Document j1y8y5KxOwQ2p5qYkxGqy32O

ETHYL CORPORATION 100 PARK AVENUE NEW YORK 17, NEW YORK October 10, i960 Product Service Circular Letter No. PS-22-60 Subject: Sludge Weathering Monitoring Reference: Product Service Safety Manual Section XI TO REGIONAL MANAGERS COPY F0R_______________ Gentlemen: In Letter PS-18-60 it was stated that as part of our test program on sludge weathering disposal, we need to check the sludge that is being weathered an our customers' locations. This letter is to give you specific instructions for doing this checking. Sludge samples should be taken and analyzed at these times: 1. When the sludge is first removed from the tank.for weathering, or as soon afterwards as possible. 2. Four weeks (la few days) from the time it is first spread. 5- If the sample taken after four weeks of weathering has a lead content of .002 Wt.$ (Hellige Comparator reading of 2 using new Lead-In-Soil analytical procedure) or less, no more samples need be taken. If it is .003 Wt.$ or more, additional samples should be taken and analyzed at approximately two week intervals until the lead content of the sludge drops to .002 Wt.$ or below. At each of these times three sludge samples should be taken and analyzed in order to confirm the findings. In addition tothe sludge sampling and analyzing, two Lead-In-Air checks should be made at the same time. The air samples should be taken at a point V' above the surface of the sludge in the middle of the largest patch. If this sample should give a reading of four or more on the Hellige Comparator other samples should be taken to determine the boundary of the contaminated air. (it is not expected that a 4 reading will be found, but if it is, it is important to follow this instruction.) The analysis of sludge samples is to be made using the new Lead-InSoil kits and the "Analytical Procedure - Determination of Organic Lead In Soil" dated September 29, i960. 2- - The material for these kits and the analytical procedures' were dis tributed to the Chief Product Service Engineers bn October 10, i960. Arrangements for using these kits should be made through your Chief Product Service Engineer. In order to get a good representative sample of sludge after it is spread for weathering, the following procedure should be followed: Take some sludge from 12 different points over the entire patch of sludge. At each point, try to get material from, the top, middle and bottom of the sludge layer. Thoroughly mix the material taken from these 12 points in a bucket or other container. The required amount of sludge for the analyses can then be taken from this composite mixture. Whenever the weathered sludge analyzes .002 Wt.$ organic lead or less, it may be considered safe and the sludge may then be treated as any other non-hazardous waste material. Until the lead level is reduced to this point the sludge area should be roped off and treated as described in the sludge weathering procedure in the Mote on Mixing and Handling, "Simple Procedure for Disposing of Sludge From Leaded Gasoline Storage Tanks", which was distributed in September. We want to watch all sludge weathering for a while until we get some field experience and data, therefore this program will not continue., indefinitely. Please notify your Chief Product Service Engineer of any sludge weathering that is scheduled in your area and keep him informed of the progress of the test. At the completion we would like a report by way of the Chief Product Service Engineer of all of the analyses and pertinent data, such as the general atmospheric con ditions and temperatures during the weathering. Please keep in, mind that this is a voluntary program. If for any reason, customers do not choose to dispose of sludge in this manner they, of course, may continue to bury it. Very truly yours, H. K. Ball DRK:gn kE- 0009749