Document 7QnzD6n1QLMvbxZpxeo659Za

Mortsanio . ____ . . .... B. PAT ' OBORaS - ST. LOUIS APRIL 7, 1970 fffMMCi TO e. l. kxncxlbi C. J. SMITE T. K. SMITE J. L SPRJN0QAT2 Attaehad Is a copy af a plan far tmrmglng the PS problem. Bala plan was reviewed with representatives af the Medleal, Legal, Pub He Halations Department and tha Buslnass Qrex^a eenearned, and represents th@ eeneenaus and eeeaiitmant af all Involved. I have arranged far a ravlew seating In Roe B~275 an Friday, April 10th, at 2;30 PH, at trfUeh time I would ippreelat yow comments far l^rovenant. Our abjective will be to develop a final plan for presentation to the CMC an April 20. m Attachment V, , B. PAPAOSDROE STR CC15 30 WATER PCB-SD0000019955 MANAGEMENT PLAN POLYCHLORINATED BIPHENYL 3JVIRONMENTAL PROBLEM I. TBI PBQBLM The presence ef materials identified as pelychlerlnated biphenyl (PCS) In marine @nvlrenats was first noted by Profeisera G. Vidmark and 1. Jensen of the Institute of Analytical Qiealstry, Stockholm, Sweden and reported In November, 1966. Since then and with increasing frequency, ether investigators have identified PCS in marine and animal life. Increasing evidence has been noted that indicates PS is ubiquitously present in the environment and is resulting in damage to the ecological system. Monsanto is a major producer of PCS (Aroclers) worldwide and has been mentlened in many ef the reports. U. BASIC STRATEGY With the growing evidence ef the presence ef PCS and the apparent damage It can do to the world environment, Monsanto must respond as a responsible member of the business world genuinely concerned with the welfare of our environment, yet not take premature actlen which would compromise its responsibilities te its customers, sharenelders er employees. Finding ourselves on the defensive, lacking considerable information te 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 camit eur limited resources in several directions. We art actively seeking information regarding the toxic!ty and biedegradability of Aroelers, improving analytical techniques, developing processes for reclaiming Aroclors which have boon 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 fer those .Aroeler uses which cannot be cent roll @4 and which must be .discontinued. We are deliberately assuming an aggressive /posture and working elesely with customers, eo-preducers, /and regulatory ageles to prevent predpiteus action. Barly reports had indicated that the pelychlerinated biphenyls with 5 sad 6 chlorines were being identified in environmental samples. From this lnferaatien It was surmised that the lever chlorinated biphenyls were being degraded and probably were not a problem. Consequently, STR CC 15i WATER PCB-SD0000019956 a deciaien was made te plan to discontinue the manufaccure of Aroclers 125^ and 1260. Recent data, altheugn still very preliminary, Indicates chat net eneugn Information Is available to justify this action. It appears that in /those uses lftore control of spillage and disposal can be Rigidly exercised and the Aroclors are In sealed containers; e.g. capacitors and transformers, the manufacture of Aroclor 125^ and 1260 should be continued. The advantages of using these Aroclors, particularly ispf 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 Ileetrie Company, has strongly indicated that the threat of explosions and fires and loss of electrical service is so great that the use o--^oclor 12fh and 1260 cannot be discontinued. Uses of/Xrocibre-- which lead to environmental contamination and cannot be controlled will be discontinued. Ebramplet Include cutting oils, extending pesticide persistence, metal working applications, coatings on surfaces exposed to feed er potable water and NCR paper. IH. OBJECTIVE 'Sit overall objective ef this plan Is to manage the PCS pollution problem to prevent It from adversely affecting the established Return-on-Investment objectives of the Functional Fluids and Plasticizers Qro\^s, while main taining the corporate image of Monsanto as a responsible and respected member of industry worldwide. We must assume worldwide leadership and work elesely with the appropriate regulatory agencies In arriving at logical ratienal decisions Objectives supporting the overall objective are as follows: 1. .Reduce and effectively control the PCB content of all effluent from Monsanto plants. Inform customers ef the PCS problem and the importance of preventing environmental pollutlen both at their < plants or by their products, and encourage them to take responsible action by offering assistance en reclamation, substitute products and proper disposal. Develop products to replace Aroclors fer those uses In which Aroclors have been demonstrated to be harmful to the environment and cannot be prevented from escaping into the environment. ST R CC l WATER PCB-SD0000019957 4. Develop reliable analytical procedures for determining PCB content of liquids, gases, or solids. 