Document dRBKNRGYBO7OqDONRapwZm6e

Monsanto Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63167 Phone: 1314) 894-1000 June 7, 1985 Mr. Paul Blinkstad 400 Kourt Dr. No. C Eugene, Oregon 97404 Dear Mr. Blinkstad: Enclosed is the information you recently requested regarding poly chlorinated biphenyls (PCBs). 1 hope it will provide the answers you are seeking. - Very truly yours. ve /ve Enclosures 81-018 81-019 (314)694-8558 Craddock, Ph.D. Environmental Policy Staff Product and Environmental Safety Director TOWOLDMONOQ59590 MONSANTO POSITION STATEMENT FOR DISPOSAL OF PCBs BY INCINERATION Monsanto Company is a broad-based chemical manufacturing company. From 1935 until 1977, Monsanto Company was the major manufacturer of poly chlorinated biphenyl (PCB) compounds in the U.S. and consequently has broad experience and expertise in handling and disposing of these chemi cals . The environmental and health effects and disposal of PCBs has been the subject of hundreds of technical and media articles. Recognized, tech nically trained, competent scientists and medical experts have published thousands of pages of documents discussing the health and environmental effects of these compounds and there is still disagreement among them as to the actual effects of PCBs on man. and the environment. The scare labels of the media headlines of the early to mid-1970's of "deadly toxins" and "human carcinogens" are being rebutted and disproved by more thorough, detailed human epidemiology and animal studies. In the report of the National Academy of Sciences Committee on the Assess ment of Polychlorinated Biphenyls in the Environment (fall, 1979) the committee stated the following: "An analysis of PCB data compiled following criteria of FIFRA and TSCA proposed guidelines, leads to the conclusion that PCBs are persistent and are likely to accumulate. PCBs do not appear particularly toxic for short-term exposure, but results are subject to interpretation." This paper, however, is directed not toward toxicity but rather the proper disposal of PCBs. Safe and acceptable technology for destruction of PCBs by high-temperature incineration has been known and practiced by the scien tific and industrial world since PCBs were first discovered to be environ mentally persistent in the early 1970's. Many European hazardous waste disposal facilities include high-temperature incineration equipment to routinely handle both solid and liquid forms of chemical wastes, such as PCBs and other chlorinated wastes. These include sludges, contaminated earth and other debris. At least a dozen such facili ties are currently in operation and have been functioning satisfactorily for several years. Many of these facilities are jointly owned and operated by both the government and private sector. All of these facilities are capable of destroying PCBs in an environmentally acceptable manner with no human health hazard. In both the U.S. and Canada successful test burns of various high-tempera ture incinerators have been performed that have been carefully monitored by appropriate State and Federal regulatory agencies. This includes the Rollins Environmental Services facility at Deer Park, Texas, and ENSCO at 81-019 0754438 TOWOLDMON0059591 El Dorado, Arkansas. Both of these facilities meet the rigid specificstions, including destruction efficiencies prescribed by Federal regulations under the Toxic Substances Control Act (AO CFR 761), and have been approved by the EPA for incineration of PCBs. Based upon the results of these tests, EPA scientists and,officials and other interested parties have concluded that the two D.S. incinerators are capable of destroying PCBs without harming human health or the environ ment . The major obstacle to safe and ultimate disposal of PCBs is not safe tech nology, but public awareness and education so that suitable disposal sites can be located in Industrial areas without unfounded public fear and oppo sition. Many citizens activists groups share this concern. Attached is information published by one of these informed groups, the Great Lakes Basin Commission, which speaks to the PCB problem generally and, specifically, to incineration and public fear of PCBs and their disposal options. I urge you to carefully consider all of the facts in an unemotional arena in discussing PCB waste disposal options. Certainly, regulated, controlled disposal facilities using proven technology, such as high-temperature incin eration, is preferable to long-term storage at many private industrial loca tions. The potential dangers of environmental contamination due to long term storage and handling (e.g., repackaging leaking or damaged containers, decontamination of storage facilities and equipment, etc.) are significantly greater than once-and-for-all ultimate destruction of PCBs by safe and accept able incineration. 