Document Edkm24ZvdJeLEXQdQ1xYoQ5j0

PCB ENVIR OKMEHTA L POLLUTION ABATEMENT PUN Introduction On 15 October the nAD HOC" Committee consisting of Messrs. M. Farr&r, P, Hodges, E. John, W. Richard/ and E, Wheeler issued a report summarizing the polychlorinated biphenyl (PCB) pollution problems from the known available Information to data. Out of this report came considerable Information, conclusions, and recommendations which we have attempted to tie together into a plan of action in this document, our objective haB been to take a reasonable and responsible approach to the entire problem. Before we get into the problem, we should clarify the meaning of PCB, the nature of the entire line, and how these tie into our product line of Aroclors. .. . R R R R 9 R R R .R H R I HONS 035371 TOWOLDMONOQ46195 2 Monsanto entered the Aroclor market in 1930 by acquiring Swadln iHec-tri-cal Company or known today aa our Anniston/ Alabama plant. The first load of Aroclor which incidentally was Aroclor 1254 -- went out of Anniston., Alabama to GE in 1931; Sinoe that time the market has grown to 170 to 2007T*worldwide* Chemical' Biphenyl Monsanto Product Line Nature of Material at Ambient Solid *at ^Suhnraas--at-* Monoahlorobipheny1 ` rCl "CricKlorobiphenyl Qu^iterchloroblphenyl 200" ?enta chiorobiphany1 Cfr'^yr r'vN'C| Hex&ghloroblphenyl Ch Heptaehloro'biphenyl e ct Do ^c^li2ripblD?i|py 1 ch\ )`e< I>ocachToro35rphenyl J} Jt Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 _ Aroclor 1260 Aroclor 1252 Aroclor 1268 Aroclor 12715 thin liquid (oil) thin flush water oily type fluid material Thicker - transmission oil Heavy-Molasses Thick - tar Vary thick - liquid Solid Solid HOWS 035373 TOWOLDMONOQ46196 - 3.Total possibility are 210 theoretically possible chlorinated biphenyl S' Santowax or terphenyl Solid Arcelor 5^60 Solid rW f CW/ W III. Damage to the ecological system by contamination from polychlorinated biphenyl (PCB) Extensiveness The problem involves the entire United States, Canada, and sections of Europe especially the United Kingdom and Sweden. As the Investigation broadens other areas of Europe* Asia and Latin America will surely become involved. Evidence of contamination have been shown i$ some of the very remote parts of the world. The involvement oould and most likely will follow the DDT investigations. IV, o^ 0 Mature of the Problem Professors Widmark and Jensen of the Institute of Analytical Chemistry at Stockholm, Sweden, in November 1966, announced and confirmed finding^ PCB in fish, birds, and eggs. Subsequent findings were made in 1967 in Oraat Britain. In February 1969, Professor Risebrough of the University of California published an article in the San Francisco Chronicle relaying his findings of PCB in the environment of the United States. Monsanto confirmed the presence of PCB's in mid~19S9 and confirmed the adequacy of work by Widmark and Jensen and others; truly, the PCB*a ' are a worldwide ecolologlcal problem. HONS 035374 TOWOLDMONOQ46197 ~4- 'Analysis indicates the environmental presence of the 5 and higher chlorinated biphenyls which take the appearance of Aroclor 1254 and Aroclor 1260, We have strong indications that Aroclor 1242 or at least part of it degrades biologically. Since the Aroclor 1242 contains around 7 percent of the 5 chlorine biphenyl or higher we cannot rule out the possibility that the observations may be a concentration affect of the higher chlorinated biphenyls of Aroclor 1242. C4K& Tilt'd /V To date t&We- have beerrno^reports of finding Aroclor 1242 present in the environment (except the effluent of our plants ** AnneJ irr--l'gllQ 4a.-.presea44-; ->%</ htjeti eur 0 /zf^M.4% id- A Hu.j> $*-<*q*^ The seriousness of the problem can best be spelled out as follows: . 1, Pish - Marine or aquatic species concentrate PCB in the fatty .. 0' tissue. Toxic is small quantities (down to 5 pplr) to sensitive marin life suoh as shrimp. 2, Birds - Predatory species feeding on the marine or aquatic life can further concentrate PCB to possible harmful effects. .Specifically in birds PCB can affect the calcium metabolism leading to egg shell imperfections which prevents proper hatch of the young* In fact, Monsanto has confirmed the eggshell by feeding chickens, a high order of the species, PCB's in controlled tests. 3, Man - There is no harmful effect known to man or other mammals after 40 years of production, investigations are underway by various sources. 4. Political and Public Emotion - PCB's are falsely linked with DOT because PCB'b show up in the analysis for DDT. PCB's are linked with Other permanent type chlorinated hydrocarbon pesticides. This becomes particularly serious since about every article of food in the country is being examined for a trace of these materials. IVUnt C/J S1 . , ^ v 1 jJ'j.jt1 CATv-p..,r--(' - MONS 035375 TOWOLDMONOQ46198 -5- V. Effect on Monsanto Business potential at stake on a worldwide basis: FlUlflB Plasticizers Total/Year 70ft lbs. 3 lbs. lOffi lbs. *1SM $6Ff 4^227^ $6-8ft o.p. $2-3ft Q.p. $8-ilft G.P. Already competition is using certain data against us in competitive situations. A. Legal Liability Direct lawsuits are possible. The materials are already present in nature having done their "alleged damage". All customers using these products have not been officially