure recplra: See alco pass XI-1. A spare cult of clotr.es Is kept ir. a ease ir. :: r4iaparidtjfcnp.^taa>cd^-ars-ua-i >rdrre - ala -ea::.-ar,'-rirhi. (ehiorir.e), fire sktlr.5uic.hfir, (toluer.e, dip.hfir.yl), stre::r.ar, said aho-erc, drinking rour.talr., eye Path. Special Hicks ' The usual oars 1c necessary Ir. deall.as vi:r. chlorir.fi. Ir. Lighting the gas furnaces, ar.d ir. har.dll.hs hot raterlalc, star lires e:e. Q4 * C ^ "*4 * * V** --M 4 at ^^ ^* "4 1" --X-- chlorl.hator were Padly cut cf lire. A Davie "Vapctester", .tod el K-i,, Type A, (Ilviclor. cf Da vie r-rgerc: ipuipre.no Co., Ire., Newark. N.J.) 1c held ir tre departrer: Tor uce Ir. tectlrs the air of the working Pulldlrs after tpluer.e ha: Peer, C uced, ar.d for tee ting vecceic before rer. are pe--_i:tsd to er.ter. art Pelt re "flare certificates' are giver.. The ir.et rarer.: :or.:drc a HARTOLDMON0017983 XT. SAZASDS, ccntd. Special Elsies, ccntd. catalytic call electrically ha a tad to a temperature, and t.te air to be tested Is aspirated thrcugh it by means cl i "squeeze ball'*. II* combustible vapours are* present, the tempera rare or' call rises, and the indicating thermocouple registers cr. a sa.li brsted scale. The instrument has a zero adjustment, and it is ch as iced tvice a month by the instrument department. ?1ana certidicates must giv the number of the Vapctester used, also the data of its last call bratisn by the instrument department. The instrument has beer. *-*n dul in detecting gas escapes, and in tracing spills cd gasoline, etc., drum a neighbouring oil refinery ir.tc a public sever vnicr. runs under Monsanto territcry. Mr. Sen!gnus, cd St. Louis, September 1533, discussed the dangers of using Arcclors in indoor paints. He discounted the assible dangers drmn phcsger.e domed by Slash discharges m rsr.sdormers charged with Arcclcrs. See the rederences to sade handling cd glycidyl phenyl ether or. pages IX-li etc. . *> n. i* HARTOLDMON0017984 2CC: ?. <3. asnonja D. A. CLSOH July 3, 1^0 Xr\ t. 3. Jankin* Via# tmldeai, Material* Sprcgu* Hootria Caapasy Hortf JLdscs, ysunhuserta 0X1*7 C**X Mr. #<nkla*J - 2 mu rcrtan*tl7 able to Tlait jour 2roa St. Plant on June 17 *lth Pondall drshaa. I personally round the dUcsssica inTomatlYe tod latsrutlcg end 2 **-* cost raTorably impressed xtth the ecucam end interest caressed by ycur nuagntat pernennel. Ve discussed br*ri7 soa* or the peinta raised la ycur letter dated June 3d. Z *411 try la this latter to be sore specific. Blodeirjrad&Bility - Biodegradation atudlaa conducted in our rtsaarw atoratorl#* la St. Louis, Missouri In rtuaficn, Yale* using aadla consisting or local rlrur xatars or activated sXudst* acclina.td to bipbeeyi give direct evidence that the loser chlorinated bipheop trt affected. There Is teas eridenae diet chlerisa petition ca the biphenyl configuration doos influence the degree of distraction Vy the eiaroercanisaa. X hare enclosed 4 tabulation frea our luabca laboratory Ttfvlcd attaepta ta show this diffarace. Ye da apt har forasl Inromatica regarding the offset or etmlight or Other natural influences ca JLreclsrs. Ecporlaace nice over ani' jwn indicates Arcelor* or* highXy stable under all fcsovn conditio cut present la the anrlraaocat. Toxlol^ Thera is tspla eridene* ftraa easy laborstcri tint artaia sped** or birds aftiah or* at the top or the cartas food chain cannot reproduce properly %han JG'd in present la thoir diets, the 3. Pisherief laboratory at Oulfbraese, Florida conducted a study *&loh indicated that juvedlj browa shrlap did not cur-rive la *atr containing 5 parts per billion or FC3. Attached era copies of reports on these studies. HARTOLDMON0017985 -2- flcassnio eponaored tana atuiicd oo liharatcry nz* cad docs, 1 siscsiry of tha result* to data " U aStAChad. JPUpoaal - 2u prafcrrtd nathod for disposal la EgatjE^dratur* ir-cineratiers. 2 auxpaet than* ara acvoral ceerart ill human on the maricat mi di Kill parfnrn rail. 1 peracnaHy mtnaaaad hurting test* 4. th* Jcha flslc Coepany4* unit ia^ulna, Oc! abcca. yanparaturad oust rrraart 1500 7 to aeaur* that eccplato destruction is aohiarod. Lower tacpar- Atnrt* wull only vepcrlt* tho irodora cd mt4 ataeapharlo pollution or, writ yat, would ftn, by purtlxl oxidation, eatariilp could be highly ' tend (a-g. fonra and dlcxlsa). btlih ircinerttioa SCI io. ftrsed Wiich xuet ha aoruhbad fren tha itacit Cti and ttautmlLsad bafar* diopoaal. 'da art planning for ta Initial installation la ana of our plants latar tila yaar la a aarric* to our puatooars who ' nay act bera anact* to other incinerator*, a hate offered to accept icnp lroclor far iaaediata itoraga and arofitual incineration. Taatatiraly, JSntaanio mil charge 2# per pound of ratumad eatasial. Shia chanyt doea not inoXurfa freight or container cotta and mil ha rrriavad man final incineration cotta ara aatabllabad. Material which la returned for diapoaol should ha addraaaed to Monsanto Coapary, V, 0 Erasstrich flint, Canget, Uliscil, Attentioni Caparrianr Departnant 245. . Solids oonianiaated mth Arcelor* pre*ant 4 biggar challenge. la yrt, ** hare not tested art incinerator rnth these aatariala- thtll *a gat cor* inforaatioa tha hat wa can adviaa la aefa hurls 1 In sa authorised, properly Operated land fill locected 4May fh any " Va harra laboratory ric updariay oo other force ef daatmatloo. la yrfc ao eocnooically fusible ifpreach 2ua >ao fuaud. Iralytinal rtethoAologr - I hare attached copies of fleneanto's anaiycacau. procedures far tha dotardutlnn of ?C3* in mter, soil, air and biological uuple*. Va ar* interested la oo>jperiug etxr uethods with those dewised by other isborotorie*. Any eserwnts year laboratory 0*7 harra would be *alcoo and appreciated. r : t* CC^C J HARTOLDMON0017986 3- Z bo?4 that th* there lrtfarsaticn Li u&tfzl ta jcu. Z? X.aaa b of rurtbcr rrU, plaa let u 1cum, HaofcrtXy, **i Xr 8. Stria 2L*Cr2L* 1* Ontfuai &xT7QttMstaZ Caofcrsl HARTOLDMON0017987 1... *- c l I- c CO l I( c l _ ) : ATv 'T ^ ir.:? _j :(. t /A> Huh .4 4 ia *--- . *! ^--' -_1". D. ft, 75. H. r.zr. 1*0 j tT-** o1 cr* . 01tan Kour.ta Davis Johnson tlf-II J DCi-50 ft-'.! 'J11 RJ3AYT vjcm; Bill, vcu ranted to heccaa none fmiliar with tha ls;sl-?ciittcil prablcos facing Arcclcr rith regard co pollution and the accusations in the literature that chlarinatod biphanyit are prison ing me fcililns wildlife. . The so vildlift people have to ba calc on seriously. The*/ have taker. the D.vT industry to court ir Vis- cor.sin to prevent the use and sale of DZT ir. Wisconsin md IT the/ vir in that state, DLT vill "bo banned in nary others, -This cast ras cr. national Television last vsed. The vilclifc people art dedicatee ta ths ccnis-c of DTT. ' Oar praties: is that. Arcelor has hc-sn "idartif: ed"' alert with TUT residues and. fconoc va arc alttast certain cf hein-; cram into the court records and cay also be cr.e`o* the scapegoats or the DID defense. The vilclife people havt accused Arcelor of doing til the bad thing's or DL7. * '.* \\s are taking 3 steps ta protect curtelvcr. Scott Tucker and a. Seller are ta repeat sane of the 'analytical identification 'earn fcoding Aroclcr ta C ! C* <}Cai M ^ A* w ^ --J v as "shots:" by she literature. X hope we have teen falsely accused out nayha Areolar is consent. E-i-fheeler is bavin* feeding tests dare on an,Inals . to establish a "safe3 level for Artclor feeding. If we can find a safe" level Cilantro.' s Lab vill . do 2 year erperinsnts on anir.als including effects ' on succeeding generations. This vill help a bit but the wildlife people vcr.'t be stopped by this hind of evidence.' ' - HARTOLDMON0017988 1. .0 i- Tlvi th< rd .'ter I.-. to ainlui'/.o copeturn o Arcelor to refute air* cater pollution, tn res riot. Arcelor to use ich ezn be controlled, This is the only uay I SO' to survive. I believe m should sake su-c that our plants have rsiniuua air or strean pollution. 2 believe Ami:ten Is vulnerable end that" ofr-yns HC1 end Arcelor should be lSCv controlled. Ervensrieh may also need help. .* ' X believe ue should dmonscrate that Arcelor can be incinerated to hamless products Tor disco eel. . X believe re should help our custeexers dispose of ofr-prade or acn-reroricable Arcclcr, cither by in cinerating or by tonic du=p. ` I believe plasticinsr creu >;here their oredust is ci cite e:rpesure`rich if Ares fled as a pollutant. We prebably have 6 norths to 1 year chile t: rifjht out the DXT csss. I cant to use this to aininise cur enpomrs. Ve vill need, you in TED Carnets. .. %* S3 ZJ * HARTOLDMON0017989 )(s * ) Robert L. Me tea If from the background data presented it appears that something of tho order of 30 million pounds of polychlor biphenyls (PC3) are produced annually. These products conuin from 3 to 9 chlorine a tons p. aolecuia and bocomo increasingly inert and stable to environmental oxidation with higher degree of chlorination. However, about half the production is in the 3-chlorine atom variety (Arociar-.12ii2),, At first thought it seams unlikely because of the major uses of PC3 in capacitors, transformer oils, heat transfer fluids in closed systemi, that these materials could be the source of the substantial degree of environmental contamination reported. However, about LO million pounds annually is stated to be used as planticiiers, hydraulic fluid, adhesives, and in carbon paper. From this amount a very substantial percentage must escape into the environment as waste. Because of the apparent high stability of PC3, amounts entering the environment would 'be degraded very slowly and it seams possible that at least lOeillion pounds annually may become environmental contaminants. Since the PCS's vers introduced commercially in 1929 there have been 1*0 .years of production. If this has averaged $0 million pounds par year, then about 2 x lfl^ pounds have been Q made and perhaps 2 x 10 pounds have entered the environment* Because of " the apparent stability of thsse compounds most of this asrount may still be circulating in the global ecosystem and this is suggested by the levels reported by Holmos at al. (1967) and Risebrough t al. (1965) in animal tissues which are quite comparable to those found for DDT. Both PCS NfcV Q471S4 .< * 740437 HARTOLDMONO017990 u .) * and DDI are extremely stable and water insoluble ana have bean produced in roughly the same total amounts over the past 30 years. lhus it seems quite reasonable to conclude that the anvironrisntal contamination described Tar PCS is due to waste amounts of these compounds, ihis, coupled with the thorough evidence from mass spectonetry strongly sugg that there is an Important environmental quellty problem involved In wastes of PCS. ixperimnntal Work Planned at Industrial 3iatssi,-- This laboratory is highly experienced and seem- -'iite competent to provide standard data required by FCA for evaluating the safety (or hazard) of agricultural or industrial chemicals, fhe long term feeding studies on rats and dogs will doubtless serve to indicate the chronic toxicity hazards of chronic ingestion of the PCS at ppn levels and this vili almost certainly result in severe liver damage at some reasonable level. Tho chicken reproduction investigations at 0-01, 1, 10, and ICO I ppm should be considerably more meaningful particularly in regard to studies of egg hatchability, shall thickness, otc. While tha fish toxLcity investigations will bo interesting, I cannot s that they are particul--ly relevant or necossary at this and I would think this data could bo obtained from Pish and Wildlife investigations, etc., and will undoubtedly be forthcoming, unsolicited. Conclusions %Q.d guggestloqs..^ ' It aeaa to the writer that the evidence regarding FC3 effects on environnental quality is sufficiently substantial, widespread, and alarming to require immediate corrective action on tha part of Konsanto. The defensive measures presently Indervay will do little if anything to NV 0471S3 740438 HARTOLDMON0017991 rofuta the evidence already presented. I would surest the following: 1.. A substantial analytical program to monitor air and water effluents from Monsanto plants producing PC3 ana also those of major customers. 2. Prompt correction of effluent conditions where PC3 can be demonstrated.. . , 3. Sorious consideration of curtailing sales of PCS for uses such as plasticizers, adhesives, and carbon paper where waste is certain to enter environment. b. Review of dispoaal and recovery methods for PCS in capacitors, trans&armers, heat transfer fluids, and hydraulic fluids. Emphasize to customers importance of preventing environmental contamination, 5,. Thorough investigation of environmental fates of various PCS* s including photochemical oxidations, chlorination in water systems, ate. ' 6, Biochemical and electron microscopic study of levels of PCB ingestion which cause proliferation of endoplasmic reticulum and induction of multifunction asddasos in chichens and rats (perhaps those are partially included in present Industrial Biotest experiment*). 