Document xd1ZJBpZrJBGyBD7a55OrJ5MJ

' . vlo 9 nrw i * ^>`"0"' v/. R.'Richard - Research Center September 9, 1969 ( i m nCI DEFENSE OF AROCLOR F.'FLUIDS TO E. Wheeler - EWHEE P. Hodges PHODG General Policy Make the Govt., States and Universities prove their case, but avoid as much confrontation as possible. Comply and / work with public officials to meet or"exceed requirements ahead of time. Adverse publicity and competition are the real weapons. Analytical In Air ' - Which Aroclors are present? Where?) for Aroclor In Water- Which cnmnounris^ In Animals ^interfere? JV Govt. Agencies Keep track of how much contamination - which sources. Prove Bloharmful - Let Govt, prove its case, on case by case basis. Monsanto Visit-Govt. Blolabs - in search of toxicological experiments and evidence vs. Aroclors to keep up with progress. Monsanto Prove Bloharmless - Limited work at Ind. Bio-test - "Safe" toxic fnan level for < mammals via (fish Rats Seek evidence of Biodegra- Chickens dation Fish Question evidence against us. Question shri-.ptoxicology . especially other toxic chemicals. If Aroclor bad, others must be worse. Probable Outcome We can prove some things are OK at low concentration. Give Monsanto some defense. Y/e can't defend vs. everything. Some animals or fish or ccts will be harmed. Aroclor degradation rate will be slow. Tough to defer.; gainst. A-gher chlorination cexpounds will be wor-v . _v. .;or chlorine compounds. Therefore we will have to restrict uses and clean-up as [ch as.jve. can, starting immediately. ' ", ) , . .. NV 02758* I i ..... cCcooOoT r- STLCOPCB4024022 -2- Therefore we will have to work for alternate products in end use applications; for Aroclor production facilities. Clean Up Aroclors and substitute products where necessary and when required, before threats of publicity and competitive activity over whelm us. Water Pollution seems to be first Issue Aroclor product is refractive, will settle out on solids sewerage sludge - river bottoms, and apparently has a long life. Florida or Gulf Coast - Aroclor 1254 - Aroclor 1260 present 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 1254 and 1260 Reported Aroclor to be present in San Francisco Bay. Reported to be thin egg shells in birds Lot of screaming - Great Lakes Warf studies on DDT Aroclor 1254 will be found! Aroclor 1242 will be found? Air Pollution - Possible spread - but less of an issue right now. Analytical work more difficult. ,f * vc - Direct Contact with Product /V'- .... Doesn't seem to be an issue - except for food heat transfer.- t We don't believe Aroclor is being used as carrier for I v-.- insecticlde - sprayed around - -v' : I-" / We are not positive but most uses are "closed" systems'- or products used in solid plastics, or adhesives, or : sealants. 740839 NEV 027585 STLCOPCB4024023 -3- F. Fluids ' Product Hydraulic Fluids Air Compressor Fluids Heat Transfer Capacitor Fluids Transformer Fluids Possible Pollution by Possible Pollutlo Customers Plant Operation by Customers Proc Yes, leakage external Yes, leakage external Yes, leakage external Yes, leakage from plant Scrap materials. No, Should be clean. Yes, Reworked trans formers Possible - See Johnson Motors Castings. Leakage into prodm Leakage into produ< In product but closed for end use In product but closed for end use' * Capacitors can go to land fill dumps. Probably not burned, in A1 containers. ** Need to take care of Aroclor in discarded transformers. Product could be drained and reworked. Probable Conclusions Hydraulic Leakage Air Compressor Fluids Product could be caught at machines but will take a lot of clean-up work with customers. Will have to have replacement product - with less-sensitive components. Work from this base on clean-up to prevent more pollution problems. it Hydraulic Fluids Must expect "shrimp" experiments. West Florida State, to be "aired" sometime soon; next few months. This will lead to bad publicity and competitive action vs. all Pydrauls. We will have to try to confine to Aroclor 1254 and Aroclor 1260. 740840 NV 027586 STLCOPCB4024024 -4- Ue will have to take action before that time. Gulf Coast - Action v; Richard Fallon/ Richard Be able to replace Aroclor 1254 and Aroclor 1260 in Pydraul AC and 625 in 2 month's time bex'ore ""v- ^69. Have trial product in hands of Gulf Coast accounts and distributor before Dec. 15. Fallon Suggest possible buy of "all phosphate" ester from Food Machinery. Use this as one trial fluid MCS___ for insurance. Richard/ Suggest 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/ Richard Suggest field trials of our own all-phosphate ester. Fallon/ Kuhn/ Kountz Work with large customers to clean-up streams. Bring in Findett as mfg. partner in the recycle business. Get money out of recycle operations. Inland-Waterways- './heeler/ Richard Be close enough to Great Lakes studies to Judge situation. Are there animals which are being affected by the concentrations found? * (Richard Be prepared to replace Aroclor 1254 and Aroclor 1260 in 4 months in hydraulic fluids and in air compressor fluids. Richard ' Be prepared to replace all Aroclor 1242 or 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 N6V 027587 Fallon/ Roush/ Kountz Systems will have some leakage