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THIS COPY FOR: T. B. Bonney - Pittsburgh FROM E. B. Parker TO Mr^D. DCfteGregor Rockdale Works September 6, 1974 Rockdale Works 9/<t aO V > MONTHLY LETTER - ENVIRONMENTAL ENGINEERING DEPARTMENT AUGUST. 197^_____________________ Safety and Industrial Hygiene Year-to-date safety statistics at the end of August were as follows: Frequency Severity Sum 3*91 .36 4.27 On Friday, August 9, 1974, the Central Texas Red Cross Bloodmobile visited the plant and collected a "record breaking" 150 units of blood. The; previous plant record was 146 units. Forty-one of the donors were firsttime donors. Our Hearing Conservation Program for the plant became effective on August 15, 1974. We are now enforcing the wearing of ear protection in areas of continuous noise, in areas of intermittent noise levels and on specific jobs requiring ear protection. The eighth Red Cross Multimedia First Aid Training Course was held on August 21, 1974. This course was conducted by Mr. Milton Holmes (Potrooms) and was successfully completed by nine employees. Fifty-four employees completed the Vehicle Operator Training Course during August (40 hourly and 14 foremen). Five crane arcings were reported to the Safety Department during August. one Atomizer employee were enrolled in the month. e+new Marinite room showed acceptable levels after 3fe>dust pick-up system on the saw were made. Excessive noise levels were found to be associated with the use of a back-fill rammer (CP-3) and a jackhanmer (CP-113), both being used in Potlining. An extensive series of noise level measurements in the areas around the ingot furnaces in Bldg. 34 showed most locations to be in the borderline range. ALCOA ARCH 18855 MHI <V. Mr. D. D. McGregor September 6, I97I+ Page Two Government Agency Contacts Operating permits covering the four new Ingot Plant holding furnaces and the stand-by fuel oil system were received from the Texas Air Control Board. An application was made to the Environmental Protection Agency for a new NPDES permit. The Texas Water Quality Board issued Rockdale a new water discharge permit. The permit requires the construction of a settling basin on Yegua Creek as it leaves the plant property. All three lignite dryer Venturi scrubbers were shut down for 5-1/2 hours on August 8 to install a strainer in the fan bearing cooling water line. The Texas Air Control Board was given prior notice in accordance with General Rule 8. Messrs. L. E. Drake, Gordon Crowell and C. H. Ross completed the TACB Smoke School. Messrs. Drake and Ross were recertified while Mr. Crowell obtained initial certification. Emissions Test Data Air Emissions testing was completed on all Fotroom scrubbers. A concentrated surveillance program was begun to upgrade the performance of these units. Estimates of the Carbon Plant electrostatic precipitator emissions opacity indicated that a rapping cycle of 1-1/2 minutes per hour results in complying with Air Control Board Regulation I. Water Outfall analyses w< sampling lubdQedure'] for the month of August. Beginning in September, . in the Water Quality Board permit will be Inventory of Alcoa 398 dust collector bags dwindled to a critically low level. Contacts with suppliers were made and delivery promises were obtained which if met, would result in alleviating the problem. To supple ment the inventory and to establish alternate sources of supply, bags were also ordered from vendors other than W. W. Criswell. Two complete bag changes were made in Alcoa 398 dust collectors. ARCH 18856 Mr. D. D. McGregor September 6, 1974 Page Three Conditions Requiring Attention Generation of nuisance dust during ore unloading. No activity High fluoride in run-off water from spent potlining storage pile. Preliminary design of the new storage pad located adjacent to the scrubber lagoons is complete. Preparation of an RFA for funds to build the pad has begun. In the meanwhile several carloads from the present "outside" pile are being shipped to Point Comfort each week. A pump to be used for the eventual elimination of the 24-acre lake overflow was received. Piping has been ordered. High levels of asbestos dust during Marinite sawing. Tests revealed that airborne asbestos levels during sawing remained high even after completion of the new fabrication facility. Compliance was indicated by retests made after several modifications to the saw's collection system had been completed. Efforts to implement the use of cast refractory Properzi spouts and FDC mold headers were accelerated. High dust emissions from the lignite crushing area. Problems with No. 1 boiler precluded any work on installing the new rotodone. Work