7. Begin investigations of possible biodegradable substitutes for PCB*s as plasticizers, adhesikes, fire resistant tydraulic fluids, etc., anticipating loss of these markets as a nocosaary corollary of environmental problem*.. Are, fer example, chlorinated diphonyl oxide* or diphenyl sulfides suitable for these uses. They should be considerably more biodegradable. n V 0 27U1* I 740439 HARTOLDMONO017992 PCS ENVIRONMENTAL POLLUTION ABATEMENT PLAN Introduction On 15 October the "AD HOC" Committee consisting of* Messrs. M. Parrar, P. Hodges, E. John, W. Richard, and E. Wheeler issued a report summarizing the polychlorinated biphenyl (PCS) pollution problems from the known available information to date. Out of this report came considerable information, conclusions, and recommendations which we have attempted to tie together into a plan of action in this document. Cur objective has been to take a reasonable and responsible approach to the entire problem. Before we get into the problem, we should'clarify the meaning of PCB, the nature of the entire line, and how these tie into our product line of Aroclors. HARTOLDMONOQ17993 Monsanto entered the Aroclcr market in 1930 by acquiring Suadkr. iSicssrlcal Comcany or known today as our Anniston, Alabama c^nThe first load of Aroclor which incidentally was Aroclor 1254 __ went out of Anniston, Alabama to G in 1931: Since that time the market has grown to 170 to 20CM4worldwide. Chemical Biphenyl Monsanto Product Line Nature of Material at Ambient Solid Moncchlorobipheny1 Cl "^ricKlorotfi phenyl - Quaterehlorobiphenyl Pentachlorobiphenyl Hexachloroblphenyl Chfll'r^l~C 1 c / 'c / Hep tachloro'bi phenyl P'-W ^ J- ef ^ O: 1 Octcnlorpblphepvl d-?' id Y- De cacnxord5ipheny1 f' .ft Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1250 Aroclor 1262 Aroclor 1263 Aroclor 127L5 thin liquid (oil) thin flush water oily type fluid material Thicker - transmisstc oil Heavy-Molasses Thick - tar Very thick - liquid Solid Solid G21t37 HARTOLDMON0017994 -3Total possibility are 210 theoretically possible chlorinated biohsr.v1 i' Santowax or terphenyl Solid Aroclor Solid A, *Y/Jr '/// Damage to the ecological system by contamination f; om pciycn^crinaced biphenyl (PCB). III. Extensiveness The problem involves the entire United States, Canada, and sections c; JlP L Surcpe especially the United Kingdom and Sweden. As the lnvestigaric: broader.- other areas of Europe, Asia and Latin America will surely became involved. Evidence of contamination have been shown i$ some of the very remote parts of the world. The involvement could ar.d ncs: likely will follow the DOT investigations. IV. Nature of the Problem Professors Widmark and Jensen of the Institute of Analytical Chemistry at Stockholm, Sweden, in November i960, announced and confirmed findir. PCB in fish, birds, and eggs. Subsequent findings were made in 1967 1 Great Britain. In February 1969* Professor Risebrough of the U.niversi * of California published an article in the San Francisco Chronicle relaying his findings of PCB In the environment of the United States. Monsanto confirmed the presence of PCB's in mld-1969 and confirmed the adequacy of -work by Widmark arc. Jensen and others; truly, the PCB's are a worldwide ecolological problem. N v *? j a HARTOLDMONO017995 4 Analysl3 indicates the environmental presence of the 5 and higher chlorinated biphenyls which take the appearance of Arcelor 1254 ar.c Aroclor 1260. We have strong indications that Aroclor 1242 or at ' part of it degrades biologically. Since the Aroclor 1242 contains < 7 percent of the 5 chlorine biphenyl or higher we cannot rule out r.v posslbility that the observations tiny be a concentration affect of t higher chlorinated biphenyls of Aroclor 1242. Luc. COH'&r** To date trio-iv? have beerrno^reports of finding Aroclor 1242 present i.- the environment (except oufca'jfa# the effluent of our plants Artalijr `10 Lahore sea4r4m <</ h* belt*) our Z fKt+Ti & 5^4- he seriousness of the problem can best be spelled out as follows: 1. Pish - Marine or aquatic species concentrate PC3 in the fatty tissue. Toxic is small quantities (down to 5 ppir) to sensitive na life such as shrimp. 2. Birds - Predatory species feeding on the marine or aquatic life ca further concentrate PCB to possible harmful effects. Specifics::-/ in birds PCB can affect the calcium metabolism leading to egg she! imperfections which prevents proper hatch of the young. In face, Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCB's in controlled tests. 3. Man - There is no harmful effect known to man or other mammals aft 40 years of production. Investigations are underway by various sources. 4. Political and Public Dmction - PCB'3 are falsely linked with DDT because PCB's shew up in the analysis for DDT. PCB's are linked w other permanent type chlorinated hydrocarbon pesticides. This becomes particularly serious since about every article of food in country is being examined for a trace of these materials. rUo Q '**/. s 57) : ^J /*. f - " r^rr- - HARTOLDMONO017996 N tV Q <!l<t}9 5 V. Effact: on Monsanto Business potential at stake cn a worldwide basis; Fluids Plasticizers Total/Year 7CM lbs. $16M o.P 3W lbs. $6M $2-3M q.p 10-^Ff lbs. $22fl $8-11*7 G.P. Already competition is using certain data against us in ccmperit" /= situations. A. Legal Liability Direct lawsuits are possible. The materials are already trese^c nature having done their "alleged damage". All customers us ins: ch.- products have not beat ofricially notiried about known effects -or our labels carry this information. These are only a few of the possible legal implications which would best be covered by the legal department. B. Public Image _ The corporate image of Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environ ment will be adversely affected with Increased publicity. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond questioning. This combined with certain scare publications is cert; to give an adverse image. Guilty 'association (with DDT) will pre vail as the background while actual facts may be sparse. ' C. Customer Relations Nv 021If,a Some customers who presently use these materials will be "scared zd to other competitive products. Products associated with the same name or "trademark:" will be adversely affected ie., Thermir.cl, HARTOLDMONO017997 o influence on Monsanto products. Customers will seek other "out3" rather than become Involved. VI. Effect on Customers and Ultimate Consumers One of the unique features of PCB's is their fire resistance. - basic decision whether to risk lives due to fire or risk extinction - soma apeciea of birds. In this case the PCB would probably be acce-- aa a necessary pollutant and tolerated under controller conditions A. Electrical Industry - Capacitors and Transformers use Arcelor because it is the best inexpensive dielectric fluid available. 3. Pood Processing - Bulk "deep frying" units for potato chips, fish, and doughnuts use the fire resistance fluid as an indirect heatirr medium. C. Die Caster -- and other hot metal working industries fire resistan: fluids to protect the workers Affects a wide range of plastics and adhesives because the PCB serves as the plasticizer. A wide range of paints and coatings are affected. The "Carbonless" carbon paper used so widely would disappear. VII. Involvement With Other Producers H- Although Mpnaanto is most probably responsible for the U.S. contain and Jointly responsible with MCL for the United Kingdom problem, we cannot accept responsibility for the world. There are five known producers in the free world, several possible producers behind the ircr curtain and couple of additional companies making overtures about entering the business. Monsanto reDresentatives have cn one occasion discussed this problem with a couple of these producers but they expressed no great concern. In fact, it i3 highly possible that one =f ney J-dlY-tL HARTOLDMONOQ17998 t these manufacturers is dumping his waste into the Rhine River. cs' any action taken by one producer will most assuredly affect the ___ It is entirely possible that a Joint plan of action could be develc but will most probably have to be spearheaded by Monsanto. It is 3 likely that producers of other chlorinated products used with PCB's will be dragged into the investigation. VIII. Sources of Contamination Although there may be some soil and air contamination involved, by f = the most critical problem at present is water contamination. To ou- knowledge to date the contamination can be broken down into two gene- categories, open and indirect pollution. A. Open Pollution - Cur manufacturing facilities sewered a sioeable quantity of PCB's in a years time. . 1. Fluids Fluids are probably the most open source of pollution because their mobility. They also may be the least serious because ch are generally the lower chlorinated materials. 2. Electrical Electrical customers have in the past sewered their wastes, 3. Heat Transfer Heat transfer customers have sewered their objectionable and their spilled material. " 4. Industrial These fluids have generally been sprayed into drains, washed down sewers and generally regarded as very harmless. it')' All of the fluids have had the "'eirrk1 constituent dumoed on dirt reads T a "dedusting agent" which inadvertently found it3 way back to the stream. Nv 729497 HARTOLDMON0017999 -8 - 5. Plastics . The plastics are not a3 mobile as the fluids so therefore -- have not found and cannot find their way back to streams - pollution. B. Indirect Shipping containers and the cleaning thereof for subsequent source of contamination^ = 1. Fluids a. Slectrical - Disposal of "burned out" transformer and capacitors may find its way back to streams. Scrap unite (new) are generally disposed of in land fills but could possibly get back to the stream. b. Heat Transfer - Leaks could contaminate. c. Industrial - Cross product contamination carried out cf an air compressor. Residual material carried on parts. 2. Plasticizers a. Process Contamination from Washing - (1.) Environment Contamination Swimming pool paints Incineration of wax coatings . Traffic paints (2.) Product Contamination Coating for tank lining ia^nttng inks and paper coatings Nv 02 ^ 3 Certain adhesives IX. Recent Technical Changes Which Have 3earing on the Contamination A. Fluids '_ The sources of pollution were pointed out as they have beer. ir, the past because we are dealing with that quantity of material in :r.e # HARTOLDMONO018000 -9- environment today which was deposited over the past forty years, w jsu^must state that responsible people throughout the industry have ta:< corrective act's.on to reduce contamination in the last two years. Ths have also been technical advances which have brought about the use : lower chlorinated biphenyls which may be an advantage because to dat low chlorinated ones have not been identified present in nature. 1. Slectrical - The large customers have established collect system, the waste is recovered. Incinerators are being investigated and built for the disposal of the materials. There has been a shift away from the higher chlorinated types products and could prcbabl' shift almost entirely away from those products. 2. Heat Transfer - System have been tightened up and redesigned to confine the contents Here^to^1 the trend has been to shift away from the higher chlorinated materials. 3. Industrial ponds have been built by the large manufac to catch the material and decant off the PC3 for reprocessing. Th trend here as the other fluid areas has been towards the lower chlorinated materials. 4. Plants - The plants effluent has been passed through limestone whl provides surface to catch some of the material. But high concen trations can be found in our effluent (that is relative to those findings in nature causing the problem). " B. Plasticizer > Quite opposite to fluids the trend in plasticizer Aroclor has been to higher chlorinated biphenyls. In plasticizers the lower chlorinated biphenyl will not be an acceptable solution however, the lower chlorir terphenyl:couId offer a possible solution. NV 02 i HARTOLDMONO018001 10 X. Courses of Action A. Do Nothing We cannot deny the findings and the acquisitions by the various agencies. If we took no action we would likely face numerous so We would let government tolerances be based on public and political pressure along with any experimental or developed data which they may generate. We would most likely be forced out of this business. Other product areas would be adversely affected-r We would project an image as an irresponsible member of the busin* world. Project poor customer relations. The only advantage to tu technique offers is it reduces the cost but this too must be weighed against potential loss of business. B. Discontinue Manufacture of All Polychlorinated Biphenyls (PC3) Although we all realize this could be an eventually unfortunately che solution is not this simple-f' Assuming we did stop manufacture immediately, the pollutants are present in the environment, the liability is present and possibly by the shifting to the lower chlorinated materials and the recovery techniques the contamination may already be reduced to an acceptable level. Obviously the entire business would be lost without any or very few substitutes to be offered. Other product areas would be affected. Financial loss could be considered due to raw material contracts, customer ccntrac and royalty -- secrecy contracts. Competition would take advantage on all fronts. We would be admitting guilt by our actions. Loss of capitol Investment in the plant, associated utilities, and asse- ciated processes. t..hi,s ac,t,ion. We would possibly gain a little public image cn NEV 021V45 C. Respond responsibly, admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. HARTOLDMONO018002 11 This approach would enable us to phase out the higher chlorine.materials in many applications where they are no longer necessaor really desired. Wecoul'd maximize the corporate image by publicizing this act. We would reduce a known pollutant. Additionally we could gain precious time needed to develop new products and investigate further the lower chlorinated materials. As new research data is generated our course may be altered considerably. Certain limited actions may reduce or limit the problem. nEv o2I o HARTOLDMON0018003 12 XI. Recommended Course of Action Baaed .on the information available today the only recommendation we I honestly make is respond responsibly admitting that there is growlr evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. XII. Implementation of the Recommended Course of Action A. Immediate (By 12-1-69} 1. Set up a task force under a project manager or the equivalent responsible for Initiating, directing and Implementing all act that Monsanto decides to take. This includes sufficient budge necessary to cope with the Immediate problems. This task fore; should include representatives from Medical, Legal, Research and the two involved Marketing Groups and Public Relations and must conduct liaison with MCL and other locations Involved in the problem. 