Document dDn6EEE7KBOmJvevpEv4QqdkB

W. B. PAPAOBORGE - ST. LOUIS December J 1970 PCB ENVIRONMENTAL' PROBLEM NOVEMBER STATUS REPORT { H. S. Bergen J. Mason . - J. E. Sprlriggate P.J.A. Marsh W. S. Clark J. R. Dari and M. W. Farrar - E. V. John R. E. Keller - R, M. Kounts T. L. Dos sage P. S. Park W. R. Richard J. R. Savage E. P. Wheeler BRUSSELS TOKYO 2nd Street 2nd Street MARKETING} NCR appears to be making very satisfactory progress toward the replacement of Aroclor 1242 in their carbonless reproduction paper solvent. To date, Monsanto has shipped nearly 100,000 pounds of the replacement product - monoisopropyl biphenyl (MIPB) to NCR. An additional 100,000 pounds is scheduled for delivery in January followed by 500,000 pounds in February, NCR is attempting to reach complete conversion by the end of February. Through our Australian organization we have received an inquiry from the Electracity Trust of South Australia. They have recently received corres pondence from General Electric Company, U.S.A., concerning the problems with Askarel Liquid Di electric. As a result, they are requesting infor mation from Monsanto as to the arrangements in Australia for the disposing of contaminated mater ials. We anticipate other inquiries from other parts of the world.. We met with Mr. Katayama of MMK in November. We discussed with him the PCB plans in the U.S. and re viewed the current situation in Japan. As a result, MMK representatives will meet with Kaneka (the other major supplier ofpolychlorinated biphenyl in Japan) to discuss future PCB plans for Japan. COMPANY CONFIDENTIAL TRAN 003094 HARTOLDMONOQ25254 2- ENGINEERING: Incineration - Krummrlch - CEA 2H15 : Plot plana and layouts have been resolved# and process design is oomplete. Design of piping# electrical# and instrumentation are proceeding on schedule. MCS 1016 - Krummrlch - CEA 2417 Customer trials of the pilot plant produot indicated an undesirable high level of low boilers. In & meeting with Research and Manufacturing it was decided to provide facilities in the project for removing a percentage of low boilers as well as the high boilers. The project scope and estimate are being revised# and a revised Data Transmittal is scheduled for submission in late December. Tributyl Phosphate - Queeny - CRA 2371 An early pilot plant run indicated a severe yield problem in the process. Continued studies by Res earch and Engineering have pinpointed some of the problems# and it is believed a substantial yield improvement can be made. Pre-approval funds have been requested to proceed with definitive design. N-C Phosphate - Queeny - CEA 2*151 Pilot plant studies are currently being made on this product# and a project scope report is being developed. Solids Waste Disposal - Krummrlch - CEA 8042 Engineering# Research# Manufacturing, and Marketing have been studying disposal of polychlorinated biphenyls on solids, A test was devised with Enviro-Chem, samples of wastes have been collected# and the test is scheduled to be run Deoember 1, .Preliminary discussions have been held with potential equipment vendors. COMPANY CONFIDENTIAL No new action or reports on toxicity to fish/animals. Court action on suits on ;*ran oil exposure humans continuing with attendant newspaper publicity. Major executives of company which processed bran oil cannot be located. More stringent testing and licensing of equipment using PCB as heat transfer will probably occur for food processing equipment. TRAN 003095 HARTOLDMONOQ25255 -3- NCR-Jap an rejecting HB-40 because they prefer one oil for both clay and resin-type granules and JuJo Paper is definitely svdtchlng to resin-coat. Kureha oil refined from heavy oil cracking bottoms (mixed aromatics of complex nature) is also being tested. MMK is pushing MIPB assuming NCR-Dayton preference for MIPB. No final decision yet. HB-40 also offered by MMK but MIPB provides better balance on bipheny1/terphenyl. EUROPE! 1. The decision has been taken to cease sales to noncontrollable applications in the UK by 1 March, 1971. 2. Sales will continue for all applications in continental Europe until the end of 1971# but reformulated products will be introduced where possible. 3. We will continue to supply products containing PCB's to German mines through 1971 even where reformulated products are available, until approval is gained for the reformulated products, 4. Customers will be informed before the end of November 1970 of this polioy. 5. We have been assured by the other European producers that they will not knowingly Bupply former Monsanto customers in the UK or USA. 6. Bayer have Indicated that they are in agreement with the Monsanto timing for withdrawal from noncontrollable applications, 7. Progil/Caffaro do not yet agree and wish to study the problem further. We have invited their repre sentatives to Ruabon for technical discussion. 