Document bO0w73gKLNoKRpXjqkNO648e3

uy THE PC3-POLLUTION PROBLEM January 21 and 22, 1970 St. Louis Heating Wltn General Electric Co. I tI GENERAL ELECTRIC REPRESENTATIVES: ' Hr. Edvard L. Haab, GS Pittsfield# Haas., representing all OZ locations Hr. H. Gerade, GB toxicological consultant Dr. K. Murphy, GS Schenectady# New York, Environmental Pollution Control ' MONSANTO REPRESENTATIVES: H. S. Bergen, D. A. Olson, S. P. Wheeler, Dr. V. R. Richard, Dr. R. H. Hunch, Dr. R. Keller, Dr. S. Tuclcer, V. B. Papageorge, J. 0. Bryant, P. 0. Benignus A. Presentation and Discussion of Published Articles About Chlorinated Aromatic Hydrocaroon Insecticides, |)Jo etc. ) and PCBs Hr. Wheeler presented to Hr. Raab a booklet containing most of the pertinent publications, to dace, and Indicated that additional articles will appear shortly. ,_ He mentioned that manufacturers of DDT and chlorinated aromatic hydrocarbon Insecticides will tend to emphasize the finding and interference of PC3s as the Government hearings limiting or banning use of the Insecticides are held. . This lead GB to seek understanding of the scope, reproducibility, reliability and validity of the analytical procedures used by various Investigators who reported finding PC3 In concentrations as low as parts per billion. ' 'j I i i | ; ! ' : ; B. The Analytical Procedures Drs. Keller and .Tucker presented details of Monsanto's GLC - Mass Spectrometrlc analytical capability and apparatus, as portrayed in Table 1. The sophistication of our analytical capability was emphasized to assure that our approach la the ultimate and is not surpassed. On this basis our views of the validity of results given In various publications are Indicated In the attachments to Tablo 1. Cenersl Slectrie were impressed and completaly satisfied with the scope of our analytical capability and work. z PLAINTIFFS 1 o EXHIBIT GO in. 7 z a. PRR 022199 SCf* 037*21 DEPOSmON EXHIBIT WATER_PCB-SD0000017461 s {! -2 ") C. Blcdegradeablllty of PC3s Mr. Wheeler related that while Arcelor 1254 and 1250 are being round, ispeelally In aquatic environment, the lover chlorinated biphenyls are not being observed. It Is anticipated that the lower chlorinated members may be largely blodegradeafcle. Drs. Richard, Keller ar.d Tuelcer discussed bicdegradeablllty studies by Monsanto at Ruaeon and elsewhere. These studies appear preliminary and not conclusive. Much more needs to be done In this area to allow - to draw conclusions. Since the literature Indicates that trichlorobenxene and trltetrachlorcbenzene are net susceptible to biodegradation, are Intrigued with the absence of reports about .finding these materials In the -environment. The obvious Implication Is that since these materials are used with the higher chlorinated PCBs found -- the source of the latter Is not from dielectric fluids. However, It was reasoned that chlorobenzenes may not remain due to their relatively higher vapor pressure or may not be found to date because they have not yet been zeroed In to the analytical spectrum. D. Status of Aroclor Studies At Industrial 310-Test. Table 2. In essence results reported by Mr. Wheeler on chronic animal toxicity tests and animal reproducibility studies underway are not as favorable as we had hoped or anticipated. Particularly alarming Is evidence of effect on hatchabillty and production of thin egg sheila regards white leghorn chickens. The studies Involved Aroclor 1242,-1254 and 1250. Some of the studies will be repeated to arrive at better conclusions. S. The Location of Aakarel Transformers. Table 3 Messrs. . and Senlgnus formulated Table 3 to portray the use and locations of aakarel. transformers throughout Industry and our commercial and residential areas. Cn discussing these aakarel transformer applications was most impelling and forceful about the non-replaceablllty of transformer askarel fluid and the critical or essential use and need for askarel transformers, which have safety from fire as their outstanding virtue. Without dwelling on details and instead carried to the ultimate, the concensus Is that without availability of askarel transformers large cities like Hew York would be shut down with no power. Certain Industries that rely mainly on askarel transformers would go down with no power. Without Aroclor capacitors most of the lights across our country would go out and motors in air conditioners and many Industrial applications would not run. PRR 022200 SCM 037622 WATER PCB-SD0000017462 o 3 .J 'V J Prankly, no on* could think of a suitable replacement for transformer askarel fluid. Fortunately, Aroclor 12ft2 with promise about biodegradeabllity is usd in moat all of Che . Aroclor type