2, Decide on timing and content of any public, and/or customer not! cation of PC3 problem. B. Interim (Within 3 months) Fluids Plasticizers 1. Confirm Aroclor 1254/Aroclor 1260 are found in the envi ronment. 1. Announce differential betwee fluids/plasticizer uses. 2. Publicize the difficult anal. 2. Announce safety of other PCB tasks. chlorinated terphe.nyi. . 3. Protect other PC3/chl. terph. 3. Educate customers on control effluent for all products. 4. Announce plans to reformulate 4. Initiate program to develop certain Thermlnola and Pydraul where control of the product 1254 & 1260 substitutes is difficult. NEV HARTOLDMON0018004 13 5. Emphasize better control over 5. Investigate with manuka- other Aroclor 1254 & 1260 the feasibility of alta~ uses. products. ' 6. Initiate customer education or need for effluent control of all products. Analyze--1242 7. Determine composition of all PCS'a. Develop a comprehensive Program C Short Term (within the next 12 months) 1. Research - Expand program for more meaningful biodegradation Medical 8tudies and confirming analytical results. Expand toxicity studies. Follow developments concerning publicity and those developments covering politics implications of PCS contamination. 2 Marketing ~ Discontinue or substitute replacement products for those applications of Aroclors 1254 and 1260 where'the Arcelor remains mobile. Work with customers to clean up plants on other Aroclors, Report the habitual violators or "do nothings" to the product group. Reclaim or safely dispose of fluids.- key 021^3 Consider renaming products that do not contain PC3. Follow ar report market developments such as customer disposal systems. Follow and report any political or public feedback which may affect the contamination problems and must be coordinated with Medical, Research and Legal. 3. Production - Clean up plants and stop gross contamination. 4. Legal - Define our present position, recommend reasonable acti that will not unduely alarm the market but reduce the exposure in terms of liabilitv. rec cmmer.dati cr.s with ct. HARTOLDMONO018005 14 - 5. Public Relations - Publicize actions where believed advancac Certainly discussions should be held with other producers v same period to determine their planned course of action, = D. Long Range Tentative Cut line (From 1 year to 3 years) Realizing that the comprehensive program must be outlined the "Lc Range Tentative Cutline" is meant to serve as a guide: All aspec ts rl of this program should review quarterly by Organic Management. 1. Research-Medical Continue biodegradation studies and analytical support Isomer distribution Toxicity and metabolism studies Water soluble removal Incineration analytical support Confirmation analytical Contract academic research for reference Develop new-and improved formulations 2. Manufacturing a. Process Research and Development ' (1.) Identification of typical Aroclor isomers (2.) Develop control for effluent composition (3-) Test substitute formulations, etc. (4.) Develop new processes b. Clean Up Plants c. Modify processes to meet market needs . 3. Engineering a. Develop and set up on plant locations incineration systems b. Design new processing equipment as necessary 4. Marketing a. Specify alternates or changes nev 021999 b. Customer liaison HARTOLDMON0018006 I - 15 - I c. Set reclaim or disposal of fluids . d. Work on name association problems 5. Patent' Investigate trademarks registered Cover with patents any work felt patentable 6. Environmental Control Develop cheap disposal systems for customers a. Incineration or pyrolysis b. Biodegradation unit etc. c. Consultants in pollution control 7. Legal Investigate and define our position on Royalty secrecy agreements. Contracts - Raw Material and Customer 8. public Relations Portray to public positive actions at correcting the contamination problem. Release periodical statements covering our position. XIII. Probability of Success . 021^^0 HARTOLDMON0018007 16 XIV. Cost of Program - Neither the program nor the "costs have been clearly defined at t.V = However, a cost estimate of $220,000 for toxicological, work alone - been presented. Tentative figures Indicated under the worst ocndi;- the entire program -could run as high as $2.0-2.577. At this stage it very difficult If not impossible to develop a reasonable cost figure one point is clear it will be larger than the normal research budget handle. For this reason, assuming the approach is acceptable, we aha be forced to ask for additional appropriations to fund the program. XV. Future Follow developments on the problem as they unfold. Develop an aggressive research program to confirm or deny findings ant better understand the problem. Develop costa for the duplementation of the Recommended course of action. Develop specific actions with each department involved Submit the actions with costs for approval Develop a timetable to solve the overall problem. Prepare for "preclpltious pullout" or drastic legislative action aithc we do not feel this is a likely possibility. Nt'V QZL^1 HARTOLDMONO018008 I g ACTION DO NOTHING DOLLARS PROFIT AND LIABILITY VS. TIME DISCONTINUE MANUFACTURE OF PCB DOLLARS RESPONSIBLE TTFPFTOTlCT----- DOLLARS 7o --i------------71 72 73 Time NV 02i*t52 729507 70 71 Time 72 75 HARTOLDMONOOI8009 PROPITS $ PROBABILITY OP SUCCESS 70 T1 72 Time 73 7^ NEV 021433 'Q = a HARTOLDMON0018010 fRat it am Llfi&UTY \ix Tim r flCT/QH HARTOLDMON0018011 pfto&d&iLirr of so cc ss. i NV 021^55 729510 HARTOLDMON0018012 XIII. . Probability of Success XIV. Cost of Program ^220,000 and bio with max. at $2J0-25M XV. Future NEV 021456 729511 HARTOLDMONOOI8013 State of Alabama Department of Public Health Donald E. Williamson. M.D. * Scats Health Okeicer March 8. 1996 Dear Rev. Weatherly: In-house dust samples collected in November 1995 have been analyzed Weston. Inc. analyzed them under contract with the U.S. Environmental Protection Agency (EPA). The amounts of polychlorinated biphenyls (PC3s) :r. dust at vour address are listed beiow in parts per million (ppm). Location PCB Level ppm Floor at main entrance Floor at entrance by office Floor at entrance at fellowship hall 1.80 ppm 3.84 ppm 4.42 ppm EPA lists the level of concern for PCBs in dust as 1.0 ppm. Your dust PCB level is above the level of concern. ' We know that you may be exposed to PCBs by accidentally swallowing contaminated soil and dust. Contaminated in-door dust can add to your total exposure. Exposure levels depend on amount and time of contact with contamination. That is. contact with more of the PCBs for a longer time cause; higher levels of PCBs in blood. Since the meeting on January 23. 1996. we have been working with other agencies to solve the problem of PCB contamination in Anniston. Decisions about clean up and testing other neighborhoods are being made this week. We will provide a report of the exposure investigation to everyone bn the mailing list. If you have questions, call us at 1-800-338-8374. Sincereiv. Neil Daniell Geologist Division of Epidemiology HARTOLDMON0018014 VsVV attachment II HARTOLDMONOOI8015 AITACBMENT II HARTOLDMONOOI8OI6 Tha Anniaeon Plant plana for poly-chlorlnae*d blphanyl (PCI) datamlnac loo* ta liquid vaata atraaa* including aourcaa,quancieiaa and rtcoaaandtd action* ara Included. Va do aoc plan Co look for aeaoapharic loaaaa baaad on our prtaaac utual foaling that loaaaa co Cha aonoaphara ara nagltgibla. Tha targat daCaa ara baaad on 1) on* aan full cisa (I.G.Wright) aaaplina, correlating and reporting thaaa and ocbar atudiaa; 2) ona ehaaiat for ona to Cvo aoncha and aufflclanC analyat t1m thereafter; 3) Chat adequate aacboda ara developed and reduced Co plane praetica la CIm; 4) that adequate inatruaanca and inaeruMnC el*a ara available. Itaaa cvo through four require r huffling of Cha Anniaeon Laboratory plana and will ba dlacuaaad with W. a. Kuhn and J. I. SaiCh (alnea lev color Aroelor 5460 aaaple praparaclon la affected). Alio,although electron capeura equipeanc axiaea ac Anniaeon 1C la noc preaancly aat up and oparaeiog, Thla will make Mating your propoaad (chadula of balng raady Co run PCI aoalyaaa by tha Tucker MChod by Juna 2 unlikely. Propoaad Plan 1. Obtain groaa aaaeplea of Snow Croak for viaual cbacka Ca datar*la* praaanca of dlaeraea, noa-aqueoua liquid phaaa In pool* or othar atraaa bottom araaa. Completion datarainad vhen dovnatraaa Halt of dlaeraea, noo-aquaou* liquid pbasa baa boon aat.ibl lakad. Start 5/1/69 Coa^lata By 7/1/69 2. Obtain and anai/aa for PCI, laaplia of aud and vatar fro* Snow Croak at Cvo polata down atraaa of llaie aacabllahad In (1). Oita of cha aaapllng palnta will ba ae tha aoueh of Snov Croak. Tvo aata of aaaplaa takan tvo vaaka apart will ba uaad. (local ^ of I am^laa) Target Coaptation 3/1.c? MQNS C97294 HARTOLDMON0018017 -2 Proponed Plan (Coot`4) J. Obtain no (capita of aud and water froa Choeeolocco Creek - oao near Snow Crank confluence and aacond 8-10 ilaa down (tree* soar Jackaoa Shoal a. 3a< frequency aa (2) abown (Total of S aaxplac). Tarjac Cowpi,: 4. Further action on nud and water inaplaa will bn daetdad altar reeulta of 1 thru } art in. Daclaion Tarj. 3. Complete tha in'?lane (array now underway to identify and quantify aoureaa of PCI to tha aowor. a) Identify all departmenta ueiliiinj or precaaainc Aroclora. b) Audit Aroclor and 3C1 department! (prerloualy idantlflad aa aejor aoureaa) to dacaralno aourea and aoounc of PCS loan c) lacoaaeend oaana of reeowarinj, elinlnatinc, or raducinc loaaaa tram aoureaa idantlflad in (b). d) Da lion rt^ulraoonta and roucJt coat to aaaura auraalraa that loan af Aroclor Co Snow Crank (Solid and Liquid Aroclora) la Halted to aolufaility loaaaa. Collated 4/13/; Tarjat Canplatlo Tarjac Cowplacic: Tarjac Cowplac1c Satabllah contlnulac oonltorinc eyataaaa: a) Tor loaa of Liquid (ot Solid)Aroclor to Snow Crank (hopefully aaro). Tarjat 6/1/70 b) Tar weakly or monthly PCS on our tfflaaat to Saow Craak (tolubllitr loaaaa). Define Xeada 9/1. ) tatahlleh water eaanplin* at at loo an Choccalacco Craak to nooltor PCS and Parathloo. In Oparation 6/ 1. 7. lawaatlgata onana of diaposal of Aroclor (crap. Thla woold noad to ba a cooperative raatura bet ween leanerch, Harkatiaj, UCZ, AaalaCoa ad CIS tinea tha problaw la noc unipan to a a Incla Hootanto location and la facinc oar cuatoowra too. Scbadula for 1970. MCNS 097295 HARTOLDMONOOI8018 -3* That complaeaa tha propoaad plan. Thar* ara a faw ochar point* I'd to aaoeloa though. 1. Tha Anni*ton Plane la proeaading with projact* to raduc* tha Aroc lor la raeowarad MCI - iom at which la aawarad. a) Tha caceh-tank la tha MCI aft-gas llaa ha* baan successfully acartad up and la eoLlsctlng iom material. b) A mambrana eypa eoalaaear ia to ba inatall.d la May to raaov* organic* from the absorbed MCI. Aroclor from chaaa two aoureaa will ba buriad la eha toxic dump. 2. Croaa sampling at Snow Craak atartad eha weak at 4/28/69. Snow Craak outfall has bsaa monitored for pg and T SCI for aawaral yaara. (Potassium and sareury analyses ara no longer run) .3 Praparaciooa ara wall underway to acart eha Aroclor/MCl daparcaaneal audita. Actual sampling should start wlchia a waak, if eha analyaaa can ba run. 4. Tha only dapartaanc* using or processing Aroclora at Annlatan ara: a) TgS. - a Thamlnol sy*tn. This la drained to drtaaa whan raplaeansnt of Tfcarminol la required. This has baan dona In this manner alnca startup. ' b) Aroclor Procaaaloc Two Tharmlnol systems floor cleanings Spills BC1 off-gas ' Ro significant amount la lost from tank car cleaning sine* any aacarlal (including haul*) la drained Into druse, cltanlng cloths ara put la Crash ceataioara. Both drums of liquid and raga ara sane to ehs dump. 5. Pra acat estimate of PCS analyst* time ladlcaca* 2 to 3 man-hours ara required par amspla. This may wall limit us to two to thras implii par day. 6. Frassnt guaaa on futura monitoring la Chat ve would need to add ona mas Ca tha laboratory staff and buy am Instrument (at abauc 110,000) to support adaquata program. 