Document 06KY9VJ8LQGmeMoDwK62r2omn

TOC P&M Environmental Affairs (COMPANY) f INTEROFFICE COMMUNICATION TO: Tenneco Polymers FOR: Ron Neugold FROM: r. D. Pruessner RE: ENVIRONMENTAL REVIEW - BURLINGTON PLANT DATE: April 29, 1983 Your approval is requested for scheduling the Environmental Review of the Burlington Plant on June 28-30, 1983. The proposed agenda and Environmental Review forms are attached. It is requested the forms be filled in prior to the arrival of the review team. pm Enclosure cc: Pat Anderson Guy Disch Hal Hees Jim Kachtick Fred Kanzler Jim Langford Ralph Maynard :A1 Smiths Roger Towe R.D. Pruessner RECEIVED APR 29 1983 TOCIEGAL-P&M XEKO 238 AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - BURLINGTON PLANT June 28-30, 19S3 Tuesday, June 28 11:30 a.m. 4:11 p.m. About 6:00 p.m. 6:30 p.m. Depart Houston Intercontinental on Eastern 554. Arrive Philadelphia airport. Obtain large Avis rent car and drive to Burlington, New Jersey. Check in Hilton on Highway 295 in Mount Laurel, New Jersey. Supper for the Review Team and Polymer representatives at Charlie's Other Brother in Mt. Holly. Fred Kanzler will make reservations for five people from Houston and the Burlington plant staff. Wednesday, June 29 8:00 a.m. Meet with Ron Neugold to conform final plans for Environmental Review. 8:15 a.m. Meet with Fred Kanzler and staff to go over the information contained in completed Environmental Review forms. 11:30 a.m. LUNCH 1:00 p.m. Meet with Fred Kanzler for plant tour. 4:00 p.m. Adjourn 4/28/83 -1- TENO 239 (I AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - BURLINGTON PLANT 3une 28-30, 1983 Thursday, June 30 8:00 a.m. 9:00 a.m. 11:30 a.m. 1:00 p.m. 2:00 p.m. 3:30 p.m. 5:05 p.m. 7:13 p.m. Visit with maintenance department representative to sight maintenance and calibration records for environmental equipment. Review analytical procedures calibration, and records associated with vinyl chloride emissions. LUNCH Draft proposed conclusions of Environmental Review. Meet with Ron Neugold and staff to review proposed findings and complete the final report. Provide copies of completed report to Ron Neugold, Fred Kanzler, Jim Langford, Jim Kachtick, Guy Disch, and Bob Pruessner. Depart for Philadelphia airport. Catch Eastern 551 for Houston. Arrive Houston. 4/28/83 -2- TENO 240 T ENN ECO OIL P&M FACILITIES ENVIRONMENTAL REVIEW TENNECO POLYMERS - Burlington Plant POLYVINYL CHLORIDE FACILITIES 4/25/83 TEN0 241 I( TENNECO OIL P&M ENVIRONMENTAL REVIEW Name and address of facility; Tenneco Polymers Burlington Plant P. O. Box 116 Burlington, New Jersey 08016 June 28-30, 1983 Affiliated with: Tenneco Oil P&M Operations Manager: __Ron Neugold Plant Manager Environmental Representative: Fred Kanzler_______________ (Name) Environmental Coordinator (Title) Type of operation and/or principle products: Polyvinyl Chloride (609) 386-9200 (Phone) (609) 386-9200 (Phone) Review Team: Name Bob Pruessner Roger Towe Hal Hees Pat Anderson Jim Kachtick Title Mgr. Environmental Affairs-TOC Sr-Environmental Eng.-TOC______ Attorney - TOC Mgr.Environmental Audits-TEN Mgr.Environmental Sciences-TOC Phone (713) 757-3306 (713)737-7685 (713)737-2607 (713) 757-3604 (713)479-3411 4/28/83 TEN0 242 (/ TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING <D Please show the reporting relationship between individuals directly responsible for environmental compliance and the senior manager associated with this facility. (Add blocks as necessary.) Name 3im Langford Title Director of Operations Name_ Title Name Title Name Title Name_ Title 12/8/82 THNO 243 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (2) Please list names and title of persons dedicating a significant portion of their time to environmental compliance. This should include those persons responsible for operating environmental control equipment, conducting laboratory environmental analysis, etc. NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:_____________________ Name TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:____________________ NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:____________________ NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility: --------------------------------------------- ------------------------------------------------------TEN0244 12/8/82 ( NPDES Permit No.: TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (1) Date Issued: Date Expires: Other Water Discharge Permits: Date Issued: Date Expires: Discharge permit requirements: Outfall Number(Add additional sheets as necessary.) Permitted Avg Max Typical Actual Ayr Max No. of Self-Reporting Violations-Last 12 Mos. Flow BOD Oil & Grease Type of Waste Water Treatment System: _______ Method by which sanitary waste water is treated: __ Who is treating sanitary waste? _____________________________________________ _ Sanitary Waste Water Permit No._________________ Issuing Agency:Expiration Date: 2/17/83 TENO 245 r TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (2) Date and significant findings of last regulatory inspection: Please attach copy of regulatory inspection