A town forever changed by Monsanto
Anniston, Alabama: Pollution Problems in Anniston
"It is impossible to establish a limit as to what can be discharged "safely". Investigation has shown that the waters in receiving streams below the Anniston Plant contain significant (parts per million) concentrations of PCB. More ominous perhaps is the fact that sediment in the bottom of these streams miles below our plants may contain up to 2% Aroclor." ["Confidential Report of Aroclor Ad hoc Committee"; October 2, 1969]
Nobody knows the exact quantity of pollution Monsanto discharged from its Anniston plant into the local waterways. Certainly, the amount was not insignificant, and likely exceeds the amount dumped by General Electric into the Hudson River (an estimated 1.3 million pounds). While the discharges to water aren't clearly established, there are incomplete records that show Monsanto dumped at least 5.5 million pounds of PCBs in landfills located near the plant. [document] What is clear from the documents is that Monsanto was never able to control its discharges effectively throughout the entire 37 year period of PCB production, and even beyond.
A company report from March 21, 1969 revealed the extent of PCB production and details the company's thoughts about the source and severity of environmental contamination:
"From the background data presented it appears that something of the order of 80 million pounds of polychlorinated biphenyls (PCB) are produced annually. These products contain from 3 to 9 chlorine atoms per molecule and become increasingly inert and stable to environmental oxidation with higher degree of chlorination. However, about half the production is in the 3-chlorine atom variety (Aroclor 1242).
At first thought it seems unlikely because of the major uses of PCB in capacitors, transformer oils, heat transfer fluids in closed systems, that these materials could be the source of the substantial degree of environmental contamination reported. However, about 40 million pounds annually is stated to be used as plasticizers, hydraulic fluid, adhesives, and in carbon paper. From this amount a very substantial percentage must escape into the environment as waste. Because of the apparent high stability of PCB, amounts entering the environment would be degraded very slowly and it seems possible that at least 10 million pounds annually may become environmental contaminants. Since the PCB's were introduced commercially in 1929 there have been 40 years of production. If this has averaged 50 million pounds per year, then about 2x109 have been made and perhaps 2 x 108 pounds have entered the environment. Because of the apparent stability of these compounds most of this amount may still be circulating in the global ecosystem and this is suggested by the levels reported by Holmes et al. (1967) and Risebrough et al. (1968) in animal tissues which are quite comparable to those found for DDT. Both PCB and DDT are extremely stable and water insoluble and have been produced in roughly the same total amounts over the past 30 years. Thus it seems quite reasonable to conclude that the environmental contamination described for PCB is due to waste amounts of these compounds. This, coupled with the thorough evidence from mass spectometry strongly suggests that there is an important environmental quality problem involved in wastes of PCB. [Report and Comments on Meeting on Chlorinated Biphenyls in the Environment at Industrial BioTest Laboratories, Chicago; March 21, 1969]
"We should begin to protect ourselves"
By 1969, Monsanto was feeling the pressure of government attention toward its Anniston, Alabama plant. The company's documents clearly show that Monsanto was trying to stay a step ahead of the interested government agencies, attempting to assess on its own the extent of the contamination near the plant in advance of any potential investigation. The company wasn't interested in cleaning up the contamination at this point, preferring to assess the situation and then wait and see what the regulators would do.
"With the likelihood that the attention now being focused on presence of aroclors in natural waters will draw attention to any aroclor being sewered in our production plant outfalls, we should begin to protect ourselves. Since the problem, if any, has not yet been defined, I'm recommending at this time only action preparatory to actual clean up." [Hodges memo Aroclors in Plant Effluent; January 23, 1969]
In a letter describing the results of sediment and water sampling in Snow Creek near the Anniston facility which showed significant PCB pollution, a Monsanto employee explains the need to prepare due to the likelihood that the government might look into the problem.
"Bill, on the basis of this information, I think that if the PCB accusation turns out to be true and the government people become more active, we should plan on an extensive evaluation of the extent of contamination in this area. For example, samples should be taken further down Snow Creek, down Choccolocco Creek and even from the Coosa River if necessary." [E.S. Tucker to Richard & Wheeler Re: Aroclor-Wildlife; February 25, 1969]
While it looked farther afield from the plant for evidence of contamination, Monsanto found it had a serious problem in Anniston regarding its pollution of the waterways, as it noted in this May 12, 1969 correspondence. Again, no one in Anniston or downstream was warned.
