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THE ToV' OF-) ENVIR ONMENTA L EVALUA TION IF you are proposing a new product, new formulation, or new application, or IF you are developing new processes or process modifications which will increase the total volume or the concentration of any component (except water, nitrogen, oxygen, or carbon dioxide) --by 25%, or --above legal limits, or --from zero THEN you will enter onto the steps of this procedure. . . FOR NEW PRODUCTS, NEW FORMULATIONS OR NEW APPLICATIONS OF EXISTING PRODUCTS Depending on where the idea is conceived (R&D, Commercial Development, Marketing), it is up to the appropriate Research Group Leader, Commercial Development Project Manager, or Product/Market Manager.. . 1. TO FACT FIND, AND PREPARE A PRE LIMINARY ENVIRONMENTAL COMPAT IBILITY ASSESSMENT, TO BE SENT TO THE MEDICAL DEPARTMENT. THIS ASSESSMENT WILL INCLUDE A STATEMENT OF PRINCI PAL SOURCES OF INFORMATION, A REQUEST FOR A PRELIM INARY ENVIRONMENTAL EVALUATION, AND COMMENTS OR ANSWERS ABOUT THE FOLLOWING: DSW 333438 STLCOPCB4080015 * Environmental Conpatablllty Assessment Page Tv:o Dst-a Sheet BC-2Q1 (cont.) Description of frhc Probable End Uses - A. Is the acute toxicity (via oral ingestion, skin absorption, . inhalation) known or can it be estimated by analogy based on data for chemically related compounds? Indicate below: Known 1) oral LD -rats ' . or 2} skin absorption MLD-rabbits ___ or 3) inhalation effect ^ ^, or- 4i skin irritation potential _ or 5) eye Irritation potential or Estimated ' mg/kg __________ mg/kg B. Are harmful effects from repeated or chronic exposures known or can they be predicted ny analogy? - C. Will l) wastes from manufacturing -' 2) anticipated use, and/or ' ' 3) ultimate disposal of end product create environ- mental problems because product fails to readily degrade .or' decompose? - ' D. Is there an indication based on data or analogy, that the product can be stored or concentrated In biological ** systems? . . E. Is It likely that harmful secondary reaction products will arise from a harmless-appearing parent as a result of chemical, biochemical, or biological activity in the environment? . NOTE: .t ` The Medical Department should be consulted for ansv^ers to Questions A and B. Questions C - E require speculation by people know ledgeable about the process and end use. DSW 333439 STLCOPCB4080016 2. ONLY AFTER THE MEDICAL DEPARTMENT responds to your EC-201, and concurs, can you release samples to potential users. 3. BASED ON THE RESULTS OF THE EC-201, you should arrange for additional studies (toxi city, biodegradation, etc. ) to obtain more infor mation on how your product will affect the en vironment. 4. BEFORE COMMERCIALIZATION, you'll have to initiate a final environmental evaluation (Data Sheet EC-202, below). Include the principal sources of your information, the uses of the new product, and a request for an environmental eval uation with intent to commercialize. Send your completed Data Sheet to the Medical Director and Manager, Environmental Protection (Bill Papageorge). DSW 333440 STLCOPCB4080017 -2- (Cont. EC-202) ` Environmental Compatibility Assessment Scheme Instructions: '; ' ' . Answer each cuestion in turn, "yes" or "no". Each answer - is provided with a directive concerning the cuestion to be answered next: the logic of the scheme assumes that aues= ' tions skipped would be answered "no" and can thus be ignored. The last ouestion, No. 12, should be considered if it is decided to make and sell materials which are very useful but potentially danaerous to man or his environment. When applying this form, consideration must be given to the product .Monsanto supplies, product impurities, as well as thefinaIl or end p. rpduct th- at ent.er. s the environment. ITEMS 1 THROUGH 3 ARE TO ESTABLISH THE HAZARDS TO HUMANS OF PRODUCTS, PRODUCT IMPURITIES, BY-PRODUCTS OR MANUFACTURING AND DEGRADATION PRODUCTS. . If Go to: ' 1. Is the material so physiologically inert that there need be no con- cern about health hazards to . humans? ` i. .2. a) ' Is the material toxic to persons as a result of a single contact with high concentrations? yes No . . 4` 2&3 ` . '* * ' b) Is the material toxic to persons at lesser concentrations following repeated or prolonged ' exposure? .. ' .' c) Is the material likely to be carcinogenic, teratogenic or mutagenic? * . 3. Recognizing the hazards to people, can procedures be devised for . safe handling at reasonable cost? `. ` Yes 4 No -Do Not Sell ' ITEMS 4 THROUGH 6 ARE TO ESTABLISH IF CONSIDERATION HAS BEEN GIVEN TO DISPOSAL, DEGRADATION PRODUCTS OF DISPOSAL AND EMVI P.ONMF.N TAL DE GRA DAB ILITY . - If Go to: 4. .: - Can "closed-loop" disposal pro visions be developed for the product so it will never reach the environment? ' Yes .No 5 - . DSW 333441 STLCOPCB4080018 -3- (Cont. EC-202) If Go to: 5. Is it likely the degradation ' products from the "closed-loop" ' disposal system could be harm ful to humans? Yes -Recycle Degra dation Products to 2. Continue at 6. Ho .7 6. Is it likelv that the product will degrade in the environment . .or in anv of the currently used disoQsal systems? - Yes -Recycle Degra dation Products to 1. . Continue at 7. No . 