Document rp8YkgEj7mKwxEeDvx9RnyQEq

THE PC3-POLLUTION PROBLEM January 21 and 22, 1970 St. Louis Meeting With General Electric Co. GENERAL ELECTRIC REPRESENTATIVES! ' Mr. Edvard L. Haab, GS Pittsfield, Hass., representing all QZ locations Mr. H. Gerade, GB toxicological consultant Dr. K. Murphy, GS Schenectady, New York, Environmental Pollution Control ' MONSANTO REPRESENTATIVES: H. S. Bergen, D. A. Olson, 5. P. Wheeler, Dr. V. R. Richard, Dr. R. H. Munch, Dr. R. Keller, Dr. S. Tuclcer, V. B. Papagecrgt, J. 0. Bryant, P. 0. Benignua A. Presentation and Discussion of Published Articles About Chlorinated Aromatic Hydrocaroon Insecticides, etc. ) and PCBs Mr. Wheeler presented to Mr. Raab a booklet containing most of the pertinent publications, to date, and Indicated that additional articles will appear shortly. ,_ He mentioned that manufacturers of DDT and chlorinated aromatic hydrocarbon Insecticides will tend to emphasize the finding and interference of PC3s as the Government hearings limiting or banning use of the insecticides are held. . This lead GB to seek understanding of the scope, reproducibility, reliability and validity of tne analytical procedures used by various Investigators who reported finding PC3 In concentrations as low as parts per billion. ' 'j I i i | ; ! ' : ; B. The Analytical Procedures Drs. Keller and .Tucker presented details of Monsanto's GLC - Mass Spectrometrie analytical capability and apparatus, as portrayed In Table 1. The sophistication of our analytical capability was emphasized to assure that our approach Is the ultimate and Is not surpassed. On this basis our views of the validity of results given In various publications are Indicated In the attachments to Tabls 1. General Slectrie were impressed and completaly satisfied with the scope of our analytical capability and work. zo1orpe PLAINTIFFS EXHIBIT in. 7 Za. PRR 022199 SCA 037*21 DEPOSmON EXHIBIT ,<r HARTOLDMONO017777 s {! -2 ") C. Blcdegradeablllty of PC3s Mr. Wheeler related that while Arcelor 1254 and 1250 are being found, ispeelally In aquatic environment, the lover chlorinated biphenyls are not being observed. It Is anticipated that the lower chlorinated members may be largely blodegradeafcle. Drs. Richard, Keller ar.d Tuelcer discussed blcdegradeablllty studies by Monsanto at Ruaeon and elsewhere. These studies appear preliminary and not conclusive. Much more needs to be done In this area to allow - to draw conclusions. Since the literature Indicates that trichlorobenxene and trltetrachlorcbenzene are net susceptible to biodegradation, are Intrigued with the absence of reports about .finding these materials In the -environment. The obvious Implication Is that since these materials are used with the higher chlorinated PCBs found -- the source of the latter Is not from dielectric fluids. However, It was reasoned that chlorobenzenes may not remain due to their relatively higher vapor pressure or may not be found to date because they have not yet been zeroed In to the analytical spectrum. D. Status of Aroclor Studies At Industrial 310-Test. Table 2. In essence results reported by Mr. Wheeler on chronic animal toxicity tests and animal reproducibility studies underway are not as favorable as we had hoped or anticipated. Particularly alarming Is evidence of effect on hatchabillty and production of thin egg sheila regards white leghorn chickens. The studies Involved Aroclor 1242,-1254 and 1250. Some of the studies will be repeated to arrive at better conclusions. S. The Location of Aakarel Transformers. Table 3 Messrs. . and Senlgnus formulated Table 3 to portray the use and locations of aakarel. transformers throughout Industry and our commercial and residential areas. Cn discussing these aakarel transformer applications was most Impelling and forceful about the non-replaceablllty of transformer askarel fluid and the critical or essential use and need for askarel transformers, which have safety from fire as their outstanding virtue. Without dwelling on details and instead carried to the ultimate, the concensus Is that without availability of askarel transformers large cities like Hew York would be shut down with no power. Certain Industries that rely mainly on askarel transformers would go down with no power. Without Aroclor capacitors most of the lights across our country would go out and motors in air conditioners and many Industrial applications would not run. PRR 022200 SCM 037622 HARTOLDMONO017778 V- o 3 J Prankly, no on* coaid think of a suitable replacement for transformer askarel fluid. Fortunately, Arcelor 121*2 with proraise about blodegradeabllity is used in Boat all of the . Aroclor type