7. An audit of tha Perathion and P Department* will ba carriad out this simmer la addition to tha proposed program. This work la urgancly naadad to aatabllsh how cloa# w* ara now approaching tha ultimata capacity of tha biological trsatmanc plant and whathar or noc raductlon through an La-pl*nt control program la faaalbla, Answara ara required MQNS 097296 HARTOLDMON0018019 -Afotati (Cant'd) urgantly bacauaa thay dataralna cha coursa of action of cha aulfur raeovary ayataa propoaad for Psrachion aa vail aa cha ultlaata production capacity of cha Parathion Plant. Vhlla Parathion balonfj to Cha Ac OlTiaion Cha biological traataant plant balooga to tka Organic Dlvlalon. I hopa thla atMMry will aarva your praaanc aaada. Many chaoka for Cha auggaatlona la your A/2# nano. Aa you can aaa aaoy found chair way Into our prograa propoaal. V. T. Taffaa MQNS 097297 HARTOLDMON0018020 I Monsanto 4 to**..*-- ft, r. Poresman - Krummrich sl( September 23, 1970 tw <C t (((WCI TO : SAMPLING PROGRAM FOR AROCLOR LOSSES Memo-M. Pierle to W. tnjpnan 8/5/70 W. C. Engman M. J. Beaudine C. L. Bratsch C. F. Buckley 8P -# W. B. Corlew Hodges H. J. Horner Papageorge R. Savage J. Garret: CONFIDENTIAL The following air sampling program is an addition to the total Aroclor sampling program as established in a memo from M. Pierle'to V. Engman dated August 5, 1970. type Air . SOURCE Different locations within Department 2<*6 FREQUENCY 2 samples/week The air sampling program will be conducted for approxi mately two months with the results being distributed on a weekly basis. v ' M IV. C _ -\ "\ M. R. Foresman pd MONS osaz-'Q HARTOLDMONO018021 MotrsiStiyv- **"' * i**"*-* . o. Ramsey - Anniston Plant 0*M Septen^ser 4, 1970 'akjclor losses to the atmosphere AT THE HCl SCRUBBER JET < l TO : E. C. Wright <c J. T. Bell V. R. Haupt J. C. Landwehr operations iho that HCl gas not converted to Muriatic Acid is by-passee to the scrubbing jets and sewered. Based on acid produced, sold, and by-passed for the nwnths of April, May, and June, an average day resulted in 4 500 l/hr. of HCl off-gas. Calculations baaed on vapor pressures, the temperatures that the HCl comes in contact with, and the ppm of Arocior in acid - yields the following results: 0.6 2.1 Ib./Tir. or 14.4 lb./day of PCS in vapor form reaches lb. /hr. or50. S lb./day of PCB in acid produced thejets Total - 64.9 Lb./day of PCS passes the HCl knockout tank Assuming 100% contact st the jets, 0.47 lb./hr. or 11.8#/day of PC3 is severe; with the remaining 0.11 lb./hr. or 2.6 lb./day being lost to the atmosphere. Poor efficiency at the jets increases the loss of PCB to the acaosphere consIdarably. . LC,/^j----- f. D. Rasisey :kd Attachment OSH 014031 HARTOLDMON0018022 dm .................. /.z'tMit ~ tf/LL iW-feXs Okt &S ovex. ^k+y-- dfy&rj4gs &nszzZ (2/?. .............................. c ...... - (****( * te). aW&r. -45" (/lh`k) ^f^^ss^ue. O.CXZS '***. Jjf .. /. Th&xt- /?U, 2" . ' ^ fy~yz 7***** *r Zt-***^ tsUl 'Au. 3^0) Qoc jj l/C? &**! -n/s_ I __ - >+n.T/t J^5* l(so x i*A & J,eo,*c* x .24? oo "Kt- 0. 02 3 7**t i N til's 7)0* rX ' ' --" 1%3 Q5U 014032 (jzSO^i) * <^3 . ?/5r ^ O.OOZt -x^r ,&. O.ooZf 7x vfe . ! /h _ 7hfi4 ^/2zy . ... jfC'tl?* /A/ -^4S33 MCA 4i~l ($ ///iy ii \ it, its n nk. * / 4.*4* Vj. HARTOLDMONOOI8023 >Y -1 0./03 x .6 ** V. './*%L v. &/.$* x#j ,u & i ri OSW 01^033 HARTOLDMONO018024 jccr.n tb >ia. +. ^0 * /A. ^2-- f.2t-A/0 -r~*L^ ?*-->(rf,LeS) <W <&s sAtto* 4_ ~/#c ; ^ f <m/-4 ?A - X* ?r 3 s & ?r (5 - 2* ~V'f*i 7k*st4e ?e (nx, 4^.^ - 0.00015" ^ OOoiC Try*/?} , 9'S (/<?* /O r*-&L ifj yc. ........... _ *(1/ ^ 3" HARTOLDMONO018025 Monsanto ^ * dc St. Louis - General Offices August 7, 1570 ANNISTON - PCS - CLEANUP PROGRAM TO Mr. H. S. Bergen, Jr. - HBERG Jonr. Mason E. ?. Wheeler V, 2. Pacaggoraa r. J. Hoitupfel D. 3. Hoarser J. R. Savage C. L. Jessee J. C. Landvehr - wp a s a FHOLE DH0S.M - JSA7A Anniston Anniston CONFIDENTIAL - 7. T. I. AND DESTROY Following are tile moves underway resulting from the FDA findings of high levels of* PCS in fish taken from Choecoiocco Creek down stream from It's confluence with Snow Creek. waste streams show a total loss of only 2#/day. The discrepancy Is believed due to; (a) sampling problems In departmental waste streams where two-phase systems of water and free aroclors may be present, and (b) possible pickup of PCB by leaching previously deposited PCB from the llasetona neutralization pit which also acts as a settling basin. (2) Work to further reduce losses presently underway: ' a) Sump is being Installed at the aroclor department to cap ture free aroclors from the 275 SP Tlow. This is believed to be the largest departmental source of sewer loss because of the liquid aroolors frequently observed. However, sampling work did not confirm the belief because, no doubt, of Inherent sampling problems. Bie project waa due for completion on 9/1, and had been delayed because of an underground spring. b) Curbing is being installed at drum loading area with dry pick up of spilled aroclors planned. c) Investigation of treatment methods - adsorption by acti vated carbon showing most promise to data. (3) Joe Crockett, Secretary of the Alabama Water Improvement Commisaion, will try to handle the problem quietly without release of the Information w the public at this time. He believes that FDA will not precipitately in this matter (he did not advise how FVQA might react). Dr. Myers, Director of Public Health of Alabama, wants toxaifcy information on PCB's and this will be conveyed per sonally to him by Jack Qarrett next week. MQNS 033351 HARTOLDMONO018026 (3) Operator Education - All Anniston personnel have been read vised of the necessity to avoid sewering of any arcclor. (C) Mechanical Program (1) Departmental Sump - at extra cost of $2,000, work is proceeding on an overtime basis with completion expected 5/12/70. This will eliminate the possibility of large los ses from the operating area. (2) Loading Area - Vashup of spilled aroclor has been stopped and dry pick via sand instituted. Curbing project is being expedited. (3) Neutralization Pit Clean out (a) Immediately, the eettled material downstream of the lit*atone will be removed as well as possible by pumping, with minimum stirring of the water. The solids (and aroclors) will be landfilled. (b) By-Pass of Neutralization Pt. - On crash basis, trenches will be dug to allow diversion of all water from the limestone pit. This will take 1-2 weeks and will aost about $10,000. In addition, it will be necessary to provide caustic neutralization of the acid wastes. This will be handled in the aroclor department via installation of a pH con troller and valve with temporary piping and trucking facilities. Coat will be about $5,000 plus about $500 per day for caustic during the period when the alternate neutralization is required. During this period, PCS losses should be no more than 5-10 lbs./day. .de HONS 033352 HARTOLDMONO018027 H. S. 3ergen, Jr. August 7, 1570 Page 3 (c) Cleanout - The pit will be thoroughly cleaned out with probable removal of the present deteriorated asphalt membrane and replacement (possibly) by a plas tic membrane which can resist aroclore. The plant will consider possible structural changes to permit more affective operation and ability to make future cleanouts without the present by-pass steps. Recommendations reli ative to this will follow. (4) Vater Plow Reduction - Present total flow through pit is 700 gpm. ?or at least several of the streams, reduction of flow will result in immediate reduction of PCS to Snow Creek. More important, reduction of flow will minimize future treat ment coots. In conjunction with the pit by-pass work in 3(a) above, approx imately 200 gpm of aroclor free water will be permanently diver ted. Included in the first reduction are the chlorinator cool ing streams and moat of the water coming from the Jflran flare tower. Details of how this will be accomplished will be avail able by 8/14/70. Over the next 3 - 4 months, further water conservation projects will be installed with abjective of reducing the stream to the lowest practical amount, now estimated to be about 300 - 4co gpm. The projects will involve multiple use of water and fur ther diversions of aroclor - free water. (3) Final Treatment - Based on some indications ( and much hope), by September, the actions above may approach the present plant objective of 10 ppb of PCB's in 7w SP (or 0.1 #/day). The hope is raised because dissolved aroclor has shown a pronounced affinity for surface adsorption (as on walls of sample bottles). The solids generated by the limestone neutralization are believed to retain aroclor passing by them. Therefore, adequate settling and/or filtration following neutralization with periodic removal of the solids may accomplish the necessary treatment (along with water flow reduction). The plant will proceed on preliminary design of filtration facilities with and without carbon treatment between neutralization and filtration. The design will be avail able for action in case the reduction is not as great as hopedfor or in case the control agencies demand more complete removal (control agency requirements are a completely unknown factor at present). By the time a decision must be made relative to final treatment, we-should have better information on requirements and methods. "CHS 033353 HARTOLDMONO018028 H. S. Bergen, Jr. August J, 1970 Paga 4 ' (D)yiah, Mud and tfatar Sampling - Since our fish samples from nearby Choccoloceo Creak also showed high levels of PCS'a, we are institu ting more sampling to determine extant of the problem. Sarly during the week of 8/10, legal size fish will be caught in Choccolocco Cnee* near to confluence with the Coosa River (Logan Martin Lake). Pish will also be taken from the laka. If these seaplae show high (-*5. c ppm) levels of PCB, sampling will be extended to points down the Coos; River. A high priority will be given these samples by Scott Tucker. Progress reports will follow at suitable intervals. Paul 3. Hodges /np HOWS 033354 HARTOLDMONOOI8029 Monsanto f __ --< . c y. ".ill r - Anniston, Alabama I May 7, 1970 ec J. C. Landvehr I AROCLCR 2.CLLITTICN AWIC CONTACT Si. L. Williams ?. 3. Hodges - G.O. W. 3. Fapageorge - G.O. r. J. HoLrapfel - G.O. J. R. Savage -G.O. . 7. John - G.O. J. H. Crova - Decatur E. G. Wright PIAINTIFF^ eCHlBfT^, On May 6, Messers. J. C. Landuehr, . C. Weigh: *nd - visited Mr. J. L. Crocke-Technicai Director or the Alabama W*cer Improvement Commission, in Moncgcmerv. the purpose of che contact was twofold; firsc, :o familiarize Mr. Crocker; Che situation regarding Arocior wastes and cheir reported poLLucicn potential and, secondly, co build confidence chac Monsanco intends to cooperace vim governnencal agencies to define che effects of Arocior on the environment. Mr. Crockecc and che AVIC acaff were totally unaware of- the published tnforma tier, ccnceming ArocLors. Copies of che nose pertinent articles describing the situation along wich Mr. Minckler'a statements were provided for his use. Additional information supplied covered the following facts: l) Monsanto is currently inves c iga C iag independently and in cooperation with governmental agent . che potential ecological effects of Aroclors. 2) Investigation and research programs are underway at Anniston to id-encify, quantify and develop techniques which would control, product losses to che environment. 3) Any Aroclors reach:.-.; Che watershed from the Anniscon plant were entering Snow Creek, 4) The produc tion process was described in generaL decail to point out chat water vis no; essential to production of Arociori, and waace water was produced anLy by auxiliary equipment such as steam jets, etc. . Mr. Crockett was sosc appreciative of Monsanto's approach to the problem and che fact chac Monsanco came co him. He alluded chac our action would produce a itcuaeioQ chac was beneficial to che protection of both che Monsanco and AWIC positions. His recommendations were as follows: 1. Supply che AVIC with a general process description detailing potential loss sources. 2. Continue co develop information and as cajor items develop inform che_ AVIC. 3. Give no statements or publications which would bring che situation to Che public's attention. - 4. If approached by news aedia, either che AWTC or Monsanto is tree to state th_c the situation is under tcud/ by che staff of AWIC ac the direction of che Technical Director, Mr. Crockect. 5. If in the future, information is developed indicating that Aroclors art detrimental co watersheds, Monaaato will be required to secure t perm:; from AUIC co allow certain maximum quantities of chlorinated bipnenyl 05 W 014093 < *tT >1 1 HARTOLDMONO018030 G. L. Jesaae -2- May 7, 1970 In aumaiary, Mr. Croelcact vaa noticeably unexcited ac our dlaeloaure and all hla rcmarka were directed coward a careful avaluacion followed by actio ni as required by data. on a confidential The full baals can cooperation of the be anticipated. AWIC to reach the abova objective It muet be rc*cn.bered, however, that all AWIC actiona are aubjec: to i'atc political praaaure and federal control. ' /be HQNS 09953h HARTOLDMON0018031 -4,iUii-uin.u Deoarrm i *? 157 <r TO J. C. Lar.dvehr Anniston Plant -- r* a S I have enclosed a espy of the data given me by ;he Siara of Alabama. water pollution authorities or. the*PCS analvsas in Chcccolocco Creek and the Marcin-Lcgar. Reservoir. ' These data are collected 'ey era C. S. FDA and ara t.