Document NGvmqLpjOjGQnO12351QG9xeg

I. MONSANTO COMPANY ! CENTRAL ENGINEERING DEPARTMENT SAFETY & PROPERTY PROTECTION , ENVIRONMENTAL CONTROL CHECK LIST APPENDIX C Rev. 7/1/70 \ DSW 333358 REFERENCE: EXHIBIT C, CED Procedure 602, Loss Prevention & Environ mental Control Reviews Fora EC-27 - Copies available from Office Supplies Department General Offices, St. Louis ~ STLCOPCB4079935 (EC-27) 1- ENVIRONMENTAL CONTROL CHECK LIST This guide for conducting an Environmental Control Review is primarily a check list of items which should be considered. The goal of the Environmental Control Review is to insure that all plant effluents are adequately and economically handled to minimize pollution potential and the possibility of unfavorable publicity and payment of penalties. Special effort should be directed toward recycling by-products, controlling raw material and product losses, and reducing waste volumes as an economical approach to pollution control, especially as compared to poten tial collection and treatment costs. I. ENVIRONMENTAL CONTROL AUDIT An audit of all plant effluents must be made to provide a basis for evaluating pollution potential and determining the requirements for environmental control facilities. Each discharge to the environment should be reviewed and the following data assembled, both the normal or average, and the range for each component. A. Atmospheric Discharges Chemical composition Quantity - lbs/hr Specific volume - cubic feet/lb Temperature of the discharge Particulate matter included in the vent or stack Chemical composition Quantities Particle size (if available) Height of discharge (elevation above surroundings) Toxicity (if available) . B. Liquid Discharges Chemical composition Flow or quantity PH Acidity or alkalinity Specific gravity DSW 333359 STLCOPCB4079936 (EC-27) -2- Total solids Total dissolved solids ' ; Total suspended solids Total settleable solids .r BOD (biochemical oxygen demand) COD (chemical oxygen demand, i. e., ultimate BOD) Quantities of nutrients ? Nitrogen (nitrates, nitrites, ammonia) v . Phosphorus (phosphates) .^ ' Temperature ? Color Toxicity (if available^ ..................... C. Solid Discharges Chemical composition Quantity - lbs/hr Toxicity (if available) Collection method ` II. QUESTIONS . The following questions should be considered when making an Environmental Control Audit. A. General ...: 1. Flow Measurement . - Can the flow or.quantities be measured? If so, are such facilities necessary? Are they required by law? Sampling Are sampling provisions necessary? Are they re quired by law? If so, have they been provided and are they adequate, especially those for gaseous discharges where particulates are present? Can sampling locations be reached safely or are access platforms necessary? . dS\N 333360 STLCOPCB4079937 (EC-27) -3- 2. Monitoring . Are special instrumentation necessary or justified to detect potential upsets which would result in unwanted (due to the value of lost materials or to potential for pollution) discharges to the environ ment, especially on sewer connnections which may otherwise go undetected? 3. Special Considerations Special consideration should be given any potential discharge of the following materials to the environ ment. a. Acid Gases and Miss I.e., HCl, NO , SO , H~S, HF. X X b. Heavy Metals and Metal Oxides . I.e., Arsenic, barium, beryllium, cadmium, chromium (hexavalent), copper, iron, lead, mercury, nickel, phosphorus, selenium, silver, zinc. c. Miscellaneous Gases - Ammonia, bromine, carbonbisulfide, carbon mon oxide, chlorine, fluorides, hydrogen cyanide. d. Organic Compounds .. Acetone (and other solvents) Acrylonitrile Benzene Carbamate compounds Chlorinated biphenols DDT Fuel oil Gasoline Highly chlorinated organic insecticides Naptha . DSW 333361 STLCOPCB4079938 (EC-27) -4- Naphthalene Organophosphorus compounds - Phenolic compounds Tetraethyl lead Tetramethyl lead (1) Hydrocarbons emissions (atmospheric) ' ,' ' Refer to the National Air Pollution Control Administration, Publication No. AP-64, March, 1970 entitled "Air Quality Criteria for Hydrocarbons." e. Radioactive materials NOTE: ' The above chemicals have appeared in various exist ing and/or proposed regulations; thus their current status vs. local regulations should be checked. In addition, they should be considered as likely candidates for future regulations. f. Others The U.S. Public Health Service Drinking Water ` Standards may also be referred to as a likely source of future regulations. g. Are chemicals which are objectionable because of their odors or lachrymatory properties properly contained or treated to avoid pollution and/or citations based on "nuisance" regulations? This ~! ' includes potential problems due to discharge to city sewer systems. B. Atmospheric -. 1. Is dispersion intended as the prime means of meeting acceptable concentrations in the ambient air? If so, are there other sources of similar discharges in the vicinity which should be considered, and is this method reasonable based on current and anticipated regulations? 2. Will the discharge of the gas in question combine with other materials in the atmosphere to form an undesirable effect, i.e., ammonia and HCl to form an ammonium chloride "haze"? . DsW 333362 STLCOPCB4079939 (EC-27) -5- 3. Are undesired liquids (mists) or particulates en trained in the vent or relief stream or will they form after discharge? Particulates must not only meet local regulations but must not create a poor public image or nuisance. 4. Will the stream be colored, i.e., will it draw attention to itself, such as N02? 5. sire large quantities of water vapor being discharged and if so, is the discharge located so as to avoid visibility and icing problems, especially outside of our plant boundaries? 6. What are the potentials for paint damage from either regular or emergency discharges? Are special con siderations justified? 