Document 82DvEMX4vjrBxE0azMVB9NJRm

Monsanto J. F. Queeny Plant ATI < Pecembe* 19, 1970 waiter Areclnr Lon - Statu* Report iruiMi Pepont 9/71/70 TO : MittA*: P. 8. Hodgt* \H. 8. PapagtoKgt J. R. Savage " P. H. Abruch F. W. Copana* P. F. GattM E. C. Oruetxemachtr V. G. Knapp P. C. Mata * E. P. Matone P. E. Munie W. F. Meyea J. F. Nemeth * A, C. Pehkemper C. R. Schrock J. A. Stepp E. P. Take 8. 1. Tilbord * R. L. Wagner R. 1. tot * Sunmaty onty. SUMMARV PCS .type Arocten have been used on handled in (oua. department* and the Pttearch Pilot Plant at JFQ. Total annual lo**e have already been reduced from 21.500 lb*, to 14,000 lb*, via interim and permanent meature* taken at a coit of, $3,000. A program ha* been developed which, if bully implemented, would e**entiatly eliminate all normal lo**e* to the environment by 1/1/7).at a coit of approximately $33,000. Comment* on the program by 1/15/71 are iolicitated. The program it tummarieed in Table 7. Prioritie* are bated on probability of lot* and ettimated coit ob correction. lip. MONS 04k9k3 *hqns o 4944 Teionity X t 3 4 5 wJiis H/.'.l; ; TABLE I AmcLoa. Stdtiu and ftopoAaU Teoblem Atea TSCl Hath Pimp W Bldg. TSCl . HeoieAitf) Eli. Loll lb*. lux.. toto 1000 1500 Sowict oi Loll Slat iluid Sep. S Vemiit. Plain1 Ifapom, pump /coin, ja.cb.tt iteam out*. VapoKi, pump itofcl. Ponihle Action* Vnain headeA connected to diipotal d>um. Change {laid to Thenminal - tt a. Snitch to T-66, incut iyitem, 04 b. Snitch to A-lUt pan pump*, cold tnap vent. Phthatgl Chloaide 1000 Vapom pump tub*. Snitch to A-Ittt, permanent pump pan, pneilu&ize iyitem, vent undent te. V Btdg. LtadtA U*4t 1000 Vapoe*, pump tub*, iteam out oi jacket* Clean *y*tern. Snitch to A-1l4t cold tup vent new type pump cuhb axea. fast t Statu* complete Eli. $ 500 Timing complete tOOO Topping uith 4000 A-lUt. Auaiting completion oi 4500 compatibility itudy oi T-66 uith TSCl. Comparability Aeiulti by lit PAFE by t/1/T, Topping uith 1500* A-1141. Temp deip pan 500** paoj. icope \tady. TATI by Util'. Unit cuuently 4*3,000 down. Top uith A-1141. UajoK pump overhaul un*ucce**iul. 7nve*tigate by mm. PAFE by */h Page 3 Pxioeity i 7 1 Pxobtem Aeea 0 Bldg. Taxi unit lit. Lot* lb*./at. tmaJU cuts 3900 0 Bldg. Centenunit * 0 SouACC o{ lot* Vapou, pump IvdtA, iteam out oi jaeklt*. Pottibh Action* Suitch to A-1747. Cold txap vent Pan pump. In*tall ckg. pump. Pump Itaki, ho*t dnainage. piping leak*. Hot in utl. PCS containing Anoclon* mill be eliminated i*om all blend* by 4/1/71. J. R. Savage memo oi 9/73/70. PATE ion new unloading pump admitted. Isolate to pfitvuU a&e. ViAmantle Statu* E*t. $ Unit cuMently doom top uith A-1 Ut. Pump in good condition. 7000 1500 Timing Invutigate by 3/1/7/. PAFE by 4/1/71 PAFE >10691 admitted 17/10/70. doton -- 500 1500 6/1/11. Veila. * Total PAFE oi $5000 expected. Juttiiication i* pnimnity to prevent COMO*ion oi ve**tl caul jaeklt. TntvuM meatuee taken. MONS 0 4 A 9 4 5 Page 4 FUTURE WORK >. Continue to define detail* of change* aeguined for. the leaden, and ibath yard unit* *ervicing the "III" Building. 1. Proceed mith program a* outlined, on a* modified to meet need* baled on information received from addreuee*. /jar MOMS 044946 Page 5 i. mmucriON PCB`s containing Anoclou are extremely stable and highly inert fluids and at, tuch mere considered to be. a tail (laid. Recent evidence, howeuea, indicates that PCBt have an adverse effect on the environment. Since anoctons are only slowly degradeabte through natural mean there it concern over their buildup in the environment, ireclou in the 1200 series are of primary concern. The higher the number, the more resistant it the {laid to bio degradation. To protect the environment Montanto hat established a self impoted limitation of PCB lottet to the untie effluent of, 10 ppb. In addition, volatile lottet to the atmotphere are to be euentially eliminated. The