Document 5ka1Ly48OZB5ryrb392p7VprR

P olych lorin ated B iphenyl (PCB) A PRESENTATION TO THE . EFFLUENT STANDARDS AND WATER QUALITY INFORMATION ADVISORY COMMITTEE BY MONSANTO INDUSTRIAL CHEMICALS COMPANY NOVEMBER 29,1973 c - ; < k < 774061 IDS 00238C I certainly appreciate the opportunity to participate in this m eeting of the Effluent Standards and W ater Quality Information Advisory Committee* My nam e is B ill Papageorge. I am Manager Product Acceptability for the Functional Product Croups of Monsanto Industrial Qiem ieals Company. I n this presentation I would lik e to consider several questions about polychlorinated biphenyl (PCB). Why w as it developed produced? Wbat has industry done to keep it out of the environment ? What has Monsanto done to contain the product through improved m anufacturing procedures ? What a re the problem s involved in sam pling and analyzing P C B 1s in m anufacturing effluents ? And finally, is PCB biodegradable? I would also like to p re se n t some comm ents on the so -called Toxic Pollutant L ist. And finally. I would like to sum m arize the points I 'm trying to make. PolychlorinatedBiphenyl (PCB) WHY WAS PCB DEVELOPED AND PRODUCED? * The chem ical stru ctu re of PCB has been known for n e a rly 100 y e a rs. It w as not until the late 1920's that a use fo r PCB was found - as a dielectric fluid in tran sfo rm ers and capacitors. Its properties (stability, fire-resistan c e, high dielectric strength and conductivity) seem ed perfectly suited to these electrical applications, w here high-voltage arcing, serious fire s, and damage to property and people could resu lt. Monsanto began com m ercial production of PCB in 1929. Other uses soon developed: in h eat-tran sfer fluids (because of its fire resistance), in lubricants (because of its stability), and for w ater proofing. . As long as p ro p er industrial hygiene practices w ere followed, the m anufacture of this product represented no safety or handling problem s for employes. T T+rCfkfi . J M h T O WHAT HAS INDUSTRY DONE TO KEEP PCB OUT OF THE ENVIRONMENT? In the late 1960's, sophisticated analytical procedures w ere developed which could d etect very m inute quantities of PCB in nature. Following this breakthrough, re se a rc h e rs discovered that PCB could possibly be affecting certain form s of wildlife. 774062 IDS 00kj< 2 Am m ore data w ere developed, Monsanto voluntarily undertook a two-phased program to keep the product out of the environment. FIRST: WE LIMITED SALES F irst: we lim ited sales of FCB for use in many, many applications where there was any danger of it getting into the environm ent. Today, FCB m anufactured by Monsanto Company is sold only to the electrical industry, w here it is used in closed system s . as a dielectric fluid in tran sfo rm ers and capacitors - applications w here th e re a re no known substitutes of acceptable quality and none that are fire resistant. In addition, representatives of the transform er and capacitor industries, utilities, and governm ental agencies (under the initial auspices of the National E lectrical M anufacturers Association) form ed the A m erican National Standards Institute Com m ittee C-107. This committe e issued guidelines (which have already been supplied to the committee) for handling and disposing of dielectric fluids. They reflect the industry's understanding of the need for proper control. SECONDLY: WE DEVELOPED A N AGGRESSIVE CONTROL PROGRAM A T OUR MANUFACTURING LOCATION Secondly: since 1969, w e have invested m o re than 22 m an y e a rs of work and m illions of dollars in this program ! Since we a re quite proud of our re su lts, let m e take a few m inutes to sum m arize it: --In our m anufacturing area, we have taken a num ber of significant steps to contain P C B 's. In essence, we have made the departm ent a "concrete bathtub".. Drainage is directed to trenches and piping, and then to one of two 3, 000-gallon settling basins. This insures FCB containment in case of accidental spill or equipment failure. We have also installed an incinerator to safely dispose of FC B 's. This is accomplished through incineration at or above 2000 +F. GENP 005412 When sm all quantities of FC B 's a re collected into the settling basins in the manufacturing area they are later pumped into drum s, and eventually incinerated. In the incinerator area itself, drainage is d irected to trenches and piping which flow into a 10,000-gallon basin. Recovered FC B 's a re periodically pumped to storage, or incinerated. In the manufacturing area, we have also rerouted rupture disc lines and atm ospheric vents through catch tanks, or redirected - them to settling basins. This insures that if a rupture does occur, PC B 's w ill not get into the environment, but w ill be contained in a controlled area. 774063 IDS 0023J 3 We also provide nitrogen blanketing on storage tanks to elim inate any ''breathing" of the tanks and resultant PCB escape* We have installed m ist elim inators in