notified about known effects nor do our labels carry this information. These are only a few of the possible legal implications which would best be covered by the legal department. B, Public Image The corporate Image of Monsanto as a responsible member of the business world genuinely concerned with the welfare of our environ ment will be adversely affected with increased publicity. The evidence proving the persistence of these compounds and their universal presence as residues in the environment is beyond Questioning. This combined with certain scare publications 1b certain to give an adverse image. aullty^assoelation [with DDT) will pre vail as the background while actual facts may be spares. ` C. Customer Relations MQNS 035376 Some customers who presently use these materials will be "Beared off" to other competitive products. Products associated with the same name or "trademark" will be adversely affected le,, Thermlnol, - Pydraul and Aroolor. Competitors will use the information for an TOWOLDMONOQ46199 -6 - influence on Monsanto products. Customers seek other "outs'1 rather than become involved. VI. Effect on Customers and Ultimate Consumers One Of the unique features of PCBfs is their fire resistance. Here the basic decision whether to risk lives due to fire or risk extinction of. Boms spades of birds. In this case the PCB would probably be accepted as' a necessary pollutant and tolerated under controller conditions. A, Eleofcrical Industry - Capacitors and Transformers use Aroclor because it is the best inexpensive dielectric fluid available. 3, Pood Processing - Bulk ''deep frying" units for potato chips, fish, and doughnuts use the fire resistance fluid as an indirect heating medium. G. Die Caater -*> and other hot metal working industries fire resistance fluids to protect the worker? i Affects a wide^rang* of plasticB and adhesives because the PCB serves as the 'plasticizer. A wide range of paints and coatings are affected. The "Carbonless" carbon paper used so widely would disappear* . VII, Involvement With Other producers Although Monsanto is most probably responsible for the U.S. contamination and jointly responsible with MCL for the United Kingdom problem, we cannot accept responsibility for the world. There are fiva known . producers in the free world, several possible producers behind the Iron curtain and couple of additional companies making overtures about entering the business. Monsanto representatives have on one occasion discussed this problem with a couple of these producers but they expressed no great concern, in fact, it is highly possible that one of HUNS 035377 ) TOWOLDMON0046200 those manufacturers is dumping his -waste into the Rhine River, Certainly any action taken by one producer will moat assuredly affect the other. It is entirely possible that a joint plan of action could be developed but will moat probably have to be spearheaded by Monsanto, It la also likely that producers of other chlorinated products used with PCR's will be dragged into the investigation. VIII, Souroes of Contamination Although there may be some soil and air contamination involved, by- far the moat oritical problem at present is water contamination. To our knowledge to date tho contamination can be broken down into two general categories, open and indirect pollution. A. Open Pollution - Our manufacturing facilities sewered a sizeable quantity of PCB's in a years time. . 1. Fluids ' Fluids are probably the most open source of pollution because of their mobility. They also may be the least serious because they are generally the lower "chlorinated materials. 2. Electrical Electrical customers have in the past sewered their wastes, .3* Heat Transfer . Heat transfer customers have sewered their objectionable and their spilled material. 4. Industrial These fluids have generally been sprayed into drains, washed down sewers and generally regarded as very harmless. All of the fluids have had the '`Mirk" constituent dumped on dirt roads as a "dedusting agent" which inadvertently found its way back to the stream. HUNS 035378 TOWOLDMON0046201 8- * 5. PlaBtics The plastics are not as mobile as the fluids bo therefore they have not found and cannet find their way back to streams in open r pollution, . B, Indirect Shipping containers and the cleaning thereof for subsequent use a source of contamination^- ' 1. Fluids a. Electrical - Disposal of "burned out(l transformer and oapacitorB may find its way back to streams. Scrap units (new) are generally disposed of in land fills but could possibly get back to the stream* b. Heat Transfer - Leaks oould contaminate, c. -Industrial - Cross product contamination carried out of an air compressor. Residual material carried on parts. 2. Plasticisers "' a. Process Contamination from Washing (1.) Environment Contamination : Swimming pool paints Incineration of wax coatings . Traffic paints (2,) Product Contamination Coating for tank lining . a * ;ng inks and paper coatings MQN5 0353?9 Certain adhesives IX. Recent Technical Changes Which Have Bearing on the Contamination A, Fluids _ The sources of pollution were pointed out as they have been in the past because we are dealing with that quantity of material in the TOWOLDMONOQ46202 9- - environment today which was deposited over the past forty years, We jatteiiiruBt state that responsible people throughout the industry have taken corrective action to reduce contamination in the last two years. There have also been technical advances which have brought about the use of lower chlorinated biphenyls which may be an advantage because to date the low chlorinated ones have not been identified present in nature. 