Document 6B91bjnbpxxONpgOyrJd46Xkg

J. j. Zeman - B2SK December 15, 1975 Emergency Plan - PCB's R. G. Potter Attached for your review is the PCB Emergency Plan. After you have had a chance to look it over, I would like to sit down with you and answer any questions you may have. I am sure your calendar is as full as mine, but I think we should meet as soon as you have had a chance to look at the plan and we are able to schedule a meeting. in addition to the plan itself, we have included a sheet titled "Policy Decisions Needed for CAC Approval", another sheet on preliminary actions and PCB Emergency Plan Telephone List. /rd Attachments J. J. Zeman DSW 185202 STLCOPCB4051448 EMERGENCY PLAN - PCB*s Scenario - Immediate ban on production, sale or use of PCB before volume production of MCS 1238 is ready. Responsibility for verification of existence of a ban, initiation of this plan and verification of acceptance of responsibilities: R.G. Potter A. Immediate Actions Upon Notification of Ban 1. Suspend chlorination operations. Suspend ship ments from Krummrich Plant and warehouses (Santa Clara, Elizabeth, Los Angeles). Do not recall shipments enroute. Finish any distillation batches under way. ^ Responsibility: R.A. Pohl Contacts: Krummrich Plant - A.E. Leisy R.W. Flint Warehouses - E.M. Potter C.B. Sigler 2. Make preliminary press release (prepared in advance) stating that operations have been suspended and supplying background information on our PCB control efforts, status of replacements. Responsibility: D.R. Bishop Timing: Upon notification from R.A. Pohl that item A.l is complete. 3. Communicate situation to other affected Monsanto operations. a. Krummrich production planning - D.T. Mayer b. Process Chemicals Marketing (CS Acid, Muriatic) - J.F. Winkler c. Anniston Plant (biphenyl) - W.E. Voss d. Purchasing (TCB, drums) - B. Byrne Responsibility: E.M. Potter DSW 185203 STLCOPCB4051449 -2- 4. Determine precise details of ban: Marketing (D. Wood) ' Product Acceptability (J.C. Weber), Washington Office (W. Easley), Legal (W. Withers/T. Bottini), and report to Business Director. Coordinating Responsibility: D. Wood 5. Review this plan to determine whether it fits the circumstances and make recommendations to the CAC on policy and implementation. Responsibility: R.G. Potter Timing: Within 2 business days , B. Follow-up Actions After CAC Approval of Detailed Policy 1. Appoint Administrative Coordinator for 3-6 month period. Responsibility: R.G. Potter 2. Briefing meeting (first day) to define policy and announce appointment of coordinator to: a. Business Group b. COP c. Sales Force d. Research e. p;r. f. Washington Office Responsibility: R.G. Potter 3. Notify Customers by: a. Telephone to most senior management contact Marketing (first day) b. Certified express letter to: - -- Office of the President -- Purchasing Manager of use locations -- Confirmation to telephone contact (Note: Direct all immediate customer responses to Marketing Group.) Responsibility: D. Wood DSW 185204 STLCOPCB4051450 -3- 4. Notify Manufacturing, Company-wide, to minimize impact on operation of Askarel units. Responsibility : - R.A. Pohl to G.L. Bratsch 5. Resume production and shipments as permitted by the . approved policy, if any. Responsibility: R.A. Pohl E.M. Potter 6. Brief corporate marketing directors with other sales to dielectric customers on policy (second day). Responsibility: D. Sliney 7. Notify Federal/State agencies of policies^ (3-5 days). Responsibility: Washington Office - W. Easley 8. a. P.R. release on policy (second day) b. P.R. prepare Q&A sheet on policy (third day) c. Series of paid advertisements (7-15 days) Responsibility: D.R. Bishop 9. Prepare form letters (third-fourth day). a. Transformer users b. Capacitor