Document ExK8Lorj8awBqKzObjV1n2Rj4

Polychlorinated Biphenyl (PCB) f . kl. A PRESENTATION TO THE EFFLUENT STANDARDS AND WATER QUALITY INFORMATION - - A Q YiS 9RY COMMITTEE BY MONSANTO INDUSTRIAL CHEMICALS COMPANY NOVEMBER 29. 1973 N PC00016 2 44 207930 I certainly appreciate the opportunity to participate in this m eeting of the Effluent S tandards and W a te r Quality In fo rm a tio n A d v i s o r y C o m m i t t e e . My n a m e is B ill P a p a g e o r g e . I a m M a n a g e r , P ro d u ct Acceptability, for the Functional P ro d u ct G roups of M onsanto Industrial Chemicals Company. In this presentation, I would like to consider several questions about polychlorinated biphenyl (PCB). Why was it developed and produced? What has industry done to keep it out of the environm ent ? What has M onsanto done to contain the product through im proved manufacturing p ro ced u res? What are the problem s involved in sampling and analyzing PCB' in manufacturing effluents? And finally, is PCB biodegradable? I would also like to present some com m ents on the so-called Toxic Pollutant List. And finally, I would like to s u m m a riz e the points I ' m trying to make. Polychlorinated Biphenyl (PCB) e WHY WAS PCB DEVELOPED AND PRODUCED? The c h e m ic a l s tru c tu re of PCB has been known for n ea rly 100 y ea rs. It was not until the late 1920's that a use for PCB was found - as a dielectric fluid in tra n s fo rm e rs and capacitors. Its properties (stability, fire -re sistan c e, high dielectric strength and conductivity) seem ed perfectly suited to these electrical applications, where high-voltage arcing, serious fires, and damage to property and people could result. Monsanto began co m m ercial production of PCB in 1929. Other u s e s soon d ev e lo p e d : in h e a t - t r a n s f e r fluids (b e cau se of its f i r e resistan c e), in lu b rican ts (because of its stability), and for w a t e r proofing. As long as proper industrial hygiene practices w ere followed, the m a n u fa c tu re of this p roduc t r e p r e s e n t e d no safety or handling problems for employes. WHAT HAS INDUSTRY DONE TO KEEP PCB OUT OF THE ENVIRONMENT? - In-the-late 1960's, sophisticated anj^^yjitai procedures, were developed which could detect very m inute quantities of PCB in nature, Following this b r e a k t h r o u g h , r e s e a r c h e r s d i s c o v e r e d that P C B coulc^ possibly be affecting c e rtain fo rm s of wildlife. ~- NPC00016245 a*; r- . T O , " . A* 207931 4 2- - As m o re data w ere developed, M onsanto voluntarily undertook a two-phased p r o g r a m to keep the product out of the env iro n m e n t. FIRST WE LIMITED SALES F i r s t : we limited sales of PCB for use in many, m any applications w here there was any danger of it getting into the environment. Today, PCB manufactured by Monsanto Company is sold only to the electrical industry, w here it is used in closed sy stem s as a dielectric fluid in t r a n s f o r m e r s and capacitors - applications w h e re th e re a r e no known s u b s titu te s of a c c e p t a b l e quality antf none that are fire resistant. In addition, re p re se n ta tiv e s of the t r a n s f o r m e r and capacitor industries, utilities, and governmental agencies (under the initial a u s p ic e s of the National E l e c t r i c a l M a n u f a c t u r e r s A s s o c ia tio n ) f o r m e d the A m erican National Standards Institute Com m ittee C-107. This committee issued guidelines (which have already been supplied to the com m ittee) for handling and disposing of dielectric fluids. They reflect the in d u s try 's understanding of the need for p ro p e r contro^. SECONDLY: WE DEVELOPED AN AGGRESSIVE CONTROL PROGRAM A T OUR MANUFACTURING LOCATION. Secondly: since 1969, we have in v e s t e d m o r e than 22 m a n y e a rs of w ork and m illions of d o lla rs in this p r o g r a m . Since we a r e quite proud of our re su lts, let m e take a few m inutes to s u m m a r i s e it: - - In our m anufacturing a r e a , we have taken a n um ber of significant steps to contain P C B 's . In e s s e n c e , we have m ad e the departm ent a "concrete bathtub". D rainage is directed to trenches and pi p in g, a n d t h e n t o one of t wo 3, 0 0 0 - g a l l o n s e t t l i n g b a s i n s . T h i s i n s u re s PCB co n tain m en t in c a s e of a c c id e n ta l spill o r equipm ent failure. We ha v e a l s o in s t a l le d an i n c i n e r a t o r to saf ely d i s p o s e of P C B ' s . This is accom plished through incineration at or above 2000 +F. When s m a l l q u a n titie s of P C B 's a r c c o llec te d into the settling basins in the m anufacturing a re a they a r e later pumped into d ru m s , and eventually incinerated. In the in cin erato r a re a itself, drainage is directed to trenches and piping which flow into a 