7. Will "breathing" of process equipment or storage tanks carburet unwanted vapors into the environment? C. Combustion Process, Including Flares and incinerators 1. Have all fuels (and wastes to be flared or incinerated) been analyzed? What will be the products of combustion? Are acid gases, i.e., HCl, SO^, N0X' formed? 2. Flue gases should be reviewed closely as possible ' pollution sources, including flares. 3. If flares are to be used will a "smokeless" type be required? Is the flare sized for emergency condi tions (this is particularly important for toxic . gases to insure complete destruction). Have draw back problems (due to condensation of gases) been considered when handling hot gases? Are continuous purges required? molecular seals? knockout drums? 4. If incinerators are to be used, are scrubbers neces sary? If so, is the scrubber effluent a source of pollution? Is an auxiliary fuel required, special pilot lights? Are materials present in the waste stream or auxiliary fuel which will affect refractory life, i.e., calcium or sodium? 5. Has heat recovery been considered? STLCOPCB4079940 -/***"' 6- - ifv D. Id-quid Discharges 1. Can a local city or area treatment plant handle liquid wastes? What are economics? What limits in quantities or waste composition would be imposed? i.e., pH, phenols, solids, chromates or heavy metals, toxicity, inorganic salts. 2. py-Products , Are there recoverable products in the plant waste , streams? can process recycle by-products? Can special plant waste streams (solvents, alcohols, etc.) be sold for re-processing? 3. Spill and/or Fire Water Control What is the effect on waste treatment in the event a sprinkler or deluge system is operated? Are special considerations justified? Are special provisions necessary for controlling possible spills, especially of liquids with high pollution potentials? Examples: Pump seal leakage Dikes for storage tanks Selective collection of storm water Provision for early detection Are environmental control provisions compatible with safety requirements? Are spills required to be reported to a pollution control agency? i.e., effect on potable water - supplies. Does the plant make a spill report to . the plant manager? 4. gewer Systems Are segregated sewers necessary for: Storm water Cooling water Sanitary wastes Concentrated or general process wastes DSW 333364 STLCOPCB4079941 (EC-27) -7- Are process area floor drains connected to process sewers? Are sewer grades compatible with existing and future sewers? Are special materials of construction required for: Acid or caustic wastes Solvents ! , Plasticizers v ' Temperature Solids or scaling * . '1 Are in-batteiy facilities (API separators, surface condensers, settling basins, etc.) required for: Oil - many waste treatment systems will not accept oil Flammable materials Solids Concentrated organics Odors or lachrymators pH adjustment Temperature reduction , 4. Are facilities provided or necessary to prevent discharge of solvents, etc. to the sewer which might result in explosive vapors in the sewers? 6. Toxicity Does the discharge contain toxic concentrations of any materials (use the 96-hour mean tolerance limit as a guide)? If so, what special precautions are necessary and/or provided to protect personnel who might be required to enter sewers? Will the ultimate plant discharge exceed this 96-hour MTL toxic limit and if so, how does this compare to existing or anticipated regulations? Also, is there any poten tial of fish kills as a result of this discharge, keeping in mind other potential sources and the possibility that similar chemicals may be present upstream of the plant. DSW 333365 STLCOPCB4079942  (EC-27) -8- 7. Storm Water Contamination Has possible contamination of storm water runoff been properly considered? i.e., curbing potential spill areas for drainage to process sewers. If so, has the waste treatment system been designed to accept wet weather surge? Or, if plant effluent is tied into a local city or area sewer system for treatment will they accept contaminated storm water? 8.? Barometric vs. Surface Condensers Are surface condensers justified over barometric condensers in the light of environmental control requirements and economics? 9. Decanting Decanting operations where a water layer is to be drained to the sewer should be considered as a potential source of high losses. This should be reviewed carefully and automatic monitoring con sidered to minimize losses from these areas. 10. Temperature Effluent temperatures should be considered carefully vs. existing and potential regulations. E. Solid Discharges 1. If solid wastes are to be landfilled, is the land fill properly designed and approved? Can toxic materials be properly handled? (This ques. tion must also be considered in the case where our 'wastes are landfilled by others on a contract basis.) Should selective landfills be employed to provide for possible future reclaiming operations? 2. Open burning should not be considered as a means of disposal unless specifically allowed by local regu lations . III. REGULATIONS AND PERMITS A. As a general guide the lowest governmental subdivision Issuing regulations are those which must be met. The ,, DSW 333366 STLCOPCB4079943 (EC-27) 9- local plant can best verify the status of regulations affecting their area. B. Have all potential discharges been checked against exist ing discharges and existing permits? Will new or revised permits be required? C. Are there tax credits or tax depreciation allowances which apply to the cost of waste treatment? D. Should federal or statevgrant money be sought? IV. RECEIVING STREAMS All new plant sites should cQnsider carefully the details of the surrounding environment and the potential effect of the plant on this environment. Air quality, potentials for inversions and stream parameters such as type, minimum flow, history and use all must be considered. V. POLLUTION CONTROL FACILITIES All major pollution control facilities should be listed, including their design capacity (specify limiting design ..parameter) and the expected loading. . DSW 333367 STLCOPCB4079944