-.s basis cf FDHAi c - 3 ^* ** v4i rrW V 3^3--3 -4 will not; his is the genera, trend tnat aamoles shew in connect!; with PCS. While I was in Alabama, J. L. Crockett, Jr., Chie of the Alabama Water Improvement Commission, recc that when we sample fish for PCS analysis chat we les above and below the Martin-Logan Reservoir, Csuggested chat our control program should be writ submitted to the state as a report covering our t. present status and our future plans in connection _JdLmitting ?C3 in the Snow Creek effluent. He also the state did reculra that we do dally analvsis f "in our effluent and~ submit .weekly jsumsvgrJLes_to,_th Imprcve'rent'Commission in' Montgomery. p n ir Crockett told me that if this PCS- issue hits the Ala press, the Alabama Water Improvement Commission wcui forced to close Choccolocso Creek and the Martin-Log Reservoir to commercial and sport fishing unless we can prove that Che contamination level does not reach the reservoir. The State of Alabama has no choice but to follow Che guide lines of the FDA which calls for* nc mors chan 5 PP ?C3 In fish. JTG: JU nolesure Garrett OSW HARTOLDMON0018032 HARTOLDMONO018033 Monsanto *. -> - < .aci* a-' J. C. OcMir IS, 1971 twl,** 7Q ; 0. 9. Koseer - G.O. n. Robirds - G. 0. Savage ' C . C Papageo, ge - c.o. Hodges G, 0 The attached letter is our proposed response to Joe Crockett's request for a status report- w have an appointment with .Hr. ' Crockett on Wednesday, Oct. 20 to present our story to him so we need your comments by Tuesday. I discussed the change in concept away from any carbon treatment at this tame with Bill Papageorge. I an also including a copy of the chart of weekly average flows and concentrations referred to is the memo. Other than these items our report will be limited to showing which Phase I and Phase II itexas in Che original report have been completed, deferred or are underway. Atr. o$y 013355 HARTOLDMONOOI8034 O/To MSSTTSO At SOUTHWEST 3SSXOTAI. OPPICS 0? SPA ""'" 1*21 PaACicre* 5c. tt.. " Atlanta, GaorgiA 5ovmflr 11, 1971 Copia* tot H. S. Bargen. J. T. Garrac: J. V. Glilaapia 'TB/Hadgaa ?. J. HolzApfal G. L. J. C. Landvaiir J. Kiicn H. L. Xincklar V. 3. PapAgaorga p. 3. Park V. 8. Robirda J. 1. SAVAga 9/ VVJ- On-- J' Prv ^ r- U- c..r o-- ~ . 4a A-' *<- -- --J (?-- " ^ o er ^ u /A- Vtn-',, V4 i - ' HARTOLDMONO018035 MZlTI^fG AT SOGTHV&Sr REGIONAX 077ICZ 07 Z?A ^ =i"" Atlanta, Georgia rfoveaoar 11, 1971 These Present: Monsanto J. T. Gerpact 0. 3. Hosaer G. ,. Jessee J. ?. Lsndve.hr State of Alab^- Joseph Crockett Southwest Regional I?A John Whit*, Director of Snforcement Dave Hill Dennis Cafaro George Harlow Subject: PC3 2ffluents from Anniston Plant to Snow Creek, Choccalocco Creek, gtc. This seating wu arranged by Mr. Joe Crockett at the request of Mr. John White. Mr. Vhite had two primary araaa for concern: 1. `Sic Federal Oepartsent of Justice haa apparently recommended that suit be initiated against the Anniston plant for PCS emission under the federal Befuee Act. 2. He will be required to approve or recommend a He fuse Act disposal permit for Anniston which Halts pollution lsvels. The PCS production history of the Anniston plant was reviewed briefly from its beginning in 1929 to the present. Our program to control and reduea PC3 emissions to Snow Creek was reviewed by both Monsanto employes and Joe Crockett who emphasized that we had kept him fully advised concerning our program end our progress. Gene Jesses carefully pointed out QSU 01^380 HARTOLDMONO018036 Heating at Southwest Regional Office of Z3A .'foveaner U, 1971 Pag* 2 ' that our production of PC3`s had bean greatly reduced in January, 1971 and discontinued in August, 1971. It was explained that currant PC3 emissions in the liquid effluents primarily resulted from our inability to make a complete separation af biphenyl frcm other polypheny!*. Mr. Jessee stated that equipment would be installed to vastly improve this separation by July 1, 1972, and that by this tine a further reduction in PCS in effluents would be effected. There was considerable discussion concerning the Halting level of PCS that should be permitted in the discharge. Mr. White suggested "no detectable amount." Hr. Crockett and the Monsanto personnel pointed out that this was an undesirable approach. The preferred concept vas explained as a reduction in aqueous volume accompanied by s concentration reduction (reduced pounds per day). This appeared to be accepted. As a result of the setting, the following agreements were reached: 1. Mr. Crockers and Mr. White will agree upon an interim permissible lerel for PCS emissions to be provided in the Refuse Act permit. Obviously, Mr. Crockett will press for a number in excess of our 0.3 lbs./day current level. 2. The permissible PCS will be reviewed again when our new separation equipment ia in operation aa of July 1, 1972 to arrive at a new permit lsvel. 3. A summary report outlining our past work and future plans will be written and sent to the MPA office via Mr. Crockett's office. U. a second copy of our existing monthly reports on PC3 effluents to Mr. Crockett will be forwarded to Mr. Vhite via Mr. Crockett. ? 5. Monsanto Is rsady and willing to meet with the Federal Z7A personnel concerning the PCS problems whenever requested and will feel it a privilege to describe cur program. OSW 01*381 HARTOLDMONO018037 M_.ting at Southwest Regional Office or HFA November 11, 1971 Page 3 - 5. SPA can ccsa and sample cur effluents In a surual program at any cine thev wane to da this. (I believe they will uaa cur data.) Va explained to Mr. John Vhlta that Mr. 0. L.. Jassee, the Anniston Plant Manager, was the aan who spake for Mcnaanto at Annlaton. Ve further explained. that Mr. Jack Garrett's presence was to indicate the support or the Company's Medical Department and that Mr. Q. 3. Hocaer't presence was to demonstrate support or the Monsanto Industrial Chemicals Company, who is respcnslhls for the manufacture or PCS's. It was suggested by Mr. Vhlta that it might be desirable to dredge Snow Creek. I believe we convinced Ma that this is undesirable. Ve received strong indications that the Southeastern Regional I?A Omce will racaeaend strongly against a Refuse Act suit by the 7ed*rrl Department or Justice on ?C3 pollution. The entire atmosphere or the meeting was favorable, including the lunch following lb. bt 11-12-71 D. 3. Ho sms r OSW 01*332 HARTOLDMON0018038 muiuauiu <uitrr cc TO 3. Hodjsa - St. Louis September 18, 1970 Toby Sell - Anniston J. R. Savage - -SAVA V. 3. Papageorge - V?a?a . aosmer G. L. lessee 3K0SK G. Miller J. Landwehr J. L. Carder Arris zzr. CONPHSOTIAL In reviewing your proposed letter to Joe Crockett with Legal, et al, we requested latest emissions data on the flow to Snow Creek. Ve had hoped that it might, show an improvement over the 1st week In September and thus * demonstrate a favorable trend to Crockett. Instead, the emissions are considerably Increased with 9/13/70 at 5.25 ppm (or about 80 lbs. of PCS for the day). Prom the Legal standpoint, there is extreme reluctance to report even the relatively low emission figures because the information could be subpoenasd and used against us in legal actions. Obviously, having to report these gross losses multiplies, enormously, our problems because the figures would appear to indicate lack of control. Realizing the extreme efforts the plant has gone to lr. order to curtail loss of PC3's, is there anything more that can be done to get the losses down? Is there .a possibility that sampling practices are responsible for the wide variations shown (you might try duplicate efflu ent samplers)? Are there any practices in the manufac turing area which night result in the peak losses? Obviously, we cannot solve the problems from St. Louis but we do want to engjhaslze the concern from here. Paul 3. Hodges /np QSW 014095 HARTOLDMON0018039 JUN-02-9S 00=13 FROM = BARRETT LAW i .GflSdfitG ft .81*' ' Qotcfter 2S, 1970 TO : C. I. lessee ID:6010342626 :nONTIAC AnaisTbr: ?iiR'c PAGE 4 - 1 J : I i. Carter 3. ?cjeec--e - 3. dodges - C. Z. R. Sav^c - C. 3. J. T. Sell t- G. Vright V. 5. Saupc O. Wright, J. r. Bell and 3. c. iandwehr oec with j. i. CrriHs-.r, Technical staff Oisec-mr of tie Alabama Water t;?rov*nent Crrrnss im ;- Friday, Tcrober 22, 1970. " Mr. Cr5det: was - very well latisfied with progress at Anniston cr. uha .-C3 problem" and Could suggest no areas of further work which were alriitv receiving our attention. ' Since he insisted again on knowing what effluent levels were, we verbally informed hw chat we were presently discharging total Aroclars in the rants of 1-5 Ihs./day with, the latest trend being toward the 1 Ih./iay er.d of i-.2 range. To hi* gueseien on past discharges, we informed him that current discharges were down from recent pest ranges by 1/5 to 1/10, but cuelified this answer Chat high recent past Barbers were a result of higher viter efflus.-. . flow and high solids content in the old limestone neutralization put. In conjunction with this information, a lengthy discussion of the tschnirii complexity of Ar-aclor or ?C* ntrobers resulted in hr. Crockett`t agre-sinr that any written effluent level reports would b held confidential by the Technical Staff and -would noc be available to Che public until or unless hensautto reicassr ic. hr. Crockett also changed bis past position from wanting a weekly report t: accepting * monthly report of 24 hour emulative effluent sample results. The initial report and transmittal letter is attached. The second report will October 21 through 31, and all reports thereafter will cover whole months. Ete Progress Report on Abatement of Polychlorinated 3ioh-nvl Oischerco to Snow Creek warn discussed in detail with Sr. Crockett with use of slides shr ing construction of svnps and new limestone pit, etc. hr. Crockett requested that a section be added to the report briefly discussing the process and the roie of various discharge abatement-devices, otherwise, he w*s cult- satisfied with our proposed report. The requested addition will be race and clans are^tn the report to hr. Crockett the week of October 2d. Numerous other related natters were discussed with Hr. Crockett during the s ix hour meeting with him. :kd Atcachaerv CONFIDENTTAC HARTOLDMONO018040 14 FROM:BARRETT LAW * U : to V) I fc* ^ ** ^ to ^ a J. R.j Savage - General Office f October 7. 19TO SEPtLmBR PCB REPORT Manufacturing Nr. H. S. Bergen JCr. P. B. Hodges Hr. V. .8. Papageorge Ocneral Office JANNISTON NT PCB Levels In Snow Creek Average ^CS lose for the aonth u high et 2500 ppb or 32 lbs/dhy, largely as * r**ult of one very bed day (400 lb) Contributing causes were: 1. The old limestone pit was overloaded end solid sludges were carried through, 2. Detergent cleaning of the department, 3. Severing of excessive amounts of suriatio acid. Since the new limestone bed was placed in service on September 23, pit effluent has been at 0-3 ppb PCS'*. However,| leaching of PCB'a fro* the creek bed results In a plant effluent level of 90 - 2t0jpb or 1.1 - 2.8 lbe/day, gradually declining. The plant believes that the new pit ean handle ordinary upsets and peak loads. i Regulatory Action Telephonic contact continued with the Alabeau Vater I*prove*ent Coanlssloo. However, a planned aeetlng did not take place due to illness of AWIC aeabera. Pressure for reufcln* subalsrihn of analytical data la not intense at this tl*. Department Suspended Aroclor Control An experkaental sklwoer operated very well restoring the PCB laden sciz* which accumulates in the new suap. Solid Waits* f Solid waste data for evaluation of dispel, methods has been accumulated. A report will be Issued in October. HONS 099026 HARTOLDMONO01804 JUN-02-98 08=14 FKUn=UMKKt1i l U O 1 W :J ' i * - ' Anniston J. T- Ball J. L. Cordar G. L- !** J. c. LanArahr H. E- SdlulU \ *^GnaraI Office! \ 0. Oanft* (1) P. 8- Hodg** . 3. Ptp*gor7 J. R- Suvag* Anniston Plant TECHNICAL SERVICES DEPARTMEN MONTHLY REPORT S ummary HOV 70 dNriCESTtJM. Bead and basrrov Air- Minnrnp ri|i --. T-SLlirrici:*--' " South Second St. Other Locations r. Macdonald - Newport . B. w. Qarlew - W.G.K. Aroelor lo*** during Mowaaber *v*rag*d 25 #/d*y (4620 ppb) . high value accounted for 18 */d*y, neglecting till* o.e Kovewber average wild be 7 /d*y (1410 ppb). Based ca knowledge of plant operation* and performance of abatement device* in Moveeber, Bds of the high larel data Is du* to uapl enataadnatloo. Spill* Minor leaks were contained by o*e of sand and disposal ir. ilni-- Me spills occurred. Prelects and Evalnations 1. Laboratory work to data judicata* the presence of niniral Mount* of PC8 In tit* residue fro* Solid Amcior distilla tion CNectar 5). This alialnat** 10 M pound* par year or solid west** frtm ear PCS disposal plan. 2. Design work to collect *pt carbon fro* 3d carbon covert ha* b**n dafarrad to aarly 1971 to accsnplish eft* Ho. 1 Bd llaeston* Pit rebuild. ' 3. Solid* r--~i~11 fron plant affluent (part of prograa ca radaea PCS in plant affluent to 10 75^ ) j* eovcnq for- *zd with preliminary screening t**t* at Denver Equipment QSO^any Bats Laboratoria* indicating good to node rata race*** with flocculation and tattling, further labora tory teeting is scheduled for aarly December- X project ha* been written, design is underway and equipment nodi id eations upd*r study workirg with Monsanto 3todire to sec via on* of thslx ciaxifiars At taaistaa for pilot seals DSU 013917 Issa *f CUO*hWw>1oI iIIxItTu^l iH#otw^noH tea*, rw HARTOLDMONO018042 JUN-02-9S 00=15 FROM=BARRETT LAW I D = B018342620 PAGE 10/12 xxxza*. WASTES Projacts and evaluations - continued t**tihg of the apparent best technique* rtcotaaendad by Oenvar and/or 3etr. A, k snrnrttfuT fast- wa made of removal ml liMJUu* Scott cn *2 HCI neutralization pic while in operation. X total weight of 127,000 pound* vmm rwoved of which. 