is expected to begin within the next few weeks. High dust emissions from B79 Dust Collector. :ated, the modified ductwork was installed, and a Es installed. Initial performance of the unit Jgbry after restart, although motor shaft and bearing >aj|p'> Although the dust collector operation seemed OK, . v.... ,,'_S serves (butt crushing) needs considerable attention. o... Excessive dust emissions from the upper levels of Bldg. 54. Installation of ductwork was stopped pending repair of loose covers to improve working conditions. High dust levels in the Carbon Plant Butt Mill area. Improvements in B79 dust collector did little to alleviate the dusty conditions prevailing during butt grinding. Work continues. ARCH 18857 Mr. D. D. McGregor September 6, 1974 Page Four Coal Tar Pitch Volatiles. Information concerning analytical methods was received from ATC. Consideration is being given to having a commercial laboratory perform analysis vs acquiring the necessary equipment to do this work in house. Solid waste disposal An RFA covering the facilities required for solid waste management is being prepared. Replacement of Lignite Dryer Venturi Scrubbers. The first of the lignite dryer Venturi scrubbers has deteriorated to the point of repair or replacement. It was decided to replace this rubber lined steel vessel with one made of FRP. Replacement is scheduled for October General Mr. H. N. Mueller attended a public hearing in Austin, Texas on the proposed Texas Occupational Safety Act. Messrs. Frank Herrington and Tom Sanders from Davenport visited Rockdale to inspect the new skim room. Mr. G. L. Crowell was selected to fill the newly established position of Environmental Engineering Technician. E. B. Parker EBPrak Copies: F. R*. Atkins - Pittsburgh T.`B. Bonney - Pittsburgh V. W. Rieke - Pittsburgh R. C. Hinkle - Badin A. A. Rambikur - Point Comfort B. M. Starner - Rockdale H. N. Mueller - Rockdale L. E. Drake - Rockdale A. G. Clayton - Rockdale ARCH 18858 THIS COPY FOR: T. B. Bonnev-PittsburyH FROM L. E. Drake Rockdale Works August 6, 1974 TO Mr. D.D. McGregor /Roc ' / MONTHLY LETTER - ENVIRONMENTAL ENGINEERING DEPARTMENT JULY. 1974 Safety and Industrial Hygiene Year-to-date safety statistics at the end of July were as follows: Frequency Severity Sum 4.49 59 4.88 During the month, we encountered 99 Company injuries. Five serious injuries are included in this number. A policy concerning danger tags for plant vehicles which are in need of repair or equipment protection was formulated during the month. This policy was announced by means of a Safetygram on July 16, 1974 and becomes effective August 1, 1974. Several meetings were held during the month in regard to our Plantwide Safety Rules. We are in the process of collating and revising these rules for plantwide publication. The seventh Red Cross First Aid Training Course was held on July 17, 1974. This course was conducted by Mr. Leroy Sladek, Mechanical Maintenance and was successfully completed by ten employees. Thirteen crane arcings were reported to the Safety Department during the month. Eighty-six employees completed the Vehicle Operator Training Course during the month (31 foremen and 55 hourly employees). Two Potroom employees were enrolled in the Wise Owl Club during the month of July. Mr. Clarence Kunze, Texas Employers' Insurance Association, visited the Plant on July 17, 1974. He brought with him information concerning our injury costs over a four-year period. Government Agency Contacts A revised NPDES waste water permit for the plant was submitted to the Texas Water Quality Board. ARCH 18859 r FV9S (ftCV. !-) Mr. D. D. McGregor August 6, 197^ Page Two Emissions Test Data Air 300^ can scrap melting opacity tests showed that 3 successive 1,8002,000 lb. charges into the No. 7 furnace render stack opacities above the TACB allowable of 30$. A series of adding 6,000 lbs. in 1,000 lb. increments over a ^5 minute period showed opacities of less than 25$ providing the natural gas. Anode baking furnace stack tests confirmed the 70-75 lb. per hour par ticulate emission level which was determined during 1973- Water Due to lack of rain, flow rates at the outfall were unusually low, although TSS remained high. Sedimentation rate studies were begun to establish the size of settling basin required at the proposed new out fall. A program of frequent sampling accompanied efforts to improve sewage plant control. Environmental Tests Opacity readings from the east end of Bldg. 37 during the metal pad cutting operation exceeded the TACB 30$ level with a range from l<-0$ to 50$. This operation cannot be continued in the present manner if per sistant 40$ opacity readings are