vapor lines - once again to elim inate the possibility of PCB's leaving the manufacturing area through these lines. Finally, we have replaced underground sew ers with above ground sew ers, and repaired or combined others, so that we ean m onitor the effluent from the department* In addition, this will prevent any unknown buildup of PC B's in our sew er system s or any contamination of PC B 's into other sewers* Much of the success of our efforts also depends on a high housekeeping level in the departm ent itself* Among the house keeping responsibilities our operators have assum ed are these: --A ll pumps a re checked for leakage on every shift. Drip pan that collect leaks a re emptied into scrap PCB drum s. --A ll leaks are reported and documented so that corrections can be made and settling basins observed* --"F loo rD ry " is used to absorb any liquid PC B's that have spilled-or leaked* If it becom es n ecessary to flusli PC B 's to the settling basin, a minimum amount of w ater is used. --Sam pling drum s and scrap-PC B drum s a re quickly palletized, labeled, and transferred to the incineration area. Through these kinds of program s, we feel we"have literally built a "concrete bathtub" to catch and safely dispose of PC B 's a t our m anufacturing location* --W e have also developed sophisticated system s to m onitor our effluent. Monitoring effluent stream s for PC B's is not an easy effort. M easurem ent ean be changed dram atically by taking the sam ple at different places along the sew er main, by changing the level at which the sam ple is taken, by changing the speed at which the sam ple is taken, o r by varying the velocity of the effluent. But we have purchased the b est available laboratory equipment, which enables us to determ ine PCB content in the parts-p er-b illio n range. Here again, however, many factors affect our findings. D r. Scott Tucker, our analytical expert, advises that the minimum detection level of PC B 's on a routine basis contained in distilled w ater is one part p e r billion (+ 25%). If "d irty " w a ter - i. e . , that containing oth er m a te ria ls which i frCOO rlKTarr \ 774064 IDS 002383 4 in terfere with the determ ination of PCB - is analysed, the detection level is 100 ppb 25%. M onitoring is a very tricky busin ess. But we feel with our experience and acquired "know-how", w e 're doing the b e st p o ssib le job. And w e do th is job 24 h o u rs a day, 365 days a year. e have also established loading and shipping safeguards to m inim ise accidental PCB loss during transportation. Specific w ritten instructions a re on every container we ship. --And finally, we have provided facilities fo r safely disposing of used PC B 's returned from custom ers. As I mentioned above, we installed a specially designed PCB incinerator, at a cost of $790,000. We have received an operating perm it from the Illinois EPA for this incinerator, which m eets all EPA requirem ents. This incinerator completely destroys PC B 's received either from our manufacturing area or from custom ers. \ Finally, we have moved toward the m anufacture of a m ore biodegradable polychlorinated biphenyl. In 1971 we in stalled a new distillation column in our m anufacturing departm ent a t a cost of $970,000. This allowed us to separate the higher chlorinated, less biodegradable compounds from the lower chlorinated, m ore biodegrad able ones. Our PC B 's a re known by the trad e nam e A roclor. We .m anufacture d ifferen t-g rad es of .A roclor .(1016, -1242,..1254, .fo r exam ple >. The lower the grade num ber, the less chlorinated and m ore biodegradable is the product. - The attached table reflects how our production mix has changed to m ore biodegradable products while the production of higher chlorinated less biodegradable products has declined. ^ GENP 0054J4 774065 10S 00238 W AROCLOR PRODUCTION AT THE Wm. 6 . KRUMMRICH PLANT IDS 002385 !7 FOTOTOTinnnnnnToHijdinnnnnj V.V.*. 00000 000090000 0000000000 1 V.V.*. > 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 so '.*>*.*.* 0 0 0 00 0000 3000000000000004 O V.V.*. > 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 V ;.V . O O O O O O O O O O O O O O O O O O O O O O D f so `V .v . l O O O O O O O O O O O O O O O O O O O O O O O O '.V-. '-..V.g..!' V.V.