Document 2qD4qMXBNrMbEnr44KL7DXyLp

Monsanto rn-:iii<\vi.*i i.m KHOii (I<ocation)II.A, VODDJSN - RUADON. date HiMMECT i 2^th January, 1972. 1 Your letter of 10 January, 1972 ncrKUBNOtt 1 HAV/bjo'g. T O : R.H. MUNCH - ST. LOUIS. C C V/.R. Richard - St. Louis. R.A. Baxter - Ruabon. E.S. Tucker - St. Louis. Dear Ralph, I appreciate your ooncern at not reoeiving the additional data for Table 3, Appendix 2 of our joint PCB report. Unfortunately, the results of the work in hand did not furnish the information I had anticipated and we have been unable to reduce the data to a simple tabular form. We find, for example, when 10? of Aroclor 1254 is added to Aroclor 1242 to increase the percentage of higher homologues present, that degradation of the whole Aroclor composition is inhibited. In other words, a sufficient concentration of more highly chlorinated Aroclor appears to behave as a bacteriostat towards the C and Cj cultures. In the presence of a low concentration of these more highly chlorinated homologues, such as in Aroclors 1016 and 1242, however, the cultures C2 and Cj appear to degrade all the isomers present in significant quantities, including some penta and hexachloro-components, with half-life periods of less than 50 days. We have just completed some of the tests leading to this conclusion and have more in progress to confirm the level at which bacteriostatic action occurs in a PCB mixture. It appears, therefore, that we cannot specify, even approximately, the degradation rates of PCB homologues without taking into account the effects of other PCB components. This makes it impossible to compile a simple table of degradation rates for insertion into a mathematical model of the type we discussed with Jack Hinchen. This work may also explain the discrepancies in results to which you refer in your letter. In a mixture, the adaptation process may permit degradation of certain .isomers which in isolation might be resistant, (e.g. 4 -4 1dichlorobiphenyl in the presence of C 2 ) if significant quantities of highly chlorinated biphenyl are present, the degradation of many other isomers may be inhibited or slowed down. ' I do not think these findings invalidate the concepts behind Aroclor 1016; indeed they seem to me to strengthen its position, but presentation of the results, in a way which allows a rational interpretation, poses some difficulties. I am rewriting the section of Appendix 2 concerned with the results on commercial mixtures and the discussion to take account of these recent findings. I was glad to learn that the appondices on analytical methodology have been completed and look forward to seeing these. Do we now have a good estimate of the distributions of homologues being used beforo and after the onsanto action and can we estimate the probable inputs to tho environment? 740610 NEV 027355 -2- In reply to your other questions the answers to 1,,2 and 3 are yes. Question 4 may be answered in part by the preceeding suggestions, but also to some extent by the way in which the rates are derived from the experimental results. We now have several more points on the degradation curves for the various isomers and will use these to provide, hopefully, more aoourate data. Regards and best wishes, H.A. VODDEN. NEV 027356 740611 ' ^ o y Co*** r, C t*tC4UGrtt was*, &*t**, 0*<>*Cfe*ie- J&T~ i s f z & h * C /3j PRESENTATION OF THE PCB MANAGEMENT PLAN *>+*&** On November 17# 19^9 we discussed with you the PC problem and outlined a program for coping with it. * (Show transparency on pounds-dollars-return) On this chart we have summarized the total worldwide business. Our concern is great because of the $21 H worldwide business involved with gross profits of $10 W on a net investment of approximately $9 H. * (Show transparency on non-degradable Aroclors) The next chart summarizes the business which now depends on the non-degradable (persistent) Aroclors. Solid Aroclors, which are not an environmental problem and Aroclor 1221 which has been demonstrated in our laboratories to respond to degradation, have been excluded. NEV 022 748 in November, the decision was made to develop a plan to phase out the manufacture of Aroclor 125^ and 1260. Since then, as you well know, the pollution hysteria continues to grow and .specifically in the area of PCB's the number of laboratories, P L A IN T IFF'S B t H 'B ,T I 732803 both governmental and university, involved continues to increase as we predicted. At this meeting, I wish to bring you up-to-date on the latest developments, the progress we have made, the need for modifying our strategy, and our new