Document reXJy7XvNa7DzXVxv290YbBRG
FLEISHMAN HILLARD INC
Public Relations
200 North Broadway St. Louis, Missouri
63102
Marjorie Brooks
June 3, 1992
Memorandum
TO: Kevin S. Cahill
FROM:
Marjorie Brooks
RE: Sauget Sites Communication Materials Binders
Enclosed for your review are the written communications materials proposed for inclusion in the Sauget sites binders. They include news releases, media statements, message points, questions and answers and fact sheets.
The materials are grouped in four categories:
1) Former Krummrich landfill
2) Dead Creek Sector B
3) Dead Creek Sector A
4) Krummrich plant waste-minimization materials
There are also some additional questions and answers on the Sauget sites that were developed in April prior to the Wall Street Journal reporter's first visit. Since they cover a wide range of topics, I would appreciate your guidance as to which category you would like them to go in (perhaps they could be duplicated, with copies under several tabs).
Please also advise if questions and answers on Superfund and on the financial indications of hazardous-waste cleanups will be forthcoming from Diane Herndon and Scarlett Lee Foster, so we know whether to make tabs for those sections. If not, tabs could be added to the binders later.
enclosure cc: Robert L. Peirce (memo only)
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Additional Questions and Answers Sauget Sites
l.Q. How much of Monsanto's reserve for hazardous-waste cleanups will go for cleaning up the Sauget sites?
A. We don't break out amounts for specific sites. However, we have currently committed $2.5 million to a remedial investigation and feasibility study for Site R, the former Krummrich landfill. This is the only Sauget site owned by Monsanto.
2.Q. What's Monsanto's view of the possibility of the Sauget sites becoming a federal Superfund site?
A. You'd have to ask the Illinois EPA about that. However, Monsanto plans to work closely with whichever agency is involved in the Sauget sites -- the U.S. EPA or the Illinois EPA.
3.Q. What's Monsanto's overall policy on the Sauget sites?
A. We are moving in a responsible manner to resolve long-standing environmental issues in the area.
4.Q. Which sites are Monsanto involved in?
A. Earlier this year, we began a remedial investigation and feasibility study of Site R, the former Krummrich landfill. The 22-acre landfill was used from 1959-1977 to dispose of waste from the Krummrich plant and from other Monsanto facilities in the St. Louis area. Site R is the only Sauget site owned by Monsanto.
During 1992, we took samples from Sector B of Dead Creek to determine the types of chemicals present. The chemicals came from a number of industrial and commercial sources over the last 75 years.
5.Q. What were the results of the sampling in Sector B?
A. Results confirm the analytical results obtained by the IEPA ten years ago.
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2- 6.Q. Is Monsanto involved in any other sites? A. Our Krummrich plant has been in operation for more than 70
years. At an undetermined number of sites, Monsanto may be one of several responsible parties. We will be working with the Illinois EPA and other parties in coming up with plans to investigate and remediate the sites, as appropriate.
7.Q. Is Monsanto's waste involved in Site Q? A. We believe any hazardous waste which we may have in Site Q
is located immediately East of the former Krummrich landfill. We are including this area is our RI/FS work plan.
8.Q. Will Monsanto do anything about Site Q? A. Our remedial investigation and feasibility study of Site R
will include a dogleg area of Site Q adjacent to Site R. This area is approximately 14 acres.
9.Q. What did the Krummrich plant do with its waste before 1959, when the former Krummrich landfill opened?
A. A variety of other landfills in the St. Louis area were used.
10.Q.Which other landfills? A. We do not have complete records on where our waste went
then, which was more than 30 years ago. As you know, there were few, if any, requirements for such recordkeeping at that time. Today, the Krummrich plant no longer uses landfills to dispose of routine process waste from its chemical operations. Great emphasis is placed on waste-minimization efforts. The plant reuses and recycles materials wherever possible. The next preferable option is to destroy or treat the waste, with land disposal the last option.
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11. Q. A.
What's your position on Cerro Copper's lawsuit on Dead Creek?
We are disappointed that Cerro Copper Products Co. has chosen to take this action. Cerro decided on its own to do the remediation work in Sector A of Dead Creek, in agreement with the Illinois Environmental Protection Agency and the Illinois Attorney General's office. The work was done entirely on Cerro's property.
12.Q. A.
Did Monsanto discharge waste from its Krummrich plant into Sector A of Dead Creek?
To the best of our knowledge, Monsanto's wastewater has not discharged into Dead Creek since the sewer system was installed during the early 30s.
13.Q. A.
In what other ways could Monsanto's materials have entered Sector A of the creek?
They could have been released by third parties who either used or transported materials from the plant.
14. Q. A.
Was Sector A a conduit for sewer flows from the Krummrich plant?
For at least the last 50 years, Monsanto's wastewater has been discharged into the Sauget village sewer system.
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NEWS
. FOR RELEASE
Andi Smith (618) 482-6322
Monsanto
IMMEDIATELY 1991
MONSANTO CHEMICAL COMPANY PUBLIC AFFAIRS DEPARTMENT Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63167
MONSANTO TO ASSESS CONDITIONS AT FORMER LANDFILL
SAUGET, ILL., Dec. 4 -- Monsanto Company has agreed to
study conditions at the former Krummrich landfill in Sauget
and to evaluate alternatives for corrective action.
The study is the result of a consent agreement
negotiated by Monsanto, the Illinois Attorney General's
Office, and the Illinois Environmental Protection Agency.
"This process will determine what action is required to
ensure the long-term protection of public health and the
environment," said William J. Boyle Jr., plant manager.
"Monsanto is committed to carrying out the work carefully
and correctly."
The landfill does not pose any immediate health or
environmental problems, but Monsanto will respond fully and
willingly to the state's concerns, Boyle said.
Public comment will be sought and considered carefully
during the process. There will be a public comment period
before the consent decree is finalized. Once the consent
agreement is entered in St. Clair County Circuit Court,
Monsanto will hold a public meeting to explain the
investigation, to answer questions and to hear the concerns
of area residents.
-- more
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Illinois Attorney General Roland W. Burris commended Monsanto for the agreement, which resolved litigation over the site that had been pending since 1982.
An environmental engineering firm will investigate conditions at the site and recommend alternatives for remedial action. The firm was hired by Monsanto, subject to the approval of the Illinois Environmental Protection Agency (IEPA) . The study is expected to take approximately a year and a half. The findings will be presented at a second public meeting. The IEPA will closely monitor the study and will select the corrective action it believes is appropriate. If Monsanto agrees, Monsanto will carry out the corrective action, again with IEPA oversight.