5. Develop methods for effective disposal of wastes con taining PCB without eontaminating the environment. 6. Develop methods for reclaiming and reusing effgrade fluids containing PCS. 7. Determine effects of PCS' a on birds, aquatic life, animals and humans. .8 1 Establish &nd maintain favorable relationships with our customers, the press, governmental agencies, other worldwide producers, the public, and the universities. ACTION FLAK 1. Objective - Reduce and effectively control the PCB 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, Wales 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 ar being identified and 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 Baglneerlsg Manager, Functional . Fluids, ZD ` Manager, Research k Development, Functional Fluids Date - All plants achieve 5 ppb in effluent by January* 1971. All plants achieve target of 10 ppb by September, 1971. sir CO 1523 WATER PCB-SD0000019958 2. Objective - Inform customers of the PCB problem ana the importance of preventing environmental pollution both at their plants or by their products. Statua - All Functional Fluids and Plasticizers customers In the U.S. have been informed. Customers In Canada,' U. K., Scuth America, Japan and Continental Barep have not ben informed. Action - Inform cuitoein In Canada, U.K. and Japan. Customers In Europe will not be Informed until con census Is reached by all PCB producers In Europe, notification of South American customers to follow. Responsibility - Sale DBreetars, Functional Fluids and Haatielxers Group Date_ - Canada, U.K. and Japan by May 1, 1970 Europe and South America - as Indicated. Objective - Develop products to replace Aroelers Tertaosir uses In which Aroelers have been demonstrated to be harmful to the environment, are resistant to biodegradation, and cannot be prevented from escaping to the environment. Status - Work on product substitutes has been cEIrected primarily at Industrial Fluids applications and NCR Paper coating. Water-glycol mixtures, bromlnated Aroelers, bromlnated biphenyl, silicates, blends using chlorinated terphenyls with lower chlori nated biphenyls, terphenyls with phosphate esters, phenyl other with biphenyl, chlorinated paraffins, and fractionated Arocler 1242 are all under study for Functional Fluids application. Alkylated biphenyls and HB-40 (hydrogenated terphenyls) appear promising for NCR Paper applications. Action - Replace Arocler 1242 in NCR paper coating with lsopropylblphenyl for U.S. applications and with HB-40 (hydrogenated terphenyl) for U.K.applications. ^-Responsibility - Manager, Research and Development, \ FlaJ'tieixiHT Group; Sales Director, Plasticizers Group Date - U.K. applications - complete by April, 1971 U.S. applications - complete by July, 1971 STR QC 153* WATER PCB-SD0000019959 -5- Actlon - Develop acceptable substitutes and complete conversion from Arcelor 125^ and 1260 in Sealants and coatings. Responsibility - Manager, Research & Development Plasticizers Group Sales Director, Plasticizers Qro\gj Date - January, '.1971 Action - Develop acceptable substitutes and selec tivity phase-out of Aroclor containing industrial fluids. Responsibility - Manager, Research St Development Punetlon&l Fluids Qrsvg> Sales Director, Functional Fluids Date - Pydraul AC - September, 1970 Pydraul AC WG - September, 1970 Pydraul 625 - September, 1970 Pydraul F-9 - December, 1970 Pydraul A-200 - December, 1970 Pydraul - December, 1970 Objective - Develop reliable analytical procedures for determining PCS content of liquids, gases and solids. Status - Procedures have been developed. Ceples have been offered to university and governmental laboratories. Consents regarding our procedures and comparison of results with other procedures have been sellcited. Arrangements have been made for exchange of sables to verify analytical results. Action - Continue to refine methodology until we . rSacST'a level of competence which will provide data ` sbofte accuracy will not be challenged. Reepenalbillty - Section Manager, Applied Sciences Date - July 1, 1970 ' SIR 001535 WATER PCB-SD0000019960 --6 -- 5. Objective - Develop methods for effective disposal of Waites' containing PCS without contaminating the environment. Status - Studies are being conducted on bledegradability, incineration and removal from water solutions. Medegrmdabillty studies of existing and substitute products with acllaatlzed aioroorgamsM are being conducted at Ruabon. Data