1. Electrical - The large customers have established collect Bystems and the waste is recovered. Incinerators are being investigated and built for the disposal of the materials. There has bean a shift away from the higher chlorinated types products and could probably shift almost entirely away from those products, 2. Heat Transfer - System have been tightened up and redesigned to confine the contents Here^toy the trend has been to shift away from the higher chlorinated materials, 3. Industrial - Sealing ponds have been built by the large manufacturers to catch the material and decant -off the PCB for reprocessing. The trend here as the other fluid areas has been towards the- lower chlorinated materials. . . 4. Plants - The plants effluent has been passed through limestone which provides surface to catoh some of the material. But high concen trations can be found in our effluent (that 1b relative to those findings in nature causing the problem). B. Plasticizer Quite opposite to fluids the trend in plasticiser Aroclor has been to the higher chlorinated biphenyls. In plasticizers the lower chlorinated biphenyl will not be an acceptable solution however* the lower chlorinate terphenyl^could offer a possible solution. MOhS 0353B0 TOWOLDMONOQ46203 10 - X, 'Courses of Action A. Do Nothing W* cannot deny the findings end the acquisitions by the various agencies. If we took no action we would likely face numerous suits. We would let government tolerances be based on public and political pressure along with any experimental or developed data which they may generate. We would most likely be forced out of this business. Other product areas would be adversely affected-T We would project an image as an irresponsible member of the business world. Project poor customer relations. The only advantage to this technique offers is it reduoes the cost but this too must be weighed against potential loss of business. B. Discontinue Manufacture of All Polychlorinated Biphenyls (pcb) Although we all realize this could be an eventually unfortunately the solution is not this simple^ Assuming we did stop manufacture immediately, the pollutants are present in the environment, the ' ""'liability is present and possibly by the shifting to the lower . chlorinated materials and the recovery techniques the contamination may already be reduced to an acceptable level. Obviously the entire business would be lost without any or very few substitutes to be offered. Other product areas would be affected. Financial loss could be considered- due to raw material contracts, customer contracts, and royalty-- secrecy contracts. Competition -would take advantage on all fronts. We would be admitting guilt by our actions. Loss of capitol investment in the plant, associated utilities, and asso ciated processes. He would possibly gain a little public image on this action. HONS 035381 C. Respond responsibly, admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data is generated to correct the problem. TOWOLDMONOQ46204 - 21 This approach would enable us to phase out the higher chlorinated materials in many applications where they are no longer necessary or really desired.. Wecould maximise the corporate image by publicizing this act. We would reduce a known pollutant. Additionally we could gain precious time needed to develop new -products and investigate further the lower chlorinated materials. As new research data is generated our course may be altered considerably. Certain limited actionB may reduce or limit the problem. HUNS 0353B2 TOWOLDMON0046205 - 12 XI. Recommended Course of Action . ' Based .on the information available today the only recommendation we can I honestly make Is respond responsibly admitting that there is growing evidence of environmental contamination by the higher chlorinated biphenyls and take action as new data Ib generated to oorrect the problem. XII. Implementation of the Recommended Course of Action A. Immediate (By 12-1-69) 1. Set up a task foroe under a project manager or the equivalent responsible for initiating, directing and implementing all action that Monsanto decides to take. This includes sufficient budget necessary to cope with the immediate problems. This task force should include representatives from Medical, Legal, Research . and the two Involved Marketing Groups and public Relations and muBt conduct liaison with MCL and other locations involved In the problem.- .. . 2. Decide on timing and content of any public and/or customer notifi cation of'PC problem. B, Interim (Within 3 months) Fluids Plasticizers 1* Confirm Aroclor 12p4/Aroclor 1. Announce differential between 1260 are found In the envi fluids/plasticizer uses. ronment . . .2 Publicise the difficult anal, 2 Announce safety of other PCB's/ tasks. chlorinated fcerphenyl. . 3, protect other PCB/chl. terph. 