81-019 Enclosure 0754439 TOWOLDMON0059592 gre^. _Kes o \ 1 <'7X^>.'v?Li\/ ru U d Li u U> <(1ui Li d^i7> s,'oT0^^^/Lr .>n' cU...*..:<. J's\\ \ITrf>P Published by the Great Lakes Basin Commission, a regional planning agency Volume 11, Number 3/December 1980 undreds of thousands of gallons of PCB-contami H PGBs:nated wastes are being stored in barrels throughout the Great Lakes region. There is no legal way to destroy You Can or discard many of them. Store Them Up,Once used as insulating materials by industry and in consumer goods, these PCBs now sit in temporary facilit ies. built to government standards, for which industry has spent millions of dollars. But Can You William Gunter, head of the U.S. Environmental Pro tection Agency's PfcB regulations staff in Washington, says some 20 million pounds of PCB wastes are being Throw Them Out? stored nationwide, mostly by utilities. A report for the Electric Power Researcn Institute says that EPA's Region V, which includes six of the eight Great Lakes states, will have the greatest demand for utility PCB disposal capac ity of aD 10 EPA regions. The technology exists to destroy the PCBs through in cineration (see insert), but public opposition and other Top: Drums in a PCB storage facility built by Ford Motor Company at its Rouge plant in Dearborn, Mich. The facility was built to federal standards, and Ford' hopes to dispose of the PCBs. Below: warning label for marking PCBs. factors have so far prevented any incinerators from being approved for commercial use in the U.S. Incineration is the only method approved by EPA for destroying high- level PCBs (those with more than 500 parts per million, a . ) cut-off point established by EPA). Lower-level PCBs can be discarded in approved chem ical waste landfills, but only eight such landfills exist na tionwide, and the cost of shipping PCBs to them is high. Meanwhile, PCBs continue to enter the environment, even though U.S. production of them stopped three years ago. In fact, small quantities of PCBs have contami nated most of the Great Lakes. They have accumulated in large amounts in Waukegan Harbor. 111.; the Saginaw River in Michigan; Sheboygan Harbor. Wis.; and other places around the Great Lakes. . PCBs also fall into the Great Lakes from the air. The burning of sewage sludge releases them, since the burn ing temperatures are too low to destroy them. PCBs also evaporate from paints, landfills, and other sources. One study estimated that 11.000 pounds of PCBs enter Lake I CAUTION CONTAINS Michigan each year with rain and snow. . Fisherman have also been affected by PCBs. State agencies have warned consumers to restrict consumption of some kinds of fish (see insert A Fish Eater's Guide to (Polychlorinated Biphenyls) PCBs). Some commercial fisherman have changed to catching less-contaminated fish. EPA is sponsoring a Michigan study of PCB levels in consumers of large quan || A toxic environmentol contaminant requiring | special handling and disposal in accordance with 2 U.S. Environmental Protection Agency Regulations tities of Great Lakes fish. As scientists at the Great Lakes S 40 CFR 761 For Disposal Information contact Basin Commission and elsewhere predicted, however, controls on usage have caused PCB levels in the lakes the nearest U.S. E.P.A. Office. and fish to fall. There is hope for an easing of fish ad visories in the future. Companies storing PCBs are hoping a solution will be w> found to ease them of the burden. Incinerators in Texas In cose of accident or spill, call toll free the U.S. Coast Guord Notional Response Center. 800-424-8802 and Arkansas (see map) are expected to receive approval ftlso Contact from EPA in the next few months, but they are a long I ^ Tel. No. Turn to Page 4 - --------.;vT>.'osa3 ) 0754440 TOWOLDMONOQ59593 Basin Briefs PCBs 1; J.S Pollution Worksheets The Background Finding the most cost-effective pol lution control program for a drainage basin is the goal of a new technique developed by the staff of the Great Lakes Basin Commission. Using a series of worksheets, decision makers can compile data on pollution sources and calculate costs and benefits of par ticular programs for reducing pollution. The application of this "Watershed" method will be explained in a hand book scheduled for release next sum mer. Copies of two preliminary reports on the technique are available from the Great Lakes Basin