Document 85JO8qrMzEEbDGbEKvXmQbZ5Z

CONFIDENTIAL Dates October 2, 1969 Subject: REPORT OF AROCLOR "AD HOC1' COMMITTEE To: Howard S. Bergen, Jr. James E. Sprlngate From: M. H. Farrar P. B. Hodges, Secretary E. V. John W. R. Richard E. P. Wheeler, Chairman HONS 036720 TOWOLDMONOQ47671 i ! . CONTENTS 1. Objectives 2. Probability of Success 3. Recommendations 4. Basis for Recommendations 5. Qeneral Background . Page 1 Page 2 Page 3-4 Page 5-H Page 036721. TOWOLDMONOQ47672 -1- A*1 OBJECTIVES At a meeting of business group directors of Function Fluids and Plasticizers with Organic Division and Cor porate Staff membersI, an "ad hoc" committee was appointed to prepare a resume of the situation concerning the envir onmental contamination through the manufacture and use of polychlorinated biphenyls (Aroclors). The objective of the committee was to pa-ey aie recommend* action# that will: ' 1. Protect continued sales and profits of Aroclors; 2. Permit continued development of new uses and sales, and 3. Protect the J^jgaee of the Organic Division and the Corporation os members of the business community recognizing their responsibilities to prevent and/or con trol contamination of the global ecosystem. / HONS 036722 I f TOWOLDMONOQ47673 1 `' "tm PROBABILITY OF SUCCESS - The committee believes there`Is little probability . . that any action that can be taken will prevent the growing Incrimination of specific polychlorinated biphenyls (the higher chlorlnated--e.g. Aroclors 1254 and 1260) as nearly global environmental contaminants leading to contamination of human food (particularly fish), the killing of Borne marine species (shrimp), and the possible extinction of several species of fish eating birds. Secondly, the committee believes that there Is H*_ourse^olLactlon that can so effectively police the uses of these products as t6 preventfenvlronraental con tamination. There are, however,/a number of paaaMe actions which must be undertaken/to prolong the manufacture, sale and use of these partlcular'AroclorV aV wel1Vs to protect the continued use of other members of the Aroclor Berles. (!*** d* The ultimate that can be expected l^the continued use o_Jbbe.lower chiqrlnatd_)?JLl>hruclB/nd the chlorlnate'd terphenyls'ln"appllciftlons amenable to such control that there Is practically tero losses to the environment. In the interim we would hope to establish by appropriate research efforts "tolerance" or safe levels for particu lar Aroclors in the environment. v 4A . 7e ' c/c ^i #v* /* ~ i h >y ^ # ------- #./ S't4^C *. -Z/M U<*J t*2 t* ^ * --' ` s*-- 0367^3 hons TOWOLDMONOQ47674 -3- RECOMMENDATIONS In view of legal and moral considerations, notify ' all Aroclor 125*1 and 1260 customers of environmental contamination problem-, CMiow^eSJ- ---- -- Consult with appropriate federal agencies1 head quarters in Washington to determine current status of concern and to inform appropriate Individuals therein of Monsanto's research and control efforts. Personally contact all governmental and university laboratories which have requested Aroclor samples and indicated interest in the environmental contam ination problem. 2,/ Reduce losses of Aroclors in liquid wastes fjn Monsanto plants to efreQlwbe minimum. Goal-*u to /*" 5. Determine extent of atmospheric losses from. Aro- clors from Anniston and WOK Plants and develop plans for control. , 6. Analyze in Organic Division laboratories (or by contract) selected appropriate samples fr.om: a. Environment of Anniston and WGK PlantB. b. Monsanto products where contamination is possible. c. Agencies and/or laboratories attempting to pinpoint specific sources of contamination. d. Customer plants' environments. e. Research efforts involved in biological tudles--i.e. animal, bird and fish toxicity studies and biodegradation studies. 7. Expand analytical capabilities in oonjunotion. with Items 5* and 6. above. HONS 03672% TOWOLDMONOQ47675 -4/ RECOMMENDATIONS (Continued) 8. Assign one Individual from the division full-time for three to six months to coordinate division and Corporate Staff department efforts. 