Document p6DGe5RnQk3y7VO8B1NK3gEa

(VS'*o IN THE CIRCUIT COURT OF CALHOUN COUNTY '' MARS HILL MISSIONARY BAPTIST CHURCH, et al Plaintiffs, VS. MONSANTO COMPANY, et al., CIVIL ACTION NUMBER CV-96-243 mu .*fwes$ '.......... - copies PLAINTIFFS' EXHIBITS 1-23 and 26-34 to the VIDEOTAPED DEPOSITION OF MICHAEL A. PIERLE Taken on behalf of the Plaintiffs June 2, 1998 (314) KRIEGSHAUSER REPORTING & VIDEO REGISTERED PROFESSIONAL REPORTER 314 NORTH BROADWAY, SUITE 810 ST. LOUIS, MISSOURI 63102 621-4408 FAX (314) 621-4533 WATER PCB-SD0000077131 V fSfr^V'y., m, i. ArfkMi^MlS^A 4<- .*>' , fflUBlM 9F 1MCLQM fOttQRJMTgP PIPgBfTL) iMh Do not hoot Arcelor s la open vessels above the teuperature* at shloh fuses appear (approximately 500P,) unless efficient ventilation Is provided to reserve the vapors* She Aroelon ere Chlorinated Diphenyl sad, as is charac teristic ef chlorinated organic ooapeuads, their vapors are irritating to the eyes, nose sad throat* Pro* looted sad repeated exposure to *ueh fuses say, in addl* tics to oeualag Irritation* interfere with the norsel ' shin fuoetlaos sod result indirectly la physiological disturbances, * .............. *"'" " ' " ........ ..... . " '-.'-the yepcirs#'"scold ?_. .. __ &ts;fiao*el*^er^ 1 elor fro entering the fkla pores' and facilitate* -their reeoval vlth tosp end eater* Application of sold ereaa to exposed parts of the body is a precaution reoooaended to eoyone working constantly vlth iroelors* These pre cautions apply to dost fres solid Aroelor ss veil as to vapors from heated saterials* : As a trsatsent for irritaticn of th r* flrst rash Jthhe* eyss vell withe 'saturated solutl .orBorlcAold ' then treat with a iOJI ablation of Argyrol* Treat burns fres hot Aroalor the sese as any ordinary burs* Aroelor adhering ts the burned area need not be rawed lew ellately unless troatneat mt the born demands it, In ehlah*see use soap and ester or repeated cashings vlth a vegetable ell (linseed oil)* Personal cleanliness is cf utmost J^ortaaea.York clothes should be changed dally and oust not bo worn any frost the plant* Swore changing to street clothes at the oid ef the day the mfkmm should bathe"vlth plenty of soap sod ears outer* degleet of theso staple precautions may result la shin Infections. Ill health, dlscoeforst, ln- effleiaaey sad loss of time* - HONS 05 735^ WATER PCB-SD0000077132 This document Use been recyp*d for clarlty. Wr-K .^Haaon-M. 0.. -*c: tute June 12, 1956 ns Dr. R. Emmet Kelly Ac Medical Dept- smfcrcnca subjeez CELORACJJH CASES AT BADISCHEN ANILIN DUS TO TRICHLORPHENOL Person Present: Dr. H. Oettel Dr. H. T. Hofmann A. Palm (Ph.D.) H. Soenksen (Plant Supt., part-time) , On the 17th of November, 1953, Badische was producing a'batch of trichlorphenol from teerachlorbenzene when the process exceeded control pressure and i.temperaturea similar to our incident ^at ;Hitro 4.N0 one was ~frr r>r{itr5iS^fe^.y3^^i.keav.-S;cagsJ,;ofichioraene (Syaerxous) showed-up ----------- 50-60 'cases____ __....___________ I did not see our most sever* Nitro cases nor have I seen photograph* of these aesee. The photographs of the worst Badische cases show horrible skin eruptions with nearly blister-like welts and some ulcera tion where infection ensued. Areas involved included the face, neck, arms, and upper half of the body. It is my impression that their severe - cases .were ,-auch ..vori'ijbhan 'Jour* **&gla addition .to ithe .akin mani-_ f estations, their men reported alltheadditicn^aymptoms as - exper-;. iences ' in our workers, i.a., fatigue, vertigo/loss of libido, painful joints, :'4": ). V --" .T:.. About ten days following the incident, and after initial clean-up, Dr. Oettel was asked to expose animals to the workroom atmosphere. Rab bits (in open wire cages) were placed in the operating area for 24-48 hours. There were no obvious symptoms which developed in the animals until one week after exposure - when they died. Autopsy showed liver necrosis. Oettsl thought there might be virus infection or some other cause for death until he exposed additional animals in the department, others in cages suspended inside the decontaminatad" autoclave,. and some the-adjacent department. fAll died within 1-2 weeks following exposure. -Subsequently, animals placed in the cages which had pre viously been in the department died of liver necrosis. A thorough systematic investigation lias isolated impurities in the trichlorphenol process (or residues) which will causa the same effects in rsbbits. Livar necrosis will develop in rabbits at the following doses of the indicated materials: 15-20 1 0.2 0.01 mg. mg. mg. mg. of pentachlor naphthalene of chlorinated diphenyl oxide _ _ of residue from trichlorphenol distillation of residue fraction from trichlorphenol (above 230C) This document has been retyped for clarity. t WATER PCB-SD0000077133 This daczxmitc bama rmtyp*s<i far clarity. ' -aV.X probably with additional oxygen atoms in the molecules. He has cor responded with Don Irish at Dow who either reached the same conclusion independently or, in mentioning the potential of chiorinateddipheny1 oxide, influenced Oettal's reasoning. Oettel believes, further, that this impurity can shew up in the production of any chlorinated phenol allegedly to ehlornapthalena*, pentachlorphenal, chlorinated biphenyl. Dr. Oettel has no faith in any animal akin teats for isolating chlor- acnogens. He was very interested in Kettering's work and was not aware of the publication referred to in Dr. Suskxnd* s first report and which describee the cyclic skin development in new-born rats Refer- .ences.^-Parnell, t .Postnatal Development and Functional Histology fo:fther^!ejjCMaljClanda3fin rffehs.'^lUt,t38S*il 1,,.,-1943 )4flle ;;1* fccmvjj^pd|^lt#!Aa|BrbasulphaIeih'teatyreported .;in^S^!attach1^^;eng'i ;irarpaiIEan]S|ra*OT 'refuaes'ftb^acceptTinateria'I 'which fails'-to 'pass : the fahiial also "learned at Bayer that they have experienced chloracne during ' the production of trichlorphenol but "have now licked the problem" . according to Dr. Hansen (chemist - Research Director At Blberfeld). * n ^- Badische has been able to reproduce in the laboratory the conditions which lead to the incident such as theirs and ours at Nitra and was quitelfeurprised. ithatv, we _Jiad not been able to do .so. /X was not given the^NK^'^procMs^ijaidrmatioh; ' :i.e.tei^eraturei'Vand' presaures,'^but if ' I had';'had this information I am sure that I could have obtained I.' Badische *s- One-of their chemists, a Dr. Palm, sat in on our dis- . cusaions and was prepared to go into details. He did mention that "with 3 mols of trichloi-phenol, methyl alcohol, and alkali, and a tem perature of 18QC" the process gets out of control. His remarks . are in quotes because he does not speak English and I'm not certain of his remarks. ' Dr. Oettel would be very happy to receive samples of any of our materials for investigation. He would like particularly: (!) Samples of tnv of the materials involved in our 1949 incident including tetrachlorben2enc, trichlorphenol, or Na salt and any residues from the autoclave or material cleaned from the equipment and structural members. - (2) Trichlorphenol (or Na salt) from regular production. (3) Any samples.from raw materials, intermediates, and final product which may have been involved in our cases which developed during our normal 2, 4, 5-T production in the years following the initial incident. Ttils document hsj ban retyped far clarity. WATER PCB-SD0000077134 T&la docae A<bjs xweypsd ae elaxiey. a. =uid b hBFpy t= us and Kettering. It was my suggestion tirst";tMa^b^itrw:t with ~ Dr. Suskind to eliminate "third parties." Be would routinely send carbons of any correspondence to us and we could request Dr. Suskind to do likewise. It is my opinion that this might save unnecessary duplication of effort and expense. In addition, Kettering might obtain valuable information to further their investigation involving human' volunteers. ' I left with Dr. Oettal copies of the following: . (1) The five (5) reports from the Industrial Hygiene Foundation which discuss their rabbit ear tests. (2) Kettering`s report -- "Clinical and Environmental Survey at Nitro, 1953." ...(3) Kettering'a report.-"Bnviromtent^l:Surway^Carried Out In Building 30, 'Honsahto'-Cheadcal^Cos^ahy.^t :'Bitxe^:rTehfuazy'''!2 We reviewed thoroughly Hr. Wager's excellent ^History of Chloracne" which he sent to me with covering memo dated Hay 15, 1956, and which included descriptions of Kettering's reports on their human and - animal research. I did not give Dr. Oettel a copy of this account because I did not have permission to do so. As a result of my visit, it may be desirable to edit this report somewhat and add further process information before forwarding this, to Badische. - h ` Any specific recommendations are implied in the above narrative account of my visit to Badische and must be based on an agreement that full and complete exchange of information with Badische is desirable and possible. BFW:dh Attachment . EPW Blmer P. Wheeler Klij document her been retyped for clarity. WATER PCB-SD0000077135 Al Aaalatoe, Alab To Mr. K. 8. Vobus St. toola At Jtoberca IU(. 0t fia/crenc* 8ojt. 30, 1937 EK/JIC 2/23/37 -'.V, Ca'>/, S. 1. lMr W. J. Dougherty C. A. Sveet* W. 1. Dunlap. Jock Clefora J.W.Craveo-VCX AJC.Illaaburi-llala Office T.V.Saltom - wot "** * * KellyHala Office 8abject: TOXICITY OF MOVTAltS Zb the rtftmci memo, Or. Xally advised that he had mo laboratory toxicological data os the Manure hat felt aartaia theyaoeld cause Woracaoci^Brtoehoj^ori&&eefBFhtholaegB4Aiph4yU-a<l, 5B^1^>^r*'4^1ily^'6h^'acSZ<'*Bi*.,'ilBir .treble ,hr>lahalatioa:"f , \ .'v-*:iiberatadat alevatod taaperature*. Be reeeeaeaadad thatliha'maximum "allowable fume coaeaatratioa h it t 0.3 mllllgrama ftcable motor of sir for exposure date laformacios to oar customers. .... v`- At Axalatoa, we drala Koatar* at 380C. from our atllla am tnri|i of o*ee ft day whea eperatlmg at maximum rete. The operattorn la performed coder ltr|t hoods which Z believe are effective la protecting oar persomael. heenr, it la yoaalbla that soma fame* may aecape lato the eperatlmg area daa to wiad sarraata or laadaqoaciaa la oar .blower ayataa. At aay rata, Z mould Ilka to gat a faw readlags la the dofiartmaat to ~ make sare wo ar# aofa. ... Cam you farmlak mo a detailed procedure for detecmialmg the eeecsatratlom of Momtara la air? Alao, baa aay farther laformadom relative to toxicity beam developed? 'r CXt/fV ></ +*7 T C. K. Kdalhlut ' ttGNS 095660 WATER PCB-SD0000077136 Pi; 1I5S,> fcf a lottar Ols Pals la Stadbhol: of tkis lotior,'mlao fc'..;s-- ,approprlatii,.,.______ 'i^^-^aa^iiama^^eiamrsSaes^^^^ss^^iesfr-' thnix ------- c u ';:** ' Ta/f oar wdloal dopartaattC* far pafcl trafr txaa of data. la rslatloa s.a- r-la- la~.ao^ -.. ... "4*: wrafraT. ttra - yiadlag far MfltfIxBMd of fljjpooal' - of odr- "a- lx- "aafm 7 *\ ^lucjj^lgg 1 f ^r"11*^ **** usd 'la 1 W^yl1 nrry?mwr.l and. fodJj la ete ptpc iarfaatry tad laficr laluticT* Xs it IfiaXy that the 4H t y --h >*i n ta t3a Ex i< WATER PCB-SD0000077137 ` --x---- ( . .- <v* aV*. r *vJ * v^-jE^itiV5; /,.? - .,,r.^-.'7^j Ril--| !ST^N <3 A& -vS-~pR A N. Q\* t-:, QF/50 akti saou-^c: ftuyuwi J4< is Tf2JX 1444 STQCXMO^M V, BV(AVA4<Ji T Ncvemte c Mcnsasr s Zurcce EHUSSZLS 1 ' Belgium - -^-&?cr the attention of Hr. D. VCCD . *' - <i : -i; "' - ' ...' - - ~ - .... - - ........-................ '.r!-`r-T,:"r-rj. , ,, . * ; " .-'' '''- ''=*-*.' AHCCLCHS * ;: ' .......................... `-' ' - - _r - ` ' ' . '-f&itilto&jS&xrg r~ ' ' '''. Jr\r-*-^ As szz.zl.znsd, there has bees seme public!.by Is Swedes ctncersisg investigations made at she Institution cf Analytical Chemistry as the Stockholm University. These have revealed chad a group of products called Polychlorinated 3i-Phenols ? PC3 for short - accumulated :is rtai^^rgaMyofsj^^ are^aald .ho jb '::;! r^I^ed ha":DDr :'and'<epiail7 pbiacrsicus. 1 '* " . '.: .' dings were discussed as a meeting of scientism as the Veuner-Gren Centre lh Stockholm cn November 22Selcw please find a translation of as article is she Swedish daily paper "Easess Nyheser*'*:- "It is found in salaaa and is pike. It.is found is sea eagle Living on fish. It is found an tho-sur- face of the needles of the fir trees i than is Tip the air. It is found is the heir at vr-flve narrfchs ... baby... .. ...............'- * * *.**'' "3 The 'scientists 'working with 'biocides have for ay long tine seen this something as unknown "peeks7 on/their ' gas chromatographs and at a meetisgN4t the Wenner- ' - Gres Center, Research Assistant Scires "Jenaen af the Institution far Analytical Chemistry at the Stock holm University could reveal the Identity of these peeks. It has been found that they consist of a group of poisons, Polychlorinated - (for snort ?C3) which are closely related.- lo, '"and equally poisonous as, DOT. FC3 is broken down considerably slower than DDT and gives rise to dacagpuf liver and aids. ?C3 is not STR 011391 r-- \/ W WATER PCB-SD0000077138 I WATER PCB-SD0000077139 v. JEl 3>^Vv temperature arh pressure*. In- paints: and- a_s- pig ments in various plastics. . ?C3 is act- isoorzed- oalj as such. It Is also part of several" finished products. Nothing Is known as to the way in, welch It reaches the water and the air. According to. Mr. Jensen, prcducts containing K3 have this openly declared. sFiCkf"2*in,Istherqouuaghllythheamfofeudl, whether efcscrhetd or by i: T **+ via. the with the aide, It can cause dena. "`cor DET highest permissible concentration in' the^'air been set at 0.5 - 1 mg/cu.aetre. Per PC5 It been nenzicned to be 0.5 ng/'cu.aeore. Another dally paper, Svenska Eagdladet, baa a shnilar article. Here It Is mentioned that Mr. Jensen., work ing under Labcratcr (Professor) Cunnar Widnark, casdisclosed facts which will have far-reaching iaportancssince the findings have proved a new source of pollu tion. of the nature. ^ Cna of the'participants'at the meeting was Er." A.7. Holden cf Scotland, 'scientific contact nan between.the .twelve . a.Z.C.3- countries, vha has estahlished 'cccrdinaced analysis cf chemicals used and found in nature. I suppose there Is no doubt that what bas been tamed Polychlorinated Biphenyls Is equal to Arcelor. There is also no doubt that the published facts will cause considerable unrest In several quarters. We probably will have to have Arcelor registered with the Swedlsn Board of Poisonous Substances and the industry will have to be particularly careful_in handling the material. - The problem In scae cases of course say be the disposal af used material. I understand that there hardly exists a convenient method cf destroying Arcelor and that " possibly burying umiseabla material may be the cnl7 answer. We shall be glad to bear from you soon. Tours sincerely. RHHG1 SIRJUUi ,.._jdLAG WATER PCB-SD0000077140 Nr. *. . Kiatesr .general Offices ~ ; FTDRAUX, umaa ^ ~ ___ T^rvS*' 1 .:# .' .' 7 -Deer H-V.rfc`I* .,% V *t 4.. `''vC^V ' ' . f-.r ., , ^ " * ; * la order to deeply with recent changes ia labeling laws eoaeted by mwmI state legislatures, tto subject of correct labeling for the Pydrauli has been a great concern to as. this situation was brought forcibly to our attention by - . a 'apecifio'repeat. . rj&tojgfflawdlto fallff3r^^whlchljb^t ppelsa^fro^|lcBlanto' . .;;x;Batanpvis;:not5in:thelbest-XntereatJaf..T?l^ptratxl-?ialeB'aiid :is , such that our competition eould use to great advantage. The language of the Socoay Nobil label Is aa follows* CilTIOI Containa Chlorinated Hydrocarbon*. Avoid prolonged breathing of vapors or aists. #8SAvoid "contact >with eyes" or prolonged "contact -" with akin. ' ~ / ; - If akin oontact is had, rewov* by washing with , soap and water. ,?or ayes, flush with water. . * ' - 1 If slothing becowea soaked with fluid, resave prooptly, end launder before wearing again. This is in cooparison to the caution label used for Aroclors, which ia as followai .. . .B cinioi. . Avoid prolonged and renewtad eon tact with skis. ; . Avoid prolonged breathing of vapora and dust. 1% Is our desire to eowply with the necessary regulations, but to eowply with the winliana sod sot to give any unnecessary inforwatloa which eould very well (Usage cur sales position In the synthetic hydraulic fluid field. WATER PCB-SD0000077141 IBP. 3U B. Hiateer From Momarao On Itey 22.1SS7 *- Deoember 5* 1953 By copy of this fceao, X t requesting that you and Hr. Caspar! discuss what Is necessary froat the la baling viewpoint sod tha legal aid, la ordff to eosply, but yet ealnfeala our excellent poaitioa la this fl14, n would be appraaiate* If fee could girt os as soever by B#cnbr 15, 00 w say t*b* positive steps to oowply with the Sooooy Wobil reqoeet, ' . .. W3:bjt B, F, Salth .r FGL 0913771 NPC0106280 WATER PCB-SD0000077142 St. Laois - General OrflMi back Michels - Clevel&od September 3* 19*5 AROCLCR 1242 -- lalisncs Electric * Engineering cie^.i,^ Richard Davis RDAVI - As I told you an the telephone Mr. Baredoe called mm earlier this ml quit* disturbed as & result of y latter of August 27. TMs letter apparently alerted Hist seweehat to the potential toxic hazards of the use of Aroelor 1242 at elevaesd taeperaturea. Be told ae that the Monsanto litera ture furnished hie had been mere reaeaurlnc in teres of idiat problsas sight arise in their application. I guess shat really shook hie sas shea I sectioned that with teeperatures greater than 150 eeehaaioal axhaust ventilation should be provided to rwwcve vapor*. for the record Kr. Baredoe' application Involves the use of Aroelor 1242 as a coolant Is electric notors. Tea motors are aounted an mining equipment used at the face of a drift. Total values of Aroelor far the two notars is spproxleately fan. gallons. Baredoe estieates that four quarts per day of this quantity would be lost in the nine -- preaaaably all of It by volatilisation. Z told hie I doubted that the ventilation provided in nines would be sufficient to keep this sacunt of Aroelor at the threshold Unit value of 1.0 eg/cu. weter of sir. He told ee there had been taw oawplainta in nines idunre the motor* were being used. Be wasn't specific but I understood chat the cawplainta were of odor and irritation, bhether or not the levels are actually irritating I don't know, it nay be that the elaers have Just recognised that there la some thing in the air now that wasn't there before. Nr. Baredoe wens an to say that in his owa plant hot Aroelor spills on the floor were n mimiiiuiwi sad that hla own employees had eowplalned of discomfort. I ms brutally frank sad told hla that this had to stop before be killed sows body with liver or kidney ``---ft -- not because of a single exposure necessarily but only to weptm *1 nr that 8-hour daily exposures of this type would be smpletely unsafe. Haredoe called a secoed tine to inquire abcut the decaeposltion products with specific reference to decawpoeltlaa products resulting fran sleetrle arcing. I told hla that we had Underwriters' Laboratories reports on heat transfer fluids which were pertinent. Be recognised that the chief deccnpoeltlon MQKS 097373 WATER PCB-SD0000077143 Richard Davis Page 2 9/2/65 produce would likely be HC1. 