36% by weight wa* solid*, Lab analysis wf th uul cvld nac ^ian iwo, uco ppb Arocior or 12 to 15 pound* of Arocior. Present indication* tr* that this method of removal of solid* while the pit i* is operation will increase the effi cient. Ufa of the pic by 25 par cant. S. X mechanical expense project for repair of the So. 1 HCI neutralisation pic vmm vritcan and approved. This project nil be coordinated with the Siran pic project to apply on asphalt lining at the saae tine, to save money on materials. :Jcd OSU 0139U HARTOLDMONO018043 Monsanto Uon**nto Comeinr Anniston. Witimi 38X01 !*: (201) X3S-S3S1 October 15, 1971 Mr. J. L. Crockett, Jr- Technical Sta.it Director Water Improvement Commission State Office Building Montgomery, Alabama 36101 Dear Mr. Crockett: We respectfully submit the following status report on prepress toward reduction of polychlorinated biphenyl discharges to a ** -r-~ The attached graph of weekly average ?C3 concentrations (ppb) and effluent flaw shows progress since our first report to you in Ifc'-ren tier 1970. As shown at the beginning of the graph, effluent was in a range of 1 - S lis./day ?C3 (100 - 500 ppb S 1000 gpn) . In con trast recent weekly averages have been 0.2 - 0.9 lbs./day with a good, downward trend still evident. These current values represent a five-fold reduction in discharge levels resulting ires numerous improvements Ln facilities and operat ing techniques made in accordance with the Phase I and Phase II program originally outlined. Revised Phase I and Phase II plans are attached with status of each item shown. Research and plant test work in removal of FC3 from water ban shown that both an activated carbon column and a limestone bed of a particu lar configuration are effective in a combination filtration-adsorp tion process for removing PC3. lie essential difference between the two is that surface loading (gpn/ft2) for carbon is much higher than for limestone and total loading capacity (# organic/* adsorbent) is also much higher for -carbon. Sowever, to take advantage of the higher performance of carbon an elaborate prefiltering and backwash ing procedure is required ta prevent blinding of the carbor. and breakthrough. A large, properly designed limestone bed overcomes these disadvantages of carbon and is a much more economical means than carbon for providing sufficient surface and loading capacity to reduce PC3 in water to low ppb levels. Rased on the above experience w are continuing to concentrate on improvement of our limestone bed design and reduction of flow to them. Ac this time it is our opinion that this approach will result fU\ i a< n r/r <r EXHIBIT osw 013356 HARTOLDMONO018044 Str. J. - C--ske 2 in 4 continuation o the davnvazd trend in ?C3 levels in plant er . Yours very crtly. /a? ACC. J. C. ianc'-'ehr Technical Services Super!. c render, a 013357 DSM HARTOLDMON0018045 <TlTJ UNTIED SEES DISTRICT CCUHT tcfcusw district cf mavis DSZESti DIVISION orrno sixes cf akeric\ . JCSZFH C. OUAhCRA, hOKEIO L. KEPLINCSt, Paul l. wright, and JV25 S. PLUK, ; ' ito. <?/ d/e 3*3s~ Violation: Title is, u-tad si* ) Cbde, Sections 1001, 1341 and 1: J ) ) The SPECIAL CC:'CEvER 1980 C5ASD JUET charges: 1. At all tioes material herein. Industrial Bio-Test Laboratories, Inc. (hereinafter referred to as 1ST) did business in Kirthbrock, Illircis ir. the Jfcrtbem District of Ulincis and wos a contract research liberator/ which ccrrfuctod animal studies on various drugs, pesticides, chercicals, and ether substances, for the sponsors of said substances, in order to deterrine the safety and effectiveness of the sihstances. Of 1ST. 2. At all tines material herein, JCSUH C. CAIA'CRA was President '* *' 3. At all tires eaterial herein, K3P22 L. 1CE7LINCZR. was Jfa.-v.ger of Toxicology at ZBT. 4. PAUL L. HKXQfT was Section Bead for Pat Toxicology at 127 free apprcsdr*fcely March, 1971 until Septenter, 1972, at Waich tire he becare Maries of Ttxioology for the Dcparteent of Mrficlfta and &vircmental Health at Ksnaanto Oorpoiation in St. Louis, Missouri, froa apprexirately 1972 until the present. 5. CDJES B. FLANX wu the Senior Group Leader for Rat TOx i, at IBT iratil of 1972, at which tire he bacarae the Assistant to the /tPP , 4 1 On :n - HARTOLDMONO018046 Manager a TtxLaalogy at ZST fcm apprscrratcly October, 1972 crtil fcr-t *> 4 2377. * 6. 327 ccnjctad a too-yaar chronic oral toxicity study & gichlcrocrirdrallLdc (TCZ) in albino rats, 127 Study Umber B9575, f-- Atonsanto Ctrpany CJtr-sAntoJ107 is an antibacterial agent used Li Cn or about May 10, 1976, JET nailed its final version of the r^rt cf the study to Jfcnsanto **o subraittad the 127 study report to the Ehiterf States Fbod and Orjg AbrLiistraticn (FC=0 with a cover letter dated Msy n, 1976, for that agency's use Li its evaluation of the safety cf T2Z. 7. 237 contacted a 22 tenth chronic oral toxicity study cn Naprosyn in albino rats, 127 Study Nurber B7922, for Syntax Corporation (Syntax). Naprosyn (also taevn as naproxen) is a drug used in the treatment of arthritis. On or about March 3. 1972, 137 sailed its report of the study to Syntex who submitted the 327 study report to FIA, with a oover letter dated March 22, 1972, as port of its application for approval to test Naprosyn on hrrars and ultimately sarket the prodxrt. B. 237 ccrxdurtsri Ojo carcinogenic at.riles cn sice (tests to determine whether a curporri causes cancer) for Cxsagro Corporatier. (Cxnagro). Cne study was cn Senccr, a herbicide, IB7 Study Reiser 9C69, and one on Rexmcur, a pesticide, 137 Study Rrer 9068. 237 submitted the reports of th studies with a cover letter dated August 15, 1972 to Chemagro, v4rj idaaittad th* 2BT study reports to the ttiitad States ftTvirarrxr.tal Protection Agency COPA), the Senccr study report by anil cn Mu-dt 8. 1973 and the Nenacur study report by Bail on October 15, 1975. Both study reports were submitted as pert cd Crreagre's application for approval to asazhet these probaots ficr use cn food crop*. -2 ir sum TUuj'Tf frpp- & HARTOLDMONO018047 . . t. flajirriny in cr about 1S70 and ocnt/juing until afccut July, 1577, In Jt^hfcrock, in the Jfcrthern District of Illinois, auetesi Divixis and elsevhere, . JOSEPH C. CUAM3A, *CS-XO X. XZPLDCER, PAUL L. WRIfflT, and JArtS B. PLVK, defendants hereir r with co-scherars both fcrvn and unknown to the grand jury, devised and intended to devise a schare to defraud clients and reports and false and fraudulent explanations of studies and study reverts, and by concealing the fraudulent nature cf the study reports and explanations cf studies and study reports, all by mans of falae. and fraudulent rrp.e- sentatiens and concealments, fcxwing and intending that the representstiers and concealments were false when made. 10. Zt was a part of the scher* to defraud that the defendants wrote and distributed false and fraudulent animal study reports to clients who comissicned the studies, which study reports were suirdtted fcy the clients to government agencies that evaluate such reports as pert cf their determination of the safety of those test materials. U. It was further a Fort of the scheme to defraud that the defendants provided FEA with false and fraudulent written auhriasicnx which reaffirms and new false and fraudulent statements as to aaterial facts, and concealments and emissions of material facts in, or pertaining to, the studies and study reports. 12. It wee further a part of the schra to defraud that the 3 L.OP t* HARTOLDMONO018048 criminal >wrxicn of the ICC study report vu written and diatributad by JBT to tenants cn or about >terth H, 1974. 23T suhnittad this version of the TUTneport to HA cn DacaJber 12, 1976, which stu*f r-p-- * the defendants bev to be fair and fraudulent in that the study report: *. stated that tbe data reported were fszn a.cicala that lad been on the study for 24 months, when defendants then knew that the report inclodod data frtra a substantial hlrfcer of animals that had beer, on the a tody for significantly leaser p-y^rc of time; ' b. stated that 480 animals were in the study W^er. defffdants then Jcav that a substantially greater nxter of animals were also part of the study; and . c. contained an Animal Mortality Table (Table IV) which defendants then knew to be false in that it substantially vrder-reported the nurrber of animals that were in the study and the narber of animals that died during the study.. 11. It was further a part the scheme to defraud that the final versicn of the TCC study report was written in April and May, 1976, was dated Kirch 21, 1974, and was nailed to Monsanto by 1ST on cr about May 1C, 1976, was submitted to FCA by Monsanto infer a cover letter dated rtjy 11, 1976, and was known by defendants to be false and fraudulent in that the study r*pcrt: a. . stated that the data reported were froa animals that ' been cn the study for 24 months, when defendants then knew that the included data from a substantial ranter of animals that had been or. the study for significantly lesser periods of time; * b. stated that 480 animals were in the study when defendants -4 seas ftP P.7 HARTOLDMONO018049 then knew that a substantially greater arrter c sniaals were of the tudy; ' ' ~ - c- contained an Animal totality 7hble (Table xvj defendants then knew ts be false in that it substantially irder-rr?=rt=d \ the rxnber of animals that %*re part of the rtedy and t>* arter of animals i that died during the atady; d. rtated that 250 extra animals were cn t^a stub/ cr 24 months and wars an independent IBT 'research* grevp, separata frm the animals reported in the TZZ study, when defendants then knew (1) that the o--called research* group animals wtre not an independent research" group, but were used as a source of extra animals and animal *'*<= >c the ICC study; (2) that the ao-called research" animals had been cn study for significantly lesser periods of tine than 24 months; and (3) that a substantial rtriar of the extra animals were ccntingled into, and rr-p-.----r as part of, the TCC study group; a. stated that no histopathologic*! ocarinatlcn (study cf tisrje characteristic of animal disease) was performed on the so-called "research" group animals, when defendants then knew that tissues fms cany cf the so-called "research" pop aniails had been so examined; f. emitted and concealed the findings listed in a table of Histopathclogical Changes in Testes -- Postmortem Animals*, when defendants then knew that the table existed; * g. stated that posterrtsa autolysis (chemical deterioration of tissue after anissl death) of testicular tissue pi rr.ltried meaningful h* cj*,h~'T pj, evaluation of the f^yM/niT^r tissues of the postmortem \ animals, vhen defeadants them knew that many of those tissues bed beer, wo -5l l 10 0 j '2: j l HARTOLDMON0018050 caseload and graded; - . . .___ . ,^ " h. ftatsrf that the 2BT pathologist, Or. Etnovmn Oraf ccatrlned the tfssur.s of'the ready animals and concluded that the in the testes of the lowest dose level (T^J animals vers iniLstirq-iuhahia free the findings of the testes of the central grot? anirais, vher. defendants then knew that Esr. Gbrion's conclusion wes that there were TCC related <-- effects in the testes of the animals in the lowest dose level; and i. aeitterf and ccrcealed, as defendants then knew, that Dr. William RLbelin, a pathologist hired by >fcnsanto, had exanirerf - of the testicular tissues of the TCT study animals and had concluded that the lowest dose level showed TCC treatment-related toxic effects. 14. Jt vas further a part cf the schare to defraud that in response to ITA questions concerning the *CC study, a written explanation of the Td study and report, dated Decanter 12, 197S was prepared and submitted to FDA by 1ST on DecerAer 14, 197S, %&ich explanation defendants then kraev to be false and fraudulent in that the submission: a. stated that the data reported in the Hsy, 1S76 report (dated rtsrch 21, 1974) were from animals that had been on the study for 24 months, when defendants then knew that the report included data firm a substantial renter of animals that had been on the study for significantly lesser periods of tin*; - b. ccncaaled, as defendants then knew, that the aniaal mortality in the TCC study wes substantially greater than reported in any version of the study report; c. . stated that 2S0 extra onioals were cn the study for 24 months and were an independent IBT research* grxp, separate free the - 1005J0 HARTOLDMON0018051 animals refers*! in the TCJ atu^y, when defendants then Jnw Cl) that tix ID-called *rrraarch* grc*p5 Ankaals were cot an Independent "nnvirth* but **re usd u a r3 of extra animals and animal tl xrrrx fc- tJ* rfijdy; (2) that the ecr-called 'research* animals had been on atudy ~ aignificantly lesser periods of time than 24 tenths; and (3) that a rvisstantial order of the ectra animals were ocmingled lr.tr, and p'p _ ^ as part of, the ICC rtudy groi^p; d. concealed that histopathologic etarxinatiens were perferred on a substantial nxber of the ao-callad "research* animals, vhm. defendants then Jew that such examinations had been perfcored; and e. oxitted and concealed, as defendants'then Jr*v, that Esc. Killian Ribelin, a pathologist hired by Monsanto, had earined sore cf the ter-'ralar tissues of the TCC study animals and had concluded in a written report that the lo-est dose level shewed TCC treatreet-relatad toxic effects. 