Document 2qk1dyj882wEX6xpXoXrvxQJL

Monsanto . --W. B. PAr ' GEDRGZ - 3T. LOUI3 APRIL 7, 1970 TO : H3uBfa1^ I. L. KDICKLSR C. J. SKITS T. K. SKITS J. . SPRIMOGATX Attached Is & copy of & plan for managing the ?CS problem* - This plan vas reviewed with representatives of the Medical, Legal, Futile Relations Departments and the Business Qrotps concerned, and represents the concensus and commitment of ail Involved. I have arranged for a review meeting In Room B-275 on Friday, April 10th at 2:30 PM, at tdHeh time I would appreciate your comments for Improvement. Our objective will be to develop a final plan for presentation to the CMC on April 20. Attachment V, , B. PAPAGED ROE EXHIBIT m 5?v STA CC153Q HARTOLDMON0028069 management plan POLYCHLORINATED 3IPHENYI BT/IRONMENTAi PROBLEM I. TSE PROBiB* The presence of materials identified u polychlorinated biphenyl (PCS) In marine envirenmit8 was first noted by Professors 0. Vidaark end 3. Jensen of the Institute of Analytical Qiemistry, Stockholm, Sweden end reported In November, 1966. Since then and with increasing frequency, other investigator* have identified PCS in marine and animal life. Increasing evidence has been noted that indicates PQ is ubiquitously present in the environment and is resulting in damage to the ecoleglcal system. Monsanto 1s a major producer of PCS (Aroclors) worldwide and has been mentioned in many of the reports. II. BASIC STRATEGY With the growing evidence of the presence of PCS and the apparent damage it can do to the world environment, Monsanto must respond as a responsible member ef the business world genuinely concerned with the welfare of our environment, yet not take premature action which would compromise its responsibilities to its customers, sharenolders or employees. Finding ourselves on the defensive, lacking considerable information to help in arriving at sound business decisions and with no real influence regarding the time of any precipitous action by the press, competitors, public or governmental agency, we are forced to commit our limited resources in several directions. We are actively seeking information regarding the toxicity and biodegradability of Aroclors, improving analytical techniques, developing processes for reclaiming Aroclors which have been determined unsuitable for further use, developing methods for complete destruction by incineration, controlling our plant effluents, working with our customers to control and eliminate environmental pollution with Aroclors and developing alternate products for those .Aroclor uses which cannot be controlled and which must be .discontinued. Ve are deliberately assuming an aggressive /posture and working closely with customers, co-producers, /and regulatory agencies to prevent precipitous action. I&rly reports had indicated that the polychlorinated biphenyls with 5 and 6 chlorines were being Identified In environmental samples. Prom this information it was surmised that the lower chlorinated biphenyls were being degraded and probably were not a problem. Consequently, S 78 cc 1 5 i HARTOLDMON0028070 a decision was aide to plan to discontinue the manufacture of Aroclors 125^ and 1260. Recent data, a_though still *' very preliminary, indicates tnat not enough inforaaticn is available to Justify this action. It appear* that in /those uses titer control of spillage and disposal can be \Tigidly exercised and the Aroclors are in sealed containers; e.g. capacitors and transformers, the manufacture of Arcelor 125^ and 1260 should be continued. The advantages of using these Aroclors, particularly ehere safety is a prime consideration, and no practical substitute has been developed, far outweigh the potential threat to the environment. One of the principal users of Aroclors in electrical equipment, General Cectrlc Company, has strongly indicated that the threat of explosions snd fires and loss of electrical service is so great that the use o--Areclor 1254 and 1260 cannot be discontinued. Uses -------------------------- )V> which lead to environmental contamination and &annot be controlled will be discontinued. Examples include cutting oils, extending pesticide persistence, metal wording applications, coatings on surfaces ej^osed to food or potable water and NCR paper. XU. OBJECTIVES The overall objective of this plan is to manage the P<2 pollution problem to prevent it from adversely affecting the established Return-on-Investment objectives of the Functional Fluids and Plasticizers Croups, tfiile main taining the corporate image of Monsanto as a responsible and respected member of industry worldwide. We oust assume worldwide leadership and work closely with the appropriate regulatory agencies in arriving at logical rational decisions. Objectives supporting the overall objective are as follows: 1. .Reduce and effectively eontrol the PCS content of all effluent from Monsanto plants. Inform customers of the PCS problem and the importance of preventing environmental pollution both at their plants or by their products, and encourage them to take responsible action by offering assistance on reclamation, substitute products and proper disposal. . 