"A. Definition of Problems
1. External to Plant-- that a problem exists at Anniston is evident because "free" globules of aroclors can be seen in Snow Creek. We do not know what problem exists in Choccolocco Creek and the Coosa River. By July 1, 1969, we will determine the limit of visual evidence of aroclors downstream in Snow Creek." [Letter from Hodges to Kuhn; May 12, 1969]
In 1969, the Anniston plant was discharging about 250 pounds of PCBs into Snow Creek a day, according to an internal memo marked "CONFIDENTIAL-F.Y.I. AND DESTROY." [Hodges to Bergen Confidential FYI and Destroy; August 7, 1970]
The possibility that government investigations might discover what company officials already knew remained a major worry for Monsanto, and became more ominous as the company learned more about the severity of its PCB effluent problem. In an internal Monsanto communication from September 9, 1969, with the subject heading "Defense of Aroclor," the company worried about the result of a potential investigation:
The Department of Interior and/or State authorities could monitor plant outfall and find ppm of chlorinated biphenyls at Krummerich or Anniston anytime they choose to do so. This would shut us down depending on what plants or animals they choose to find harmed." [W.R. Richard to E. Wheeler]
The last thing Monsanto needed was another massive discharge from the Anniston plant just when the government might come knocking on its door. In November 1969, an equipment malfunction at the plant resulted in the loss of some 1,500 gallons of PCB into the sewer. This memo describes the scene:
"On Thursday (November 6, 1969) the line on the bottom of the #3 Aroclor still receiver failed which resulted in the loss of approximately 1,500 gallons of Aroclor 1242 to the acid sewer. To date we have only been able to recover approximately 350 gallons of this material." [E.G. Wright to W.B. Papageorge; November 14, 1969]
Further efforts to recover the spilled PCBs were moderately successful, but an estimated 900 gallons of PCBs were lost in the sewer. [E.G. Wright to W.B. Papageorge; November 20, 1969]
A January 1970 memo, containing the results of an analysis of water and mud samples taken at various points along Choccolocco Creek, showed levels as high as 1656 ppm Aroclor found in mud samples, and 16.5 ppm in water samples. [E.S. Tucker to E.G. Wright; January 19. 1970]
In a March 1970 communication to Monsanto Tokyo regarding Aroclors, W.B. Papageorge explained the situation in Anniston, noting that there continued to be no sign of life in Snow Creek, a fact which had been pointed out to Monsanto four years earlier by the Mississippi State University contractors investigating the watershed.
"Aroclor Toxicity-Anniston plant
Your question as to why the toxicity of Aroclors has not turned up downstream of the Anniston plant after 40 years of manufacture is difficult to answer. We just don't know. Aroclors have been found in Snow Creek near the plant. There is no record of any water life observed in this creek for many years. We've assumed other plant wastes were to blame; e.g. muriatic acid. Aroclors could be involved also.
Tests on the biodegradability of Aroclors are being conducted both in St. Louis Research and at Ruabon [Wales]. At present, Aroclor 1221 appears biodegradable in river water and activated sludge. Aroclor 1242 undergoes slight degradation in sludge containing microorganisms acclimated to biphenyl. All other Aroclors have resisted biological degradation, to date. There is some indication that isomer structure determines ease of degradation." [W.B. Papageorge to J.R. Durland-Tokyo; March 6, 1970]
This same memo shows that Monsanto fully recognized its poor waste disposal practices at the time, yet decided not to do anything proactive to address the problem.
"All waste containing PCB's is at present hauled to the dumps the plants have been using for other plant waste. We recognize this is not the ultimate, since PCB's could eventually enter the environment, but we will continue this practice until better methods of disposal are available." [W.B. Papageorge to J.R. Durland-Tokyo; March 6, 1970]
Just a few weeks later, in a March 31, 1970 memo, an employee in Anniston revealed that the dump where Monsanto put all of its PCB wastes was leaking.
"A serious problem exists at the present time with the Monsanto dump. The two main areas of concern are: (1) water leakage from the P.C.B. dump, and (2) lack of security throughout the dump area. These two areas create hazards in the areas of water pollution and in liability problems." [Recommendations of Task Force on Plant Dump; March 31, 1970]
Noting that the State of Alabama would soon require all dumps to convert to lined landfills, Monsanto recognized that its dump operations could be subjected to scrutiny.