Commission, P.O. Box 999, Ann Arbor, MI 48106. PCBs are a group of chemicals, generally clear and odorless ranging in consistency from that of thin oil to that of wax. Until the early 1970s. PCBs were used in adhesives, plastics, paints, varnishes, sealants, and even carbonless copy paper. Although manufactured in the U.S. from 1929 to 1977. they were not seen as a problem until a decade ago. A-study of museum specimens of Lake Michigan fish detected no PCBs until 1949, and a progressive increase from 1949 to 1966. ,, . PCBs are still in use as coolants in many capacitors and transformers, espeiaily in the utility industry. High voltage capacitors are common on ordinary utility poles, where they store voltage momentarily and correct imbalances that occur over long distances. Capacitors are also used in air conditioners, microwave ovens, and fluorescent light ballasts made before 1977. There is no easy way to distinguish a PCB capacitor from a non-PCB one. Transformers change electrical voltage to a level required by the equipment drawing current. They are common in industrial buildings Corps General Retires and generating stations, and they last 30 to 40 years. Industry has developed substitutes for PCBs in both transformers and Major General Richard L. Harris capacitors. Fluorocarbons, silicone fluids, and mineral oils are now used retired Nov. 30 as commander of the in transformers. U.S. Army Corps of Engineers' North PCBs are toxic to humans. They are suspected carcinogens. They Central Division. He is succeeded by have caused tumors in rats and mice, reproductive dysfunctions and . Brigadier General Scott B. Smith, other problems in monkeys, and increased liver weight and other pro who will become the Corps' new blems in rats and guinea pigs. In humans, excessive PCBs may cause commissioner on the Great Lakes Ba skin eruptions, nausea, abdominal pain, jaundice, and fatigue, among sin Commission. During his command. otheT things. Harris oversaw the Corps' study of an The U.S. Environmental Protection Agency considers the release of extended shipping season on the even slight amounts of PCBs significant. "The available data indicate Great Lakes and St. Lawrence that PCBs may cause several adverse effects in humans, mammals, Seaway. birds, and aquatic organisms at extremely low concentrations," a recent ! EPA report said. Midwest Water Study Avoiding contaminated foods, however, does not eliminate exposure to PCBs. Airborne PCBs may be absorbed through the lungs. PCBs cir A study by the Northeast-Midwest Institute has declared that water qual- tty problems and decaying municipal culate in the blood and accumulate in the fat. liver, kidneys, brain, heart, and other organs. Breast-fed infants may receive 50 or more times the PCBs in food their mothers eat. water supply systems may make water the area's most serious problem before long. Send S3 to the institute and re T Next Month: Transportation iV-'3 quest Water Resource Priorities for the Midwest. Address: P.O. Box 37209, Washington, D.C. 20513. `Superfund' Support The Great Lakes Basin Commission has endorsed swift Congressional ac tion to pass "Superfund" legislation. The two related laws would authorize $1.2 billion to clean up abandoned hazardous waste spills in navigable waterways. Many Great Lakes con gressman and senators responded to the resolution with indications of sup port. Both bills passed the House in late September. At this writing, the bills are pending in the Senate for pos sible action during the post-election "lame duck" session. great lakes ' i-.ftmnnmiVj-ifniCOffiff (UniCUIUr Published free of charge each month as a service of the Great Lakes Basin Commission, a planning agency established under the fed eral Water Resources Planning Act (PL 89-80) of 1965. Commission members include the eight Great Lakes states, 11 federal agencies, and one interstate commission. Except where otherwise noted, views expressed herein do not necessarily represent official policies of the commission. Address letters and subscription requests to the Communicator. P.O. Box 999. Ann Arbor, MI 48106, (313) 668-2300 (Federal Telecommunications System 378-2300). Additional copies free' upon request. Reprinting materia) from the Communicator is -encouraged. Please credit the Great Lakes Commutator and send a copy to our office. Deadline for calendar notices is the 1st of the month prior to publication date. Great Lttkat Bum Conimnon Ontni.................................................... Lm Sorts Vet Ottoman ...................... Frank Kudma (fata*) Pubk Wormtnon Orfct OnCKK .......................................... Wahtr ftwrwroy Communicator Editor ........................... David Staart Wovmanon Special**!................... Sandra Gieyonan Stcrttary......................................... Kathy Andmon 2 December 19S0 - --'~jt_UUes. communicator 0754441 3 TOWOLDMONOQ59594 The Law and ..is PCBs : . . 