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H. S. BERGEN - ST. LOUIS SEPTEMBER 12, 1969 defense or aboclor - FPHCTIDNAL FLBUB R. H. KOWTZ V. A. rOHH*-- itirvnsM Please rind attached a rough draft froa Dr. Richard to ELaar Rheeler regarding Aroclor tori city. I would appreciate tout coeaienta to both Dr. Richard and BQrsolf regarding this draft. H. S. BHU3EN OSW 014254 HARTOLDMONO015061 IZCjI'CID '} Cr ?/?A'9 A /v. t3 ^t^C" 0*- VJM^N , PM-;*<_ M*-~ t>*A a. ,f~cl^frj !vi*~t~ /fr*^yfr^` J&- cl*^*. , Tl^> f&M OSW 014255 HARTOLDMONO015062 r.iO fmc* iStMi lOC*f*0Ni R. Richard - Research Center September 9, 1969 .ul KriMfCt DEFENSE OF AROCLOR r'. j'ELi'xilS jo : E. Wheeler - EWHEE P. Kodges PKODG General Policy 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 ahead of time. Adverse publicity and competition are the real weapons. Analytical In Air - Which Aroclors are present? Where? for Aroclor .In Water- Which compounds-3 Govt. In Animals ^interfere? Agencies Keep track of how much contamination - which sources. Prove Bioharmful - Let Govt, prove its case, on case by case basis. Monsanto Visit-Govt. Biolabs - in search of toxicological experiments and evidence ' vb. Aroclors to keep up with progress. Monsanto Prove Bloharmless - Limited work at Ind. Bio-test - "Safe" toxic level for man mammals via fish Rats Chlckens Pish Seek evidence of Blodegradation 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. -.roclor degradation rate will be slow. Tough to defer. wbi.-.st. i_.;.~.er chlorinaeion c orpounds '.rill be wo-'-- . . .:or chlorine compounds. Therefore we will have to res-rict uses and clean-up as muc.i as_wa_san, starting immediately, it, ' 1 4- ..--- ' " 9 1 OSK 014256 HARTOLDMONO015063 j Make the Govt., States and Universities prove their case, I but avoid as much confrontation as passible. Comply and work with public officials to meet or'emceed requirements V ahead of time. Adverse publicity and competition are the real weapons. . Analytical In Air ' - Which Aroclors are present-? Where? for" Arcelor iIn. Water- which eflUTfmn^i 1 Govt. In Animals ^interfere? Agencies Keep track of how-much contamination - which sources. P_l ro" ve Bio"har- m" ^ful - let Govt, prove-its case, on case by c ase basis. Monsanto Visit-Govt. Blolabs - in search of toxicological experiments and evidence ' vs. Aroclors to keep up with progress. Monsanto Prove Bioharaless - Limited work at Ind. Bio-test - "Safe" toxic level for man mammals via fish Probable Outcome ' Rats Seek evidence of 3iodegra- Chickens dation Pish Question evidence against us. Question shrimp toxicology . especially other toxic chemicals. . If Aroclor bad, others must be wopie. 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 defar.-.jiinst. u.rher chlorination compounds will be woruc _u-.:er chlorine compounds. - Therefore we will have to restrict uses and clean-up as much as we^-can, starting n immediately. t i . .. osu Ti' ' 014256 AO HARTOLDMON0015064 -2- Tv.eref ore we will have Co woric for aisarnaia products in er.d use applications; for Arcelor production facilities. Clean Uo Aroclors and substitute orcducts where neeessarv ~ and wr.en requires, cefore threats of publicity ana competitive activity over- whela us. ` * Water Pollutisn seems to be first issue Arcelor product is refractive, will settle out on solids - sewerage sludge - river bottoms, and apparently has a long life. . Florida or Gulf Coast - Aroclor 1254 - Arcelor 1260- present . issue. 40-2C0 ppb - causing problem at Pensacola (Monsanto) in plans effluent-causing " with shrimp. - can't rislc shut-down of plant* ' Federal and State can extrapolate to other plants in . Gulf area. ' San Francisco - Arcelor 1254 and 1260 Reported Arcelor to. be present in San Francisco Bay. Reported to be -thin egg shells In birds - Lot of screaming - . Great Lakes Warf studies on DOT Aroclor 1254 will be found 1 Aroclor 1242 will' be found? . Air Pollution - Possible spread - but less of an issue right now. Analytical woric more difficult. r.^A To `7 Direct Contact with Product . u1 A -' ----------------------------------------------------- * i"r. ^ Doesn't sees to be an issue - except for food heat transfer /We don't believe Aroclor is being used as carrier fer insecticide - sprayed around . 1! \^r We are not positive but most uses are "closed" systems;! or products used in solid plastics, or adhesives, or ~ sealants. OSH 014257 HARTOLDMONOOI5065 -3- ?. Fluid3 Product Hydraulic Fluids Air Compressor Fluids Heat Transfer Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutior Customers Plant Operation by Customers Yes, leakage external Yes, leakage external Yes, leakage external Yes, leakage from plant - Scrap materials. No, Should be clean. Yes, Reworked trans formers Possible - See Johnson Motors Castings. Leakage into produc Leakage into produc In product but closed for end use* 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 Air. Compressor Fluids 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. tf . Hydraulic Fluids ' Must expect "shrimp1' 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. ASW 014258 HARTOLDMONO015066 'ie will have to take action before that tine. Gulf Coast - Action W. Richard Fallon/ Richard 3e 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 Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS___ for insurance. Richard/ . Suggest passible 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. '. 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/ Be close enough to Great Lakes studies to Judge Richard situation. Are there animals which are being ' affected by the concentrations found? Richard Be prepared to replace. Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and in air compressor fluids. Richard ' Be prepared to replace all Aroclor 1242 or 124P 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. Heat Transfer OSW Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. 014259 Fallon/ Roush Need to replace ?R especially in food or sensitive profiHat areas &.* r.n<j prnduot is itettins into water. See uish washer eompounca. See letter E. Wheeler to T; Fallon. . We have possible rep cement products i.. Thermir. 55. Thermi.-... cc. HARTOLDMONO015067 -5- Acuion Kuhn Kuhn/ Fallon Try to assure adequate production of Themlnol 66 in face of decreased Aroclor production. Ha and terphenyl supply may become short. Switch customers to Themlnol 55 or Themlnol 66 ahead of pollution problems in customers plant. Work with customers on plant and dumping practices. Findett already set up to rework. Heed to make them a manufacturing arm. We get sale of re cycle-rework fluid. Capacitor Capacitor plants have re- Fliilas purification and recycle systems but up to 5* of product can be lost by poor plant producers and off-quality material. Kkt. Ber.igr.us / Bryant 5 of production could be Eng.-Kountz/ Mfg-Hodges 3JT lbs/year. This is a big loss for the type of 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. We have set-up to accept material for rework into hydraulic fluid but this relocation is not a satis factory 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. ft Action Monsanto must help plant clean up of customer plants c-ocantatlon, coalescing, adsorption, dis posal of adui.-ber.s or recycle of &C50** isnz s. Monsanto badly needs "know-how" for clean-up. Monsanto should seek Govt, contract --* money for clean-up research, (See MRC R. Binning, D. Nelson) qSW 014260 HARTOLDMONO015068 -o- Trzr.s formers Action Benignus/ Bryant Transformer Plant can operate In a clean, efficient manner with recycle of off-grade Arcelor. Should advise disposal of filter element materials so as to minimize chance of water pollution. Incinerate or dispose. Reworked transformers pose a threat if the Aroclor Is dumped Into a water stream. Product transformers can remain clsae no exposure for Should try to retain business by clear.-up; by education of cus tomers . w r. Action Benlgnus/ Bryant Should try to minimize chance of dumping "old" fluid by re working 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 Krummrlch 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 ' to reduce to ppb level. . f ' T P .Hedges-Seek a Ooyt. contract on adsorption and incineration TSD cycles - MR.C. 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 Mor.SRr.to clean-up methods to customsr plant Up cia'.U pi\J CtiCUrC . OSH 01^261 HARTOLDMONO015069 Action - Engrg. & Mfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing or Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at 1-4?T lbs/year, exclusive of'cleaning up river bottoms or outfall bottoms. . Hydraulics 20^ of W lbs Heat Transfer 10S6 of 2ff lbs Capacitors ' 5^ of 20ff Transformers 51 of 155T 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. k Mfg TSD Kountz k Kuhn Set up an incinerator to handle Aroclor dis-\ * posal - preferably one which will handle \ . solids such as muds - slurries as well as . I' L liquids. Have in operation within 12 months. /P / ` Ideally have incinerators available different / sections for disposal. /' Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio- Test . Continue studies to establish PDA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. ' Rework: with R. Keller-S. Tuclcer the number of samples which are to be analyzed for Aroclor in tissue. Try to see if Aroclors are changed metabollcally. 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. OSW 014262 HARTOLDMONO015070 8- - Blodegradatlon Studies Set up rate or biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 Aroclor 5442 vs; Aroclor 5460 Swisher Chlorinated diphenyl ether Chlorinated paraTrin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 . Baxter Contact Baxter and LIdgett at MCI regularly for results on Lldgett Aroclor degradation. They are reported to be moving on MCL laboratory experiments. ' Establish contact with chlorophenol degradation studies or Cellu-Chea Group. WRRims 2 V. R. Richard OSH 0142^3 HARTOLDMON0015071