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PRELIMINARY DRAFT BULLETIN NO. 0- ENVIRONMENTAL EVALUATION -- PRODUCTS AND PROCESSES I. PURPOSE This bulletin assigns responsibilities and describes the - .'V procedure for conducting environmental impact assessments of new products and processes before commercialization is approved and of existing products and processes as significant changes in application or manufacture are undertaken. II. POLICY The Organic Division recognizes the need for control and re duction of environmental degradation and thoroughly assesses the impact of proposed products and processes on the environ ment before commercialization and of proposed changes in existing product usage or manufacture. III. SCOPE This bulletin applies to proposed new products, new formulations and new applications of existing products. dsw 333635 This bulletin also applies to new processes and to process and/or equipment modifications when the proposed change is estimated to increase either the total volume or the concentration of any STLCOPCB4080212 2 component in the water effluent or air emmission streams: (1) by 25# or (2) any lower percentage increase which might exceed i prescribed limits for any components of waste streams, or (3) any change from zero. Changes in water, nitrogen, oxygen or carbon dioxide concentrations are exempt from these considerations, IV. RESPONSIBILITIES A. PRODUCT EVALUATIONS 1. Director, Business Group Shall be responsible for assuring that no new product, new formulation or new applica tion of an existing product is commercialized by his group un less a positive environmental impact assessment has been determined. 2. Manager, Shall be responsible for pursuing, Research & Development through his Research Group Leaders, DSIV 333636 STLCOPCB4080213 3. Manager, Commercial Development 4, Sales Director 3 the assessment of the environ mental Impact of new products, new formulations or new appli- , cations of existing products which are conceived within the Research function. Shall be responsible for pursuing, through his Project Managers, the assessment of the environmental impact of new products, new formulations or new applications of existing products which are conceived within the Commercial Development function. Shall be responsible for pursuing through his product/ Market Managers, the assessment of the environmental impact of DSW 333637 STLCOPCB4080214 4 * 5. Manager, Environmental Protection - new products, new formulations or new applications of existing products which are conceived within the Marketing function. Shall he responsible for coordinating the product enviro- m mental evaluation activities in the division. B. PROCESS EVALUATIONS 1. Director, Manufacturing 2. Manager, Research & Development DSW 333638 Shall be responsible for assuring that no new process or change in process is accepted for operating manufacturing facilities until a positive environmental impact assessment is determined. Shall be responsible for initiating, through his Research Group Leaders, the preliminary STLCOPCB4080215 5 environmental evaluation of the process or process change conceived within the Research , function and for participating in subsequent more definitive evaluations. 3. Manufacturing Manager m Shall be responsible for , initiating, through the General Superintendents, Technical Services and the Guest Superin tendents, the preliminary environmental evaluation of the process or process change con ceived within the Manufacturing function. He shall also be respon sible for initiating the more definitive evaluationsmade before implementation of those projects handled by Manufacturing. DSW 333639 STLCOPCB4080216 6 4. Engineering Manager 5. Manager, Environmental Protection Manufacturing Shall be responsible for initiating, through his Project Managers, the more definitive evaluationsmade before imple mentation of those projects handled by CED. Shall be responsible for coordinating the process environmental evaluation activities in the division. ; V. PROCEDURE i A. PRODUCTS DSW 333640 J 1. Ihe Research Group Leader, Commercial Development Project Manager, or Product/Market Manager, who is primarily responsible for the development of a new product, new formulation or new application of an existing product, must initiate a preliminary environ t mental evaluation as soon as the proposed product is identified and the end uses visualized by completing STLCOPCB4080217 7 data sheet EC-201 (Appendix A) after conducting a literature search and consulting with others. He forwards copies of data sheet EC-201 with a statement of his principal sources of information, environmental r _ problems visualized, probable end uses, and a request i* for a preliminary evaluation to the Medical Director and to the Manager, Environmental Protection. - 2. The Medical Director will respond regarding the environmental problems foreseen and information required i before samples are forwarded to potential users. 