Document NGog4DvKLer07vZdbrbg6R8Oy

On November 17, 1969 we discussed with you the PCB problem and outlined a program for coping with it. At that time the decision was made to develop a plan to phase out the manufacture of Aroclor 1254 and 1260. Since then, as you well know, the pollution hysteria continues to grow and specifically in the area of PCB's, Lfc * the number of laboratories,^governmental and university involved continues to increase as we predicted. At this meeting, I wish to bring you up-to-date on the latest developments, the progress we have made, and the need for modifying our strategy. Since November, the press has been relatively quiet except for the recent flurry following Congressman Ryan's Press Conference. Two publications have appeared which implicate PCB. The January- February, 1970 issue of Environment carried an article by Robert Risebrough and Virginia Brodine. The presence of PCB in samples of human milk is first article. An article by Dr. David Peakall of Cornell University appeared in the April issue of Scientific'American. In this article, the effect of DDT and PCB on egg shell formation and reproduction -1 la described, and emphasizes that problem has been apparent since the Introduction of DDT to the environment. Three newspaper articles were noted, one in the Miami Herald, another in the Tampa.Tribune, and the third in the Ann Arbor News, again ` ................. *~ ' ' ` B on the environment. T1** fr,o|'aLA- MQNS 035405 In March, we held discussions with Dr's. Risebrough and Olcutt at Berkeley, California, They are personally convinced PCB's are harmful and were pleased that Monsanto was concerned and cooperative. * WATER PCB-SD0000027970 : T------ Also In March, we participated with about 50 technical repre sentatives representing State, Federal and Canadian regulatory agencies In an 'objective discussion in Duluth, Minnesota. Analytical techniques, monitoring and toxicity of PCB were dlsoussed. Absolute identification of PCB and its effect on the environment were identified as requiring considerable research. Concern was expressed by many present that some agency such as the FDA would take precipitous action before adequate information oould be gathered which was believed to require at least one year. Monsanto*s presence and offer to cooperate was appreciated. About two weeks ago, we received word from a Dr. Hill, Ohio State Health Department, that his laboratory had found PCB's in milk from an area around Columbus, Ohio. They believed they traced the source of PCB to deteriorating coating applied to silos In 1967. This coating was formulated using Aroclor 1254 and Aroclor 5460. We requested samples which our laboratory could analyze and so far our analytical work has shown chlorinated compounds similar to our Aroclor 1254 in the extract samples. The milk samples were contaminated during shipping and we have requested additional samples. During our discussions with Dr. Hill, we were told that the FDA was considering establishing a PCB limit of 0.2 ppra in food. Subsequent discussions with FDA personnel indicated that the FDA will in a few weeks advise their offices that PCB contents exceeding 0.5 ppm in milk and 5 ppm in food would subject the milk or food to confiscation. HONS 035406 WATER PCB-SD0000027971 1 I In the U.X. we are, of course, also experiencing considerable ' concern. The Ministry of Agriculture, Fisheries and Food has repeatedly requested Monsanto to divulge our customers. From ; the U.S. point of view we were reluctant to divulge this infor a . nation because of.adverse consequences worldwide. From the U.K. I point of view, divulging the customers' name with assurances i. that it would be kept in confidence and any information to be i released would be cleared with both Monsanto and the customer i j is considered the wiser approach. We are receiving permission I i fromJCR^ divulge their name and will approach the Ministry ! on a^basls. In Europe, we have assumed worldwide leadership and contacted the representatives of the European producers. Initially, their response was indifferent. Subsequently, Bayer, Qermany, and Prodelac, France have become more concerned and are cooperating with information exchange. The Italian producer does not believe he has a problem. During our meeting with General Electric representatives in late January, we discussed our decision to discontinue the manu facture of Aroclor 125^ and 1260. (JE immediately challenged the decision on the basis that information available was not adequate to incriminate these Aroelors and that the adverse consequences of fires and explosions far exceed the potential threat to the environment. They also indicated that at the proper time they would be willing to have an officer of their company go on record as stating that the unavailability of these materials would result in serious power blackouts. MONS 0354107 WATER PCB-SD0000027972 k. As you can see, we are atlll very much on the defensive, however, considerable