"In light of the attention P.C.B. has received, it is highly probable that the Monsanto (P.C.B.) dump area could be classified as a serious water pollution source." [Recommendations of Task Force on Plant Dump; March 31, 1970]
While the company appeared to be addressing the problem with its wastes and had even helped some of its customers with their waste problems, Monsanto certainly had an ulterior motive. It surmised that if the company were able to control the release of PCBs into the environment to an "acceptable" level; appease its customers' needs regarding disposal; and appear to be taking measures to guard against further contamination, perhaps they would be allowed to continue selling the highly-profitable Aroclor products. Monsanto informed one of its customers:
"From the interest and concern which you have expressed I am certain that you will do all you can to reduce the escape of PCB's from your operation. When all of us succeed in this objective, I am certain that no regulatory agency will be compelled to take precipitous action regarding the use of PCB's in vital applications." [Papageorge to Cavenaugh; July 6, 1970]
Friends in the Right Places: Alabama Regulators Quietly Assist Monsanto
On May 6, 1970, three Monsanto employees met with Joe Crockett, Technical Staff Director of the Alabama Water Improvement Commission. This was the first time that the company discussed PCB pollution with a regulator. Monsanto's agenda for the meeting was to:
"familiarize Mr. Crockett with the situation regarding Aroclor wastes and their reported pollution potential and, secondly, to build confidence that Monsanto intends to cooperate with governmental agencies to define the effects of Aroclor on the environment." [Aroclor Pollution AWIC Contact; May 7, 1970]
The document explains the reaction the AWIC official had toward the situation:
"Mr. Crockett was most appreciative of Monsanto's approach to the problem and the fact that Monsanto came to him. He alluded that our action would produce a situation that was beneficial to the protection of both the Monsanto and AWIC positions. His recommendations were as follows:
1. Supply the AWIC with a general process description detailing potential loss sources.
2. Continue to develop information and as major items develop inform the AWIC.
3. Give no statements or publications which would bring the situation to the public's attention.
4. If approached by news media, either the AWIC or Monsanto is free to state that the situation is under study by the staff of AWIC at the direction of the Technical director, Mr. Crockett.
5. If in the future, information is developed indicating that Aroclors are detrimental to watersheds, Monsanto will be required to secure a permit from AWIC to allow certain maximum quantities of chlorinated biphenyl to enter Snow Creek.
In summary, Mr. Crockett appeared notably unexcited at our disclosure and all his remarks were directed toward a careful evaluation followed by actions as required by data. The full cooperation of the AWIC to reach the above objective on a confidential basis can be anticipated.
It must be remembered, however, that all AWIC actions are subject to state political pressure and federal control." [Aroclor Pollution AWIC Contact; May 7, 1970]
Monsanto later agreed to submit status reports to Crockett about their efforts to reduce PCB emissions from the plant. In these reports, and other correspondence of the early 1970s, Monsanto sought to convince regulators that the company had responded to the problem immediately upon learning about the potential danger, and that they were in control of the situation.
Crockett agreed to keep the reports out of the public eye, giving the company control over the fate of vital information pertaining to public health and safety.
"In conjunction with this information, a lengthy discussion of the technical complexity of Aroclor or PCB numbers resulted in Mr. Crockett's agreeing that any written effluent level reports would be held confidential by the Technical Staff and would not be available to the public until or unless Monsanto released it." [Landwehr to Jessee; October 26, 1970]
An internal "Progress Report on Aroclor Losses at the Anniston Plant" dated July 21, 1970 revealed that Monsanto had taken a sample from the source of the drinking water supply for the City of Anniston and had tested it for the presence of PCBs. The sample did not contain PCBs. However, to quote the Progress Report's description of the matter:
"It might be interesting to note that this is the only sample collected to date which does not contain Aroclors." [Progress Report; July 21, 1970]
"Confidential- F.Y.I. and Destroy"
In August 1970, Monsanto learned that the Food and Drug Administration (FDA) had taken fish samples from Choccolocco Creek and found fish with more than 55 times the legal limit of PCBs set by the Alabama Department of Public Health. FDA had provided the results to the Alabama Water Improvement Commission (AWIC), which alerted Monsanto to the situation. Luckily for Monsanto, the AWIC regulator in charge was looking out for their best interests.
