Document pBx4gZ1zeMGebODnmY8DOanJw

'Monsanto O. D V. R. Richard - Research Center Stpttnbtp 9# 1969 P. Hodges.. PHODG DEFENSE OF AROCLQR FTOTT#-"-- TO Se Wheeler - EWH3S General Policy . Make the Govt., States and Universities prove their ease, but avoid as much confrontation as possible. Comply and work with public officials to meet or" exceed requirements ahead of time. .Adverse publicity and competition are the real weapons. Analytical (in Air - Which Aroclors are present? Where?! .for ArocTor lln Water- Which eomnotmda-3 > . .. (in Animals cinterfere? JA| Keep track of how much contamination - which sources. Prove Bloharmful - Let Govt, prove its ease, on case by ease Monsanto Visit-Govt, Slolabs - in search of toxicology r. experiments and evident vs. Aroclors to keep up . progress. Monsanto Prove Bloharmless - Limited work at Ind. Bio-test - "Safe" toxle (Iman Rats Seek evidence of B1 level for mammals via Chickens ti fish Pish' Question evidence a u Question shrimp texi' . . . especially other t< chemicals. . If Aroclor bad, ot! . must be worse. Probable Outcome We can prove some things are OK at low concentration. Give Monsanto some defense. . We can>t defend va. everything, Some animals or fish or insects will be harmed. Aroclor degradation rate will be slow. Tough to defend gainst. Higher chlorination compounds will be worse -.u ; lover chlorine compounds. . ; ' ^ 44 174 Therefore we will have to restrict uses and clean-up as muchwe starting immediately. A ****> ^ ' I i PLAINTIFF'S EXHIBIT : 23 Ev.qn MON 0209 f vsisy WATER PCB-SD0000026337 o3 -2- 6 Therefore vt will have to work for altomato product* la ad use applications; for Aroclor production facilities. Clean Vp Aroclors tad aubatltuta product* where necessary and when required", of publicity and competitive activity over whelm ma. Water Pollution aeema to be first issue Aroclor product la refractive, will settle out on solids sewerage sludge - river bottoms, and apparently has a long life. Florida or Gulf Coast - Aroclor 1254 - Aroclor 1260 pres Issue. 40-200 ppb - causing problem at Pensacola (Monsanto) In plant effluent -causing " with shrimp. - can't risk shut -down of plant. Federal and State can extrapolate to other plants In . Gulf area. San Francisco - Aroclor 125*4 and 126 . leported Aroclor to be present In San Irmmtnm Bay. Jteported to be thin egg shells in birds - - Lot of screaming - . Great Lakes Warf studies on WS . Aroclor 1254 will be found1 Aroclor 1242 Will be found? Air Pollution Possible spread - but less of an issue 7 right now. Analytical work more difficult. -0^` Direct Contact with Product ........... "" c......... ............ .. '" ............ ~ ~ ~ ........................... Ak'*J**''.*% A r " ** Doesn't seem to be an issue - except for food heat transfI<er Ve don't believe Aroclor is being used as carrier for / insectici. de - spraye. d around - . I >i;V/. * Si1 Ve are not positive but moat uses are "closed" systems j! .. or products used In solid plastics, or adhesives P S; sealants. . . . :* MON 0210 4 0079 WATER PCB-SD0000026338 J 7. Tlulda e ` Product . Vydnollo fluid* * Mr Cooprtiaor Fluid Heat Transfer: ' Capacitor Fluids Transformer Fluid Potsiblt Pollution by Possible ] Cmtomera Plant Operation by Custom leakage external TUi leakage external Tea* ltaka|t external Tea leakage fren plant Scrap material, Vo, Should be clean. Tea, Reworked trana formers Possible Johnson Not Castings. Leakage 1st Leakage int In product closed for In product closed for Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ## Heed to take care of Aroelor in discarded transformers. Product could be drained and reworked. Probable Conclusion Yydraolle Leakage Mr. Compressor Fluid Product could be can^st at machines but will take a lot of clemnup work with customers. <-> 111 hay to have replacement product - with less"sensitive components. Work from this base on clean"Up to prevent more pollution problems. Hydraulic Fluid ` ; Must expect * shrimp* experiments, Vest Florida State, to be "aired" sometime sooni next few months. Thl win lead to bad publicity and competitive action vs. all Pydra* uls. .. * *. ~*tf -' 'Ye will have to try to confine to / Aroelor 125* and Arc o* l*or* 1260. ^ . I 4 0080 MON 0213 WATER PCB-SD0000026339 o -4- ) Vt will htvt to take action befort that time Gulf Coast - Action V. ' Richard Fallon/ Richard Bt able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in 2 month's time before Nov. 15, 1969. Have trial product in hands of Gulf Coast accounts and distributor before Bee. 15. Fallon Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS___ for insurance. Richard/ Suggest possible substitution of Aroclor 5442 for Aroclor 1254 in hydraulic and compressor blends. E. Wheeler Judges lower order of toxicity and solubility for 5442 series. Have to test product in pump test for deposits. Fallon/ Suggest field trials of our own all -phosphate Richard ester. Fallon/ Kuhn/ Kountz Work with large customers to clean-up streams. Bring in Findett as mfg. partner in the recycle business. Get money out of recycle operations. Inland-Waterways- . Wheeler/ Be close enough to Great Lakes studies to Judge Richard situation. Are there animals which are being ' affected by the concentrations found? Richard Be prepared to replace Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and in air compressor fluids. Richard , k Be prepared to replace all Aroclor 1242 or 124f in 