1 emphasised that thle la itself is & good *nroinc agent" ehlsh serves e limit voluntary sacposure to high caecentratlana of decoapoeition asteriaJLs. I told Kr. Karedc* further that th Medical Department m skeptioal about the us of Axoelar* in ninlrm operations because we had not seen data to show absence of toads levels. I emphasised and re-emphasixed that the Aroolors are excellent products but must be used in closed systems if they are to be heated. S laplied in his second conversation that his engineering grou$ ms looking at redseign 50 provide a "sealed* system. 2 ZPWiaJb ZLeer F. Wheeler P.S. Mr. Haredoe pointed out that in his application the Aroclar could be heated up to nearer 400y than the 157 figure which I had Mentioned. zm HONS Q9?a?<t WATER PCB-SD0000077144 PHCCI22 ?CH. THZ PRCSCCTTCH a? AP.CCLSHS, PT7JLHGI-3, KC. AT THZ AKHISTCIf XSD AT TZ2 VX. <3. ERTC?in ?LU?7 April 1555 -------------------------- 2. Xxtler el -iv-- 15/ 155c) Kr. J. 2. Hrtrxsi, Lcnler. IT. H. 3. Epson, Hevpcrt > Hewpcrt T.I.2. Tils Xr, G. T.'Ti7lsr, Hempen Kr. a. 7. Txylor, Hevpcrt -* Keeper-; process Super: Kr. V. 2. Hirer, Ruxtcn . ,, Xr. T. ?. Stlcider, St. Louis * L~.=r.:h Pilot Kr. J. ?. Stlciiiey, St. Louis 4 St. Lrtli Lltnry XCL Tile xt St. Louis Kr. D. 3. Kcs=sr, Amis ter. Spire held Ir. X.C.L. Tile it St. Louis fuL Dr. V. A. Exy^irl'a rile Ruitcr. terlar.t 0250036 ilso Section II, Speciri cxtlcr.s ir.l Teat to Xerporr Ar_xl7tleil Depxrtx^r.t. , WATER PCB-SD0000077145 TZ . P7.CCZSS IN DETAIL, coned . uctaa.1 Packms . *"- *** Ar- - ir= drams. a =r d. 3_._ cloth being tied. or. the pipe cutlet far the lighter Aroclors "1-- a piece of fine gaus e far the heavier Aroclors, which have ta he' handled hot. ta of pipe scale e V...~ rarr.ri,ch plant vr.e: Avery cf the fil-a arrangements far filling and weighing drar.s are discurse- (evpcra Engineering Pinal Report, Septenher 1551, page 1D8 and 1 P3-10, alao in the atari-up reports, July 24, and Septenher 27, 1551. * The da-ana matt be clean and dry, especial cars being needed with electrical grades. Newport complaint N?/Si, Ncvenber 1551, cf turbidity' in 12-8 was traced ta the presence cf water in the d~ -- Apparently, in presence of water, the Arocicr'reacted on the galvanizing of the dran. Newport plant report, Decenher 1551, < installation of equipment for drying the drats . Care is taken net to do any packing if there is HC1 funs in the air The gaskets for the bungs of the dross have to bo correctly chosen. A sample of the gaskets supplied by the Melratr. Supply k Gasket Co. to the Krarstrich plant was sent to MCI, April 15-7. See also the . dis-cussion .cf-gacjfcsna-.crr-pnre. -2 r> -Seeder- -jGrT->4re-ldvv - -*-- Hr. Periertor., Deceter 155^, collected samples cf the labels used at -the Kram.rich plant; one a patent list label, end the ether a warning label or. tendcity. The effect of exposure of Aroclors to netal contact is discucsed in Section VII, cements, page 17 below. Generally speaking, the distilled Aroclors are packed in galvanised drars, the ur.distliled cr.es In black steel drars, Flaked or railed solids were packed in barrels or Leverpac containers, bulk solid or resinous Aroclors go out in friction type lid drars, (galvanised for the sistllied grades). Storage and blending of the distilled Aroclors is done in steel vessels sprayed wish tin or sino, or aiurinds: lined. I WATER PCB-SD0000077146 ??.CZ2S IH DPTAIL. ccr.cd. ?--1 2c ta; packing, ct 2lr.ce the Arccicrs are such effective solvents , they __ 4--s damaged by, ordinary paih-ta, lac-cars, Iranian-- varnisr.es Till a rearers la important in connection. with hydraulic v.-- IT V J containing Artcicrs. See. r=r emarpie, MCL. He search Progress ------ 1151, D? 5V25/7 ar-d DP 5V277/6 and 1152 DP y'ic/7 and 5 July"l=: ere., alac the Section IZZ, Physical 4: Chemical data, above. D--~ Tar electrical grades cl Arccicrs are nor painted. Kevpcrt Plant Technical Ccmrittee meeting, April 14, 1953, ?2Lg- 2, reported acne premains teats with lacquered drams Tor electrical grades. It was decided net to uae lacquered drum for rsamcua Aroclcrt cn a returnable basis, because the lacquer suffered at he high temperatures likely to be used in melting the naterial ir: he drums. ct ft Arcclora also are dispatched in rail cart. At the .Krunmrich plant the nanhcle at the car is prctected by a tarpaulin tent during fill; r Kevpcrt plant report for July 155^ rentiers .the instaliaticr. cl tank-filling facilities. The jCraunrich plant operating instruction; August 10, 155^ mention that rail cars fer Pyrar.ola and Arcclora are insulated and have either a steam coil or a atesr jacket. They are lined with Aluminium or else sprayed with tin and tine. Only dry air is used for unloading. MCC have a "Christmas Tree" fitting, a one piece fitting carrying air valve, dip pips, release valve_____ an d_ assure, -gauge- -_fom-aaca- on * marl- t amki . -1 `nTtr-i r Ittp'ori in t~ To' "era":. .* the ceil cr Jacket cf the rail tank ir. cell weather, Gaivanred cr lacquered drums are used' f'c " is. WATER PCB-SD0000077147 n. HA2A?rs. ! --r 1 -* harzT. .1 effect hior acza'r resulting fror exposure to. chi.orinatecL ially in. cases where people- working*, wizhr. anil elect zs have been, exposed. to. the 'Tares. oT her, high y chi era. Chlotr sera in. acre tires ie;==pr- d. -r sz. hers are litera.rare references to. liver t There was acre trouble of thla kind arcng the production vc-ke -- Ami a tar* in the early days of the develaprer.r of the Arcelorthat tire highly chlorinated Arcclcra were being cade. frer dlphe---which had care frtr lew grade benzene. Since good benzene has be-used, the aare Arcclcra have been rade without trouble. In Ma.ro- ' it waa reported that the Anri a ton diphenyl and Arcelor plants had 12 years without Isat tire acoident. Prcr the start of Arcelor nanufacture at the Xzz rrish plant the operators have been aupplied a clear, change, of c ethea every day, r and tire has been allowed at the end of the ahif far bathing, Opera tera are adviaed to waah hands and face bef re eating. The Amiaton eperatora do net have the aare lasue of clean cicthea. Percy Kay, "Cheriat--/ of Syr.zhetl Druga" , 3rd edition, peg- 1? The "Cheriat Analyst", Septerber 19-7, Vciure 3, Me.2 pace 33, -azd-.-i -ze-pc Mr.-S. les c rv Amis-- 'crxi pi as a-, -ve-c-2" cr. the ton dry cf diphenyl. / *iy 4 ,-* } KCC Bulletin ?-Il5/renticna'07p t higheat safe -concentration of hig. rare-highly chlorinated Arcclcra . r. air a. w- H. 2. Idkins "Cheriat-* of L-.duatrial 0.5 to 1.0 rg. as the allowable lizit give (> V II The HCC Bulletin "Physical Properties cf Arcclcra" terio effects arising frer the oral injection of A See the letters, 2. Kather to ?,J. Mather to Kewrar., January S, 1952. tensity cf Arcolcrs. ayvacd, Teesober 17, is viewing the literature See also ssrrerspcr.der.ee relating Kay 17, 195-, pages 2033 md page 72-3* above. the a. warn!. WATER PCB-SD0000077148 c' --. --------a - i ycu cr. Dec^r 3rd S' 53 Mr. V. M. Cscper --r.--* -- > --^ --n / (c V.D.S., V.H.C., ar.d article in. tda J, T. ", Valises 26, He. 2, pa^e 33, Septerssr a espy ci t.tia are at sr.e vamir-s re la as ar.suId occur lr. Or. October 27 j 19-7 Hr. Ear cent a espy- cj she Journal csssvrr.a. Dr. Jenkins did r. but the relieving extract r eatir-s: J will 7 ta: leal wervr. 1 3-- r is inter- w111. IIII II 11| J WATER PCB-SD0000077149 c a Analyst, Vai. 3c, tfc. 2, pa-. ; J. T. Baker Chenics1 Co., pwi-t ------- v September 19-^7 OK TnZ. TC2CCIT7 0? THZ "AP.CCZLSPJT :ic) Hebert M. Brown, Chier Industrial Hygiene Sec tier., Division or Health Eepc. or Puis He Vellara, Cl by a Si.Lcuis*"~Ms7 A re cer.tly published article (Kglie, K. Martin, Chemist Ans 17= t. 1 (19~6) ), has recommended the substitution of cr.e.cl - A.-cblcr:" as the melting-point bath liquid Ir. preCerer.ee t; cu: :o=ar7 sulphuric acid. As stated Ir. that article "Arcchi: ar: a group cl chlcrl.tated diphenyls produced by the Kensant: Chi deal Company. There Is need the re. ere to give warning. Per the *****-< -- r these compounds has been repeatedly demonstrated, beth Cron th standpoints of their absorption Cron the inspired air, as well as Cron, their elCects in produ s-ing a aerlcua. and (c4<_as"._^---------------- j, dematltls when allowed to' reusin In contact with the skm. Since these eCCects have beer, repeatedly observed, industrial hygienists have taker, care to see that the proper ccr.trcla hav teen established wherever these products are used, 5-- m-r,---1 the nanism allowable concentration cl chlorinated oitr.e: an 5-hour working day Is 1 nllllgran per cubic net er qC air. It is probable that- nothing like an uncontrolled industrial er sure will occur -in the laboratory. However, wr.ether an indivi Is subjected to- a possible acute exposure to chlorinated dip.te and its serious consequences, will depend upon tie site of the melting-point b xth, the caution with which it is used, and tr.e temperature to which It nay be heated. Likewise, with, careles handling ol the material and the resulting ccntarisatier, cl th. akin, clothing, laboratory towels, work table seriates, etc. t. way Is leCt ope.r. icr the producing ci dermatitis. Scrupulous cleanliness nus t be Insisted upon wherever this raterial is ha. I WATER PCB-SD0000077150 c ?J2Z, cc: Mr. A. C. V. Pemlngtcr. cf Newport, repcr *-- t~tr, Lecenber 29, 1950, page 5. wr.:5J: W- 'HEALTH ANT ."At Anniston, no special protective clothing the Cipherer 1 and. Arccicrs operators. A dally charge cr'c'c-pl-vas provided Ir. the pa.it but this practise seated bere-*"-'--* --Gauntlet leather slaves and face shields are, sf course, ava' "T* as require! cn the plant. " Tins of csld ere an sirtreat, theatrical quality, are tc in the building, but the application of the crear is left to the operators decision, of the Jcb in question. The rer. are expected take a bath, in their own tire, at the end of the shift. A good *1 M quality acap, and alcohol for robbing down purposes, are. ` The operators are sufficiently trained in, the need for pa cleanliness that a record of bath taking' is not warranted. C "Emergency showers are provided cr. each floor of the Lipher 1 -> ---XT"1 safety notices are widely used. "At St. Louis, Plant 3, the Arccicrs building is rated a toxic departrent. Each operator is provided with a complete set of clothing comprising hat, coat, trousers, combination under clothes, seeks and rubber shoes. A clear, change of clothing, creeps shoes, is placed in the operator's locker in tine for the following shifl. hen working extra shifts are giver, a clear, set of clothing. Canvas gloves and goggles are provided and 'Ply' hand barrier cream is available for use when necessary*. "Twenty minutes' paid tins is allotted for bathing at the end of the shift but, again, no record is kept that baths are actually taker.. Theoretically, feed is net allowed to be eater, within the Arccicrs building. Instructions are issued that hands and face should be washed well before eating. "Employees in to.ilo departments are giver, ar. annual r.edltaexamlnatior. and a lung X-ray ever/ three years.". WATER PCB-SD0000077151 r XI. HA2JLPJ2S, car.ti. A good. deal cX wcrk Pas beer, donea cr.: dc:?-- -i-- -he vapeur pressure cX the Araclcrs, and. cr. the dete manaticr. a-/c-_-.___ , i cX Arccicrs ir. air. See pages 9-, Section III, abcv*, *-! a. auzr cX this work. Ir. 155^ (letter April 20, N. ?. Happs be . Harper) the Adri-a1 -- expressed interest ir. the de Semination aX =iere-cuarsities cX " Arccicrs. MCI Pave a re shed. Xcr the detamnatisn cr erases ir. air by rears cX the "Halidareter". Mr. Illenburg, Harsh 15, cer.tians wcrlc dcr.e by K. 3. RisPa: Jr., cX MCC, Jure 17, 1953, or Che deterriraticr. ci the csr.cer.srss oX Araclcrs ir adr. Mr. Zller.turg also scates: "------------ work cr the saXe lirits aX Arcclcr vapour concen tration ir air is being carried an by the Medical Department, r at the Xetterirg Laboratories ir. Cir.sirrati. This work cr. anirais is well under way, and will help us tc knew a little better Just wpat is the saXe lint cX Arcslsr Vapours that fW*m*4m. --* -- * A que: Pas beer, asked, about the passible Par -- .>. <i-.-_------,- <* -- ..^ pairts are used' ir. greenhouses. r-It i; par rest Lre a ere what Parr " ,, and there is r.o evident rake then worse. Arcclsrs Pave been used. as rabbit repec-.ar.ts, v cut doing any hart to vegetation. Care is needed in laboratories etc. where Arccicrs are used Ir. he a. sirs baths; the re should be very positive ventilation. The vapours oX hat Araclcrs are distinctly Irritating tc eyes art nsse above a concentration oX about 3 =5 per ctr Ir. air. Newport plant report Xcr DecerPer 1951 records bums by Pot Arcelor -- a case cX a splash into a tar's eye -- without serious Oarage. Packages cf Arcclsrs leaving the Krur :er.t_cr. :ssltla toxic eXXeots. ch plant tear a _ate_ WATER PCB-SD0000077152 r XT. EA2A323, ccr.td. pdre .-.asards Diphenyl, cf :cune, will bum, aa--nd rreasonable car; :* _ handling it. prscauticna wi: tcluer.s are mentioned UsTe-'`-rZ, VT-29, and under ''Dteclal Pinks", be lew. *"* f*~-ta5- -- t r The Aroclors are handled as IT non-inflammable. Drums cf material are melted ir. the middle of the operating building, flames, and open gas flames are freely used to heat Ar. instruction, dated April 2S, ig^S, calls far a dall>- i.-s--__- cf safety showers, fire extinguishers ar.d gas masks, a "check" lies** Vw "--4 -- * J Flanged Joints cr. Aroclor heating system car. be a scarce cf fame. See the notes cr. gaskets, page 2, Section XII, below. Phosgene may be generated in electrical flashes and fires in tranr- foners containing Arcclcrs, but this is not thought to be a major risk. ' ' Safe tv Tcuitmer.t Each operator in the L~or.:lch Arcelor plant is supplied with geggi* rubber covered gloves, canvas gloves, robber shoes ar.d fore respira: See also page XT-1. A spare suit cf clctr.es is kept ir a case in tr d -- ipr-.m : hrr.kiap amen 1 ,-hsam> t h* - -us uai > fira-s -aid cc: ire rp-garTha. (chlorine), fire extinguisher, (toluene, diphenyl), stretoner, saf = : showers, drinking fountain, eye bath. Special Risks ' The usual can is necessary in dealing with chlorine, ir. lighting the gas furnaces, and in handling hot materials, steam lines etc. Diphenyl might start to bum in chlorine gas if conditions in the chlorlnator were badly cut of line. A Davis Tapctester", model K-I,, Type A, (Division cf Davis Emergens; Equipment Co., Ere., Newark, N.J.) is held in the department for use in testing the air cf the working building after toluene has beer, used, and for testing vessels before men are pern, before "flame certificates'' ar; given. - , ar.d a WATER PCB-SD0000077153 xr. eaul-ts ear Sherial Risks, csrrd. cataiyric ceil electrically heated to a Sized terperazur- ---' -v Air to be beared is aspirated tbraush it by rears cr a ''le^Taza'" bill''. I- ccrhustibie rap curt are- present, the terperarure or -* cell rices, srd. the ir-dica.ri.is therracaupie registers cn a calir* brazed scale. iratrurent has a rare adjustment, and ir is checked rviee a h by the ircrr-tre.it department, Flare certiSicatea mat give the number of rhe Vapctester used, also the data cS its last calibrat iar by rhe instrument department. The instrument haa beer v~-.- T 1 ir detectirg gas escapes, ar.d ir tracir.g spilia at gasoline,- , rrer a neighbouring ail reSir.ery irre a public sever which .a under Kcnsarto terrircry. Mr. 2e.iigr.ua, ct St. Louis, Sep tender 1533, diacuaaed the dar.gera at using Araclers ir irdcor paints. _He diaccur.ted the aaaible dargers Srar phesgere formed by Slash discharge** ir rsrsScmers charged with Araclcrs. See th pages e Sc rer.ee s ta saTe hardlirg cS glycidyi phenyl ll ere. . Or n. i> i WATER PCB-SD0000077154 bccj ?. a. ssncns o. a- OLsaa July 8, I7f0 Xr. t, <3* *4fikin* 71 fmident, Katariais SQrt&i* Usotrlo toapany SorcS Alma, yaaaschuaerta CllVf **r Jtr. Jcnkisai 1 ms fortunately able to rlait your 2ro*n St* Plant an June 17 TdtS Pincta.? 1 4r*h,in, 1 pamcnally found th* dUcaaaica infamatiYa and interesting and 1 lour mat favorably isprtsaad xicii th concern end interest 5rtaa*d by year ranagnant parsennsi. * discussed briefly da<* of the paints raised is jour latter dated June 11. 1 Td.ll try is this latter fca be ator* apecifia. 31 od*rrsdability - Biodegradation atudiea ecsducted in our rasaaren lafcor-itaida* la St* Louis Xissnuri ano In Ztuaboa, Valaa uamg sort la ccnnixtiss of local rtrur waters or activated aiudsta acclinatsd to bipbaayi give dirtot evidence that the lower chlorinated bipfcasp ere affected. 