Document jNjbjaEeEGXBokyb96M4kmoBQ

MANAOEMENT PLAN POLYCHLORINATED BIPHENYL ENVIRONMENTAL PROBLEM I. THE PROBLEM The presence of materials Identified as polychlorinated biphenyl (PCB) In marine environments was first noted by Professors 0. Wldmark and S. Jensen of the Institute of Analytical Chemistry, Stockholm, Sweden and reported In November, 1966. Since then and with Increasing frequency, other Investigators have Identified PCB In marine and animal life. Increasing evidence has been noted that Indicates PCB Is ubiquitously present In the environment and Is resulting In damage to the ecological system. Monsanto is a major producer of PCB (Aroclors) worldwide and has been mentioned in many of the reports. II. BASIC STRATEGY With the growing evidence of the presence of PCB and the apparent damage It can do to the world environment, Monsanto must respond as a responsible member of the business world genuinely concerned with the welfare of our environment, yet not take premature action which would compromise Its responsibilities to Its customers, shareholders or employees. Finding ourselves on the defensive, lacking considerable Information to help In arriving at sound business decisions and with no real Influence regarding the time of any precipitous action by the press, competitors, public or governmental agency, we are forced to commit our limited resources In several directions. We are actively seeking Information regarding the toxlolty and blodegradabllity of Aroolors, improving analytical techniques, developing processes for reclaiming Aroclors Which have been determined unsuitable for further use, developing methods for complete destruction by Incineration, controlling our plant effluents, working with our customers to oontrol and eliminate environmental pollution with Aroclors and developing alternate products for those Aroclor uses Which cannot be controlled and whloh must be discontinued. We are deliberately assuming an aggressive. posture and working closely with customers, co-producers, and regulatory agencies to prevent precipitous aotion. Early reports had indicated that the polychlorinated biphenyls with 5 and 6 chlorines were being Identified In environmental samples. From this Information it was surmised that the lower ohlorinated biphenyls were being degraded and probably were not a problem. Consequently, MONS 033815 -2- a decision was made to plan to discontinue the manufacture of Aroolors 1254 and 1260. Recent data, although Btlll very preliminary. Indicates that not enough Information Is available to justify this action. It appears that In those uses where oontrol of spillage and disposal can be rigidly exercised and the Aroclors are In sealed containers) e.g. capacitors and transformers, the manufacture of Aroclor 1254 and 1260 should be continued. The advantages of using these Aroolors, particularly where safety Is a prime consideration, and no practical substitute has been developed, far outweigh the potential threat to the environment. One of the principal users of Aroolors In eleetrlcal equipment, Oeneral Bleotrio Company, has strongly Indicated that the threat of explosions and fires and loss of eleetrlcal service 1b so great that the use of Aroclor 1254 and 1260 cannot be discontinued. Uses of Aroolors whloh lead to environmental contamination and cannot b' controlled will be discontinued. Examples Include cutting Oils, extending pesticide persistence, metal working applications, coatings on surfaces exposed to food or potable water and NCR paper. HI. OBJECTIVES The overall objective of this plan Is to manage the PCB pollution problem to prevent It from adversely affeoting the established Return-on-Investment objectives of the Functional Fluids and Plasticisers Croupe, vMle main* tainlng the corporate Image of Monsanto as a responsible and respected member of Industiy worldwide. We must assume worldwide leadership and work olosely with the appropriate regulatoxy agencies In arriving at logical rational decisions. Objectives supporting the overall objective are as follows 1 1. Reduce and effectively control the PCB content of all effluent from Monsanto plants. 2. Inform customers of the PCB problem and the Importance of preventing environmental pollution both at their plants or by their products, and encourage them to . take responsible aotlon by offering assistance on reclamation, substitute products and proper disposal. 3. Develop products to replaoe Aroolors for those uses In whloh Aroolors have been demonstrated to be harmful to the environment and cannot be prevented from escaping Into the environment. MONS 033826 3' 4. Develop reliable analytical procedures for determining PCS content of liquids, gases, or solids. 5. Develop methods for effective disposal of wastes con taining PCS without contaminating the environment. 