The 36-acre landfill was used from 1959 to 1977 to dispose of waste from the Krummrich plant and from other Monsanto facilities in the St. Louis area. The landfill was capped with clay, in accordance with state law for closing landfills at that time, covered with soil and seeded. It is completed fenced.
"The landfill does not represent current Monsanto waste-disposal practices," Boyle said. "It was built more than 30 years ago, in compliance with existing state law of that era, but landfill designs were not as sophisticated then and the state of environmental knowledge was not as advanced."
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Monsanto
Monsanto Chemical Company500 Monsanto Ave. Sauget, Illinois 62206-1198 Phone: (618) 271-5835
STUDY TO BEGIN AT FORMER KRUMMRICH LANDFILL
Monsanto Company plans to study conditions at the former Krummrich landfill in Sauget and to evaluate alternatives for corrective action.
The study is the result of a consent agreement finalized in December by Monsanto, the Illinois Attorney General's office and the Illinois Environmental Protection Agency. Public input will also be sought and carefully considered.
The landfill does not pose any immediate health or environmental problems, but Monsanto acknowledges the state's concerns and is committed to carrying out the work safely and correctly. The study will determine what action is required to ensure the long-term protection of public health and the environment.
Facts About the Project:
A well-qualified environmental engineering firm approved by the Illinois EPA will do the work.
The study will take approximately a year and a half.
The Illinois EPA will closely monitor the study and will select the corrective action it believes is appropriate.
If Monsanto agrees, it will carry out the corrective action, with Illinois EPA oversight.
Residents will be kept informed about the project and will have opportunities to comment. Another public meeting will be held when the study is completed.
The 36-acre landfill was used from 1959-1977 to dispose of waste from the Krummrich plant and from other Monsanto facilities in the St. Louis area. It was closed in 1978.
Today, the Krummrich plant no longer disposes in landfills routine process waste from its manufacturing operations. Waste elimination and minimization efforts receive highest priority. The next preferable option is to destroy or treat the waste, with land disposal the last option.
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For More Information: More information about the project is available at the Sauget Village Hall. Monsanto has set up a special telephone line to provide information about the project and to answer questions. The number is 618-271-5835. Monsanto's public information coordinator for the project will respond to all calls.
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October 18, 1991
Preparedness Statement Former Krummrich Landfill
Monsanto Company and the Illinois Environmental Protection Agency have been negotiating a consent agreement for the company to assess the conditions at the former Krummrich landfill in Sauget, 111., and to evaluate alternatives for corrective action.
This process will determine what action is required to ensure the long-term protection of public health and the environment. Monsanto is committed to carrying out the work carefully and correctly.
Public input will be sought during the process. Once the consent agreement is entered in St. Clair County Circuit Court, Monsanto will hold a public meeting to explain the investigation, to answer questions and to hear the concerns of area residents.
An environmental engineering firm will investigate conditions at the site and recommend alternatives for remedial action. The firm was hired by Monsanto, subject to the approval of the Illinois Environmental Protection Agency (IEPA) . The study is expected to take approximately a year and a half. The findings will be presented at a second public meeting. The IEPA will closely monitor the study and will select the corrective action it believes is appropriate. If Monsanto agrees, Monsanto will carry out the corrective action, again with IEPA oversight.
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The 36-acre landfill was used from 1959-1977 to dispose of waste from the Krummrich plant and from other Monsanto facilities in the St. Louis area. The landfill was capped with clay, in accordance with state law for closing landfills, covered with soil and seeded. It is completely fenced.
The landfill does not represent current Monsanto waste-disposal practices. It was built more than 30 years ago, in compliance with existing state law, but landfill designs were not as sophisticated then and the state of environmental knowledge was not as advanced as it is today.
Today, the Krummrich plant no longer uses landfills to dispose of routine process waste from its chemical manufacturing operations. Great emphasis is placed on waste-minimization efforts. The plant reuses and recycles materials wherever possible. The next preferable option is to destroy or treat the waste, with land disposal the last option.
The Krummrich plant's efforts are part of a voluntary program announced by Monsanto in 1988 to reduce air emissions of toxic chemicals by 90 percent by the end of 1992. Monsanto Chemical Company, the largest operating unit of Monsanto Company, has targeted a 70 percent reduction in the amount of organic and toxic inorganic waste released into the environment by the end of 1995.
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Message Points
Former Krummrich Landfill
Monsanto Company and the Illinois Environmental Protection Agency have been negotiating a consent decree for the company to assess the conditions at the former Krummrich landfill and to evaluate alternatives for corrective action. This process will determine what action is required to ensure the long-term protection of public health and the environment.
The public will be kept informed about the project and will have a chance to comment. Monsanto will hold public meetings before the investigation begins and to announce the results of the investigation and feasibility study.
The investigation and feasibility study are expected to take approximately a year and a half. The work will be done by an experienced environmental engineering firm hired by Monsanto, subject to the approval of the Illinois Environmental Protection Agency.
Monsanto is committed to the future economic development of the Metro East area. We pledge to carry out the appropriate corrective action carefully and correctly.
The IEPA will closely monitor the project and will select the corrective action which it believes is appropriate.
The landfill operated 1959-1977 to dispose of waste from the Krummrich plant and other Monsanto facilities in the St. Louis area.
The landfill was built more than 30 years ago, in compliance with existing state law, but landfill designs were less sophisticated then and the state of environmental knowledge was much less advanced than it is today.
The Krummrich plant no longer uses landfills to dispose of routine process waste from its chemical manufacturing operations. Waste elimination and minimization efforts receive highest priority. Efforts are made to reuse and recycle materials wherever possible. Incinerating waste is viewed as the next-best option. Landfilling is viewed as the last option.
These efforts are part of a voluntary initiative announced by Monsanto in 1988 to reduce air emissions of toxic chemicals by 90 percent by the end of 1992.
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Confidential & Privileged
Questions and Answers Former Krummrich Landfill
1) When was the consent decree finalized?
The consent decree was entered into court on February 13, 1992.
2) How long have the negotiations been going on?
Major progress in the negotiations has been made since last June. While we would all agree we wish it had been settled sooner, there is no impact on public health. If there was an impact, it would have been settled sooner.