to date lndlcatos that the manoefalor and seme of the dl and trlehlor biphenyls degrade; remaining PCS'e are highly resistant. Studies in St. Louie in river water indicate high resistance to degradation. Incineration tests of 12^2, 1260 and Inertsen PPO indicate combustion can be sustained with minimum 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 fflC 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. S. Krumarlch plant, the removal, of Aroclora from HC1 gas streams by high temperature cracking are being studied. Discussions have been held with representatives of Monsanto tovlro Chen Systems regarding disposal of Aroclors, solids containing Aroclors and water con taining Aroclora. 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 varleus customers' plants. * Action - Continue biodegradation work of existing and substitutes products at both Ruabon and St. Louis to establish degree of degradation possible and optimum conditions required. Responsibility - Manager, Research k Development Functional Fluids Qroiv Date - October 1, 1970 STB CC 1 Sic WATER PCB-SD0000019961 -7- Aciion - Evaluite alternate methods of disposal by incineration - Monsanto operated va. contract. * Responsibility - Engineering Manager, Functional TXulds Group,CD Date - July 1, 1970 Action - Continue the work at Anniston, Kruasarich anaTSyton on the removal of PCS from water streams. Responsibility - Manager, Research and Development, Functional Fluid* Group. Date - September 1, 1970 Action - Pursue possible contribution by Monsanto Rviro Q%mm Systems, Znc. to disposal of Arcelor wastes. Responsibility - Manager, Environmental Control Date - September 1, 1970 Objective - Develop methods for reclaiming and re using ofr-grade fluids containing PCS. Status - Limited reclaiming has been achieved by KSSett, Inc. Arrangements have been made for the reworking of a tank car of material at V. G. Krumarich plant. Initial efforts will be concentrated en returned material from large electrical customers. Meanwhile, customers are holding material for further instructions or are dinping la authorised land fills. Action - Develop procedure for processing of re turned' material. ' Responsibility - Manager, Research t Development, Functional Fluids Group Manufacturing Manager Date - May 1, 1970 ' Action - Select and modify as necessary, the required equipment at the V. G. Krusnrlch plant. Respenalb 1 Hty - Manufacturing Manager Pate - Appropriation request by June 1, 1970 Fully operational by January 1, 1971 STR 001.537 WATER PCB-SD0000019962 8- - 7. X Objective - Determine effects of PC3' a on birds, \aquatic life, animals and humans. Status - Toxieltj studies are being mad fir Monsanto 'By^TnHustrial Bio-Test Laboratories. Studies include tiro year eral toxicity on rats, three generation reproductlen study on rats, two year oral toxicity en dogs asd studies on egg production, hatehahllity and survival en chickens. The Arocler* used in these studies are Arocler 1242, Arocler 1254 and Arocler 1260. Results te date indicate the follevlng: Liver en largement in male rats at 100 ppm; bo^ velghtlloss in dogs by higher chlorinated Arocler*; rat repro duction effected by 100 ppm Arocler 1242 or Aroclor 1254; chicken reproduction effected by lower chlori nated Arocler*. Studies en fish were attempted, but were discontinued when cross contamination was discovered. These studies will be resumed. Action - Centlnue studios now underway. Evaluate need ^er extending studies te include chlorinated terphenyla, hydrogenated terphenyla, alkylated biphenyls and Porocel treated chlorinated biphenyls. Resume fish texlclty studies. Responsibility - Medical Department Date - Complete by mid-1971. ' 8. Objective - tttabllsh and maintain favorable relationships with customers, the press, gtvtmmmtal agencies, ether worldwide producers, the public and the universities. Status - Relationships are excellent. Ve have expressed interest In studying the problem and indicated that we wish te cooperate to help identify and solve it. Pressure te divulge more information vUl centlnue to Increase. Action - Appropriate Monsanto personnel will continue to participate In activities related te the PCS problem in a manner which will maintain our excellent relationship Responsibility - All personnel Date - Continuing SIR CC1538 WATER PCB-SD0000019963 "9" 7. COSTS Costa for tbs program for 1970 havo boon budaotod u follow; Program Budfot . $M DoyoIop ABalytlcal Proeoduros To^eity Studios Plant Xffluit Studios ModogradabiUty Studios Dovolop Edapesal Motboda Soelaiislnt Sjstoms Doslpi Substitute Produets Ortrall Administration $ 80 105 105 40 50 30 150 Total $675 STR GDIS WATER PCB-SD0000019964