* OOOOOOOOOOOOOO00000000004lO n O D Q O D Q P O O Q O Q O Q Q O Q O Q O Q P 900000000000000000000000*0000000000000 H x -x v SD V . W . D ooooooooooooooaoooaoooooo'ooooooooooc 9 0 0 0 0 0 0 0 0 0 0 0 OOOOOOOOOOOOOOODOOOOOOOOO lO o o o a a oooD ooooooo ooooooooo aoooooooo oc si v.v.v.v/.v 9 0 0 0 0 0 0 0 0 00000 0000000000 000000000 0000 i iXc -X -bXa . v\S oaooooooooooooooaooooooDDaoaooooooooo 9000000000000000000000000000000000000 loooooooooooooooooooooaooaoaoooooooooc OOOODOOOOOOOOOOOOOOOOOOOOOOO >_ u> iOn Bo a n o o c OOOOOOOOOOOOOO0 0 0 0 0 0 0 0 0 0 0 0 0 4 lO O O O O O O O O O O D O O O O O O O O O O O O O O O lO O O O O O O O O O O O O O O O O O O O O O O O O O O l aooooooooooaaooooooooooooooo OBBl oooooooooooaooooooaooooooooi nooooooooooooaooooaoooooooop 0000000000000000000000000004 ----------------------------------- T i y r 1 1 -------------- --- o OOOOOOOC o> r . w K v05 ooooooo oaooooot u> i v . v . v . ooooooo "o BB oooooaot K> ooooooo aaoooaor d io o o o a o o i MT I H OH u . io ID J nu rat o. a . i b jb BB b o m m BB B JB e * b m o ' W .V A BBBBBC IOOOOOOOODOOO OOOOOOOOOOOOC lO D O O O O O bO O Q O OOOOOOOOOOOOC >000000000000 410000 OOOOOOOC <000000000000 OOOOOOOOOOOOC s It'S o o d M a o g MH M Kl <n Ol Mo -* Kl Ul ff H - H o Kl Kl o o * * H K co Kl VI O h ODI loOoOc lOO ooc loOoOc lOO 6 So I think wo can safely a s s e rt that industry and Monsanto have taken strong m easu res to contain PC B 's and keep them out of tiie environment. IS PCS BIODEGRADABLE? I mentioned before that we are presently manufacturing m ore biodegradable PCB's* We feel a ll inform ation points out - beyond any reasonable doubt - that many PCB isom ers do degrade, and they do degrade at different rates* Under pro p er conditions of use and control, PC B 's can be utilised without serious adverse consequences to the environment* To support this view, we have previously seat the reports of Monsanto studies which w ere subm itted to the Federal Interdepart m ental Task Force, on PCB's*. A rticles describing the resu lts of biodegradation studies in activated sludges a re also being prepared, and we will send copies when they a re completed. TheToxicPollutant list N either Mr* H osm er nor m y self a re toxicologists* We a re chem ical engineers. - But we would like to m ake some comments dn the toxic' pollutant list* In Section 502 (13) of the c u rre n t F e d e ra l W ater Pollution Control Act, the term "toxic pollutant" is defined as "those pollutants or combinations of pollutants including disease causing agents, which after discharge or upon exposure, ingestion, inhalation or assim ilationinto any organism , either directly from the environment o r ind irectly by ingestion through food chains w ill, on the basis of inform ation available to tho A dm inistrator, cause deatk, disease, behavioral abnorm alities, cancer, genetic m utations, physiological m alfunctions (including m alfunctions in reproduction) o r physical deform ations in such o rg an ism s o r th e ir offspring*11 We have also read the F ed eral R egister, Volume 38, No. 173, dated Septem ber 7, 1973. P a r t 129 (beginning on page 24343) is concerned with the Toxic Pollutant Effluent Standards. We a re concerned with the "catch -all" nature of these definitions and c rite ria . Depending on how they a re defined and applied, the toxic pollutant lis t could conceivably cover all chem icals and m any, many other m aterials which a re relatively innocuous in their im pact on the environment. LrtN P 005416 774067 IDS i 7 We concur with the recent suggestion of the E PA 's Acting A d m in istrato r (F ederal R eg ister Volume 38, No. 129, page 18044) th a t C ongress, intended the A d m in istra to r under the A ct " * to be selective in determ ining which of the potentially large num ber of candidate substances actually should be listed at various tim es". Although not spelled out in the definition, we feel it im portant to consider the degree of toxicity of the substance; whether or not the substance poses a threat to man, anim als, b ird s, the aquatic environm ent or some other aspect of the ecosystem . W hether or not FC B 's rem ain on the "enemy list", it is our recom m endation that an effluent lim it no m ore stringent than one pound of FCB p e r 100, 000 pounds of production be established fo r our m anufacturing operation. To keep this in p erspective, this would correspond to a concentration in the M ississippi River of 1.4 parts p e r trillio n , b a sed on th at r iv e r 's av erag e flow. We believe this concentration would have no ad v erse effect on the aquatic environm ent. In Summary e F irst: Monsanto began producing FCB to fill a m arket need. The product has excellent qualities to fill these needs. When the "alarm b ell" sounded in the late .'60's, Monsanto and the concerned in d u stries took positive steps to keep FCB out of the environment. At our manufacturing location, we developed a manysided program to contain FCB, and keep any of the product from the environm ent. Because of this, levels of FCB in the aquatic environ m ent a re reported to be lower now than before. We fee l th at sam e F C B 's a r e biodegradable, and we a re develop ing supporting evidence. Secondly: We a re concerned that the c rite ria for the Toxic Pollutant L ist are too general and susceptible to "fishing expeditions". (Excuse the p u n .) W hether FCB should be on that lis t at all is questionable.. Finally? We recom m end th at a lim it no m o re strin g en t than one pound of F C B 's p e r 100, 000 pounds of production be established for our manufacturing location. This corresponds to 1.4 parts per trillion in the M ississippi River. GENP 005417 774068 IDS 002