Document zQ49pndVy2qwk86E7z09M8210

MANAGEMENT PLAN POLYCHLORINATED BIPHENYL EMVIRONMENTAL PROBLEM THE PROBLEM The presence of materials Identified as polychlorinated biphenyl (PCB) In marine environments was first noted by Professors 0. 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 PCB In marine and 'animal-life. ino posing 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 (AroclorB) worldwide and has been mentioned In many of the reports. 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 tlmlPJbf any precipitous action by the press, competitors, public or governmental agency, we are forced to commit our limited resources in several directions. We are aotlvoly-seeklng Information regarding the toxlolty and blodegradabi-ity~uf Aruciors, Improving analytical techniques, developing processes for reclaiming Areelors Mhl/lh hn fnr- fiirthn. <, developing methods for oomplote destruction by Incineration, controlling our plant effluents, working with our oustnmorn to-control and eliminate environmental pollution with Areelors-and doveloplng-alternate products for thoe-e lAroelon nspw which rinnnt-b controlled and whl-oh muot-be PBeSn^fmed. ^ We are deliberately assuming an aggressive 'posture and working cloBely 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 thlB information it.was surmised that the lower chlorinated biphenyls were being degraded and probably were not a problem. Consequently, MONS 035413 -2- a decision was made to plan to discontinue the manufacture of Aroclors 1254 and 126,0. 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, Oenoral Eleetrlo Company, has strongly Indicated that the threat of explosions and fires and loss of electrical service Is so great that the use or Aroclor 1254 and 1260 cannot be discontinued. Keen nf Aresisrs Whloh lead to environmental__ml namrnt he controlled will.he dli cUv applieatiafig, coalings 'un surfaces exposed to feed-er potable water end NCR piper. Ill, 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. 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 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. HONS 035A1A -3- 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. IV. ACTION PLAN 1. Objective - Reduce and effectively control the PCB content of all effluent from Monsanto plants. Status - A tentative target of 10 ppb of PCB in plant liquid effluent has been established. Plants at Anniston, Alabama, Newport, Wales and Sauget, Illinois have monitored plant effluents and found high levels of PCB 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 Interceptor basins to contain major spills. Action - All plants to continue emphasis on control to achieve target of 10 ppb in effluent. Responsibility - Manufacturing Manager Engineering Manager, Functional FluidB, CED Manager, Research & Development, Functional Fluids Date - All plantB achieve 50 ppb in effluent by January, 1971. All plants achieve target of 10 ppb by September, 1971. MONS 035415 /\ C l-r M _ -- To o^ure. ~b y hf ^-{V # -t A.-OC (fu uiot "Hut. ts S-C- e^" "i~ ' by 'H**' P/fioAc !-f {?rU U /3 W , / t .A s .V ^>*->1 $ / hilt ly - ^1 / ^Cc l_v * P^O 5,/iC ' CorOt jji. Dqlc - l^-<4-4 Co j flow 4^ pkjO yt- Ook - I'litUf^ 1 , ' ? 70 Lct-Z- p - Oc^ - <?e/, /^i- MONS 035416 -4- .2 ObJectlve - Inform customers of the PCB problem ana the importance of preventing environmental j 'a pollution both at their plants or by their products. *1 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. if Responsibility - Sales Directors, Functional FluldB J v and Plasticizers Croups 4 Date - Canada, U.K. and Japan by Hay 1, 1970 Europe and South America - as indicated. 3. Objective - Develop products to replace Aroclors ^ for those uses in which Aroclors have been demonstrated k ? to be harmful to the environment, are resistant to 4j biodegradation, and cannot be prevented from escaping to the environment, o Status - Work on product substitutes has been directed primarily at Industrial Fluids applications > and NCR Paper coating. Water-glycol mixtures, bromlnated Aroclors, bromlnated biphenyl, Blllcates, ^ blends using chlorinated terphenyls with lower chlori- ^ nated biphenyls, terphenyls with phosphate esters, ^ biphenyl ether with biphenyl, chlorinated paraffins, and fractionated Aroclor 1242 are all under wturtu--^ for Functional Fluids application. ^Alkylated biphenyls and HB-40 (hydrogenated terphenyls) appear promising for NCR paper applications. j Action - Replace Aroclor 1242 in NCR paper coating with isopropylbiphenyl for U.S. applications and with HB-40 (hydrogenated terphenyl) for U.K.applications. Responsibility - Manager, Research and Development, Plasticizers Oroup; Sales Director, Plasticizers Oroup tec. Date - U.K. applications - complete by April, 1970 U.S. applications - complete by Juts, 1971 4fhl MONS 035A17 -5- Actlon - Develop acceptable substitutes and complete conversion from Aroclor 1254 and 1260 In Sealants and coatings. * Responsibility - Manager, Research & Development Plasticizers Oroup Sales Director, Plasticizers Oroup Date - January, 1971 ,, . ,, . fivt-li. Action - Develop acceptable substitutes and selec- r tivlfc- phaseSout of Aroclor containing Industrial fluids. o rtU (* tr^c) Responsibility - Manager, Research & Development Functional Fluids Oroup Sales Director, 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 IISo - Oec.m'n*, "T>u 4. 