3) Was Monsanto sued by the state of Illinois over this landfill?
The Illinois Attorney General's office filed a lawsuit in 1982 in connection with the landfill. The suit is still pending. Before and after the suit, we have taken steps to protect the public health and the environment. We have placed a two-foot-thick clay cap over the landfill, in accordance with state law at that time for closing landfills, and planted grass on it to help prevent seepage of rainwater through the landfill. We also began a groundwater monitoring program and completed a $1.5 million program to install rocks and sand along the riverbank to control erosion.
4) Did Monsanto wait to get sued before it acted?
We have not waited to take action in connection with the landfill. In 1979, we placed a two-foot-thick clay cap over the landfill and planted grass on it to help prevent seepage of rainwater through the landfill. About a decade ago, we began monitoring groundwater at the site. And in 1985, we completed a $1.5 million project to install rocks and sand along the riverbank to help control erosion.
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5) What types of work will the remedial investigation and feasibility study involve? It will include additional, more extensive groundwater monitoring to determine the extent and movement of the waste. The work will also involve checking the integrity and coverage of the clay cap already in place over the landfill.
6) Who will do the work?
An experienced environmental engineering firm hired by Monsanto, subject to the approval of the Illinois Environmental Protection Agency.
7) What firm is it?
Geraghty & Miller Inc.
8) How long will the work take? Initial work completed (Phase I). IEPA has requested additional testing of site.
9) How much will the remedial investigation and feasibility study cost? In excess of $2 million.
10) What will be Illinois Environmental Protection Agency's role in the remedial investigation and feasibility study? The Illinois Environmental Protection Agency will closely monitor the project and will select the corrective action. If Monsanto and IEPA disagree over what corrective action is appropriate, the court can be called upon to decide.
11) What will be the court's role in the remedial investigation and feasibility study? The St. Clair County Circuit Court will enforce the terms of the consent agreement and must approve the Illinois Environmental Protection Agency's choice of corrective action.
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12) What remedial options will be considered? We plan to look at a number of options aimed at protecting the public health and the environment. They include adding more cover, building a slurry wall between the landfill and the river, and pumping and treating the groundwater.
13) What do you mean by adding more cover? Increasing the size and/or thickness of the two-foot-thick clay cap that has been in place since 1979.
14) What's a slurry wall? An underground wall to restrict or reduce the flow of groundwater into the Mississippi River.
15) What do you mean by pumping and treating groundwater? Pumping the groundwater and treating it to remove the waste at a plant that would be built near the landfill site. The treated groundwater would then be discharged to the river.
16) Why can't the waste be dug up and moved elsewhere? It would not be feasible and it would be risky to disturb the waste and move it elsewhere for disposal, even if another disposal site could be found. It could harm the environment rather than protect it.
17) Will incineration be an option? The large volume of material involved and the mixture of chemicals would make incineration more difficult. Digging up the waste and transporting it to an incinerator would increase the likelihood of public exposure to the material.
18) Is the Times Beach incineration remedy applicable here? The contamination at Times Beach is virtually all one chemical -- dioxin. In addition, the dioxin is limited to the first 12 inches of soil, so excavation is easier. The landfill is much deeper than that.
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19) Monsanto has been researching the use of bioremediation to clean up hazardous waste sites. Why not use it here? Bioremediation would be extremely difficult. That's because the depth of the landfill would make it almost impossible to deliver nutrients evenly and efficiently to enable the bacteria to destroy the waste.
20) What will assure that the most appropriate form of remediation is chosen? The court and the Illinois Environmental Protection Agency will provide external review to ensure that the work is done right. Monsanto has a strong investment in the future economic development of the Metro East area and is committed to carrying out the appropriate corrective action carefully and correctly.
21) How big is the landfill? Twenty-two acres. The size of the site under study, including the landfill, is 36 acres.
22) Where is it located? On the west side of Illinois Route 3, near the Krummrich plant.
23) Is this in a flood plain? Yes.
24) What would happen to the landfill in a flood? The clay cap would help prevent water from seeping through the landfill and would protect the site. There are no exposed chemicals. The landfill withstood the 500 year flood of '93.
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25) Why was it built next to the Mississippi River? The landfill was built more than 30 years ago, in compliance with existing state law, but landfill designs were less sophisticated and the state of environmental knowledge was much less advanced as it is today. The site is in close proximity to several other landfills and waste-disposal facilities. Today, we would do a number of things differently, including choosing a location. In addition, modern landfills have improved engineering and design features, including impermeable liners.
26) How much waste is in the landfill? An estimated 262,500 tons.
27) Where did the waste come from? Mainly from the Krummrich plant, but also from other Monsanto facilities in the St. Louis area.
28) What kinds of chemicals are in the landfill? They include chlorinated hydrocarbons, chlorophenols, nitrophenols, chlorobenzene, nitrochlorobenzene, creosols, waste sulfuric acid, waste caustic soda, waste solvents and filter sludges.
29) What health risks are posed by these chemicals? Are they dangerous? Some of the chemicals are considered hazardous if they are not contained properly. The materials in the landfill are contained and there is little likelihood of public contact. Thus, there is believed to be no health risk. The goal of our investigation and remedial action is to protect the public health and the environment.
30) When was the landfill used? The landfill operated from 1957 to 1977.
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31) Are wastes from the landfill leaking into the Mississippi? A small amount of material is entering the river.
32) What's the content of the leaking waste? Analysis of leachate and sediment samples by the Illinois Environmental Protection Agency has indicated a variety of organic compounds, including chloroaniline, PCBs, chloronitrobenzene, dichloroaniline, chlorophenol and diochlorophenol. The material is flowing into the river at a very slow rate. While any leak is a concern, it is an infinitesimal amount compared to the flow rate of the Mississippi, which is about 1 million gallons per second.
33) Was dioxin found in the leaking waste? Extremely low levels of dioxins and furans were detected in some samples. There are many chemicals in the dioxin family, however, and these were not 2,3,7,8-TCDD -- the type found at several dozen sites in eastern Missouri. The dioxins found in the samples were not a concern from a public health standpoint.
34) When was this leakage first detected? In 1981. A short time later, we began a $1.5 million project to install rip-rap to extend the riverbank and to control erosion. Approximately 90,000 tons of rock and sand were placed on the 2,300-foot riverbank. The project was completed in 1985.
35) How much waste is leaking? The number obviously varies depending on what chemicals one considers. An extensive risk assessment has been performed, which shows that the landfill does not pose a risk to human health or the environment.