3. Upon receiving Medical Department concurrence, the Research Group Leader, Development Project Manager or Product/Market Manager involved may release shipment of samples. DSty 333641 4. Based on the results of the preliminary environmental assessment, the Research Group Leader, Development Project Manager or Product/Market Manager concerned will arrange for appropriate studies; e.g., toxicity. STLCOPCB4080218 8 biodegradation, to develop additional environmental information. 5. Before commercialization, the Research Group Leader, , Development Project Manager or Product/Market Manager concerned must initiate a final environmental evaluation t* by completing data sheet EC-202. He forwards copies of data sheet EC-202 (Appendix B)with a listing of the principal sources of information, the intended product uses and a request for an environmental evaluation with intent to commercialize to the Medical Director and to the Manager, Environmental Protection. 6. The Medical Director will respond regarding the environmental acceptability, restrictions or . additional information required. dsw 333642 7. When a positive environmental assessment is achieved the Business Director will approve commercialization. J 8. The Manager, Environmental Protection, will maintain suitable records, issue appropriate reports and co ordinate the environmental evaluation activities to STLCOPCB4080219 9 assure that assessments are processed thoroughly and quickly and that new products, new formulations and new applications of existing products meet the standards of environmental acceptability. B. PROCESSES (MEW OR CHANGED) AND EQUIPMENT MODIFICATIONS Intent * This procedure applies to all new processes and process and/or equipment modifications which are estimated to in crease either the total volume or the concentration of any component in the water effluent or air emission streams by: (a) 25# or more, or (b) any lower percentage increase which may cause exceeding emission or effluent regulations (or Monsanto standards, if more stringent) by any component of the waste streams or (c) any change from aero. Changes in water, nitrogen, oxygen or carbon dioxide con centrations are not significant and are therefore exempt. DSW 333643 STLCOPCB4080220 10 Steps applying to new processes and/or process changes are detailed in 1 through 7 below. Steps applying to equipment modifications (or de-bottlenecking) where no process changes are involved are detailed in 4 through 7 below. 1. The Research Group Leader, General Superintendent, Technical Services, or Guest Superintendent, who is primarily responsible for the development of a new process or process change, will arrange for a pre liminary environment evaluation review (see CED Procedure #602, Section V Procedure - Research LP & EC Review, pages 2, 3 of 7). This will be made along with a loss prevention review and will be coordinated with the Director of Safety and Property Protection. An Environmental Control Review Check List (EC-27, Appendix C) will be used to insure that all pertinent items are considered. \M 333$^ 2. A report summarizing the review and defining problems requiring particular attention during subsequent STLCOPCB4080221 11 process development work is prepared and copies are sent to appropriate division management and to the ( Medical Director, Director of Safety and Property Protection and Manager, Environmental Protection, Manufacturing. 3. Appropriate comments resulting from this review are included in the Suggested Procedure or Tentative Process which will be used during the development period. 4. Following the decision to implement the process or process change and/or in cases involving-equipment modifications, three definitive environmental evalua tions are made along with the loss prevention reviews. (See CED Procedure #602, Section V Procedure, pages 3, 4 and 5 of 7.) a. Pre-project review - made prior to preparing the appropriation request. b. Project design review - made after the appropriation DSW 333645 STLCOPCB4080222 12 has been approved and the process design is suf ficiently advanced. c. Pre-startup review - made when the plant operating manual is completed and before plant startup. 5. These evaluation reviews are initiated by the appro priate project manager or engineer. Representatives of concerned groups including plant, division and CED personnel participate. The Environmental Control Check List, EC-27 (Appendix C) is used as a guide. Plants will develop and implement "Environmental Review" procedures similar to present "Safety Project Reviews" for their Operations on Procedure Manuals. Reports summarizing the evaluations are sent to all participants, appropriate division management. Medical Director, Director of Safety and Property Protection and the Manager, Environmental Protection, Manufacturing. 