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H. S. BERGEN - ST. LOUIS SEPTEMBER 12, 1969 DEFENSE OF AROCLOR * FUNCTIONAL FLUIDS R. M. KOUNTZ V. A. KUHN- 0L50& Please find attached a rough draft from Dr. Richard to Elmer Nheeler regarding Aroclor toxicity. I would appreciate your comments to both Dr. Richard and myself regarding this draft. H. S. BERGEN ms DSW 387993 STLCOPCB4101240 \/ C^C^.v^rs 4 j^i'* J<J^ A. ,ct~clfcj/Tij f W) DS\N 387994 STLC0PCB4101241 W.FROM tNAMf. A LOCATION) R. Richard - Research Center DaTL SUOJLCT RCfEfttNCt September 9, 1969 DEFENSE OF AROCLOR onnrs---------------------- TO E. Wheeler - EWHEE P. Hodges, PHODG General Policy j Make the Govt., States and Universities prove their case, ( but avoid as much confrontation as possible. Comply and work with public officials to meet or~exceed requirements V ahead of time. -Adverse publicity and competition are the real weapons. . Analytical fin Air - Which Aroclors are present? Where?J for Aroclor LIn Water- Which compounds-? > Govt. , [in Animals ^interfere? . j Agencies Keep track of how much contamination - which sources. Prove Bioharmful - Let Govt, prove'its case, on case by case basis. - ' `V Monsanto Visit-Govt. Biolabs - in search of toxicological experiments and evidence ' vs. Aroclors to keep up with progress. Monsanto Prove Bloharmless - Limited work at Ind. Bio-test - "Safe" toxic level for man mammals via fish . ' Rats Seek evidence of Biodegra- Chickens dation Pish Question evidence against us. Question shrimp toxicology . especially other toxic chemicals. , If Aroclor bad, others . must be worse. . Probable Outcome We can prove some things are OK at low concentration. Give Monsanto some defense. . We can't defend vs. everything. Some animals or fish or insects will be harmed. Aroclor degradation rate will be slow. Tough to defend .gainst. Higher chlorination compounds will be worse _n. _ower chlorane compounds. . Therefore vie will have to restrict uses and clean-up as much a_s__w_.can,. starting immediately, h osW 387995 'V- iO Hi'V 1 I - r.% STLCOPCB4101242 2- - Therefore we will have to work for alternate products in end use applications; for Aroclor production facilities. Clean Up Aroclors and substitute products where necessary and when required,! before threats of publicity and competitive activity over- whelm.us. . . Water Pollution seems to be first issue . Aroclor product is refractive, will settle out on solids - sewerage sludge - river bottoms, and apparently has a long life. . Florida or Gulf Coast - Aroclor 1254 - Aroclor 1260 present issue. 40-200 ppb - causing problem at Pensacola (Monsanto) in plant effluent-causing " with shrimp. - can't risk shut-down of plant. Federal and State can extrapolate to other plants in . Gulf area. San Francisco - Aroclor 1254 and 1260 . Reported Aroclor to be present in San Francisco Bay. Reported to be thin egg shells in birds - Lot of screaming - .. Great Lakes Warf studies on DDT Aroclor 1254 will be found*. Aroclor 1242 will be found? Air Pollution - Possible spread - but less of an issue . Af s.' right now. Jz Analytical work more difficult. Jj L,'-<- / S'v Direct Contact with Product j A* A ! 's'ffAA' Doesn't seem to be an issue - except for food heat transfer.- fc* -. We don't believe Aroclor is being used as carrier for insecticide - sprayed around - '; '' ' . .. . !; We are not positive but most uses are "closed" systems;! or products used in solid plastics, or adhesives, or H sealants. ,v ^ K'/ ; DSW 387996 STLCOPCB4101243 F. Fluids ___ Product Hydraulic Fluids - Air Compressor Fluids Heat Transfer . Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutior Customers Plant Operation by Customers P " . . . Yes, leakage external ' ' Possible - See Johnson Motors Castings. Yes, leakage external Leakage into produc Yes, leakage external Leakage into produc Yes, leakage from plant .. In product but - Scrap materials. , closed for end use* No, Should be clean. Yes, Reworked trans formers . In product but closed for end use* * Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ** Need to take care of Aroclor in discarded transformers. Product' could be drained and reworked. Probable Conclusions Hydraulic Leakage . - Product could be caught at machines but will take a lot of clean-up work With customers. Will have to have replacement product - with less-sensitive components.. Work from this base on clean-up to prevent more pollution problems. Air Compressor Fluids " Hydraulic Fluids ' . Must expect "shrimp" experiments, . West Florida State, to be "aired" sometime soon; next few months. This will lead to bad publicity . and competitive action vs. all Pydrauls. We will have to try to confine to . Aroclor 125^ and Aroclor 1260. DSW 387997 STLCOPCB4101244 We will have to take action before that time. Gulf Coast - Action Wv Richard Fallon/ Richard Be able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in 2 month's time before Nov. 15, 1969." . Have trial product in hands of Gulf Coast accounts and distributor before Dec. 15. | Fallon I Suggest possible buy of "all phosphate" ester from Food Machinery. . Use this as one trial fluid MCS for insurance Richard/ . Suggest possible substitution of Aroclor 5^2 for Aroclor 1254 in hydraulic and compressor blends. E. Wheeler judges lower order of toxicity and solubility for 5^2 series. Have to test product in pump test for deposits. Fallon/ Richard. Suggest field trials of our own all-phosphate ester. . . '. Fallon/ Kuhn/ Kountz Work with large customers to clean-up streams. Bring in Findett as mfg. partner in the recycle business. Get money out of recycle operations. Inland-Waterways- Wheeler/ Richard Be close enough to Great Lakes studies to judge situation. Are there animals which are being affected by the concentrations found? sRichara ! Be prepared to replace.Aroclor.1254 and Aroclor 1260 In 4 months in hydraulic fluids and In air compressor fluids. 1 iRichard V Be prepared to replace all Aroclor 1242 or 1242 . In 6 months in hydraulic fluids. This means . replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. DSW 387998 Heat Transfer Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to wrork with customers on clean-up* . Fallon/ Rouoh Need to replace FR especially in food or sensitive product aro&s whpre the product is getting into water. Sec.- dish washer compounds. See letter E. Wheeler to T'. Fallon. la vo la vo Vie have possible rep cement products in Thermin-v' . . .. , Thermin... STLCOPCB4101245 Action Kuhn Kuhn/ Fallon Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. Hz and terphenyl supply may become short. Switch customers to Therminol 55 or Therminol 66 ahead of pollution problems in customers plant. Work with customers on plant, and dumping practices. . Findett already set up to rework. Need to make them a manufacturing arm. We get sale of recycle-rework fluid.- Capacitor Capacitor plants have re Fluid's- purification and recycle systems but up to of product can be lost by poor plant producers and off-quality material. Mkt. Benignus/ Bryant 5$ 0 pro{3Uction. COuld be Ene -Kountz/ lM" iWyear. This is a big MfllHod^s *> pollution we are trying now to guard against. Capacitor products Enclosed in A1 or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product for a time. Action Eng.,TSDPlant Pol lution Con trol Hodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. Vie have set-up to accept material for rework into hydraulic fluid but this relocation is not a satisfactory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical. Must start now to get con trol of off-grade material. Recommend replacement of .future Aroclor business with other products. Have 2 years, . .. ' Action . ~ Monsanto must help plant clean up of customer plants decantation, coalescing., adsorption, cis . posal of adsorbent or recycle of cn o ~ 1 v ' Monsanto badly needs "know-how" for clean-up. Monsanto should seek Govt, contract money for clean-up research, (See MRC R. Binning, D. Nelson) . _ DSVN/387ay STLCOPCB4101246 6- - Transformers Action Benignus/ Bryant Transformer Plant can operate in a clean, efficient manner . with recycle of off-grade Product transformers Aroclor. can remain closed and . no exposure for 25 yrs. Should advise disposal of filter element materials so '. as to minimize chance of ' ' water pollution. Incinerate': y. or dispose. . J Should try to retain Reworked transformers pose business by clean-up $ a threat if the. Aroclor is by -education of cus- dumped Into a water stream. tomers. . Action Benignus/ Bryant Should try to minimize chance of dumping "old" fluid by reworking and by educating co. shops and collecting product for rework or disposal. Dalton Is set up in England to rework electrical grade fluid. Kuhn/Kountz Findett? Need rework facility here + disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of .chlorinated biphenyls at Krummrich or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. . " Action - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try r to reduce to ppb level. . P.Hodges-Seek a Govt, contract on adsorption and incineration TSD cycles - MRC. . Engrg.- .' Kountz Take samples of streams and river water and mud . evidence for before and after clean-up. Samples _can be stored for further analysis if we can't keep up current with analytical determinations. Apply Monsanto cloan-up methods to customer plant DSW 388000 STLCOPCB4101247 Action Engrg. & Mfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at 1-4m Ibs/year, exclusive of cleaning up river "bottoms or outfall bottoms. . .' . Hydraulics 20% of 4m lbs Heat Transfer 10% of 2JT lbs Capacitors '5$ of 20M Transformers 5% of 15M" . 800,000 lbs 200,000 lbs 1,000,000 lbs 750,000 lbs 2,750,000 lbs Central Eng. & Mfg TSD Kountz & Kuhn Set up an incinerator to handle Aroclor dis-\ f: j or-J- posal - preferably one which will handle \ solids such as muds - slurries as well as \', liquids. Have in operation within 12 months. //-' Ideally have incinerators available different. y sections for disposal. / , k Possible help from MRC Chronic Toxicity Studies - Xnd. Bio-Test Wheeler Keller Ind.Bio- Test Continue studies to establish FDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Aroclor in tissue. Try to see if Aroclors are changed metabolically. Does concentration level off, decline if feeding Is stopped? Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Aroclor levels of toxicity, then we will have to have biological studies on these species to con firm or deny adverse findings. DSW 388001 STLCOPCB4101248 8- - Blodegradation Studies Set up rate of biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 . . Aroclor 5^2 vs. Aroclor 5460 Swisher Chlorinated diphenyl ether .= Chlorinated paraffin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 . Baxter Contact Baxter and Lidgett at MCL regularly for results on Lidgett Aroclor degradation. They are reported to be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. ' VJRR:ms W. R. Richard DSW 388002 STLCOPCB4101249