report. Do any discharge permits contain a compliance schedule? Is the facility meeting the compliance schedule? Primary flow measuring device properly installed? Calibration frequency adequate? (Date last calibration) Primary flow measuring device properly operated & maintained? Secondary instruments (totalizers, recorders, etc.) properly operated and maintained? Permittee sampling meets requirements and intent of permit? Details: ______________________________________ _ Locations adequate for representative samples? Parameters and sampling frequency agree with permit? Permittee is using method of sample collection required by Permit? If NO,_____ Grab _____ Manual Composite _____ Auto composite frequency: YES ____ ____ ____ ____ ____ NO N/A ____ ____ ____ ____ __ Sample collection procedures are adequate? Samples refrigerated during compositing? Flow proportioned samples obtained where required by permit? Sample holding times prior to analyses in conformance with 40 CFR 136.3? Monitoring and analyses being performed more frequently than required by permit? If YES, results are reported in permittee's self-monitoring report? Permittee lab procedures meet the requirements and intent of permit? Details: ____ ____ ____ ____ ____ ____ ____ EPA approved analytical testing procedures used?(40CFR 136.3) If alternate analytical procedures are used, proper approval has been obtained? Parameters other than those required by the permit are analyzed? Satisfactory calibration and maintenance of instruments and equipment? Quality control procedures used? Duplicate samples are analyzed?_____ % of time. Spiked samples are used?_____ % of time. ____ ____ ____ ____ ____ ____ ____ 2/17/83 TENO 246 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (3) Commercial laboratory used? Commercial laboratory state certified? Weeds cut and vegetation growth in ponds removed? Banks and dikes maintained? (Erosion, etc.) Any reports of groundwater contamination from pond? If Y ES, give details: YES NO N/A ____ _____ _____ _____ _____ Seepage reported? Adequate freeboard (2 feet) to prevent overflow? Effluent release is: _____ Continuous _____ Intermittent _____ Seasonal What is the receiving stream? Is there a formal Spill Control Plan (SPCC)? Has the SPCC been approved by management? 2/17/83 TENO 247 ( LAB NAME: TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (3-A) (CONTRACT LAB) YES NO N/A Is lab state certified? Date of last certification test: Sample collection procedures are adequate? Samples refrigerated during delivery to laboratory? Chain of custody records maintained? Sample holding times prior to analyses in conformance with 40CFR136.3? Lab procedures meet the requirements and intent of permit? Details: EPA-approved analytical testing procedures used? (40CFR 136.3) If alternate analytical procedures are used, proper approval has been obtained? Satisfactory calibration and maintenance of instruments and equipment? Quality control procedures used? Duplicate samples are analyzed_____ % of the time. Spiked samples are used_____ % of the time. 4/25/83 TENO 248 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (4) Is the 5PCC certified by a registered engineer? Has the SPCC been reviewed and updated within the last 3 years? Have there been any reported spills the prior 12 months? How many? If more than two (2) reported spills within the last 12 months, has the SPCC been revised and certified by a registered engineer? Is a training program existing to instruct personnel in operation and maintenance of spill control equipment? Are briefings scheduled to insure adequate understanding of the SPCC plan by company personnel? Is this facility a "major facility" as defined in the New Jersey Water Pollution Control Regulations, i.e., N.J.A.C. 7:1 E-1.3(k)? If so, has a Discharge Prevention, Containment or Countermea sure (DPCC) Plan and Discharge Cleanup and Removal (DCR) Plan been prepared in accordance with N.J.A.C. 7:lE-4.5 and 7:1E-4.21? Have the DPCC and DCR Plans been approved by the N3DEP, Division of Water Resources? Have the DPCC and DCR Plans been approved by management? Have the DPCC and DCR Plans been reviewed and evaluated in the last three years? Has the NJDEP, Division of Water Resources ever inspected this facility for compliance with the DPCC and DCR Plans? If so, when? YES NO N/A 2/17/83 TENO 249 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (5) How is storm water treated? What is the design basis for storm water treatment? Do existing discharge permits have storm water requirements? What are the requirements? 