333646 STLCOPCB4080223 13 6. Appropriate comments resulting from these definitive reviews are Included in the Tentative Process, Interim Process or Standard Manufacturing Process. 7. The Manager, Environmental Protection, Manufacturing, will maintain suitable records, issue appropriate reports and coordinate the process environmental assessment reviews to assure timeliness and thorough ness. VI. REFERENCE PROCEDURES AND BULLETINS Corporate Procedure - Evaluation of Proposed New Products and Processes. CED Procedure 602 - Loss Prevention and Environ mental Control Reviews. Organic Division Bulletin 0-18 Organic Division Bulletin 0-36 - Procedure for Toxicological Testing. - Process Documentation. lp 9 ? M sq Organic Research Reference 0R-16 - Suggested Procedures. Organic Research Reference E-10 - Tentative Process. Organic Manufacturing Procedure Procedure OM-13 - Standard Manufacturing Process. STLCOPCB4080224 APPENDIX A BULLETIN Data Sheet EC-201 NEW PRODUCTS Preliminary Environmental' Compatability Assessment following Environmental Compatabillty Assessment Scheme i'.eludes some procedures similar to those now used by the ;`Jical Department to assess the potential hazard of new - Aerials to humans. This systematic scheme is being adopted te ensure insofar as possible that our products are not haz ardous to the public or the environment. . The scheme is designed to elicit the Information needed to protect people who come in contact with large or small amounts of a material, occasionally or continually, and all aspects cf the environment which may contact or accumulate it or its degradation products. It takes the form of a series of ques tions to be asked about the material which can be answered simply "yes" or "no". However, as will be obvious from consideration of the questions, considerable knowledge will be required to provide satisfactory answers. As provided for in corporate procedures (D-II-8 in Manage ment Guide), the division in the company responsible for * a new product must obtain a preliminary environmental eval uation, as soon as the proposed product is identified and the end uses visualized. ' To initiate this evaluation the individual responsible for the product consults the literature and obtains the best . answers he can by consultation with others and completes data Sheet EC-201. He sends this to the Medical Department along with a statement of his principal sources of information and a request for a preliminary environmental evaluation. The Medical Director will respond as to the environmental problems foreseen and information required, if any, before sending out trial samples. STLCOPCB4080225 Page Two Environmental Compatablllty Assessment - Data Sheet EC-201 (cont.) Description of the Product - 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: 1) oral LD -rats 2) skin absorption MLD-rabbits 3) inhalation effect 4) skin irritation potential 5) eye irritation potential Known Estimated or ;__mg/kg or mg/kg or or or B Are harmful effects from repeated or chronic exposures known or can they be predicted by 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: ., ` The Medical Department should be consulted for answers to Questions A and B. Questions C - E require speculation by people know ledgeable about the process and end use. DSW 333649 STLCOPCB4080226 APPENDIX B BULLETIN . * NEW PRODUCTS Data Sheet EC-202 Final Environmental Compatibility Assessment As provided for in corporate procedures (D-II-8 in Manage ment Guide and Medical Department Bulletin EC-201) the division in the company responsible for a new product must obtain a final environmental evaluation before commercial ization. . To obtain this evaluation, the individual responsible for the product reviews the Preliminary Environmental Compati bility Assessment (EC-201) form, consults the literature, obtains the best answers he can by consultation with others, and completes Data Sheet EC-202. He sends this to the Medical Director along with a statement of his principal sources of information, the intended product uses and a request for a final environmental evaluation with intent to commercialize. The Medical Director will respond as to the environments, 1 acceptability, restrictions,or additional.information needed, if any, or if unacceptable, the reasons why. oS\N 33365 STLCOPCB4080227 -2- (Cont. EC-202) Environmental Compatibility Assessment Scheme Instructions: Answer each question in turn, "yes" or "no". Each answer is nrovided with a directive concerning the question 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 auestion, No. 12, should be considered if it is decided to make and sell materials which are very useful but potentially dangerous to man or his environment. When aoplying this form, consideration must be given to the product Monsanto supplies, product impurities, as well as thefinal or end prpduct that enters 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 1. Is the material so physiologically inert that there need be no con cern about health hazards to humans? Yes No 2. a) Is the material toxic to per sons as a result of a sinqle contact with high concentra tions? Go to: 4 2&3 b) Is the. material toxic to per sons at lesser concentrations following repeated or prolonged ` exposure? c) Is the material likelv 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 ENVIRONMENTAL DEGRADABILITY. 