capacitor*. Moreover, possible favorable laomer rearrangements are foreseen In the case of Aroclor 12ft2. Heed to control, accumulate and properly dispose of scrap askarels Is unquestionable In light of'the PC3 pollution problem, and essential toward maintaining the use of askarel dielectrics. At alone apparatus In which askarel fluid Is used represents 100 million dollars annually. About Sojt Is In the capacitor area and ftOjS represents transformers. requested and we were pleased to give _ _ their Environmental Control man, a Hat of all and other locations receiving Pyranol shipments In 1969. This amounts to about 16 million pounds of askarel fluids with economic worth of near 2.5 million dollars. This listing Included 2ftft different locations of which 115 were plants and service shops scattered throughout our country. Of course In addition to dielectric use In hermetically sealed capacitors and transformers major amounts of FC3a are used as Plasticizers, Industrial Hydraulic Fluids and Heat-Transfer media. Environmental Sources of PC5a From Dielectric Applications 1. Spills ' 2. Disposal of waste 3. Ultimate disposal of product -- for failed apparatus ft. Ventilation of operation for employe protection 5. Vasts from containers 5. Field on service failures 7. Repair and return apparatus "service shops" Considerations of Degradation Disposals 1. PC3a up to and Including 3 chlorine atoms appear biodegrade- able In preliminary laboratory work. 2. Thus far there Is no evidence that higher chlorinated biphenyls will biodegrade. PRR 022201 SCH 037623 . . ' . ' : j I i ! j i WATER PCB-SD0000017463 3. According to ths literature TC3 and TTC3 biodegrade at a vsry slow rats. 4. Chemical, catalytic brealcdcwn would probably require high temperatures. - 5. Incineration will require 800*C. and 5 second sojourn time. HC1 scrubbing would be required. H. Estimated Annual Amounts of Contaminated and Scrap PC3s Prom The liectrical ir.Quatry ! c------------------ - 1. Prom The Transformer Industry; a) In plant and field spills are small and controllable with adsorbents, which snould be Incinerated. b) Near 2 million pounds a year of transformer asicarels are sold to service and repair shops. Thsae people do not manufacture new transformers, although on occasion they may fill new transformers sent Into the field without fluid. As these service shops are devoted primarily to repairing faulty transformers, we can assume that as much as 1.0 million pounds annually of "scrap" is generated. Most of this has been dumped or disposed of In streams. . e) We estimate that probably 150,000 pounds of this Is ' arced beyond reworking and needs to be incinerated. The remainder may be reworitable by distillation. 2. proa The Capacitor Industry: , a) Collectable waste from normal capacitor Impregnation operations amounts to about 850,000 pounds annually. Most of this should be reworkabls via simple take-over distillation. b) Scrap, badly contaminated with polypropylene, epoxides, solvents, oil. grease and "Junk" Is generated at not over 50,000 pounds a year. This material should bs Incinerated, along with the 150,000 pounds of scrap from transformers. ' e) Power capacitors are designed to last over 30 years. Modem motor runs may last 10 years and the small lighting ' ballast usually last not ovar 10 years. Eventually and cumulatively there Is a large potential of field-failed capacitors. Portunataly Aroclor 1242 has bean used almost exclusively since about 1950. ' PRR 022202 SCW 037*2* WATER PCB-SD0000017464 o -5- 3 The failed unit* are disposed of In Industrial dumps. In ease of ballast* the Aroclor capacitor along with . the transformer Imbedded In asphalt or encapsulated ' In epoxy resin, all encased in a metal box are discarded as a unit. This Is emphasized to Indicate that Incineration of such apparatus Is not applicable. . 3. Proa Containers; Most askarel moves in bulk, tank cars or tank wagons, which do not present a problem. _ It Is questionable that drum shipments may present a problem. The drums can be used for returning scrap. Monsanto's Program To Handle Scrap 1. asked what Is Monsanto's plan about reclamation of scrap . PCS froa plants, service shops, utilities. Industrial users. commercial users, ete.? 2. What Is our view about a "Buy-Back" arrangement? 