capacitor*. Moreover, poaaible favorable laoner rearrangements are foreseen in the caae of Aroclor 12^2. Meed to control, aeeuraulate and properly diapoae of scrap - aakarela la unqueatlonable in light of'the FC3 pollution problem, and essential toward maintaining the us* of aakarel dielectrics. At alone apparatus in which askarel fluid is used represents 100 Billion dollar* annually. About 60% is in Che capacitor area and U0% represents transformers. requested and w* were pleased to give _ . their Environmental Control man, a list of all and other locations receiving Pyranol shipments in 1969. This amounts to about 16 million pounds of askarel fluids with economic worth of near 2.5 million dollars. This listing included 2W different locations of which 115 wre plants and service shops scattered throughout our country. Of course in addition to dielectric use in hermetically sealed capacitor* and transformers major amounts of FCBs are used as Plasticizers, Industrial Hydraulic Fluids and Heat-Transfer media. Environmental Sources of PC5a From Dielectric Applications 1. Spills ' 2. Disposal of waste 3. Ultimate disposal of product -- for failed apparatus U. Ventilation of operation for employe protection 5. Waste from containers 5. Field on service failures 7. Repair and return apparatus "service shops" Considerations of Degradation Disposals 1. PCBs up to and including 3 chlorine atoms appear biodegrade- able in preliminary laboratory work. 2. Thus far there is no evidence that higher chlorinated biphenyls will biodegrade. PRR 022201 SCH 037623 . ' . ' : i I i j i HARTOLDMONO017779 o -u- J 3. According to the literature TC3 and TTC3 biodegrade at a vary slow rata. 4. Chemical, catalytic breakdown would probably retire high temperaturea. - 5. Incineration will require 800*C. and 5 second sojourn time. HC1 scrubbing would be required. - H. Estimated Annual Amounts of Contaminated and Scrap PC3s Prom The Siectrlcax ir.cuatfy !c ' 1. Prom The Transformer Industry: a) In plant and field spills are small and controllable with adsorbents, which snould be Incinerated. b) Near 2 million pounds a year of transformer asicarels are sold to service and repair shops. These people do not manufacture new transformers, although on occasion they may fill new transformers sent Into the field without fluid. As these service shops are devoted primarily to repairing faulty transformers, we can assume that as much as 1.0 million pounds annually of "scrap" is generated. Most of this has been dumped or disposed of In streams. . e) We estimate that probably 150,000 pounds of this Is ' arced beyond reworking and needs to be Incinerated. The remainder may be reworkable by distillation. , 2. Prom The Capacitor Industry: a) Collectable waste from normal capacitor impregnation operations amounts to about 850,000 pounds annuslly. Most of this should be reworkable via simple take-over distillation. b) Scrap, badly contaminated with polypropylene, epoxides, solvents, oil, grease and "Junk" Is generated at not over 50,000 pounds a year. This maserlal should be Incinerated, along with the 150,000 pounda of scrap from transformers. ' e) Power capacitors are designed to last over 30 years. Modem motor runs may last 10 years and the amall lighting ' ballast usually last not over 10 years. Eventually and cumulatively there Is a large potential of field-failed capacitors. Portunataly Aroclor 1242 has been used almost exclusively sines about 1950. ' PRR 022202 SC* 037*2* \ HARTOLDMONO017780 o -5- 3 The failed unit* are disposed of In Industrial dumps. In ease of ballast* the Aroclor capacitor along with . the transformer Imbedded In asphalt or encapsulated ' in epoxy resin, all encased In a metal box are discarded as a unit. This Is emphasized to Indicate that Incineration of such apparatus Is not applicable. . 3. Proa Containers? Most askarel moves in bulk, tank ears or tank wagons, which do not present a problem. It Is questionable that drum shipments may present a problea. The drums can be used for returning scrap. Monsantos Program To Handle Scrap 1. asked what Is Monsanto's plan about reclamation of scrap . PCS from plants, service shops, utilities. Industrial users, commercial users, ete.? 2. What Is our view about a "Buy-Back" arrangement? 