Document jmwD8NZbJoGjYJm8p1ebx9xNQ

Monsanto " St. Louis - General Offices August 7, 1970 ANNISTON - PC3 - CLEANUP PROGRAM Mr. H. S. Bergen, Jr. - H3ER0 ' John Mason - JMASO Z. ?. Wheeler - ZWHEE J, Pacsrearre . - wpAPA F. J. Holz.'.pfel - FHOLZ D. 3. Hosraer - DHOSM J. R. Savage - JSAVA Q. L. Jessee - Anniston J. C. Landwehr - Anniston CONFIDENTIAL - F. Y. I. AND DESTROY Following ara the moves underway resulting from the FDA findings of high levels of PC3 in fish taken from Choccolocco Creek down stream from it's confluence with Snow Creek. STATUS (1) We are presently discharging to Snow Creek about lSr/a.y of PC3 (down from-250#/day in '69). Measurements of departmental waste streams show a total loss of only 2#/day. The discrepancy is believed due to; (a) sampling problems In departmental waste streams where two-phase systems of water and free aroclcrs may be present, and (b) possible pickup of PCB by leaching previously deposited PCB from the limestone neutralization pit which also acts aa a settling basin. (2) Work to further reduce losses presently underway: a) Sump is being installed at the aroclor department to cap ture free aroclors from the 275 gpra flow. This Is believed to be the largest departmental source of sewer loss because of the liquid aroclors frequently observed. However, sampling work did not confirm the belief because, no doubt, of inherent sampling problems. The project was due for completion on S/1, and had been delayed because of an underground spring. b) Curbing is being Installed at dram loading area with dry pick up of spilled aroclors planned. c) Investigation of treatment methods - adsorption by acti vated carbon showing most promise to date, (3) Joe Crockett, Secretary of the Alabama Water Improvement Commlselon, will try to handle the problem quietly without release of the information to the public at this time. He believes that FDA will not precipitately In this matter (he did not advise how FWQA might react). Dr. Myers, Director of Public Health of Alabama, wants toxelty information on PCB's and this will be conveyed per sonally to him by Jack Oarrett next week. MCNS 033851 HARTOLDMON0034537 H. S. 3ergen, Jr. August 7, 1970 Page 2 PROGRAM (a) Public Relations - E. V. John developed a proposed state ment to be used in event of public disclosure but, after consul tation with Legal, felt it should not be used because of the recent lawsuit instituted against the plant by BASS. Therefore, an innocuous, essentially "no comment" type statement is being drafted. (3) Operator Education - All Anniston personnel have been read vised of the necessity to avoid sewering of any aroclor. (C) Mechanical Program (1) Departmental Sump - at extra cost of $2,000, work is proceeding on an overtime basis with completion expected c/12/70. This will eliminate the possibility of large los ses from the operating area. (2) Loading Area - Washup of spilled aroclor has been stopped and dry pick via sand instituted. Curbing project is being expedited. (3) Neutralization Pit Clean out (a) Immediately, the settled material downstream of the limestone will be removed as well as possible by pumping, with minimum stirring of the water. The solids (and aroclors) will be landfilled. (b) By-Pass of Neutralization Pt. - Cn crash basis, trenches will be dug to allow diversion of all water from the limestone pit. This will take 1-2 weeks and will cost about $10,000. In addition, it will be necessary to provide caustic neutralization of the acid wastes. This will be handled in the aroclor department via installation of a pH con troller and valve with temporary piping and trucking facilities. Cost' will be about $5,000 plus about $500 per day for caustic during the period when the alternate neutralization Is required. During this period, PCB losses should be no more than 5 ~ 10 lbs./day. MQNS 033852 HARTOLDMON0034538 H, S. Bergen, Jr. August 7, 1970 Page 3 (c) Cleanout - The pit will be thoroughly cleaned out with probable removal of the present deteriorated asphalt membrane and replacement (possibly) by a plas tic membrane which can resist aroclors. The plant will consider possible structural changes to permit more affective operation and ability to make future cleanouts without the present by-pass steps. Recommendations rel* alive to this will follow. (4) Water Flow Reduction - Present total flow through pit Is 700 gpra. For at least several of the etrearas, reduction of flow will result lr. immediate reduction of PC3 to Snow Creek. More important, reduction of flow will minimize future treat ment costs. In conjunction with the pit by-pass work in 3(a) above, approx imately 200 gpm of aroclor free water will be permanently diver ted. Included in the first reduction are the chlorinator cool ing streams and most of the water coming from the Nlran flare tower. Details of how this will be accomplished will be avail able by 8/14/70. Over the next 3 ^ months, further water conservation projects will be installed with objective of reducing the stream to the lowest practical amount, now estimated to be about 300 - 400 gpm. The projects will involve multiple use of water and fur ther diversions of aroclor - free water. (5) Final Treatment - Based on some indications ( and much hope), by September, the actions above may approach the present plant objective of 10 ppb of PCB's In ?0O gpa (or 0.1 #/day). The hope Is raised because dissolved aroclor has shown a pronounced affinity for surface adsorption (as on walls of sample bottlea). The solids generated by the limestone neutralization are believed to retain aroclor passing by them. Therefore, adequate settling and/or filtration following neutralization with periodic removal of the solids may accomplish the necessary treatment (along with water flow reduction). The plant will proceed on preliminary design of filtration facilities with and without carbon treatment between neutralization and filtration. The design will be avallable for action In case the reduction is not as great as hopedfor or In oase the control agencies demand mdre complete removal (control agency requirements are a completely unknown factor at present). By the time a decision must be made relative to final treatment, we-should have better information on requirements and methods. M0KS 033B53 HARTOLDMON0034539 1 H. S. Bergen, Jr. August 7, 1970 Page ** (D)Pish, Mud and Vater Sampling - Since our fish samples from nearby Choccoloceo Creek also showed high levels of PCS's, we are Institu ting more sampling to determine extant of the problem. Early during the week of 8/10, legal size fish will be caught in Choccoloceo Creek near to confluence with the Coosa River (Logan Martin Lake). Pish will also be taken from the lake. If these samples show high (-^5.0 ppm) levels of PCS, sampling will be extended to pointa down the Coosa River. A high priority will be given these samples by Scott Tucker. Progress reports will follow at suitable intervale. Paul B. Hodges /np MONS 033854 HARTOLDMON0034540