depending strongly on engineering and maintenance. Need to work with customers on clean-up. Fallon/ Roush Need to replace FR especially in food or sensitive prophet arose v o product is f.ettlns umo water. Sew Jir,,k washer oompounce. See letter E. Wheeler to ?. Fallon. We have possible rep cement product0 i.. Therm:r Therr.il.. 740841 STLCOPCB4024025 Action Kuhn Kuhn/ Fallon Try to assure adequate production of Therminol 66 in face of decreased Aroclor production. Ha and terphenyl supply may 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. Pindett already set up to rework. Need to make them a manufacturing arm. We get sale of recycle-rework fluid. Capacitor Capacitor plants have re- ftluids purification and recycle systems but up to 5? of product can be lost by poor plant producers and off-quality material. Mkt. Benignus/ Bryant 5* of production could be Eng,-Kountz/ Mfg-Hodges lfT lbs/year. This Is a big loss for the type of pollution we are trying now to guard against. Capacitor products Enclosed in AI or stainless steel for 5 to 25 year period. Will ultimately have to dispose of capaci tor products. Recommend we try to save this product for a time. Action Eng.,TSDPiant Pol lution Con trol Hodges/ Kountz Monsanto must start to work with capacitor people to clean up plant practices. We have set-up to accept material for rework into hydraulic fluid but this relocation is not a satis factory solution. Material must be reworked to electri cal grade or destroyed, whichever is more economical. Must start now to get con trol of off-grade material. Recommend replacemen future Aroclcr busln with other products. Have 2 years. Action Monsanto must help plant clean up of cuc-tou:.r pl.u.ta ^.cnntation, coalescing, oincrption, dis pose.! of c.<'--c..*be:.e cr recycle of ivonsihic. bail/ needs "know-how" for clean-up. Monsanto should seek Govt, contract money for clean-up research, (See MRC it. Binning, D. Nelson) 740842 NV 027568 n> cr STLCOPCB4024026 6- - Transformers Action Benlgnus/ Bryant Transformer Plant can operate In a clean, efficient manner with recycle of off-grade Aroclor. Should advise disposal of filter element materials so as to minimize chance of water pollution. Incinerate or dispose. Reworked transformers pose a threat If the Aroclor is dumped Into a water stream. Product transformers can remain closec ar.a no exposure for 25 yro Should try to retain business by clear.-uo; by education of cus tomers . Action Benlgnus/ Bryant Should try to minimize chance of dumping "old" fluid by re working and by educating co. shops and collecting product for rework or disposal. Dalton Is set up in England to rework electrical grade fluid. Kuhn/Kountz Findett? Need rework facility here + disposal scheme. Monsanto Plants The Dept, of Interior and/or State authorities could monitor plant outfall and find ppra of chlorinated biphenyls at Krummrlch or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed. Action - Take steps to see that every precaution is taken to prevent Aroclor entering water streams. Try to reduce to ppb level. P.Hodges-Seek a Govt, contract on adsorption and incineration TSD cycles - MRC, Engrg.- Kountz Take samples of streams and river water and mud evidence for before and after clean-up. Samples can be stored for further analysis if we can*t keep up current with analytical determinations. Apply Moi'.crr-'.o cv.-anmethods to customer plan'. ^m t . . o p 1 v U uUi|>'d (p NEV 0275bS 740843 STLCOPCB4024027 -7- Actlon - Engrg. & Kfg. Kountz and Kuhn Evaluate liquid incinerators vs. solids handling incinerators for disposing of Aroclor and pentachlorophenol wastes. I estimate Aroclor disposal at l-4{7 lbs/year, exclusive of cleaning up river bottoms or outfall bottoms. Hydraulics 20# of 4FT lbs Heat Transfer 10# of 2fT lbs Capacitors 5# of 20fT Transformers 5# of 15FT 8oo,oco 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-N posal - preferably one which will handle solids such as muds - slurries as v/ell as liquids. Have in operation within 12 months. Ideally have incinerators available different sections for disposal. ' ^7 > i:-, M- Possible help from MRC Chronic Toxicity Studies - Ind. Bio-Test Wheeler Keller Ind.Bio Test Continue studies to establish FDA 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 Aroclors are changed metabolically. Does concentration level off, decline if feeding Is stopped? Institute studies against the most limiting biological parameters. If shrimp are the most limiting species for Aroclor levels of toxicity, then we will have to have biological studies on these species to con firm or deny adverse findings. tafeV 0*7590 740844 STLCOPCB4024028 8- - Blodegradatlon Studies Set up rate of biodegradation studies with Inorganic Div. on Aroclor 1242 vs. Aroclor 1254 Aroclor 5442 vs. Aroclor 5460 Swisher Chlorinated diphenyl ether Chlorinated paraffin vs. chlorinated naphthalene Chlorobromo Aroclors 1242 and 1248 Baxter Contact Baxter and Lidgett at MCL regularly for results on Lidgett Aroclor degradation. They are reported to be moving on MCL laboratory experiments. Establish contact with chlorophenol degradation studies of Cellu-Chem Group. VJRR:ms W. R. 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