strategy. Since November, the press has been relatively quiet except for the recent flurry following Congressman Ryan'B Press Conference. Two publications have appeared which Implicate PCB. The JanuaryFebruary, 1970 issue of Environment published in St. Louis carried an article by Dr. Robert Risebrough and Virginia Brodine. The presence of PCB in samples of human milk is first publicly reported in this article. An article by Dr. David Peakall of Cornell University appeared in the April issue of Scientific American. In this article, the effebt of DDT and PCB- on egg shell formation and reproduction is described, and emphasizes that the problem has been apparent since the introduction of 732804 Nv <^7*9 DDT to the environment. Three newspaper articles were noted,. one in the Miami Herald, another in the Tampa Tribune, and the third in the Ann Arbor News, again describing the effects of DDT and PCB on the environment. The Florida papers referred to the effect on shrimp of hydraulic fluid which was traced to our Pensacola plant. In March, we held discussions with D r 's. Risebrough and Olcutt at Berkeley, California. They are personally convinced PCB'8 are harmful and were pleased that Monsanto was concerned and cooperative. Also in March, we participated with about 50 technical repre sentatives representing State, Federal and Canadian Water, Fish, Wildlife regulatory agencies in a very objective discussion In Duluth, Minnesota. Analytical techniques, monitoring of the a environment and toxicity of PCB were discussed. Absolute identi fication of PCB and its effect on the. environment were identified 732805 022 750 as requiring considerable research. Concern was expressed b y many present that some agency such as the PDA would take precipitous action before adequate information could be gathered; which was believed by many to require at least one year. Monsanto's presence and offer to cooperate was appreciated. About two weeks ago, we received word from a Dr. Hill, Ohio State Health Department, that his laboratory had found PCP's in milk from an area around Columbus, Ohio. They believed they traced the source of PCB to deteriorating coating applied to silos % in 1967* This coating was formulated using Aroclor 12f>4. We requested samples which our laboratory could analyze and our analytical work has confirmed that chlorinated compounds similar to our Aroclor 1254 are present. NV 022751 During our discussions with Dr. Hill, we were told that the FDA a was considering establishing a PCB limit of 0.2 ppm in food. In pursuing this further, Dr. Kelly was subsequently told by 732806 P the PDA personnel that the PDA will, In a few weeks, advise their offices that PC contents exceeding 0.f> ppm In milk and 5 ppm In food would subject the milk or food to confiscation. In the U.K. we are, of course, also experiencing considerable concern. The Ministry of Agriculture, Fisheries and Pood has repeatedly requested Monsanto to divulge the names of our major customers. Prom the U.S. point of view, we were reluctant to divulge this information because of possible adverse consequences worldwide. Prom the U.K. point of view, divulging th customer's name with assurances that it would be kept in confidence is considered the wiser approach in the long run. We are receiving permission from NCR to divulge their name and will approach the Ministry on a confidential basis. *e\, In Europe, we have assumed worldwide leadership and contacted the representatives of the European producers. Initially, their response was indifferent. Subsequently, Bayer, Germany 732807 V and Prodelac, Prance have become more concerned, have initiated programs of their own, and are cooperating with information exchange. The Italian producer does not believe he has a problem. MMK, Japan, has been fully informed of our progress. During our meeting with General Electric representatives in late January, we discussed our decision to discontinue the manufacture of Aroclor 125** and 1260. GE immediately challenged the decision on the basis that Information available was not adequate to incriminate these Aroclors for electrical use, since other non-degradable ingredients used in dielectric fluids have not been identified in the environment, and that the adverse consequences of fires and explosions far exceed the potential threat to the environment. They also indicated that at the proper time they would be willing to have an officer of their company go on record as stating that the unavailability of these materials would result in serious power blackouts. Without Aroclors the maintenance of existing equipment