Document pBr1DVYLmXMGwV3xoegRgL6Na
Monsanto
COMPANY r H v CONFIDENTIAL
i mom i NftMi * i ot.ai "'"'E. E. Stewart, W. G. Krummrlch Plant -----------------
0u September 1, 1972
G. L. Bratsch
( 1 STATUS - PCB POLLUTION CONTROL PROGRAM
C. F. Buckley w C, Engman p.' E. Heisler g! A. Hlppe
TO :
Mr. J. R. Savage General Offices
B2SL
P. B. Hodges - G.O. (E1SF) a. E. Leisy/R. M. McCutchan w R. Richard - G.O. (T3A)
*
This Is the September 1, 1972 status of PCB pollution control program.
I. PCB LEVEL IN SEWERS
August "knowing PCB losses" from the operating depart ment and the Incinerator area at 0.78 ff/day average are within the expected guideline from the EPA. Losses measured at the Waste Treatment Plant Effluent reflect slight upward trend toward end of month to average of 6 #/day. Record low values were established in mid month at Waste Treatment Plant Influent; however, upward trend after mid month increased average at month's end to l1* #/day.
Aroclor sewer loss control data are attached.
A. Aroclor Department - Continuous samples taken from main department effluent stream average 0.^8 #/day. Continuing to coordinate production with operations In the c/S department so as not to sewer off-gas at the Aroclor department. Resumed air blowing at mid month because of possible related corrosion problems In the Intermediate crude storage tanks. Higher PCB losses to the sewer will occur when air blowing. Long range corrections must be made.
B. Incinerator Area - Measured losses averaged 0.3 #/day. The unit was on stream for about a day but had to be shut down because hot spots developed at the plenumoxldlzer. Repairs are In progress. Continuing to empty returned drums from customers for subsequent Incineration.
MONS 028690
Mr. J. R. Savage STATUS - PCB POLLUTION CONTROL PROGRAM
rage 2
9/1/7? WGK
X, PCB LEVEL IN SEWERS (Cont'd)
C, Total Plant - The average dally loss measured at the influent to the Waste Treatment Plant was l1! #/day after dropping to a record low of 5 #/day (average of past ?1 days) at mid-month. This loss reflects background losses from the entire plant and village sewer system in addition to the knowing losses from the manufacturing department and the incinerator area. Do not know of any plant operations, upsets or repairs that would have contributed to increase second half of August. Torrential rains may have resulted in ground water flows to sewers and sewer system purging actions.
D. Treatment Plant Effluent - The average dally loss Increased from record low established last month to 6 #/day. Higher effluent values relate to higher influent values. An effluent loss of 6 #/day is equivalent to a PCB concentration in the Mississippi River of 0.005*1 ppb at current river flow rates and assuming this effluent stream is the sole contributor of PCB to the river. EPA guidelines are 0.01 ppb in the river.
II PROJECT STATUS
Project 3972 - "Reroute North Basin Sewer" - To reroute effluent from department North Settling Basin such that all sewer flow from the department will flow from one point.- Awaiting field completion.
Project 3956 - "Alterations to HC1 Distribution System" To eliminate possibility of sewering Dept. 246 HC1 gas. Awaiting field completion.
III. PROCRAM STATUS Re Engman/BratBch 4/24/72
1. HC1 Off-Gas
A, Aroclor - Continuing to coordinate production with operations in the C/S department so as not to sewer off-gas.
B. Equipment design essentially complete on project to provide off-gas scrubbing facilities at the Aroclor Department. Estimate and justification to be prepared in September.
M0NS 028691
Mr. J, R. Savage STATUS - PCB POLLU TION CONTROL PROGRAM
WGK
III. PROGRAM STATUS (Continued)
2. Blow Tank Off-Gas
Resumed the aeration process step in the continuous process to produce Aroclor 1142 on 8/14 because of leaks that developed in the intermediate storage tanks top heads. Had discontinued air blowing about nine weeks ago to reduce PCB loss to the sewer. Additional work to be done.
5. Rip Track Washer
Washed 4 T/C and 2 T/T during month. Estimated losses about 1-2 #/wash. Will analyze wash water content during September. Future work to be done to get PCB content down to desired 0.01 #/wash.
WGK Strategy
"In hand" document that could be given federal authorities if asked what historical events took place at WGK to reduce PCB entrances to environment was reviewed by Business Group, Law Department and Environmental personnel.
PCB "knowing loss" data from the continuous monitoring of the manufacturing and incinerator effluent streams as related to the possible PCB concentration in the Mississippi River are being collected for review with federal authorities if required. Waste Treatment Plant Effluent data also available which contain background losses in addition to "knowing losses".
Edward E. Stewart Technical Services Department
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HONS 028692