1, 1979. It requires ; :n on distribution in commer.L -j. July 1, 1979. Certain uses may be continued, however. PCBs in Most of the major federal recuiatic-ns concerning PCBs were authorized under the Toxic Substances closed systems like transformers and capacitors (in which PCBs are not directly exposed to the environment) are Control Act. But as of last month, the U S. Environstill allowed to be used, but will gradually be taken out of mental Protection Agency has incorporated PCB control service as they wear out. PCBs not in totally enclosed into its regulations under the Resource Conservation and uses may continue until July 1, 1984, if the user receives Recovery Act. an exemption from the EPA. Both laws were enacted in 1976. PCB regulations un PCBs now being stored must be disposed of by 1984 in der the toxic substances act did not take hold until 1979. facilities that meet EPA requirements. PCBs stored after Hazardous waste regulations under the resource conser 1983 ntust be discarded within one year after storage vation act were not. in large part, put into effect until begins. Until disposal facilities are available, industries 1980. Meanwhile, states such as Wisconsin, Minnesota, must store PCBs in secure facilities whose locations, and Michigan began regulating PCBs by themselves. roofs, walls, floors, and openings meet EPA require The toxic substances act banned manufacturing of ments. They must also keep careful records of the PCBs. ' Map by Connla U . Somca: ElacMc P o w i Raanich tnaUiria and ERA You Can Store PCBs, But... From page 1 ______________________ distance from the Great Lakes region's industries and are too few to handle the nation's PCBs. The Great Lakes Basin Commission has. initiated a series of roundtable discussions to stimulate discussion on a regional disposal solution (see From the Chairman, p. 7). One hope lies in emerging technologies that do not require large, perma nent incineration facilities. But such technologies, in cluding one highly-publicized process developed by Goodyear Tire and Rubber Company, may not be suit able for all PCB-contaminated materials (see special in sert inside). . r>--loan Although some chemical landfills accept low-level PCBs (those with fewer than 500 ppm), landfills are only a partial solution. And temporary storage risks accidents, fires, or spills, although federal storage rules are stringent. The Great Lakes Water Quality Board of the Interna tional Joint Commission says temporary storage of toxic substances "may be a serious threat to the health and safety of a community." "We ought to get rid of the PCBs through destruction instead of sitting on them." says Malcolm Day. environ mental advisor to Consumers Power Co. in Jackson, Mich. He and other industrial spokespersons say it will take a large effort to convince people that destruction methods are adequate to protect the environment. Dauid Stoats 0754442 great lakes communicator TOWOLDMON0059595 0 ibi k -- Contrary to common belief, and despite.warehouses of undisposed PC3$. the technology exists to destroy PCBs safely and effectively. Several new processes have made headlines in recent months. One pro cess. incineration, has already been approved by the U.S. Environmental Protection Agency (EPA) and suc cessfully used to destroy PCBs. This fact sheet is a brief overview of incineration. landfilling, and some of the emerging technologies for the destruction of PCBs. Incineration What It Does Incineration of PCBs is currently the only EPA-approved method for destroying high level PCBs (500 ppm or more). However, at this w-riting there are no EPA approved commercial incin erators. Basically, incineration is the controlled burning of PCBs at high temperatures, at least 2200CF, for a specified length of time. Incineration works by heating the PCB compound until its chemical structure breaks apart. The resulting products are different chemical compounds, usually in the form of non-toxic gases. In test and actual burns. PCBs have been destroyed 99.99% by incineration. Several different types of incinerators can be used to destroy PCBs. The most promising type is actually a rotary- kiln used for making cement. The advantages of cement kilns include the fact that they already exist, saving construction time and costs. In addition, cement