10,000-gallon basin. Recovered PCB's are periodically pumped to storage, or incinerated. In the ana ouia.ctuxing.area, we have a l so 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 P C B ' s w i l l n o t g e t i nt o t he e n v i r o n m e n t , b u t w i l l be c o n t a i n e t L i n a* - -- controlled area. NpC00016246 207932 -3- We a lto provide nitrogen blanketing on storage tanks to e lim in a te any ,Tb rea th in g " of the tanks and r e s u lta n t P C B e s c a p e . We have installed m ist elim in ators in vapor lin es - once again to elim in ate the p o ssib ility of PC B 'e leavin g the m anufacturing a rea through th ese lin e s. F in ally, we have replaced underground sew ers with ab ove ground sew e rs, and repaired or com bined oth ers, so that w e can m onitor the efflu en t fro m the d ep artm en t. In ad d ition , th is w ill prevent any unknown buildup of P C B 's in our sew er sy stem s or any contam ination of PC B 's into other se w e r s. Much of the su cce ss of our efforts a lso depends on m aintaining a high housekeep in g le v e l in the departm ent its e lf. Am ong the h o u se keeping re sp o n sib ilities our op erators have assu m ed are th ese: --A ll pumps are checked for leakage on every shift. D rip pans that co llec t leak s a re em ptied into scrap PCB d ru m s. . --A ll leak s a re reported and docum ented so that co r rec tio n s can be m ade and settling b asin s ob served. - -" F lo o r D r y " is u sed to absorb any liquid P C B 's that h ave sp illed or leak ed . If it b eco m es n ece ssa ry to flush P C B 's to the settling b asin , a m inim um amount of w ater is used. --S am p lin g drum s and scra p -P C B drum s a re quickly p a lle tized , labeled, and tra n sferred to the incineration a rea . T hrough th ese kinds of p ro g ra m s, w e fe e l w e have lite r a lly built a "concrete bathtub" to catch and sa fely d isp o se of P C B 's at our m anufacturing location . --W e have also developed sophisticated sy stem s to m onitor our effluent. M onitoring effluent stream s for PC B 's is not an easy effort. M easurem ent can b e changed d ram atically by taking the sam p le at d ifferent p la c es along the sew er m ain, by changing the le v e l at w hich the sam ple is taken, by changing the speed at w hich the sam p le is . taken, or by varying the velocity of the effluent. But we have purchased the b est a vailab le laboratory equipm ent, w hich en ab les u s to determ ine PCB content in the p aT ts-p er-b illion range. H ere again, however, many factors affect our findings. D r. Scott T ucker, our analytical exp ert, ad v ises that the m inim um detection le v e l of PC B 's on a routine b a sis contairiecf'ih d istille d water"** one part p e r b illio n (+ 25%). If "d irty" w a te r - i . e . , th at con tain in g o th er m a t e r ia ls w h ich - *V*, t*,+-JvYV ; * **:^* 'V-*, NPC0001624 207933 -4in terfe re with the determ ination of PCB - i analyzed, the m in im u m d e t e c t i o n l e v e l i s 100 ppb +^25%. M o n i t o r i n g i s a v e r y t r i c k y b u s i n e s s . But we feel with our experience and acquired "know-how", w e 're doing t h e b e s t p o s s i b l e j o b . And we do t h i s j o b 24 h o u r s a d a y , 365 day>s a year. We have a l s o e s ta b lis h e d loading and shipping s a f e g u a r d s to minimize accidental PCB loss during transportation. Specific written instructions a re on every container we ship. -And finally, we have provided facilities for safely opposing of used PCB's returned from cu sto m ers. As 1 mentioned above, we installed a specially designed PCB in c in e r a to r, at a c o st of $790, 000. We have re ceiv ed an operating p e r m i t f r o m the Illinois E P A for this incinerator, which meets all EPA requirem ents. This incinerator completely destroys PCB's received either from our manufacturing area or from customers. Finally, we have moved toward the m anufacture of a m ore biodegradable polychlorinated biphenyl. In 1971, we installed a new distillation colum n in our m anufacturing d e p a rtm e n t at 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 P C B 's a r e known by the tr a d e nam e A r o c lo r . We m anufacture different grades of A ro c lo r (1016, 1242, 1254, for example). The lower the grade number, 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. NPC00016248 207934 AROCLOR PRODUCTION AT THE Wm. G. KRUMMRICH PLANT KEY A r o c l o r 1016 1242 1248 5o0o0c 5O0O0C oooooc 5o0o0c t More b io d e g r a d a b le 1254 1260 1262 }m IL esa b io d e g r a d a b le POUNDS 50 40 .. 1232 .o*O2^o20o02ooFc 30 .. 20 .. *o2o02oo2Sr ,oXOoOXoo0EOoogOoc00 Oo Oq Oq G PXoOg0egOo gOoC 0So0o s|islg 10 .. jr i r i T 1969 ss22g2oooooo5Sox222-222|&oSooooo0oo0o2oorXSrXXXooo0oo0ooo0oooo0o0oX2Xr2x22" oooooooooo 223o22oSox|S2S os 22222o2 S l S 22SS2222OooooooX2oo252E2,,22ooooooo200So"Xo0Xoroooso00og0ro22fooso g,XXoo ofogox A*y 1970 v. *.vI 1971 OogooOg0ooOgooO Ili! i j feSafeft II: i a %a a l 1972 os2|isos2ligso|i2so oo2oo2oo2o0 o2o22 ooo22oo22ooo2ooo0 W eM 1973 (P rojected) -v "7-T'>V'.'T NPC00016249 207935 t - 6- So I think we can safely a s s e r t that in d u s tr y and M on san to have taken strong m e a s u re s to contain P C B 'i and keep them out of the environment. IS PCB BIODEGRADABLE? I mentioned before that we are presently manufacturing m o re b io d e g ra d a b le P C B 's . We feel all in fo rm a tio n points out - beyond any r e a s o n a b l e d o u b t - t h a t m a n y P C B i s o m e r s dho d e g r a d e , a n d t h e y do degrade at different ra te s. Under p ro p e r conditions of ufS and control, PCB's can be utilised without serious adverse consequences .to the environment. To support this view, we have previously sent the reports of Monsanto studies which w e re subm itted to the F e d e r a l I n t e r d e p a r t m ental Task F o rc e on P C B 's . A rticle s desc rib in g the r e s u lt s of biodegradation studies in activated sludges a r e also being p re p are d , and we will send copies when they a re completed. The Toxic Pollutant list > Neither M r. H osm er nor m yself a re toxicologists. We a re chemical engineers. But we would like to m ake som e com m ents on the toxic p o l l u t a n t l i s t . In S e c t i o n 502 (1 3) of t h e c u r r e n t F e d e r a l W a t e r Pollution Control Act, the term "toxic pollutant" is defined as "those pollutants or com binations of pollutants including d is e a s e causing agents, which after discharge or upon exposure, ingestion, inhalation or assimilation into any organism, either directly from the environment or indirectly by ingestion through food chains will, on the b a s is of information available to the A dm inistrator, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such organism s or their offspring. " We have a ls o r e a d the F e d e r a l R e g i s t e r , V olum e 38, No. 173, dated S e p t e m b e r 7, 1973. P a r t 129 (beginning on page 24343) i s concerned with the Toxic Pollutant Effluent Standards. We a r e con c ern e d with the " c a tc h - a ll" n atu re of th ese definitions and crite ria. Depending on how they a r e defined and applied, the toxic pollutant list could conceivably cover all chemicals and many, many other m aterials which are relatively innocuous in their i m p a c t on t h e e n v i r o n m e n t . ................... NPC00016250 207936 -7 We c o n c u r with the re cen t su g g estio n of the E P A 'a Acting A d m i n i s tr a t o r (F e d e ra l R e g is te r Volume 38, No. 129, page 18044) that Congresa intended the A d m in istrato r under the Act ". . . to be s e l e c t iv e in d e t e r m in i n g which of the p o tentially l a r g e n u m b e r 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 d e g r e e of toxicity of the su b stan ce ; w h e th e r o r not the substance poses a threat to man, anim als, birds, the aquatie environment or som e other aspect of the ecosystem . W h e t h e r o r not P C B ' s r e m a i n on t h e " e n e m y l i s t " , it H o u r r e c o m m e n d a tio n that an effluent lim it no m o r e s trin g e n t than one pound of PCB p e r 100, 000 pounds of p ro d u c tio n be e s ta b l i s h e d for our manufacturing operation. To keep this in p erspective, this would correspond to a concentration in the M ississippi River of 1.4 p arts p e r trillion, based on that r i v e r 's av erag e flow. We believe this c o n c e n tra tio n would have no a d v e r s e effect on the aq u a tic en v iro n m e n t. In Summary f F irst; Monsanto began producing PCB to fill a m ark e t need. The product has excellent qualities to fill these needs. When the " alarm bell" sounded in the late '60's, Monsanto and the concerned in d u stries took positive steps to keep PCB out of the environment. At our manufacturing location, we developed a manysided p ro g r a m to contain PCB, and keep any of the product fro m the environm ent. B ecause of this, levels of PCB in the aquatic e n v iro n ment a re re p o rted to be lower now than before. We feel that som e P C B 's a r e b io d e g ra d a b le , and we a r e d ev e lo p ing supporting evidence. Secondly; We a r e concerned that the c r ite r ia for the Toxic Pollutant List are too general and susceptible to "fishing expeditions". (Excuse the pun.) W hether PCB should be on that list at all is questionable. F in a lly ; We r e c o m m e n d that a lim it no m o r e s t r i n g e n t than one pound of P C B ' s p e r 100,000 pounds of p r o d u c tio n be e s t a b l i s h e d for our manufacturing location. This corresponds to 1.4 parts per trillion in the M ississippi River. NPC00016251 * 11 907937