Document 91ZKON5YN508RnkwXL8Ery84e

Monsanto MM (NAM* m L J. F. Queeny Plant ATI i December 19, 1910 UMtCT troclor Lott - Statut Report Report 9/11/10 TO Uettrtt Jp. B. Hodget. I W. 8. Papageooge J. R. Savage DiJ. " P. H. Abretch F. W. Copanat * P. F. GaXtni E. C. GAuetzemachea W. G. Knapp V. C. Maim ' * E. P. Malone P. E. Munie . W. F. Megea J. F. Nemeth * A. C. Rehkemper C. R. Schrock 3. A. Stepp * E. P. Tafee * 8. 1. Tiliord * R. L. Wagner R. L. Kiue * Suimary only. SUMMARY PCB tgpe AaocIoa* have, been used on handled in (out departmenit and the Ret touch Pitot Plant at JFg. Total annual lottet have already been reduced (rom 11,500 Ibt. to 14,000 Ibt. via interim and permanent meaturet taken at a cott oi $3,000. A program hat been developed which, i{ (utlu implemented, would ettentially eliminate all normal lottet to the environment by Him.at a cott oi approximately $35,000. Coimentt on the program by 1/15/71 are tolieitated. The program it tummarized in Table 1. Prioritiet are bated on probability o{ loa and ettimated cott oi correction. " N-IA MV I'M HONS 045179 fage 7 PnioAity 1 7 5 4 5 i D Z Co . TABLE I Atwclos Status and Proposals Problem AAtA TSCt Nash Pump W Btdg. TSU HeatessUI 1st. Lett tbs./ys. 6000 1000 7500 Sowice Lon Seat ituid Sep. t Demist. Vaains Vapons, pump teaks, jacket item outs. Vaposi, pump teaki. Ponibte Action Onain headed connected to (Litpoint doom. Change ituid to Thesminat - 66 a. Sutitch to T-66, ineat tyitem, OA b. Sutitch to A-1741 pan pumps, cotd tnap vent. Vhthalyt Chtokide - 1000 Vapo/u pump teaki. Sutitch to A-1747, permanent pump pan, psessuaize iyitem, vent condenses.. tf &ldg. LiadtA Unix tooo Vaposs, pump teaki, iteam out o( jacketi. Clean system. Sutitch to A-1747 cold tnap vent new type pump cuab anea. Status complete Est. # 500 Timing complete 7000 Topping utith 4000 A-1747. Awaiting completion oi 4500 compatibility Study oi T-66 utith TSCt. Computability . nesults by 11/31/ 70. PATE by 7/1/71. ' Topping utith 1500* A-1747. Temp deep pan 500** pnoj. scope heady. TATE by 1/71/71. Unit cuAAentty 13,000 down. Top utith A-1747. Uajoe pump overhaul unsuccessiut. Investigate by 5/1/71. PAFE by 4/1/71. MGNS 045180 Rage 3 Pnioxity t Problem Anea V Bldg, food unit Eat. loot lb*./yn. *matt 1 cuts 3099 1 V Bldg. Centekunit 0 > Sowiae o{ loo* Vapon*, pump leak*, *team out o{ jacket*. Po**ible Action* ' Switch to A-1343. Cold t/iap vent Pan pump. InitaJtl ckg. pump. Pump leak*, hose drainage, piping leak*. Hot in use. PC8 containing Axoclon* will be eliminated friom alt blend* by 4/1/71. J. R. Savage memo o( 9/13/70. PAFE jon nett unloading pump iubmitted. Uolatt to pttvtnt cue. Vi*mantle Statu* E*t. t Timing Unit cuMently down top with A-mi. Pump in good condition. 7000 Investigate by 3/1/71. PATE by 4/3/71. 1500 PAFE *10691 aubmitted ' 11/10/70. down -- 500 1500 6/1/71. Veien. HONS 045181 * Total PAFE o{ f5000 expected.' Justification i* piUoaxily to prevent comuuion o( veuel and jacket. ** Intent* meatwtc taken. Page 4 FUTURE WORK I. Continue to define detail* o{ change* neguiited (on the leaden and ibuth yand tout* ifiviclng tkt "tt" Building. t. Proceed uith pnognam at outlined, on at modliled to meet need* bated on .cn^oAmatcon received {aom addeetteet. //cm HONS 045182 Page 5 I. ItmtOVtlCTlON PCS'* containing Arectors ant extremely stable and highly incut fluid* and a* such went considered to be a safe fluid. Recent evidence, however, indicate* that PCS* have an adverse effect on the environment. Since arector* one only *lowly degradeable through natural mean* there i* concern over their buildup in the environment. Aroclor* in the 1200 eerie* ere of primary concern. The higher the number, the more resistant i* the fluid to bio degradation. t To protect the environment Monsanto ha* e*tabti*hed a *elf impoted limitation of PC8 tone* to the watte effluent of 10 ppb. In