7 ITEMS 7 THROUGH 10 ARE TO ESTABLISH HAZARDS OF PRODUCTS AND DEGRADATION PRODUCTS TO PLANTS, ANIMALS OR ECOSYSTEMS. 7. Is it probable that the product or degradation products are harmful to plants and animals at concentrations to which they are likely to be exposed? Yes No - . 8 9 8, Recoanizino the hazards to . plants and animals, can oroce- dures be devised at reasonable costs to render the material innocuous? Yes 9' No -Do Mot'Sell 9. Is it likelv that harmful secondary reaction products could be formed from the _ harmless parent material as * a result of a chemical, bio chemical, or biological activity - in the environment? Yes -Recvcle the By-product at 1 & 7. Continue at 10. No 10 10. ' Is there reason to suppose that the material could have dele terious effect on the ecosystem, e.g., through concentration in the food chain, antagonism, synergism, abiotic reactions, chelation or plain physical con- centration even though the material was not directlv toxic to the biota? . _ . ` . ves -Recycle to Continue at 11. No 11 : 8. 11. Have procedures been devized to handle catastrophes in the production, storage, or trans portation of the product? '. Yes -Sell 12. Is it necessarv to restrict sales to specific end uses? DSW 333442 STLCOPCB4080019 J 5. BASED ON YOUR REPORT, the Medical Director will respond on the environmental acceptability, restrictions, or additional information required about the new product. 6. WITH THE MEDICAL DIRECTOR'S blessings, the Business Group Director can approve commercialization. DSW 333443 STLCOPCB4080020 FOR NEW PROCESSES 1. DEPENDING ON WHO IS RESPONSIBLE (Research Group Leader, General Superin tendent, TSD, or Guest Superintendent), you will have to prepare a preliminary environ ment evaluation review. This should be made along with the loss pre vention review, and be coordinated with the Director of Safety and Property Protection. Use the environmental control check list be low as your check list. DSW 333444 STLCOPCB4080021 (EC-27) -1- ENVIRONMENTAL CONTROL CHECK LIST _ This guide for conducting an Environmental Control Review is primarily a check list of items which should be considered. The goal of the Environmental Control Review is to insure that all plant effluents are adequately and economically handled to minimize pollution potential and the possibility of unfavorable .. publicity and payment of penalties. Special effort should be directed toward recycling by-products, controlling raw material and product losses, and reducing waste volumes as an economical approach to pollution control, especially as compared to poten tial collection and treatment costs. I. ENVIRONMENTAL CONTROLAUDIT An audit of all plant effluents must be made to provide a basis for evaluating pollution potential and determining the requirements for environmental control facilities. Each discharge to the environment should be reviewed and the following data assembled, both the normal or average, and the range for each component. A.- Atmospheric Discharges - Chemical composition _ ' Quantity - lbs/hr Specific volume - cubic feet/lb Temperature of the discharge Particulate matter included in the vent or stack Chemical composition Quantities _ Particle size (if available) Height of discharge (elevation above surroundings) Toxicity (if available) B. Liquid Discharges Chemical composition Flow or quantity PH Acidity or alkalinity Specific gravity DSW 333445 STLCOPCB4080022 (EC-27) -2- Total solids Total dissolved solids . .. . Total suspended solids - .. . ' .J ; Total settleable solids * :: - ... .. BOD (biochemical oxygen demand) ' . COD (chemical oxygen demand, i.e., ultimate BOD) . Quantities of nutrients J Nitrogen (nitrates, nitrites, ammonia) 1 ..Phosphorus (phosphates) : * * ' Temperature > - - ' .. . Color . Toxicity (if availablejT . ...... C. Solid Discharges Chemical composition Quantity - lbs/hr Toxicity (if available) ' Collection method ' . - '** II. QUESTIONS . '' "` The following questions should be considered when making an * Environmental Control Audit. A. General '. 1. Flow Measurement Can the flow or quantities be measured? If so, are sucl facilities necessary? Are they required by law? Sampling Are sampling provisions necessary? Are they re quired by law? If so, have they been provided and are they adequate, especially those for gaseous .discharges where particulates are present? Can sampling locations be reached safely or are access platforms necessary? . DSW 333446 STLCOPCB4080023 (EC-27) -3- 2. Monitoring . Are special instrumentation necessary or justified to detect potential upsets which would result in unwanted (due to the value of lost materials or to potential for pollution) discharges to the environ- ` . ment, especially on sewer connnections which may otherwise go undetected? - 3. Special Considerations . Special consideration should be given any potential discharge of the following materials to the environ ment. a. Acid Gases and Mists . I.e., HCl, NO , SO , H-S*, HP. X X^ b. Heavy Metals and Metal Oxides . I.e., Arsenic., barium, beryllium, cadmium, chromium (hexavalent), copper, iron, lead, mercury, nickel, phosphorus, selenium, silver, zinc. c. Miscellaneous Gases ' ' .; . Ammonia, bromine, carbonbisulfide, carbon mon oxide, chlorine, fluorides, hydrogen cyanide. d. Organic Compounds Acetone (and other solvents) - , Acrylonitrile , Benzene Carbamate compounds Chlorinated biphenols ' ' DDT . . Fuel oil . - Gasoline Highly chlorinated organic insecticides Naptha . Sw 333447 STLCOPCB4080024 (EC-27) -4- Naphthalene . Organophosphorus compounds - Phenolic compounds . Tetraethyl lead Tetramethyl lead -. . (1) Hydrocarbons emissions (atmospheric) ' .` ' . '' - Refer to the National Air Pollution Control Administration, Publication No. AP-64, March, 1970 entitled "Air Quality Criteria for Hydrocarbons." Radioactive materials NOTE: ~ The above chemicals have appeared in various exist ing and/or proposed regulations; thus their current status vs. local regulations should be checked. In addition, they should be considered as likely candidates for future regulations. f. Others ' TheU-S. Public Health Service Drinking Water - Standards may also be referred to as a likely - source of future regulations. g. Are chemicals which are objectionable because of their odors or lachrymatory properties properly contained or treated to avoid pollution and/or citations based on "nuisance" regulations? This includes potential problems due to discharge to city sewer systems. B. Atmospheric - . 1. Is dispersion intended as the prime means of meeting '' acceptable concentrations in the ambient air? If so, ' are there other sources of similar discharges in the vicinity which should be considered, and is this method ' reasonable based on current and anticipated regulations? 2. Will the discharge of the gas in question combine with other materials in the atmosphere to form an undesirable effect, i.e., ammonia and HCl to form an ammonium chloride "haze"? ' . DSW 333448 STLCOPCB4080025 (EC-27) -5- 3. Are undesired liquids (mists) or particulates en trained in the vent or relief stream or will they form after discharge? Particulates must not only meet local regulations but must not create a poor public image or nuisance. 4. Will the stream be colored, i.e., will it draw attention to itself, such as NC>2? 5. Are large quantities of water vapor being discharged and if so, is the discharge located so as to avoid visibility and icing problems, especially outside of our plant boundaries? 6. What are the potentials for paint damage from either regular or emergency discharges? Are special con siderations justified? 7. Will "breathing" of process equipment or storage tanks carburet unwanted vapors into the environment? C. Combustion Process, Including Flares and Incinerators 1. 2. ' Have all fuels (and wastes to be flared or incinerated) been analyzed? What will be the products of combustion? Are acid gases, i.e., HCl, SCu, NO , formed? X Flue gases should be reviewed closely as possible pollution sources, including flares. 3. - . If flares are to be used will a "smokeless" type be required? Is the flare sized for emergency condi tions (this is particularly important for toxic gases to insure complete destruction). Have draw back problems (due to condensation of gases) been considered when handling hot gases? Are continuous purges required? molecular seals? knockout drums? . 4. ' If incinerators are to be used, are scrubbers neces sary? If so, is the scrubber effluent a source of pollution? Is an auxiliary fuel required, special pilot lights? Are materials present in the waste stream or auxiliary fuel which will affect refractory life, i.e., calcium or sodium? 5. Has heat recovery been considered? DSW 333449 STLCOPCB4080026 0 5* ) 6- D. Liquid Discharges 1. Can a local city or area treatment plant handle liquid wastes? What are economics? What limits * in quantities or waste composition would be imposed? i.e.f pH, phenols, solids, chromates or heavy metals, * toxicity, inorganic salts. * ' 2. By-Products /*, ** -- '' , Are there recoverable products in the plant waste . streams? can process recycle by-products? Can special plant waste streams (solvents, alcohols, etc.) be sold for re-processing? 3. Spill and/or Fire Water Control What is the effect on waste treatment in the event a sprinkler or deluge system is operated? Are special considerations justified? Are special provisions necessary for controlling possible spills, especially of liquids with high pollution potentials? Examples: Pump seal leakage Dikes for storage tanks ' Selective collection of storm water Provision for early detection Are environmental control provisions compatible with safety requirements? Are spills required to be reported to a pollution control agency? i.e., effect on potable water ' supplies. Does the plant .make a spill report to . the plant manager? 