Document 3eKXm5x97rrnp2Xa0k4K5j80y

I/) i' .r!irj Robert N. Bannon lim, G. Krunmrich Plant Oc tob er 5, 19 77 DISPOSAL -OF WGK ALKALI INSOLUBLES STREAM_____ F . B as ile D. Metherd G . Watson H. Yapp B. W. Eley - A2SC M. A. Pierle - EISA Please review the attached proposal for disposal of alkali insoluble waste. This proposal has been reviewed and is supported by appropriate WGK plant" personnel. In addition to the reasons cited in the proposal for select ing landfilling as the best route of disposal, the uncertain future of Pentachloropheno1 manufacture from which'these by products are formed, should be weighed heavily. I suggest that we lo ok'at this plan as an interim solution which should be reviewed in one year should we still be in the Penta business. Timing for this project is rather tight. I am targeting 10/12/77 for submitting this AR to the Manufacturing Manager. Your comment prior to that date are essential for a smooth flowing project. Thank you in advance for your help in this matter. I am looking forward to meeting you both and working with you now and in .the future. /It a 11 achmen t Confided ,C ; Robert N. Bannon  'J SC. -/c -7 / H. G. Ya?p - Wm. G. Kr ummr ich Plant October 3, 1977 MINUTES MEETING DISPOSAL ALKALI - D E P T . 227 Th os'e Present : E. J. Bas ile G. R. Davis J . A. Lab anoskv TO DISCUSS INSOLUBLES . J. Wolfsberger H. Yapp R. N . 3ann on G . R. Davis P. E. Heisler D. J. Me th e rd W. r t Scruggs V. L. Snui 1 A neeting was held September 13, 1977 at 2:00 p.m. TR #3 Bldg. EK to discuss plans for disposing of the alkali insolubles, which have been accumulating in the cone bottom separator (Item 401, Dept. 227) Based on experience, the cone bottom part.of the settler fills up in about six months. This amounts to 187 ftJ of solids or about 1400 gals (i.e . approx. a drum per week of solids, dry basis). It has been the practice to dispose of these solids by opening a 3M gate valve on the bottom of the cone, probing down through the solids with a steam sparger until an opening is made through to the bottom outlet", and using a water hose (sometimes a high pressure hose) the solids are washed out the bottom outlet and on to the sever. It has been determined that these solids contain dioxins. An analysis of this mud gave the following results: Octachlorodioxin 12%, heptachlorodioxin 1.8%, hexachlorodioxin -4352 ppm p en tach loro dioxin A 17 7 .ppm , te trachlorodioxin C. 13 ppm. These lower chlorinated dioxins, if actually present are quite toxic. The higher chlorinated ones are non-biodegradable. For these reasons the above described method of disposal is no longer acceptable. PROPOSED DISPOSAL METHOD As a result of the discussions and subsequent investigations, the following method is recommended for the removal of the solids that are present accummulated in the settler. The procedure for drumming the solids preparatory to landfilling is outlined below in a stepwise raanne 1 . Install a 3" air cylinder operated sliding gate valve on the botton of the present 3" gate valve that is on the bottom of the settler. Connect instrument air to the cylinder actuator so that the valve can be opened and closed from the approx. 4 fc. high platform locat on the west side of the settler. Minutes of Meeting to Discuss Disposal Alkali Insolubles Dent. 22 7 _________ _ - 9- 9/30/77 2. Pipe up the 1" side nozzle vhic." presently tees into the sice of the 3" bettors nozzle sc that either 80 psig steam or water can be blown or washed up into the bottom of the settler iron the platform. 3. When the tank is ready for draining and using a 2 wheel barrel dolly, place an open top 55 gal. barrel (:.* DOT 53 Code No. *93223) under the bottom outlet and withdraw the dolly. There will_ be approx. 6" of clearance between- the top of the barrel and the valve on the bottom of the tank. 4. With the air cylinder actuated sliding gate valve closed open the manual gate valve from the platform (10 to 12 ft. away). Open the automated sliding gate valve and observe if the material flows into the drum. When the drum is full, close the valve, clamp the cover on the drum and replace it with an empty one. When the material does not flow out, close the valve and blow back up into the tank with steam or wash up into it with water. If necessary to work from the top of the tank with the bottom valve open, a second man should be stationed on the platform to close the valve when the drum is ful Continue with the steam sparging, washing/slurring and draining into.the drums until the tank is empty. Opening and closing the bot valve and/or blowing with steam and washing with water at the bottom should be done from the platform at a distance of 10 to 12 ft. Use as little water as possible. Filled drums can be* stored on pallets until they can be shipped. ALTERNATE DISPOSAL METHODS Other prop osals ,for handling this material were considered. Briefly these involved drumming Che material and holding for incineration. Thedrumming to be accomplished either by slurring up the mud like solids and pumping into drums, or washing and dropping the sludge through the bottom nozzle into a fabricated box designed for dewatering and then shoveling the solids into drums. It was felt that both of these methods increased the potential for exposure, either in the shoveling operation, or in the possibility of having to unplug, plugged pipe lines. It was not Considered advisable to store for incineration in the new incinerator to be built by 1980, unless absolutely necessary. The new incinerator will no doubt be running at capacity for some time burning other accummu1ated wastes. In any event a burning test will be necessary to determine, requirements for eventually incinerating these wastes. Ccr.iid Pi Minutes of Meeting to Discuss Disposal Alkali Insolubles Dent. 227 "3" 9/30/77 Frank J. Basile is obtaining clearance for landfilling this material. Approval is expected by October 31, 1977. R. C. Pfiefle is obtaining Department of Transportation clearance for shipping this material (rated as a Class B poison) in DOT approve'd drums. -r Review with MIC Energy and Environmental and with Medical and Environ mental Health for their concurrence by October 7, 1977. Delivery on the air cylinder operated sliding gate valve is 2-3 weeks Completion of the overall installation by mid November, 1977 will require overtime. Total cost $5,000. f/, J # /lr