2/17/83 TENO 250 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) (1) YES NO N/A What type(s) of PVC resin is produced: Dispersion resin Latex resin Bulk resin Does this plant have a fixed vinyl chloride monitoring system in place to continuously monitor VCM emissions? Do exhaust gasses meet the less than lOppm VCM limit? What sort of control devices are used to reduce VCM exhaust gases to lOppm or less? How many emergency manual vent valve discharges to the atmosphere were reported in the last 12 months? Were they reported within the required time (10 days)? _ FUGITIVE EMISSIONS FROM EQUIPMENT IN VCM SERVICE Are loading and unloading lines in VCM service degassed thru a control system before opening? _ Are slip gauges used in the VCM loading/unloading operation? _ Are slip gauge emissions reduced via a control system? __ If controlled--what is the control mechanism? Are all pumps either sealless, have double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? Are all compressors equipped with double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? Are all agitators equipped with double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? c. Other ________________ 10/27/82 TEN0 251 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) (2) Are relief valves connected to a process line, recovery system, or equivalent? If not, are they equipped with rupture discs? YES NO N/A _____ ____ ____ _________________ When sampling, are sample containers purged into a closed process system? Are unused portions of samples (10% or more VCM by weight) returned to the process? Is the VCM content of equipment reduced as required before opening to atmosphere? Does this plant have a formal leak detection and elimination program? a. Has the program been approved by the EPA Administrator? b. What is the plant definition of a "leak"? Is the VCM content of "in process wastewater" reduced as required? Does this plant have Standard Operating Procedures incorporating the VCM fugitive emission requirements? Are emissions data reported in Semiannual Report as required? How many reported exceedances were there the last 12 months for: a. Residual VCM content of stripped PVC slurry?___________ What percent is this of total reported values?_____________ b. Reactor opening emissions? What percent is this of total reported values? c. Incinerator VCM emissions greater than lOppm?__________ What percent of incinerator operating hours?_____________ Is record keeping performed as required? a. Are records kept two years? b. Are they destroyed after two years? When was last NESHAPS inspection? (Please provide copy of report.) 4/25/83 TENO 252 (( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (1) List air construction permits or permit exemptions obtained in the last 12 months: Description of Permitting Permit Unit Agency Control Allowed Device Emissions Date Issued 1. 2. 3. 4. 5. 6. 7. List air operating permits presently in force: Description of Date Expiration Allowed Monitoring Permit Unit Issued Date Emission Requirements 1. 2. 3. 4. 5. 6. 7. 8. 9. Reporting Requirements 12/8/82 TENO 253 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (2) When was the last air regulatory inspection? _________________* Please provide a copy of last inspection report (Date). Describe any noted deficiencies and the corrective action taken: DEFICIENCY CORRECTIVE ACTION 1. 2. 3. 4. 5. 6. Is this facility now in compliance with Subchapter 16 of the New Jersey Regulations (this subchapter addresses VOS)? Comments: If this facility now in compliance with Subchapter 17 of the New Jersey Regulations (this subchapter addresses TVOS)? _ Comments: 4/25/83 TENO 254 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (3) When was the last air emissions inventory? ___________________ DATE List reported emissions rates: Tons/Year 1. Hydrocarbons 2. Sulfur Dioxide 3. Nitrogen Oxides 4. Carbon Monoxide 5. Particulate 6. Vinyl Chloride 7. 8. What procedure is followed to report emission excursions to regulatory agencies? Please attach a copy of existing written procedure. Is this facility monitoring ambient air quality? Is a quality assurance program used? (Please provide quality assurance records.) 12/8/82 YES NO N7A YES NO N/A TENO 255 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (4) What parameters are monitored? Has air monitoring data shown exceedences of air standards? ____ ___ YES NO ~N7A Is this facility in compliance with or on a schedule of compliance with all applicable emission limitations and standards under the Clean Air Act? Discussion if required: "yes "no ~n7a Does this facility have procedures to insure leaded gasoline is not used in company vehicles designed for unleaded gasoline? ____ ___ YES NO ~N7A If this facility dispenses more than 200,000 gallons of gasoline per year, does it have stage I vapor control system installed? ____ ___ YES NO "n7a tENO256 t /O /O') (( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (1) Is this facility registered under the Resource Conservation and Recovery Act (RCRA)? Generator Storer Treater Disposer Transporter YES NO N/A _____ ___________ _____ ___________ _____ ____ ____ _____ ____ ____ _________________ _____ ____ ____ What is the registration number? List any hazardous waste and the amount being generated and show if it is disposed of on or off-site. ON OFF List any solid waste and the amount being generated and show if it is disposed of on or off-site. 12/8/82 TENO 257 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (2) If this facility is a storer, treater or disposer, is it in compliance with the interim