purpote of thit report it to relate the interim and permanent itept taken to date to reduce PCB lottet to the environment and to invite comments on meaturet prepoted to obtain a {anther and permanent reduction in lottet. II. PITAILS A. General An intpection o{ the Aroclor uting {acilitiet at TSCi, Phthalyl Chloride, "hi" Building and the Research Pilot Plant l"IM" Bldg. I uat made. Technical advice and recomendationt mere obtained {ram P. E. Routh o{ the Fluidt Group. Pitcutiiont mere held with Pepantment Supervision and alternate tolutiont to the elimination o{ PCB lottet to environment mere presented and a course o( action chosen. A final decision in TSCl can not be made until the outcome o{ a compatibility study is complete. Interim and permanent measures mhere immediately feasible have )been taken. 8. Pepartmentt I. Research Pilot Plant Two portable high temperature fluid heating systems have been employed in this facility. A third unit hat just been obtained. Although the units originally used Therminol 77, Aroclor 1241 was tubttituted many yeans ago and its use continued, fluid lottet have been incurred from pump leaks and steaming of vessel jackets to the tenter when changing heating or cooling medium, and vaporization. HONS 044947 Page 6 Alternate solutions fo>i the ftW p/wbiem mere: 1. Continue with Anoclor fluid. Estimated coot Uooo. T. Switch to Motto* 124! because it is mo*e biodegtodeable. b. Ptovide. large drain pani under pumps. c. Cold trap vent to prevent volatile losses. d. Provide <o* trapping of effluent steamed from vessel jackets. 1. Change to non PCB containing fluid. coot $2000. a. Suiitch to Therminol 66. Estimated b. Inert the systems to prevent oxidation and eliminate the fine hazand. A meeting woo held with Vr. Knapp and Hr. H. Close of the Research Pitot Plant to discuss the alternates proposed. Alternate *2 was recommended to and accepted by Research as the best overall solution. Since Therminol 66 contains no PCB, future concern over such tosses from this facility mill be eliminated. Vr. Knapp agreed to complete the changes regained before the next startup of heating systems (22/li/70). TSCl a. Nash Compressor - HCl system Arador 1232 is used as the sealing fluid for the Nash Compressor in the HCl system. Losses are estimated at 6,000 lbs. annually. Anoclor builds up regularly in the system's instrumentation and is drained periodically to the pump's catch pan. The drain line from the Brink's demister joins the pump pan drain. This tine formerly . ton directly to the semen. The line has been altered so that the drainings are now caught in a drum. Pull drums art marked "Anoclor for Incineration" and sent to NGK <o* storage. HCl from TSCl is used in the manufacture of Bisphenol A. Samples of Bisphenol A have been submitted to Research to determine uihethen any PCB's are present. Analytical problems have been encountered by Research. New laboratory facilities have just been completed which are expected to provide reliable results. Analysis of the BPA sample is expected by year end. HONS 044948 Page 1 A Atanch mu conducted ion a AubAtitute iluid ion the Nath CompneAAon, but no Aatteiactohy matenial could be iound. Stephenol A manuiactune In Acheduled to elate at JF2 by ike end o{ 1971. At thin tint it may be pottiblt to atten the HCt tyttem to eliminate the Nath CompneAAon and thtne.bg eliminate tht ue oi Anaclon. b. Heating Unite - Two Tino heating AyAtemA employing Anaclon 1241 ant in ute. Annual loan total appnaximately 2500 paundt inom thete unite, Tht bulk oi the load ant the netult o< pump leakA. Some atmoAphenic load ant incunned as no continuation meMunei ant employed on the venti. Ai an intenim meaiuhe the dipantment ii uiing Anaclon 1242 {on Ioaa makeup. Openating inAtnuctionA have been modiiitd and pentomel inttnucted to exent extneme cant in handling oi Anaclon iluidi to pneuent inaduentent 4 nothing. Altennate AolutionA to connect the pnoblemt with that htattM ant I. Continue with Anaclon iluid. litimatid coit $4500. a. Snitch iluid to Anoclon 1242. b. Pnouide lange dnain pant ion pumpi. c. Cold tnap vtnte. 