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36) Has anything been done to stop the leaks?
Things have been done. We placed a clay cap over the landfill in 1979 and completed a $1.5 million project in 1985 to install rip-rap to extend the riverbank and to control erosion. Approximately 90,000 tons of rock and sand were placed on the 2,300-foot riverbank. Both projects were designed to minimize present leakage and to help prevent more future leakage into the river.
37) What effect do the leaks have on fish and aquatic life in the Mississippi?
They are not believed to have any effect. The amount of material entering the river is infinitesimal compared to the flow of the river, which is about 1 million gallons of water per second.
38) What effect do the leaks have on communities downstream who draw their drinking water from the river?
There are no nearby communities downstream that draw their drinking water from the Mississippi River. Any material from the landfill that enters the river would be undetectable by the time it reaches downstream water users. (NOTE: The nearest community is Chester, about 75 miles downstream).
39) From a technical standpoint, is it possible to stop the waste from leaking into the river?
Experts could debate how "possible" this could be with enough reasons, money and time. In this instance, the reasons, not to mention the money and the time, may not warrant it.
40) Why was the landfill closed?
As our environmental standards increased, we restricted chemical disposal and then closed the landfill entirely.
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41) Where has the Kruirimrich plant disposed of its chemical waste since the landfill's closure?
Monsanto has a philosophy that the best way to deal with hazardous waste is to avoid making it in the first place. At the Krummrich plant, landfills are no longer used to dispose of routine process waste from its chemical manufacturing operations. The plant reuses and recycles materials wherever possible. The next preferable option is to treat or destroy the waste, with disposal the last option. Some chemical process waste is incinerated off-site.
42) Has anything been done to mitigate environmental damage at the landfill since its closure?
The landfill was capped with clay and grass was planted in 1979. In 1985, we completed a $1.5 million project to install rip-rap to extend the riverbank and to control erosion. Approximately 90,000 tons of rock and sand were placed on the 2,300-foot riverbank. Groundwater monitoring has been conducted for about ten years.
43) How will area residents and community leaders be kept informed about the project?
We will hold public meetings to explain the project and to answer questions. One will be held before the assessment of conditions at the site begins. Another will be held to discuss the results of the study and options for corrective action. We will also establish a repository at the Krummrich plant containing documents pertaining to the project. The documents will be available for public review.
44) Where can people see the investigation report and other documents pertaining to the project?
A repository at the Sauget Village Hall will contain documents pertaining to the project. Repository materials will be available for public review.
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45) What is Monsanto doing to prevent future hazardous waste problems like those at the former Krummrich landfill? Monsanto is working to reduce pollution from its operations, with the top priority being to avoid making waste in the first place. In 1988, we voluntarily initiated a program to reduce air emissions from toxic chemicals by 90 percent by the end of 1992. The goal was later broadened to include releases to all environmental media. Monsanto Chemical Company, the largest operating unit of Monsanto Company, has targeted a 70 percent reduction in the amount of organic and toxic inorganic process waste released into the environment by the end of 1995.
46) How many other hazardous waste sites in the Sauget area that Monsanto is involved in? When will they be cleaned up? Our Sauget plant has been in operation for more than 70 years. At an undetermined number of sites, Monsanto may be one of several responsible parties. We will be working with the Illinois Environmental Protection Agency and other parties in coming up with plans to investigate and remediate the sites as appropriate.
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Supplemental Questions and Answers Former Krummrich Landfill
l.Q. Why has it taken nine years for this lawsuit to be settled?
A. While we would agree we wish it had been settled sooner, there is no impact on public health. If there was an impact, it would have been settled sooner. We have been negotiating in good faith with the Illinois Environmental Protection Agency and the Illinois Attorney General's Office for some time on this matter.
Monsanto has not waited to take action in connection with the landfill. Before and after the suit, we have taken steps to protect the public health and the environment. We placed a two-foot-thick clay cap over the landfill when it was closed in 1977, in accordance with state law at that time for closing landfills, and planted grass on it to help prevent seepage of rainwater through the landfill. We also began a groundwater monitoring program and completed a $1.5 million project to install rocks and sand along the riverbank to control erosion.
2.Q. The attorney general says that for decades, "companies routinely dumped their waste by-products into the creek or buried them in makeshift landfills in the area." What does Monsanto say about that?
A. The former Krummrich landfill was built more than 30 years ago, in compliance with existing state law. However, landfill designs were not as sophisticated then and the state of environmental knowledge was not as advanced. The landfill was closed in 1977. It was capped with clay, in accordance with state law for closing landfills, covered with soil and seeded. It is completely fenced. Today, the Krummrich plant no longer uses landfills to dispose of routine process waste from its chemical manufacturing operations.
Prior to the 1930s, when the state of environmental knowledge was not as advanced as it is today. Dead Creek was used to discharge waste from a number of industrial and commercial operations in the area, including the Krummrich plant. Monsanto has not discharged waste into the creek for many decades. The company has a policy that the best way to deal with hazardous waste is to avoid making it in the first place.
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3.Q. The attorney general talks about a Monsanto "cleanup"; Monsanto's news release talks about "corrective action." Are these the same things?
A. Monsanto has agreed to assess the conditions at the former landfill and to evaluate alternatives for corrective action. It would be premature to speculate what those alternatives might be; that is the purpose of the investigation we will undertake. Whatever corrective action is chosen, it will protect the public health and the environment. Monsanto and the attorney general's office clearly agree on the course of action we are about to pursue.
4.Q. What is Monsanto's response to the attorney general calling the Dead Creek area "one of the most polluted sites in Illinois."
A. The former Krummrich landfill is only one of 18 sites -- 12 tracts of land and six sections of Dead Creek -that have been lumped together as the "Dead Creek sites." The reason these sites were consolidated by the Illinois Environmental Protection Agency is that none of them, on their own, pose enough potential hazard to warrant the expenditure of government investigation and cleanup funds. In fact, the former Krummrich landfill is about a mile from the creek. The waste in the landfill is not related to the chemicals in the creek, which were discharged by a number of industries and commercial operations in the area over many years. The attorney general has correctly noted that many other companies in the vicinity of Dead Creek are responsible for the contamination in the area.
5.Q. Isn't the $150,000 that Monsanto will pay the state a penalty for doing something wrong?
A. No, the money is to reimburse the state for the amount it spent to investigate and monitor the site -- so-called response and oversight costs.
