Document jmE5a5X6OzKOedmG0pmDko7gp

54446 ftrttps://www. infodoxxom/secure/data2/Lightfoot/smith/images/54/54446. CPC?strict;scale=fitwidth;page=ldbid=smlthdbid=snPage 1 of 25 V .. I C 0 M ,_P_A_WJC C_Q_N H TI A L A T T 0 R N K Y--C LIEN T PRIVILEGE Rate: October 15, 1969 Subjoct: REPORT OR AROCIflR riAD HOC" COMMITTEE "(Second Draft) To: Rodney Harris, Jr. Director, Law Department From: M. N. Farrar P. B. Hodges, Secretary E. V. John W. R. Richard E. P. Wheeler, Chairman Copy S. Bergen, Jr. //2--J. E. Springste //3--M. N. Farrar //'I--P. B. Hodges #!5~E. V. John //6--W. R. Richard //7--W. C. Robinson //8--W. A. Kuhn //9~T. K. Smith #10-J. Mason #11-H. L. Minckler Origins1-E. P. Wheeler DSW164905 STLCOPCB4041167 .cgm/secuTe/data2/Ughtfgot/^ 2 of 25 CONTENTS 1. Evidence of Problem Page 1-2 2. Toxicological Aspects 3-5 3. Persistence or Lack of Biodegradation 6 /J. Pressures which Will Affect Sales and Uses of Aroclors 125^1 and 1260 7 5. Laws and Regulations Controlling Environmental Contamination A. U.S. Dept, of 1IEW-FDA 8 B. U.S. Dept, of Agriculture 8 C. U.S. Dept, of Inlerlor-FWPCA 9 D. State Legislation 9 6. Legal Implications 10 7. Alternative Courses of Action ' 11-12 8. Status of Individual Products A. Summary of Sales Volumes 13 B. Functional Fluid Uses t 13-18 C. Plasticiser Uses 18-19 D. Possibility of Contamination from Plasticizer Uses 19-20 E. The Chlorinated Terphenyls 20 9. Recommendations 21 10. Summary . 23 DSW 164906 STLCOPCB4041168 5M4.6.1ht!:|>s://ww^ smith/images/54/54446.CPC?strict:scale=fitwidth:Dage=ldbid=smithdbid=srTPaRe 3 of 25 1 EVIDENCE OF PROBLEM ' For the last fifteen years there has been crowing world wide concern regarding the persistence of chlorinated pesticides (particularly DDT) and their universal pre sence in man, food, animals, fish, birds, air, watex*, and soil. DDT and its metabolites have been found in virtually every living organism and matter around the globe--includlng penguins in the Antarctic and the polar ice cap. As analytical techniques for measuring the residues have improved, interl'ering substances have become apparent and raised doubts as to the quantitative validity of reported concentrations. Gas chromatograph techniques, making possible determination in the parts per fell lion and parts per trillion range are particularly sensitive not only to DDT but also to its metabolites DDE, the insecticides Dleldrin and Aldrin, and polychlorinated biphenyls (PCB's), isomers of which have similar reten tion times "(^Pak"1 ocatio"hs) irf~the gas chromatogram. Identification of some of the major Interfering sub stances as PCB's was announced by Professors Widrnark and Jensen of the Institute of Analytical Chemistry at Stockholm in November, 1966. With the identification (confirmed by mass spectroscopy) Widrnark and Jensen announced finding PCB's in fish, birds, eggs, pine needles and childrens' hair. Samples analyzed were all from Sweden and the Swedish coastal areas. Subsequently, PCB's were identified in fish and wild life in Great Britain 1967)> the Rhine River and Netherlands estuaries (March, 1969) ` In August of I960, Professor Risebrough of the Univer sity of California at Berkeley presented a paper at a . private meeting of toxicologists indicating he had - found PCB's in fish and wildlife along the coast of California. The first reference in the American public press followed the publication of Risebrough's paper in Nature, February, 1969. At that time the San Fran cisco Chronicle carried a "scare" story concerning PCB's after an interview with the author. In the last six months, PCB's have been reported in: a. Milk in Georgia b. Waters of Lake Michigan c. Fish in Connecticut d. Sea food along the Gulf Coast (toxic--fatal to shrimp at Pensacola) ' -1- DSW164907 STLCOPCB4041169 ... fP.dox.com/secure^data2j^_Lj_g_htfoot/_sni[t.h./.jjTTages^^ idth:page= 1 dbid=srnitbdb|d=s,Q_Page 4 of 25 EVIDENCE OF PROBLEM (Continued) e. Electric dishwashing compounds f. Milk in Maryland g. uald eagles from the mid-west and h. Mother's milk (rumor--not confirmed) in Denver. After invesllsation--not complete in all cascs--the colnmj~t'tce 1ia~s concluded: 1. That the Identification of the PCD's as contam inants of the environment is certain; 2. There is no question as to the non or low bio- gradabllity of the PCB ^.--particularly the higher chlorinated members of the series in cluding Aroclors 123*1 and 1260 and probably 12*l0; 3. The possibility of natural origin of the PClVs (such as biological or chemical degradation of other chlorinated hydrocarbons by natural processes or metabolism In the eco-system) is so remote that it is not a satisfactory expla nation of their presence; As discussed in the following section, these may be significant toxicological effects in some species of living organisms* and, 3. Aroclors 123*4 and 1260 are the compounds winch are found and reported in the literature by the Aroclor trade-names or as the "biphenyls with .predominantly 3 to 8 chlorine atoms". We believe that references to Aroclors 12*12 and 1260 (and chlorinated terphenyls) in several letters 2'eceived reflect early non definitive efforts of the analysts. DSW164908 -2- STLCOPCB4041170 5A4.