9* Establish special budgetary account to allow implementation of these recommendations and the continuation of the toxicological research effort now underway and continuing until June, 1971. . HONS 036725 TOWOLDMONOQ47676 BASIS FOR RECOMMENDATIONS 1 Notification of All Customers *" 2A, 1969 the San Francisco Chronicle pubrisnea a "scare story following an interview with Dr. Robert Rlaebrough of the University of .California, The latter had recently publlahed In Nature the finding of polychlorinated blphenylB In fish, birds and eggs in the California coastal areas. On March 3* 1969* the Functional Fluids group sent a letter to the 31 major Aroclor customers in the transformer and capacitor applications. The letter Included a copy of the Chronicle story and a Mon santo statement concerning the situation. This was intended to announce to these customers that the polychlorinated biphenyls might be in trouble and implied that the customers should make every effort to prevent loss of these materials to the environment. There has been subsequently some follow-up with at least General Electric and Vestinghouse. It has been recognised from the beginning that other functional fluid uses could lead to losses of the Aroclors to liquid waste streams from the customers' plants. Losses could occur from spills, unusual leakage of large volumes and daily losses of smaller volumes. It has also been recognised that there could be vapor losses but it has been felt that these were perhaps of less significance than the vapor losses In plasticiser applications. The concern for vapor losses rises from the published proposed theory that even minute quantities of vapors are eventually transferred to the water environment and accumulated therein. Another possible source of air environmental con tamination is the eventual destruction of materials which have Aroclors in them. Of particular signifi cance might be the burning or partial incineration of waste or used products containing the Aroclors. HONS 036726 TOWOLDMONOQ47677 -6- BASIS FOR RECOMMENDATIONS (Continued) As the alarm concerning the contamination of the environment growB It Is almost certain that a number of our customers or their products will be incriminated. The company could be considered derelict, morally if not legally, if it fails to notify all customers of the potential Implication. , A case in point is the recent determination (mld- eflT' A**et) that milk to be marketed by the Maryland ' Cooperative Milk Producers, Inc. in Baltimore was contaminated with polychlorinated biphenyls. The source of the PCB's was isolated to six dairy herds in Martlnsburg, West Virginia. Investigation by the Producers Association Is continuing but to our knowledge the specific source of the PCB has not been pin-pointed. When the Aroclors were indited as causing poisoning In cattle In the mld-1950'B, chlorinated naphtha lenes were eventually identified as' the causative agent. The naphthalenes were used in greases or lubricants for cattle feed machinery and had con taminated the animal food. (Members of the Medical Department have been told that the Texas company "bought" 6,000 head of cattle around the country as a result of this incident. It is not known whether or not the suppliers of the naphthalenes to Texaco were brought into the settlement) Are our customers selling grease or lubricants con taining Aroclors that are now responsible for the milk contamination? In the plasticizer use area, the Aroclors may be used in rubber based paints or surface coatings. The uses for these surface coatings include the interior walls of potable water aupply storage tanks in some communities. In Europe we have been told that similar paints are widely used for swim ming pools. In spite of the low degree of solu bility of the PCB's in water, there are sentiments among the European scientists (and our PCB competl tive manufacturers) that such uses may be sources of pollution. Other customer applications or uses which could be suspect Include highway marking paints, aw4- any of the oil and/or grease lubricant applications^ ~ ii^r7zr&; HONS 036727 TOWOLDMONOQ47678 I i> I i \ I l 1 1 -7- BASIS FOR RECOMMENDATIONS (Continued) 2. Consultation with Federal Agencies In August of 1968 when the current effort related to this problem got underway, the scientists at the U. S. Department of Interior, Fish and Wildlife Lab oratories at Paturent ^.Maryland were visited. In the six to twelve months that the laboratory had been looking for PCB residues, they had Identified such compounds In dead eagles as well as marine birds. At that time they did not report positive findings in fish, shell fiBh or other marine organisms. We know that their efforts have been continuing at an accelerated rate but the labor atory has not been revisited to learn of current developments. The U. S. Food and Drug Administration in Washington called Dr. Kelly In June to report that the State of Oeorgia had found PCB'a in milk (we had in April supplied samples of our