15. It was further a part of the ecbsre to defraud that the final study report cn Naprosyn, dated Jarusry 4, 1972, was written by 237 and was received through the mail by Syntax frern 2B7 on or about March 3, 1972, and submitted to the FLA by Syntax under cover letter datad March 22, 1972, which report defendants then Jew to be false and frauhlent in that the report; a. contained individual animal and summary animal data allegedly baaed on blood and urine tests performed an or about the time of final sacrifice of the study, Wien defendants then knew that no such tests K*- been conducted and that the data was fabricated and false; and b. Wes supplemented by an Appendix II which was submitted to FLA by Syntex cn April 9, 1974 which purported to represent, among other things, *11 the findings from gross examination of the study anioels, when PrPf.tO lOOv: f HARTOLDMONO018052 defandant* then knew that fez a substantial portion of tf gross finiinys fcr pcataortaa infanlj, no such axaninatims were perfoensd ard tfm were fahriratad and false. # IS. It was further a part of the achene to a**t*ii*. that la response to FEA questions raised In Septacber, 1975 concerning t1* teprosvn study/ a letter sieped by Joseph C. CSdandra and an planaticn of Naprosyn study dated Ncvrr.ter II, 1975 was written air! submitted to TZA, and a copy v*s sailed to Syntex under cover letter dated NOvwter 17/ 1S7S. Defendants then knew that the Jfcvexrher 11, 1975 submission to the FZA was false and fraudulent in that the submission: a. stated that the data reporial for individual anioel and sumary animal bleed and urine values allegedly collected cn cr about the tine of final sacrifice of the study were accurate, vhen defendants then fcvsw that the data were fabricated and false; and to. stated that gross examinations were perfected cr. the postmortem animals and that the data froa those examinations reported in Appendix II were obtained from animal cage cards and animal disposition sheets, when defendants then knew that for a substantial nxfcer of the reported postoertaa animal findings no gross examinations were perform! and the data were fabricated and false. ~ 17. It was further a part of the achane to defraud that 227 preparsd and asdied to Cieragro final reports fer the fiercer and Nrracur studies under cover letter dated August IS, 1972 to Cheoagro. Casmagro submitted the J27 Sercor study report to ETA by mil on cr about March 8, 1973, and submitted the 127 Nerzacur study report to E?A by mil on cr abo-t October 15, 1575, vbiich reports defendants then knew to be false and ft?P. Il 10 0 0:J U HARTOLDMON0018053 fraudulent in that each report _ a. stated that all the nice on the study were fed test material for 15 tenths, when defendants knew that (1) the study crly \ ran for 14 tenths; and (3| the mice sacrificed and oaszired at te end 4 of the study included a substantial raster of mice which had been fed the test material 14 tenths or lass; b. contained a Mortality Table \hirh defendants the*, fc-ew substantially irder-repcrted the renter of anirals that vaere cn the study and the meter of animals that died during the study; c. concealed that a larger ranter of extra mice were added to and were a part of the study; and d. stated that there was a third positive control group fed benoadine, when the defendants then knew that no such control group had been conducted with these studies. ' 18. It was further a part of the scheme to defraud that 2B7 wrote an "Addendctj Report to Cheragro" regarding the Sensor study report and mailed it to Chamagro on or about Decerter 21, 1973, which addendum Cveragro mailed to EPA on or about October 8, 1974, and which defendants knew to be false and fraudulent in that the addergua: 1. listed the raster of days that each mouse was on the study as if the study had rrn for 18 months, when defendants then knew that the mice had bean cn the study for significantly lesser periods of time; 2. emitted and concealed that a substantially greater rtrter -of mice were on the study than reported; and 3. listed for the individual anbnals designated as K-Lil, their alleged rerter of days cn the study and gross pathological findings which 'wtuhi c 9- 1 nnw'r; HARTOLDMONO018054 4afa==*ticn defendants knew u false hrrnuse no such positive consul esse? had been ccndictad with this study. 15. Zt ias further a pert of the achare to defraud that an 237 was crarrtgtsd on the Cwsagro studies in April, 1576 thieh doorsntad that the studies were fal^e, as sprcifind show in Paragraph 17a, ard that the defendants cgcrale! the results of this audit fror Cwegro stil July, 1577. 20. Zt was further a part of the scheme to defraud that tJ* ttritod States m!1 and interstate wire ccrrmLruca tires were osad in furtherance of the achsee. 21. Cn or about ttsy 10, 1376, in the Jtrthem District cf Illinois, Eastern Division, JOSEPH C. CALANDKA, HOtENO L. KEPLINCES, PALL L. WRICKT, and JA^ES B. FLANK, defendants >*rein, for the purposes of executing the aforesaid ache* to defraud, and attempting to to ao, knowingly did cause to be placed in the Doited States sails the final version of the TOc study report, addressed to: Daniel Ifcran * Monsanto Qxrpany - BOO Lindbergh Blvd. St. Icuis, Kisscuri to ^ wit and delivered by the Dhitad States Poatal Service according to . the fractions thence. In violation of Title 18, Dhitad States Ctde, Section 1341. -lo ss swvnv1 ran. AfP. ;3 100 n m" JO HARTOLDMONO018055 ( \je SPS3AL CCTgO 1980 CUO JUKf ftxrsher ebar^t 1. - Paragraphs Cne through Twenty of Cant &je of the iaiictrt gre raaHayad herein. 2. Cii car about August 11, 1976, In the Northern District of Illinois, Eastern Division, JOEPH C. CMANDRA, hDJ20 L. IC^LDXZP, PAUL L. WIGHT, and J?VES B. PIASX, f defendants berain, for the purposes of executing the aforesaid achate to defraud, and attarpting to do so, Jorvingly did cause to be placed in the 1 : United Staters g*H a letter fraa Joseph C. Calanira dated August 11, 1976, P j addressed to: ' ' Dr. Carl M. Leventhal | Deputy Director, Bureau of Earugs . ; Departient of Health, Uiucatim and Welfare r Public Health Service : Ftcd and Drug Xitinistratim Jbchville, Maryland 20852 to be sent and delivered by the United States Postal Service according to the directions thereon. i in violation of Title 18, Ehitad States Qode, Section 1341. I li - i 3Q AfP-M loo i i-J.) HARTOLDMONO018056 The SPECIAL CCUO 1980 CSvVO JURf further charges: 2. ' Paragraphs One through T-enty of Car*.t Che of this irrflror are realleged herein- v .\ 2. to or bout N^vner 17, 1976, in the Jfcrthem District cf Illinois, Eastern Ed.vision, XSZPH C. OJANDBA, K3JEN0 L. KEPLINCZS, PAUL L. WRICSfT, and JS^ES B. PXANX, deferdA.--.t_s herein, for the purposes of executing tne aforesaid schere to defraud, and atterpting to do o, knowingly did cause to be placed in the United States sails a copy of the written submission by 1ST to the PEA regarding Naprosyn dated Rverber 11, 1976, addressed to: Mr. Virgil Thxpem Syntex Corporation 3401 EillvieJ Avenue Palo Alto, California 94304 ' to be sent and delivered bf the toitad States Postal Service according to the directions thereon. , In violation of Ti*-le IS, United States tode, Section 1341. - 12 - AfP./Z' 10033b- HARTOLDMON0018057 CXNT POOR Sc SPECIAL GC7CEZ7 1580 StVO JESDf isrfcher cf^rgas; 1. Paragraphs Cw through Twenty of Ceunt G* cf irr** are realleged herein. . . 2. In or about October, 1575, In the Jtertbem District of Illinois, gajtem Division, JCSZPH C. CMAJCRA, k:ksjo l. kepldjgo, Paul L. KPicjrr, and ja^zs a. plv, deferslints herein, for the purpo-aes of emruting the aforesaid schere to defraud, and attesting to do so, fcrvirgly did transmit and r,"v to be transmitted in interstate errreroe, by ceans of wire crriar'-ication, certain signs, signals and sounds, to wit; a lerg distanoe telephone call betsn 227 and EC. D.W. Larrb at C^ragro in Kansas City, Kii:url. ' In violation of Title 18, United States Code, Section 1343. 13 srasr: ioo > > ), HARTOLDMONO018058 cxkt rrvs Tli SPSGAL CCTZEZ3. 1980 G5VO JURY further diargcst I-' Paragraphs Qae thswgh Six of Count Che of this indict* are raallaged herein. , . .1 2. At all tines sateriel herein, the food and Drug Ahiinist; CFLAJ was an agency of the ttitad States Ooverment. 3. CX\ cr about May 10, 1976, in fcrthbrooJt, in the yfcrthem District of Illinois, Eastern Division, and elsewhere, JCSZFH C. QLVCSA, HDKE2 L. XITLINCER, PAUL L. KRIS*T, and J?*S B. PLAKK, - defoliants herein, wilfully and Jcnowingly did js&Jce, and cause to be nade, false, fictitious and fraudulent statements --J representations as to Material facts and concealed and covered up Material facts, in a matter within the jurisdiction of FDA, to wit: "Report to Jfcnsants Crpany, IVjo-Year Chronic Oral Toxicity Study with TCC in Albino Bats, KL 71-8, hfeLTch 21, 1974, 2B7 No. 9575," fchich study report was submitted to FDA fcy Ptnsanto under ocver letter dated May 11, 1976. U* aforesaid false, fictitious ard fraudulent statements and representations and emissions as to Mtcrial facts are 1 < In Paragraph Thirteen of Cnort ttie of this frdlctaant and arc reallaged herein. In violatim cd Title 18, Ohitad States Oade, Section 1001. - 14 wp.n > j o HARTOLDMONO018059 CDLNT SEC The SPECIAL CGOBEa 1980 GKVO jus* fcrt*r char^ij 1. Paragraphs toe thrcugh Six of teat toe and Paragraph %o of Count Five of this indictment are realleged herein. 2. to or about Decerber 12, 1976, in Ncrthicoak, in the Northern District of Illinois, Eastern Division, and elsa-here, JOSEPH C. CAUVCPA, H2KJ20 L. KE7I2M23, PAUL L. WRIGHT, and JV25 S. PIANX, . defendants herein, vilfully and fcxwinjly dLid make, and cause to be cade, false, fictitious and fraudulent statements and rrpresentatiers as to Mterial facts and concealed and covered up material farts, in a matter within the jurisdiction of the FDA, to wit: a written explanation to t* FWi by 337 regarding IBT's "Report to Jtonsanto Company, TWo-Year . Chronic Oral Ttrdcity Study with TC in Albino Jfcts, EL 71-8, March 21, 197-4, UJT No. 9575." The aforesaid false, fictitious and frauribirat statements and representations and emissions as to material facts are listed in Paragraph Fourteen of Count toe of this indictment and are realleged herein. ~ In violation of Title 18, toited States Code, Section 1001. 15 on HARTOLDMONO018060 ODWT SEVEN The' SP2DIAL CCKUZR 1980 GPAND JUW further charges: 1. Paragraphs Qoe through Six of Cxat Che and Paragraph TVo of Cxr.t Pive of this indirtpent are realleged herein. -1 2. On or ahxjt Drtfagrhrr 12, 1975, In Northbrook, in tte Northern District of Ulirois, Eastern Division, and elsewhere, JOSEPH C. CALVOPA, MDKNO L. KEPLZNIZR, PAUL L. WRICHT, and JAMES B. PLANK, defendants herein, wilfully and knowingly did rake, and cause to be rade, false, fictitious and fraudulent statements and representations as to c&terial facts and concealed and aovered up raterial facts, in a ratter wit!-in the jurisdiction of the FDA, to wit: the original version of the study report "Report to tonsanto Qrgany, T^o-Year C------ ic Oral TCxicity Study with TCC in Alhino nits, BE. 71-8, Jtaich 21, 1974, lETT Ho. 9575*, which was submitted along with the written explanation of the TOT study to the TCA under oover letter dated Deoeraber 12, 1976 by 337. The aforesaid false, fictitious and fraudulent statements and representations and ceissims as to material facts are listed in Paragraph Twelve of Count fr* of this indiotaent and are realleged fcrrain. In violation of Title 18, Oiitad States Cade, Section 1001. - 16 ftPP.i*! 1003,1, HARTOLDMONO018061 ccwr cmr The SPECIAL OCT^EZS 1580 GVtfO JUFC further charges; ` 1. Paragraphs Q* through Five and Paracpaph Seven of Cant Che and Paragraph TVs of Gomt Five of this indicts*nt are realleged herein. 2. Oi or about Itovwber H, 1576, in Jtorthbrtck, in th: Northern District of Illinois, Eastern Division, and elsewhere. JOSIPH C. CMANDBA, >CfSTO L. KZPLINCER, PAUL L. KRIG3C, and JA>S B. PLANX, defendants herein, wilfully and tervingly did saAe, and cause to be rede, false, fictitious and fraudulent statorrents and representations as to roaterial facts and concealed and covered up material facts, in a ratter ' within the jurisdiction of the FDA, to wit: a letter and written explanation to the F^ prepared and submitted by IBT dated Novmber 11, 1976 regarding the IBT study report on Naprosyn called: "Report to Syntax Research, Division of Syntex Cbrporation, 22-htnth Cuonic Oral Tend city Study with PS 3540 Albino Pats, January 4, 1572, IBT Ns. B7922*. The aforesaid false, fictitious and fraudulent statements and representations and qrissions as to Mterial facts are listed In Paragraph Sixteen of Cant Che of this indictment and are realleged herein. In violation of Titla 18, Dhitad States Cbde, Section 1001. A TOE SUL: Sl^izS Arrc^SS " FOREPERSON " mm cr-tl.vsr:^L^?~y?r^n -17- ` frfp.zo 1 n r, , HARTOLDMON0018062 cc 'V ' s Monsanto uaaita Cj *< 00 M. Si. l*nl. U(f*n <3169 014: 114.1000 July 18, 1575 Dr. J.C.` Calandra Industrial BIO-TEST Laboratories 1810 Frontage Rd. Northbrook, 111. 