attained. Asbestos tests in the new Marinite room indicated need for improvement in dust collection system along with protection from dust transferred to workers* clothing during physical handling of finished Marinite. Spring urinary fluoride survey summaries were received from Pittsburgh. Results reflected little change since last Fall. Environmental Control Activity There were three bag changes on Alcoa 398 units during July. Problems were still experienced with the Line 5 Reacted Ore Tank Metritape. However, the tape straightened itself and there were no false readings after the middle of the month. arch 18860 Mr. D. D. McGregor August 6, 197k Page Three Conditions Requiring Attention Generation of nuisance dust during ore unloading. No activity during July. High dust emissions from the lignite crushing area. The rotoclone was delivered on August 2 and foundation work is expected to start August 12. High dust emission from B-79 dust collector. The shutting off of the fan for 15 minutes each 2 hours was reinstated as a method of maintaining low bag pressure drop and minimal emissions. A bag change is planned when the collector is moved during mid-August. Excessive dusting from upper levels of Bldg. 5^ (coke grinding). The ductwork installation remains as a problem and the project's timetable for completion appears to be late September. L. E. Drake LED: Copy this letter to: P. R. Atkins - Pittsburgh T. B. Bonney - Pittsburgh V. W. Rieke - Pittsburgh R. C. Hinkle - Badin A. A. Rambikur - Pt. Comfort B. M. Starner - Rockdale E. B. Parker - Rockdale H. N. Mueller - Rockdale A. G. Clayton - Rockdale ARCH 18861 ' FROM THIS COPY FOR: E. B. Parker T B. Bonney - Pittsburgh TO Mr. D. D. McGregor Rockdale Works Rockdale Works June 4, 1974 A} 0 ' r .u *V /- MONTHLY LETTER - ENVIRONMENTAL ENGINEERING DEPARTMENT MAY, 1974________________________________________________ Safety and Industrial Hygiene Year to date safety statistics at the end of May were as follows: Frequency Severity Sum 6.31 .41' 6.72 During the month we experienced 123 company injuries, four of which were classified as serious injuries. An additional serious injury for April was recorded during May when X-rays read on May 4 revealed a fracture of a potroom employee's third left finger. He suffered this injury on April 28, 1974, when he caught his left hand between a crowbar and the ring bus. The monthly meetings with the Mechanical Maintenance Department were held on May 6 and 7, 1974. A film recently purchased from Forklift Sales and Service Company entitled "Color of Danger" was shown. This film is also used in the Vehicle Operator Training Program. The first session of the Ladies First Aid Training Course for 1974 was held on May 8 and 9, 1974. This course was conducted by Guard Jimmie Davis and was successfully completed by nine employees and two employees' wives. The DuPont STOP Program got underway during the month. Unit T was preseD. D. McGregor, Plant Manager, and then to the Mr. the Pittsburgh Office visited the plant from May 6 through^^^^^^gSaffe* On May 20 and 21, 1974, he was joined by Mr. R.'r^3Mp8^^^fe||^sburgh Office. These two gentlemen were down to assistto improve our safety performance. Mr. Sharkey felt that the two main areas we need to work on the most are the lack of safety awareness of our employees while performing their jobs and the lack of training to do the job (especially in the areas of crane operation and industrial vehicle operation). The fifth Red Cross Multimedia First Aid Training Course (for men) was held on Wednesday, May 22, 1974, with Personnel's J. T. Terry as instructor. Twelve employees attended and successfully completed this course. rrr * 'v ALCOAUA'. ARCH 18862 |F49I (MV. !) Mr. D. D. McGregor June k, 197 k Page Two Messrs. Curtis England (Potrooms) and Woodrow Dorsey (ingot) were enrolled in the Wise Owl Club during the month. An application was submitted to enroll Mr. B. J. Chambers (Potrooms) in the Golden Shoe Club. Mr. Chambers only suffered a chip fracture of his right great toe and a few bruises when a butt fell over onto his foot putting a deep gash in the metatarsal guard and denting the steel cap. Fifty-one employees graduated from the Vehicle Operator Training Course during the month making a grand total of 118 employees trained to date. Thirteen crane arcings were reported during the month. On May 21 and 22, 197k, Mr. Wayne Lindbrugger with U. S. Safety visited the plant. During his visit, he talked with amaerous employees who were having problems with their prescription safety glasses. On May 10, 197k a meeting was held to lay the groundwork for the proposed Crane Operator Training Program. A review