6.Q. Will the remediation be a multi-million-dollar project?
A. We won't know the cost of remediation until the study is completed. The study will cost over $2 million.
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NEWS
FOR RELEASE
IMMEDIATE
Monsanto
CONTACT: Andi Smith, Monsanto (618) 482-6322 (W) (314) 832-1621 (H)
MONSANTO TO COLLECT SAMPLES FROM DEAD CREEK
Sauget, Illinois, October 11, 1991 -- Beginning Monday, October 14, Monsanto Company will be collecting soil samples from a portion of Dead Creek and adjacent sites to determine the types of chemicals present. The chemicals have come from a number of industrial and commercial sources over the past 75 years.
The Illinois Environmental Protection Agency is being kept informed of the sampling, as part of a long range environmental program by Monsanto to evaluate whether corrective action is warranted or feasible.
The part of the creek being tested runs from Queeny Avenue to Judith Lane in Sauget and Cahokia and is fully enclosed by a chain-link fence. Adjacent sites are also a part of the sampling due to their proximity to the creek.
None of the property is owned by Monsanto, however the owners of the properties are cooperating with Monsanto and its sampling program.
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Contingency Statement Dead Creek Sector B Testing Monsanto Company is collecting samples from a portion of Dead Creek and two adjacent sites to determine the types of chemicals present. The chemicals came from a number of industrial and commercial sources over the last 75 years. The part of the creek being tested runs from Queeny Avenue to Judith Lane in Sauget and Cahokia and is fully enclosed by a chain-link fence. The other sites are known as Sites L and M. The sampling is being done as part of a long-range, voluntary program by Monsanto to determine if corrective action is desirable or feasible. Because of the proximity of Sites L and M to the creek, the company believes that corrective action cannot be fully evaluated without more thorough knowledge of those sites.
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Questions and Answers Dead Creek Sector B
April 20, 1992
1. Q. Why is Monsanto doing this testing?
A. To learn the types of contamination present and to determine if corrective action is desirable or feasible.
2. Q. Why is the testing being done now?
A. No specific occurrence led to this present testing. It had been under consideration and it was decided to proceed.
3. Q. How much will the testing cost?
A. About $300,000.
4. Q. Where is Sector B of Dead Creek?
A. It runs from Queeny Avenue to Judith Lane, in Sauget and Cahokia.
5. Q. How long is that?
A. Sector B is approximately one mile in length.
6. Q. How much water is in the creek?
A. Water levels in the creek vary substantially, depending on
rainfall, and during extended periods of low
.
precipitation, the creek can become a dry ditch.
7. Q. What chemicals are in the creek?
A. The sediment contains a variety of organic chemicals and metals.
8. Q. Has dioxin been found in the creek?
A. No.
9 . Q. Have PCBs been found in the creek?
A. PCBs have been found in some previous samples of sediment taken from Sector B.
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10. Q. Where did these chemicals come from?
A. The chemicals came from a number of industrial and commercial sources over a period of 75 years.
11. Q. Are health hazards posed by these chemicals?
A. Some of the chemicals are considered hazardous if they are not contained properly. The chemicals in the creek are contained because the culverts have been blocked off at Judith Lane and Queeny Avenue, creating a surface impoundment that holds the water in place. The creek segment is also fully enclosed by a chain-link fence. No drinking water is drawn from the creek. There is little likelihood of public contact and thus, there is believed to be no health risk.
12. Q. What property is adjacent to Sector B of the creek?
A. There are about a dozen industrial, commercial and residential properties adjacent to Sector B.
13. Q. Is Sector B accessible to the public?
A. No. The creek is encompassed by a chain-link fence installed in 1982.
14. Q. Has the health of nearby residents been affected by the chemicals in the creek?
A. No, because there has been little likelihood of public contact with the chemicals in the creek.
15. Q. One resident has claimed that his dog went in the creek and then died of chemical burns. What does Monsanto say about that?
A. Monsanto did not investigate that incident. We only know what we heard from the IEPA and newspaper accounts.
16. Q. How did Monsanto's chemicals end up in Sector B?
A. We do not know for certain that they did. However, prior to the 1930s, when the state of environmental knowledge was not as advanced as it is today, Dead Creek was used to discharge wastewater of a number of industrial and commercial operations in the area, including the Krummrich plant.
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17. Q. Does Monsanto still discharge waste into the creek?
A. Monsanto has not discharged wastewater into the creek for more than 50 years. Monsanto has a philosophy that the best way to deal with hazardous waste is to avoid making it in the first place. At the Krummrich plant, great emphasis is placed on waste-minimization efforts. The plant reuses and recycles materials wherever possible. The next preferable option is to destroy or treat the waste, with land disposal the last option.
Wastewater from the Krummrich plant is treated three times before it is discharged into the Mississippi River. First, it goes through a $25 million pretreatment system at the plant, in which 11 organic chemicals are removed and levels of six others are reduced. It then goes to the Sauget Physical-Chemical Primary Treatment Plant, where acids are neutralized and solids and heavy metals are removed. The wastewater then flows to the American Bottoms Regional Wastewater Treatment Plant, where organic chemicals are removed.
18. Q. Have all the adjacent property owners given permission for the testing?
A. No, several property owners have not.
19. Q. Which property owners have not granted permission?
A. Cerro Copper, Wiese Engineering and Hankins. However, we have agreements from everyone we need and are able to move forward.
20. Q. Why have these property owners refused to give permission for testing?
A. We can't speak for them.
21. Q. How will the lack of access affect testing?
A. Monsanto will be able to work around the properties.
22. Q. How long will the testing take?
A. The testing is expected to take several months.
23. Q. Who will do the testing?
A. Geraghty and Miller, an environmental engineering firm, will do the testing.
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24.Q. Will the workers wear protective clothing?
A. Yes, the workers will be appropriately protected.
25.Q. Will the IEPA oversee the testing?
A. We have provided the agency with a sampling plan and they are invited to oversee the work if they feel that it is necessary.
26. Q. Will the test results be made public? How and when?
A. We will work with the IEPA to assure the public availability of the test results.
27. Q. How is it possible to confine testing and/or corrective action to only part of a creek? Wouldn't the flow of water spread the contamination?
A. Because the culverts have been blocked off at Queeny Avenue and Judith Lane, Sector B is like a surface impoundment, holding water in place. In addition, the IEPA has done sampling downstream and found minimal residual contamination.