60062 Dear Joe: re: AR0C10R 2-year Rat Feeding Studies The attached table sur-arices a comparison of the 3 revised AROCLOR reports (12^2, 125^, 1250). . In 2 instances, the previous conclusion of*"slightly tumcrigenic" vas changed to "does not appear to be carcinogenic". The latter phrase is preferable. Hay vie request that the ARCCLOR 125^ report be acended to say "does net appear to be carcinogenic '. The number of hepatocas reported for AROCLORS 12^0 and 12^2 have been interchanged. This appears to have arisen from con fusion regarding the numbering of the animals. The original reports show tumors in anitals with numbers in the 100-300 range for AROCLOR 1260 and in the 500 to Soo range for ARCCLOR 12^2. This leads me to conclude that the numbering scheme shewn in the second set of reports is correct. With AROCLOR 125^ confusion is compounded. The original report showed tumors in animals -~ with numbers in the. units to teens, but the revised report shews animal numbers ranging froa ^0 to 10C0. Can this be straightened out? I was unable to reconcile the differences in the anical numbers between the first supplemental report and the original reports, I had inquired as to "the changes in the numbers. As I recall, I was told that the sections had been renumoersd wher. the new e slides were cade and that a key relating to the sets of r.umters 10073 received HART OLDMONO018063 c cc Dr. J.C. Calandra July 18, 1975 Page - 2 - would be supplied. This has net beer. done. It ray not be necessary for AROCLORS 126o and 1242, but AROCLOR 125^ remains unresolved. Insofar as I can see, the remainder of the reports appear acceptable. Kindest personal regards, Sincerely / George J. Levinskas, FhD Mgr., Environmental Assessment and Toxicology /bkp at cc: Dr. George Roush, Jr., M.D 10073 HARTOLDMON0018064 c r c Product A3QCL0H 1260 conclusion hepatomas Supplemental Repo: #1 fisailed 1 Suppieacn^: Re?ort de1 j^ slightly tumorigenic dees not appea: carcinogenic P- 9 p. 10 P. 11 p. 12 P. 13 p. 14 600 to 800 1000 series 70 to 100 500 to 600 600 to 700 700 series ICO to *C0 SCO to too ic to &o So to 2C0 2C0 to 2C0 200 to 2CC AROCLCR 125^ ccnclusion hepatomas slightly tuoorigenic 6 slightly tunorigenic 6 ARCCLOR 12-2 ccnclusion *1 < , tuzorigenic does not appear . carcinogenic hepatomas 7 3 range of test animal nos. as in report w2 as in report #1 for AROCLOR 1260 ARCCLCR 1260 1007.3 HARTOLDMON0018065 cc *t August 4, 1975 lr. . Dr George J. Levin a ha a, VUc4{<r - Xavlroomental Assessment lad Tojrfcolagy Hoasanto Company 800 North Lindbergh Boulevard St. Louis, VUaaouri 63166 7-;. .: * . i " * -* Dear George: Re: Aroelor - 2 Year Rat Studies Xa regard to the comments and questions covered In your letter dated July 18, 1975, pertaining to the above, pleaae note the following: 1. We will amend our atatement la the Laat paragraph on page Z of the Aroelor 125-4 report to read, "does not appear to. be carcinogenic" la place of "slightly tumorigenie" aa requested. 2. In regard to the animal numberi in the Aroelor 1242 and 1260 reporta, they are correct la our final reviled report. la the original reporta, the Aroelor title* for thaee two c-JiterLal* were reversed. 3. The animal identification numbers appearing in the reports on evaluation of additional liver sections are the same aa thoae la our original report. The animals were not renumbered. 4. We cannot find any discrepancy in animal identification numbers in the reports (original, re-evaluation, final revision) on Aroelor 1254. However, ia the report on re-evaluation of additional liver sections dated Viarch 21, 1975, there was a typo graphical error on page 1 which referred to Aroelor 1260 Lnitaad of 1254. Perhaps this la the basis of your cooiuaioa. I hope that this will serve to further clarify the situation. Ttaui. you for your assistance and cooperation. SLacerely yours, J, C. CaLandra President _ 1007; G 0213b HARTOLDMONOOI8O66 IXC'JIRY Fr.C'A VAPCR CORPORATION Oii TOXIC EFFECT CF CHLORINATED ElPHENYL J. I. ?.cdir -- C.-._ ~ AGO a - A HR C,i Stan forv/ar-dad to me the note you received frcm Id gustaf = .-.s ;,ic accompanying letter from ?. Pujiwara, Managing Director, N'-Con Vapor Generator Company, and to H. J. Schicxedanz, General Manager, Vapor International. V/e have been advisee by our Ja.pa.nese representatives of the bran oil poisoning of cuite a numoer of Japanese citizens that uas attributed to Kar.eclor bCO (cnlorinated biphenyl comparable to FF.-2) . He assembled both medical and application data and sent it to our Japanese counter-parts as arguments Tor the safe use o." chlorinated biphenyl heat transfer fluid. Essentially, v/e said that there are certain toxic and systemic effects that can be brought about by the vapors of chlorinated oinr.cnyls. We did not rule specifically on ch^ ir.Jestlon lit.itr of this chemical. We also directed attention- to'tr.e iar-c r.umoer of applications in food processing that utilize The11 PR heat transfer fluid. V/e Drought out very strongly c.-.c ftet that these systems have been designed to minimize accidental contamination of food products with chlorinated biphenyls. I think we have a good track record here in the States us in.; Thcrnir.cl PR in these applications. However, it only uscro" a r.:atter of time until the regulatory agencies will be look ing cov/n our throats regarding the use of this material. Pcssibly, by the time this comes about, we will have ccmpluted feeding studies with chlorinated biphenyls that vein ailow ut more exact data than has been available in the pact. As a matter of fact, .they're feeding this stuff to chic^uns r.ov/, but I have no specific results of these teste. I can only suggest that you attempt to put Gustaf'3 mind at case regarding the ''toxic" aspects of these chlorinated biphenyls by playing down the medical reports and playing up proper system design. Look at the bright side for us in the heat transfer fiuui cr.s of our business -- if the government closes us dov.n on tno use cf chlorinated biphenyls, we have two excellent fluids in Therminol 55 and Therminol 66, as well as, a proprietary fluid In Therminol 77 Co exploit. Therminol 66 will cartel.-. ly be available in Japan according to recent information from our Engineering Department. HONS 096865 HARTOLDMONO018067 r February 14, 1969 Page 2 A final caution Jim, please use the attached information v/< -* some discretion. X certainly would not pass completed 3ets~of tthheisedsasteanttioal thpoosientsasfkroinmg tthheis qduaetsat,ionnsa,meblyu,t rthaetherurlienjgc*t-aonc*-' vapor limita as handed down by the Industrial Hygienist Assoc*ation, and a strong play on proper system design to prevent * macactiedreianltablyccohnltoarmininaatetiodnboipfhfeonoydlsp. rod_u_c__t_*___a_n_d___p__r_oces_ s*ing Don Roush l MQNS 096866 HARTOLDMONOOI8068 January 23/ 3^*6') AROCLCi'-S IH PLA1M* EFFIAJTJiT . Messrs. ' ' E. G. Wright- - AJaMSTOi'J C. P. Buckley - ICTvUM-iRICH . K-P-I-D-E-lj.-T-1-A-L Ct Mess r: V. R. R.tcburd V/. A . Kuhn D. 13. Hosnfor E. S. Tucker E. IJ. Wheeler G. L. Bratsch V/. B. rapagoorge D. V/. Jackson/ B. H. Williams - VIRICH - W' Wifi*'lim"' - Dnrv;;-; - S. 2W:: - EV.'KEr: - KRl'/ihg - AK.TIS'f ~ KRUi'lin J. C. Landwchr/ - AWNIST W. Tftffec With the .likelihood that the attention nov: being focused on presence of arocloro in natural waters will drav: attention to any aroclor being sewered in our production plant outfalls v/e should begin to protect ourselves. Since the problem any, has not yet been defined, I'm recommending at this tim-> only action preparatory to actual clean up. Please arrange" for the following: ` 1. Waste samples -- Bafore any clean up action of any kind is taken, v;e need to know, at least approximately, how much aroclor we are discharging into natural waters via our waste outfalls. : V/e do not presently have techniques for analyzing fox- ax-ocior3 m low concentrations, It is expected that these techniques v;ill be developed by late this coming fall. Therefore, please collect,, freeze and hold indefinitely three 2-3 liter samples of your out fall as it is discharged to natural surface waters (enhance to Snow Creek at Anniston; outlet of Village waste treatment plant at W. 0. Krummrich}. Scott Tucker, vrho is developing .the analytical procedures suggests use of polyethylene bottles. Samples should be taken several days apart and should represent normal conditions, including one sample taken at peak loading (e.g. after . dropping spent aroclor from F2S5 heat exchanger at . V/. a. Krummrlch). 2. In addition to collecting the samples, commence collect ing data on points and amounts of aroclor discharges to sewer3 and means of disposal alternate to sewering. This information will help permit us to move rapidly in case a crisis develops. Do not proceed with abatement projects at this time except as in (3) below. Publish report on information developed along vrith roughly . estimated costs. June 1, 1969, appears to be a reason able deadline at this time for the report, but this could change drastically. T ) HARTOLDMONO018069 Monsanto O'* s<( - aart - '---O -------- o. a. RaatHgton ~'cria - u~u9ia-------- February 26, 1987 SCMBCC Environmental Status -- Anniston Plant TO : R. C. Potter/C4NH M. L. Reding/C2NA MAfl 02 & H. J. Corbect/DID R. L. Fields/C2NJ R. 1. Harness/C2NA 7. T. Mattaucei/GSNR. D. D. Mickelson/C2NA The acacua of environmental programs and Issues at the Anniston Plant was reviewed with Mr. Hal Corbett on February 26, 1987. In view of the present indicated direction of transferring taanagemenc responsibility for the plane from MAC to MCC, our objectives were to inform Hal of the present environmental setting and direction of the plane and to ascertain any corporate environmental reservations or concerns relative to that transfer. Dennis Redingcon of MAC Environmental Affairs reviewed plant status vs. our Internal guidelines, and discussed on-going activities to further advance environmental programs ae the plane as part of the 1987-88 project for site consolidation -- given ehe demise of paraehion manufacture ac the sice. Site consolidation is funded by the MAC restructuring reserve and is expected eo leave an unexpended variance of about 92 H La the environmental sector of the reserve. In addition to coses for consolidation, MAC expects to incur on-going costs in the range of 1400 k per year for environmental remedial requirements. Copies of Denny's presentation materials are attached. A number of future potential environmental issues were identified, which will require continued monitoring and sensitivity. Hal agreed, however, that the plant's assessment, program and corrective action efforts are doing about what should be done given our understanding of site Issues. It is further understood that cost3 for remedy of any future environmental Issues chat emerge will be borne by the operating companies in proportion to cause. Ve should continue to maintain a cooperative interaction with the regulators, and to be responsive to local community attitudes to stay ahead of and defuse these future concerns. DSR-MAP:jb OSW 119459 HARTOLDMONOOI8070 ANNISTON PLANT WORLDWIDE GUIDELINE STATUS WATER ASSESSMENT AIR ASSESSMENT NO NPDES VIOLATIONS 2-7 TSS VIOLATIONS/YR 1-4 AIR EXCEEDANCES/YR NO CERCLA REPORTS 6/84 PLAN ESSENTIALLY CURRENT NEEDS TO BE RE-DONE 2/6/87 REVISION POTW FLARE BYPASS IN ESSENTIAL COMPLIANCE WITH ACUTELY HAZARDOUS/ INCINERABLE TIMETABLE ACTIVE SUPPORT OF HAZARDOUS WASTE DATA BASE/REDUCTION LAST ENVIRONMENTAL AUDIT - 4/8S LAST GROUNDWATER ANNUAL REVIEW - 10/84 LAST ASSESSMENT UPDATE - 1/83 I/M PLAN FOR UG STRUCTURES - 6/28/8S 6 OP'S USED AND LISTED MINOR USE _____ 5/6 ASSIGNED TO OTHERS AUDITS ESSENTIALLY CURRENT (10/86-5/88 NEXT) 5/6 UNDER CONTRACT 0SW 119460 HARTOLDMONO018071 ANNISTON ENVIRONMENTAL REVIEW ENVIRONMENTAL ELEMENTS OF SITE CONSOLIDATION DISMANTLEMENT - 12/87 4 PCD TRANSFORMERS ' NUCLEAR INSTRUMENTS UPGRADE 1600 FT. SEWERS ASBESTOS, P4, MAT'LS DISPOSAL DECONTAMINATION FOR DISPOSAL/SALE CONSOLIDATE WTP CONTROL ROOM MODIFY RCRA DRUM STORAGE ' RCRA CLOSURES LIMESTONE BED - 1/88 LANDFILL - 6/88 '_ $_JK 50 6 383 111 120 ' 92 IS 104 ISO OSw 1 L 9 <* 6 1 HARTOLDMON0018072 PAGS 2 3. RCRA REMEDIAL ACTION LIMESTONE BED - 6/88 OLD LANDFILL CELLS - 12/87 US 10 Q 90 4. ADDED MONITORING WELLS - 12/87 3 RCRA (DEEP) 4 VOLUNTARY (2 DEEP, 2 SHALLOW) / SO 5. PCB REMOVAL -- SNOW CREEX ERA? 6. EXCESS WTP OPERATION TO FACILITATE SHUTDOWN . 1370 7. SHARE OF PROJECT ADMIN BUDGET ESTIMATE RESERVE ALLOWANCE PLAN VARIANCE " 315 2996 4900 1904 QSW LL9<to2 HARTOLDMONO018073 ANNISTON ENVIRONMENTAL REVIEW EXPECTED MAC COST BORDEN FOR ON-GOING OPERATIONS . 1. LANDFILL POST-CLOSURE MONITORING 2. LIMESTONE BEDS POST-CLOSURE MONITORING 3. LANDFILL AND LIMESTONE BEDS REMEDIAL ACTION 4. CONTINGENCY (FUTURE PART B NEEDS) / S K/YR 17t gi 300 ' 74 S400 1 COVERED BY RCRA ACCRUAL DSW 119463 HARTOLDMON0018074 ANNISTON ENVIRONMENTAL REVIEW FUTURE POTENTIAL PROBLEMS 1. CHLORINATED HYDROCARBONS IN GROUND WATER 2. DEEP GROUNDWATER 3. OLD FERRO-MANGANESE LANDFILL 4. POTENTIAL FUTURE MOBILIZATION OF SOIL CONTAMINANTS PCB'S MERCURY ORGANOPHOSPHATES PNP__ OTHER RESOLVED: ANY FUTURE ENVIRONMENTAL COSTS TO BE BORNE BY. OPCO MOST CLOSELY RELATED TO CAUSE DSW L 19464 HARTOLDMONO018075 DATE 4/82 3/83 4/84 5/85 6/85 2/86 1 ANNISTON PLANT CHLORINATED ORGANICS IN GROUNDWATER WELL MW-7 MW-a, 9 PPB FOUND 11 1,2-DICHLOROETHENE 48 TRICHLOROETHENE -------- CLEAN MW-7,8,9 MW-7 MW-8 MW- 9 -------- CLEAN -------- CLEAN / TR 1,1,2,2-TETRACHLOROETEANE TR METHYLENE CHLORIDE MW-7 7 1,2-DICHLOROETHENE 18 TRICHLOROETHENE 29 1,1,2,2 -TETRACHLOROETHANE PROD'N 5 4 10 31 TR CARBON TETRACHLORIDE CHLOROFORM METHYLENE CHLORIDE TRICHLOROETHYLENE BENZENE PRODN NO 3., 4,4 282,41,13 9,16,16 8,6,6 CARBON TETRACHLORIDE CHLOROFORM METHYLENE CHLORIDE TRI CHLOROETHYLENE BENZENE . 1 THREE SUCCESSIVE SAMPLES QSW 119^65 HARTOLDMONO018076