Document r4KMyb0RR57xLan3V5Eo83Zr

Monsanto c- W' E- P^AGZORGS - ST. LOUIS *- APRIL 7, 1970 TO H, S. BERGEN 'j. VjASuI H. L. MINCKLER C. J. SMITH T. K. SMITH J. E. SPRINGGATE Attached is a copy of a plan for managing the PCS problem. This plan was reviewed with representatives of the Medical, Legal, Public Relations Departments and the Business Groups concerned, and represents the concensus and commitment of all involved. I have arranged for a review meeting in Room B-275 on Friday, April 10th at 2:30 PM, at which time I would appreciate your comments for improvement. Our objective will be to develop a final plan for presentation to the CMC on April 20. ms Attachment - - (/ V. B. PAPAGBORGE __ 0(501499 WATER PCB-SD0000001340 MANAGEMENT PLAN POLYCHLORINATED BIPHENYL ENVIRONMENTAL PROBLEM I. THE PROBLH'l . The presence of materials identified as polychlorinated biphenyl (PCS) in marine environments was first noted by Professors G. Widmark 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 PCS 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. Binding 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 toxicity and biodegradability of Aroclors, 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 control and eliminate environmental pollution with Aroclors and developing alternate products for those Aroclor uses which cannot be controlled and which must be discontinued. We are deliberately assuming an aggressive posture and working closely with customers, co-producers, and regulatory agencies to prevent precipitous action. 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 chlorinated biphenyls were being degraded and probably were not a problem. Consequently, TOf n n1 n 4 A 0001500 WATER PCB-SD0000001341 2- - a decision was made to plan to discontinue the manufacture of Aroclors 1254 and 1260. Recent data, although still very preliminary, indicates that not enough information is available to justify this action. It appears that in those uses where control 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 Aroclors, 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 Aroclors in electrical equipment. General Electric Company, has strongly indicated that the threat of explosions and fires and loss of electrical service is so great that the use o^UA^oclor 1254 and 1260 cannot be discontinued. Uses of/^oclbr&-^T' which lead to environmental contamination and 6annot be 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. t ' III. OBJECTIVES ____ The overall objective of this plan is to manage the PCB pollution problem to prevent it from adversely affecting the established Return-on-Investment objectives of the Functional Fluids and Plasticizers Groups, while main taining the corporate image of Monsanto as a responsible and respected member of industry worldwide;--We must assume worldwide leadership and work closely with the appropriate regulatory agencies in arriving at logical rational decisions. Objectives supporting the overall objective are as follows: 1. 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 action by offering assistance on reclamation, substitute products and proper disposal. 3. Develop products to replace Aroclors for those uses in which Aroclors have been demonstrated to be harmful to the environment and cannot be prevented from escaping into the environment. . 0001501 IDS 001.367 WATER PCB-SD0000001342 4. Develop reliable analytical procedures for determining PCB content of liquids, gases, or solids. 5. Develop methods for effective disposal of wastes con taining PCB without contaminating the environment. 6. Develop methods for reclaiming and reusing off-grade fluids containing PCB. . . 7. Determine effects of PCB's on birds, aquatic life, animals .and humans. 8. Establish and maintain favorable relationships with our customers, the press, governmental agencies, other worldwide producers, the public, and the universities. . ACTION PLAN \ IDS 00136a 0001502 WATER PCB-SD0000001343 Ob jective - 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 Plasticizers 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 Plasticizers Groups . Date - Canada, U.K. and Japan by May 1, 1970 Europe and South America - as indicated. Objective - Develop products to replace Aroclors 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 chlort _ nated .biphenyls, terphenyls with phosphate esters, ' phenyi .