28. Q. Where are Sites L and M?
A. Site L is a former surface impoundment used by a hazardous and special waste hauler to dispose of wash water from truck cleaning. The former impoundment is approximately 250 feet south of the present Metro Construction Equipment Company building and about 125 feet east of Dead Creek in Cahokia.
Site M, in Cahokia, is a former sand pit excavated by H.H. Hall Construction Company in the mid- to late 1940s. It is immediately east of Dead Creek and approximately 300 feet north of Judith Lane.
29. Q. Why is Monsanto also testing Sites L and M?
A. Monsanto is testing Sites L and M because they are adjacent to Sector B of Dead Creek. Because of their close proximity to the creek, we believe that corrective action cannot be fully evaluated without more thorough knowledge of those sites.
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30. Q. Who owns Site L?
A. Site L is owned by Metro Construction Equipment Company. The site is covered with cinders and is used for equipment storage.
31. Q. How big is Site L?
A. According to state studies, the dimensions of the former surface impoundment were approximately 70 feet by 150 feet. The site is now covered with cinders and is used by Metro Construction Equipment Company for equipment storage.
32. Q. Is Site L accessible to the public?
A. Access to the area is not controlled.
33. Q. What chemicals have been found at Site L?
A. According to state studies, previous water samples taken from a nearby monitoring well have indicated the presence of such organic chemicals as chlorophenol, phenol and cyclohexanone, as well as heavy metals. Previous surface soil samples were found to contain alkyl benzenes, dichlorobenzene, dichlorophenol, hydrocarbons, napthalenes, trichlorobenzene and PCBs.
34. Q. How did Site L become contaminated?
A. According to state reports. Site L is a former surface impoundment used by a hauler to dispose of wash water from truck-cleaning operations.
35. Q. Who owns Site M?
A. Site M is a sand pit excavated by the H.H. Construction Co. in the mid- to late 1940s.
36. Q. Is Site M accessible to the public?
A. No. Site M is enclosed by a chain-link fence that also encompasses Sector B of Dead Creek.
37. Q. How big is Site M?
A. Site M is approximately 275 by 350 feet, and the estimated depth is 40 feet.
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38. Q. What chemicals have been found at Site M?
A. According to previous state studies, water samples showed no significant contamination, although water-quality standards for copper, phosphorous and zinc were exceeded. Trace levels of PCBs were also found in previous water samples. Previous sediment samples indicated the presence of several chemicals, including cadmium, chromium, copper, lead, nickel, zinc and PCBs.
39. Q. How did Site M become contaminated?
A. The IEPA has no information concerning waste-disposal activities at Site M, however, flow from Dead Creek Sector B can go into Site M.
40. Q. Why is this testing needed if the IEPA tested all the Sauget sites in 1988?
A. The IEPA testing was not extensive enough to determine if corrective action is desirable or feasible.
41. Q. What will Monsanto do after the test results are known? Will the company clean up Sector B?
A. Monsanto will use the information gained from the sampling to evaluate corrective action.
42. Q. What options for corrective action will be considered?
A. They will be determined once the sampling results are known.
43. Q. Will Monsanto pledge to clean up Sector B voluntarily since Cerro Copper cleaned up Sector A voluntarily?
A. We can't make that commitment without the kind of information these tests are designed to provide.
44. Q. If Monsanto won't voluntarily clean up Sector B, can the IEPA file suit to force Monsanto to do so?
A. The IEPA has a number of enforcement options although we hope none will be necessary.
45. Q. Will Monsanto clean up Sites L and M?
A. We will not know until the testing provides more information about what is there and what, if anything, needs to be done.
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-746.Q. Should the creek have been cleaned up earlier?
A. Access to the site is limited, so exposure is limited. The chemicals in the creek need to be addressed, but do not present an immediate hazard.
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CONTINGENCY STATEMENT DEAD CREEK SECTOR A REMEDIATION
We are disappointed that Cerro Copper Products Co. has chosen to take this action. We have been discussing this matter with Cerro since June and believe we have made substantial progress. We hope we still can.
The chemicals in the creek came from a number of industrial and commercial sources over the last 75 years. As a result, we believe the best approach would be a broader one addressing the whole creek. We have invited Cerro to work with us on the entire Dead Creek issue, and we hope they will do so.
Last fall, Monsanto took samples from Sector B of the creek and from two adjacent sites to determine the types of chemicals present. The sampling work was done in cooperation with the Illinois EPA as part of a long-range, voluntary program by Monsanto to evaluate whether a corrective action is desirable or feasible. Test results are still being analyzed.
Cerro decided on its own to do the remediation work in Sector A of Dead Creek, in agreement with the Illinois Environmental Protection Agency and the Illinois Attorney General's office. The work was done entirely on Cerro's property. Monsanto believes it has no liability in this situation.
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CONTINGENCY QUESTIONS AND ANSWERS DEAD CREEK SECTOR A REMEDIATION
1. Q. Did Monsanto discharge waste from its Krummrich plant into Sector A of Dead Creek?
A. While there are materials in Sector A that likely were produced at Monsanto's Krummrich plant, there are other ways that they could have entered the creek, rather than directly from the plant. Private haulers, for example, used to clean out their tank trucks in the creek.
2. Q. Was Sector A a conduit for Monsanto's sewer flows from the Krummrich plant?
A. For the last 50 years, Monsanto's wastewater has been discharged into the Sauget village sewer system. In the event of a sewer overflow, it is extremely unlikely that any substantial amount of flow would have backed up into Sector A of the creek.
3. Q. When will the results of the sampling from Sector B be available?
A. We are still analyzing the test data. We are hoping the results will be available this spring or summer.
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The Krummrich Plant: A Commitment to Waste Minimization
Monsanto's W.G. Krummrich plant in Sauget has made a strong commitment to reduce the amount of waste it generates through significant financial investment and employee involvement. This in turn has helped improve the environment in the Metro East area.
The plant has reduced air emissions of hazardous chemicals by 64 percent in just three years. It is more than two-thirds of the way toward the Monsanto goal of reducing such emissions by 90 percent by the end of 1992, with the ultimate goal of zero effect.
In addition, the plant has pledged to reduce releases of most process waste by 70 percent by the end of 1995 -- from nearly 10 million pounds to fewer than 3 million pounds. Projects have been identified to eliminate 67 percent of the organic and toxic inorganic process waste by the end of 1993.