would be impossible. Replacement of this equipment would be extremely costly, primarily 732808 NtV 0*^753 7 because of the Increased space required by the replacement. The power companies could not provide the uninterrupted service expected. As you can see# we are still very much on the defensive# however# considerable progress has been made. In our plants# control of emissions is progressing extremely well. After initial audits, all plants instituted programs for control of spillage, leaks and disposal. Our Newport plant installed and placed in service this month an interceptor pit to hold major spills. Anniston and the Krummrich plant are proceeding with similar installations. These should be in service by the end of the third quarter. Reduction in PCB contents of our plant streams below the solubility level in water (50-200 ppb) will be achieved only after research work now underway is completed and plant units are designed and Installed. Completion of this work is expected to occur in late 1971. a (Show transparency on plant effluent) NV q u i z * 732809 u A major development has been achieved by our research department in refining our analytical procedures to the level that we now possess capabilities far exceeding many laboratories and un surpassed by any. We are actively communicating our methodology to other laboratories to improve the type of information being generated and published. Our objective is to be considered i experts with relaible results. Toxicity studies are now in the tenth month. Data to date indicate that Aroclors are mildly toxic to mammals, however, it is highly unlikely that this will be a significant factor in any decision regarding the banning or restricting of the use of Aroclors. Biodegradation studies have, thus far, confirmed our initial beliefs that the lower chlorinated biphenyls would degrade > easily. We were disappointed in the resistance to degradation of some of the isomers in Aroclor 1242. This would tend to 732810 NV 0227i>5 y confirm the belief that some of the 5 and 6 chlorinated biphenyls being found in the environment couid be residue from degraded Aroclor 1242. We are actively pursuing the possible use of distilled Aroclor 1242 with degradable components as a possible substitute with minimum loss of other favorable characteristics; e.g. fire resistance. (Show transparency on Aroclor Applications) This chart is a summary of the major uses of the Aroclors which have shown resistance to degradation. Solid Aroclors are not Included. A critical review of these uses was completed. We have classified these uses into three categories. Business we discontinue, business we retain and business we retain with product substitution. Uses in which control to prevent environmental contamination is virtually impossible are being Immediately discontinued as shovm a on this chart. NEV 022756 (Show transparency) 732811 10 The use of Aroclors to extend pesticide persistence, a use developed by the U.S. Department of Agriculture, Is not one we have been recommending, however, We still have some extremely minor sales through distributors which we are discontinuing. We have recommended to the U. S. Department of Agriculture to reject ArocLors as an approved inert material when pesticide reregistrations occur this year. We are taking immediate steps to terminate the use of Aroclors for cutting oil, medicinal, dental and cosmetic applications. We don't know where our distributors are selling Aroclors. To obtain better control of the end uses of Aroclors, we will immediately take steps to terminate distributor selling arrange ments as soon as possible. There are many applications which are extremely difficult to control which we will discontinue, but we will retain the business with acceptable product substitutes. NEV 022757 732812 IX. * (Show transparency) This chart is a summary of those applications for which we either have or will have substitutes. The formulations for sealants, coatings and Industrial Fluids consist of biodegradable Aroclors, chlorinated terphenyls (Aroclor 5000 Series) or phosphate esters. In the NCR paper application, we are applying considerable ' pressure on NCR to accelerate the conversion to products we manufacture or propose to manufacture. At present, HB-J|0 . appears promising i-n the U.K. after one month of plant trials. | I\ Alkylated biphenyl appears promising for the U.S. application. We can at present satisfy the HB-40 needs for U.K. by sacrificing some low profit plasticizer business. However, capital funding will be required to expand our production capabilities. We do not