^.6.1https^ smith/images/54/54446 CPr.7strirf-qralp=fihiirith-j->ar>0~ ldbid=smitbdbid=srrPage 5 of 25 2. TOXICOLOCICAL ASPECTS A. Mon--Data available at present indicate that PCB's may be "moderately toxic" to man. Safe industrial usage has been based on a recognition of possible toxic-effects and control of exposures to minimize the hazard. There have been a limited number of cases of occupational disease where workmen have been exposed to excessive vapor Inhalation or repeated and prolonged skin contact with subsequent development of skin manifeststions ("chloracne") or more serious involvement of the liver and kidneys. B. Animols--Chronic toxicity data for animals (which would allow a better extrapolation of "safety" levels for humans) has been meager. In May, 1969 chronic (two year) feeding studies in rats and dogs were initiated'at our consultant's Industrial Bio-Test Laboratories in Chicago. A three generation rat reproduction study is also underway. Tne purpose of the research is to make available to the U. S* l*'ood and Drug Administration and other' federal and state agencies data which will confirm that the levels of PCB's being found in nature--and particu larly in human food--do not constitute a serious threat to the public health. C. Fish--The proven presence of pesticides (and PCB's) in fish is beginning to cause concern for two reasons. In Sweden and other Scandinavian countries where fish make up a largo portion of the daily diet, the use of DDT has been temporarily or permanently banned, Similiar action has been taken in several . states in the United States and bills have been . presented in Congress to outlaw the sale and use. of DDT. This summer the U. S. Food arid Drug Adminis tration seized and destroyed Coho Salmon caught in Lake Michigan because of DDT content. This highlights the particular problem with fish which can concentrate/accumulate persistent chlorinated hydrocarbons in their tissues. For example, trout raised in water containing 1 part per billion wl11 contain 1 part per million in their tissues in six weeks. Other marine species exhibit a similar "con centrating" propensity. Although no scientist has maintained that these accumulated levels in fish are toxic per se, the question of the desirability of having such fish in the human diet has caused concern-and in some minds, alarm. _o_ DSW164909 STLCOPCB4041171 .5M4MhMs://wvwjn{odoxxom/seciire/data2/Llghtfoot/srnith/imaRes/54/54446.CPC?stric_t:gc3lR=:fi twidth:page=ldbid=smithdbid=srrPage 6 of 25 2. TOXICOLOGICAL ASPECTS (Continued) A second consequence of the chlorinated pesticide presence in fish. Is the alleged effect on species of coastal and other fish-eating birds. There is evidence interpreted by a number of scientists (and seized upon by the conservatlonlst-pseudo-scientists) that several species of birds face elimination or absolute extinction because of persistent chlorinated hydrocarbons In fish which make up the major portion if not all of their diet. Included in the United _ States are the Peregrine Falcon and the brown peli can. (At a meeting in October, 1969, of the Associ ation of Official Analytical Chemists, will be a paper presented entitled, "The Determination of PCB's in Two Bald Eagles". This is based on work done by the Fish and Wildlife Laboratories of the U. S. Department of the Interior at Patuxent, Maryland. Now the emblem of the heritage of the United States is threatenedJ) D. Birds--The effect in birds appears to be due to an upset of enzyme metabolism in the liver leading to the laying of eggs with thin or no shells at all. On Anacapa Island, near Oxnard, California, only three of one thousand brown pcfcV^can eggs were found tliis year with shells and oniyAbird was born. This was due allegedly to anchovies -- the main diet of the pelican--containing "DDT and hundreds of parts per million of PCB's". Preliminary results from studies at Industrial Bio Test Laboratories indicate that 100 ppm of Aroclors 12!