1. Change to non PCB containing iluid. Eitimated cett $4000. a. Sulitch to Thenminol-66. b. IneAt igitemt with COj. e. Allen, tine inom continuation uent and pnouidt cold tnap/ilame anneiten. The altennatd wine dtecuned with the dipantment Aupenuteon Pon AbneAch and altennate *2 necommended. Mn. Abnetch agnted with the necommendatian pnouiding that Thenminol-66 MU iound to be compatible with the TSCl AtneamA heated. A Atedy hat been Acquitted oi the TSP Pnoceti Gnoup and netulte one expected by 12/11/11. MQNS 044949 Page I Bo-th units ant heated by 350 lbs. steam. Tht (luids ant tiled at a maximum temperature o( iOS'C, White this temperature is above the (lash and (ire pointi o( Therminol-66, inerting o( the lyitm with CO% ihoatd provide adequate (ire protection. The ante ignition temperature o( T-66 ii 364'C ox I2(J'C higher than temperature o( the heating steam. There(ore instrument mal(unctionS cannot xeiutt in over heating o( the (luid. A PAFE /oa the neceliaxy changes can be lubmitted by 1/1/ 71. . Phthalyl Chtoxide Thii department hoi one Aroclox lyitem uted (ox both heating and cooling o( a xeactox. Heating il accomplished by the use o( bayonet heatex submerged in the agitated jacket. The (laid is circulated through an external heat exchanger (ox cooling o( the xeactox. Losses axe about 1000 tbs.fyx. and axe primarily (xom pump Itaks. Atmospheric losses axe estimated to be 60 tbs./yx. Corrosion o( the vessel has become a major problem. The corrosion is caused by the introduction o( atmospheric moisture which causes the breakdown o( Axoctox to (arm HCl at the temperatures used (30tf*C). The moisture is introduced by the breathing action taking place via the open vent as alternate heating and cooling cycles are employed. Jacket maintenance costs (rom corrosion average $1500/yr. Corrective action is a necessity to prevent the loss oj the $15,000 reactor and consequent business interruption. Interim actions have been taken to reduce the PCS loss and limit its e((ect on the environment. Axoctox 1Z4Z is used to make up any (laid tost. A temporary drip pan at the pump packing gland has been provided. Operators have been instructed to take precautions against allowing Aroclox (laid to enter the waste e((luent and operating instructions modi(ied. Two alternatives were developed to solve the combined PCB corrosion problem in this department. They are t. Continue with Aroclox (laid. Estimated cost $5000. a. Switch to Aroclox 1t4i. b. Provide large drain pan (or pump. MONS 044950 Page 9 c. Inert the system with W, and provide. conservation vent. 1 d. Provide condenser on conservatien vent, t. Install rupture disc. t. Change to non PCS containing {laid. Estimated colt $5000. a. SuUteh to Thirminol-66. b. Inert the system mith M, and provide conservation vent. c. Provide vent condenser. The alternatives mere discussed mith the department supervisor C. Schrock. Alternate J urn chosen primarily ion sa{ety reasons. The use o{ electrical heating units in the jacket urn the overriding consideration. Temperatures could exceed the auto ignition temperature. 