at present manufacture alkylated biphenyls, but we have the technology. Facilities must be designed and installed to provide for this application. N6V QZZ7SQ 732813 Successful control to prevent contamination is possible in * . systems in which Aroclors are sealed. We are working very closely with our customers to educate and motivate them and have offered technical assistance on their disposal and effluent problems. Aroclor business which we will retain is shown on this chart. (Show transparency) In summary, we have assumed worldwide leadership in facing the PCB problem. We have educated and pressured our customers and co-producers to fully appreciate the problem. We are leaders in analytical methodology. Our plants are effectively reducing the PCB content of their effluent. We have without waiting for any orders from any agency, selectively and voluntarily dis continued the sale of Aroclors for some uses. We are aggressively developing and introducing product substitutes for uses difficult to control. Where control is possible, we are working' hard at a making it effective and keeping the business. 732814 13 t We are doing this and at the same time, maintaining the Imageof Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environment. ozi'60 Nfc* 732815 f* r MONSANTO WORLDWIDE AROCLOR BUSINESS POUNDSA E A R salesA ear oross profitA ear CROSS INVESTMENT ROI WORLDWIDE M/I MONSANTO PRODUCTION LOCATIONS: OTHER PRODUCERS: 104 H (70 IT In Junctional Fluids 34 R In Plasticizers) |21 FT $100 H (il5 IT in Functional Fluids f 6 R in Plasticizers (7.5 FT in Functional Fluids 42.5 IT in Plasticizers) 413 FT ($8*8 FT net investment) 10.5* 62* ' USA (2 plants, Anniston, Alabama Sauget, Illinois) U.K. (Newport) JAPAN (Yokkaichi) Bayer, Prodelec, Caffaro, Flick, Kanegahuchl, and several Eastern European producers (all ex-USA) -jb'' oil 732816 WORLDWIDE AROCLOR BUSINESS . PRODUCTS CONTAINING NON- DEGR ADABIiS AROCLORS POUNDSAEAR saussA ear 92 R |I8 H ( 70 "R In Functional Fluids 22 K in Plasticizers) ($15 E in Functional Fluids 3 H in Plasticizers NEV 022762 732817 PCB CONTENT PLANT EFFLUENT <. June, 19^9 Present October, 1970 January, 1971 September, 1971 Anniston 50 pounds per day 5 pounds per day 2 pounds per day 5 pounds per day .1 pounds per day April, 1969 March, 1970 Present September, 1970 October, 1970 September, 1971 Jr Present V Sauget . 700 pounds per day 200 pound8 per day 65 pounds per day 55 pounds per day 10 pounds per day 2 pounds per day % Newport 30 pounds per day (5,000 ppb) (500 ppb) (200 ppb) (50 ppb) (10 ppb) (3,500 ppb) (1,000 ppb) (325 PPb) (275 PPb) (50 ppb) (10 ppb) (3,000 ppb) 732818 t!TTr;iar*r*.tw .. ki . r v . .-a AROCLOR APPLICATIONS APPLICATION Industrial Fluids Transformers Capacitors Heat Transfer NCR Paper Coatings Jnulslon Adhesives Sealants Vax Modification Miscellaneous Plasticizers. M DOLLARS/YEAR 5# 000 6,000 3,000 1,300 2,000 200 200 200 200 200 NEV 022764 732819 I AROCLOR BUSINESS TO BE DISCONTINUED IMMEDIATELY APPLICATION Pesticide Extender Medicinal, Dental, Cosmetic Cutting Oils . Distributor Sales Plasticizers vn o SALES M DOLLARS/YEAR $10 90 COMPLETION DATE Completed June, 1970 June, 1970 September, 1970 -. C NEV 022765 732820 AROCLOR BUSINESS TO BE RETAINED WITH PRODUCT SUBSTITUTES APPLICATION Sealants Coatings Adhesives Wax Modification Miscellaneous Plasticizer NCR Paper SALES M DOLLARS/YEAR 4 200 200 200 200 200 2,000 ^3,000 COMPLETION DATE December, 1970 December, 1970 December, 1970 December, 1970 December, 1970 April, 1971 Industrial Fluids Pydraul AC Pydraul AC-WO Pydraul 625 Pydraul F-9 Pydraul A-200 Pydraul 5^0 Pydraul 280 Pydraul 135 Pydraul 150 Pydraul 230 Pydraul 312 Santosafe 100, 150, 300 4 300 3005 700 800 50 150 500 500 1,6050 50____________ 45,005 4 September, 1970 September, 1970 September, 1970 December, 19/0 December, 1970 December, 1970 December, 1970 June, 1971 June, 1971 June, 1971 June, 1971 June, 1971 NfcV 02276O 732821 APPLICATION Transformer Capacitors Heat Transfer AROCLOR BUSINESS TO BE RETAINED SALES M DOLLARS/YEAR $3,000 REMARKS In sealed systems. Can exercise tight control at customer plants and repair shops. Contaminated material to be reclaimed or safely destroyed. $6,000 *1.300 In sealed units.. Can exercise tight control at customer plants and repair facilities. Contaminated material to be reclaimed or safely destroyed. Disposal "of old capacitors presents problems. Development of degradable Aroclors Is underway. Used In closed systems. Control can be exercised. We will discontinue the sale of Aroclors for heating -- systems used In food pre paration* 022?b7 732822