progress has been made. In our plants, control of emissions Is progressing well. After Initial audits, all plants Instituted programs for control of spillage, leaks and disposal. Our Newport plant Installed and placed In service an 0M d it*** interceptor pit to hold major spills. Anniston has approval and - -4a proceeding with ef- similar Installation*? This should be In service by the end of the third quarter. Reduction in PCB contents of our plant streams below the solubility level (50-200 ppb) will be achieved only after research work now underway is completed and plant units are designed and Installed. Completion of this work is expected to occur In late 1971. HONS 035408 WATER PCB-SD0000027973 PCB CONTENT PLANT EFFLUENT June, 1969 Present October, 1970 January, 1971 September, 1971 Anniston 50 pounds per day 5 pounds per day 2 pounds per day .5 pounds per day .1 pounds per day (5,000 ppb) (500 ppb) (200 ppb) (50 ppb) (10 ppb) April, 1969 March, 1970 Present September, 1970 October, 1970 September, 1971 Saupcet 700 pounds per day 200 pounds per day 65 pounds per day 55 pounds per day 10 pounds per day 2 pounds per day (3,500 ppb) (1,000 ppb) (325 PPb) (275 PPb) (50 ppb) (10 ppb) Present Newport 30 pounds per day (3,000 ppb) HONS 035409 WATER PCB-SD0000027974 We have worked closely with our customers and have offered our teohnloal assistance on their disposal and effluent problems. Arrangements have been made for the return and reoovery of some of these fluids. Successful control is possible for those uses whloh utilize 'Aroclors Iri closed, sealed systems. In those Instances where control Is virtually impossible; e.g. coatings, adhsslves, pesticide uses, cutting oils, we must discontinue sales or offer, preferably, an acceptable substitute product, ttiese substitutes must be thoroughly evaluated to determine long term effect on the environment to avoid problems In the future. In developing product substitutes, we are very hoperul that the NCR applications In the U.S. and U.K. can be met with biodegradable hydrogenated terphenyls or alkylated biphenyls. Testing is active in NCR laboratories and plants. If successful, complete conversion from Aroclor 1242 should be possible within a year to eighteen months. The use of Aroclors to extend pesticide persistence 1b not one we are recommending of present, but we still have some extremely minor sales through distributors which we are discontinuing. We have recommended to the U. S. Department of Agriculture to reject Aroclors as an approved inert material when pesticide reregistrations occur thlB year. We have developed or are making rapid progress in developing acceptable substitutes for sealants, coatings and industrial fluid use. By year end we should have replaced Aroclors in sealants and coatings or have discontinued sales. Also, by year end about $0% of our Pydrauls will have been reformulated with the remainder targeted for early 1971. WATER PCB-SD0000027975 OT^SCO SNOW SCHEDULE FOR DISCONTINUING ` AROCLOR APPLICATIONS Application Pesticide Extender Cutting Oils Coatings Sealants Hydraulic Fluids Pydraul AC Pydraul AO-WO Pydraul 625 Pydraul F-9 Pydraul A-200 Pydraul 540Pydraul 280 NCR Paper Sales M Dollars/Year $ 10 50 1,000 1,000 290 3 250 600 740 35 130 2,000 $6,108 Target Date Completed June, 1970 December, 1970 December, 1970 September, 1970 September, 1970 September, 1970 December, 1970 December, 1970 December, 1970 December, 1970 July, 1971 HONS 035*11 WATER PCB-SD0000027976 (. Toxicity studies axe now In the tenth month. Data to date Indicate that Aroclors are mildly toxic to mammals, however. It Is highly unlikely that this will be a significant factor In any decision regarding the banning or restricting of the use of Aroclors. A major development has been achieved by our research department In refining our analytical procedures to the level that we now possess capabilities far exceeding many laboratories and un> surpassed by any. We are actively communicating our methodology to other laboratories to Improve the type of information being generated. Our objective is to be considered experts with reliable results. Biodegradation studies have, thus far, confirmed our initial beliefs that the lower chlorinated biphenyls would degrade eaBlly. We were disappointed in the resistance to degradation of some of the Isomers In Aroclor 1242. This would tend to confirm) the belief that some of the 5 and 6 chlorinated biphenyls being found in the environment could be residue from degraded Aroclor 1242. We are aotlvely pursuing the possible use of distilled Aroolor 1242 with degradable components as a possible substitute with minimum loss of other favorable characteristics;'e.g. fire resistance. I rtj K/ I C-U ' U tif' (M H- * rtH M r-C *t <* *>***** `/'t**,*** ~ r, I recommend that we proceed with the plan ae presentees t*i- and I particularly refer to the change In our strategy regarding the discontinuing the manufacture of Aroclors 1254 and 1260. 0NS 035412 WATER PCB-SD0000027977