addition, volatile lo**e* to the atmosphere are to be ettentially eliminated. The purpoie of thi* report it to relate the interim and permanent itept taken to date to reduce PC6 lone* to the environment and to invite comment* on meaturet propot ed to obtain a further and permanent reduction in lone*. II. DETAILS A. General An intpection of the Arector uiing facilitie* at TSCl, Phthalyl Chloride, "W" Building and the kesearch Pilot Plant ("Mil" Bldg.) wa* made. Technical advice and recomendation* were obtained from V. E. kouih of the Fluid* Group. Discussion* were held with Department Supervision and alternate solution* to the elimination of PCB lane* to environment were presented and a course of action chosen. A final decision in TSCl can not be made until the outcome of a compatibility study is complete. interim and permanent measure* where immediately feasible have been taken. . >_ B. Department* ' I. ketearch Pitot Plant Two portable high temperature fluid heating system* have been employed in this facility. A third unit has just been obtained. Although the unit* originally used Therminol 77, Aroclor 1241 wa* substituted many year* ago and it* ate continued. Fluid lotto* have been incurred from pimp leak* and steaming of vessel jacket* to the sewer when changing heating or cooling medium, and vaporization. MONS 045183 Page 6 ... . AIternote solutions {or the W problems werei 1. Continue with Arcelor {luid. Estimated cost iitOO. tT. Snitch to Aroclor IHt because it it mo*e biodegradeable. b. Provide targe drain pant under pumpt. .. c. Cold tnap vent to prevent volatile tosses. d. Provide {ok flapping o{ e{{luent steamed {Kom vettel jackets. 2. Change to non PCS containing {laid. dost (2000. a. Suiitch to Therminol 66. Estimated b. Inert the systems to pKevent oxidation and eliminate the {iKe hazaKd. A meeting was held with Vr. Knapp and Mr. H. Close o{ the Research Pitot Plant to discuss the attenuates pnoposed. Attenuate *2 was recommended to and accepted by Research as the best ovenall solution. Since Thenminol 66 contains no PCS, tfutuAe concenn oven such losses {nom this {acility will be eliminated. Vk. Knapp agneed to complete the changes required be{oKe the next stantup o( heating systems (12/12/70). 2. TSCl a. Nash Compnesson - HCl system Anoclon 1252 is used as the sealing {laid {ok the Nash Compnesson in the HCl system. Losses one estimated at 6,000 lbs. annually. Anoclon builds up Kegulanly in the system's insfumentation and is drained periodically to the pump's catch pan. The drain line {nom the Brink's demister joins the pump pan drain. This line {onmenly . Kan directly to the sewer. The line has been altered so that the drainings are now caught in a drum. Tull drums are marked "Aroclor {or Incineration" and sent to WGK {or storage. HCl fuom TSCl is used in the manu{acture o{ Bisphenol A. Samples o{ Sisphenol A have been submitted to Research to determine whether any PCB's are present. Analytical problems have been encountered by Research. New laboratory {anilities have just been completed which art expected to provide reliable results. Analysis o{ the BPA sample is expected by year end. HONS 045184 Page 7 A t torch wot conducted Ion a substitute fluid for the Hath Compressor, but no satisfactory material could be found. Bitphcnol A manufacture is scheduled to ceate at JFg by the end of 1171. At thin time it may be pottible to alter the HCl system to eliminate the Hath Compaction, and thereby eliminate the ute of Aroclor. ' b. Heating Unitt - Two Two heating tyttemt employing Aroclor 1141 one in ute. Annual lottet total approximately 7500 poundt from these unitt. The bulk of the lottet are the result of pump leakt. Some atmospheric lottet are incurred at no conservation measures are employed on the vents. At an interim meatuAe the department it uting AaocIoa 1747 for loti makeup. Operating inttAuctiont have been modified and personnel'instructed to exert extreme care in handling of Aroclor fluidt to prevent inadvertent t entering. Alternate solution to correct the problems with thete heaters art: 1. Continue with Aroclor fluid, estimated cost $4500, a. Switch fluid to Aroclor 1747. b. Provide large drain pans for pumps. c. Cold trap vents. 