These waste-minimization goals are being achieved by a wide range of projects, from new seals on tanks that prevent the escape of vapors to a $25 million investment in equipment to remove chemicals from wastewater leaving the plant.
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Greatest emphasis is placed on not generating waste in the first place. Materials are also reused or recycled wherever possible. The next preferable option is to destroy or treat the waste, with land disposal the last option. The Krummrich plant no longer uses landfills to dispose of waste from chemical manufacturing processes.
"Hands-on" involvement by Krummrich employees has been an important key to the waste-minimization progress. Many of the 630 employees live in the Metro East area and have a personal interest in working to improve the local environment.
As the plant has worked to meet its waste-minimization goals, it has remained open and responsive to the community. Reducing waste and being open to the community are two components of the Monsanto Pledge, a seven-part management initiative on health, safety and the environment that governs all of the company's operations.
For years, the Krummrich plant has made public information about the content of its waste and all chemical materials. The plant also was the first Monsanto facility to form a community advisory committee to discuss environmental and safety issues with neighbors who live and work near the plant.
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The Krummrich Plant At A Glance The Krummrich plant is the second-oldest plant in the Monsanto family. It began operation in 1907 as the Commercial Acid Company and was purchased by Monsanto in 1917. It is the largest Monsanto plant in the St. Louis area and a major economic force. In 1990, the plant had 630 employees and a payroll of $32,585,000. The plant operates 24 hours a day, seven days a week, producing more than 500 million pounds of chemicals a year. The 12 different chemical products made at the plant are used in such diverse items as swimming pool sanitizers, oil additives, dry cell batteries, mothballs, scouring powders, automobile tires, inks, dyes and non-aspirin pain relievers.
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Wastewater Pre-Treatment: $25 Million Investment in a Cleaner Environment
Monsanto has invested more than $25 million in equipment to pretreat wastewater leaving the Krummrich plant, going far beyond what was required by environmental regulations.
The equipment removes 11 organic chemicals covered by recent federal regulations, plus reduces six additional organic chemicals. In all, 1.8 million pounds of organic chemicals are removed from the plant's wastewater each year. Of these, 1.2 million pounds are recycled and reused.
The pretreatment system, which began operation in November 1990, was the largest engineering effort ever undertaken at the Krummrich plant. Construction involved: 1200 engineering drawings 640 new instruments 150 trucks of concrete 71 miles of new wire and cable 80 new tanks, pumps and heat exchangers 5 miles of pipe
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About 4 million gallons of wastewater leave the Krummrich plant daily for off-site treatment. The wastewater goes first to the Sauget Physical-Chemical Primary Treatment Plant, where acids are neutralized and solids and heavy metals are removed. The wastewater then flows to the American Bottoms Regional Wastewater Treatment Plant, where organic chemicals are removed.
With the new pretreatment system, the plant's wastewater is treated three times before it is discharged to the Mississippi River.
The pretreatment system has three components: a carbon treatment unit and two steam strippers designed to treat different chemicals.
Carbon Treatment Carbon treatment removes from wastewater low concentrations of organic chemicals from the plant's departments that produce rubber chemicals and an ingredient for Monsanto's Saflex interlayer for windshields and windows. After neutralization, the wastewater is fed through four carbon towers, where the organic chemicals are absorbed by activated carbon. The system pretreats 24 million gallons of wastewater a year and removes 600,000 pounds of organic chemicals. The saturated carbon is sent to a facility in Pennsylvania, where the chemicals are removed and incinerated. The recycled carbon is then returned to the plant for reuse.
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Steam Stripping
Although it would have been cheaper and easier to use carbon treatment to pretreat all of the plant's wastewater, plant officials were guided by Monsanto's policy of recovering and reusing materials wherever possible. As a result, steam strippers were installed to recover volatile organic chemicals from wastewater.
Steam is used to "strip" or separate the chemicals from the wastewater. The wastewater is boiled, and the organic chemicals boil off -- or vaporize -- at different temperatures than the water. The chemical vapors are condensed into a liquid for reuse at the plant.
Monsanto is required by federal law to pretreat monochlorobenzene -- an ingredient in Lasso herbicide -- and it is essentially eliminated from the plant's wastewater through steam stripping. Ninety-five percent of the nitrochlorobenzene, which is used to make non-aspirin pain relievers and dyes, is also removed, even though it is not required. The equivalent of four tank trucks of nitrochlorobenzene is recovered each year.
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Bioremediation: Waste-Minimization Technology of the Future
Monsanto continually searches for new and better waste-minimization technology. Bioremediation is a promising technology for the future.
Bioremediation uses bacteria found naturally in the environment to digest organic chemicals in wastewater. Scientists give the bacteria an optimal amount of oxygen, water and nutrients to encourage them to digest the chemicals.
For a year and a half, Monsanto scientists have tested bioremediation to pretreat certain types of wastewater from the Krummrich plant, with good results.
The bacteria have come from the American Bottoms Regional Wastewater Treatment Plant, where they are accustomed to digesting small quantities of similar chemicals. They are grown on "beads" made from diatoms or activated carbon and then mixed with the wastewater. The increased concentration of bacteria, plus the optimal environment, result in more effective removal of chemicals.
Monsanto scientists hope that some day, bioremediation can replace carbon pretreatment of wastewater at the Krummrich plant and at other Monsanto facilities.
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New PDCB Crystallizer Eliminates 1 Million Pounds of Waste
The Krummrich plant's new $5 million process for making paradichlorobenzene (PDCB) -- the main ingredient in mothballs -- is proof that what's good for the environment can also be good for business.
The PDCB Continuous Crystallizer has increased production by 36 percent while eliminating 1 million pounds of waste that had been discharged to the air and water annually.
Basically, the crystallizer works like a giant ice cream maker. A liquid mixture is chilled and crystals are formed that are almost 100 percent pure PDCB.
The operation is self-contained -- all the chemicals remain enclosed in vessels or piping -- and emissions to the environment have been virtually eliminated.
Monsanto's worldwide search for a more efficient -- and more environmentally sound -- way to make PDCB began in 1986, when it was projected that the Krummrich manufacturing process could not easily meet growing demands for PDCB. The new crystallizer, which began operating at the end of 1989, is the first in the United States to use this technology.
Monsanto's customers repackage PDCB as mothballs and use it to make bathroom cleaners, deodorizers and high-strength plastics.