3. Develop products to replace Aroclors for those uses in which Aroclors have been demonstrated to be harmful to the environment and cannot be prevented from escaping Into the environment. STR -C l HARTOLDMON0028071 I 4. Develop reliable analytical procedures for detsmnlng PCS content of liquids, gases, or solids. 5* Develop methods for effective disposal of wastes con taining PCS without contaminating the environment. 6. Develop methods for reclaiming and reusing off-grade fluids containing PCS. 7. Determine effects of PCS's on birds, aquatic life, animals and humans. .8 Xstabllah and maintain favorable relationships with our customers, the press, governmental agencies, other worldwide producers, the public, and the universities. 17. ACTION PLAN 1. Objective - Reduce and effectively control the PCS content of all effluent from Monsanto plants. Status - A tentative target of 10 ppb of PCS In plant liquid effluent has been established. Plants at Anniston, Alabama, Newport, Vales and Sauget, Illinois have monitored plant effluents and found high levels of PCS contamination in waste streams and In sediment at plant discharges. Leakage and spills are being Identified snd corrected. Arrangements have been made for the installation of Interceptor basins to contain major spills. ' Action - All plants to continue emphasis on control to achieve target of 10 ppb In effluent. Responsibility - Manufacturing Manager Bigineering Manager, Functional . Fluids, CXD * Manager, Research k Development, Functional Fluids Bate - All plants achieve 50 ppb in effluent by January, 1971. All plants achieve target of 10 ppb by September, 1971. ST.R CO 1523 HARTOLDMON0028072 -i- 2. Objective - Infora customers of the PC2 probiea ana the importance of preventing environmental pollution both at their plants or by their products. Status - All Functional Fluids and Plasticizers customers In the U. S. have been Informed. Customers. In Canada, U.K. , South America, Japan and Continental Surope have not been informed. Action - Inform customers In Canada, U.K. and Japan. Customers In Surope will not be Informed until con census Is reached by all PCS producers In Surope. Notification of South American customers to follow. Responsibility - Sales Directors, Functional Fluids and Plasticizers Qroupt Date - Canada, U.K. and Japan by May 1, 1970 . Surope and South America - as indicated. 3. /Objective - Develop products to replace Aroclors / for those uses In which Aroclors have been demonstrated / to be harmful to the environment, are resistant to A. biodegradation, and cannot be prevented from escaping \to the environment. Status - Work on product substitutes has been directed primarily at Industrial Fluids applications and NCR Paper coating. Water-glycol mixtures, bromlnated Aroclors, bromlnated biphenyl, silicates, blends using chlorinated ccrphenyls with lower chiori* nated biphenyls, terphenyls with phosphate esters, phenyl ether with biphenyl, chlorinated paraffins, and fractionated Aroclor 1242 are all under study for Functional Fluids application. Alkylated biphenyls and EB-40 (hydrogenated terphenyls) appear promising for NCR Paper applications. Action - Replace Aroelor 1242 In NCR paper coating * with lsopropylbipheny1 for U.S. applications and with HB-40 (hydrogenated terphenyl) for U.K.applications. Responslb111ty - Manager, Research and Development, \ Plasticizers Group; Sales Director, Plasticizers Croup Date - U.K. applications - complete by April, 1971 U.S. applications - complete by July, 1971 SIR 0C 151- HARTOLDMON0028073 -5- Actlon - Develop acceptable substitute* and complete conversion; from Aroelor 1254 and 1260 In Sealants and coatings. Responsibility - Manager, Research k Development Plasticisers Group Sales Director, Plasticisers Grov^ Sate - January,' 1971 Action - Develop acceptable substitutes and selec tivity phase-out of Aroclor containing Industrial fluids. Responsibility - Manager, Research & Development Functional Fluids Group - Sales Director, Functional Fluids Date - Pydraul AC - September, 1970 Pydraul AC TO - September, 1970 Pydraul 625 - September, 1970 Pydraul P-9 - December, 1970 Pydraul A-200 - December, 1970 Pydraul 5^0 - December, 1970 1. Objective - Develop reliable analytical procedures for determining PCS content of liquids, gases and solids. Status - Procedures have been developed. Copies have been offered to university and governmental laboratories. Consent regarding our procedures and comparison of results with other procedures have been solicited. Arrangements have been made for eacnange of samples to verify analytical results. Action - Continue to refine methodology until we . reach a level of competence which will provide data ' rtioee accuracy will not be challenged. Responsibility - Section Manager, Applied Sciences Date - July 1, 1970 STA OOIS35 HARTOLDMON0028074 -6- Ob Jectlve - Develop methods fop effective disposal of wutea cenc&inins PCS without contaminating the environment. Status Studies are being conducted on biodegrad ability, Incineration and removal from water solutions. B1degradability studies of existing and