3. Vnat arrangements will Monsanto make for Incineration? Disposal in suitable land-fills? Reclamation by distillation at Monsanto? "* fc. To date Monsanto's posture Is: a) Ve have taken "good quality" scrap from capacitor plant at and had it reworked by simple filtration at Plndett. This Plndett arrangement is not practical nor economical. Ve paid 1 i/lb. for this "quite good" Aroclor, plus 1.9 ^/lb. freight. Plndett charged 2.1 i. to filter thla material, making our cost- 5 i/lb. b) 130,000 pounds of somewhat lower quality scrap from capacitor plant has accumulated at Plndett for lack of distillation equipment. . e) Scrap from plant appears to need reprocessing by distillation. d) About $ million pounds of "bad serap" from , has been disposed to a land-fill In New Jersey. Monsanto paid half of the freight eoet. e) A ear load of serap transformer sskarel from , Virginia la being sent to V. a. Krummrieh for reprocessing. PRR 022203 SCH 3-*6** HARTOLDMONO017781 u -5 - J f) V advised Co incinerate 12,000 gallcne of oil contaminated asKarel. g> talked with Sangamo, PicKen, S. C. and strongly urged them to discontinue present disposal. 5. The above "take-back" arrangements have Seen made on an individual and experimental basis. We have no fixed "buy back" arrangement, regards answering question. S. We have no established process for reclaiming either capacitor or transformer scrap. , 7. We have no incinerator for disposal of totally unreelaicable material. . 8. To date and for the foreseeable future our only effective disposal is to a land-fill. While this is not deslreable, it is better than indiscriminate dumping. , i ! Transformer AsKarel 31ends -Discussed With . Table ft. -1 Table A lists the transformer asKarel blends reviewed with . '; j1.. has discontinued use of Blend A due to combustibility Jof arc formed gas. for this same reason', as dictated by their legal people they will not use Blend B. : 2. Today both and . use Blend C (Pyranol A13333), which they mix themselves. 3. Blend D optimizes the Arcelor concentration in conformance with requirements for ncn-cor.bustlbillty of the arc formed gas and with the pour point requirements. The price is in direct conformance with our previous quotation for Aroclor 12^2, when was using this at a concentration of 505 by weight. PRR 022204 SCI' HARTOLDMONO017782 o Accordingly 3lend D meets requirements, although containing Tl.if of the higher chlorinated Aroclor it does not conform with Konaanto's concern with Che PC3 pollution prchlea. , 4. Tor all practical purposes 31end E (Inerteen 70-30) la llentical properties with Blend D, which latter . proposes to use. In the Interest or standardization, we seeic to oi7t , at use 31end X, which la used by for lew temperature applications and Is used by cany other aslcarel transformer manufacturers for general application. 5. Although USA uses 31end P (100* Aroclor 1242) for all applications, except for low-tenperature application, does not accept this use ox* 100* Aroclor. 1242 In transf cmerm . will not accept Aroclor 1242 or ary other blend with less than a 1 to 1 ratio of chlorine to Hydrogen atom*. A ratio s irni.fi cart 17 lower than 1 to 1 tends to yield ccrousticie aro-ftreed gaznes. feels strongly that this does not conform with the original definition of an asVcirel. Accordingly their legal people stress that this presents potential liability in case of an accident for which various precedents have already been set In court action*. points cut that this precedent for* liability regard* crrcustitility is already set, in contrast with the PC3 pollution situation which thus far is void of legal action*. He reiterated that the pollution problen thus far is a source cf technical putlioatlons and warnings and enphasized that in the case of electrical applications which involve only hermetically sealed apparatus, adequate control should be possible. Pacts As Agreed 37 Those In Attendance 1. CI5 - C5-3 Biphenyls -- found in aquatic eco system In populated asd industrial areas. 2. DDT Cl hydrocarbon Insecticides have effect cn fish-eating birds (reproduction) leading to possible extinction of scae species. - 3. PC3* (sect) are definitely suspected along with polychlorinated hydrocartcs insecticides. 4. Pesearch data being developed seem* to confirm incrimination of ?C3s subject to rechecJclng. . 5. Public, political and government pressures stopping aotne uses of chlorinated hydrocarbon Insecticides (PCHIJ. prr 022205 SC* 03762T HARTOLDMONO017783 u -3 ) 6. PCBs have been brought Into hearings proposing restriction* or elimination of DDT, PCHI. 7. As manufacturer of PCHI'a fight for thslr life, attention will be directed to PC3a. ' 8. To our knowledge PCBs are not being found In terrestrial birds cr animals, but DDT and PCHI's are found. 9. PC3s are not being found In the eco system without the presence of DDT or PCHI's. 10. PCHI's residue are found without PC3s. i ! i ! | i 11. We have no evidence that anyone has found lower PCBs except that Dutch researchers found PC3s in roaches. 