Document Nen10Y6aXGMzwRYGxgVjDJkXy

DOW CONFIDENTIAL AUTHORIZATION REQUEST COMPANY THE DOW CHEMICAL COMPANY ACQUISI TOR U CAPACITY, QUALITY, MIX j other title 1986 U.s. AREA ENVIRONMENTAL IMPROVEMENT PROJECTS - PRELIMINARY AUTH. NO. US-168763 P DATE: 1/13/86 REVISED: 2/5/86 AREA. U.s. LOCATION: LA, MICH, TEX, WESTERN SPONSOR: B. A. Weaver STARTUP: 12/88 proposal summary $22800M Is requested to provide preliminary engineering and to fund initial phases of the environmental improvement projects at the major U.S. Area manufacturing locations. These projects are necessary for continued compliance with state and federal requirements. Projected annual expenditures for these projects are: 1986 - $22800M1987 - S28000M1988 - $2500M ___ FIXED CAPITAL THIS REQUEST, USMS | TOTAL PROJECT. USMS 19 86 S USMS INFLATION. USMS CAP. INTEREST. USMS 28 33 46500 2300 4500 PROJ WORKING CAPITAL. USMS EXPENSES. USMS NA WRITEOFF STARTUP DEMOLITION LAUNCH AREA PEOPLE CURRENT MFG NA R&D MKT CHANGE TOTAL RELATED AUTHS. JS168298 1984 Environmental S6220QM JS168570 1985 " $49300M BASIS FOR REQUEST (business strategy, protect lit. ana principal reasons) LOUISIANA DIVISION - TOTAL $1100M - PRELIMINARY $70QM Tank Farm Environ. Upgrade, Louisiana Div. - LA-75411? - Total $I100M - Preliminary $700M This project is in Blocks 5 and 6 of the Marine Tank Farm, It provides diking and drainage systems to segregate storm water runoff plus collection systems for systematic recovery to comply with NPDES Permit discharge limitations. MICHIGAN DIVISION - TOTAL $17600M - PRELIMINARY S8100M New Diversion Basin - M-850750P -Total SIOOOOM - Preliminary $3000M - This project is to construct four above ground storage tanks (50MM gallons) and associated piping and pumps to replace a 12 acre pond. This surface impoundment, the current Diversion Basin, will not be in compliance with RCRA regulations and therefore not usable after November 8, 1988. The Diversion Basin allows for emergency response for building spills to the plant sewer, organic load equalization to aid treatment performance, and surge capacity during heavy rains. Ludington Environmental Upgrade - M-850787P - Total $2900M - Preliminary $1400M - This project is to protect the plant shoreline along the Pere Marquette Lake and to provide a collection and monitoring system for storm water runoff. The location of the Ludington site adjacent to the Pere Marquette Lake, which outfalls directly to Lake Michigan, dictates extraordinary precaution be taken to contain a major spill. This project compliments an earlier project which addressed Internal containment and outfall monitoring and will complete the Ludington site environmental upgrade. Air Emission Reduction Phase II - M-850810P - Total $1800M - Preliminary $1500M - This project Is a second phase of air emission reduction and consists of. vent scrubbers, a THROX, and associated equipment due to requirements of the new 1986 State Air Permit. This project will provide air emission reduction of approximately 600M lbs/year of methyl chloride, methylene chloride, and sulfur dioxide from the Dowfax"*, Anion and Cation Plants. -2- Replace Burled Tanks - M-85C811P - Total $1500M - Project is to replace, refurbish, and repipe over 50 underground storage tanks in the Michigan Division to above ground status to avoid regulation under RCRA. This regulation will require ground water monitoring for each individual tank. Rotary Kiln Modernization - M-850812P - Total $1400M - Preliminary $700M - This project will reduce maintenance costs and should Improve burning efficiency from 99.99 to 99.9999% destruction removal efficiency (DRE) so acute hazardous wastes including PCB's can be Incinerated on site.' TEXAS OPERATIONS - TOTAL $29400M - PRELIMINARY $10000M Aeration System Retrofit - T-33175P - Total $2500M ~ Preliminary $1500M - This project will complete the upgrading of the Biological Oxidation Aeration System by installing a new air dispersion system in "A" Lagoon and revising the overall air distribution system. "A" Lagoon has lost over 60Z of its treatment capacity and continues