'Chare la team evidenee that chlorine position on the biphenyl ecnflguratioo doaa influence the de^Tte of dlatroation by tie alaroorttnlaoai. I hare eaaLceed a tabulation frea. car X&abon laboratory waitS attaoapt* to show this difftrenoe. Vo do nsjf have foranl inforcaticn regarding tie effect or sunlight or Other natural influence* on JLroclnra, gtporlanc* raise ever aanr reers indicatae Arcelor* ar* highly stable under all xsarwn cocmtloaa present la the ertTirorxeent. Ctedcity ** there la anpla evidence fyoa easy laboratori that eertaia speed** or bird* which are at th* top of the caring Pood chain cannot reproduce properly when JCS't are present la their diets* the XT, S* fisheries laboratory at Cuifbre*. fierila conducted a ready wnob indicated chat Juvenile brown ahrisp did not survive in water containing 5 part* per billion of PC3. Attached era copies of reports on these studies. EXHIBIT JL^Czs WATER PCB-SD0000077155 ncnscsto epcnaorrd flooa studied oa litaraicry rsss nd does* A suanry of th result* to date * is attached* Cisocaal - *Isa preferred cefchod far disposal Eisa tesper*bur ir-clnee-atias. 2 luspoet there ar* 4cvcrtl ooessreiAL burner* ca the aarkat Hilda odU perd ra **11, 2 personally Ltseaad bursins test* at th* -John dak Coepany4* unit is-yulo*, QSt!iAoM. fsepamturaj* mat iSCGTf to a**ur* that eocplat destruction la afittiowd, tovr taepar'- aturf* wuld only vapcrlta th Jtroalera and create ataospherU pollution, or, wrM yet, wold fsru, by partiil axtdatlca, eataxtala Holed could b highly ' tezli (<4U ftirans tad dicsElas). Vlt& lrclnerttioa Ed is. ftread Haled x*t be scrubbed frt the stick Ctx tod. tttttnlltxl before dlOpeaal, V art plaralnc for as iaitlal Installation la case of our plants later this year* la a aarrlo to our puatooaro *ho ' nay sot h&T aoocoa to other Incinerator*, bar* offered to accept scrap JLroclar far lasodlata atoms and arestual incineration, tfwtatiToly, toeaar.to id.11 chars 2# per pound of returned eaferial. Cols chars* 4e* not include freight or ccattlaer cotta ' and dll bo reviewed Hi on final iaeisentlos costa are aacabllahed, Material adich la returned for disposal should bo addreeaad to Jtariaarrto Ccapacy, V, 0, rramrich riant, lancet, XlllseU, Attactlcei Saporrlaac Department 246, . Solid* oonta-itnatad efth JLroclor* pwet 4 bid*** dvailaosa. la yes, n have not tasted art iaclnantor with tfceae aatarlala. tbatll ao gat 'core laforsation the boat w css advlao la aef* burlxl la sn authorized, properly operated land dll located a**y doa try "- Vo harr laboratory wsric usd ax ay on odor fares ef dootnctloa, As ye* no eoccoclceLlly faaalble spprcjsch fc*ft been fnaod, Malytlaol Kathode logy - I here attached copica of Jtaaancn'a enaiycrcal produra far th dctarrltstioa of fd1% is eater, soil, air and biological aaupl**, Ve are iateraeted is oo*p*ras our netted* eith the** devised by other Lahoreton eg. Any esanonxa your lehcrratary cey here wuld be *elcoa and a^predated. STS CC^CJ WATER PCB-SD0000077156 X baa*t tisaA ibcrn inTassatica Is tiAafai to jq 2f z.ean b of further 44rrl4* pleas# 1$ as tec*- 2na*r%l9V ** Mr- S. Ocris apngB* ZLacfcrl* i. U Qeabaa. V. 8* Pfi^C^erKf fitflratosatal Control tl -n WATER PCB-SD0000077157 I n-rT"'rn~i-"ri"T". nnnn~rTTT-cf iiiHWiu*t t'j n*1f O ; 'IU : Tsrs&RCS? .pi.n U N j^ # j,,j ft fl rt u tr a If u M it i* t n n non it ft ll fftt n| Hft Hii* lil-* ; ii(. i*l| In*. nl-.Mji* lI*I -*> Mlit* ii i ** I !i ft ft i*|V| o **.ci 'I |f * ii I i ft U ft Mfl l*> lI)I 1`4I f11l IfIt Ili'-ItJ'l 'ii ii u t*# u l-*!*- ii *r ft II II SH ft ;i n ii i i! U I-* it. it* ft ii it c* ;i u -< i * ii - [* it ii=i iiOll I'M ft' ii o n tf I* H o *l ft li U ft ' ft -* V- I Ml u *i u I <1 . ii *. h ft- H If-t*.|4| IO*' itfl rr li. - *i ft it ii j * u l-*!l MO /`il in tr* n ;i -J fit ft fit ft li* I). ft it < i . h I ^ r* i*- o1 4j 14* K ft ft . cf ft n p i-lr; o fl. 1 O ft o i u ji* h i. ii iiii in*" If-t* :nrft M fMt ll at IKJ *i1l ft U !l I1 *o it ft i I-* ll '-.l 't 'I fut. iol ft Ij** Uft *;i. *1 I) U JJ ft ft I-* I*. U ll ft t I. li II il ft 11 fl I* it Q It H II a ft I- |t ft* MI-' cl* 1i1l-1 4 1*1 Ift* ft *1 M nft. l/l . i-*1it/ a fitf ccii i * ft fi l-J M O al ft 11 !`IU tr t: iu II ll* ft a a IV Il ft j* I* I-*M U ll *o I-* li ft (*1/1I * la ft fl. II#* I* fnt *rf;tl fl* ll t * a a fft fl <1 I* *1 It ft Cl *1 it H O ft If cr n. t~t n. ft J4 ft l- Ij i** at li.f-/l`J ft-* 11 ft ft ii l) ' I i" ft *1 ll |J ) il ft I) i j ' i : i ,, |ili : uft iC <oiv'iI l*`fl ft * .1 it ft n ti ft m ill ft l* If ii o u *ii -ii ti ii. *j ai.i'* ft io-'Ia *i uft If If ,V ft ft ll ll ij i> ' oit iv i*fit }ri*t rfrt fftt* ft*|t is Jl u y* H i* i-i ft it 11 U ft ft cl rr ti a*o o q 'i ft. Ii-*'ii ii (`M 'l O it ft ft (I ft 1 i-4i il ft Uft vt II HCl u< (4 o ffitii rt r; Ifn>tt ft i *1 ii Ji ti ft ft al ft . if m ft I-* lu* 14**5 If**| o *1ft pr'ft ft 11 '-I lMl*l M H> Uf) IIft ft fftt. ft ft *l o 11 ! A' lJ t li ii u o ft* fr-ti!1.! il li lu *j n ia u It n JI il ct <l oil ft tut "ft H ii ft* [t t ii if it* o It 1 n. i-j tf tf. n ftl a it ia t* it ;r if i>. i-* u n >t it iI-I i<a <fl* Un u|4 *1 tfti 1<1t i* m jii *t.ii ;i tftr t: ft i* o i* ft : ! il. o ft- u o it H ji n. it I-* ri */j (i |j o ct i|tv-il*:|jl Iiti l?;i Jii*si* 1i/"J* ,*i* 11 ji * i ;i u ti*-tii *i k *l ft ft ii* fInI. >nifr oft fullt> itft :ni* i'Iat-la I* ,*l**4 Ik cl Ik ft It C| . i*t 'll ilijrt* 111! IMl ft o :n* ia iI-t*o-i . ! - ft l * I*J tfl* *1 4* ii |ii.l u|1 fit Ji m* ft ti n. u I-* lj*t' u ft | *! aft* 1* n rr M lN 11 (4 ft a ft ti fftt 41 II fiti o *4 o W it r> !< tt ft 11 i-* ij it i uOu *1 Jl Cl i* i* I* l-J ll JI o `I *.H ft ft at I * I* I t .r.S |* I-* ft N* ft I-* I E f**H f` lu it 1* rt if i* Cl til ti I-* it u i-* fi M <\M' n. t <*!'-< I ff ii a I * la | ft* at *t'li *4ft1 i14i !I'I lflt* I1--** II-** U4* t`| ft p HU i * n. fjiii'n ft i* <i ji ft t- I * ;i i- u . /ji.*u/ ft ut ir f* I ** !i i ii it ti.i* ii ik ft 11* it <t ft i-* ji ft ft* it ii li. 4*4 jl *4 ll o*ft ll tj i\ ft li n* ll o * 14 la f- M ^i 14 il ! ui ll* i- | 1* u O tl t>l' l-t f| .. . Ik ftti* lnJ t< * :rt0t ft u it iii*ft* tf i* i* n at JJ ;r 1 rC > li n*. i IJ t j ri j* 11 i* i( u tr n Ji; II ?> `I * i u Ci (J i: vI..I.1 4c*0. i 117 ij iI :iii * r, I i*i r \`v* n: r;J "Jb : i `.*1 -4 t-l M p n o jj rr rri*-` o |T I) m .f Jl1 O li |iaif i-J* ia i: jfjt tf:tii i:nir tii>*j J'nlim*iii ii ii >i n *.i;i ;i i n.:sain,!*i?! ;j o rj 1-* j] */! cj 11 *.ii U Cl Ml..* WATER PCB-SD0000077158 I The th<rd otrp i" to ziniuiac crpccurz oT Arcelor, to reduce zir'trd rater po.1 luticr., tn rcccri.cC. l. Arcelor to uses chi eh- can be controlled. This is the culy ray I see to survive. I believe re shsulc zshe su-c that cur plants heve gjniagrt air or strsaz pollution. I believe Aerie ten ie vulnerable are thet* ciT-ias HC1 ace Arcelor should be lCCiS controlled. Erreerich ter/ alio need help.. * ' X believe re should dcnonstratc that Arcelor can. be incinerated te hzrzlcss products for discczal. . X believe re should help ocr custarters dispose of eXX-irzee or ncn-rcroricaale Arctier, either by In cinerating or by tczic cure. - - I believe plasticiser sreu vhere their product is ci nice eccpcsure *risic IX Ares fled as a pollutant. w'z^rl'C * i f4cr.cv_ w < *1 ;*) We probably have 6 tenths to 1 year chile they firjht cut the DUT esse. I rant tc use this tire tc ziririte cur eapecure. Vs rill need ycur help ir **sci n-r TED carrots. . ._ . V. -K. Si shard us sJ <r -1 3 WATER PCB-SD0000077159 < ) . ) -VrU 2, report Ain: caiiinrs ai nniiLiG an ciiioruiarii) IH fH iUVIRONKiltT Ai* I:. LU3 TRIAL DIOfLSr LtBOHAfGuIiJ CHICAGO, MARCH 21, 1969 Robert L. Metcalf from the background data presented it appears that somethin? of tho order of 00 million pounds or polychlor biphonyIs (PC3) are produced annually. These products contain from 3 to 9 chlorine atoas pr molecule and baccmo increasingly inert and stable to environmental oxidation with higher degree of chlorination. However, about half the production is in the 3-chlorine a tea variety (Aroclor/12i2) At first thought it seams unlikely because of the major uses of PCS in capacitors, transformer oils, heat transfer fluids in closed system*, that these materials could be the source of the substantial degree of environmental contamination reported. However, about hO million pounds annually is stated to be used as planticisars, hydraulic fluid, adhesives, and in carbon paper. From this amount a very substantial percentage must escape into the environment as vasts. Because of the apparent high stability of PCS, amounts entering the environment would `be degraded very slowly and it seem* possible that at least. lCnillion pounds annually may become eavironnantaJL contaminants. Since the PCS'.s were introduced commercially in 1929 there have been UO years of production. If this has averaged 50 million pounds per year, then about 2 x Ifl^ pounds have been ' made and perhaps 2 x ID pounds have entered the environments Because of the apparent stability of thsse compounds most of this amount may still be circulating in the global ecosystem and this is suggested by the levels reported by Holmes et al. (1967) and Risebrough _et al. (1966) in animal tissues which are quite comparable to those found for DDT. Both PC8 NfcV 027182 740437 WATER PCB-SD0000077160 U . ) -2- and MI are extranaly stable and water insoluble and have been produced in roughly the acme total amounts over the pact 30 years. lhus it seems quite reasonable to conclude that the environmental contamination described Tor PCS is due to vasts amounts of these compound- xhis, couplad with tha thorough evidence from mass spectonetry strongly sugg-e-j that there is an important environmental quality problem involved in vastes of PCS. Ixperimontal Work Planned at Industrial 3io test.-- Phi3 laboratory is highly experienced and seems quite competent to provide standard data required by PEA. for evaluating the safety (or hazard) of agricultural or industrial chemicals, fhe long term feeding studies on rats and dogs vill doubtless servo to indicate the chronic toxicity hazards of chronic ingestion of the PCS at ppm levels and this vill almost certainly result in severe liver damage at soma reasonable level. The chicken reproduction investigations at 0-01, 1, 1D, and IDO ppm should be considerably more meaningful particularly in regard to studies of egg hatchability, shall thickness, etc.. While tha fish toxicity investigations will be interesting, I cannot see that they are particularly relevant or necessary at this time and I would think this data could bs obtained from Pish and Wildlife investigations, etc., and will undoubtedly bo forthcoming, unsolicited. * Conclusions and Suggestions..-- ' It seems to the writer that the evidence regarding PCB effects on environmental quality is sufficiently substantial, widespread, and alarming to require immediate corrective action on the part of Konsanto. The defensive measures presently indervay vill do little if anything to . % ** . * N V 017183 .' . . -V ^ ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- -- 740438 WATER PCB-SD0000077161 u ) 3 rofute the evidence already presented. I would suggest the foilowing: I*. A substantial analytical program to monitor air and vaeer cfflue-rs from Konsanto plants producing ?C3 and also those of major customers. 2. Prompt corrsction of effluent conditions where PC3 can ba demonstrated*. . . 3. Serious consideration or curtailing sales of FC3 fa* uses such as plasticizers, adhesives, and carbon paper where waste is certain to enter environment. U, Review of disposal and recovery re thods for PC3 in capacitors, transformers, heat transfer fluids, and hydraulic fluids. -Emphasize to custcaers importance cf preventing environmental contamination- 5- Thorough investigation of environmental fates of various PCS' s including photochemical oxidations, chlorination in water systems, etc. ' 6- Biochemical and electron microscopic study of levels of PCB ingestion which cause proliferation of endoplasmic reticulum and induction of multifunction oxidases in chichens and rats (perhaps these are partially included in present Industrial Biotsst experiments), ' 7. Begin investigations of possible ^biodegradable substitutes for PCB's as plasticizers, adhesiVes, fire resistant hydraulic fluids, etc., anticipating lea* of these markets as a necessary corollary of environmental problems.. Ire, far example, chlorinated diphonyl oxide* or diphenyl sulfides auitabla far these uses. They should be considerably more biodegradable- nY 0271.8^ 740439 WATER PCB-SD0000077162 PCS ENVIRONMENTAL POLLUTION ABATEMENT PLAN ` Introduction On 15 October the "AD HOC" Committee consisting of Messrs. M. Farrar, P. HodgesE.. John, V. Richard, and E. Wheeler issued a report summarizing the polychlorinated biphenyl (PC3) pollution problems from the known available information to date. Out of this report came considerable information, conclusions, and recommendations which we have attempted to tie together into a plan of action in this document. Cur objective has been to take a reasonable and responsible approach to the entire problem. Before we get into the problem, we should'clarify the meaning of PCB, the nature of the entire line, and how these tie into our product line of Aroclors. N V 02143 WATER PCB-SD0000077163 Monsanto entered the Arcelor market in* 1Q,n hy acquire,- ,,., _ Company or known todav ,, "*S Swa* day as ou" Anniston, first lo*d of Aroclor which Incidentally went out of Alston, Alabama to CE In 1031. S1 rCl0r 125U -- market has grown to 170 to 200l74worldwide. ^ ^ the Chemical Biphenyl Monsanto Product Line Nature of Material at Ambient Solid MonochlorobipWSSy 1 r'^Nr^N-C/ DtChJoro 6i fhrittt | ~r1 c n1o r o 0i phfe#i C\.^y^yC\ k^-cl Quaterchlorob'iipi^y ^ Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 pentachlorobiph^1 Aroclor 1254 Aroclor 1250 Aroclor 1262 Aroclor 1258 Aroclor 12715 thin liquid (oil) thin flush water oily type fluid material Thicker - transmissio: oil Heavy-MolasBes Thick - tar Very thick - liquidl Solid Solid Nv 02H37 WATER_PCB-SD0000077164 - 3- Total possibility are 210 theore eally possible chlorinated biphenyls Santowax or terphenyl Solid Aroclor ^U6o Solid \ Damage to the ecological syst by contamination from polychlorinatec Zy/J* biphenyl (PCB). : .id III. Extensiveness The problem involves the entire United States/ Canada, and sections c; Europe especially the United Kingdom and Sweden. As the investigation^ broadens other areas of Europe, Asia and Latin America will surely become involved. Evidence of contamination have been shown 1$ some of the very remote parts of the world. The involvement could and most likely will follow the DDT investigations. IV. Nature of the Problem Professors Widmark and Jensen of the Institute of Analytical Chemistry at Stockholm, Sweden, in November 1966, announced and confirmed findir. PCB in fish, birds, and eggs. Subsequent findings were made in 1967 i Great Britain. In February 1969* Professor Risebrough of the Universi * of California published an article in the San Francisco Chronicle relaying his findings of PCB in the environment of the United States. Monsanto confirmed the presence of PCB's in mid-1969 and confirmed the adequacy of -work by Widmark and Jensen and others; truly, the PCB's are a worldwide ecolological problem. HE* 031^3c WATER PCB-SD0000077165 4 Analysis Indicates the environmental presence of the 5 and higher chlorinated biphenyls which take the appearance of Aroclor I2p4 a- Aroclor 1250. We have strong indications that Aroclor 1242 or ar part of it degrades biologically. Since the Aroclor 1242 contains - 7 percent of the 5 chlorine biphenyl or higher we cannot rule out t > possibility that the observations my be a concentration affect of higher chlorinated biphenyls of Aroclor 1242. / To date trio re have freerrno^ reports of finding Aroclor 1242 present i the environment (except Autoo-^r'-l-g'iC La. rresaa^4-: the effluent of our plants ke/uu 0ur 0 /3 ^$ tAior/0h_ The seriousness of the problem can best be spelled out as follows; 1. Fish - Marine or aquatic species concentrate PCB in the fatty k tissue. Toxic is small quantities (down to 5 ppi-) to sensitive rr.. life such as shrimp. 2. Birds - Predatory species feeding on the marine or aquatic life a further concentrate PCB to possible harmful effects. Specifically in birds PCB can affect the calcium metabolism leading to egg she! imperfections which prevents proper hatch of the young. In fact, Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCB's in controlled tests. 3. Man - There is no harmful effect known to man or other mammals aft 40 years of production. Investigations are underway by various sources. 4. Political and Public Emotion - PCB ' 3 are falsely linked with DOT because PCB's shew up in the analysis for DDT. PCB's are linked w other permanent type chlorinated hydrocarbon pesticides. This becomes particularly serious since about every article of food in country is being examined for a trace of these materials tlLyj1 Sd A r/w J f ____ ' \)x/> F. C*rv '.Js- A * . /- N tV 02 1 39 WATER PCB-SD0000077166 5 V. Effect on Monsanto Business potential at stake on a worldwide basis: Fluids Plasticizers Total/Year 7CSf lbs, 34M lbs, 104fT lbs, $16FT $6FT $22H $6~m a. p. $2-3M a.p. $8-nff g.p. Already competition is using certain data against us in competitive situations. A. Legal Liability ' Direct lawsuits are possible. The materials are already present i nature having done their "alleged damage". All customers using th products have not beeo officially notified about known effects nor our labels carry this information. These are only a few of the possible legal implications which would best be covered by the legal department. B. Public Image . The corporate image of Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environ ment will be adversely affected with increased publicity. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond ' questioning. This combined with certain scare publications is cert; lf`1 , . to give an adverse image. Guilty 'association (with DDT) will pre vail as the background while actual facts may be sparse. ' C Cvistvmsr oRc-iw.Mxo.n.s. NV 021^40 Some customers who presently use these materials will be "scared cfi to other competitive products. Products associated with the same name or "trademark" will be adversely affected le., Therminol, Pydraul and Aroclor. Competitors will use the information for-an WATER PCB-SD0000077167 influence on Monsanto products. Customers will seek other "outs" rather than become involved VI. Effect on Customers and Ultimate Consumers One of the unique features of PCE's is their fire resistance. Here basic decision whether to risk lives due to fire or risk extinction c some species of birds. In this case the FCB would probably be access as a necessary pollutant and tolerated under controller conditions. A. Electrical Industry - Capacitors and Transformers use Arocicr because it is the best inexpensive dielectric fluid available. 3. ?ood Processing - Bulk "deep frying" units for potato chips, fish, and doughnuts use the fire resistance fluid as an indirect heating medium. C. Die Caster -- and other hot metal working industries fire reslstanc fluids to protect the workers Affects a wide range of plastics and adhesives because the ?C3 serves as the plasticizer. A wide range of paints and coatings are affected. The "Carbonless" carbon paper used so widely would disappear. VII. Involvement With Other Producers Although Mpnsanto is most probably responsible for the U.S. contamina and Jointly responsible with MCL for the United Kingdom problem, we cannot accept responsibility for the world. There.are five known producers in the free world, several possible producers behind the iron curtain and couple of additional companies making overtures about entering the business. Monsanto representatives have on one occasion discussed this problem with a couple of these producers but they expressed no great concern. In fact, it is highly possible that one cf NEY WATER PCB-SD0000077168 ct these manufacturers is dumping his waste into the Rhine River. Ct any action taken by one producer will most assuredly affect the ot It is entirely possible that a joint plan of action could be devel but will most probably have to be spearheaded by Monsanto. It is -c likely that producers of other chlorinated products used with PCB's will be dragged into the investigation. VIII. Sources of Contamination Although there may be some soil and air contamination involved, by r the most critical problem at present is water contamination. To our knowledge to date the contamination can be broken down into two gene: categories, open and Indirect pollution. A. Open Pollution - Our manufacturing facilities sewered a sizeable quantity of PCS's in a years time. 1. Fluids Fluids are probably the most open source of pollution because their mobility. They also may be the least serious because th. are generally the lower chlorinated materials 2. Electrical Electrical customers have in the past sewered their wastes. 3. Heat Transfer Heat transfer customers have sewered their objectionable and their spilled material. 4. Industrial These fluids have generally been Bprayed into drains, washed down sewers and generally regarded as very harmless. All of the fluids have dumped on dirt roads a "dedusting agent" which inadvertently found its way back to the stream. N V 021442 729497 WATER PCB-SD0000077169 -8- ; 5. Plastics . The plastics are not as mobile as the .fluids so therefore * have not found and cannot find their way back to streams in pollution. . B. Indirect Shipping containers and the cleaning thereof for subsequent use ^ source of contamination) 1. Fluids ' a. Electrical - Disposal of "burned out" transformer and capacitors may find its way back to streams. Scrap units (new) are generally disposed of in land fills but could possibly get back to the stream. b. Heat Transfer - Leaks could contaminate. c. Industrial - Cross product contamination carried out of an air compressor. Residual material carried on parts. 2. Plasticizers a. Process Contamination from Washing (1.) Environment Contamination Swimming pool paints Incineration of wax coatings __ . Traffic paints (2.) Product Contamination Coating for tank lining fainting inks and paper coating! N6V 021iri'3 Certain adhesives IX. Recent Technical Changes Which Have Bearing on the Contamination A. Fluids . The sources of pollution were pointed out as they have been ir. the past because we are dealing with that quantity of material in tbe WATER PCB-SD0000077170 -9- environment today which was deposited over the past forty years, j-wrdmust state that responsible people throughout the industry' have ta corrective action to reduce contamination in the last two years. have also been technical advances which have brought about the use lower chlorinated biphenyls which may be an advantage because to da low chlorinated ones have not been identified present in nature. 1. Slectrical - The large customers have established collect systec the waste is recovered. Incinerators are being investigated and built for the disposal of the materials. There has been a shift away from the higher chlorinated types products and could probabl shift almost entirely away from those products. 2. Heat Transfer - System have been tightened up and redesigned to confine the contents Here^to^ the trend has been to shift away from the higher chlorinated materials. 3. Industrial - Selling ponds have been built by the large manufactur to catch the material and decant off the PCS for reprocessing. Th trend here as the other fluid areas has been towards the lower chlorinated materials. 4. Plants - The plants effluent has been passed through limestone whi-. provides surface to catch some of the material. But high concen- ' trations can be found in our effluent (that is relative to those findings in nature causing the problem). ' B. Plasticizer Quite opposite to fluids the trend in plasticizer Aroclor has been to t higher chlorinated biphenyls. In plasticizers the lower chlorinated biphenyl will not be an acceptable solution however, the lower chlorir.; terphenylvcould offer a possible solution. NEV 021^<r WATER PCB-SD0000077171 10 X. Courses of Action A. Do Nothing We cannot deny the findings and the acquisitions by the various agencies. If we took no action we would likely face numerous s' " We would let government tolerances be based on public and political pressure along with any experimental or developed data which they may generate. We would moat likely be forced out of this business. Other product areas would be adversely affectedr' We would project, an image as an irresponsible member of the bus in world. Project poor customer relations. The only advantage to t technique offers is it reduces the cost but this too must be weighed against potential loss of business. B. Discontinue Manufacture of All Polychlorinated Biphenyls (PCS) Although we all realize this could be an eventually unfortunately the solution is not this simple^ Assuming we did stop manufacture Immediately, the pollutants are present in the environment, the liability is present and possibly by the shifting to the lower chlorinated materials and the recovery techniques the contamination may already be reduced to an acceptable level. Obviously the entire business would be lost without any or very few substitutes to be offered. Other product areaB would be affected. Financial Iosb could be considered- due to raw material contracts, customer ccntrac and royalty -- secrecy contracts. Competition would take advantage on all fronts. We would be admitting guilt by our actions. Loss of capitcl investment in the plant, associated utilities, and asse- clated processes. this action. We would possibly gain a little public image cn NV 0214^5 . C. Respond responsibly, admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. WATER_PCB-SD0000077172 11 - This approach would enable ua to phase out the higher chlcrina materials in many applications where they are no longer necess. or really desired. .Vecould maximize the corporate image by publicizing this act. We would reduce a known pollutant. Additionally we could gain precious time needed to develop new products and investigate further the lower chlorinated materials As new research data is generated our course may be altered considerably. Certain limited actions may reduce or limit the problem. ` N V 0 21hbo WATER_PCB-SD0000077173 - 12 XI. Recommended Course of Action Based .on the information available today the only recommendation w / honestly make is respond responsibly admitting that there is growl; evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. XII. Implementation of the Recommended Course of Action A. Immediate (By 12-1-69) 1. Set up a task force under a project manager or the equivalent responsible for initiating, directing and implementing all act that Monsanto decides to take. This includes sufficient budge neceasary to cope with the Immediate problems. This task fore should include representatives from Medical, Legal, Research and the two involved Marketing Groups and Public Relations and must conduct_liaison with MCL and other locations involved in the problem. 2. Decide on timing and content of any public and/or customer notl cation of PCS problem. B. Interim (Within 3 months) Fluids Plasticizers 1. Confirm Aroclor 1254/Aroclor 1260 are found in the envi ronment. 1. Announce differential betweer fluids/plasticizer uses. 2. Publicize the difficult anal, 2. Announce safety of other PC3' tasks. chlorinated terphenyl. . 3. Protect other FC3/chl. terph. 3. Educate customers on control effluent for all products. i4. Announce plans to reformulate 4. Initiate program to develop P certain Therminols and Pydraul 1254 & 1260 substitutes where control of the product is difficult. NEV 0214A ? WATER PCB-SD0000077174 13 - 5. Emphasize better control over 5- Investigate with manuf other Aroclor 1254 & 1250 the feasibility of alt< uses. products. 6. Initiate customer education or 6-r--A~zlyzrs--242 need for effluent control of all products. 7. Determine composition of all PCB' a. Develop a comprehensive Program C, Short Term (within the next 12 months) 1. Research - -Expand program for more meaningful biodegradation Medical "' studies and confirming analytical results. Exoan toxicity studies. Follow developments concerning publicity and those developments covering politics implications of PCB contamination. 2. Marketing - Discontinue or substitute replacement products fo: those applications of Aroclors 1254 and 1260 where the Arocloi remains mobile. . Work with customers to clean up plants on other Aroclors, Report the habitual violators or "do nothings" to the product group. Reclaim or safely dispose of fluids.' nev ozia^b Consider renaming products that do not contain PCB. Follow an: report market developments such as customer disposal systems. Follow and report any political or public feedback which may affect the contamination problems and must be coordinated with Medical, Research and Legal. 3. Production - Clean up plants and stop gross contamination. 4. Legal - Define our present position, recommend reasonable actic that will not unduely alarm the market but reduce the exposure in terms of liafcilitv. rnnffMriate recommendations with -v---' WATER PCB-SD0000077175 5. Public Relations - Publicize actions where believed advanta Certainly discussions should be held with other producers w same period to determine their planned course of action, i_? Long Range Tentative Outline (From 1 year to 3 years) Realizing that the comprehensive program must be outlined the "L Range Tentative Outline" is meant to serve as a guide: All aspec lr rJ of this program should review quarterly by Organic Management. 1. Research-Medical Continue biodegradation studies and analytical support Isomer distribution Toxicity and metabolism studies Water soluble removal Incineration analytical support Confirmation analytical Contract academic research for reference Develop new-and improved formulations 2. Manufacturing a. Process Research and Development (1.) Identification of typical Aroclor isomers (2.) Develop control for effluent composition (3.) Test substitute formulations, etc. . (4.) Develop new processes b. Clean Up Plants < c. Modify processes to meet market needs . 3. Engineering a. Develop and set up on plant locations incineration systems b. Design new processing equipment as necessary 4. Marketing a. Specify alternates or changes b. Customer liaison ' nV 0219^9 ' WATER PCB-SD0000077176 15 - c. Set reclaim or disposal of .fluids d. Work on name association problems 5. Patent' Investigate trademarks registered Cover with patents any work felt patentable 6. Environmental Control Develop cheap disposal systems for customers a. Incineration or pyrolysis b. ` Biodegradation unit etc. - c. Consultants in-pollution control 7. Legal Investigate and define our position on Royalty secrecy agreements. Contracts - Raw Material and Customer 8. Public Relations Portray to public positive actions at correcting the contamination problem. Release periodical statements covering our position. XIII. Probability of Success . 021^50 WATER PCB-SD0000077177 16 XIV. Cost of Program " Neither the program nor the "costs h-ave been clearly defined at th However/ a cost estimate of $220/000 for toxicological, work alone been presented. Tentative figures indicated under the worst cond: the entire program -could run as high as $2.0-2.5Sf. At this stage very difficult if not impossible to develop a reasonable cost figu: one point is clear it will be larger than the normal research budge handle. For this reason/ assuming the approach is acceptable, we s be forced to ask for additional appropriations to fund the program. XV. Future . Follow developments on the problem as they unfold. Develop an aggressive research program to confirm or deny findings a: better understand the problem. Develop costs for the duplementation of the Recommended course of action. Develop specific actions with each department Involved Submit the actions with coats for approval Develop a timetable to solve the overall problem. Prepare for "precipitious pullout" or drastic legislative action althc we do not feel this is a likely possibility. nV 02l>5t WATER PCB-SD0000077178 ACTION DO NOTHING DOLLARS PROFIT AND LIABILITY VS. TIMS DISCONTINUE MANUFACTURE OF PCB DOLLARS "1 ' l -----1 70 71 72 73 Time RESPONSIBLE , IMOT1 ` DOLLARS 70 "7l " Time . . 72 73 NV 021^52 729507 ---t--70 71 7? WATER PCB-SD0000077179 PROFITS $ PROBABILITY OP SUCCESS 70 72 73 74 Time NEV 021453 WATER PCB-SD0000077180 WATER_PCB-SD0000077181 ?&!>&/}&)lnr ccjjss. nV 02l^5 7295 m WATER PCB-SD0000077182 XIII. . Probability of Success XIV. Cost of Program $220,000 and bio with max. at $2)~25M XV. Future N V 021456 729511 WATER PCB-SD0000077183 State of Alabama Department of Public Health Oon\ld E. '<Vit.LiA.MSON. M.D. * Statu Health Officer March 8, 1996 Dear Rev. Weatherly: In-house dust samples collected in November 1995 have been analvzec Weston. Inc. analyzed them under contract with the U.S. Environmental Protection Agency (EPA). The amounts of polychlorinated biphenyls (PCBs) ir dust at your address are listed below in parts per million (ppm). Location PCB Level ppm Floor at main entrance Floor at entrance by office Floor at entrance at fellowship hall 1.80 ppm 3.84 ppm 4.42 ppm EPA lists the level of concern for PCBs in dust as 1.0 ppm. Your dust PCB level is above the level of concern. We know that you may be exposed to PCBs by accidentally swallowing contaminated soil and dust. Contaminated in-door dust can add to your total exposure. Exposure levels depend on amount and time of contact with contamination. That is. contact with more of the PCBs for a longer time cause: higher levels of PCBs in blood. Since the meeting on January 23. 1996. we have been working with other agencies to solve the problem of PCB contamination in Anniston. Decisions about clean up and testing other neighborhoods are being made this week. We will provide a report of the exposure investigation to everyone bn the mailing list. If you have questions, call us at 1-800-338-8374. Sincerely. /Tt Neil Daniell y Ge__o1l_o__gi:s__t Division of Epidemiology 'ulmini'Mfjmc Ofnccw: Nrmjndjlu Mulf. .iTZ F.. Putcun Avenue. MiMitsfiniefv. Mainnti Wdrov Monrnc .Street. Muncsjrimerv. Aljbainu .iAI.iij- t){ 7 .ln{ 1 I WATER PCB-SD0000077184 West Drainage Ditch WATER PCB-SD0000077185 H H ; EEffl!!1 "V-l WATER PCB-SD0000077186 Vo The Anniston Plant plane for poly-ehlorinatad biphenyl (PCS) determination* In liquid vaaca trees* including *ource*,quantiti** and reccwaendad action* era Included. We do not plan Co look for at*o*ph*ric loeaee baaed on our praaeat mutual feelin( that loeeea to Che atmoaphere are nagligibla. The target date* are baaed an 1) one nan full time (K.C.Urljht) sampling, correlating and reporting thee* and other atudlae; 2) one chemist for one to tvo months and aufficlant analyst time thereafter; 3) that adequate aethod* are developed and reduced to plant practlca in time; 4) that adequate inatruaants and in*trument else are available. Iteaa tvo through four require r ehuffling of the Anniaton Laboratory plan* and will be diacuaaed with U. a. Kuhn and J. 1. Smith (aince low color Aroclor 5460 aaapla preparation i* sffsctsd). Also,although electron capture equipment axiata at Anniaton it la not praiantly t up *nd operating. Thli will maka meeting your propoaed schedule of being ready to run PCS aoalyaaa by the Tucker aethod by June 2 unlikely. Propoaed Plan 1. Obtain groea tempi** of Snow Creak for vlaual check* te determine praeence of discrete, som-eqoeou* liquid phase in pool* or other ecream bottom area*. Completion determined when dovnetreea limit of dlecrete, noo-aqueoue liquid phaae baa been established. 