\2, ]254 and 1260 in the diet of white leghorns causes a reduction in egg shell thickness and an effect In chick embryos which prevents hatching. E. Shrimp--In August, 1969, West Florida State Univer sity at Pensacola reported to our Pensacola Plant ' that PCB's (Aroclor 1?5*0 had been found in the Escambia River below our outfall. The amount was reported as *10-45 parts per billion one quarter mile below the plant and 1 ppb at the bridge over the river as it enters Pensacola Bay. The Gulf Breeze Laboratories of the Bureau of Commercial Fisheries (U. S. Department of Interior) at Pensacola next reported that 4o ppb killed baby shrimp-In 96 hours. Further study.indicated that 5 ppb killed 18 of 25 baby shrimp in 18 daytj. Plant investigation revealed that one to three gallons per day of Aroclor 1254 was being lost to the river from the use of Pydraul AC in air compressors. DSW 164910 STLCOPCB4041172 2:i44..[bUBSL//ywwjnfod^ 2. TOXICOLOGICAL ASPECTS (Continued) F. Summary of Toxlcity Considerations a. The PCB's are "moderately" toxic to man. A probable safe level for Aroclor 125^ and 1260 in the diet will be some tiling Jess than one part per million. b. Although only "moderately" or "slightly" toxic to adult birds and fish on the basis of acute exposure, the "safe long term" or "chronic dose" is less than 100 ppm Insofar as reproduction is concerned. c. In the case of shrimp, the "safe" or no effect" level for Aroclor 12is less then 5 parts per bill 1 on. - It thus appears that, while we may be able to show some kind of reasonable numbers for "safe levels" of Aroclors 12^4 and 1260 (and other lower chlor inated biphenyls)in some species, there are other species of life in the ecosystem where a zero to parts per billion limit for Aroclor 12^f and 1260 ;(7f^7d~po'sTi'l^*y-othc), more highly chlorinated biphenyls) will be the tolerance level. 7 gf 25 DSW 164911 -5- STLCOPCB4041173 5^i|46..[hUps;/,/www.jnjodox.com/jL^re/djta2/Ughtfgot/^^^ 8 of 25 3. PERSISTENCE OH LACK OF BIODEGRADATION --" ' -- rin-- --r * Evidence for the persistence of Aroclors 125*1 and 1260 in the environment .includes: a. The chemical stability of most of the chlor inated aromatic hydrocarbons. b. The ldentification of Aroclors 125*1 and 1260 in the environment as Itemized in Section 1. c. Reports from Sweden indicating the presence of Aroclors 125*1 and/or 1260 or competitive equivalent products In the sludge from muni cipal waste treatment plants. d. The lack of data up to now indicating that lower chlorinated PCB's are interfering in the pesticide residue analysis in spite of the equivalent usage of some of them (c.g. Aroclor 12*12) and undoubted losses to the environment depending on use applications and ultimate disposal. (Comfort in this conclusion is tem pered by some evidence that the preparation of samples for GC analysis--destroying the DDT and metabolites--may be causing destruction of Aroclor 12*12) . * q. Literature evidence that other lower chlor inated hydrocarbons in a scries of compounds (e.g. mono and di-chlorophenols) are subject to biodegradation whereas increase in chlor ination makes them more refractory (pentachlorphenol). f. Early reports of research In Monsanto's Ruabon Laboratories that indicate that Aroclor 12*12 is indeed subject to biodegradation in biological waste treatment plants (research scale). 6- - DSW 164912 STLCOPCB4041174 j^iJMiel//www.infodox.com/secure/data2/Lightfoot/smith/images/54/54446.CPC?strict:scale=f itwidth;pa.pe=ldbid=smithdbid=srrPage 9 of 25 4. riiliSSUHKS MUCH y/ILL AFFKCT SALES AND USE OF AROCLORS 1 2^1 "AN'J 1260 ~ *' As of this date (October, 1969), there are no restric tions which control the current uses of our Aroclors or PCD's. We are faced instead with pressures being applied relative to persistent chlorinated hydrocarbon pesti cides in general and specifically DDT. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond question. Although the significance of these residues is subject to wide difference of opinion among reasonable scientists, the development of "lunatic fringe" post-Rachel Carson has led to a domination of _ the media by scare publications in the public and scientific press. Only the most myopic individual in the business world could be unaware of the overwhelining interest and Influences being directed at preventing contamination of the environment. The principal groups wJ tit an apparent avowed mission of providing a world of pristine pure food, water and air include many in aca demic and political fields who recognize the headline value of statements supporting these ideals. In the case of the PCB's as environmental contaminants, the committee believes that Monsanto is faced with a barrage of adverse publicity in all elements of the nows media--including those with national coverage, factual basis will be sparse or non-existent but quilt by association (vjith DDT) will provide background and 1 prevail. . As indicated in the earlier sections of this report, it will he impossible to deny the presence and persistence of Aroclors 125^ and 1260 at least. The public and legal pressures then to eliminate or prevent global contamination are inevitable and probably cannot be ' contained successfully. ' In defense of the chlorinated pesticides, their manu facturers will not be loath to incriminate the PCB's as being culprits in the development of misleading data relative to their concentrations as residues. Secondly, the manufacturers of competitive products will seize any opportunity to point out to our customers their potential problems if they continue to use products con taining Aroclors. This has already occurred in the case of our Pydrauls, There arc pertinent federal laws and regulations rela ting to environmental control as discussed in the . following section. " -7- DSW 164913 STLCOPCB4041175 54^46.[htt^ smith/imases/54/54446.CPC?strict:scale=fitwidth;page=ldbid=smithdhir[=<;Pagp 10 of 25 5 LAWS AND RF.GULATTONS CONTROLLING ENVIKONMKNTAL CONTAMINATION A. U.S. Department oV 1 lealth, Education and Welfare - Food ancTHDruTf Admini stration ' The most pertinent legislation governing the quality of human food is the 1938 Act amending the Pood, Drug and Cosmetic Act and the reguifctions which have been estab lished thereunder. Briefly, the requirements relate to food additives - direct and Indirect, and control food production and processing to insure a supply free from bacterial contamination and unauthorized chemicals (or levels greater than established "tolerances"). The regulations also Include animal feeds. No acceptable or "safe" levels for PCB's in human foods or animal feeds have been established. Currently, there has been no indication that the PDA is seriously concerned about the levels of PCB's which have been reported alone or in conjunction with chlorinated pesticide residues. At the same time, the Pesticide Tolerance Branch of PDA has requested (late September) samples of Aroclors 12^4 and 1260 for the expressed purpose of initiating acute toxicity studies in laboratory animals. In the past, the PDA has not seized and destroyed food contaminated by the unintentional or unexplained presence of "adulterants" unless there has been some basis for a judgement that the adulterant was toxic or might pose a threat to health. An exception has been milk because of its primary role in the diet of children. Seizure and destruction of milk containing any "adulteration" has not been uncommon. It can be assumed that the finding of PCB's in milk in C.eorgia in June and In Baltimore in September has created a new interest in and emphasis on the PCB # problem. B. U.S. Department of Agriculture - Under lav/s and regulations governing the use oT~economic poisons which include insec ticides, rodenticides, fungicides, this department shares with the FDA the responsibility for establishing safe levels or tolerances for these products. It does seize and destroy meats and poultry subject to inspection under regulations controlling the processing of these foods originally those entering interstate commerce but more recently, practically all slaughtered and processed Items. As In the case of FDA, the U5DA has not established any acceptable or tolerance levels for the PCB's in products subject to their control. -8- DSW164914 STLCOPCB4041176 ^46~[htt[j^ smith/imaqps/^A/^/l/l^l^npr^r-^i^i saIe-fitwidth,;pagg=1 dbjd=srnithdbid=sPage 11 of 25 5, LAWS AND REGULATIONS CONTROLLING ENVIRONMENTAL CONTAMINATION ^CbnlinueZT) . C U.S. Department of Interior - Federal Water Pollution Control Administration Under the provisions of the Clean Water Act of 19^7 > the FWPCA has to approve standards of water quality estab lished by the individual state regulatory agencies. For practical purposes, this has meant that FWPCA has set not only parameters but actual numbers for dissolved oxygen, pH, temperature, solids, etc. Including the broad category of "toxic11 compounds. As of this date, no limits per se have been promulgated for pesticides including the chlorinated hydrocarbons. This week (October 10), a bill has been Introduced in Congress requiring the FV/PCA to establish "limits" for pesti cides. Obviously this is associated with the furor over DDT and the persistent chlorinated hydrocarbons. Hearings ori the proposed legislation are expected early In 1970 soon after the Congress reconvenes. It is reasonable to expect that the PCD problem will be brought up at these hearings. Further, with the political and public interest In all forms of environmental contam ination, it is likely that the legislation will be broadened to include all persistent chemicals. D. State Legislation - In addition to Federal legislation, all states have regulatory programs governing the adult erations of food, the contamination of intrastate and interstate waters, and the protection of fish, wildlife and natural resources. Up to this point most of the state government agencies which have contacted Monsanto represent water pollution