11 the inerting system mould {ail, an explosive situation could result. A PAPE toill be submitted by 1/21/71, i{ no adverse comments are received. "ill" Building The "Id" Building has three Arodor heater systems. The small homemade unit located in the center section is no longer used and mill be isolated to prevent use. The "yard" unit has an excellent maintenance record and addition o{ {luid is rare. The losses that do occur are {Torn pump leaks and valdtile losses through the open vent. The principle source o( loss {or "Id" Building operations is. the leader unit located south o{ the "BBS" Building. Last year the pump seal {ailed on {ive accessions and accounts {or the majority o{ the toss. In addition some volatile losses are incurred through the open vent. A major overhaul o{ the pump mas completed in November, but the seals {ailed mithin a meek a(ter startup. All units are currently damn. When operation is required only Arodor 1242 mill be used {or makeup o{ losses. The manu{acturing superintendent {or the "Id" Building, F. Copanas reports that current project {orecasts indicate that only one heater mill be required {or the {oreseeable (uture. Operations mill be con{ined to the yard unit as long as only one heater is required. MONS 044951 Page 10 Two basic altexnatives (ox a pexmanent solution to the PC8 tonel (xom the too heatexs mu dueuiied with Hessxs Suthexlin and Copanas. One wal to continue with Axoclox and the othex to twitch to Thexminol-66. Both men objected to the ult o( Thexminel-66 (xom a sa(ety viewpoint. The fluids in both uniti axe heated by open gal (lame buxnexs. A xuptuxed tube in the (uxnace would xexult in a (ixe. Special instxumentation would be xeguixed to lente the (ixe, ihut 0(5,5 Ikx do* end extinguish the (ixe automatically. Cuxbing to pxevent the ipxead oi btinning iluid (xom the unit would oho be xeguixed. The itated auto ignition tempexatuxe o( the (luid it lomewhat towex when the matexial it looked into insulation. Since the (luid it (xeguentty heated to ovex SOO'C, a leak into the imulation could xeiult in a (ixe. System altexationl (ox eithex Axoclox ox Thexminol-SS axe in the lame oxdex o( magnitude. Although the itepl xeguixed to be taken (ox the continued ate o( Axoclox (luidl it itill undex inveitigation, the (allowing changet axe being contidexed. 1. Leadex Unit. Estimated colt (13,000. a. Change (luid (xom Axoclox 124S to 1141. b. Pxovide new leakpxoo( pump. c. Cold txap vent. d. Clean lyitem. ' l. Vaxd unit. Estimated colt (7000. a. Change (luid (xom Axoclox 124S to 1242. b. Pxovide system changing pump. c. Pxovide Sump pump. ' d. Pxovide dxip pan (ox pump. e. Cold txap vent. (. Paxtial xoo(ing o( axea. g. Clean system. It is expected that a PATE could be submitted (ox changes to both units by 4/1/71. MONS 044952 Page II $. cuts . The magnitude of PCS lottet at CLHS ate unknom, but ate believed to be tonga. Mn. J. R. Savage in hit memo of 0/13/70 ttated that by 4/1/71 PCS containing Kroclont uiilt no longer be. handled in CLHS and that capital improvement* cannot be juitified on that batit. Department tupervition hat been aequated to exert cane in preventing lottet utithin equipment limitatijont. tot. E. R. ' Reagen hat tecomnended a number o( minor, improvement* to department tupervition to minimize lottet. The pollution group arranged a film pretentation for all pertonnel involved for motivational purpotet. A PAPE hat been tubmitted to replace the pretent Aroclor unloading pump uihich hat almyt leaked badly. Prime jutti- fication for thit project it not bated on PCB lottet, but on unloading capacity, tafety and reduced repaint. C. Sevier Sampling Compotite iampler of the main effluent are tubmitted for PCB analytit each month. The reported retuJUt are: Month June July Augutt September October November EE* 46 4i.S 43.0 77 70 It. 9 Analytical problem* have been encountered by Pet earch and the figure* for September and October are open to guettion. Nem laboratory facilitiet have jutt been completed. The November retulti tnoum mere obtained in the new facilitiet. P. Volatile Lottet The volatile lottet from the Amelon unit in phthalyl chloride mere calculated at 49 ibt./yr. Volatile lottet from the other unitt are believed to be contiderably let*. No attempt to calculate or meatare there lottet mat made tince completion of the change* propared in thit report mill ettentially eliminate them. /jem V Z> W A. E. Ptterton 044953 mqns