Document e1nogZZdK7jLNnO9E2RjZy4xE

Monsanto 'Mo .mam* LocAnoHi p b Hodges ~ General Offices May 12, 1969 AROCLORS CLEAN-UP FROM PLANT EFFLUENTS to Mr. W. A. Kuhn (4) E-N-T-I-A-L . _< . .*/- y TM Messrs. D. B. Hosmer W. R. Richard E. S. Tucker E. P. Wheeler G. L. Bratsch D. W. Jackson B. R. Williams C. P. Buckley W. B. Fapageorge J. C. Landwehr w. F. Taffee E. 0. Wright At your request (and for your transmittal to appropriate members of the Business Group), I have summarized information on actions, plans and problems at Anniston and at V. a, Krummrlch to avoid sewering aroclors into natural waters. The Informa tion was obtained from Messrs. W. F, Taffee (Anniston) and C. F. Buckley (W. Q. Krummrlch). I. Analyses of Waste and Natural Water Samples A. General Ve have generally taken the position that, before any expensive projects are undertaken to holt sewering of aroclors, we should know what levels exist In the receiving waters, in other words, we need to define problems. If any, resulting from loss of aroclors in the.plant effluents. This work is, of course, de pendent on development of analytical techniques and implementation of these techniques in the plants (or arrangements to have the samples analyzed in a single laboratory), deneral statue of this work Is that Dr. Tucker has developed the necessary techniques (ahead of schedule) and haB analyzed one lot of samples from Anniston and will soon have completed analyses of several samples from W. 0. Krummrlch. Transmission of analytical methods to the plants Is expected during mid-May. However, problems of manpower priority exist at both plants and, in addition, there is a problem of equip ment priority at Anniston. As soon as the laboratory techniques are received and studied by the plants, we need to determine priority of the aroclors testing program 117 tn thT wnr yy "b- "taln the necessary manpower arfl equipment. EDO of -Study phase - June 1, 1969 (both plants). We will then move to clarify problems of priority (EDC - June 15, 1969). HONS 036147 DEFENDANT'S EXHIBIT y WATER PCB-SD0000054939 u Mr. W. A. Kuhn -2 - > May 12, 1969 B. Problems at W. Q. Kruanrleh The necessary electron-capture equipment Is available but only one licensed operator Is available. He has a full schedule of other work laid out for the near future, so priorities must be established. C. Problems atAnniston Electron capture equipment exists at Anniston but it has never been used. Considerable developmental work is necessary, therefore, for someone to familiar ize himself with this equipment and then to work out the technique for PCS content. Another problem Is that of equipment priority because the chromatograph, with which the eleotron capture is used. Is occupied full time on other high priority work. II. Work to Minimize Losses at W, G. Krummrlch In absence of analytical techniques for actual measurement, a qualitative study of loss sources has been made. The only substantial source (that of occasional sewering of the Therminoi from F255 production) was immediately stopped and instructions have been issuedunroughout the plant ` that no aroclor Is to be sewered Intentionally. A. Motes on Aroclors Production Department 1. With the recent years Improvements In chlorinator off-gaB cooling pluB Brink mlBt eliminators, there is no longer any free aroclor in the HC1 off-gas which comes out In catch pots (at one time this was considerable). The catch pots never require draining. 2. The only sewered source of Iobs of significance Is from leaks, Bpllls, pump packing glands, etc. Supervision has moved to minimize these sources, but no positive protection exists. As policy on any new construction (as being planned for the aroclor storage tank farm and car loading opera tion), sumps will be provided to capture any spillage. However, no action la presently plan ned to swmn the production area. This will de pend on need as evidenced by sampling of our plant outfall and the Mississippi River. 3. The only discharge to atmosphere is from packag ing, T/C loading and spillage (particularly on to steam traced lines). No changes are planned. The air stream from the blow tankB Is being HONS 036 WATER PCB-SD0000054940 O Hr. W. A. Kuhn -3- ) May 12, 1969 drowned to sewer (this sewered stream will be tested eventually, but Is believed to be Insignificant). B. Other Possible Sources 1. Tank car washing - Infrequent, but significant (up to 200 gallons). Warehouse department per sonnel are studying alternates - no major pro ject Is anticipated but minor changes should virtually eliminate any significant loss. 2. Miscellaneous menuinol systems -- no intentional sewering is now made; however, accidental losses can occur. No projects are contemplated at this time, but these systems must receive high opera ting and maintenance priority to minimize acci dental losseB. 3. HC1 off-gas vapor losses (including spent carbon from KCl treatment) -- these are believed to be very small but will be measured when analytical techniques are available. Waste water samples are being collected Intermittently now for later analysis. Ill* Work to Minimize Losses at Anniston A. Definition of Problems 1. External to plant -- that a problem exists at Anniston is evident because 11 free" globules of aroclors can be seen in Snow Creek. We do not know what problem exists In Choccolocco Creek and the Coosa River. By July 1, 1969, we will determine the limit of visual evidence of aroclors downstream In Snow Creek. Between this "point of last visible evidence" and the mouth of Snow Creek, two sets of mud and water samples for soluble losses will be collected with EDO of analyses targeted for August 1, 1969. Two sets of mud and water samples will be taken in Choccoloooo Creek -- one about 1/4 mile be low the Snow Creek mouth, the other about 5 - 10 river miles further downstream. EDO of analyses August 1, 1969. \ MQNS 036149 f WATER PCB-SD0000054941 o Mr. W. A. Kuhn -4 May 12, 1969 Further testing will depend on results from the above sampling. PlanB will be made by August 15. 1969. 2. Internal plant problems -- here is schedule for measurements and controls inside plant: a. Identification of possible sources -- done. b. Audit (measurement) of loss sources - EDO July 1, 1969. c. Recommendations for means to reduce lOBses to limit of solubility - EDO August 1, 1969. d. Definition of requirements and rough coats to reduce as in (c) above - EDC October 1, 1969. e. Establish continuous monitoring station on Choccoloeco Creek (for aroclors and PNF and Parathion) - EDC June 1, 1970. The above schedule is dependent on obtaining necessary manpower and equipment for the analyti cal work. As mentioned before, there Is no experience with the electron capture equipment and the chromatograph Is utilized full time. To adequately conduct an Investigation and con , ,tinued monitoring program will likely necessitate addition of a chemist plus purchase of a $10,000 chromatograph. This problem will be defined by June 1 1969 with recommendations by June 15, 1969. B. Work to Reduce Sewering 1. Aroclors In HC1 -- a catch tank has been instal led In the vapor line near the HC1 absorber. The aroclors captured are now being hauled to landfill. A coalescer is being Installed to capture aroclor globules in the crude muriatic add. This aroclor will be taken to land fill. 2. Therminoi Systems -- no known losses were found from these systems. Spent aroclor from the P2S5 operations has been drummed for hauling to land fill for at least the past several years. 3. Aroclor production department -- an audit of losses is under way. Ho aroclors are sewered intentionally -- losses are of mechanical nature. Need for a sump system will be defined by the audit and a project(a) will be submitted if Justified. MOWS 036150 WATER PCB-SD0000054942 o Hr, Vi. A. Kuhn -5- ) May 12, 1969 4, Losses to atmosphere -- there are no process losses to atmosphere except for tank car load ing, etc, A closed loop loading system is planned for about 1970-1971 (objective Is reduction of contamination of aroclor). 5. Tank car cleaning -- this is not a problem at Anniston, No heels are drained to the sewer. Comments from recipients of this letter are Invited. Paul B. Hodges acd HONS 030151 WATER PCB-SD0000054943