control, natural resources, or agriculture areas of interest. No states have established any "tolerance" limits for PCBfs but a number of states have banned or restricted the use of DDT and have expressed more than a casual interest in the PCB's. In expressing such interest, several states (and the Province of Ontario) have pointed out the actions which have been taken against DDT. DSWI64975 STLCOPCB4041177 44.4.6,htt|)s;//www_.infodox^xom/seciiie/d.ata2/Ughtf^ 22 of 25 6. LEGAL IMPLICATIONS * The committee recognizes that there may be a number of legal Implications including financial liability that may be in volved in the PCB problem. It believes that these should be explored thoroughly with representatives of the Law De partment and discussed apart from this report. - 10 - DSW164916 STLCOPCB4041178 5i446Ihtt[os://wy^^^ 13 of 25 7. ALTERNATIVES (AND PROBABLE OUTCOME) ' In the face of all of the circumstances, what can Monsanto do? What does the committee recommend? First, the committee has considered several alternatives as follows: 1) Say and do nothing - making the governmental agencies prove their case against Monsanto and its customers. Let the government establish "tolerances" based on public and political pressures and any experimental or developed data which they generate. 2) Take action to create a smoke screen hoping to delay any restrictive action by governmental agencies. 3) Immediately discontinue manufacture and sale of Aroclors 125^ and 1260. 4) Discontinue manufacture and sale of all polychlorinated biphenyls. 5) Respond responsibly, admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action to resolve the problem. Hopefully, such a course would postpone pre cipitous action by governmental agencies for a few months and then limit any restrictions to Aroclors 1254 and 1260. In the interim, there would be an opportunity for a concerted effort to find and promote substitute products for those particular Aroclors and the develop ment of data to protect the continued use of lower chlorinated biphenyls such as Aroclor 1242 and the chlorinated terphenyls. The principal purpose of the toxicological research ' effort underway is to establish that "safe" or "harmless" levels can be set for mammals including man and fish. As the work progresses, it appears more and more likely that "safe" levels for birds (and thus the fish con sumed by birds) and some species in the marine environ_ ment will approach zero (shrimp-less than 5 parts per ~ billion). In summary, the committee believes that the probable outcome of a "responsible" course of action will show that some low levels or concentrations are "harmless" to some species in the environment. This gives Mon santo some defense. At the same time, safe levels of some of the Aroclors for some species will be such that any contamination will be harmful and must be prevented. - 11 DSW 164917 STLCOPCB4041179 54.14.6.1h]tps://wwwJn[qdqx.com/secure !! 14 of 25 7. ALTERNATIVES (AND PROBABLE OUTCOME) (Continued) Further, Aroclor degradation in the environment will be proven to be extremely slow with the higher chlor- inated compounds being worse in this respect. Finally, in view of the above, this course of action will dictate that we will have to restrict uses and begin a program of "clcan-up", starting immediately. -12- DSW 164918 STLCOPCB4041180 54i46.iM!P.s;2l/yywW:lnfodox;corn/secure/d 15 of 25 8. STATUS OP INDIVIDUAL PRODUCTS A. The table below summarizes the approximate sales volume of the chlorinated biphenyls by product_____ designation and end use: Aroclor 1242 1248 1254 1260 1262 1268 Others Total Pydraul 4.06 1.16 0.58 Sales for Aroclors in Millions, Pounds Therminol Miscel. Electrical ....................... PlastlTotal FLU sizer 1.12 1,01 0,12 2725 0.30 .20 .50 T~ 1.0 35.5 -- 0.8 3*15 . 39735 40.98 2.37 1.45 3.73 l.l 49.6" 6.6 1.35 5.37 0.42 .50 .41 39 15.2 Total 47.6 3.7 6.8 4.2 2.4 64.7 B. Functional Fluids Uses In outline form, the possibility of functional fluids uses resulting in environmental contamination, possi ble courses of action and effectiveness of control action are indicated as follows: F. Fluids Possible Pollution by Possible Pollution Customer Plant Operation by Customers' Produc Product Hydraulic Fluids Yes, leakage external Possible - see Johnson Motors Castings Air Compressor Fluids Yes, leakage external Leakage into produc Heat Transfer Yes, leakage external Leakage into produc Capacitor FluldB Yes, leakage from plant In product but scrap materials closed for end use* Transformer Fluids 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. -13- DSW 164919 STLCOPCB4041181 54446 rhttps://www.infodox.com/secure/data2/Lightfoot/'smith/irriages/54/54446.CPC?strict;scale=fitwidth;page=ldbid=smithdbid=sPage 16 of 25 6. STATUS OF INDIVIDUAL