kilns operate above the high temperatures needed to destroy PCBs. The chloride salts produced by incinerating the PCBs can be used in. the cement making process, and the lime used in cement making neutralizes any acidic gases that remain. . The Process Under EPA regulations". PCBs must be burned at 2200CF or hotter for at least 2 seconds. After the PCBs are burned, the remaining products are gases and water. These are then cleaned to remove any heavy metals and other solid panicles. The cleaned gases are vented through an exhaust stack and the treated water is discharged into the municipal wastewater treatment plant or recycled. If ash or sludge remains, it is dis posed of in an approved landfill. Limitations Incineration of PCBs is no: widespread because of the high cost of constructing new facilities and pub!;c oppcs r.on to this type of facility. The principal disadvantages of incineration of PCBs are: 1) risks associated with transporting PCBs to the incinerator, and 2) the need to monitor carefully and frequently the byproducts to insure that no toxic elements are created. Landfills . ' ` <* Under U.S. EPA regulations, low level PCBs. those under 500 ppm. can be disposed of in approved landfills. However, only eight approved landfills exist in the U.S. - not nearly enough for the quantity of low- level PCBs needing disposal. -. . . ?c- rcr-ijv.onj for ir.cnirivor. j.iJ :jnu uisposji o: PC3> see V.*;. .j!. l p? 31551 0754443 TOWOLDMONOQ59596 > Land disposal of PCBs means permanent burial in pits. The pit; are lined with an impermeable clay or plastic liner to prevent the leaking of PCBs into ground or surface waters. Several layers of soil including impermeable clay are placed on top of the hole to cover and fill it and reduce any chance of PCBs escaping into the air. or infiltration into the ground by precipitation. Emerging Technologies* Several companies around the U.S. are developing methods other than landfilling and incineration to destroy PCBs. Many are still under development, while others have reached U.S. EPA for review. All but the last method described below are variations on the incineration theme, using different chemical substances and temperatures to rearrange and render harmless the chemical structure of PCBs. In laboratory tests they have all achieved 999b or more destruction of PCBs. Here is a brief run-down: Atlantic Research Corp.: has developed a process that uses ultraviolet light to destroy high and low level PCBs from contaminated transformer oils and pure PCBs. The process can be housed in a mobile unit and the end product is biodegradable biphenyls which can be safely burned. D & D Disposal: its process burns PCBs in a diesel engine and has been effectively tested with both high and low level PCBs. The by-products are hydrochloric acid, which is a recoverable solvent, carbon, and trace elements. It is also a mobile unit. Goodyear Tire & Rubber: this well-publicized process bums PCBs with a sodium solution to cause a chemical reaction which detoxifies low-level PCBs. The end products are sodium chloride and non-hazardous polyphenyls. This process allows contaminated heat-transfer fluids to be recovered and reused. Lockheed: its process uses a microwave furnace to burn high level, almost pure PCBs. The micro wave plasma is very destructive and capable of breaking chemical bonds mat are not normally easily broken. The unit can be very compact compared to a regular incinerator and thus.mobile. The by-products or this pro cess are carbon dioxide, steam, and recoverable hydrochloric acid. In addition, this process creates its own energy supply. Rockwell International: has developed another process which uses he: salts imclten sodium car bonate) as a cataiyst ana heat to incinerate high lave! PCBs. The end products are hydrogen chloride, carbon dioxide, and watOT. Sunohio: has not released the details of its low-temperature chemical process which changes high and low level PCBs into harmless substances. The company says the process allows contaminated trans former oils to be recovered and reused. v ): * Far rr.-jif '.vi.vri.v.ijp.-m; h.'ce ?