to lose capacity at an accelerated rate. Texas Kiln - T-33177P - Total $18000M - Preliminary S2100M - This project Is for the design, engineering and construction of a licensed RCRA waste incineration train within the Plant B facility. RCRA requirements and anticipated receipt.of the RCRA Part B Permit make it necessary to complete construction and successfully perform a RCRA Part B trial burn in 1988. Preliminary reviews with the new Dow facility acquired from Upjohn at La Porte, Texas, Indicate this kiln will be able to accommodate the waste generated there. This preliminary request will provide design and engineering support as well as funds to place orders for long-delivery equipment. New Class I Landfill - T-33234P - Total $1500M - This project is to construct a new Class I Hazardous Landfill for Texas Operations to be in operation by the 4th quarter, 1986. The existing landfill will be full by the end of 1986. This landfill will be designed to comply with the latest regulations and will have a double polyethylene liner and double leachate collection system. The alternative to constructing this facility is to dispose of waste in a commercial facility off-site. Magnesium Slag Disposal Phase I - T-33235P - Total $3000M - Preliminary $2500M - This project is for the design engineering and construction of a crushing and screening plant at A401 to process 25000M# annually of slag from Magnesium operations. 1500M#/year of magnesium product will be recovered for sale. The slag is presently going to landfill. Disposal of magnesium slag is currently exempt from regulation under RCRA. However, under the new EFA proposal, this material will be considered a hazardous waste due to its reactivity. This project is the first phase of rendering magnesium slag a non-hazardous waste. The anticipated passage of this rule is September 1986 with 6 months allowed for compliance. P0 Vent/Bottoms Incinerator - T-33238P - Total $2400M - Preliminary S400M - This project is to install a THROX unit with an acid recovery system to Incinerate the vent and bottom organic compounds from the crude propylene oxide process at B1300, including the new PDC finishing system. Chlorinated hydrocarbon liquids will be used for fuel and recovered acid will be used to neutralize the propylene oxide process bottoms stream. This unit will reduce organic compounds emissions by 1500M#/year and will incinerate 25MM pounds per year of chlorinated hydrocarbon compounds. Groundwater Clean-up Phase III - T-33244P - Total $2000M - This project will complete the groundwater clean-up at the A-41 inactive landfills which was begun in the 1985 Environmental Authorization. New requirements were determined after final assessment reports and a Compliance Agreement with the Texas Water Commission, which includes 8 recovery wells, 1300 feet of additional slurry wall and modifications to the steam stripper at Plant A to treat recovered groundwater. r>0 073570 CONFTOFNTTAl -3WESTERN DIVISION - TOTAL $52QOM - PRELIMINARY $4000M Secondary Containment - Phase II - W-84140P - Total $1500M - Preliminary $300M - This project is a continuation of a spill containment program in existing diked areas. This containment is needed to prevent contamination of groundwater from existing storage. Products requiring spill containment upgrading include TeloneTM, trichlors, DowanolTM DM, propylene glycol, methylene chloride and others. Solar Pond Elimination - Phase II - W-84170P - Total $3700M - Preliminary $3700M - This project completes the elimination of aqueous waste from the chloropyridine complex (Symtet, N-ServeTM, Lontrel1" and LontrelTM semi-plant). Process changes include both process vent and relief valve discharge containment for recycle or combustion. In addition, chlorinolysis will be used to treat the aqueous wastes to provide suitable quality brine for recycle. The technology needs to be in place and functioning to meet both Dow's goal of eliminating hazardous waste surface impoundments by October 1987 and a new State regulatory prohibition effective July 1988. 0 07357 1 ^0NRlOFisj-f TAL