PRODUCTS (Continued) Probable. Outcome 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--wJ.th less sensitive components. Work from this base on clean-up to prevent more pollu tion problems. Air Compressor Fluids Hydraulic Fluids Ditto Must expect "shrimp11 experiments, West Florida State, to be "aired" sometime soon; next few months. This will lead to bad publicity and competitive action vs. all Pydrauls. Y/e will have to try to confine to Aroclor 1254 and Aroclor 1260. We will have to take action before that time. Gulf Coast Action~~Be able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in two months' time before Nov. 15, 1969. Have trial product in hands of Gulf Coast accounts and distributor before Dec. 15. Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS____ for insurance. Suggest possible substitution of Aroclor 5442 for Aroclor 1254 in hydraulic and compressor blends. E. Wheeler judges lower order of toxicity and solubility for 5442 series. Have to test product in pump test for deposits. Suggest field trials of our own all-phosphate ester. Work with large customers to clean-up streams. Bring in Findett as manufacturing partner in the recycle business. Get money out of recycle operation. -14- DSW 164920 STLCOPCB4041182 544461httBs://wwwjnfodgxxom/,secu^ 1Z of 2,5 8. STATUS OF INDIVIDUAL PRODUCTS (Continued) Iniand-Waterways . Actlon--Be close enough to Great Lakes studies to judge situation. Are there animals which are being affected by the concentrations found? Be prepared to replace Aroclor 125^ and Aroclor 1260 in four months in hydraulic fluids and in air compressor fluids. Be prepared to replace all Aroclor 12^2 or 12^8 in six months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 12^8 to other hydraulic accounts such as Cities Service and Mobil. Heat Transfer ' Action--Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. Need to replace FR especially in food or sensitive product areas where the product is getting into water. See dishwasher compounds. See letter E. Wheeler to J. Fallon. We have possible replacement products in Therminol 55. Therminol 66. Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. H2 and terphcnyl supply may become short. Switch customers to Therminol 55 - or Therminol 66. - ahead of pollution problems'in customer's 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 Fluids Capacitor Products Capacitor plants have repurification and recycle systems but up to 5^ of product can be lost by poor plant producers and off-quality material. 5# of production could be 1M lbs/year. This Is a big loss for the type of pollution we are trying now to guard against. DSW164921 -15- 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. STLCOPCB4041183 54446_[b.t?sy/w_wwjnfoclox.cornZ.secy[e/data2/L!ghtfoot:/sni!th/jm jg gf 25 8. STATUS OF INDIVIDUAL PRODUCTS (Continued) Capacitor Fluids (Cont.) Capacitor Products (Cont. Action--Monsanto must help plant clean-up of customer plants' decantation, coalescing, adsorption, dis posal of adsorbent or recycle of adsorbents, Recommend replacement of future Aroclor business with other products. Have two years. Monsanto badly needs "know-how" for clean-up. Monsanto should seek government contract money for clean-up research (see MRC R. Binning, D. Nelson). Transformers Transformer plant can operate in a clean, efficient manner with recycle of off-grade Aroclor. Action--Should advise disposal of filter element materials so as to minimize chance of water pollu tion. Incinerate or dispose. Product transformers can remain closed and no exposure for 25 years. Reworked transformers pose a threat if the Aroclor is dumped into a water stream. Should try to minimize chance of dumping "old" fluid by re working and by educating _ company shops and collecting product for rework or dis posal . Should try to retain business by clean-up; by education of cus tomers . Dalton is set up In England to rework electrical grade fluid. Need rework facility here and disposal scheme. Monsanto Plants The Department 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 could shut us down depending on what plants or animals they choose to find harmed. -16- DSW 164922 STLCOPCB4041184 5444-6 [https: / ^wjnf^dox^pjn/secure/c!iata2/Lightfoot/srnith/images/54/54446.CPC?strict:scale=fitwidth-P3e=Idbid=s ig of 25 0. STATUS OF INDIVIDUAL PRODUCTS (Continued) Monsanto PIants (Cont.) . Action--Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try to reduce to ppb level. Seek a government contract on adsorption and incineration cycles--MRC. 