2. Obtain and analyte for PCS, saaplaa of mud and vatar from Sncrv Creek at tvo points down stream of limit eecabllebed in (1). Start 5/1/69 Complete By 7/1/69 One of Che aamp ling paint* will be at the mouth of Snov Creek. Tvo sets of sample* taken tvo veeks apart will be used. (Total of I sample*) Target Completion S/1/69 HONS 09729V WATER PCB-SD0000077187 -2- Fropoaed Plan (Coat'd) 3. Obtain two sop let of mud and water fro Choccalocco Creak - ooa near Saw Creak confluence oak second t-10 ilea down screes aer Jacksoa Shoals. Sane frequency as (2) above (Total of 8 soapier). Target Compi 4. Further action oa mud and water samples will ha decided after results of 1 thru 3 ere ia. Decision Tar 3. Complete the lo-plant surrey now underway to identify and quantify sources of FCX to the sever. a) Identify all departments utilising or processing Aroclor*. h) Audit Aroclor end SCI departments (pre viously identified ss major sourcss) to determine source sad amount of PCX loee te sever. c) tacommend Mens of recovering, elimi nating, or reducing losses from sources Identified in (b). Completed A/13 Target Campled Target Comp Is cl d) Define requirements end rough coat te assure verselvee that lose ef Aroclor te 8ao Creek (Salid end Liquid Aroclers) is limited to solubility losses. Target Coeaplecl establish continuing monitoring systems: a) For loss of Liquid (or Solid)Aroclor to Saw Creek (hopefully aero). Target 6/1/70 k) For weekly or monthly PCX om our effluent te leow Creek (solubility lasses). Define Keede 9/1. a> establish water sampling station ee Checcslccco Creek to momltor FCX end Farathlom. In Operation 6/1/ 7. Iavaatigate oeaos of disposal of Aroclor scrap. This would oead to be e cooperatire reatura betweee teaserch, Marketing, WCZL, Anaistow end CX9 since the problem Is noc unique to a single Monsanto location and la facing oer csstaesrs too. Schedule for 1970/ MONS 097291 WATER PCB-SD0000077188 -3- Thsc completes the proposed plan. There ere a faw other point* I'i like Co Beat loo though. 1. The Anniecoa Plane ie proceeding with project* to reduce the Aroclor in recovered MCI * com of which is sewered. a) The "catch-tank" in the HC1 off-gas line has been successfully started up and It collecting icee material. 7 b) A membrane type eoalascar 1* to be in*tailed in May to remove organics from the absorbed MCI. Aroclor from these two sources will be burled la the toxic dump. 2. Cross sampling of $now Creek started the week of 4/28/69. Snow Craek outfall has been monitored for pfi and X BC1 for several years. (Potassium and mercury analytes are no longer run) 3. Preparation* are well underway to start the Aroelor/BCl departmental audits. Actual sampling should start within a week, if the analyses can be run, 4. The only depercaenc* using or procssslng Aroclors st Anniston srs: t) PjS. - s Thermlnol systsm. This is drainsd to drums when replacement of Thermlnol is required. This has bean done in this manner since startup. b) Aroclor Procasalag Two Thermlnol systems Floor cleanings Spills BC1 off-gss Bo significant amount is lost from tank ear cleaning sines any material (including heels) is drained into drums, clseaLag cloth* are put la traah containers. Both drums of liquid and rag* are sent to the dtsp. 5. Present eetlmate of PCS analyst* time indicates 2 to J man-hours srs required per samp la. This any well limit ua to two to thrsa samples per dey. 6. Prasent guess on futurs monitoring Is that we would need to add one mas ts the laboratory staff sod buy so instrument (st about $10,000) to support ao adequats program. 7. An sudlt of the Parathloa and PSP Departments will be carried out this etamer in addition to the propoeed program. This work 1* urgently noodad to establish how close we are now approaching the ultimata capacity of the biological treatment plant and whsChar or not reduction through an In-planC control program is feasible. Answers are required MQNS 097296 WATER PCB-SD0000077189 Point* (Coat'd) urgently becauea they dataraine tfca court* g( act loo of tfca eulfur recovery eyetea propound for ptrathlon u well u tkm ultimate production capacity of t&a Parachlon Plant, While Paratlilon belonga to tha A| Dirt*Ion the biological traataant plant balonga to tfca Organic Divtaiou. I hope tfci* tuwrj will urn your praaant aaeda. Kany thanka for ttaa auggaationa in your 4/21 naato. A you can ae oany found their way Into our prograa propoaul. V. T. Taffaa MOWS 097297 WATER PCB-SD0000077190 ! Monsanto .m. fi. Poresman - Krummrich 4l( September 23, 1970 SAMPLING PROGRAM FOR AROCLOR LOSSES Memo-M. Pierle to W. Engman 8/5/70 TO : W. C. En gman ec M. J. Beaudine C. L. Bratsch C. F. Buckley B. V. Corlew P. B. Hodges H. J. Horner Papapeorge R. Savage J. Garrett CONFIDENTIAL The following air sampling program is an addition to the total Aroclor sampling program as established In a memo from M. Pierle to V. Engman dated August 5, 1970. TYPF. Air SOURCE Different locations within Department 246 FREQUENCY 2 samples/week The air sampling program will be conducted for approxi mately two months with the results being distributed on a weekly basis. 'A'iv.V - -V' M. R. Foresman pd MONS 098220 WATER PCB-SD0000077191 TO ''"4'. 0- Ramsey - Anniston Plane September 4 1970 'aroclor lossesto the atmosphere AT THE HC1 SCRUBBER JET E. C. Wright J. T. Sell V. R. Haupt J. C. Landwehr Operations show that HC1 gas not converted to Muriatic Acid is by-passed to the scrubbing jts and severed. Based on acid produced, sold, and by-passed for the months of April, May, and June, an average day resulted in 4500 */hr. of HC1 off-gas. Calculation* based on vapor pressures, the temperatures that the HO come* in contact with, and the ppr* of Arocior in acid - yields the following results: 0.6 lb./hr. or 14.4 lb./day of PCS in vapor form reaches the jets 2.1 lb./hr. or SO. 5 lb./day of ?C3 in acid produced Total " 64.9 lb./day of PCB passes the HC1 kncckout tank Assusiing 100% contact at the jets, 0.47 lb./hr. or 11.3#/day of ?C3 is severed with the remaining 0.11 lb./hr. or 2.6 lb./day being lost to the atmosphere. Poor efficiency at the jets increases the loss of PCB to the atmosphere considerably. :Jcd Attachment P. 0. Ramsey 05b <314031 WATER PCB-SD0000077192 //it OLA- GAs (X^. %%/*'** *"* ft.waited " (Z'tn*# /f^" Okk (?As ovex. C//jlA/tJZs 3rXs& ^n &/?. 'kPtfg c ............. -............................................................................................................................................................................. - - (* &$ f/6l jui{<nu Cfipj/z^k a/j&h:. -*r*d (/ts'k) .................. - 0. CLZ3 /J*f ... . K #33icMt, /111 /fgKtti ^AdC %-*t'7b4 </&*). Z~ . * tilt ^fcm fkf_ Ltbi ti/ut 3,*W,6* /i tie/ '*+rCtb **4. / ------- - J'ZZZiifZ x 34~S # (lK? * i^ >& Ji^co fjfrjr+Lc l{ _ _ 05 W 014032 0. 02L> 7h^h -- Ql<T no* /C It3 '- *- ................ f/S- * *11 a . frr 0.005! o-aozt t~a * '$. m.\ /b - - - , t WUV *' .VA0 jp'r*. <u ih/S'/-jLMszaezjzs tik_ CA'll'i. 7wj4 ^ /ZtJ l Mid \ \ \ tA t i!\ A * t * l* /4.4- &/j_ WATER PCB-SD0000077193 OSU 014033 WATER PCB-SD0000077194 Sco -n ib 300 & yici. Ccc/ (y/fs Sjjtftfs* /* ^4 - X* ?7 ? - *3 TV _3i-- . TLQ / )//,<r^ /A. ^C/<2/ '-/0c ; 5?w /V. *^/c, /0 ~ /9 'G/ (2 --/*' 7%<siAe 7%g //aw - 0.oool.s~ o. oooif 9^ -r * /o tQ p<%' ^ <^0 " /d ............. )(?.** X*')~ * ............ _ ... . WATER PCB-SD0000077195 Monsanto lc dr--.1 l """~ St. Louis - General Offices August 7, 1S70 ------- ANNISTON - PCB - CLEANUP PR00RAM TO Mr. h. S. Bergen, Jr. - H5ERQ " Jor.n Mason E. ?. Wheeler " JMASO W, 5, Paosirearrs . - v?a?& F. J. Hoizupfei D. 3. Hoarser - FH0L2 - dhosm J. R. Savage - JSAVA Q. L. Jessee " Anniston J. C. Landwehr ~ Anniston CONFIDENTIAL - P, fc, I. AND DESTROY Following are the moves underway resulting from the FDA findings of high levels at PCB in fish taken from Choecolocco Creek down stream from it's confluence with Snow Creek. STATUS f(p It / (1) We are presently discharging to Snow Creek about l6#^iav of PCB (down from 250#/day In '69). Measurements of departmental waste streams show a total loss of only 2#/day. The discrepancy Is believed due to; (a) sampling problems in departmental waste streams where two-ohase systems of water and free aroclors may be present, and (b) possible pickup of PCB by leaching previously deposited PCB from the limestone neutralization pit which also acts as a settling basin. (2) Work to further reduce losses presently underway: a) Sump is being Installed at the aroclor department to cap ture free aroclors from the 275 gp flow. This la believed to be the largest departmental source of sewer loss because of the liquid aroclors frequently observed. However, sampling work did not confirm the belief because, no doubt, of inherent sampling problems. The project was due for completion on S/1, and had been delayed because of an underground spring. ' b) Curbing is being installed at drum loading area with dry pick up of spilled aroclors planned. c) Investigation of treatment methods - adsorption by acti vated carbon showing most promise to date. (3) Joe Crockett, Secretary of the Alabama Water Improvement Commission, will try to handle the problem quietly without release of the Information to the public at this time. He believes that FDA will not precipitately in this matter (he did not advise how FVQA might react). Dr. Myers, Director of Public Health of Alabama, wants toxoity Information on PCB's and this will be conveyed per sonally to him by Jack Qarrett next wk. J HQHS 033851 WATER PCB-SD0000077196 H. S. Bergen, Jr. August 7, 1570 Page 2 PROGRAM / (a) Public Relations - E. V. John developed,4 proposed state ment to be used in event of publio disclospBa-bat. after consul tation with Legal, felt it should not be"led beciuSBv of the recent lawsuit instituted agsinet the pliant by BASS^ Therefore, an innocuous, essentially "no comment" typ_aateoent is being * drafted. (3) Operator Education - All Anniston personnel have been read vised of the necessity to avoid sewering of any aroclor. (C) Mechanical Program (1) Departmental Sump - at extra cost of $2,000, work is proceeding on an overtime basis with completion expected 8/12/70. This will eliminate the possibility of large los ses from the operating area. (2) Loading Area - Vashup of spilled aroclor has been stopped and dry pick via sand instituted. Curbing project is being expedited. (3) Neutralization Pit Clean out (a) Insaediataly, the settled material downstream of the limestone will be removed as well aa possible by pumping, with minimum stirring of the water. The solids (and aroclors) will be landfilled. (b) By-Pass of Neutralization Pt. - Cm crash basis, trenches will be dug to allow diversion of all water from the limestone pit. This will take 1-2 weoks and will cost about $10,000. In addition. It will be necessary to provide caustic ' neutralization of the acid wastes. This will be handled in the aroclor department via installation of a pH con troller and valve with temporary piping and trucking facilities. Cost will be about $5,000 plus about $500 per day for caustic during the period when the alternate neutralization is required. During this period, PCS looses should be no more than 5 ~ 10 lbs./day. _ .ii ' * MONS 013352 WATER PCB-SD0000077197 H. S. Bergen, Jr. August 7, 1970 Page 3 (c) Cleanout - The pit will be thoroughly cleaned out with probable removal of the present deteriorated asphalt membrane and replacement (possibly) by a plas tic membrane which can resist aroclors. The plant will consider possible structural changes to permit more affective operation and ability to make future cleanouts without the present by-pass steps. Recommendations rel* ative to this will follow. (k) Water Flow Reduction - Present total flow through pit la 700 gpm. For at least several of the streams, reduction of flow will result in icaaedlata reduction of PCS to Snow Creek. More important, reduction of flow will minimize future treat ment costs. In conjunction with the pit by-pass work In 3(a) above, approx imately 200 gpm of aroclor free water will be permanently diver ted. Included in the first reduction are the chlorlnator cool ing streams and most of the water coming from the tflran flare tower. Details of how this will be accomplished will be avail able by 8/14/70. Over the next 3 ~ ^ aontha, further water conservation projects will be Installed with objective of reducing the stream to the lowest practical amount, now estimated to be about 300 - 400 gpo. The projects will involve multiple use of water and fur ther diversions of aroclor - free water. (5) Final Treatment - Based on some indications ( and much hope), by September, the actions above mar approach the present plant objective of 10 ppb of PCB's in 700 gpm (or 0.1 #/day). The hope is raised because dissolved aroclor has shown a pronounced affinity for surface adsorption (as on walls of sample bottles). The solids generated by the limestone neutralization are believed to retain aroclor passing by them. Therefore, adequate settling and/or filtration following neutralization with periodic removal of the aollds may accomplish the necessary treatment (along with water flow reduction). The plant will proceed on preliminary design of filtration facilities with and without carbon treatment between neutralization and filtration. The deaign will be available for action in case the reduction la not as great as hopedfor or in case the control agencies demand more complete removal (control agency requirements are a completely unknown factor at present). By the time a deciaion muat be made relative to final treatment, we-should have better information on requirements and methods. MCttS 033 as 3 WATER PCB-SD0000077198 i : H. S. Bergen, Jr. August 7j 1970 Page ' C(Dho)Pccisahla, ccMaudCarendektfAaltseor sShaomvepdlinhgig-hSlienvceelsouor ffi^sh's<^imeni - , ting more sampling to determine extant of toe Problem Earl? SI?" the week of 8/10, legal site fish *112 be 5yTlT&oeSScfc=2ir near to confluence with the Coosa River {Logah Martin Laks) will also be taken from the lake. If thia.6s*H^s shoTM^h * 0 .ppm) levels of PCS, sampling will be extended to points do^hthe River. A high priority will be given these smpl^y ScoS Soke.-? Progress reports will follow at suitable Intervals. /np Paul 3. Hodges MOWS 0338 54 WATER PCB-SD0000077199 UGfI5au tQ ^ y u;n - Annii:ca, * *< May 7, 1970 lvi(CT <*<<*<< AROCLQS. 'OLLtlTICN AWIC CONTACT TO : G. L. Jesses ** J. C. Landwehr H. L. WHI Lams ?. 3. Hodges - G.O. V. 2. Papageorge - C.O F. J. HoLrapfel - C.O. J. X. Savage - C.O. . V. John - G.O. J. Si. Crowe - Deca cur E. G. Wright t - *<v i* On May 6, Messe,,rs. r C * Landvehr,'y*C. eGr . ImWprriogvhetmaenndt CI ovmismiitsesdionM, r.InJM. oLn.tgComroecryk.et Technical O^ecsor w twofold; first, co famiLUrire Mr. Crockett wi th the purpose o: =** ' Aroclor wastes and choir reported pollution pocenciaL Che sicuacion J c-R.-dence chac Monsanto Incends co cooperate with and, secondly, co ou - ^ efee,, 0 Aroclor on che environment, javeraaental igenc-es * Mr. Crockecc and che AWIC staff were totally unaware of* che published information concerning ArocLors. Copies of che most pertinent articles describing che aituacion along with Mr. Minckler'a scacemencs were provided for his use. Additional Lnfomation supplied covered che following facts: l) Monsaato Is currently Investigating Independently and In cooperation with governmental ager.c-. che pocenciaL ecological effects of Aroclors. 2) Investigation and research programs are underway ac Anniston co idencify, quancify and develop techniques which would concroi product Losxes co the environment. 3) Any Aroclors reaching che watershed from the Anniston plant were entering Snow Creek. 4) "he produc tion process was described In general decall co polnc ouc'chac water was not esa.encial co production of Aroclors, and waste vacer was produced only by auxiliary equipment such as steam jecs, ecn. . Mr. Crockecc was case appreciative of Monsanto's approach Co che problem and che fact that Monsanco came co him. He alluded chat our action would produce a aituacion chat was beneficial co che protection of boch che Monsanto and AWIC positions. His recommendsciona were aa follows: 1. Supply che AWTC with a general process description detailing pocenciaL lots sources. 2. Continue co develop information and aa major items develop Inform che-- AWTC. ' 3. Give no atatementa or publications which would bring che aituacion co the public's actenclon. - ' 4. If approached by news aedla, either che AWTC or Monsanco is free to icace ch-t che sicuacion la under scud/ by che scaff of AWIC ac che direction of che Technical Director, Mr. Crockecc. 5. If In che future, Information is developed indicating chac Aroclors art detrimental co wacersheds, Monsanto will be required co secure a permit from AWTC co allow certain maximum quancities of chlorinated biphenyl Q-SW Q1409 3 WATER PCB-SD0000077200 0. L. Jeaaae -2- Kay 7, l70 In atimeery, Hr. Crockett va noticeably unexcited at aur dUclo.ure and all hia rctnarka were directed toward a careful evaluation followed by action* as required by data. The full cooperation of the AUIC to reach the above ob1ec*ive on a confidential baaia can be anticipated. ' It *uac be rnace-bered, however, that all AWIC acciona are aubjec: to atatc political preaaure and federal control. ' /ba MQNS 099539 WATER PCB-SD0000077201 Monsanto . . rsNSM .*< *|^gr*^ cs. 1 sc31**-rr.2r** -- IT, 1573 c .TO J. C. La.odweh: Anniston Plan: ?. B. Hedges, PHCZG B. S. Tucker, Queer.-/ I have er.clcsed a copy of cha data given me by the State of A lab area, water pollution authorities or. the P.CB analyses in Choccslocco Creek and the Martir.