8. The UK Board of Trade, through their Marine Safety Department, have proposed that Aroclor should be classified under Class 9, Dangerous Goods, for the purpose of carriage by sea. We will meet with the Board of Trade, in December to discuss this and following discussion with J. T. Garrett will attempt to persuade the Board of Trade to alter the pro posal. COMPANY CONFIDENTIAL TRAN 003096 HARTOLDMONOQ25256 MEDICALt Arrangements were made for Initiating aoute and sub acute studies at Industrial Bio-Test Laboratory for Aroclor 1221, 5432, 5442 and MCS 1016, Sub-acute studies will include 90 day rat and 90 day dog studies and sub acute fish Btudies (according to protocols to be devel oped). Rat and ohicken reproduction and rabbit tera tology studies are being deferred for the time being. Rabbit teratology studies were begun with Aroolors 12*12, 1254 and 1260. PUBLIC RELATIONS} The Anniston Star, Anniston, Ala., obtained figures from the FDA whioh showed unusually high levels of PCB in fish Bamples taken from Choccolocoo Creek. A Star reporter contacted the Anniston plant for comments on the data and information about our PCB production oper ations there. Public relations prepared replies to specifio questions. *0 Plant management convinced the reporter to visit the . plant for a firsthand view of what the plant was doing to eliminate PCB escape to the environment. A factual front-page feature appeared in the Star Sunday, November 22, edition reflecting the value of cooperation with news media planning PCB stories. Quoting both plant management and the Alabama Water Improvement Commission, the feature emphasized the PCB problem was relatively new, was being solved by Monsanto and, at this point, was no cause for public alarm. RESEARCH l , COMPANY Biodegradation Testing - St. Louis CONFIDENTIAL Statistical analysis (t-tests) of the data accumulated to date in the semi-continuous activated sludge (SCAS) testing of the PCB Aroclor products indicates that some bacterial degradation is occurring. The percent dis appearance rates, based on a feed level of 1 mg/cycle, were as followsj MCS 1043---55# (p " 0.05); .MCS 1016-- 11% (p - 0,05); Aroclor 1242--30 (p - 0.05); Aroclor 1254--0^ (p - 0.05) However, the observed decra'datlon TRAN 003097 HARTOLDMON0025257 5 - rates are still highly scattered indicating that the units have not reached a steady state yet. Other physical sources of data scatter are being investi gated. The addition of stirring, modification of the sampling method and the elimination of the LAS from the feed all appear to be steps in the appropriated direction, but have by no means totally eliminated the scatter. SOAS testing of trichlorobenzene (TCB) and Arobromochlor 1232 at the 1 trig/cycle level have been started and analysis of the first samples is in progress* River die-away (RDA) tests have been started for Aro- clor 1242, Aroclor 1254, MCS 1016, MCS 1043, Arobromo chlor 1232, and TCB. Completion of the RDA tests is scheduled for 1-13-71* .* A liquid chromatographio method for the analysis of halogenated terphenyl systems is being developed. A liquid-liquid chromatography system using Zipax Permaphaze (a new DuPont chromatography packing) as the stationary phase and water/methanol aB the mobile phase appears to give sufficient separation to characterize the isomerio distribution of the materials. The system is being optimized for solvent composition and column length. Environmental Program - U,S. Analysis of a second set of Mississippi River fish collected above and below the WCK plant has been com pleted. The levels found in fillets from these fish ranged from 0.2 ppm to as high as 8 to 9 ppm total PCB's, All the necessary equipment for PCB's, with the except ion of two gas meters, required to sample the Enviro-Chem St. Charles incinerator has been assembled and laboratory tested. Ihe PCB bum is now scheduled for 12-1-70. Additionally, analysis of background samples taken at the site 10-29-70 Tor PCB has been completed. Low levels of apparent PCB's were observed in all cases. The PCB analysis of the JFQ September and October sewer water composites has been completed. The levels found, 77 ppb and JO ppb respectively, were higher than in previous months, . * Shrimp from Escambia Bay, fat and liver from a dead pig found near the Anniston landfill, QE plant water samples, Delaware River phthalio acid, and a U.S. Steel plant v/ater effluent sample have also been analyzed for PCB's. COMPANY CONFIDENTIAL TRAN 003098 HARTOLDMON0025258 -6- Partlcle size analysis by microscopy was performed on a solids sample from the Anniston limestone waste pit. Correlations are being developed between particle size of adsorbent and waste retention in the Aroolor waste treatment studies. Aroclor 1121 and 1129 