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 clean-up methods to customer plant clean-up equipment and procedures. Evaluate liquid incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorohenol wastes. Estimated Aroclor disposal at 1-*JM lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. Hydraulics 20# of *1M lb.s. Heat Transfer 10# of 2M lbs. Capacitors 5# of 20M Transformers 5# of 15M 800.000 lbs. 200.000 lbs. 3,000,000 lbs. 760.000 lbs. 2,7567000 IbsT Set up an incinerator to handle Aroclor disposal-preferably one which will handle solids such as muds--slurries as well as liquids. Have in operation within 12 months. Ideally have incin erators available different sections for disposal. Chronic Toxicity Studlen--Industrial Bio-Test Actlon--Continue studies to establish FDA type limits of toxicity on Aroclor 12*42, Aroclor 126*4 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. Doe.s concentration level off, decline if feeding is stopped? % Institute studies against the most limiting biological parameters. If shrimp are the most limited species for Aroclor levels of toxicity, then we will have to have biological studies on these species to confirm or deny adverse findings. -17- DSW 164923 STLCOPCB4041185 ----^^i9.?Sl/^J!!'JBfo^J<,:cg!7)/_seci^e/data2/L!p;htfoot/smith/imases/54/54446.CPC?strjr.f-sr.alp.=fitwirithLRaEe=ldbid=s 20 of 25 8. STATUS OF TNDIVJ-DUAL PRODUCTS (Continued) Biodegradation Studies Aetion--Set up rate of biodegradation studies with Inor ganic Division on Aroclor 124? vs. Aroclor 1254 Aroclor 54*12 vs. Aroclor 5460 Chlorinated diphenyl ether Chlorinated paraffin vs. chlorinated naphthalene Chlorobronio Aroclors 1242 and 1248 ' Contact Baxter and Lidgett at MCL regularly for results on Aroclor degradation. They are reported to be moving on laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. ~ C. P1asticlxer Uses Analysis of chlorinated biphenyl uses as plasticizers (1968 figures) Is as follows (provided by C. Paton, . 3/23/69) 1 No carbon required paper NCR: 6.0M pounds Aroclor 1242 Until mid-1968, only NCR plant was at Dayton, Ohio. There is now a plant at Portage, Wisconsin on stream. 2. D1strlbutors Our distributors resold 4.5M pounds chlor inated biphenyls in 1968. It is Impossible to pinpoint all uses. I estimate surface coatings is the biggest market. ,, 3. Hot Melt Adhesives DuPont at Parlin, New Jersey uses 460 ST pounds (mainly Aroclor 1248) in a hot melt adhesive for bookbinding. 4. Sealants^ Aroclors are used in polysulfide sealants (automotive windscreen sealant and light construction, e.g., window sealants). 1968 sales were 1.4m pounds (Aroclor 1240/Aroclor 1254). Our largest customers are Products Research at Burbank, California and Gloucester City, Pennsylvania (680 Fl pounds) and Sonneborn In New Jersey (225 M pounds). . -l8- DSW164924 STLCOPCB4041186 MM6Xhltps,-/Zwyw smith/irnages/54/54446.CPC?strict:scale=fitwidth;paeie=ldbid=smithdbiri=sPa .8....2.I_oL25 8. STATUS OF INDIVIDUAL PRODUCTS (Continued) 5. Adhesives Rubber adhesives, etc^ accounted for 0.8 K pounds In 1968 of which *100 M pounds went to 3-M. 6. Coatings In 1968, we sold 1.3 M pounds on a direct basis to this market. Our biggest direct customers In this_market is Sherwin-Williams (Cleveland) at 1*10 M pounds and Koppers (Pittsburgh/Newark) at 250 M pounds. 7 Ml seellaneous Approximately 0.7 M pounds chlorinated biphenyls are used in miscellaneous applications as fire retardant additives, wax compounds, etc. 1968 sales of chlorinated biphenyls were: NCR Distributors Eight Major Customers All Others 6.0 M pounds 4.5 2.5 2.2 15.2 M pounds market, 1968 sales were: NCR Distributors Sealants Coatings Adhesives Hot Melt Adhesives Miscellaneous 6.0 M pounds 4.5 1.4 1.3 0.8 0.5 0.7 1^.2 M pounds - JL). Possibility of Contamlnatlon from Plasticizer JJsejs With the exception of the use of the higher chlorin ated biphenyls in rubber based paints for swimming pools and water storage tanks, it is more difficult to pinpoint end uses that would permit "direct1! contamination of the aquatic environment than is the case with functional fluid uses. "Indirect" contamination could occur from the eventual leaching of the Aroclors from the final disposal or ultimate end point of any product containing them. For example, highway marking paints obviously have a short life. It may be presumed that such paints containing Aroclors eventually end up in the drain age areas for the highways and provide a continuing source of PCB's to the limit of their solubilities. Similarly, any Aroclor containing products which end -19- DSW 164925 STLCOPCB4041187 ^y^^,:j..CllP<:|ox.com/secu^ i** *2? **v UAj HbVv'., kV /1mages/54-/544:46 CPC'strict1 ..J..i"Litwjdthij^age--_1 dbjd=smithdbid=sPaee 22 of 25 J STATUS OF INDIVIDUAL PRODUCTS (Continued) up ultimately in refuse dumps or land fill operations are possible sources. - Several scientists alarmed about the marine envir onment contamination have theorized that any PCB's which get into the atmosphere from processes