-Lcgar. Reservoir. ' These data are collected by the U. S. FDA and are the basis cf IDA contact wish she Alabama authorities. You will notice than this is the general crer.d that cur own samoles shew in ccnr.ec tier. with PCS. While I was in Alabama, J. L. Crockett, Jr., Chie: Engine? of the Alabama Water Improvement Commission, reccr a 1-- r* a U that when we sample fish for PCS analysis that we a = pies above and below the Martin-Logan Reservoir, He ('-'suggested that cur control program should be writ; :er. submitted to the state as a report covering our 'zt at :crts, \ present status and our future plans in connection wi L--limiting PC3 in the Snow Creek effluent. He al "the state did recuire that we do daily ar.alvsis f< in our effluent and~ submit weekly summaries_to.J:hi later Improvement'Commission- in' Montgomery. Crockett told me that if this PCS issue hits the Alabama press, the Alabama Water Improvement Commission would be forced to close Checcolocco Creek and the Martin-Logan RenervoLr to commercial and sport fishing unless we can prove that the contamination level does not reach Che reservoir. The State of Alabama has no choice but to follow the guide lines of the PDA which calls for* nc mar? than 5 ppm PCB in fish. JTG:J U Enclosure os* Q 11*Q<?6 WATER PCB-SD0000077202 WATER PCB-SD0000077203 Monsanto October 15, 1971 Anniston TO D. 3. Hosmcr - G.O. O. R. Robirds - G. 0. R. Savage - G.C B. Papageorge - G.O. 3. Hedges -G.O The attached letter is our proposed response to Joe Crockett's request for a status report. We have an appointment with Mr. ' Crockett on Wednesday, Oct. 20 to present our story to him so we need your comments by Tuesday. I discussed the change in concept away from any carbon treatment at this time with Sill Papageorge. I aa also including a copy of the chart of weekly average flows and concentrations referred to in the memo. Other than these items our report will be limited to showing which Phase I and Phase II items in the original report have been completed, deferred or are underway. Att. osw 013355 WATER PCB-SD0000077204 ccxPAiTf cc:r?izzyriAi w/v o %,'tL MsararG at southwest soiota& optics op spa i**il PsACixrss Sc. JT.S" A-elsar*, Georgis, Hoveabsr II, 1971 Copies Co: H. S. 3rsan J. T. Gattsc! J. V. Gillsspls Irf: -Sallies 3odgc* ?. 0. J. L. SolrspTsl JTsssss J. C, Lindvshr Xsscn H- l. XiaeJelsr v. a. Psp*4scrgs ?. 3. Psric V. H, Hobirds j. a. SsvAga . AIcJn'w^ VV*h" 5^ --<a *-- 4b '< ------ Onw-- 'S > JJk t * _ J- 'Prv J~r 1 6. ^ r-- -- , -- ^rji--/ (?--Jn-d- r-1^ Vly. ^ ^ 0^ 'l*" ,A'U' 'CJ k L. -, /A- ^ 05W 014379 WATER_PCB-SD0000077205 MZZTTHQ AT SOlTl-ixcST REGIONAL OFFICE OP ="3a " i`+2i Paac.itrea 5c. 8~~-- Atlanta, Georgia November 11, IS71 These Present: Monsanto J. T. Garrett 0. 3. Keener G. L. .lessee J. P. Landvehr State of Alabama Joseph. Crockett Southwest Regional. 2?A John White, Director of Enforcement Dave Hill Dennis Cafaro Geers* Earle* Subject: PC3 Effluent* from Anniston Plant to Snow Creek, Choccolocco Creek, Etc. This meeting "as arranged by Xr. Joe Crockett at the request of Mr. John White. _ Mr. White had tiro primary areas for concern: 1. The Federal Deparsient of Justice has apparently recommended that suit be Initiated against the Anniston plant for PCS emission under the Federal Refuse Act. 2. He will be required to approve or recommend a Refuse Act disposal .permit for Anniston which Halts pollution levels. The PCS production history of the Anniston plant was reviewed briefly fro* its beginning in 1929 to the present. Cur program to control and reduce PCS emissions to Snow Creek was reviewed by both Monsanto employes and Joe Crockett who emphasised that we had kept hia fully advised concerning our program and our progress. Gene Jessee carefully pointed out OSk GU380 WATER PCB-SD0000077206 Meeting at Southwest Regional om:a of E?A .Vovesoer 11, 1971 Pangs 2 ' :.w-ac our production of FC3's had bean greatly reduced in January, 1971 and discontinued in August, ig71- It was explained that current PCS emissions in the liquid afJluar.es primarily restaltad frea our inability to v. a complete separation of biphenyl frem other polyphenyla. Mr. Jasaea stated that equipment would be Installed to * vastly improve this separation by July 1, 1972, and that by this tine a further reduction in PCS in effluents would be effected. There was considerable discussion concerning the Halting level of PCS that should be permitted in the discharge. Hr. White suggested "no detectable mount." Xr. Crockett and the Monsanto personnel pointed out that this was an undesirable approach. Tha preferred concept waa explained as a reduction in aqueoua volume accompanied by a concentration reduction (reduced pounds per day). This appeared to be accepted. As a result of tha neeting, the following agreements were reached: 1. Xr. Crockett and Xr. White will agree upcc an interim permissible leral for PCS ealssloos to be provided In the Refuse Act permit. Obviously, Xr. Crockett will press for a number in excess of our 0.3 lbs./day current level. 2. The permissible PCB will be reviewed again when our new separation equipment la la operation as of July 1, 1972 to arrive at a new permit level. 3. A summary report outlining our past work and future plans will be vrittaa and sent to the MPA office via Xr. Crockett's office. U. a second copy of our existing monthly reports on PCB effluents to Xr. Crockett will be forwarded to Mr. White via Mr. Crockett. '* 5. Monsanto is ready and willing to meet with the Pederal Z7A personnel concerning the PCS problems whenever requested and will feel it a privilege to describe cur program. . OSW 014331 WATER PCB-SD0000077207 clng at Southwest Regional cmca or spa November 11, 1971 Pigs 3 - ' 6. SPA can casus and sample cur effluents in mutual program as any tine they wans cm da this. (I believe they will ua cur data.) W explained to Hr. John White that Hr. 0. L-. Jassee, the Anniston Plant Manager, was the man who spoke for Monsanto at Anniston. V further explained, that Mr. Jack Garrett'* presence waa to indicate the support or the Company's Medical Department and that Mr. D. 3. Earner's presence vaa to demonstrate support oT the Monsanto Industrial Chemicals Company, who la responsible far the manufacture of ?C3's. It vaa suggested by Hr. White that It might he desirable to dredge Snow Creek. I believe we convinced him that this Is undesirable. Ve received strong indications that the Southeastern Regional EPA Office will recamend strongly against a Refuse Act suit by the Federal Department of Justice on PC3 pollution. The entire atmosphere of the meeting was favorable, including the lunch following It. bt 11-12-71 . B. Hosaer T OSM Q1V382 WATER PCB-SD0000077208 Monsanto s*r Paul Hodges - St. Louis ' September 18, 1970 - TO lob** Sell - Anniston c= J. R. Savage ~ JSAVA V. D. B. 3. Papageorge Rosmar - VPA?A - GHOSH G. L. Lessee - Arris- G. Miller - Arris c. J. Landwehr - Anri 3 r. J. L. Carder - Annls*. CQNTOHNTXAL In reviewing your proposed letter to Joe Crockett with Las11; et al w requested latest emiaalons data on the flaw to Snow Creek. Ve had hoped that It might, show an Improvement over the lat week in September and thus demonstrate a favorable trend to Crockett. Instead, the emiaaiona are considerably Increased with 9/13/70 at 6.25 ppa (or about 83 iba. of PCS for the day). Prom the Legal standpoint, there la extrema reluctance to report even the relatively low emission figures because the Information could be subpoenaed and used against us In legal actions. Obviously, having to report these gross losses multiplies, enormously, our problems because the figures would appear to Indicate lack of control. Realizing the extrema effort* the plant has gone to In order to curtail loss of PC3`a, is there anything more that can be done to get the losses down? Is there a possibility that sampling practises are responsible for the wide variations shown (you might try duplicate efflu ent samplers)? Are there any practises In the manufac turing area which might result In the peak losses? Obviously, we cannot aolvs the problems from St. Louis but we do want to emphasize the concern from here. Paul 3. Hodges /np OSW 014095 M.4I WATER PCB-SD0000077209 .GdSantG 1 U : b 1 fcl JA ^fcj i!fc) .\T!0SN7IAC -- Cacdvehr - Anarstor. Plant PACE A/ 1 /* r* / /. Octcfter 25, 1970 TO C. 1. lsse J- t~ drier V- 3. Japacec --e - C ?- 3- dodges - C. Z. kC- X- Savage - C. 2. J. T. Sell - G. Vright v. a. e*u=c 3. G. Wright, J. T. Sell and d. C. Lindwehr nec with J, 1, CrtcM-eth, Technical Staff Otrecmr of the Alabama, tracer Improvement Crmrjs:.-- Friday, Comber 23, 1370. * Mr. Crockets was "very well satisfied with progress at Anniston nn the =.3 problem" and could surest ao areas of further vori which were airiAfv -eceiving our attention. * Sis.ce he its is red again on knowing wfaat effluent levels wcre. we verbally informed hint eftae we were presently discharging tonal Aroclors in the ranee of 1-3 lbs./day with the latest trend being toward the 1 lb ./day end of rha range. To his question on past discharges, we informed his that current discharges were down from recent past ranges by I/S to i/10, but qualified this answer that high recent past nnrbers were a result of higher water effluer-. flow and high solids content in the aid limestone neutralization pit. In conjunction with this information, a lengthy discussion of the tschniral complexity of Arcelor or ?0 ntsrbers resulted in Mr. Crockett V. agreeing that any written effluent level repacks would be held confidential hy she Technical Stiff and would not he available to the public until or unless Monsanto reluisad it. Hr. Crockett also changed his past position from wanting a weekly retort tc accepting a monthly report of 24 hour cumulative effluent sample results, the initial report and. transmittal letter is attached, the second report win rev-; October 21 through 31, and all reports thereafter will cover whole tends. The Progress Report on Abatement of Polychlorinated 3iohenvl Oischemc to Snow creek was discussed in detail with hr. Crockett with use of sirdar shoe ing construction of swaps and sew limestone pit, etc. - Mr. Crockett requested chat a section be addad to the report briefly discussing the process and the role of various discharge abatement-devices, otherwise, he was cults satisfied with our proposad report. The requested addition will be made and plans are_^tr uramsnit the report eg Mr. Crockett the week of October 26. ' Numerous other related natters were discussed with Hr. Crockett during the srx hour seating with him. :kd Accacftmea CONFIDENTTAC WATER PCB-SD0000077210 '-'UN-02-9S 0Q. 14 FROM - LAW 10:6010342628 PAGE 0/ J. R.jSavage - General Office October 7 1ST0 SFriiMBgt PCB RgPOHT Manufacturing Hr. H. S. Bergen Hr, P.B. Hodge Hr. V. .B. Papageorge General Office ANNISTON NT PCB Lcveiu In Snow Creek Average ^C3 loss for the sooth was high at 2600 ppb or yz lbs/dky, largely a* a result of ooe very bad day (too iba} Contributing caaaee were* 1. The bid limestone pit was overloaded and solid sludges sere carried through, 2. Pet argent cleaning of the department, J. Sewering of excessive Mounts of uriatlc acid. I * Since the nes limestone bed was placed la service oa September 2J, pit effluent has been at 0-5 pph PCS'*. However,| leeching of PCB's from the creek bed results in a plant effluent level of 90 - 2t0ppb or 1*1 - 2.8 lbs/day, gradually declining. The plant believes that the new pit can handle ordinary upeets and peak loads. Regulatoiry Action Telephone contact continued with the Alabama Water Improvement Commission. However, a planned aseting did not take place due to illness of AVIC member*. Pressure for routine submisribn of analytical data is not intense at this time. Department Suspended Aroclor Control An experimental skimmer operated very *11 removing the PCB laden sous which accumulates in the new sump. . Solid VaLte* i Solid waste data for evaluation, of dispoed. methods has been accumulated. A report will be Issued in October. < HONS 099026 I I i I WATER PCB-SD0000077211 :) I Anniston j. T. B*ii J. L. Cordmi Q. C- Jeeaee J. c. landvehx H. e. settle* \ 4 S^General Offices \ 0. Dean* (1) 8- Hodges B. Pepegvorge J. R. Savage Anniston Plant TECHNICAL SERVICES DEPARTMEN MONTHLY REPORT Summary c::?tg'ICEKTULI. And Destroy South Second St. Other Location* F. Kecdsnsld ttevpart . B. w. Corlev V.G.K. Aroclor lau daring Kovmeber averaged 25 */dey (4620 ppb). high vela*! ecaouated Cor 18 #/dey, neglecting th* the * *OT*wb*r Average would be 7 #/day (UXO pgb). *xed ca ' knowledge of plant operation* end perforoenc* of device* in Mqt--br, each of the high level date i* due to . Sollls Minor leaks verm contained by use of *and and disposal in draw. Ho epill* occurred. Projects and Eva1 nation* 1. laboratory work to date indicatas ehe presence of ainiaal ajwobc* of PCI la the residue fro* Solid Aroclor distilla tion ihaaiur 5). Oil* eliminate* 10 X pound* per year or *clld utM ' frasi our PCS- disposal pi jus. 2. Design. edit to collect apeat carbon fro Hd carbon tsven hu been deferred to eerly 1971 Co accomplish the Ho. 1 HG Limestone Pit rebuild. r 3. Solid* lMD'n \ from pleat effluent (pert of progran ca reduce PCS la pleat effluent to 10 ppb) is moving for ward with prel imi.ne.ry screening t*#t at Denver Eguipnent Qrepany end Beer Laboratories indicating good. to moderate success with flocculation end settling. Further labora tory casting is scheduled for eerly Decmeber. A project has been written, design i* uadervey end eguipoent nodifiCatioae under study working vith Monsanto Blodize Co sec ua one of their dexifiers et Annietan far pilot teal? OSW 013917 COMKOtMTtAt. IMS-OSManC* 3 WATER PCB-SD0000077212 A8QCL0R WASTES Project* and Evaluations - continued 2. tasting of Che apparent best techniques recommended by Cenver and/or Sees. 4, A sturr**ftT7 r*r waff made of raeowal a# lime*to* xuru from ena 2 HCI o*utr*lixa.tiaa pie while in operation. A total weight of 127,000 pounds was removed of which 3* by weight we* solid*. Lab analysis wf eiw to til aaUcial iwvied * then luo.oao ppb Arociar or 12 to IS pound* of Aroclor. Present indication* axe thee this method of removal of solid* while the pit is in operation will increase the effi cient life of the pit by 2S per cent. .. 5. A mechanical expense project for repair of the So. 1 HCI neutraliracion pic v* written and approved- This project will be coordinated with the Hiran pit project to apply an. asphalt lining at the same cine, to save money oa saterial*. i)cd 9 QSW 01391a WATER PCB-SD0000077213 Monsanto Uc/itfATO CocwcirtY Annuton. Al^Qami 262.CI P*o*: (2CS} Z25-S3SI October 15, 1971 Mr. J. C. Crockett, JrTechnical Staff Director Water Irorsveaeat commission State Office Building Montgomery, Alabama 3SI0I Dear Mr. Crockett; We respectfully subair Che following- status report on prepress Coward reduction of polychlorinated biphenyl discharges co a minimum. The attached graph of weekly average ?C3 cencen era cions (peb) and effluent flow shows progress since our fine report to you in Ucvember 1970. As shown at the beginning of the graph, effluent was in a range of 1 - 5 lbs./day ?C3 (100 - 500 ppb 9 1000 gpm) . In con trast recent weekly averages have been 0.2 - 0.9 lbs./day with a good, downward trend still evident* These current values represent a five-fold reduction in discharge levels resulting from numerous improvements in facilities and operat ing techniques aade in accordance with the Phase I and Phase II program originally outlined. Revised Phase I and Phase II plans are attached with status of each item shown. Research and plant test work in removal of PC3 frota water has shown that both an activated carbon column and a limestone bed of a particu lar configuration are effective in a combination filtration-adsorp tion process for removing PC3. the essential difference between the two is that surface loading (gpm/ft^) for carbon is much higher than for limestone and total loading capacity (*- organic/# adsorbent) is also much higher for-carbon. Sovever, to take advantage of the higher performance of carbon an elaborate prefiltering and backwash ing procedure is required to prevent blinding of the carbon and breakthrough. A large, properly designed limestone bed overcomes these disadvantages of carbon and is a much more economical means than carbon for providing sufficient surface and loading capacity to reduce ?C3 in water to low ppb levels. Rased cn the above experience we are continuing to concentrate on improvement of our limestone bed design and reduction of flow to them. At this time it is our opinion that this approach will result 0SW 013356 WATER PCB-SD0000077214 T'JN -Bi as 8S = 1 3 PROM:BARRETT LAW !B;al0341028 Hr. J. 1. Cr= cieecc. Jr. 2 in 4 concir.ua.cica of she dawnvard trend. in ?C3 Levels in plane . Yours very truly. PAGE 1 2.y 1 /3? Atr. J. C. Cand^eir Technical Services Supe. 'ircendene osw 013357 WATER PCB-SD0000077215 41 p <f*i. .- / (TUJ ~ UNITED STATES DISTRICT CTUHT NDFCKDN DISTRICT CF mUPTS EASTERN DIVISICN UNITED STATES CF AMERICA VS. JCSIFH C. CALWORA, MDKENO L. KERUTdR, PAUL L. WRIGHT, and JAMES B. PLANX, ) ) ) Ho. B( <L& SBS" ) Violation: attic Is. 'o-.vr^ S;r: ) Code, Sections 1001, 1341 and 3; ) ) ) The SPECIAL 0C7CEER 1980 GRAND JUST charges: / 1. At all tires material herein. Industrial Eio-Test Laboratories, Inc. (hereinafter referred to as 127} did business in Horihircck, Illinois in the northern District cf Illinois .and was a contract research laboratory which ccrsducterf animal studies on various drugs, pesticides, chersicals, and ether substances, for the sponsors of said substances, in order to detacrine the safety and effectiveness of the substances. 2. At all tires rate,rial herein, JCE2TH C. CMASTRA was President Of 22T. 3. At all tines material herein, M07SJ0 L. KEPLTKZR was ten^ger de'Ci ** c of Toxicology at 2BT. .4 PAQL L. WRiair vas Section Bead for Pat Ttxicology at 33T fr= approximately March, 1971 until September, 1972, at Wiich tins he become *otf Huwa^ax of Toxicology for the Department of Madiciht and Zrvircirental Health *e ^ at Monsanto Corporation in St- Louis, Missouri, foot approximately October, t^ 1972 until the present5. JAMES B. FIANK was the Senior Group Leader for Pat Ttodcolcgy at IBT until October of 1972, at which tire he became the Assistant to the thas. tfP. ^ r'nrwr,I JrT nf-n/Ti 1 on ? o-< WATER PCB-SD0000077216 jtexmger c Ttrsiaalogy at XBT frca approximately Qrtober, 2572 until April, 2577. _ 6. 