Aroclors to the Oeorgia State Department of Agriculture Laboratories in Atlanta). The analyses of milk from the Maryland co-op mentioned in 1. above were performed by an FDA laboratory. ' On- Friday, September 26, we were asked to send samples to the Atlanta Toxicological Branch of the FDA and to the Residue Chemical Branch Divi sion of Pesticides, FDA In Washington, The stated reason for the request was for these laboratories to determine the ''acute toxicity" of Aroclors 125*1 and 1260. In the past year we have had request for samples from five or six of the regional laboratories of the Federal Water Pollution Control Admlnlstration-an agency within the U. 3. Department of Interior. We have not had an opportunity to follow-up with these laboratories as to their interest or concern. In August a laboratory of the Bureau of Commercial Fisheries, Department of Interior, at Pensacola, Florida, reported finding PCB's in the river below our Pensacola Plant. Subsequently, they reported that 5 parts per billion of Aroclor 125*1 killed baby shrimp in 18 days. There has been no follow up by St. Louis based personnel since our Pensacola Plant discontinued the uee of Pydraul AC. . MQNS 036728 TOWOLDMONOQ47679 BASIS FOR RECOMMENDATIONS (Continued) Appropriate individuals in the parent "federal agencies should be visited to determine their current activities and concern and, secondly to make these agencies aware of Monsanto's interest, research and control efforts. 3* Contact with other Governmental and University Laboratories In addition to the above, Monsanto has provided earn pies of the Aroclors to 30 or *J0 other governmental and university laboratories or scientists. It would be prudent and appropriate for someone from Monsanto to personally follow-up the supplying of the samples and determine the status of the efforts of these groups. For example, the State Department of Agriculture Laboratory in Hartford, Connecticut reported in July that they had found PCB in fish off the coast of Connecticut. This led to two articles in the Hartford Times and a five minute radio program through a syndicated outlet of 108 radio stations. k. Losses from Monsanto Plants Efforts to reduce the losses of Aroclors in liquid wastes from the Anniston and WOK Plants are com pleted or underway. It is impossible to establish a limit as to what can be discharged "safely". Investigation has shown that the waters in receiv ing streams below the Anniston Plant contain sig nificant (parts per million) concentrations of PCB. More ominous perhaps is the fact that sedi ment in the bottom of these streams miles below our plants may contain up to 2% Aroclor. To prepare for the eventual publication in the press of the discharge of PCB's in Alabama and to the Mississippi River, a significant effort must be made to determine the present levels of contami nation and more importantly, determine .the .levels jif^ont^lnatlqr^BB "clean up" "procedure sj begin to . show an effectf ' ` *------- ~ " The Incident at the Monsanto Plant at Pensacola indicates that all Monsanto Plants using Aroclors should be made aware of the potential problem and efforts made to eliminate any losses. The sig nificance of "any losses" may be related to the one to three gallons per day which was being lost at the Pensacola Plant. * HOMS 036729 TOWOLDMONOQ47680 I j ( -9- BASIS FOR RECOMMENDATIONS (Continued) Hopefully research efforts will indicate that a safe level' of losses would be higher in fresh water streams not adjacent to coastal estuaries. At the present time we know of no claims that the PCB's are destroying" fish. 5* Atmospheric Losses at Anniston and WOK The determination of atmospheric losses for our Aroclor manufacturing plants will be more tedious and time consuming than in the case of liquid wastes. We will never be prepared to discuss Intelligently potential problems of our customers where there may be atmospheric losses until we have some data on our-own plants. This is parti cularly true if we ever expect to recommend to our customers measures for control of atmospheric losses. - 6. Analytical Capabilities (a. through e. inclusive) In each of the recommendations 2. through 5* above# there is the implication that Monsanto's best inter est could be served by appropriate sampling and analysis. In connection with any of the governmental and other laboratories, we must accept their reported analytical results or in specific Instances offer to run duplicate analyses to confirm for ourselves the validity of the reported results. The