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 lsopropylbiphenyl for U.S. applications and with HB-40 (hydrogenated terphenyl) for U.K.applications. Responsibility - Manager, Research and Development, Plasticizers Group; Sales Director, Plasticizers Group Date - U.K. applications - complete by April, 1971 U.S. applications - complete by July, 1971 IDS 001369 n n 01 WATER PCB-SD0000001344 -5- Action - Develop acceptable substitutes and complete conversion from Aroclor 1254 and 1260 in Sealants and coatings. Responsibility - Manager, Research Sc. Development Plasticizers Group Sales Director, Plasticizers Group Date - January, 197'1 Action - Develop acceptable substitutes and selec tivity phase-out of Aroclor containing industrial fluids. Responsibility - Manager, Research St Development . Functional Fluids Group Sales Director, Functional Fluids Date - PydraulAC - September, 1970 Pydraul AC WG - September, 1970 . Pydraul 625 - September, 1970 Pydraul F-9 - December, 1970 Pydraul A-200 - December, 1970 Pydraul 5^+0 - December, 1970 ' Objective - Develop reliable analytical procedures for determining PCB 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 accuracy will not be challenged. Responsibility - Section Manager, Applied Sciences Date - July 1, 1970 IDS 001370 0001504. WATER PCB-SD0000001345 -5- Objectlve - 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. Biodegradability studies of existing and substitute products with aclimatlzed microorganisms are being conducted at Ruabon. Data to date indicates that the monochlor and some of the di and trichlor biphenyls degrade; remaining PCB's are highly resistant. Studies in St. Louis in river water indicate high resistance to degradation. Incineration tests of 1242, 1260 and Inerteen PPO . indicate 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. Recovery of Aroclors 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 acid clays, limestone silica and treated silica are being studied. , At the W. G. Krummrich plant, the removal of Aroclors from HC1 gas streams by high temperature cracking are being studied. Discussions have been held with representatives of Monsanto Enviro Chem Systems regarding disposal of Aroclors, solids containing Aroclors and water con--_____ -taining Aroclors. Proposals Tor 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 Group Date - October 1, 1970 0001505 IDS 001371 WATER PCB-SDOOOOO01346 Action - Evaluate alternate methods of disposal by incineration - Monsanto operated vs. contract. ' Responsibility - Engineering Manager, Functional fluids Group, CEE Date - July 1, 1970 Action - Pursue possible contribution by Monsanto Enviro Chem Systems, Inc. to disposal of Aroclor wastes. " Responsibility - Manager, Environmental Control Date - September 1, 1970 Objective - Develop methods for reclaiming and re-* using off-grade fluids containing PCB. Status - Limited reclaiming has been achieved by Findett, Inc. Arrangements have been made for the . reworking of a tank car of material at W. G. Krummrich 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 .authorized land fills.' Action - Develop procedure for processing of re turned material. Responsibility - . Manager, Research & Development, Functional Fluids Group Manufacturing Manager ' Date - May 1, 1970 Action - Select and modify as necessary, the required equipment at the W. G. Krummrich plant. Responsibility - Manufacturing Manager Date - Appropriation request by June 1, 1970 Fully operational by January 1, 1971 0001508 IDS 001372 WATER PCB-SD0000001347 8- - 7. Objective - Determine effects of PCB's on birds, aquatic life, animals and humans. Status - Toxicity studies are being made for Monsanto by Industrial Bio-Test Laboratories. Studies include two year oral toxicity on rats, three generation ' reproduction study on rats, two year oral toxicity on dogs and studies on egg production, hatchablirty and survival on chickens. . The Aroclors used in these studies are Aroclor 1242, Aroclor 1254 and Aroclor 1260. Results to date indicate the following: Liver en largement in male rats at 100 ppm; body weightlloss in dogs by higher chlorinated Aroclors; rat repro- duction effected by 100 ppm Aroclor 1242 or Aroclor 1254; chicken reproduction effected by lower chlori nated Aroclors. m . Studies on fish were attempted, but were discontinued when cross contamination was discovered. These studies will be resumed. Action - Continue studies now underway. Evaluate need for extending studies to include chlorinated terphenyls, hydrogenated terphenyls, alkylated biphenyls and Porocel treated chlorinated biphenyls. Resume fish toxicity studies. . Responsibility - Medical Department -------- Date--=~~Complete by-mid-1971"; --- - 8. Objective - Establish and maintain favorable relationships with customers, the press, governmental agencies, other worldwide producers, the public 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 increase. Action - Appropriate Monsanto personnel will continue to participate in activities related to the PC3 problem in a manner which will maintain our excellent relationship. Responsibility - All personnel Date - Continuing WATER PCB-SD0000001348 -Q-, COSTS Costs for the program for 1970 have been budgeted as follows:. Program Develop Analytical Procedures Toxicity Studies ' Plant Effluent Studies Biodegradability Studies Develop Disposal Methods Reclaiming Systems Design Substitute Products Overall Administration Budget $M Total ' 0001508 r r> r O nl 1 7 ^ WATER PCB-SD0000001349