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 HONS 03541* -6- 5. Objective - Develop methods for effective disposal of wastes containing PCB without contaminating the environment. Status - Studies ai'e being conducted on blodegradability. Incineration and removal from water solutions. Blodegrad&blllty studies of existing and substitute products with aclimatized microorganisms are being conducted at Ruabon. Data to date Indicates that the monochlor and some of the di and trlchlor 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 f indicate combustion can be sustained with minimum --ruel requirements?* $tack gas BampleB taken for nnwlysln tn iitermlnn lieirree nf* Jarl-rmntinn indicated degree of destruction to be acceptable. Recovery of Aroclore from dilute water solutions is being studied at Anniston and by MRC at Dayton. At Anniston, adsorption on carbon Is being evaluated. At Dayton, the use of add clays, limestone stttea .. and treated silica are being studied. 5trio^ c*n ;<-w -fo Solicit''"'} a 0)rnvT ft' a. pnhvil't mu >< wo At the W. 0. Krummrich plant, the removal of Aroclors from HC1 gas streams by high temperature cracking are being studied. Discussions have been held with representatives of Monsanto Enviro-Chem Systems regarding disposal of Aroclors, solids containing Aroclors and water con taining Aroclors. Proposals for the testing at the St. Charles unit of disposal by pyrolysis were requested. Further work on water effluents is planned following the analysis of samples from various customers' plants. Action - Continue biodegradation work of existing and substitute products at both Ruabon and St. Louis to establish degree of degradation possible and optimum conditions required. Responsibility - Manager, Research & Development Functional Fluids Group Date - October 1, 1970 HONS At. 1-7 vi ' /TV<r /uc((^ ^ o pj>ly " y CCKK '^v'CVh YKyj CCj>j>-a-~a)^.i.{{ --ffaa I * '> /-& G- r^t/x rr^ty*rif>y-t'Citfi Pck\F*y*\ pl^KJ' *^Cuii pn> L/inil ^ r-tXf- <--/W-- `'g^' O^' ^y'`/$VT*( , A6?!t Gyn/i r-m /i-i/^A-C^ GrthrC. 1 ^t^ivue-A. iPt-vW fctviCrjuye.i!' FtyiStL f?(Vl -.. FliSlfiv GrcJup- [vyvJrisi' I, i <r>o HONS 035420 -7- Aetion - Evaluate alternate methods of disposal by Incineration - Monsanto operated vs. contract. Responsibility - Engineering Manager, Functional Fluids Group, CED Pate - July 1, 1970 Action - Continue the work at Anniston, Krummrlch and Payton on the removal of PCB from water streams. Responsibility - Manager, Research and Development, Functional Fluids Oroup. Date - September 1, 1970 o ----------- Action - Pursue possible contribution by Monsanto Enviro Chem SyBterns, Inc. to disposal of Aroclor wastes. Responsibility - Manager, Environmental 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 Flndett, Inc. Arrangements have been made for the reworking of a tank car of material at W. 0. Krummrlch 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 8c Development, Functional Fluids Croup Manufacturing Manager Date - May 1, 1970 Action - Select and modify as necessary, the required equipment at the W. 0. Krummrlch plant. Responsibility - Manufacturing Manager Date - Appropriation request by June 1, 1970 Fully operational by January 1, 1971 . MQNS 035A11 -8- 7. Objective - Determine effects of PCB's on birds, aquatic life, animals and humans. Statua - Toxicity studies are being made for Monsanto by Industrial Bio-Test Laboratories. Studies Include two year oral toxicity on ratB, three generation reproduction study on rats, two year oral toxicity on dogs and studies on egg production, hatchability and survival on chickens. The Aroclors used In these studies are Aroclor 1242, Aroclor 1254 and Aroclor 1260. Results to date Indicate the following: Liveren largement in male ratB at 100 ppm; body weight^Loss 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. T+ P8'> **- cU*4-w< 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 *or extending studies to include chlorinated terphenyls, hydrogenated terphenyls, alkylated biphenyls and Poroeel 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 PCB problem In a manner which will maintain our excellent relationship. Responsibility - All personnel Date - Continuing muns 035422 -9- V. COSTS Costs for the program for 1970 have been budgeted as follows: Program Budget $M Develop Analytical Procedures Toxicity Studies Plant Effluent Studies Blodegradabillty Studies Develop Disposal Methode Reclaiming Systems Design Substitute Products Overall Administration $ 80 105 105 40 50 30 150 115 Total $675 MQNS 035423