2B7 cmxducted a two-year chronic oral toxicity study cn e (ICO in albino rats, 257 Study Nuttoer BSS7S, ~ Monsanto Oxqpary (Monsanto)TCC is an antibacterial agent used in acaps. C& or about May 20, 1576 , 23T sailed its final version cf the rrpnrt of the study to Monsanto vte submitted the 157 study report to the Chited States Fcod and Drug Administration (FDA) with a cover letter dated rtsy n 1976, tor that agency's use in its evaluation of the safety cf TCC. 7 . 257 conducted a 22 tenth chronic oral toxicity study cn Naprosyn in albino rats, 127 Study Number B7922, tor Syntax Corporation (Syntax). Naprosyn (also known as naproxen) is a drug used in the treatment of arthritis. Cn or about March 3. 1972, 227 tailed its report of the study o Syntex who submitted the 127 study report to IDA, vith a cover letter ited March 22, 1972, as part of its application tor approval to test -presyn on brans and ultimately market the product. 8. 1ST conducted two carcinogenic studies on nice (tests to etrine whether a crirpound causes cancer) for Chenagro Corporatlcn xragro). Cne study was cn Sencor, a herbicide, 2BT Study Number 9069, on* an Nexracur, a pesticide, XB7 Study Number 9063. 257 submitted the ' rts of th* studies with a cover letter dated August 15, 1572 to Croagro, ubaittsd the 237 study reports to the Chi ted States Snvinxnjental rticn Agency (27A) , the Sencor study report by nail on March 8. 1973 e Neracur study report by rail an October 15, 1575. Both study : were submitted as part cf Cxaoagro's application tor approval to these products tor use cn feed crops. - 2 0 0 'j2 App- a WATER PCB 1577, in >fcrthfcrock, in the Rothem District of Illinois, rut-a Dlvixicn elsr-here, ' . .\ i t JOSEPH C. OIANURA, r ' K2ru2 K. KE7LDIS, PAUL L. HEIGHT, and JAMS B. FLANK, b defondsnts herein, together with co-schemers both known and unknown to the grand jury, devised and intended to devise a scheme to defraud clients and t 9c^rrnar.t agencies by writing and distributing false and fraudulrrt ready reports and false and fraudulent explanations of studies and e^vy reports, and by concealing the fraudulent nature of the study reports and explanatiers of studies and rtudy reports, all by crons of false. and fraudulent rep.e- aentatiens and concealments, knowing and intending that the representations ( and concealments were falae v*en node. 10. It was a pert of the achene to defraud that the defendants wrote and distributed false and fraudulent animal rtudy reports to clients who ccmaissicned the studies, vhiri study reports submitted by the t clients to government agencies that evaluate such reports as part of their t defy mi nation of the safety of those test snteriala. 11. It was further a part of the scheme to defraud that the defendants provided HA with false and fraudulent written auhriasims which reaffizred and new false and fraudulent statements as to naterial facts, and concealments and arissims of pa ferial facts in, car pertaining to, the studies and rtudy reports. 12. It was further a part of the scheme to defraud that the LOP (,, ( WATER PCB-SD0000077218 origin*! verxiarj of the TCI rtudy report was written and distributad hy 1ST ta Monsanto cn car about Mirth 21, 1974. 1ST submitted this version of the TIC~report to FTA an Dsaerteer 12, 1976, Which study report tds fefzsdar.ts knew to be false and frmidulcnt in that the study report; " *V ' &. stated that the data reported were foot aniaais that had been an the study for 24 norths, \hen defendants then knew that the report included data froa a substantial nrtser of animals that had been an the study far significantly lesser periods of tin?; ` b. - stated that 480 animals were in the stody when defendants then knew that a substantially greater rrrfcer of arivals were also part of the shady; and . c. contained an Animal Mortality Table (Table IV) which defendants then knew to be false in that it substantially under-reported the number of animals that were in the study and the nrber of animals that died during the study. 13. It was further a part of the scheme to defraud that the f-irjT version of the TCC study report was written in April and htey, 1976, was dated March 21, 1974, and was railed to Monsanto by XBT on cr about May 10, 1976, was submitted to FDA by fcnsanto vrder a cover letter dated Msy 11, 1976, and was known by defendants to be false and fraudulent in that the study i aparti . a. stated that the data reported were froa anlrals that ' had baen cn the study far 24 tenths, when defendants then knew that the rfpi-rrt included data froa a substantial rariaer of aninn Is that had been cr. the study far significantly lesser periods of tire; ' b. stated that 480 animals were in the study when defendants 4- 1 " 1 "T *iml MB frPp. -7 100'J2n WATER PCB-SD0000077219 then knew that a substantially greater axdaer of animals were -> J^r* ~ of the ty2y; ' ' ; C. contained an Animal Jfcrtaiity Table CTable IV) vhirb defendants then know to be false in that it substantially irder-rrpcrtad the rtnber of animals that were part of ths study and ths arisr of ani.-a-ls that died during the study; d. stated that 2S0 extra animals were cn the study tenths and wsrs an independent IBT "rf-search" grrxp, separate from ths animals reported in -the. TUT ttofy, vhr. defendants then knew (1) that ths so-called "nssearch* group animals were not an independent "research" group, bet were used as a source of extra animals and animal *!:<=>. T f~ the TCC study; (2) that the so-called "research" animals had teen cn study for significantly lesser periods of tine than 24 tenths; and (3) that a substantial nrrfcer of the extra animals were corsingled into, and as part of, the TCC study group; stated that no histcpathologioal examination (study of tissue cn the so-called "research" group animals, when defendants then knew that tissues free cany cf the so^oalled ". " grotp animals had been so examined; . emitted and concealed the findings listed in a table of "Kis tapathological Changes in Testes -- Poshrortea Animals", when defmiants then knew that the table ecLstad; ' g. stated that postcortera autolysis (checical deterioration of tissue after animal death) of testicular tissue precluded meaningful anirals, vhen defendants then kr*v that cany of those tissues had been so a WATER PCB-SD0000077220 02sninad and gradadj - - . .___ . . ' ' h. stated that the XET pathologist, Dr. Dxcvan araf fT^.hTed the tissues of'the study anisals and concluded that the firdiags in the testes of the lowest dose level (7^) anicals were irdis tirgirithahle frm the findings of the testes of the control group aniruls, \ten defendants then fcnew that Dr. Gordon's conclusion w that there vere TCC related <-- effects in the testes of the animls in the lowest dose level; and i. critied and concealed, as defendants then Jrsev, that Dr. Ki3liars Ribelln, a pathologist hired by Jfcnsanto, had examined rrg of . the testicular tissues of the ICC study arinals and had concluded that the lowest dose level showed TCC treetrent-rel* ted trade efforts. 14,. It was further a part cf the scheme to de.fraid that in response to IDA questions concerning the TCC study, a written explanation of the TCC study and report, dated Eecerber 12, 1976 was prepared and subrsitted to FEA fcy 1ST cn Eecrsrfcer 14, 1976, t&Lch explanation defendants then Jcnev to be fnl** and fraudulent in that the suhrdxslcn: a. stated that the data reported in the hfey, 1376 report (dated hfarch 21, 1974) vere frtn anieals that had been on the study for 24 souths, when defendants then Joow that the leptr*, included data frm a substantial nxrier of animals that had been cn the study for significantly .lesaar periods of tins; b. concealed, as defendants then >new, that the animl Eortality in the TOC study was substantially greater than reported in any version of the study report; c. rtat2d that 250 extra animls were cn the study for 24 xnnths and were an independent 1ST "research" group, separate frm the - - ioo r\ *> j-j ^ 0. WATER PCB-SD0000077221 ania&ls xeportsd in the Td ita^, wd?n defendants then taew DO that the eo-calld "research* group aniraals were not an independent "resa&roh* grnv^; but were' used as a source of extra animal* and aniaal tissues for the TCT ready; (2) that the ao-cailed "research" animals had been on study f--- significantly leaser periods of tire than 24 norths; and (3) that & substantial anter of the ectra anicals were ccrrnirgled into, and reported as part of, the 2C2 stu^y group; d. conceal ad that histopathologic exseinatims were perferred cn a substantial xxrher of the ao--called "research" animals, vher. defendants then knew that auch examinations had been performed; and e. aritted and concealed, as defendants'then knew, that Dr. Killian Ribeiin, a pathologist hired by Monsanto, had examined am: of the testicular tissues of the TCT study animals and had concluded in a written report that the lowest dose level showed TCC treatment-related toxic effects. 15. It was further a part of the scheme to defraud that the firvi ,study report cn Kaprosyn, dated Jartmary 4 1572, was written by 1ST and was received through the nail by Syntax from 137 on or about March 3, 1972, and submitted to the TEA by Syntax under cover latter dated Mardi 22, 1972, which report defendants then knew to be falsa aid fraudulent in that the report: a. contained individual animal and suanaxy animal data allegedly based on Mood and urine tests performed on or about the tins of final aacrifiae of the study, when defendants than knew that no such tests __ had been conducted and that the data was fabricated and false; and b. was supplemented by an Appendix II wfiich was submitted to ITA by Syntex cn April 9, 1574 which purported to represent, aomg other things, aTl the findings fren gross examination of the study ariosi*, when 7 firPf. 10 WATER PCB-SD0000077222  defenisnts then knew that tor & substantial partim of the grc*s finiings for pcrtccrtm anise!*, oo such examinations rs perfocrsd ani tbs finH-j-j were fabricated and falsa. 26. It was further a part of the achate to defray* that ia response to HA questions raised in Septscber, 1976 oanoerrJLng the Kaprosyn study, a letter signed by 3as=ph C. Cslardra and an explanation of the Kaprosvn study dated }fc*mber 11, 1576 was written and submitted to HA, and a copy was Balled to Syntax under comet letter dated Jtovwtoer 27, 1976. Defendants then knew that the Ncvesrfcer 12, 1976 submission to the HA was false and fraudulent in that the suhnissicn: ' a. stated that the data reported for individual animal and lurmary animal hlocd and urine values allegedly collected cn cr about the tine of final sacrifice of the study were accurate, vhers defendants then knew that the data were fabricated and false; and b. stated that gross examinations were perfoeoad cn the posteertam animals and that the data from those examinations reported in Appendix II were obtained from animal cage cards and animal disposition sheets, when defendants then knew that for a substantial nmfcer of the ' reperhod postmortem animal findings no gross examinations ver* perfected ard the data were fabricated and false. - 17. It was further a part of the schane to defraud that ST prepared end sailed to Cbenagro final reports for the fiercer and Wemaour studies under cover letter dated August 15, 1572 to Cossagrc. Cmgro submitted the XB7 fiercer study report to HA by nail cn cr about March 8, 1573, and submitted the 1ST Samoa:r study report to HA by mil cn cr about Ctrtober 15, 1975, vfaioh reports defendants then knew to be filar and ftPA II ioo:j-j WATER PCB-SD0000077223 fraudulent in that each report: * ' - a- stated that all the mice can the study wera fed the test material for IS months, Wien defendants toew that (1) the study cr'y \ ran for 14 tenths,* and (2f the mice sacrificed and examined at the end t of the study lixzluded a substantial nurber of mica which had been fed the test material 14 months ox lass; b. contained a Mortality Table which defendants them knew substantially under-reported the narber of animals that ware cm ths study . and the number of ardzals that died during the study; c. concealed that a larger nurber of extra mice wjere added to and were a part of the study; and d. statad that there vas a third positive control group fed benredine, when the defendants then knew that no such control group had ' been conducted wdth these studies. 18. "It vas further a part of the scheme to defraud that 237 vrote an "Addendum Report to Caeragro" regarding the Senour study reper t and mailed it to Cieragro cn or about December 21, 1573, which addendum Chemagro mailed to EPA cn or about October 8, 1574, and which defendants knew to be false and fraudulent in that tbe 1. listed the number of days that each mouse vas on the study as if tha study had run for 18 months, when defendants then knew that the mice had been cn the study for significantly lesser periods of time; 2. omitted and concealed that a substantially greater irrber of mice vjere cn the study than reported; and 3. listed for the individual animals designated as PCHI, their alleged number of days cn the study and gross pathological findings which 1- 9 AYP. it- OO'^rA WATER PCB-SD0000077224 ijrfcsratifln defendants taew %ats false because to sueh positive cmtrul grx& hsd been ccndLctad with this study. ' If. ' It was further a part of the scheme to defraud that an 1*7 txxiit was ccrrfuctsd on the Cxiraagro studies in April, 1975 which doorsrntad that tbs stodies wen: fal^s, as specified above in Paragraph 17a, and that the defendants esncsaled the results of this audit frera Cbemagro until July, 1977. 20. It was further a part of the scheme to defraud that the Outed States lwHi and interstate wire corasucaticns %*re used in furtherance of the scheme. 21. Ch or about Hay 10, 1976, in the Northern District of Illinois, Eastern Division, ' JCSEFtt C. QUAKER*, H3EEN0 L. KEPLINCER, PAUL L. WHICKT, and JAKES B. FXANK, defendants herein, for the purposes of executing the aforesaid scheae to defraud, and attempting to do so, knowingly did cause to be placed in the tilltad States nails the final version of the TCC study report, addressed to: . Denial taaan Monsanto Ctepany -- BOO Lindbergh Blw2. St. Louis, Missouri to soot and delivered by the Qaitad States Postal Service according to . the JirectinRS theraen. In violation of Title 18, Dhitsd States CSsie, Section 1341. 4PP.1 100 n m` JO' WATER PCB-SD0000077225 CXH7 TWO ,JC ?S=AL CCQigl 1580 AND JUFC further charges*. 1.- Paragraphs Ore through TVer.ty c Cant One of the ***' pr-g rsall^j1^ Persia- 2. Q? csr about August 11, 1576, in the Northern District of Illinois, Eastern Division, OCSZPH C. CMANDBA, *DFTO L. XEPLDCZR, PAUL L. KRimi, and JA^ES B. PLANX, defendants herein, for the purposes of executing- the aforesaid chare to defraud, and attesting to do so, fcrwingly did cause to be pi sped in the United States trails a letter fma Joseph C. Calandra dated August 11, 1S76, addressed to: ' Dr* Carl K. Icventhal Deputy Director, Bureau of Drugs Department of Health, Eduratlm and Welfare Public Health Service Rxd and Drug Adrinistratim ftxkville, Maryland 20852 to be sent and delivered by the United States Postal Service according to the directions thereon. In violation of Title IS, Qiited States Qode, Section 1341. 11 aa&tcryi wrrsrMTai wgfCTereagasza a APPM 10033:7 WATER PCB-SD0000077226 coutTt sheet The' gCXL CCOO 1380 Gwo JUKf further charges* 1. ' Paragraphs One through Twenty o Count Cre of this axe realleged herein- v .\ 2. Cft cr about N$verer 17, 1916, In the Norther District of Illinois, Eastern Division, 0C5Z7H C. OIAK3HA, KDFENO L. KEPUNBl, PAUL L. WRIGHT, and JW25 B. PXANX, defendants herein, for the purposes of executing the aforesaid achere to defraud, and attempting to do ao, kncwirgly did cause to be placed in the ttiited States mails a copy of the written submission by 1ST to the FD\ regarding Naprosyn dated Itovnrber 11, 1376, addressed to: fir. Virgil Tixrpecn Syntax Corporation 3401 Hillview Avenue Palo Alto, California >4304 to be sent and delivered by the Oilted States Postal Service according to the direct ions tberacn. In violation of Title IB, ttiitad States Dade, Section 1341. 12 - =azz=a; AW-1*~ loo Q J M J , b WATER PCB-SD0000077227 CXNT PCCR xprrrxL CCTOrSZ. 1S80 CWD JCHf further charges: 2. Paragraphs toe through %enty of Count toe cf this <-**' are ra&He^ed herein. _ J . 2. In cr abort October, 1S7S, in the Marthem District of Illinois, Pastern Division, JOSEPH c. owm, ' . IEK20 L. KEPLINCZE, PAH L. WRIGHT, ani JAMES B. PLV*, defendants herein, for the purposes of executing the aforesaid achew to defraud, and attesting to dc *o, Jcrwingly did transmit and cause to be transmitted in interstate caxerce, by reans cf wire comnioatim, certain signs, signals and Mocrds, to wit: a long distance telephone call between 1ST and Dr. D.V. larrh at Chenagro in Kansas City, Kimrl. In violation of Title 18, toiled States Code, Section 1343. 13 ftPP-H/ loo JQ-ii WATER PCB-SD0000077228 CXNT ms ' ci SPECIAL CCTESt 1980 G5WD JUTCf further eharg*s: 2-' Paragraphs Che through Six of Count Che of this irdictrant are realleged herein. v . . .\ 2 At aH tirrs gaferial herein, the fted and cuj Adtinistrati CFCAJ *as an agency of the Chi tad States Gbverrrent. 3. O. cr about ftoy 10, 1976, in terthhrooJc, in the Northern District of Illinois, Eastern Division, and elsewhere, JOSEPH C. CCCANDPA, MOHENO L. KEPLBKZa, PAUL L. KRICXT, and JAKES B. PIANX, - defendants herein, wilfully and tarcvirsjly did raJce, and cause to be cade, false, fictitious and fraudulent statements and representations as to jaaterial facts and concealed and covered up naterial facts, in a ratter within the jurisdiction of PDA, to wit: 'Jteport to Monsanto Crnpany, Tv*o-Year Chronic Oral Toxicity Study with TCC in Albino Bats, KL 71-8, March 21, 1374, IBT No. 9575,* vhioh study report vols submitted to FDA by Monsanto under cover letter dated May 11, 1976. 