12. There is ns evidence of natural sources of PC3s nor any source other.than Industrially produced and used. ' 13- PCBs In a- single dose have a low order- of acute toxicity and are no significant problem to rats, dogs, chickens, fish and humans. 14. Based on six months of chronic studies In rats and dogs some PCBs are 'moderately" toxic and more so than DDT, but less toxic than sore of the other chlorinated hydrocarbon Insecticides. ' . 15. Some PC3s affect rat reproduction, (10 ppm. apparent no effect ^ levels). i ; ! 15. Some PCBs affect leghorn chicken reproduction (100 ppm.). PCBs have no affect level for chickens, estimated 10 ppm. 17. Some environmentalists are claiming that the FC3a pose a . threat to humans, are so "philosophizing" In publications. ' 18. Cne published page Indicates that PCBs are as bad (or worse) than DDT In microsomal enzyme effect. What Is significant1? Since many chemical compounds react similarly.' . 19. Human experience in production of PCBs and their use has been favorable. Less than 20 Instances of illness known to Monsanto Company since 1940-45. Proper precautions.were not always followed. ' 20. Company's use of PCBs as dielectric fluids, has been extremely favorable without illness throughout 40 years. 21. Monsanto Company is convinced that analytical techniques and data from some laboratories investigating PCBs are reliable and that conclusions being formulated are valid. PRR 02220b . sc* 03762* : HARTOLDMONO017784 u) I 22. Monsanto Company has not ran duplicate analysis on samples reported'ln the literature. L. What Pealrea . 1. seeks that Monsanto take no precipitous reaction to the PCS problem that would result In withdrawing supply of Arcelor 125^ or 1260 to 2. The consensus is that no suitable replacement for transformer askarel fluid Is foreseen. 3. In event of development of a suitable fire-resistant fluid replacement for askarel, emphasized that a minimus of 2 years testing work would be required before commercial use could be adopted. u. In reply to^Mcnsanto's legal question whether with continued use of Aroclor 125^ and 1260 would assume sole and complete liability -- answered. No' To substantiate his reply, cited caae examples Involving where damages were scught and collected, even though was only the third party. He further stated that any arrangement seeking to delegate and confine liability to relative to the PCS problem would be worthless. . 5. seeks to knew the magnitude and time of Aroclor price Increase that would result If Monsanto discontinues sale of Aroclor for non-electrical uses, or If pollution control expenses warrant a price Increase (as anticipated). 5. seeks to send a letter to their plants and service shops ' and majer users of transformer askarel, such as the ' utilities giving notice of the PC3 problem and guidance about the most suitable controls. 7. In the ease of service shops scattered throughout our country It Is unrealistic that these people would assume any- expense to return scrap to Monsanto. The minimum we can expect Is that Monsanto pay the freight charges, and relaourse for a suitable container-to avoid additional and excessive contamination. This emphasizes need for Monsanto to have an effective reclaiming prceess. Otherwise, the best we can expect from service shops and many other uaers is to continue to dump In a land-fill and atop discarding Into the severe. j f i ; i I j ; ; : . PRR 022207 SC* 03762* 1 HARTOLDMONO017785 r 8. re*liras that Monsanto is caught between- the explasiver.eaa of arc-formed gasses problem and on the other hand the PC3 pollution problem. Realizing possible unfavorable outcome of the are-formed gas problem, desires to withhold the PC3 problem from Involvement at NDtt, ASTM, IEES, EX and ASIA st this time, (making It an Industry-wide problem) pending better ln-depth understanding of the FCB problem. 9. strongly seeks to continue manufacture of askarel type transformers, because In many applications this apparatus cannot be replaced with mineral oil nor open dry, nor seal gas dry type units. ' Mineral oil burns. Open dry accumulates dust, lint, moisture and can then fall with explosion and burning. Sealed gas dry types are very expensive, space consuming and very difficult to. maintain sealed. Transformer design and application Is governed by National Electric Code, by local building codes, ?lr* Underwriters, NZMA, XZZE, ASTM, TEC, ASA, Insurance companies and other*. Because of the diversity of organizations Involved a directive to discontinue askarel transformer manufacture would assume highly complex proportions. i I ; : 1 ! i I i P. 0. Beni gnus January 26, 1970 PRR 02220ft sen 037630 HARTOLDMON0017786