distillation fractions were anal yzed by OC for isomer distribution to compile data for plant design. Aroolor 5442 We recently reported tetraohlorodibenzofuran as a possi ble impurity in Aroclor 5442. Additional work has shown that this identification is not conclusive; tetrachloro- methyl biphenyl might interfere with this determination. Methylbiphenyl has been shown to be an impurity in the Santowax R used to make Aroclor 5442. Efforts are currently underway to develop a reliable method for distinguishing between chlorinated dibenzofuran and chlorinated methylbiphenyl. Environmental Studies - Ruabon Workers at the Tolworth Laboratory of the Ministry of Agriculture, Fisheries it Pood have been studying effects of feeding Aroclor 1242 to pigeons and quail. Their analyses have indicated, what we have ourselves sus pected, that the residues tend to resemble 1254/1260. Discussion with Bailey and Bunyan from this laboratory shows that they now believe that Aroclor 1242 may be a major source of the environmental pollution. They have also "discovered" that reproducing paper of the no carbon type is a potent source of Aroclor 1242 and, although they have not published this information yet, they may wish to do so as an explanation of the presence of PCB in cardboard. Feeding trials using single isomers are also planned by the Tolworth group, who are hoping to establish metabolic routes for the degradation of PCB's in animal organs, A visit was made to the Monks Wood Experimental Station of the Nature Conservancy, but little new information emerged from the discussion. . v Biodegradation - Ruabon COMPANY ' CONFIDENTIAL It has been confirmed that 2,32`, 3', 4, 5'-hexa- chlorobiphenyl is degraded by Cp when mixed with lower chlorine isomers. This has been achieved under less vigorous conditions of flask shaking than previously, which suggests that the addition of the lower chlorine isomers has increased the solubility of the material. We are currently studying a pentachloro-biphenyl. which should degrade, and the 4,4 *-dichlorobiphenyl, which should be resistant, using a similar technique to im- TRAN 003099 HARTOLDMON0025259 7 prove solubility. Hie analytical results are"awaited on these tests. The results of degrading a series of PCB products with Cg until no further change with time can be observed are now available. Subject to limitations imposed by the difficulties of interpretation of the GLC chromato grams it appears that the order of degradability, or the inverse order of apparent residues, is as follows* MCS 1016, MCS 717* MCS 762, Pyralene 1500, Aroclor 1242 Satisfactory progress in the identification of isomers corresponding to the peaks obtained using high select ivity PLOT columns is reported, but development work is still needed on OLS - Mass before this can be util ized. The most recent results on attempts to degrade HB-40 by Co have shown that at low concentrations (5 ppm) con siderable degradation has ocourred. The main problem in this investigation has been that of sensitivity in the analysis, but this problem now seems to be overcome. Pydraul Reformulation Factory Mutual Visit A representative of FM visited the fire test facility November 4 and 5, Tentative FM approval was obtained for Pydraul 625-A, F-9A, MCS 1063 (Turblnol 153A), MCS 1066 (312A), MCS 030T, 050T, 065T, 0115E, Santosafe W/0 15, 20 and 30. All fluids submitted were approved. Pydraul 312A A VI05C pump test on MCS 1066 indicated excellent lubri city. A tentative process will be issued shortly. Pydraul 540B Hie terphenyl version is tentatively defined. Hie FR is equivalent to old 540. Approximately ^ of a poly glycol VI improver will be incorporated to meet old 540 viscosity specs. Pydraul 230A A terphenyl blend has been developed which looks good on the FM spray test, It will contain of a poly glycol VI improver to meet 230 viscosity "PCoMpANY CONFIDENTIAL TRAN 003100 HARTOLDMON0025260 -s- Pydraul 135A ; A blend of TCB, 5^32, oil and Santioizer 711 has been developed which looks excellent on the PM spray test. Turblnol 153A MCS 1063 demonstrated good lubricity in a V105C pump test. The moderate wear noted was attributed to high TAN Krummrich CDP. This fluid also exhibited low deposits in the Aloor Deposition test. Pydraul A-200B . . A lower viscosity F-9A type blend was blended, tested and a tentative process issued to fill an order from Chevy Messena. They refused to purchase any more fluid containing PCB's. ' A VI05c pump test was terminated at 225 hourB due to mechanical failure of the pump. A lobe cracked off of the rotor. This is considered to be a meohanioal failure and not fluid related. The test will be repeated Just to make certain, though. The wear observed up to 225 hours was very low (11.8 mg total) and no problems are expeoted. Carbon Adsorption Study The