5b* aforesaid false, fictitious and fraudulent statenants and representations and cnissions as to aatarial facts are listed in .Paragraph thirteen of Count One of this indictsent and are realleged herein. In violation of Title 18, United States Cede, Section 1001. - 14 Afifi.n 1()0XJn WATER PCB-SD0000077229 ccojt six Th* SPECIAL CCTCFO 1380 (SAND JUHY furtia: charges: 1. Paragraphs One throu^: Six of Ca=nt Ox and Paragraph j^o of Qxnt rive of this indicWnt are realleged herein. 2. Qi csr about DBcerber 12, 1376, in Northbrook, in the Northern District of Illinois, Eastern Division, and elsewhere, ' JOSEPH C. OLANDRA, K3FCC L. KZ7LU*0, PAUL L. WEIGHT, and 2WS B. PLANX, . " defendants herein, wilfully and knowingly did rake, and cause to be cade, false, fictitious and fraudulent sta.tjsxr.ts and representations as-to joaterial facts and concealed and covered up raterial facts, in a ratter within the jurisdiction of the PDA, to wit: a written explanation to the IDA by 1ST regarding IBT4* "Report to ffcmsanto Qorpany, TVo-Year . Coonic Cbal Ttrdcity Study with TCC in Alhino Rsts, BTL 71-8, March 21, 1974, XBT No. 9575.* The aforesaid false, fictitious and fraudulent statements and representatiens and cnissions as to rateriai facts are- listed in Paragraph iburtaen of Qoint Crx of this indictrent and are realleged herein. " In violation of Title 18, Ehitad States Oode, Section 1001. - 15 /W. /f 1 Of)r] },. WATER PCB-SD0000077230 CKKT SEVEN The' SPECIAL CCTCEO 1380 GSMC JUK5T farther charges; 1. ' Paragraphs Coe through Six of Cant Che and Paragraph TVo of Qxnfc rive of this indictment are rmllaged herein. .t 2. On cr about Drijnmbrr 12, 1376, in Northbrook, in tia Northern District cf XHinois, Eastern Division, and elsewtere, JOSEPH C. CALANDRA, ECKENO L. H3L3NGER, PAUL L. WRIGHT, and JAWES 8. PLANK, defendants herein, wilfully and fcrvingly did make, and cause to he trade, false, fictitious and fraudulent statements and representstiers as to material facts'and concealed and covered up material facts, in a Batter within the jurisdiction of the FEA, to wit: the original version of the study report Jteport to Htnsanto ttngany, Two-Year Chronic Oral Toxicity Study with TCC in Albino Pats, btl 71-8, Jteroh 21, 1374, 1ST Eta. 3575", vhich was submitted along with the written explanation of the TCC study to the FDA under cover letter dated Deoesaber 12, 1376 ty JBT. The aferesaid false, fictitious and fraudulent statements and representations and anissions as to material facts are listed in Paragraph Twelve of Count CM of this indictment and are realleged heroin. In violation of Title 18, Chitad States CSrfe, Section 1001 16 -tfESS ftPP.rf ZZZ9A 100 WATER PCB-SD0000077231 CWT EOfT The SPECIAL CCTfEa 1380 GJWD JUFCf further charges: ` 1* Paragraphs One through Five and Paragraph Seven of Csmt Cne and Paragraph Two of Qount Five of this Indictment are realleged herein. 2. Cn or about Ntvorfcer H, 1916, in Northbrook, in the Northern District of Illinois, Eastern Division, and elsewhere, ' JCSIPH C. CKLANDPA, K0PEN3 L. KEPUNOER, PAUL L. HRICSC, ard JWCS B. PIANX, defendants herein, wilfully and tervingly did make, and cause to fas cade, false, fictitious and fraudulent statements and representations as to material facts and concealed and covered vp material facts, in a matter ' vithin the jurisdiction of the FIA, to wit: a letter and written explanation to the FIA prepared and submitted by IBT dated Ntvanber 11, 1376 regarding the IBT study report cm Naprosyn called: "Depart to Syntrx Research, Division of Syntex Corporation, 22-Hunth Gucnic Oral Ttnririty Study with PS 3540 Albino Pats, January 4, 1372, IBT No. B7322*. She aforesaid false, fictitious and fraudulent statements and representatims and emissions as to ntezial facts are listed in Paragraph Sixteen of Count Cne of this jLndicfanent and are realleged herein. 2n violation of Title IB, Dtiitad States Code, Sectiffl 1001. A ixUE Ed) LnIIZD STATES ATTQrfS " - ' P 0 R L P E R S ON " *1 - 17 - ` jrC?C5=r*gBJ:'r7a -2-5 Y nno r WATER PCB-SD0000077232 E V Monsanto tOO M. Si. Lm<. Uk <3189 3I 884-tOCO July ia, 1975 Dr. J.CJ Calandra Industrial BIO-TEST Laboratories 1310 Frontage Rd. Northbrook, 111. 60062 re: AROCLOR 2-year Rat Feeding Studies Dear Joe: __ The attached table sum rites a comparison of the 3 revised AROCLOR reports (12^2, 125**-, 1250). In 2 instances, the previous conclusion of "** slightly tunorigenic" was changed to "does not appear to be carcinogenic". The latter phrase is preferable. Hay we request that the AROCLOR 125^ report be amended to say "does not appear to be carcinogenic'". The natber of hepatomas reported for AROCLGRS 1260 and 12^2 have been Interchanged. This appears to have arisen from con fusion regarding the numbering of the animals. The original reports show tumors in animals with numbers in the 100-300 range for AROCLOR 1260 and in the 500 to SOQ range for AROCLOR 12^2. This leads me to conclude that the numbering scheme shown in the second set of reports Is correct. With AROCLOR 123^ confusion Is compounded. The original report showed tumors in animals - with numbers in the. units to teens, but the revised report shows animal numbers ranging from &0 to 1000. Can this be straightened out? I was unable to reconcile the differences in the animal numbers between the first supplemental report and the original repents, I had inquired as to the changes in the numbers. As I recall, I was told that the sections had been re.numoered when the new slides were cade and that a key relating to the sets of cummers 100737 WATER PCB-SD0000077233 -* tj cc Q Vf c Product Supplemental Repo: #1 (called)______ AROCLOH 1260 conclusion slightly tumorigenic hepatomas range of test animal nos: P. 9 6oo to 8oo p. 10 1000 series p- 11 p* 12 70 to 100 500 to Soo P 600 to 700 p. TOO series AROCLOH 125^ conclusion hepatomas tunarigenic Sa?pieaenta>1 He #2 f JCC does not &ppe&r carcinogenic 100 to C0 800 to 900 10 to 0 80 to 200 200 to 200 200 to 200 slightly tunorigenic AROCLOH 12^2 conclusion slightly tumorigenic does not appear carcinogenic hepatomas 3 range of test animal nos. as in report #2 for AHOCLOR 1260 s in report #1 AROCLOH 1250 C 2ii 10073:'/ WATER PCB-SD0000077234 V * I 1 Dr. J.C. Calandra July 18, 1975 Page - 2 - . * " would be supplied. This has not been done. It nay net be necessary for AROCLORS 1260 and 12b2, but AROCLOR 1254. remains unresolved. ' Insofar as I can see, the remainder of the reports appear acceptable. _ Kindest personal regards, Sincerely, George J. Levinskas, PhD Hgr., Environmental Assessment and Toxicology /bkp att. cc: Dr. George Roush, Jr., M.D. I 10073 7 l 210 WATER PCB-SD0000077235  . Dt George J. Levinskas, VUupr "* Environmental Assessment and Toxicology Monsanto Company 800 North Lindbergh Boulevard St. Louis, Missouri 63166 Dear George: He: Aroclor - 2 Year Rat Studies la regard to the comments and (questions covered in your Utter dated July 18, 1975, pertaining to the above, please note the following: 1. We -will amend our statement in the Last paragraph on page 2 of the Aroclor 125-4 report to read, "does not appear to be carcinogenic" in place of "slightly tumorigeaic" as requested. 2. Ia regard to the animal numbers La the Aroclor 1242 and 1260 reports, they are correct La our final revised report. la the original reports, the Aroclor titles for these two materials were reversed. 3. The animal identification numbers appearing in the reports on evaluation of additional Liver (actions are the tame as those la our original report. The animals were not renumbered. 4. We cannot find aay discrepancy La animal identification numbers La tbe reports (original, re-evaluation, final revision) on Aroclor 1254. However, ia the report on re-evaluation of additional liver sections dated March 24, 1575, thsre was a typo graphical error on page 1 which referred to Aroclor 1260 Lastaad ? ' of 1254. Perhaps this Is the basis of your confusion. - " I hope that this will serve to further clarify the situation. Think you for your assistance and cooperation. Sincerely yours, ; X, J. C, Calaadra President ___ . ..212 1007:4 a WATER PCB-SD0000077236 peoruary Id, 1569 ce. J. R. Pa'll on IHC'JIFY PR CM VAPOR CORPORATION OW TOXIC EFFECT 0? CALOnZXATEE) DOPRENYL R. A. C&rcia rw ' l, U/ TO : _ j. J. Pcder - CHICAGO Scan forwarded to me the note yea received from Ed castaf and she accompanying letter from T. pujlwara, Mana.3ln.-3 Director, Nipon Vapor Generator Company, and to H. J. Schickedanz, General Manager, Vapor International. V/e have been adviced by oar Ja.pa.nese representatives of the bran oil poisoning of cuite a number of Japanese citizens that was attributed co Xaneclor too (chlorinated biphenyl comparable to FR-2). V.*e assembled both medical and application data and sent it to our Japanese counter-parts as arguments for the cafe use of chlorinated biphenyl heat transfer fluid. Essentially, wo said that there are certain toxic and systemic effects that can be brought about by the vapors of chlorinated bipr.cnyls. ;/e did not rule specifically on th^ ingestion limits cf this chemical. We also directed attention- to* the larpe r.umoer of applications in food processing chat utilize Thens 1 heat transfer fluid. We Drought out very strongly sne fact that these systems have been designed to minimize accidental contamination of food products wish chlorinated biphenyls. I think we have a good track record here in the States uti.-.g Thermir.ol PR in these applications. However, it only seems a matter of time until the regulatory agencies will be look ing down our throats regarding the use of this material. Possibly, by the time this comes about, we will have com pleted feeding studies with chlorinated biphenyls that will allow us more exact data than has been available in the past. As a matter of fact, .they're feeding this stuff to chickens now, but I have no specific results of these tests. I can only suggest that you attempt to put Gustaf'3 mind at cate regarding the "toxic" aspects of these chlorinated biphenyls by playing down the medical reports and playing up proper system design. . Look at the bright side for us in the heat transfer fluid cr.z of our business -- if the government closes us down on tne ate cf chlorinated biphenyls, we have two excellent fluids in Thermir.ol 55 and Thermlnol 66, as well as, a proprietary fluid in Thermlnol 77 to exploit, Therminol 66 will certain ly be available in Japan according to recent information from our Engineering Department. " HONS 096365 WATER PCB-SD0000077237 February 1^, 156g Page 2 A final caution Jim, please U3e the attached information wi^ some discretion. I certainly would not pass completed sets a? this data to those asking the questions, but rather ext-acthe essential points from this data, namely, the ruling*on" vapor limits as handed down by the Industrial Hygienist Assoc< ation, and a strong play on proper system design to prevent accidental contamination of food products and processing material by chlorinated biphenyls. ______________ ________ Don Roush MQNS 09634.6 WATER PCB-SD0000077238 . January 231 3 S'6 9 AKOCLOi'S IH PLAKT EFFJATJI11T . Men r>TB . ' ' G. Wright - ANHIST0.7 C. P. Buckley - KTiUMI-iRICH Kouijru. W. R. Richard W. a . Kuhn D. D. Jlosnrcr --E. S. Tucker E. P. l/hccler G. L. Dratsch V/. B. rnpcEOOi'ge D. W. Jackson/ B. n. Williams J. C. Landwchr/ W. Taffec - vmicr. - HiChi::; - DliCVvi - S. 2 Li - LVKEK - KRVili? - AKlEXS'j - KIUKLMF, - ANNTST With the likelihood that the attention nov; being focuaed on presence of aroclors in natural waters will draw attention to any aroclor being sewered in our production plant outfalls v/e should begin to protect ourselves. Since the problem, ifW> any, has not yet been defined, I'm recoramending at thi3 time only action preparatory to actual clean up. Please arrange" for the following: ' 1. Waste samples -- Before any clean up action'of any kind is taken, vre need to know, at least approximately, how - much aroclor we are discharging into natural waters via our waste outfalls. ; -' We do not presently have techniques for analysing water for uroclor3 an low concentrations. It is expected that these techniques will be developed.by late this coming fall. Therefore, please collect,, freeze and hold indefinitely three 2-3 liter samples of your out fall as it is discharged to natural ourfEce waters (entrance to Snow Creek at Anniston; outlet of Village v/aste treatment plant at V/. 0. Krur.rmri ch). Scott Tucker, vfho is developing .the analytical procedures suggests use of polyethylene bottles. Samples should be taken several days apart and should represent normal conditions, including one sample taken at peal: loading (e.g. after . dropping spent aroclor' from F2S5 heat exchanger at W. a. Krummrich). . 2, In addition to collecting the samples, commence collectins data on points and amounts of aroclor discharges to sewer3 and means of disposal alternate to sewering. This information will help permit U3 to move rapidly in case a crisis develops. Do not proceed with abatement projects at this time except as in (3) below. Publish report on information developed along v.'ith roughly *. estimated costs. June 1, 199> appears to be a reason able deadline at this time for the report, but this could change drastically. 8 WATER PCB-SD0000077239 Monsanto --------- o. s. aldington -'czss ---------- iut;ccr e<fCC*CC February 26, 1987 Environmental Status -- Anniston Plant TO : R. G. Pocter/G4NH N. L. Reding/C2NA MAR 02 H. J. Corbecc/DID R- L. Fields/C2MJ R. L. Harness/C2NA 7. T. Matteucci/G3NR D. D. Mickelson/C2NA The status of environmental programs and issues ac the Anniston Plant was reviewed with Mr. Hal Corbett on February 26, 1987. In view of che present indicated direction of transferring management responsibility for che plant from MAC to MCC, our objectives were to inform Hal of che present environmental setting and direction of che plant and Co ascertain any corporate environmental reservations or concerns relative to chat cransfer. Dennis Redingcon of MAC Environmental Affairs reviewed plane status vs. our internal guidelines, and discussed on-going activities to further advance environmental programs at Che plant as part of che 1987-88 project for sice consolidation -- given che demise of parachion manufacture ac che site. Site consolidation is funded by che MAC restructuring reserve and is expected to leave an unexpended variance of about $2 H in Che environmental sector of che reserve. In addition to costs for consolidation, MAC expects to incur on-going costs in che range of $400 k per year for environmental remedial requirements. Copies of Denny's presentation materials are attached. A number of future potential environmental issues were identified, which will require continued monitoring and sensitivity. Hal agreed, however, that che plant's assessment, program and corrective action efforts are doing about what should be done given our understanding of site issues. It is further understood that costs for remedy of any future environmental issues that emerge will be borne by che operating companies in proportion to cause. We should continue to maintain a cooperative interaction with the regulators, and to be responsive to local community attitudes to stay ahead of and defuse these future concerns. DBR-MAF:Jb QSW 119459 WATER PCB-SD0000077240 ANNISTON PLANT WORLDWIDE GUIDELINE STATUS WATER ASSESSMENT - 6/84 PLAN - ESSENTIALLY CURRENT - NEEDS TO BE RE-DONE AIR ASSESSMENT - 2/6/87 REVISION NO NPDES VIOLATIONS 2-7 TSS VIOLATIONS/YR POTW 1-4 AIR EXCEEDANCES/YR FLARE BYPASS NO CERCLA REPORTS IN ESSENTIAL COMPLIANCE WITH ACUTELY HAZARDOUS/ INCINERABLE TIMETABLE ACTIVE SUPPORT OF HAZARDOUS WASTE DATA BASE/REDUCTION LAST ENVIRONMENTAL AUDIT - 4/8S LAST GROUNDWATER ANNUAL REVIEW - 10/84 LAST ASSESSMENT UPDATE - 1/83 I/M PLAN FOR UG STRUCTURES - 6/28/85 6 OP'S USED AND LISTED MINOR USE 5/6 ASSIGNED TO OTHERS AUDITS ESSENTIALLY CURRENT 5/6 UNDER CONTRACT (10/86-5/88 NEXT) 'Sk U946Q WATER PCB-SD0000077241 ANNISTON ENVIRONMENTAL REVIEW ENVIRONMENTAL ELEMENTS OF SITE CONSOLIDATION DISMANTLEMENT - 12/87 4 PCB TRANSFORMERS / NUCLEAR INSTRUMENTS UPGRADE 1600 FT. SEWERS ASBESTOS, ?4, MAT'LS DISPOSAL DECONTAMINATION FOR DISPOSAL/SALE CONSOLIDATE WTP CONTROL ROOM MODIFY RCRA DRUM STORAGE " RCRA CLOSURES LIMESTONE BED - 1/88 LANDFILL - 6/88 . _ SK 60 g 383 m 120 92 IS 104 ISO OS* 119461 WATER PCB-SD0000077242 PAGE 2 3. RCRA REMEDIAL ACTION LIMESTONE BED - 6/88 OLD LANDFILL CELLS - 12/87 4. ADDED MONITORING WELLS - 12/87 * 3 RCRA (DEEP) 4 VOLUNTARY (2 DEEP, 2 SHALLOW) 0 5. PCS REMOVAL -- SNOW CREEK 6. EXCESS WTP OPERATION TO FACILITATE SHUTDOWN 7. SHARE OF PROJECT ADMIN BUDGET ESTIMATE RESERVE ALLOWANCE PLAN VARIANCE ' SK ioq 90 80 ERAP 1370 315 2996 4900 1904 DSw 119462 WATER PCB-SD0000077243 ANNISTON ENVIRONMENTAL REVIEW EXPECTED MAC COST BORDEN FOR ON-GOING OPERATIONS 1. LANDFILL POST-CLOSURE MONITORING 2. LIMESTONE BEDS POST-CLOSURE MONITORING 3. LANDFILL AND LIMESTONE BEDS REMEDIAL ACTION 4. CONTINGENCY (FUTURE PART B NEEDS) / S K/YR 171 91 3GO 74 $400 1 COVERED BY RCRA ACCRUAL OSH 119463 WATER PCB-SD0000077244 ANNISTON ENVIRONMENTAL REVIEW FUTURE POTENTIAL PROBLEMS 1. CHLORINATED HYDROCARBONS IN GROUND WATER 2. DEEP GROUNDWATER 3. OLD FERRO-MANGANESE LANDFILL 4- POTENTIAL FUTURE MOBILIZATION OF SOIL CONTAMINANTS PC3'S MERCURY ORGANOPEOSPHATES PNP__ OTHER RESOLVED: ANY FUTURE ENVIRONMENTAL COSTS TO BE BORNE BY. OPCO MOST CLOSELY RELATED TO CAUSE OSH LL9464 WATER PCB-SD0000077245 DATE 4/82 3/83 4/84 5/85 6/85 2/861 ANNISTON PLANT CHLORINATED ORGANICS IN groundwater WELL PPB FOUND MW-7 MW-8,9 11 1,2-DI CHLOROETHENE 48 TRI CHLOROETHENE -------- CLEAN MW-7,8,9 . MW-7 MW-8 MW-9 -------- CLEAN -------- CLEAN / TR 1,1,2,2-TETRACHLOROETEANE TR methylene CHLORIDE MW-7 PROD'N PROD'N 7 18 '29 5 4 10 31 TR NO 3,4,4 282,41,13 9,16,16 8,6,6 1,2-DICHLOROETHENE TRICHLOROETHENE 1,1,2,2-TETRACHLOROETEANE CARBON TETRACHLORIDE CHLOROFORM methylene chloride TRI CHLOROETEYLENE BENZENE CARBON TETRACHLORIDE CHLOROFORM METHYLENE CHLORIDE TRICHLOROETHYLENE BENZENE 1THREE SUCCESSIVE SAMPLES QSW I19465 WATER PCB-SD0000077246