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Other Waste Minimization Projects
Several other significant projects to reduce waste have been
completed or are in the works at the Krummrich plant. They
include:
A new $1 million centrifuge in the department that makes an ingredient used in rubber chemicals has reduced air emissions of xylene, a raw material, by about 300,000 pounds a year. Plans call for replacing several other pieces of equipment in the department with a "melt surge tank system," which will eliminate an additional 400,000 pounds of xylene emissions annually.
Improvements in the process to make swimming pool sanitizers have reduced air emissions of chlorine from 400,000 pounds in 1987 to 100,000 pounds last year. The reductions were achieved through improved instrumentation, added packing material in the scrubber, improved chlorine absorption in the process and modifications made to improve raw material yields. A $1.2 million scrubber project planned for the end of this year or early next year is expected to further reduce emissions.
An old filter tank in the paranitroaniline department, which makes an ingredient used in animal feeds, pharmaceuticals and rubber chemicals, was replaced with one of improved design. It collects more product for sale that would otherwise go to the sewer. Emissions are reduced by 100,000 pounds a year. The project cost $480,000.
A bulk rail car loading system was installed in January in the phosphorus pentasulfide department, which produces an additive used in motor oil to prevent engine wear. The new system reduces air emissions by 6,200 pounds a year and non-hazardous liquid waste by 44,900 pounds a year.
Three new scrubbers were installed in the nitrochlorobenzene department at a cost of $500,000. They reduce air emissions by 76,000 pounds a year. The department makes a chemical used in non-aspirin pain relievers and dyes.
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Within the Plant and Beyond the Gates
The Krummrich plant works closely with neighboring industries, fire and police departments and emergency service and disaster agencies to develop emergency plans and to share resources. Joint drills and mutual aid cooperation help ensure the highest level of community protection.
The Krummrich plant was one of the founding cosponsors of the St. Clair County Community Awareness and Emergency Response (CAER) program, which seeks to improve the protection of public health and safety. CAER is a detailed emergency response plan that involves local public safety officials and industry to provide procedures for handling emergencies and for communicating safety information to area residents.
The plant also fully supports and participates in Responsible Care, the Chemical Manufacturers Association's initiative to respond to public concerns by continuously improving the industry's responsible handling of chemicals.
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The plant has been designed with safety devices that
detect problems early and warn employees so incidents can be
prevented. In addition, the plant led the chemical industry by
installing a community warning system in 1984.
The Krummrich plant also sponsors safety and emergency
training for area fire departments and has a reciprocal agreement
with Scott Air Force Base for the use of foam to fight certain
chemical fires.
The plant also has its own fire department, an emergency
response team and an emergency medical technician squad on-site.
The emergency response team is on call 24 hours a day to handle
any plant emergency.
The plant fire department can respond to a fire call
within minutes. There are 70 fire hydrants throughout the plant,
capable of delivering more than 1 million gallons of water to put
out fires quickly.
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Within the plant, safety is the Number One priority.
Monsanto works constantly to ensure that the plant's safety
equipment is the most modern available. The plant's target is
zero injuries, and the safety record has improved steadily. Over
the last four years, injuries have decreased by more than 40
percent.
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-3Monsanto has joined with labor unions to help promote emergency response training. Instructors from the International Chemical Workers Union Center for Worker Health and Safety recently conducted a three-day hazardous materials response course at the plant. This was the third time that the course has been offered at the plant. On the last day of the course, plant employees applied what they had learned by responding to mock emergencies. The drill was videotaped so employees could evaluate their performance. An employee committee was formed in February to develop an environmental training program for plant employees. Training is expected to begin this fall. All employees will receive general training on environmental issues; business units and manufacturing groups will undergo a more comprehensive and technical program.
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Community Responsiveness
At the Krummrich plant, being open and responsive to the community is an integral part of daily operations.
The plant was the first Monsanto facility to form a Community Advisory Committee to discuss safety and environmental issues with neighbors who live and work near the plant. Other chemical plants have looked to the Krummrich plant for guidance in establishing their own committees.
The committee has met quarterly since September 1988. The goal has been to form a partnership with the community by ensuring that plant operations meet or exceed community expectations. The committee is made up of representatives from nearby communities, emergency response agencies, hospital administrators and plant employees.
The committee discusses safety and environmental issues, reviews emergency communication and safety programs and discusses preparedness procedures. It also serves as a conduit between the plant and community, channeling suggestions to the plant and updating local residents on plant progress.
The committee is one way Monsanto is working to meet its goal of keeping plants open to the communities in which it operates. Another way is by inviting the public to visit the plant and to learn more about its operations. Plant employees also visit local schools to talk to students about chemicals and the environment.
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Monsanto in the Community
The Krummrich plant and its employees are actively involved in a wide range of community programs, from education to job training to helping the needy. The plant received the 1991 Salute to Southwestern Illinois Award for Community Service from the Leadership Council of Southwestern Illinois.
The Krummrich plant and the Monsanto Fund sponsor an after-school center and summer field trip program through the Villa Griffin Homes and other public housing projects in East St. Louis. "St. Louis is rich in all kinds of cultural and scientific opportunities, but not for a kid stuck in a housing project," says Sister Julia Huiskamp, who runs the program. "Monsanto's contribution has helped hundreds of East St. Louis children see the bigger world and have fun together." The Krummrich plant has been a longtime partner with Target 2000, a non-profit organization aimed at revitalizing East St. Louis. As a major contributor to Target 2000 since its founding in 1978, Monsanto has helped the organization implement economic development programs, including the Bluffview Estates apartment project. The Krummrich plant and the Monsanto Fund support the new Jackie Joyner-Kersee Foundation, which helps youths in East St. Louis develop into tomorrow's community leaders. The program emphasizes academic preparation and development of community consciousness.
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2- Monsanto donated $5,000 to help fund a business education program at the GEMM Center in East St. Louis. Thirty youths, age 12 to 19, will be taught the basics of business, including taxes, banking, advertising and legal issues. Each student will be required to start his or her own small business before the course is over. Through the Monsanto Fund, the plant also supports the United Way, local fire departments and emergency services and disaster agencies, Belleville Area College, H.I.S. K.I.D.S. for seriously ill children, St. Mary's Hospital, Bicycle Safety Rodeo, Boy Scouts and Girl Scouts, St. Clair County Local Emergency Planning Committee, Illinois Center for Autism job training program, MECCO community action organization in East St. Louis and the East St. Louis School District Science Fair.
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