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 6 dsnn 333651 STLCOPCB4080228 3- (Cont. EC-202) If Go to: 5. Is it likely the degradation products from the `'closed-!oop" disposal system could be harm ful to humans? 6. Is it likely that the product will degrade in the environment or in anv of the currently used dispqsal systems? Yes -Recycle Degra dation Products to 2. Continue at 6. Mo 7 Yes -Recycle Degra dation Products to 1. Continue at 7. No . 7 ITEMS 7 THROUGH 10 ARE TO ESTABLISH HAZARDS OF PRODUCTS AMD DEGRADATION PRODUCTS TO PLANTS, ANIMALS OR ECOSYSTEMS. - 7. Is it probable that the product of degradation products are harmful to plants and animals at concentrations to which they are likely to be exposed? Yes No 8 9 8, Recognizing the hazards to plants and animals, can procedures be devised at reasonable costs to render the material innocuous? . Yes 9 No -Do Not Sell 9 Is it likelv that harmful secondary reaction products could be formed from the harmless parent material as Yes -Recvcle the - a result of a chemical, bio By-product at 1 & chemical, or biological activity 7. Continue at 10. in the environment? Mo 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 Yes -Recycle to 8. material was not directlv toxic Continue at 11. to the biota? . No 11 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 333652 STLCOPCB4080229 MONSANTO COMPANY CENTRAL ENGINEERING DEPARTMENT SAFETY A PROPERTY PROTECTION ENVIRONMENTAL CONTROL CHECK LIST APPENDIX C Rev. 7/1/70 OS'N^653 REFERENCE: EXHIBIT C, CED Procedure 602, Loss Prevention & Environ mental Control Reviews Form EC-27 - Copies available from Office Supplies Department General Offices, St. Louis ~ STLCOPCB4080230 (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 CONTROL AUDIT _ An'audit of all plant effluents must be made to provide a basis for evaluating pollutioh 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 oSnN M3664 STLCOPCB4080231 (EC-27) -2- Total solids Total dissolved solids Total' suspended solids Total settleable solids BOD (biochemical oxygen demand) COD (chemical oxygen demand, i.e., ultimate BOD) Quantities of nutrients ? Nitrogen (nitrates, nitrites, ammonia) Phosphorus (phosphates) Temperature Color Toxicity (if available^ 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 such 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 333655 STLCOPCB4080232 (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 Miss I.e., HCl, NO , SO , H~S, HP. X X fc 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 . DSW 333656 STLCOPCB4080233 (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 Hydrocarbdns;" NOTE: e. Radioactive materials m- . . 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 The U.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 333657 STLCOPCB4080234 (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. 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, SO^, N0X' formed? 2. 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? OSNN STLCOPCB4080235 C !>) -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., pH, phenols, solids, chromates or heavy metals, toxicity, inorganic salts. 2. Bv-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. jtewer Systems Are segregated sewers necessary for: Storm water Cooling water Sanitary wastes Concentrated or general process wastes DSW 333659 STLCOPCB4080236 (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 _ Temperature Solids or scaling ' \ Are in-batte3yfacilit4.es (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 lachirymators 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 necessasry 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 333660 STLCOPCB4080237 (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 4P' , 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 333661 STLCOPCB4080238 (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 state^grant money be sought? IV. RECEIVING STREAMS All new plant sites should CQnsider 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 such 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. . DSVJ 333662 STLCOPCB4080239