Contact
Report
Date:
July
24,
2002
August
6,
2002
From:
Brenda
Shine
North
State
Engineering,
Inc.

To:
MON
Project
File
Subject:
Contact
Report
 
Ms.
Lonnie
Gleaton
Environmental
Representative
Rhodia,
Inc.
2151
King
Street
Extension
Charleston,
SC
29405­
8339
(
843)
740­
5228
Summary:
On
July
24
I
contacted
Ms.
Gleaton
regarding
follow
up
information
on
methanol­
containing
wastewater
streams
at
the
facility.
In
the
Section
114
information
request
filled
out
by
the
facility
in
June
of
1997
a
wastewater
stream
contacting
methanol
was
reported
as
being
generated,
managed
and
treated.
I
contacted
the
facility
to
verify
some
information
regarding
this
stream.

Ms.
Gleaton
was
not
the
person
that
filled
out
the
questionnaire
in
1997
but
she
is
familiar
with
plant
operations
and
explained
the
facility's
wastewater
collection
and
treatment
system.

Process
wastewater
containing
methanol
and
other
HAPs
are
collected
in
aqueous
waste
tanks
at
numerous
points
in
the
facility,
corresponding
to
different
processing
areas.
These
aqueous
waste
tanks
are
covered
(
fixed
roofs)
and
vented.
Wastewater
is
hardpiped
from
the
aqueous
wastewater
tanks
to
a
collection
tank,
also
covered
and
vented,
and
then
to
a
pH
adjustment
tank
to
an
air
stripper.
The
air
stripper
gas
stream
containing
stripped
wastewater
contaminants,
including
many
OCPSF
chemicals,
is
sent
to
a
thermal
oxidizer.
The
bottoms
from
the
air
stripper
are
sent
to
a
collection
tank
where
inorganic
chemical
wastewaters
are
added,
and
then
to
the
POTW.
Stormwater
and
pad
washes
are
collected
in
the
plant
sumps
and
also
pumped
to
the
first
collection
tank
to
go
through
the
TOU
(
pretreatment)
system.
Contact
Report
Based
on
this
description,
it
appears
that
the
reported
wastewater
stream
from
the
TOU
feed
is
actually
an
aggregated
stream
that
appears
to
be
the
exit
stream
from
the
collection
tank.
Ms.
Gleaton
indicated
that
there
would
also
be
other
HAP
materials,
such
as
EDC,
in
the
wastewater
at
this
point.
The
air
stripping
operation
was
designed
primarily
to
remove
these
strippable
compounds.
I
indicated
that
we
would
be
interested
in
understanding
the
methanol­
wastewater
stream
characteristics
at
the
point
at
which
they
exit
equipment.
For
example,
would
there
be
a
possibility
that
methanol­
only
wastewater
streams
would
be
generated
at
equipment
and
sent
through
the
same
treatment
system?
Ms.
Gleaton
indicated
that
there
could
be
methanol­
only
wastewaters
and
cited
a
couple
of
examples,
including
methanol
washes,
and
the
bottoms
from
their
methanol
recovery
column,
which
was
added
to
a
process
to
recycle
methanol
back
to
the
process.
These
bottoms
are
routed
to
the
TOU
system
Ms.
Gleaton
also
stated
that
excess
methanol
from
another
process
is
burned
as
a
fuel
for
the
thermal
incinerator
in
the
TOU
system.
In
yet
another
process
(
transesterification),
methanol
is
removed
from
a
process
stream
and
shipped
offsite
for
fuel
blending.

I
noted
that
there
are
numerous
wastewater
streams
at
the
facility
that
we
did
not
have
specific
information
on
and
that
we
might
need
more
information
on
to
conduct
subsequent
MACT
floor
analyses
and
told
Ms.
Gleaton
that
I
would
probably
contact
her
again
for
additional
information.

On
August
6,
Ms.
Gleaton
returned
a
call
that
I
had
made
the
week
before
requesting
information
on
whether
the
facility
had
any
streams
that
are
methanolonly
and
less
than
30,000
ppmw
by
weight.
Ms.
Gleaton
said
that
the
only
stream
she
could
think
of
at
this
time
is
the
bottoms
from
the
methanol
recovery
column,
which
contains
approximately
.5%
methanol
(
5000
ppmw).
This
stream
is
hardpiped
to
the
TOU
system,
as
described
above.