oommlttee agrees tha.t to perform analyses that *ould confirm~~all ~~5f the reported findings repre sents an unreasonable cost in terms of personnel and facilities. At the same time there appears to be no alternative to the acceptance in the last three months that confirmation analysis in selected cases should be done. This has led to an accumulation of a backlog of samples which need attention. Delays In analysis are occurring because of shifting pri orities for samples as they are received or as they have been retained. . A case in point is the delay in analyzing thirteen samples from the Inorganic Division. Samples were submitted following the finding that five of five ' commercially available electric dishwashing com pounds analyzed showed the presence of PCB's. The Inorganic Division can not exonerate the products it sells to the detergent manufacturers until it has some data showing whether or not Monsanto supplied materials sre contaminated. In the mean time Inorganic Division Quality Control has HONS 036730. TOWOLDMONOQ47681 -10- BASI8 FOR RECOMMENDATIONS (Continued) suggested to Its Division Engineering that future designs for making detergent components Insure that the use of Aroclors will not permit contamination. Secondly, It Is obvious that the Division cannot approach Its detergent manufacturing customers about their potential problem until the above data Indicate that "our own skirts are clean". This week It was agreed that milk and water samples from the Maryland co-op in Baltimore should take precedence over other samples which had been scheduled. In summary, the committee believes there will be a growing number of samples from the following* a. Environment of Anniston and WOK Plants. b. Monsanto products where contamination la possible. c. Agencies and/or laboratories attempting to pin-point specific sources of contam ination. d. Customer plants' environment. e. Research efforts Involved In biological studles--i.e. animal, bird and fish tox icity studies and biodegradation studies. 7. Expansion of Analytical Capabilities The recommendation to expand the analytical capa bilities is a necessity In view of the preceding recommendations. 8. Assignment of Pull-Time Effort Up to this time the coordination of the Division effort has been principally the reB~ponsibillty of W. R. Riohard and E. P. Wheeler with support from R. B. Keller and Cumming Paton. Each of these Individuals has other responsibilities to the extent that, although the Aroclor problem may have been a predominant Issue, other areas of interest could not be slighted. The committee believes that the problem ie of sufficient seriousness to warrant the full concen tration of at least one Individual for the next three to six months. Those who have been involved up to this point would -obviously continue in their HONS 036731 TOWOLDMONOQ47682 -11- BA5I5 FOR HBCOMMEWDATION (Continued) supporting efforts where the Individual's background or expertise would make It appropriate. For example in connection with the follow-up with the federal agencies in Washington, Dr. Kelly would expect to be present for any contact with USFDA officials. Other members of the Medical Department would be made available for contacts with the pollution control agencies or those laboratories or univer sities where toxicity appears to be of interest or concern. Certainly Dr. Keller and Scott Tucker should accompany anyone making visits where the specific question of analytical techniques was to be discussed. This still leaves a number of man months to be de voted to the other laboratories or agencies which have up to this point not made their specific interest known. Equally if not more important is the effort which must be made relating to the contacts with custo mers. The committee does not believe that this can be handled by district marketing representatives without supplying such "local" individuals with a complete background of the problem. 9. Budgetary Considerations The committee recognises the restrictions placed on those currently involved by mandates to operate within normal or proposed reduced budgets. It should be clear, however, that the product groups, the Division and the Corporation are faced with an extraordinary situation. There can not be too much emphasis given to the threat of curtailment or outright discontinuance of the manufacture and ales of this very profitable series of compounds. If the products, the Division and the Corporation are to be adequately protected, adequate funding - is necessary. HONS 036732