3. Educate customers on control of effluent for all products. a. Announce plans to reformulate if4 Initiate program to develop A/ certain Therrolnols and Pydraul ` 1254 & 1260 substitutes ` where oontrol of the product is difficult. HONS 0353S3 TOWOLDMON0046206 13 - 5. Emphasize better control over 5. Investigate with mrEnufacturjif*} other Aroclor 1& 1260 the feasibility'of alternate > uses. products* ' 6. Initiate customer education or St--ftn&dyse--242 need for effluent control of all products. 7. Determine composition of all ' PCB'b. Develop a comprehensive Program C, Short Term (within the next 12 months) 1. Research - Expand program for more meaningful biodegradation Medical studies and confirming analytical results. Expand toxicity studies. Follow developments concerning publicity and those developments covering political Implications of PCB contamination. 2. Marketing - Discontinue or substitute replacement products for those applications of Aroclors 125^ and 1250 where the Aroclor remains mobile* . Work with customers to clean up plants on other Aroclors* Report the habitual violators or "do nothings" to the product group* Reclaim or safely dispose of fluids MOWS 0353U4 Consider renaming products that do not contain PCB, Follow and report market developments such as customer disposal systems. Follow and report any political or public feedback which.may affect the contamination problems and must be coordinated with Medical, Research and Legal. 3* Production - Clean up plants and stop gross contamination* 4. Legal - Define our present position, recommend reasonable action that will not unduely alarm the market but reduce the exposure in terms of liability. Coordinate recommendations with Marketing. TOWOLDMONOQ46207 5* Public Relations - Publicize actions where believed advantageous, Certainly discussions should be held with other producers within same period to determine their planned course of action, if any. Long Range (Tentative Cutline (prom 1 year to 3 years) Realising that the comprehensive program must be outlined the "Long Range Tentative Outline" is meant to serve as a guide: All aspects of thiB program thould^eview'*quarterly by Organic Management. 1, Research-Medical Continue biodegradation studies and analytical support Isomer distribution Toxicity and metabolism studies Water soluble removal Incineration analytical support Confirmation analytical .' Contraot academic research for reference Develop new and improved formulations 2. Manufacturing ' a. Process Research and Development (1.) Identification of typical Aroclor isomers (2*) Develop control for effluent composition (3.) Test substitute formulations, etc. (4.) Develop new processes b. Clean Dp Plants , o. Modify processes to meet market needs . 3 Engineering a. Develop and set up on plant locations incineration systems b. Design new processing equipment as necessary 4, Marketing a. Specify alternates or changes b. Customer liaison MQMS TOWOLDMONOQ46208 15 c. Set reclaim or disposal of fluids . d. Work or name association problems 5. Patent' Investigate trademarks registered Cover with patents any work felt patentable 6. Environmental Control Develop cheap disposal systems for customers a. Incineration or pyrolysis b. Biddegradation unit etc. - c. Consultants in pollution control 7. Legal Investigate and define our position on Royalty secrecy agreements. Contracts - Raw Material and Customer 8. Public Relations Portray to public positive actions at correcting the contamination problem. Release periodical statements covering our position. nn. probability of Success .. E HONS 03t>3S6 TOWOLDMON0046209 16 - v6- XIV. Cost of Program " Neither the programmer the tests have been clearly defined at this time. i Howeverj a cost estimate of $220,,000 for toxicological, work alone has i been presented. Tentative figures indicated under the worst conditions the entire program -could run as high as $2.0-2,5M. At this stag it is very difficult if not impossible to develop a reasonable cost figure but one point is clear it will be larger than the normal research budget can handle. For this reason, assuming the approach is acceptable., we shall be forced to ask for additional appropriations to fund the program. f- ) 3tV, Future , Follow developments on the problem as they unfold. _ Develop an aggressive research program to confirm or deny findings and better understand the problem. Develop oasts for the duplemenfcetfcioh of the Recommended course of action. Develop specific actions with each department involved Submit the actions with costa for approval Develop a timetable to solve the overall problem. Prepare for "precipitioua pullout'* or drastic legislative action although we do not feel this is a likely possibility. HONS 03536? TOWOLDMONOQ46210 ACTION 2 nothing DOLLARS PROFIT AND LIABILITY VS. TIME DISCONTINUE MANUFA CTURB OF PCB DOLLARS RESPONSIBLE IPPOTSH DOLLARS 7o 71 -- 72 73 7? Time HONS 035388 70 71 Time 72 73 7* TOWOLDMONOQ4621 PROFITS * ' PROBABILITY OP SUCCESS * '. ------------------- ,-------------------- V TO 71 ------------ 1---------------------"1--72 73 Tima -------- , ---------- , 1 7^ 75 8 I HONS 035389 TOWOLDMONOQ46212 TOWOLDMONOQ46213 of so cc f ss TOWOLDMONOQ46214 . .............................. XIII* . 'Probability of Success XIV* Cost of Program $220,000 and bio with max* at $20-25$ XV* Future HONS 035392 TOWOLDMONOQ46215