6 months in hydraulic fluids. This means replacement of Pydraul 312 series, and control of sale of Aroclor 1248 to other hydraulic accounts such as Cities Service and Mobil. Heat.Transfer ' * 00ii Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. . Fallon/ Roush Heed to replace FR especially in food or sens! si vs product arsas whf'r* the product is gttunj into water. Sec dish washer compounds. See letter 2. Wheeler to J`. Fallon. We have possible rep cement products in Thermir.: : MON 0212 Therr.ir. WATER PCB-SD0000026340 H \ Vl CM V II o 5 Action ' . Kuhn ' *' Try to assure adequate production of Therminol ` 66 in face of decreased Aroclor production. H and terphenyl supply nay become short. . Switch customers to Therminol 55 or Therminol 66 ahead of pollution problems in customers plant. Work with customers on plant and dumping ' practices. Kuhn/ Fallon Findett already set up to rework. Heed to make them a manufacturing arm. We get sale of recycle-rework, fluid.- Capacitor Capacitor plants have re purification and recycle systems but up to 5* of product can be lost by poor plant producers and off-quality material. Mkt. Benignus/ **7"* 5* of production could be Eng. -Kountz/ Mfg-Hodges . 15T lbs/year. This is a big loss for the type of pollution we are trying now to guard against. ^ Capacitor products Enclosed in A1 or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product fc a time. Action Eng.,TSDPlant Pol lution Con trol Hodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. Ve have set-up to accept material for rework into hydraulic fluid but this relocation is not a satis factory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical Must start now to get con trol of off-grade material. Recommend replacemen future Aroclor buain with other products. Have 2 years. Action Monsanto must help plant clean- ' up of customer plants decantation, - ~ coalescing, adsorption, dls- posal of adsorbent or recycle of adsorbents. .. Monsanto badly needs "know-how" for clean-up. Monsanto should seek Govt, contract money for clean-up research, (See MRC R. Binning, D. Kelson) MON 0213 k 0082 WATER PCB-SD0000026341 Transformer# Action Benlgnui/ * Bryant Transformer Plant can eperats'. ' In a clean, efficient manner '* with recycle of off-grade Product transfor. Aroclor. . can remain clot* . . r ` no txooiure fcr ; Should advise disposal of . filter element materials so as to minimize ehance of water pollution. Incinerate or dispose. . . Should try to ret Reworked transformers pose business by clear a threat if the Aroclor Is ' by education of dumped into a water stream. toaers. Action Benignui/ Bryant Should try to minimize chance of dumping `'old" fluid by re working and by educating co. shops and collecting product for rework or disposal. Dalton is set up in England to rework electrical grade fluid. . KuhnAountz Tindett? Need rework facility here disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Kruremrich or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. / ' Action - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try to reduce to ppb level. . P.Hodges-Seek a Govt, contract on adsorption and incineration TSD cycles - MEG. . Engxg. . Xountz Take samples of streams and river water and mud . evidence for before and after clean-up.* Samples ' . can be stored for further analysis if we' eant - keep up current with analytical determinations. Apply Monsanto elean-up methods to'customer plant , al**n up and procedures. . 4 008 3 MON n?14 WATER PCB-SD0000026342 Action ` Engpg. k Mfg. . Kountz and Kuhn Evaluate liquid incinerators vs, solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at 1-4FT 1bs/Vsr, exclusive of cleaning up river bottom* or outfall bottoms. .. Hydraulics 20% of 4fT lbs Beat Transfer lOff of 2R* lbs Capacitors *' ' 5^ of 20fT ' Transformers 5^ of 15fiT . 800.000 lbs 200.000 lbs 1,000,000 lbs 750.000 lbs 2,750,000 lbs Central Eng. & Mfg TSD Kountz & Kuhn Set up an incinerator to handle Aroclor dis-\ , posal - preferably one which will handle \ solids such as muds - slurries as well as ;, , liquids. Have in operation within 12 months, /k Ideally have Incinerators available different ' sections for disposal. y Possible help from me Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio Test Continue studies to establish TEA type limits of toxicity on Aroclor 1242, Aroclor 1254 and Aroclor 1260. Rework with R. Keller-S. Tucker the number of samples which are to be analyzed for Aroclor in tissue. Try to see if Arodors are changed metabollcally. Does concentration level off, decline if feeding is stopped? Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Aroclor levels of toxicity, then we will have to have, biological studies on. these species to con .firm or .d.eny adverse findings. 'V *i ' ' *V.': *', t k OOS4 MON 0215 WATER PCB-SD0000026343 8* 0 9 Biodegradation Studies !" " '' ' Set up rate of biodegradation studies with Inorganic Div. on Aroelor 1242 va. Aroelor 1254 . ' Aroelor 5442 va. Aroelor 5400 ' Swisher Chlorinated diphenyl ether Chlorinated paraffin va. chlorinated naphthalene 1 Chlorobroao Aroelora 1242 and 1248 Baxter Contaet Baxter and Lldgett at MCL regularly for re suita on Lldgett Aroelor degradation. They are reported to be moving on MCL laboratory experiments. Establish eontaet with ehlorophenol degradation studies of Cellu-Chea Group. . * VRR:ms V. R. Richard * * 0085 MON 0216 WATER PCB-SD0000026344