7. Change to non PCB containing fluid. Estimated cost $4000. a. Switch to Therminol-66. b. Inert tyttems with COj. - e. Alter line from conservation vent and provide cold trap/flame arrester. The alternates were dotcutted with the department supervisor Von Abreach and alternate *7 recommended. Ur. Abretch agreed with the recommendation providing that Therminol-6i wot found to be compatible with the TSCt streams heated. A study hat been requested of the TSV Process Group and results are expected by 17/51/71. HONS 045185 t Page I 8oth units are heated by 550 tbs. stum. The fluids one. used alt a maximum temperature of 205*C. While this temperature is above the flash and fire points of Therminol-it, ineating of the system utith CO, should provide adequate fire protection. The auto ignition temperature of T-66 is 364'C or 120*C higher than temperature of the heating steam. Therefore instrument malfunctions cannot result in over heating of the fluid. A PAFE for the necessary changes can be submitted by t/1/11. 3. Phthalyl Chloride This department has one Aroclor system used for both heating and cooling of a reactor. Heating is accomplished by the use of bayonet heater submerged in the agitated jacket. The fluid is circulated through an external heat exchanger for cooling of the reactor. Losses are about 1000 tbs./yr. and are primarily from pump leaks. Atmospheric tosses are estimated to be SO lbs./ye. Corrosion of the vessel has become a major problem. The corrosion is caused by the introduction of atmospheric moisture which causes the breakdown of Aroclor to form HCl at the temperatures used |300`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 from corrosion average $1500/yr. Corrective action is a necessity to prevent the toss of the $15,000 reactor and consequent business interruption. Interim actions have been taken to reduce the PCS toss and limit its effect on the environment. Aroclor 1242 is used ' to make up any fluid lost. A temporary drip pan at the pump packing gland has been provided. Operators have been instructed to take precautions against allowing Aroclor fluid to enter the waste effluent and operating instructions modified. Two alternatives were developed to solve the combined PCS corrosion problem in this department. They are: I. Continue with Aroclor fluid. Estimated cost $5000. a. Switch to Aroclor 1242. b. Provide large drain pan for pump. HONS 045186 Page 9 c. Inert the system with N. and panvide, cnnsenvation vent. d. Poovide condensen on conseAvaXion vent, t. Install anptune disc. 2, Change to non PCS containing fluid. Estimated coat 5000. a. Switch to Theaminol-ii. b. Inert the system with and poovide consenvation vent. c. Paovide vent condensen. The altennatives weae discussed with the department supenvison C. Schnock. Atteanate *1 urn chosen pnimanily for safety neasons. The use of etectaicat heating unit* in the jacket wot the oveoaiding considenation. Temperatures could exceed the auto ignition temperature. If the ineating system would fail, an explosive situation could result. A PAFE will be submitted by 1/21/71, if no adverse torments aae /received. 