pilot unit (series of four five-inch diameter columns), that was put on stream 10/2, continues to operate with minimum difficulties. The initial flow of 2 gpnv/ft2 was increased to 4 gpm/ftz on 10/28. Effluent quality, at the present flow, is <.10 ppb Aroolor for influent con centrations in the range 100-2,000 ppb. The present plan is to increase the flow to 6 gpm/ft2 by II/25. MANUFACTURING! W. 0. Krummrich Plant FOB Levels In Sewer A. Aroolor losses from the Aroolor Department averaged about 1.0 lbs/day and ranged from about 0.4 to 2.5 lbs/day. Losses from the Sauget Village treatment plant for the period 10/l6 - 11/16 averaged 72 lbs/day (^95 ppb). Range for 9 samples was 32 to 115 lbs/day (220-79 ppb). COMPANY CONFIDENTIAL TRAN 001101 HARTOLDMON0025261 9" Projects To Reduce Sewered PCB'b From Aroolor -Department A. Blow tank demister project was successfully demonstrated. About 100 lbs/day of mist Aroolor Is being collected. Sewer loss has been reduced from about 20 lbs/day to about 0.5 lb/day. B. Project to provide paving, curbs, trenches, and catch basins in the tank car and truck loading areas has been approved as part of the Aroclor incinerator project. The design package is about 75# complete. Program To Eliminate Sewered PCB'b From Using Departments A. A second meeting with Bon Roush is scheduled for 12/7/70. Don will discuss with plant production and engineering personnel design considerations for changing Therminol units to non-Aroclor Thertninols. B. Status of work on Therminol units is as follows* Dept. 255 Switched from PR-2 to Therminol 66 on 11/16/70. Dept. 222 0 & P, UiDept. Dept. Plans underway to change out these systems to Therminol 60. EDO for all units 1b 3/1/71. Removal of Soluble PCB'b From Sewer Stream * A test is planned for the week of 12/Y/70 to determine effect on Aroclor losses in the treatment plant effluent by neutralizing the sewer flow to the treatment plant. Lime will be added at Dept. 265 for about 3 days to hold the pH above 7.0 at the treatment plant. The re sulting floe is expected to improve PCB removal based on Anniston work. PCB Levels In The Atmosphere Sampling program has been completed. Only significant area of loss is at the mix tanks due primarily to the nitrogen purge. Loss is in the range of 4 to 5 lbs/day. Plans are to replace the nitrogen purge with a nitrogen blanket. ` PCB Rework Project Project approved as part of the Aroclor Incinerator project. Construction schedule will be determined in December. COMPANY CONFIDENTIAL TRAN 003102 HARTOLDMON0025262 -10- Anniston Plant PCB Levels In Sewer Aroclor losses during November averaged 25#/day (4620 ppb). One high value accounted for 18#/day, neglecting this the November average would be T#/day (1410 ppb). Based on knowledge of plant operations and performance of abatement devloes in November, much of the high level data is due to sample contamination. Spills Minor leaks were contained by use of sand and disposal in drums. No Bpills ooourred. Projects and Evaluations 1. Laboratory work to date indicates the presence of minimal amounts of PCB in the residue from Solid Aroclor distil- \ lation (Montar 5)* This eliminates 10R pounds per year ' or solid wastes from our PCB disposal plan. \ 2. Design work to collect spent carbon from HC1 oarbon towers has been deferred to early 1971 to accomplish the No. 1 HC1 Limestone Pit rebuild. 3. Solids removal from plant effluent (part of program to reduce PCB in plant effluent to 10 ppb) is moving forward with preliminary screening tests at Denver Equip ment Company and Betz Laboratories indicating good to moderate success with flocculation and settling. Fur ther laboratory testing is scheduled for early December. A project has been written, design is underway and equip- . ment modifications under study working with Monsanto \ Biodize to set up one of their olarifiers at Anniston for pilot soale testing of the apparent best techniques . recommended by Denver and/or Betz. 4 A successful test was made of removal of limestone inerts from the #2 HOI neutralization pit while in operation. A total weight of 127,000 lbs was removed of which 36$ by weight was solids. Lab analysis of the- total material revealed more than 100,000 ppb Aroclor or 12 to 15 Ibd of Aroclor. Present indications are that this method of removal of solids while the pit is in operation will inorease the efficient life of the pit by 25j6. 5 A project for repair of the No. 1 HC1 neutralization pit was written and approved. This projeot will be coordinated with the Niran pit project to apply an asphalt lining at the same time, to save money on mater ials. COMPANY CONFIDENTIAL TRAN 003103 HARTOLDMONOQ25263 11- Newport Plant _ The Ootober Newport Report has not been received. W. B. PAPAGEORGE ms i COMPANY CONFIDENTIAL TRAN 003104 HARTOLDMONOQ25264