6. Develop methods for reclaiming and reusing off-grads fluids containing PCS. 7. Determine effeots of PCB's on birds, aquatlo life, animals and humans. 8. Establish and maintain favorable relationships with our customers, the press, governmental agendas, other worldwide produoers, the public, and the universities. IV. ACTION PLAN 1. Objective - Reduoe and effectively control the FOB content of all effluent from Monsanto plants. Status - A tentative target of 10 ppb of PCS in plant liquid effluent has been established. Plante at Anniston, Alabama, Newport, Wales and Sauget, Illinois have monitored plant effluents and found high levels of PCS contamination in waste streams and in sediment at plant discharges, leakage and spills are being identified and corrected. Arrangements have been made for the installation of lnteroeptor basins to contain major spills. Aotlon - All plants to continue emphasis on control to achieve target of 10 ppb in effluent. Responsibility - Manufacturing Manager Engineering Manager, Functional Fluids, CED Manager, Research A Development, Functional Fluids Date - All plants achieve 50 ppb in effluent by January,. 1971. All plants achieve target of 10 ppb by September, 1971. HONS 033827 -4- 2. Objective - Inform customers of the PCB problem and the importance of preventing environmental pollution both at their plants or by their products. Status - All Functional Fluids and Plasticisers customers In the U.S. have been Informed. Customers In Canada, U.K., South America, Japan and Continental Europe have not been Informed. Action - Inform customers In Canada, U.K. and Japan. Customers In Europe will not be Informed until con census Is reached by all PCB producers In Europe. Notification of South American customers to follow. Responsibility - Sales Directors, Functional Fluids and Plasticisers Croups Date - Canada, U.K. and Japan by May 1, 1970 Europe and South America - as Indicated. 3. Objective - Develop products to replaoe Aroolors for those uses in which Aroclors have been demonstrated to be harmful to the environment, are resistant to biodegradation, and cannot be prevented from escaping to the environment. Status - Work on product substitutes has been directed primarily at Industrial Fluids applications and NCR Paper coating. Water-glycol mixtures, bromlnated Aroclors, brominated biphenyl, silicates, blends using chlorinated terphenyls with lower chlori nated biphenyls, terphenyls with phosphate esters, phenyl ether with biphenyl, chlorinated paraffins, and fractionated Aroclor 1242 are all under study for Functional Fluids application. Alkylated biphenyls and HB-40 (hydrogenated terphenyls) appear promising for NCR Paper applications. Action - Replace Aroclor 1242 in NCR paper coating with lsopropylblphenyl for U.S. applications and with HB-40 (hydrogenated terphenyl) for U.K.applications. Responsibility - Manager, Research and Development, Plasticizers oroupj Sales Director, Plasticizers Oroup Date - U.K. applications - complete by April, 1971 U.S. applications - complete by July, 19?1 HONS 033828 -5- Action - Develop acceptable substitutes and complete conversion from Aroolor 1254 and 1260 In Sealants and coatings. Responsibility - Manager, Research & Development Plasticisers Group Sales Director, PlaBtlclzers Group Date - January, 1971 Aotlon - Develop acceptable substitutes and selectlvlty phase-out of Aroolor containing Industrial fluids. Responsibility - Manager, Research & Development Functional Fluids Qroup Sales Dlreotor, Functional Fluids Date - Pydraul AC - September, 1970 Pydraul AC WO - September, 1970 Pydraul 625 - September, 1970 Pydraul f-9 - December, 1970 Pydraul A-200 - December, 1970 Pydraul 540 - December, 1970 4. Objective - Develop reliable analytical procedures for determining PCS content of liquids, gases and solids. Status - Procedures have been developed..' Copies have been offered to university and governmental laboratories. Comments regarding our procedures and comparison of results with other procedures have been solicited. Arrangements have been made for exchange of samples to verify analytical results. Action - Continue to refine methodology until we reach a level of competence which will provide data Whose accuraoy will not be challenged. Responsibility - Section Manager, Applied Scienoes Date - - July 1, 1970 HONS 033829 6 - 5. Objective - Develop methods for effective disposal of wastes containing PCS without contaminating the environment. Status - Studies are being conducted on biodegrad ability, Incineration and removal from water solutions. Blodegradablllty studies of existing and substitute products with acllmatlzed microorganisms are being conducted at Ruabon, Data to date Indicates that the monochlor and some of the dl and trichlor biphenyls degrade; remaining PCB's are highly resistant. Studies In St. Louis In river