4. "W" Building The "W" Building has thn.ee Anotion heaten systems. The small homemade unit located in the centen section is no longen used and will be isolated to pnevent use. The "yand" unit has an excellent maintenance necond and addition of fluid is none. The losses that do occun ane fnom pump leaks and volatile losses thaough the open vent. > The paineipte sounce of loss fon "01" Building openations is. the leaden unit located south of the ''BBS'' Building. Last yean the pump seal failed on five occessions and accounts foa the majonity of the loss. In addition some volatile losses ant incurred thaough the open vent. A majon oveahaul of the pump was completed in November, but the seals failed within a weeh after stantup. All units ane cuanently down. (Mien openation is neguined only Aaoclon 1242 will be used fon makeup of losses. The manufacturing supenintendent fon the "01" Building, f. Copanas Keponts that cuanent pnoject fonecasts indicate that only ane heater will be neguined fon the foneseeable future. Operations will be confined to the yand unit as tong as only one heater is neguined. HONS 045187 rage to * Two batic alteAnolivet fon a permanent tolution to the PCS lotttt from Ike. two keotent wtAe dit cutted with Meant Suthenlin and Copanat. Ont wat to continue with AaocIoa and the othen to twitch to Thenminol-H. Both men objected to the me of Thenminol-tt fnom a tafety viewpoint. The iluidt in both unite cute heated by open gat flame buAneu. A AuptuAed tube in the fuAnace would netult in a fine. Special initAumentation would be nequined to ttnte the Ha*., thut oil *he gat and extinguith the line automatically. Cunbing to pAevent the tpAead oi buAning fluid lAom the unit would alto be nequined. The itated auto ignition tempenatuAe of the fluid it tomewhat lowen when the matenial it toaked into intulatien. Since the ftuid it frequently heated to ovea SOO'C, a leak into the Intulation could Aetuli in a line. Syttem alteAotiont foA eitheA AaocIoa oa TheAminol-it one in the tame oAdeA of magnitude. Although the tiept AequiAed to be taken fon the continued ute of AaocIoa fluid* it tlill undeA invettigation, the following change* an* being contideAed. 1. Leaden Unit, tttimated cott $11,000. a. Change fluid from AaocIoa lilt to 1241. b. Pnovide new leakpnoof pump. c. Cold tnap vent. d. Clean tyttem. t. VaAd unit. Eitimated cott $7000. a. Change fluid fnom AaocIoa 124t to 1242. b. Pnovide tyttem changing pump. C. Pnovide tump pump. d. PAovide dAip pan (oa. pump. e. Cold tnap vent. f. Pantial noofing of anea. g. Clean tyttem. It it expected that a PAPC could be tubmitted fan changet to both unite by 4/1/71, HONS 045188 Page 11 * S. CLHS The magnitude of PCS losses at CLHS nu unknown, but ant betieved to be targe. Hr. J. R. Savage in hit memo of 9/13/70 ttoted that by 4/1/71 PCB containing Anoolors wUU. no longer be handled in CLHS and that capital improvements cannot be justified on this basis. Department supervision has been requested to exert care in preventing tosses uUthin equipment limitations. Hr. E. R. Kroger has recommended a number of minor improvements to department supervision to minimize losses. The pollution S arranged a film presentation for all personnel ved for motivational purposes. A PAFE has been submitted to replace the present Aroelor unloading pump which has always leaked badly. Prime justi fication for this project is not based on PCB losses, but on unloading capacity, safety and reduced repairs. C. Sewer Sampling Composite samples of the main effluent are submitted for PCB analysis each month. The reported results are Honth 096 June July August September October November 46 43.S 43.0 77 70 It. 9 Analytical problems have been encountered by Research and the figures for September and October are open to question. New laboratory facilities have just been completed. The November results shown were obtained in the new facilities. V. Volatile Losses The volatile losses from the Aroelor unit in phthalyl chloride were calculated at 69 tbs./yr. Volatile losses from the other units are believed to be considerably less. No attempt to calculate or measure these losses was made since completion of the changes proposed in this report will essentially eliminate them. A. E. Peterson HONS 045189