of the Hearing Conservation Program revealed some weaknesses. The program was revised to reflect changes necessary. A plant Noise Map along with a list of specific noisy jobs was prepared to be used in re-education of all plant employees. Noise dosimeter studies were initiated in the Rotrooms, Ore Shed and the Rectifier Stations. Information obtained will be used to up-date the Noise Map as necessary. Dust levels were measured in areas around the Carbon Plant butt mill, packing material loading station and in the BUdg. 60 ring furnace area. Some excessive dust concentrations were found. .uoride Survey was completed May k and data was sent |ghe month for processing. cts aSp^ljoard was notified of a 15-hour lignite dryer scrubber jronra fan bearing failure. Mr. Bob James, Texas Air Control Board staff member, asked for and was granted permission to evaluate a DuPont SO2 mnxmitoring instrument in one of the power plant stacks. His trip was later postponed indefinitely. Notice was received of a Texas Water Quality Utoard Public Hearing to be held June 19, 197k, to consider a change in fmrraat of Rockdale's waste water discharge permit. ARCH 18863 Mr. D. D. McGregor June k, 19714- Page Three A request was submitted for a Texas Air Control Board permit to operate the new standby fuel oil system used to fire the utility steam boilers. Emissions Testing Air Continued observation of the new Skim Room stacks indicated a normal 10-15$ opacity range. During one period of intentionally severe operation, opacity reached 58$ which is in violation of the 20$ TACB limit. Practices will be. established to insure compliance. Repeated dusting necessitated a complete inspection of the Carbon Cleaning Dust Collector. It appeared that the shaker mechanism was worn to the extent that it was ineffectual. Tests made during this period indicated an emission rate of 2^.6 lbs/hr compared with an allowable level of 11.6 lbs/ hr. Work on the shaker mechanism is progressing. Stack testing of an Ingot Plant furnace during pot pad remelting revealed a fluoride emission rate of 1.1 lbs/hr. Efficiency testing of the Line 7W and 8e Alcoa 598 units was performed. Water Total Suspended Solids increased for the fourth straight month; volatile suspended solids and BOD ran higher than normal. Work was begun to determine whether non volatile suspended solids are merely fine sand or silt carried by run-off water. Little River samples are being analyzed concurrently. Emissions Control Activity On May 10 the new reacted ore tank for the Line 5 Alcoa 398 units was put in serviqg^r^fter^a^week-long shakedown the system operated satisfactorily. The Meti^m^^|fej|^^^easviring device presented difficulties which were found equipmei^^^^^^^Lered7 of venting for the tape controls. Corrective Alcoa from W. W. Criswell slowed down and were several weeks behind schedule at month's end. Vendor contacts continued in order to expedite the Micro-Pulse bags. Complete bag changes were performed on Alcoa 398 units 53N, 72E and 83E. Rebagging of 5^N was completed and the unit placed in operation without the Electrostatic suppression grid. It is anticipated that the grid will be ready for operation in early August. ARCH 18864 Mr. D. D. McGregor June 4, 1972 Page Four Information concerning planned emissions control equipment was given to Pittsburgh legal people to help prepare paperwork associated with pollution control bond financing. It was determined that mechanical erection of the second and third electro static precipitators would probably not begin before the dates specified by the Air Control Board. It appears that it will be necessary to approach the Board with this information and to seek an amendment to the schedule from the court. Reason for the delay is late steel delivery. Although the delay is significant, it is felt that the final completion date. May 31, 1975, can be met if no other, complications develop. Installation of the Alcoa 4k6 system for- the Carbon Plant ring furnaces proceeded and the first reactor was set in place at the end of the month. New Legislation and Regulations A study was begun to enable comparison of Rockdale's fluoride emissions with those to be specified in the impending EPA fluoride regulation. Conditions Requiring Attention Generation of nuisance dust during ore unloading. No activity during the month. High fluoride in run-off water from spent potlining. Shipments from the pile resumed the week of May 20, and three cars from "outdoors" were sent to Point Comfort. It is planned now to ship 5 cars per week, 3 from "indoors" and 2 from "out doors." At that rate the outside storage pile should be gone in three months. After the pile