3. Wnat arrangements will Monsanto make for Incineration? Disposal In suitable land-fills? Reclamation by distillation at Monsanto? "* fc. To date Monsanto's posture Is: a) We have taken "good quality" scrap from capacitor plant at and had It reworked by simple filtration at Plndett. This Plndett arrangement is not practical nor economical. Ve paid 1 i/lb. for this "quite good" Arcelor, plus 1.9 ^/lb. freight. Plndett charged 2.1 i. to filter this material, making our cost- 5 */lb. b) 130,000 pounds of somewhat lower quality scrap froa capacitor plant has accumulated at Plndett for lack of distillation equipment. . e) Scrap froa plant appears to need - reprocessing by distillation. d) About $ million pounds of "bad serap" froa , has been disposed to a land-fill In New Jersey. Monsanto paid half of the freight cost. e) A car* load of serap transformer askarel froa * , Virginia Is being sent to W. 0. Krummrieh. for reprocessing. PRR 022203 SCH Da?62* WATER PCB-SD0000017465 o -5 - J r) We advised Co incinerate 12,000 gallcne of all contaminated askarel. : g) We talked with Sangamo, Plcken, S. C. and strongly urged them to discontinue present disposal. . i 5. The above ''take-back" arrangements have been made on an Individual and experimental basis. We have no fixed "bu7- back" arrangement, regards answering question. : ; 6. We have no established process for reclaiming either capacitor or transformer scrap. , 7. We have no Incinerator for disposal of totally unreelaimabla material. . : . i ' . 8. To date and for the foreseeable future our only effective disposal la to a land-fill. While this Is not deslreable# It Is better than Indiscriminate dumping. . i ! Transformer Askarel 31ends -Discussed With . Table A. Table lists the transformer askarel blends reviewed with . 1.. has discontinued use of 31end A due to combustibility of arc formed gas. For this same reason; as dictated by their legal people they will not use 31end 3. 2. Today both and . use Blend C (Pyranol A13333), which they mix themselves. 3. Blend D optimizes the Arcelor concentration In conformance with requirements for ncn-ccmbustlblllty of the arc formed gas and with the pour point requirements. The price Is In direct conformance with our previous quotation for Aroelor 12^2, when was using this at a concentration of S0% by weight. PRR 022204 oV*6** sen WATER_PCB-SD0000017466 o 7 Accordingly 3lend D meets requirements, although containing Tl.if cf the higher chlorinated Aroclor It does ntc ecnform with Konsanto's concern with Che PC3 pollution problem. , 4. Per all practical purposes 31end E (inerteen 70-30) la Identical properties with Blend D, which latter . proposes so use. In the Interest or standardization, we seeic to tare , at use 31end S, which is used by for lew temperature applications and la used by cany other aslcarel tranafercer narufacounens lor general application. 5. Although USA uses 31end P (lZO% Aroclor 1242) for ail applications, except for low-tenrerature application, does not accept this use of 100J8 Aroclor. 1242 in transf oroers. will oot accept Aroclor 1242 or ary other blend with less than a 1 to 1 ratio of chlorine to Hydrogen atoms. A ratio significantly lower than 1 to 1 tends to yield conoustioie are-fomed gashes. feels strongly that this does root confers with the original definition of an asVcarel. Accordingly their legal people stress that this presents potential liability in case of an accident for which various precedents have already been set In court actions. points cut that this precedent fot* liability regards ccroustitility is already set, in contrast with the PC3 pollution situation which thus far is void of legal actions. He reiterated that the pollution problem thus far is a source cf technical cur Ideations and warnings and enphasized that in the case of electrical applications wnlch involve only herretically sealed apparatus, adequate control should be possible. Pacts As Agreed Hr These In Attendance 1. CI5 - C5_3 Biphenyls -- found in aquatic eco system in populated asd industrial areas. 2. DOT Cl hydrocarbon insecticides have effect cn fish-eating birds (reproduction) leading to possible extinction of scae species. ' 3. PC3s fsost) are definitely suspected along with polychlorinated hydrocarecn Insecticides. 4. Pesearch data being developed seems to confirm incrimination of ?C3s rub feet to rechecJdng. . 5. Public, political and government pressures stopping some uses of cnlcrirated hydrocarbon insecticides (PCHlJ. PRR 022205 SC* 03T62T WATER PCB-SD0000017467 u 6. PCBs have been brought Into hearings proposing restriction* or elimination o_ f DOT, PCXX. ' 7. As manufacturer of PCHT's fight for thslr life, attention will be directed to PC3s. ` 8. To our knowledge PCBs are not being found In terrestrial birds cr animals, but DOT and PCHI's are found. 9. PC3s art not being found In the eco system without the presence of DOT or PCHI's. 10. PCHI's residue are found without PC3s. I i i ! j i | 11. Ve have no evidence that anyone has found lower PCBs except that Dutch researchers found PCBs in roaches. I 12. There Is no evidence of natural sources of PCBs nor any source other.than industrially produced and used. ' 13. PCBs In a- single dose have a low order, of acute toxicity and are no significant problem to rats, degs, chickens, fish and humans. 