"Joe Crockett, Secretary of the Alabama Water Improvement Commission, will try to handle the problem quietly without release of the information to the public at this time." [Hodges to Bergen Confidential FYI and Destroy; August 7, 1970]
Even though the local waterways were heavily fished both commercially and recreationally, Monsanto and State regulators took active steps to keep the public in the dark about the PCB-laden fish. Minutes of an August 1970 meeting- marked "Confidential- F.Y.I. and Destroy"- indicated that "a proposed statement" had been drafted in case the word got out, but even this was rejected in favor of "an innocuous, essentially 'no comment' type statement." [Hodges to Bergen Confidential FYI and Destroy; August 7, 1970]
Keeping the Press and Public in the Dark
Another document, from a few weeks later, confirmed the troubling response by the AWIC official who was supposed to be protecting public health and the environment, not Monsanto:
"Crockett told me that if this PCB issue hits the Alabama press, the Alabama Water Improvement Commission would be forced to close Choccolocco Creek and the Martin-Logan Reservoir to commercial and sport fishing unless we can prove that the contamination level does not reach the reservoir. The State of Alabama has no choice but to follow the guide lines of the FDA which calls for no more than 5 ppm PCB in fish." [Garrett to Landwehr; August 17, 1970]
The press did pick up the issue, but Monsanto acted quickly to influence the coverage. "Somehow," as this November 1970 "PR REPORT" describes, the Anniston Star (local newspaper) obtained the figures from the federal Food and Drug Administration (FDA) that showed high levels of PCBs in fish in Choccolocco Creek. But, as this document describes, the company successfully averted negative attention by "convincing" the reporter to write a "factual" piece "emphasizing" that there was "no cause for public alarm." [John to Papageorge; November 30, 1970]
Internal Progress Reports Find Lack of Progress
The same August 7, 1970 memo, which had described the strategy for dealing with the PCB-laden fish problem, had also relayed to several company employees the findings of the Technical Services Department's Progress Report from July. The memo explained that between April 15 and June 30, the Anniston plant had dumped an average of 16 pounds of PCBs per day into Snow Creek, though the waste load sometimes spiked as high as 80 pounds a day. [Hodges to Bergen; August 7, 1970][Hodges to Bell; September 18, 1970]
Also in August 1970, Monsanto implemented measures to limit discharges of Aroclor, hoping to show that they could curb the PCB losses to the environment. However, the monthly Progress Report for August 1970 from the Technical Services Department at Anniston, this time marked "Confidential- Read and Destroy," revealed that the pollution control measures were not immediately successful, and in fact the discharge of PCBs had increased significantly since the last report:
"Aroclor loses during August increased to a level of 7280ppb in plant effluent, equal to 88 #/day. This increase corresponds to high turbidity of the effluent from limestone inert material as the settling capacity of the final acid treatment pit has deteriorated since last clean-out." [TSD Monthly Report; August 1970]
These results were nearly 900 times higher than the plant's goal for discharges at the time, which was a tenth of a pound a day, as described here:
"(5) Final Treatment- Based on some indications (and much hope), by September, the actions above may approach the present plant objective of 10 ppb of PCB's in 700 gpm (or 0.1 #/day)." [Confidential FYI and Destroy; August 7, 1970]
"Extreme Reluctance to Report" Emissions from Anniston Plant
A few weeks later, a September 18, 1970 memo from Monsanto headquarters to an Anniston plant employee explained that the emissions problem had not been solved, and in fact was out of control. Headquarters pleaded with the plant employees to find a solution. The memo also indicated the company's hesitancy to be forthright with regulators regarding its discharges in Anniston, highlighting Monsanto's fear that the public might learn about the pollution.
"In reviewing your proposed letter to Joe Crockett with Legal, et al, we requested latest emissions data on the flow to Snow Creek. We had hoped that it might show an improvement over the 1st week in September and thus demonstrate a favorable trend to Crockett. Instead the emissions are considerably increased with 9/13/70 at 6.25 ppm (or about 80 lbs. of PCB for the day). From the Legal standpoint, there is extreme reluctance to report even the relatively low emission figures because the information could be subpoenaed and used against us in legal actions. Obviously, having to report these gross losses multiplies, enormously, our problems because the figures would appear to indicate lack of control.
Realizing the extreme efforts the plant has gone to in order to curtail loss of PCBs, is there anything more that can be done to get the losses down?" [Hodges to Bell; September 18, 1970]
The September Status Report continued to show that Monsanto couldn't get the discharge levels anywhere near their goal of 0.1 pound a day in Anniston.
"PCB Levels in Snow Creek- Average PCB loss for the month was high at 2600 ppb or 32 lbs/day, largely as a result of one very bad day (400 lbs). [September Status Report, Papageorge; October 6, 1970]
This memo from December 7, 1970 conveys the sense of urgency Monsanto had to get the discharge numbers down quickly.
"One very important objective of our PCB environmental control program was to control the losses of PCB in our plants to achieve a maximum of 50 ppb in the waste water effluent by 1-1-71 and 10 ppb by 9-1-71.
During the month of September, Newport reported an average of 246 ppb. During November Anniston reported 1410 ppb and the Krummrich Plant reported 495 ppb.
Because of the seriousness of the PCB problem this level of performance cannot be allowed to continue. I do not recall that any of the plants have been denied a resource they requested to achieve the stated objectives.
We do not have the luxury of unlimited time to combat this problem. What do we need to reduce losses quickly? [Papageorge to Savage; December 7, 1970]
Having failed to meet its goals for pollution reduction, Monsanto was noticeably frustrated with the amount of money it would require to actually meet the goals.
"Early in 1970 we established a target of 10ppb of PCB's in our plate waste streams which we expected to achieve by the third quarter 1971.
Clean-up of these sources can be economically impractical.
It appears that the PCB contamination is so widespread that all of the plant's effluent must be treated. ...
For 1971 I am proposing that 1 pound per day of PCB in the water effluent be achieved in our plants by Sept. 1972 and 1 pound per day to the atmosphere by year end. These are levels which I believe the regulatory agencies might tolerate." [Papageorge to Savage; January 29, 1971]