standards? YES NO N/A Are the following prepared: Written Waste Analysis Plan? Is the site secure to prevent unknowing entry or are "DangerUnauthorized Personnel Keep Out" signs installed? Written inspection schedule on: (a) Monitoring equipment? (b) Security devices? (c) Operating and structural devices? Personnel training? "No Smoking" signs for ignitable or reactive waste? Preparedness and prevention? Contingency Plan? Arrangements with local authorities? Are manifests used with each off-site load of hazardous waste? Are all hazardous waste manifests accounted for? Is manifest record system properly maintained? Is an annual hazardous waste summary provided to the State? (Provide a copy.) Is hazardous waste held over 90 days? Have any drummed waste been held over 90 days? What is the present inventory of drummed waste?____________ _ Number of drums Is each drum dated when hazardous wastes are placed in the drum? What is the present inventory of empty drums? Number of drums 4/25/83 TENO 25$ TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (3) How are empty drums disposed of? Are any empty drums given (sold) to employees or neighbors? Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material? YES NO N/A _____ _____ What types of hazardous waste treatment are accomplished on site? Solar Evaporation Processing for Detoxification Incineration Neutralization Landfarming Fixation prior to burial Recycling Biological Other Has TOC provided closure costs of on-site treatment and storage facilities? What is estimated cost?Who estimated cost? Are ponds used in hazardous waste treatment? Are ponds in natural clay? Are ponds lined with clay? How thick? What freeboard is maintained in ponds?__________________ What is expected 24-hour rainfall in a five-year period?__ Are monitoring wells used? How many wells are upgradient? ______________ _ How many wells are downgradient?______________________ How deep are the wells?______________________________ _ How often are they monitored?_________________________ TENO 259 12/8/82 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (4) What are the wells monitored for? 1. _____________________________________________________ 2. 3. _ 4. __ 5. Are monitoring-well results reported to state? Have reported (last 12 months) monitoring results indicated underground contamination potentially related to this facility's activity? What is the depth of the shallowest aquifer currently used? Does this facility operate water wells? What depth?___________ How many?________ List private drinking water wells near this facility. Owner Depth 1. 2. _ 3. 4. List industrial/commercial water wells near this facility. Owner Depth Water Use 1. 2. 3. 4. List municipal or public water wells near this facility. Owner Depth Water Use 1. 2. 3. 4. 12/8/82 YES NO N/A ____ ____ ____ TENO 260 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (5) Do you receive hazardous waste from off-site? What types of hazardous waste disposal are accomplished on site? Sanitary Landfill Chemical Landfill Solar Evaporation Landfarming Deep Well NPDES Discharge after treatment Other What is the estimated useful life of on-site disposal? YES NO N/A Has TOC provided for expected future closure costs of on-site disposal facilities? What is the estimated cost? Who estimated the cost? How has TOC provided for the expected cost? Has this facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note? Have these discrepancies been corrected? 12/8/82 TEN0 261 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (6) OFF-SITE DISPOSAL If off-site hazardous waste disposal is used: What is the name of the facility? Name Permit Number 1. 2. 3. Do you have a copy of their current RCRA permit? Do you have a copy of their current state permit(s)? Have you visited this facility in the last 12 months? Did the evaluation confirm this site is satisfactory for disposal of your facility's hazardous waste? (If a written evaluation report was made, please attach.) Are DOT approved containers and labeling used for off-site delivery of hazardous waste? Estimated annual cost of off-site disposal? Has this off-site facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note?___________________________ YES NO N/A _____ ____ ____ _____ ____ ____ _____ ____ ____ _____ ____ ____ _____ ____ ___ Have these discrepancies been corrected? (Provide a copy of last regulatory inspection.) 12/8/82 TENO 262 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS POLYCHLORINATED BIPHENYLS (PCB) (1) As of July 2, 1978, did this facility contain in service, stored for future use, or stored for disposal: YES NO N/A A. 50 or more large high or low voltage PCB capacitors? B. One (1) or more PCB transformers? C. 45kgs (99.4 lbs) or more PCB chemical substances or PCB mixtures? Does the facility contain other PCBs, PCB equipment (e.g., electromagnets, electric motors, hydraulic systems, heat transfer systems, compressors), or containers of PCBs or PCB mixtures? An annual inventory of PCBs is required if the facility has PCB equipment (equal to or greater than is shown in A,B,or C above). