Document KJ0pGGBQKyB567Z9Y6Nr8n8G2

AT7 A PCB PREPAREDNESS Q&A - RE EPA TRESS CONFERENCE - 12/22/75 Ql. What is Monsanto's reaction to the statements made by EPA at the press conference? Al. The conference contained no surprises and no new information other than EPA'8 plan to invite interested parties to a meeting in Washington in mid-January. The information presented was basically a summary of that presented in November at the PCB Symposium in Chicago. I Q2. Will Monsanto attend the meeting and do you plan to cooperate ' with EPA? A2. Yes. We will attend the meeting and we Intend to continue our policy of cooperation with the EPA, other government agencies .......... and Industry in our Joint search for an acceptable solution to the problem. Q3. Is Monsanto doing any research on non-PCB alternates and, if so, what is the current status of these programs? A3. Yes. Monsanto has had research programs on-going for several years. These programs were Intensified at about the time we began withdrawing from open system applications. To date we have spent millions of dollars in our search for alternate products that would be, in themselves, more environmentally compatible than PCBs and significant progress has been made. -more- MOHS 051291 T? --2 fcjpcapapltor Industry has been evaluating hon-PCB capacitor $l*le&trfc candidate 'for"some `time and, subject to final ft|j^ery acceptance, Monaapto could begin supplying the new fcluld in quantities Sufficient to meet the entire U.S.'Industry's {fM& ' jijr'Ut# " s ......... ' . Development work on new, non-PCB, transformer dielectric fluids is also being aggressively pursued. Several promising candidates have been identified and are presently being readied for further evaluation by the transformer industry. Q4. Assuming acceptable replacement dielectric fluids become available from some source, be it Monsanto, Dow or whomever, would Monsanto then voluntarily phase out its PCB production in the absence of any federal mandate? A4. Of course! When we made the conscious decision back in 1970 to begin restricting sales to closed-system dielectric uses, the main reason we elected to continue supplying the electric Industry was that they had no viable alternates to turn to. *r EPA recognizes thlq, even today. At the press conference, Mr, Train said he would not ask Monsanto to stop production because that would shut down the electrical power Industry and the railroads in short order. He said we must find a way to proceed without shutlng down the country. This is precisely the position to which Monsanto has been committed since 1970. -more- MONS 051292 Monsanto has every Intention of eventually phasing out Its PCB production (In a planned and orderly manner) as soon as we are satisfied that the electrical power Industry's needs for usable, viable alternates have been met. In the Interim, we will continue to work with Industry and government to ensure that the restricted measures and controls we voluntarily implemented in the early 1970s remain In force and are diligently pursued. Mr. Train's objectives are aimed at the same results. , Q5. According to EFA, Monsanto makes about 40 million pounds of FCBs per year at Its Sauget, Illinois Plant. What does Monsanto know about the effects this large volume has had on.Its plant workers and the nearby residents? Surely they must be Inhaling vapors and being contaminated In other ways. What assurances can you give that this won't become another asbestos, VCM or Kepone situation? How many people are employed In the PCB production/incineration units? . A5. PCBs are considered by our 19 pr' oduction people and five Incinerator operators to be a normal Industrial chemical as contrasted to many which are actively toxic. We provide the same safeguards and monitoring program for PCBs as we do for other Industrial chemicals. Exposure to the material and Its vapors is very limited, protective clothing and related safety equipment Is not only provided but required. -more- MONS 051293 rr Proper ventilation Is also provided and standard Industrial hyglcm practices are vigorously followed. We perform routine maintenance and safety inspections on all the manufacturing equipment and we continually monitor and sample the workers environment. Each plant employe undergoes a thorough, mandatory physical examlnatloi every year. Several months ago a group from the National t' Institute of Occupational Safety and Health (NIOSH) visited the Krummrich plant and concluded that employe exposure to PCBs In our operation was too low to be of concern. NOTE - Any additional questions on this subject or on the subject of animal testing should be referred to Or. G. Roush, Monsanto's Medical Director. The EPA said that from two to five pounds of PCBs per day are discharged Into the sauget waste treatment plant from Monsanto's production facilities. Is this true? And what has Monsanto done to minimize Its discharges? No. Our curpant measurable losses to the environment^ are less, than 0.Qtfl per (cent of total plodiiction (less than y pound p^ dayV/fcnd no level hhs been^aetectad in the agfbient rflng sampling tn^d analytical techfl^queg/currently/avail Since 1969, we have Invested more than 30 man years of work and millions of dollars in this program. . In our manufacturing area, we have taken a number of significant steps to prevent loss of.PCBs to the environment. In essence, we have made the department a "concrete bathtub." Drainage is -more- HONS 051299 directed to trenches end piping, and then to one of two 3,000gallon settling basins. This Insures PCB containment in case of accidental spill or equipment failure. We have also installed an incinerator to safely dispose of PCBs. This Is accomplished through incineration at or above 2000 +F. Use of he incinerator and other technical assistance is avallabl to our customers on a continuing basis. When small quantities of PCBs are collected into the settling basins in the manufacturing area they are later pumped into drums, and eventually incinerated. In the incinerator area itself, drainage is directed to trenches and piping which flow into a 10,000-gallon basin. Recovered PCBs are periodically pumped to storage, or incinerated. In the manufacturing area, we have also rerouted relief valve lines and atmospheric vents through catch tanks, or redirected them to settling basins. We also provide nitrogen blanketing on storage tanks to eliminate any "breathing" of the tanks and resultant PCB escape. We have Installed mist eliminators in vapor lines - once again to eliminate the possibility of PCBs leaving the manufacturing area through these lines. Finally, we have replaced underground sewers with above-ground sewers, apd repaired or combined others, so that we can monitor .-more- NONS 051295 the effluent from the department. In addition, this will prevent any unknown buildup of PCBs In our sewer systems or any contamination of PCBs Into other sewers. Much of the success of our efforts also depends on maintaining a high housekeeping level In the department Itself. Among the housekeeping responsibilities our operators have assumed are these: --All pumps are checked for leakage on every shift. Drip pans that collect leaks are emptied Into scrap PCB drums. --All leaks are reported and documented so that corrections can be made and settling basins observed. --"Floor Dry" Is used to absorb any PCBs that have spilled or leaked. If It becomes necessary to flush PCBs to the settling basin, a minimum amount of water Is used. --Sampling drums and scrap-PCB drums are quickly palletized, labeled and transferred to the incineration area. Through these kinds of programs, we feel we have literally built a "concrete bathtub" to catch and safely dispose of PCBs at our manufacturing location. - Q7. Could you describe disposal policies regarding spent PCBs? -more- HQKS 0SU6 --7 A7. Guidelines for handling and disposal of capacitor and transformer grade PCBs were prepared In 1972 and have been approved by the American National Standards Institute. These guidelines are Intended to restrict the release of PCBs into the environment. They provide standards for incineration as well as for disposal by other, than burning. Incineration facilities must meet the applicable requirements of the state In which they are located. In addition, certain landfill sites have been classified by state governments and the federal government-as suitable for the disposal of toxic and hazardous liquids. Where these "environmental" landfills exist, they may be used for the disposal of liquid PCB wastes. ' . Q8. How are requests for incineration fondled by Monsanto? A8. Arrangements for all return shipments of PCB containing material to Monsanto are handled Individually. Instructions are forwarded for each consignment to customers to ensure that they are aware of any changes In procedure. Monsanto supplies pre-addressed drum return labels marked "Disposal Only." All drums used must meet DOT 17E specifications as to construction. Monsanto supplies an Identification number for each shipment to be placed on the bill of lading and on each drum. Incineration charges are currently 8c/lb. with an $8.00 per drum handling charge for each drum returned. It should be pointed out Chat these charges do not begin to cover the cost -more- MONS 051297 --8 of maintaining and operating this service. Monsanto does not accept solids such as sawdust, rags or sludge. These items can not be handled in the incinerator. A letter is provided by Monsanto to be attached to the driver's copy of the bill of lading. The subject of the letter is to be brought to the driver's attention. Included are instructions to the driver to prevent Introduction of the liquid into the environment. Included in the letter are phone numbers of Monsanto Company officials and the shipper. ' Q9. Could Monsanto reach the "zero" discharge level being proposed by EPA? A9. No. "Zero" discharge at a facility producing some AO million pounds per year would be technically impossible. However, Mr. Train pointed out at his press conference that the quantities being found in the environment are not coming from our Sauget Plant, but rather from the shipments made to Monsanto's customers. ' Q10. In addition to Monsanto's own incineration service, are there other locations where PCBs can be disposed of properly? A10. Disposal service companies, meeting American National Standard Guidelines relating to the disposal of PCB containing materials, are located in at least nine states and include both incineration services and environmental landfills. States where these facilitic -more- HONS 091298 -9 are located Include the following: California, Delaware, Illinois, Kentucky, Louisiana, Hew York, Hew Jersey, Texas and Washington. Qll. Mr. Train indicated that Japan had banned PCBs and that EPA will conduct a thorough review of the Japanese experience. /' If a highly Industrial nation like Japan, with widely acknowledged electronic technology can get along without PCBs, why can't the u.S. electrical power industry? All. Monsanto and the U.S. electrical industry are, often asked this question'. In the first place, it should be pointed out that the major uses for PCBs in Japan were not electrical but rather "open applications," particularly for carbonless paper. The Japanese power distribution industry, less advanced than the U.S. technically, had never actually gotten around to taking advantage of fire resistant transformers to the extent they have been used In this country. Most of their transformers were either using mineral oil or were dry-type units. The Japanese capacitor Industry on the other hand was only In the beginning stage of converting its equipment to the more reliable PCB dielectrics when the ban was announced. Reliability standards for capacitors In the U.S. are much more stringent than they are In Japan or anywhere else In the world. So the Japanese bah really did not materially Impact that country's electrical power distribution industry. HONS 051299 -more- --H) Q12. Mr. Train has repeatedly said he will never be able to control PCBs effectively without Toxic Substance Control Legislation. What is Monsanto's reaction to this? A12. We don't really understand his reasoning here. He has said he would not ask Monsanto to stop production because it would shut down the country. We assume this statement would apply equally with or without a new Toxic Substance Law. If he had Imports (which we understand are being used in "open applications") in mind, which according to figures released by Rep. Les Aspln (D-Wis.) earlier this month, are projected to b as high as 385,000 pounds this year -- up 40 per cent since 1972, Monsanto feels he has. all the authority he needs under section 504 of the Federal Water Pollution Control Act. Q13. What is Monsanto's position regarding Toxic Substance Control Legislation? A13. Monsanto Company's corporate policy supports government actions whenever such actions are clearly in the.publie's best interest and are needed to protect human health and the environment. We- recognise that there are certain gaps in existing regulatory controls, and that safeguards may be needed to fill those gaps. Consequently, we do not oppose enactment of reasonable leglslatic that would provide for the testing and regulation of chemical substances which present unreasonable risks. At the same time, we object emphatically to any prospective legislation that would Impose broad, sweeping controls that overlap and duplicate | existing laws. -o0o_ = MONS 051300