*aiv*cs P O. Box 999. Ar.r. Arror. tSiVS. Civ.i-w: tna Inform.i:...,'. Gif ct. Gw-w 2asin Cammis-ion. I 0754444 TOWOLDMONOQ59597 the Chairman D Why Public Fear Threatens Public Health By Lee Botts The people of the Great Lakes region need to decide what to do about the banels of liquids containing PCBs (polychlorinated biphenyls) that are being stacked up at power plants and factories around the region. The choice is between leaving them in storage (and trusting that they will never escape into the environ* ment) or destroying the chemicals so they are no longer dangerous. This issue of the Communicator is de voted to information about the PCB dilemma--why they are being stored and ways they could be destroyed. No region of. the country has more at stake than ours in deciding how to handle PCBs safely. It was in the Great Lakes that scientists dis covered that PCBs. like their cousin DDT, can enter the food chain and contaminate entire ecosystems. This is where commerical fisherman whose families have fished the Great Lakes for four generations have had their livelihood destroyed because of the presence of PCBs in quantities almost too small to be imagined. This is where the excitement of some of the best sports fishing in the world is maned by the risk of eating more than small amounts of the lakes' huge salmon and trout. With regulation of PCBs to keep them from further contaminating the environment, our industries are faced with huge costs for safe storage because there is no agreed-upon other way of handling them. My question is: can we afford not to destroy PCBs when we can? The problem is that people are afraid of hazardous chemical wastes. Their fear is based on almost daily dis closure of public health and environmental problems caused by past unsafe handling. Their fear is making the problem worse by preventing communities and neighbor hoods from allowing disposal, even if the disposal methods actually destroy the PCBs. PCBs Are Everybody's Problem Just as all communities must provide for disposal of household garbage, they also have a responsibility for safe disposal of hazardous chemicals used in the commu nity. PCBs were used for 40 years before we knew how dangerous they were. Now that we know the problem, laws have been passed to make their manufacture and use illegal in the U.S. Industry is removing them from use and putting them in storage. But. industry has no way at present of getting rid of high-level PCBs. There are good signs that the PCBs already in the Great Lakes are declining. This means that if no addi tional PCBs get into the system, the lakes may, ultimately cleanse themselves of PCB contamination. We must de stroy the PCBs removed from use under the new laws to make sure that no more get into the Great Lakes, or the rivers, or the groundwater, or the air. In recent months the Great Lakes Basin Commission has joined forces with other agencies and institutions to draw attention to the need for deciding what to do about PCBs. In Michigan and Indiana, we have already discov ered that industry and environmentalists have a common interest in providing for safe handling and disposal of PCBs. We have learned that there is great agreement'on incineration as the best immediate means of disposal, but we have also learned that communities are afraid to allow it. In coming months we will continue discussing this pro blem elsewhere in the region. I urge citizens in the Great Lakes to find out what is happening to PCBs in their com munities. and consider under what conditions disposal should be allowed. Obviously, officials and citizens confronted with the PCB dilemma need more information. The information we have about PCBs and their disposal is available to anyone. Let us know if you want more information and whether you would like our help in promoting considera tion of the problem in your community. Let us know also, if you have ideas about how citizens ought to be involved in deciding whether to allow PCB disposal in their community. The PCB problem will not' go away. It is time to search for solutions, for the sake of the Great Lakes and the people who depend on them. Worse because, in the case of PCBs and other wastes, lack of accessible disposal facilities means that industries must either put the wastes in storage or get rid of them se cretly and illegally. Communities need to decide whether it is riskier to allow regulated and monitored destruction or to trust that accidents and/or illegal dumping will never happen'. The assumption that there is no safe disposal techno logy leads to attitudes that PCBs ought to be someone c else's problem But PCBs are some of the most widely-used chemicals, as well as some of the most persistent. They are everyone's problem, because everyone has benefited from their use in electrical transformers, capacitors, fluorescent lighting fixtures, television sets, and other In some places, salmon than 20 inches have high PCBs things that we depend on in an industrial society. levels and may be unsafe to eat. great lakes.cominunicator December 1980 7 0754445 W.*.H,vn UNK TOWOLDMONOQ59598