14. Based op six months of chronic studies In rats and dogs some PCBs are ' moderately" toxic and mere so than DOT, but less toxic than sore of the other chlorinated hydrocarbon insecticides. ' -. 15. Some PC3s affect rat reproduction, (10 ppm. apparent no effect ^ levels). j i ! 15. Some PCBs affect leghorn chicken reproduction (100 ppm.). PCBs have no affect level for chickens, estimated 10 ppm. 17. Some environmentalists are claiming that the PC3a pose a . threat to humans, are so "philosophizing" In publications. ' 18. Cne published page Indicates that PCBs are as bad (or worse) than DOT In mlcroaomal enzyme effect. What Is significant? Since many chemical compounds react similarly.' . 19. Human experience In production of PCBs and their use has been favorable. Less than 20 Instances of illness known to Monsanto Company since 1940-45. Proper precautions.were not always followed. ' 20. Company's use of PCBs as dielectric fluids, has been extremely favorable without Illness throughout 40 years. 21. Monsanto Company is convinced that analytical techniques and data from some laboratories Investigating PCBs are reliable and that conclusions being formulated are valid. PRR 022204 . SC,, 03762 ! WATER PCB-SD0000017468 u3 22. Monsanto Company has not ran duplicate analysis on samples reported'in the literature. L. What Pealres . 1. seeks that Monsanto take no precipitous reaction to the PCS problem that would result In withdrawing supply of Arcelor 125^ or 1250 to 2. The consensus Is that no suitable replacement for transformer askarel fluid Is foreseen. 3. In event of development of a suitable fire-resistant fluid replacement for askarel, emphasized that a minimum of 2 years testing work would be required before cocsnerclal use could be adopted. u. In reply to_Mcnsanto's legal question whether with continued use of'Aroeior 125^ and 1260 would assume sole and complete liability -- answered. No' To substantiate his reply, cited case examples Involving where damages were sought and collected, even though was only the third party. He further stated that any arrangement seeking to delegate and confine liability to relative to the PCS problem would be worthless. . 5. seeks to know the magnitude and time of Aroclor price Increase that would result If Monsanto discontinues sale of Aroclor for non-electrical uses, or If pollution control expenses warrant a price Increase (as anticipated). 6. seeks to send a letter to their plants and service shops ' and major users of transformer askarel, such as the ' utilities giving notice of the PC3 problem and guidance about the most suitable controls. 7. In the ease of service shops scattered throughout our country It Is unrealistic that these people would assume any- expense to return scrap to Monsanto. The minimum we can expect is that Monsanto pay the freight charges, and relaourse for a suitable container-to avoid additional and excessive contamination. This emphasizes need for Monsanto to have an. effective reclaiming process. Otherwise, the best we can expect from service shops and many ether users Is to continue to dump In a land-fill and stop discarding Into the sewers. j f i ; i I j ; ; : . PAR 022207 SCM 03762* WATER PCB-SD0000017469 .y -y ) 10 8. realizes that Monsanto la caught bstween- the explosiveness of arc-forced gaases problem and on the other hand the PC3 pollution problem. Realizing possible unfavorable outcome of the are-formed gaa problem, desires to withhold the PC3 problem from involvement at NEMA. AST*. I2ES. EZI and ASIA at this time, (making It an Industry-wide problem) pending better ln-depth understanding of the FCB problem. 9. strongly seeks to continue manufacture of askarel type transformers, because In many applications this apparatus cannot be replaced with mineral oil nor open dry, nor seal gas dry type units. ' Mineral oil burns. Open dry accumulates dust, lint, moisture and can then fall with explosion and burning. Sealed gas dry types are very expensive, space consuming and very difficult to. maintain sealed. Transformer design and application Is governed by Rational Electric Code, by local building codes, ?lre Underwriters, N2MA, IEEE* ASTM, XEC, ASA, Insurance companies and others. Because of the diversity of organizations Involved a directive to discontinue askarel transformer manufacture would assume highly complex proportions. r I' I i I i P. a. Beni gnus January 26, 1970 PRR 02220S sen 037630 WATER PCB-SD0000017470