invol ving plasticizer uses or the incomplete Incineration of waste products containing PCB's eventually end up in the sea because of "rain-out". This then could Involve nearly all of the plasticizer use3 other than coatings. ' E. The Chlorinated Terphenyls Up to this point there have been only scattered re ports that these compounds are present in the envir onment and/or are1 interfering with the analysis of chlorinated pesticide residues. There are at least two possible explanations: 1. Due to extremely 1ow solubility, they are _ _ not being dispersed as are the chlorinated biphenyls; and 2. The retention times in the GC analytical techniques are so great that their peaks don't Interfere with the identification of DDT, its metabolites and the other chlorinated hydrocarbon pesticides. This explanation implies that they may be pre sent but are not being Identified. Hopefully, if they are eventually identified and their presence confirmed, we will be able to provide data that they are sufficiently biologically "inert" for man, animals and all species in the ecosystem that they present no problem. -20- DSW 164926 STLCOPCB4041188 M.116.[httgs://www jnfodox.com/secijre/data2/Ughtfogt/ r.Pr.UM*; 9. RECOMMENDATIONS From the specific recommendations indicated in Section 8, pages 13 to 20 as they relate to individual Aroclors and their uses, the following general recommendations have been developed: A. Immediately assign full time at least three individuals for a period of at least three months to an ''emergency" task force to implement the action indicated by the specific recommendations referred to above and those which follow. B. In view of legal and moral considerations, notify all Aroclor 1254 and 1260 customers of environmental con tamination problem and their possible Involvement. C. Reduce losses of Aroclors in liquid wastes from Monsanto plants to minimum. Goals for Aroclors 1254 and 1260 0 to 10 parts per billion. - D, Consult with appropriate federal agencies * headquarters in Y/ashJngton to determine current status of concern and to inform appropriate individuals therein of Mon santo's research and control efforts. E. Personally contact all governmental and university lab oratories which have requested Aroclor samples and in dicated interest in the environmental contamination problem. F. Determine extent of atmospheric losses from Aroclors from Anniston and WGK Plants and develop plans for and install control. G. Analyze in Organic Division laboratories (or by contract) selected appropriate samples from: (1) Environment of Anniston and WGK Plants. - (2) Monsanto products where contamination is possible. (3) Agencies and/or laboratories attempting to pinpoint ' - specific sources of contamination. (4) Customer plants' environments. %* (5) Research efforts Involved in biological studies-i.e. animal, bird and fish toxicity studies and biodegradation studies. -21- DSW164927 STLCOPCB4041189 5^4^Lhttpps:^ .:.o^Zscure/data2/L[ghtfoot/siTi^ V. , g. RECOMMENDATIONS (Continued) 24 of 25 { H. Establish a special budgetary account to allow im- plementation of these recommendations and the con tinuation of the toxicological research effort now underway and continuing until June, 1971. The pro blem involves not only Research whose budget has born the major costs to date. It Is a joint problem involving also sales, and production or manufacturing. The budget for the remainder of 1969 and 1970 should include: (1) Costs of 3~man task force for six months - in cluding travel .............. $40,000 (2) A continuing 3-man effort in the analytical area. (At present there is the equivalent of one and a half men)..................................... .... . $55,000 (3) * Toxicological research and biological degradation studies. ............................ .... $125,000 Sub Total $220,000 (4) Development of substitute products . * In connection with the toxicity research, developments during the next 3 to 6 months may dictate that some studies be dis continued in mid-1970 because the results may be meaningless in terms of preventing loss of business. DSW164923 STLCOPCB4041190 M44.6.1http^ secure/data2/Lightfoot/smith/imaRes/54/54446,CPC?strict:scale=fitwidth;paRe=ldbid=smitbdbid=sPae 25 of 25 10. SUMMARY 1. The committee has concluded that the identification of PCB's as an environmental contaminant is certain. 2. Toxicity to some biological species at extremely low levels (a few parts per billion) is significant. 3. The PCB'3 are persistent once they become a part of the environment and the rate of degradation is extremely low. i|. There is little likelihood that the PCB's appear in the environment as a result of "natural"origin on the metabolism or degradation of other chlor inated hydrocarbons * * -23- DSW164929 STLCOPCB4041191