Document rbd7mndV05wYJ7Qw1Rv64Epq

bcos J. A. Hellala - Akron R. A. Garcia - Akron February 23# 1971 Nr. Richard Pfleffer Union Carbide P.0. Box 180 Slstorsville, Vent Virginia 26125 Dear Mr. Pfleffer: In substituting Thermlnol FR-0 for the non-avallable Aroclor 1232 In your heat transfer application you are maintaining the vory desirable features of stability at relatively high temperatures and fire resistance but must still review the environmental contamination considerations. To keep stability and fire resistance In Thermlnol fr-o we use some of the more resistant polychlorinated biphenyls (PCS) which have been Identified as environmental oontamlnants. Ke believe, hov.over, that the advantages gained warrant the extra care Involved in Its use. To prevent the escape of PCB.'s to the environment calls for a lovel of control and housekeeping many of us have never been asked to achieve In the past. Every effort must be made to prevent leakage and spillage. Maintenance must be kept at a very high standard. For those areas where leakage and spills will occasionally occur# catch pans must be provided. These pans must drain to a collecting basin or be emptied by respon sible employees on a schoduled basis. Nixing of Aroclore with waste water streams should be avoided since sepsratlon of PCB's from water can be costly. If mixing cannot be avoided# a oatch basin and settling pond should be provided to separate the heavy Aroolor from the water. Unusable contaminated Aroclor should be disposed by incinera tion which assures complete destruction to COg# HoO. and HC1. Any incineration below 800*C will result in vaporization which will contaminate the atmosphere or In partial oxidation which may yiold materials which ere highly toxic. To avoid polluting tho ntmoophere with HC1 the stack geses must be scrubbed and neutralized before disposal Into the plant waste water system. HONS 087456 -2- To help our customers with tholr liquid disposal problems, vc have offered to accept for future incineration scrap liquid Aroclora shipped to Monsanto Company, V. a. Krummrieh riant, Sauget, Illinois, Attention: Suporvlocr, Dept. 246. Tho chare,c for this disposal is per pound of material. Thlo charge Is tentative ponding a complete evaluation of Incineration costa and does rot Include freight or container oosto. The services of a waste disposal company such us Hollins-Purle. Inc., 3200 Conoord Pike, Wilmington, Delaware, 19603, (302) 478-5150 should also bo Investigated. Contamination of the atmosphere must also bo eliminated. All handling systems must be closed wherever possible. Fumes exhausted from a tank, vessel, or working area must be trap ped and collectod using condensers and entrainment separators. Sollda contaminated with PCB's pose a greater challenge. Until a proper Incinerator la designed, we are suggesting that disposal be made In an authorized, properly operated land fill away from any water systems. These solids Include absorbing materials used to contain spills, rags and containers. In summary, control of PCB's ean be achieved with equipment engineered to prevent losses and maintained properly coupled with good manufacturing practices which result In a high stan dard of housekeeping. From the Interest and concern which you have expressed, I am certain that you will do all you can to reduce the escape of PCB's from your operation. When all of us succeed In this ob jective, I am confident that no regulatory agency will be com pelled to take precipitous action regarding the use of PCB's in vital applications. Sincerely, W. B. papageorga Manager Environmental Control os MONS 087457