is gone, the remaining old, weathered.and widely scattered material will have to be removed. High lev ireifjps dust during sawing of Marinite. Mafefnite fabricating facility is complete. Testing for Revels of asbestos still remains to be done. High dust emissions from lignite crushing area. No activity during the month. High dust emissions from B79 dust collector. Increased surveillance and changes in operating practices have improved the performance of the collector. Construction is reviewing the modified ductwork installation job in order to develop a schedule. AF*CH 18865 Mr. D. D. McGregor June k, 19714Page Five High dust emissions from the Carbon Cleaning dust collector. Problem still appears to be related to inadequate bag shaking. Work continues toward repairing the shaker. Excessive dust emissions from upper levels of Bldg. (coke grinding). Installation of revised ductwork is scheduled to begin June 8, with completion scheduled December 28, 197^- High dust levels in the Carbon Plant butt mill area. Environmental testing revealed some conditions of high dust exposure. Modification to improve dust collection from the mill are being studied. Tests with a water spray dust suppression system have shown promise in minimizing dust generation when filling buckets with packing material. Work continues. Coal tar pitch volatiles We are still awaiting recommendations from the Environmental Health Laboratories on test procedures and equipment. General Mr. E. B. Parker attended a Safety Management Techniques course offered by the National Safety Council. Dr. P. R. Atkins visited Rockdale to review environmental problems and progress. Messrs. Henry Wickes and Russell Putman, Point Comfort Operations, visited Rockdale to-^^tness^lcoa 398 unit emissions testing. E. B. ParJcer EBP: ak Copies: P. R. Atkins - Pittsburgh T. B. Bonney - Pittsburgh V. W. Rieke - Pittsburgh R. C. Hinkle - Badin A. A. Rambikur - Pt. Comfort B. M. Starner - Rockdale L. E. Drake - Rockdale H. N. Mueller - Rockdale A. G. Clayton - Rockdale fcRCH 18866 THIS COPY FOR: T. B. Bonney - Pittsburgh FROM E. B. Parker Rockdale Works TO Mr. D. D. McGregor Rockdale Works May 6, 197k MONTHLY LETTER - ENVIRONMENTAL ENGINEERING DEPARTMENT APRIL, 197k____________________________________________________________ Safety Year to date safety statistics were as follows at the end of March: Frequency - Severity - Sum - 7.09 .36 7.1-5 During the month of April, 110 Company injuries were encountered including three disabling injuries and five serious injuries. The monthly Red Cross Multimedia First Aid Training Course was held on April 17, 197^ with Ronald Ranly of the Mechanical Maintenance Department as instructor. Twelve employees plus one member of the Rockdale Fire Department attended and successfully completed this course. Mr. J. W. Keltner, Industrial Security Specialist with the Defense Supply Agency, visited the plant on April 2k, 1971 and made an inspection of the Atomizer. Mr. L. Patridge (Potrooms), Mr. R. V. Schneider (Ingot) and Mr. Pete Kunz (ingot) were enrolled in the Wise Owl Club during the month. Blood Bank was held at the plant on Friday, April 5, 1971. Our quota was 115 units and we collected 1I3 units which almost met the record of 116 units collected on April ll, 1972. Thirty of the employees who donated blood on April 1 were first-time donors. The first Defensive Driving Course of 1971 was held on April 23-25 (the class elected to have three days instead of four). Seventeen (17) employees and/or their dependents graduated from this course. Forty employees graduated from the Vehicle Operator Training Course during the month. Government Agency Contacts The Texas Air Control Board reported that results of their February IGC Boiler Stack tests showed S02 emissions to be in compliance with Regulation II. r --\1 SA ARCH '8S7 M9T8 (REV Mr. D. D. McGregor May 6, 1974 Page Two The 1973 Emissions Inventory was completed and submitted to the Texas Air Control Board. Reports covering first quarter, 197^ progress on the Anode Baking Furnace and IGC Boiler Stacks pollution abatement projects were submitted to the Air Control Board. An Air Control Board Construction Permit for the new coke storage facility was received. The Air Control Board was notified that start-up of the stand-by fuel oil system for the plant steam generating facility took place on April 30. This project was covered by a Construction Permit. Emissions Testing Air Opacity readings were made on emissions from Ingot Plant furnace stacks during additions of manganese using Solumang. Results of three separate observations were 7$, 25$, 35$ compared with an allowable opacity of 20$. Methods of adding Solumang which result in low fume evolution must be found. Opacity measurements of emissions from the new skim room stacks ranged from 0 to 1^$ compared with an allowable opacity of 20$. Water Total suspended solids were the highest since last October, exceeding permit limits. Fluoride, chloride and sulfate levels declined somewhat. Other Environmental Tests Breathing zone samples taken during milling of Marinite Properzi spouts showed excessive asbestos levels. The operation was stopped until the new dust collection system is operative. The Spring urinary fluoride survey began April 9- Samples taken in the ring furnace area during the packing and pulling operations showed excessive levels of particulate in the breathing zone of the packer-unpackers. Audio dosimeter surveys showed the need for hearing protection in Towmotor cabs and in the furnace and casting areas of the new 360-inch DC casting unit. Emissions Control Activity Complete bag changes were accomplished on Alcoa 398 Units 7^W and 76W. ARC*.18868 Mr. D. D. McGregor May 6, 1974 Page Three An extensive pulsor tube renovation program was begun in Alcoa 398 Unit 83W. These tubes require replacement because of leaks that developed as a result of abrasion by alumina. A complete bag change in Alcoa 398 Unit 5^N, in which the electrostatic suppression grid is being tested, is planned for early May. Installation of the redesigned insulators and high voltage cable input is expected to be complete by early June, at which time testing of suppression system will resume. The Line 5 South Alcoa 398 system Convair line was found to be plugged with a hard gray scale. This reduced the alumina flow through the reactor and resulted in bed attrition which generated an abnormal amount of fine ore for Potroom consumption. New Legislation and Regulations A draft of proposed changes to TACB Regulation VIII covering emissions reductions during emergency episodes was received from Mr. A. A. Rambikur, Point Comfort. Environmental Conditions Requiring Attention Generation of nuisance dust during ore unloading. No activity during the month. High fluoride in run-off water from spent potlining. Shipments of Point Comfort were halted and the size of the storage pile increased. High levels of asbestos dust during sawing of Marinite. Installation of the new dust collector was completed and bags were installed. High dust emissions from lignite crushing area. Shipment of the new rotoclone has been postponed from May until July 5- No activity involving the testing of the dust suppression spray nozzles. High dust emissions from B79 dust collector. High bag drop was found to be a result of re-entrainment of collected dust. Redesign of the dust collector gas inlet was begun to eliminate this condition. ARCH 18869 Mr. D. D. McGregor May 6, 1974 Page Four High dust emissions from the carbon cleaning dust collector. Bags were changed and mechanical work on shaker mechanism was done. Emissions improved, but still appeared visually to be higher than they should. Work continued. High dust emissions from CC-62 dust collector. Opacity remained marginally compliant. No activity. Excessive dust emissions from Carbon Plant precipitator during rapping and insulator cleaning. Delivery of the rapping cycle timer is anticipated May 30. Excessive dust emissions from upper levels of Bldg. 54 (coke grinding). Design complete and ductwork has been received. Site visits for ductwork installation were held. Electrical installation of a fan will be required. High dust levels in the Carbon Plant Butt Mill area. Dusty environment is due to leaks in the mill itself in conjunction with high bag drop in the B79 dust collector. Maintenance efforts were stepped up to minimize mill leaks. Planned dust collector modifications are described elsewhere in this report. Environmental testing is to begin May 2 to establish dust levels and personal exposure. Coal tar pitch volatiles. Personal exposure in the anode and cathode mixing areas needs to be determined. We have repeated our request to the Environmental Health Lab for recommendations on test procedures and equipment. Excessive dust emissions from H. B. Reed boiler slag processing facility Inadequate dust collection results in emissions from Reed's screening operation. No indication from Reed concerning their planned action. E. B. Parker EBP: ak See Page Five for Distribution ARCH 18870 Mr. D. D. McGregor May 6, 197^ Page Five Copies this letter to: P. R. Atkins - Pittsburgh T. B. Bonney - Pittsburgh R. C. Hinkle - Badin A. A. Rambikur - Pt. Comfort B. M. Starner - Rockdale L. E. Drake - Rockdale H. N. Mueller - Rockdale A. G. Clayton - Rockdale ARCH 18871