users Responsibility: D. Wood 10. Brief U.S. Export Managers on export policy (fifth day). Responsibility: C. Paton/D. Wood 11. Management/Marketing meetings with customers (secondthird week). Responsibility: D. Wood 12. Notify U.S. export customers of policy (second week). Responsibility: Area Managers 13. Upon completion of final customer shipments, move all Monsanto PCB inventories to Kruramrich incinerator. Responsibility: E.M. Potter 14. Initiate decontamination of Krummrich PCB facilities (see detailed decontamination plan): Responsibility: R.A. Pohl DSW185205 STLCOPCB4051451 EMERGENCY PLAN - POLICY DECISIONS NEEDED FOR CAC APPROVAL Dbmestic 1. Date of final production. . / 2. Shipment of inventory. 3. Customer commitment to orders on books but unshipped. 4. Incinerator returns (maximum rate 300,000 pounds per month). ' a. All returns invoiced a price to fully cover incineration cost. b. All customers given equal opportunity to use service. c. COP to be set up to handle. d. Alert other incinerator services of our policy. 5. No change in policy on refusal to ship transformer makeup requirements to transformer users. They should still obtain product from transformer manufacturer. 6. What assistance we will give on customer plant decontami nation. a. Capacitor/Transformer manufacturers. b. End users -- will refer to equipment manufacturers (let our customers know we will do this). 7. Position on replacement fluid from Monsanto. D S W 185206 U.S. Export 1. Recommend cease shipments two months after we cease domestic shipments. a. Documentation/L of Credit/Import licenses involve longer lead time and possibility of legal liability if we shut off immediately. b. Additional flexibility in inventory run down. Ex-U.S.A. a. Maintain U.K. production and take separate decision within one month of a U.S. ban. b. MESA should avoid commitment to long term supply contracts. STLCOPCB4051452 Preliminary Actions 1. Persuade customers (capacitors) to buy and increase inventory of Aroclor/Capacitors/Inventories at users to give 4-6 months bridge. ' Responsibility: D. Wood (first contact by 2/15/76) 2. Persuade customers to accelerate MCS 1238 approval pro grams . Responsibility: D. Wood (contact by 2/15/76) 3. Confirm no continuing contractual obligations to supply. Responsibility: D. Wood (12/31/75) 4. Prepare survey of Askarel equipment used by Monsanto. Responsibility: G.L. Bratsch (request to GLB by 12/22/75) 5. List corporate sales to all dielectric customers. Responsibility: R.E. Hatton (12/31/75) 6. Prepare Tentative P.R. statement. Responsibility: D.R. Bishop (1/1/76) 7. List names of contacts to call at all customers. Responsibility: D. Wood (12/31/75) 8. Define detailed decontamination procedure for use at Krummrich and possible adaptation for customers. Responsibility: J.R. Savage (1/5/76) 9. Prepare recommendation on advice to customers re decontami nation. Responsibility: D. Wood (2/1/76) 10. Develop list of publications for potential ad campaign. Responsibility: D.R. Bishop (12/19/75) DSW 185207 STLCOPCB4051453 PCB EMERGENCY PLAN - TELEPHONE LIST R.G. Potter Manufacturing R.A. Pohl A.E. Leisy R.W. Flint D.T. Mayer W.S. Voss ' Marketing C. Paton D. Wood Medical/Prdt. Acceptability J.C. Weber Dr. G. Roush W.B. Papageorge Legal W.W. Withers ' T. Bottini - Distribution E.M. Potter C.B. Sigler R.A. Sipes ' Washington Office W.K. Easley Public Relations D.R. Bishop Office 4-2142 4-2243 812-2019 812-2045 812-310 823-205-293 4-2529 4-2623 4-2027 4-2191 4-2086 4-2851 4-2872 4-2443 4-2428 4-2431 821-4548 4-2891 Home 469-1835 991-5455 966-5603 849-0753. 613-286-3483 205-237-5334 227-7581 536-2161 961-7693 997-2234 878-3513 227-8345 725-0677 567-6043 618-234-9945 821-0938 301-299-9587 469-1377 SVV 185208 STLCOPCB4051454