water lndloate high resistance to degradation. ' Incineration tests of 12b2, 1260 and Inerteen PPO lndloate combustion can be sustained with minimum fuel requirements. Stack gas samples taken for analysis to determine degree of destruction Indicated degree of destruction to be acceptable. Reoovery of Aroolors from dilute water solutions Is being studied at Anniston and by MRC at Dayton. At Anniston, adsorption on carbon Is being evaluated. At Dayton, the use of add clays, limestone silica and treated silica are being studied. At the W. 0. Krummrloh plant,' the removal of Aroolors from HC1 gas streams by high temperature cracking are being studied. Discussions have been held with representatives of Monsanto Envlro Chem Systems regarding disposal of Aroolors, solids containing Aroolors and water eontalnlng Aroolors. Proposals for the testing at the St. Charles unit of disposal by pyrolysis were requested. Further work on water effluents Is planned following the analysis of samples from various customers' plants. Action - Continue biodegradation work of existing and substitute products at both Ruabon and St. Louis to establish degree of degradation possible and optimum conditions required. Responsibility - Manager, Research & Development Functional Fluids droip - Date - Ootober 1, 1970 HONS 033830 -7' Action - Evaluate alternate methods of disposal by incineration - Monsanto operated vs. contract. Responsibility - Biglneering Manager, Functional Fluids Group.CKD Pate - July 1, 1970 Action Continue the work at Anniston, Krummrloh and Payton on the removal of PCS from water streams. Responsibility - Manager, Research and Development, Functional Fluids Group. Date - Septentoer 1, 1970 Action Pursue possible contribution by Monsanto STvTro Chem Systems, Xno. to disposal of Aroolor wastes. Responsibility Manager, firvlronmentsl Control Date - September 1, 1970 6. Objective - Develop methods for reclaiming and re using off-grade fluids containing PCB, Status * Limited reclaiming has been achieved by Flndeit, Znc. Arrangements have been made for the reworking of a tank oar of material at V. 0. Krummrloh plant. Initial efforts will be concentrated on returned material from large electrical customers. Meanwhile, customers are holding material for further Instructions or are dumping In authorised land fills. Action - Develop procedure for processing of re turned material. Responsibility - Manager, Research & Development, Functional Fluids Croup Manufacturing Manager Date - May 1, 1970 Action - Select and modify as neoesaary, the required equipment at the W. 0. Krummrloh plant. Responsibility - Manufacturing Manager Date - Appropriation request by June 1, 1970 Fully operational by January 1, 1971 MQNS 033831 -8- 7. Objective - Determine effects of PGB's on birds, aquatic life, animals and humans. Status - Toxicity studies are being made for Konsanto by "Industrial Bio-Test Laboratories. Studies lnolude two year oral toxicity on rats, three generation reproduction study on rats, two year oral toxicity on dogs and studies on egg production, hatohabllity and survival on chlokens. The Aroolors used In these studies are Aroolor 1242, Aroolor 1254 and Aroclor 1260. Results to date Indicate the following! Liver en largement In male rats at 100 ppm; body welghtlloss In dogB by higher chlorinated Aroclors; rat repro duction effected by 100 ppm Aroclor 1242 or Aroolor 1254) chicken reproduction effected by lower chlori nated Aroclors. Studies on fish were attenpted, but were discontinued When oross contamination was discovered. These studies will be resumed. .. Aotlon - Continue studies now underway. Evaluate need for extending studies to Include ohlorlnated terphenyls, hydrogenated terphenyls, alkylated biphenyls and Porocel treated chlorinated biphenyls. Resume fish toxicity studies. Responsibility - Medical Department Date - Complete by mld-1971. 8. Objective - Establish and maintain favorable relationships with customers, the press, governmental agencies, other worldwide producers, the publlo and the universities. Status - Relationships are excellent. We have expressed Interest In studying the problem and Indicated that we wish to cooperate to help Identify and solve It.- Pressure to divulge more Information will continue to Inorease. Aotlon - Appropriate Monsanto personnel will continue to participate In activities related to the PCB problem In a manner which will maintain our excellent relationship. Responsibility - All personnel Date - Continuing MOWS 033832 -9 V. OOST3 Costs for the program for 1970 have been budgeted as fOllOWSI Program Budget 4M Develop Analytical Procedures Toxicity Studies Plant Effluent Studies Blodegradablllty Studies Develop Disposal Methods Reclaiming Systems Design Substitute Products Overall Administration Total $ 80 105 105 40 50 30 150 -li5. 4675 HONS 033833