Document 3Dwex9ogBDXVdpQ9kp2VXady

Monsanto . <) r*oM ihahl * iocmioh. P. B. Hodges - General Offices ) OfcTC . October 9, 1969 .ueJ.c, RiicftiNcr STATUS REPORT - AROCLORS CLEAN-UP OP PLANT EFFLUENTS . TO : Mr. W. A. Kuhn (4) W1CUI1N cc, Messrs. . D. B. Hosmer - DHOSM W. R. Richard - WRICH E. S. Tucker - QUEENY E. V. John - EJOHN M. W. Farrar - S. 2ND ST. E. P. Wheeler - EWHEE This memorandum advises progress and problems involved with clean-up of Aroclors from the-waste effluents at W. G. Krummrich and Anniston. . W. G. KRUMMRICH PLANT A. Status With the changes in practice at Aroclor using departments plus the greatly improved HC1 off-gas cooling at the pro ducing department chlorinators, the only significant losses now occur from handling at the producing department, some of the changes in practice: 1. No spent heat transfer Ai-oclor is now deliberately sewered. Only losses are from leakage in pump packlng glands, accidental handling losses, vapors, etc. The spent Aroclors are being disposed of in our toxic land fill -- a temporarily acceptable practice. 2. Aroclor heels from tank cars being washed at the re pair track are also collected and hauled to the land fill. At the producing department free Aroclor is visible in the sewer trenches. Samples of the affluent have been collected but, to date, none have been analyzed. Based on material balances, loss to sewer is an estimated maximum of 50,000 pounds per year (137 pounds per day average). Actual loss is probably considerably lower due to soaking Into chat snrend around the operating area. B. Future Work PAUL HODGES DEPOSITION May 31 -- June 1, 1994 1 Waste Sampling EXHIBIT NO. 23 In-plant water, plant effluent water and Mississippi River mud samples are being taken on a regular basis, but no analyses have been run in recent months. The samples are being stored. We need to have the samples analyzed in order to guide futux-e sampling work. Ac- soon as we can find out where we Btand quantitatively, we will review the sampling points and, no doubt, do more comprehensive sampling of the Mississippi River, CONFIDENTIAL 92-GV-204-WDS CER 015685 WATER PCB-SD0000005618 Mr. W. A. Kuhn 2 October 9, I9S9 Including cross-section samples above our outfall and at a considerable distance below, e.g. Jefferson Barracks Bridge. No plans presently exist for air sampling, but these will be developed ;Ln the next several months, depend ing on priorities established as the whole Aroclor problem becomes clearer. 2. Waste Reduction An engineering study has been made to reduce losses at the production department. A number of sumps have been proposed which would virtually eliminate any sewering of "free" (undissolved) Aroclor by allowing the Aroclors lost to be settled out and to be inter mittently pumped to a waste trailer. The trailer contents would be hauled to the toxic land fill. Total cost of the projects would be $81,000. One sump (to cost $11,000) is estimated to collect 5056 of the total losses. This is the collection point for process area discharges. Installation of this sump would be a logical point to commence with the next round of clean-up activities with other projects to follow as justified by actual measure ments . * ANNISTON PLANT A. Status 1. Waste Reduction Numerous small changes have been made to eliminate any possibility of free Aroclor leaving the plant and depositing in Snow Creek (as previously experienced). These changes include: &. 'Rehabilitation of the neutralization pit in the . total (less Nlran) effluent flow leaving the ; plant. This will effectively prevent Aroclor ^`losses above saturation and will stop future deposition in Snow Creek. 1) To reduce losses to well below saturation, changes have been made to' collect free Aroclors at points prior to dilution of the wastes. Included are: a) An existing sump at the end of the ware house is being utilized to trap Aroclors spilled from drumming and flaking opera- ti0ns* CER 015686 COHFIDENTIAl 92-CH04-WDS WATER PCB-SD0000005619 3 Mr. W. A. Kuhn October 9> 19&9 b) A coalescer was Installed in the muriatic acid flow from the HC1 absorbers. Primary purpose was to improve quality and ease of treatment of the muriatic acid, but a considerable amount of free Aroclor is being trapped following the coalescence. 2. \7aste Sampling A set of samples taken June 10 were analyzed recently. A full report will be Issued soon. The most interest ing data are: a. Snow Creek, about 1 mile below our plant - Mud - 2.36$ PCB Water - 8.3 ppb PCB With this concentration of Aroclor in the mud of Snow Creek, we can expect leaching to continue for a long time, regardless of how well we clean up in the plant. b. Choccolocco Creek, about 10 miles below confluence with Snow Creek -- Water - 5.8 ppb PCB B. Future Work 1. Waste Sampling Drs. Gunning and Suttkus, biological consultants from Tulane University, who have been making fish studies for the plant, will be conducting a phase of their continuing study during late October. They will be requested to collect a variety of fish species above and below our outfall for PCB analysis by Dr. Scott Tucker's laboratory. itollectlon of water and mud samples from Snow Creek, Chdccolocco Creek and the Coosa River will be con tinued on an as-justified basis. A limited number of samples were collected recently during a severalday shut down of Aroclor production to establish losses without Aroclor production. Another full set of samples will be collected soon in order to resolve discrepancies with results from the first (June 10, 1969) samples. Following establishment of reason ably reliable facts on present receiving stream PCB levels, we will continue to sample at about six months intervals. As in the case at W. G. Krummrich, IKNIIAL 92-CV-20M5 CER 015687 ****< - .v-. -r* `.ftr** WATER PCB-SD0000005620 Mr. W. A. Kuhn 4 October 9> 1969 we need the laboratory results fairly promptly in order to guide future sampling work. 2. Waste Reduction The next logical step in waste reduction is to provide sumps in the operating department to collect spillage from pipe leaks, pump packing, etc. Firm plans will be developed after we gain quantitative information on losses (about January 1, 1970). Meanwhile, efforts will be directed toward making maximum use of the collection equipment already provided (the warehouse sump and the coalescers). (l\-t Jt fyi't Paul B. Hodges acd CQMTIAL 92-CV-204-WDS CER 015688 WATER PCB-SD0000005621