substitute products with aclla&tlzed mieroorganisaa are being conducted at Ruabon. Data to date Indicates that the monochlor and some of the dl and trlchlor biphenyls degrade; remaining PCS's are highly resistant. Studies in St. Louis In river water indicate high resistance to degradation. Incineration tests of 12U2, 1260 and Inerteen PPO Indicate combustion can be sustained with aiMnua fuel requirements. Stack gas samples taken for analysis to determine degree of destruction indicated degree of destruction to be acceptable. Recovery of Aroclors from dilute water solutions Is being studied at Anniston and by KRC at Dayton. At Anniston, adsorption on carbon is being evaluated. At Dayton, the use of add clays, limestone silica and treated silica are being studied. At the V. G. Krumatrich plant, the removal of Aroclors from SCI gaa streams by high temperature cracking are being studied. Discussions have been held with representatives of Monsanto Bnvlro Chem Systems regarding disposal of Aroclors, solids containing Aroclors and water con taining Aroclors. Proposals for the testing at the St. Charles unit of disposal by pyrolysis were requested. Further work on water effluents Is planned following the analysis of samples from various customers' plants. Action - Continue biodegradation work of existing and substitute products at both Ruabon and St. Louis to establish degree of degradation possible and optimum conditions required. Responsibility - Manager, Research S> Development Functional Fluids Gr\|p Date - October 1, 1970 STR CC lSift HARTOLDMON0028075 7- Actlon - Evaluate alternate methods of disposal Incineration - Monsanto operated vs. contract. -7 Responsibility - Engineering Manager, Functional fluids Group,CZD Sate - July 1, 1970 Action - Continue the work at Anniston, Kruaarich ana Dayton on the removal of ?C3 from water streams. Responsibility - Manager, Research and Development, Functional Fluids Group. Sate - September 1, 1970 Action - Pursue possible contribution by Mansante Stiviro Che* Systems, Inc. to disposal of Aroclor wastes. Respenalblllty - Manager, Environmental Control Sate - September 1, 1970 6. Objective - Develop methods for reclaiming and reuslng efT-grade fluids containing PCS. Status - Limited reclaiming has been achieved by Pindett, Inc. Arrangements have been made .for the reworking of a tank car of material at V. 0. Krumauich plant. Initial efforts will be concentrated en returned material from large electrical customers. Meanwhile, customers are holding material for further instructions or are dumping in authorised land fills. Action - Develop procedure for processing of re- turoed material. ' Responsibility - Manager, Research & Development, Functional Fluids Oroup Manufacturing Manager Date - May 1, 1970 Action - Select and modify as necessary, the required equipment at the V. a. Krumnrlch plant. Responsibility - Manufacturing Manager Date * Appropriation request by June 1, 1970 Fully operational by January 1, 1971 STR 0CLS37 HARTOLDMON0028076 -8- 7. / Objective - Determine effects of PC3's on birds, \aquatic lift, animals and humans. ' Status - Toxicity studies are being made for Itonsante by Industria1 Bio-Test Laboratories. Studies include two year oral tcxieity on rats, three generation reproduction study on rata, two year oral toxicity on dogs and studies on egg production, h&tchability and survival on chickens, ft Arcelor* used in these studies are Aroclor 1242, Arocler 1254 and Aroclor 1260. Result a to date indicate the following: Liver en largement in male rats at 100 ppm; body velghtlloas in dogs by higher chlorinated Aroclora; rat repro duction effected by 100 ppm Aroclor 1242 or Aroclor 1254; chicken reproduction effected by lower chlori nated Aroclora. Studies on fish were attempted, but were discontinued wnen cross contamination was discovered. These studies will be resumed. Action - Continue studies now underway. Evaluate need for extending studies to include chlorinated terphenyla, hydrogenated terphenyla, alkylated biphenyls and Porocel treated chlorinated biphenyls. Resume fish toxicity studies. Responsibility - Medical Department Date - Complete by mid-1971. 8. Objective - Establish and maintain favorable relationships with customers, the press, governmental agencies, other worldwide producers, the public and the universities. . Status - Relationshipa are excellent. Ve have expressed Interest in studying the problem and indicated that we wish to cooperate to help Identify and solve it. Pressure to divulge more information will continue to increase. Action - Appropriate Monsanto personnel will continue to participate in activities related to the PCS problem in a manner which will maintain our excellent relationship Responsibility - All personnel Date - Continuing STS CCIS3S HARTOLDMON0028077 7. POSTS Costa for tbs program for 1970 bate been budgeted u follows: Program . develop Analytical Procedures Toxicity Studies Plant Zffluent Studies Biodegradability Studies develop Disposal Methods Substitute Products Overall Administration Budget *H 4 80 105 105 40 50 30 150 Total 4675 STR CO 1 3 HARTOLDMON0028078