4. Sewer Systems . Are segregated sewers necessary for: ". Storm water Cooling water Sanitary wastes Concentrated or general process wastes 05W 333450 1 STLCOPCB4080027 (EC-27) -7- Are process area floor drains connected to process sewers? Are sewer grades compatible with existing and future sewers? . Are special materials of construction required for: . ', Acid or caustic wastes Solvents Plasticizers v' Temperature Solids or scaling " .............. ' Are in-batteiy facilities (API separators, surface condensers, settling basins, etc.) required for: Oil - many waste treatment systems will not * accept oil . . Flammable materials Solids Concentrated organics -. Odors or lachrymators . . . pH adjustment . Temperature reduction 4. Are facilities provided or necessary to prevent discharge of solvents, etc. to the sewer which might result in explosive vapors in the sewers? 6. Toxicity Does the discharge contain toxic concentrations of any materials (use the 96-hour mean tolerance limit as a guide)? If so, what special precautions are necessary and/or provided to protect personnel who might be required to enter sewers? Will the ultimate plant discharge exceed this 96-hour MTL toxic limit ' and if so, how does this compare to existing or anticipated regulations? Also, is there any poten tial of fish kills as a result of this discharge, ' keeping in mind other potential sources and the possibility that similar chemicals may be present upstream of the plant. . DSW 333451 STLCOPCB4080028 (EC-27) -8- 7. Storm Water Contamination . Has possible contamination of storm water runoff been properly considered? i.e., curbing potential spill areas for drainage to process sewers. If so, has the waste treatment system been designed to . accept wet weather surge? Or, if plant effluent . is tied into a local city or area sewer system for treatment will they accept contaminated storm water? 8. ' Barometric vs. Surface Condensers - ' 'Are surface condensers justified over barometric condensers in the light of environmental control requirements and economics? 9. Decanting ' = ' Decanting operations where a water layer is to be drained to the sewer should be considered as a potential source of high losses. This should be reviewed carefully and automatic monitoring con sidered to minimize losses from these areas. 10. Temperature Effluent temperatures should be considered carefully vs. existing and potential regulations. E. Solid Discharges ; 1. If solid wastes are to be landfilled, is the land fill properly designed and approved? Can toxic materials be properly handled? (This ques. tion must also be considered in the case where our -'wastes are landfilled by others on a contract basis.) .Should selective landfills be employed to provide for possible future reclaiming operations? 2. Open burning should not be considered as a means of disposal unless specifically allowed by local regu lations. III. REGULATIONS AND PERMITS A. As a general guide the lowest governmental subdivision issuing regulations are those which must be met. The DSW 333452 STLCOPCB4080029 (EC-27) -9- local plant can best verify the status of regulations affecting their area. , B. Have all potential discharges been checked against exist , . ing discharges and existing permits? Will new or revised permits be required? . C. Are there tax credits or' tax depreciation allowances which apply to the cost of waste treatment? D. Should federal or statevgrant money be sought? IV. RECEIVING STREAMS All new plant sites should consider carefully the details of the surrounding environment and the potential effect of the plant on this environment. Air quality, potentials for inversions and stream parameters s*uch as type, minimum flow, history and use all must be considered. V. POLLUTION CONTROL FACILITIES All major pollution control facilities should be listed, including their design capacity (specify limiting design parameter) and the expected loading. . DSW 333453 STLCOPCB4080030 ii I 2. NOW WRITE A REPORT - - summarizing your review, and defining major problems which need attention during later development work. Send it to appropriate division management, the Medical Director, the Director of Safety and Property Protection, and the Manager, Environmental Protection, Manufacturing. Ask for comments. 3. IF YOU GET ANY APPROPRIATE COMMENTS, include them in the Suggested Procedure or Tentative Process to be used during the develop ment period. . 4. FOLLOWING THE DECISION to implement the process or process change, the project engineer (along with representatives of plant, division and CED) will initiate a a. pre-project review - made prior to preparing the appropriation request. b. project design review - made after the appropriation has been approved and process design is sufficiently advanced. c. Pre-startup review - made when the plant operating manual is completed and before plant startup. Use the environmental control check list as a guide. The final reports will be sent to all parti appropriate division management, Medief;i4^p' Director of Safety and Property Prote^ Manager, Environmental Protection,,' .46- A 5. INCLUDE ANY APPROPRIATE Tentative Process, Interim Pro Manufacturing Process. DSW 333454 STLCOPCB4080031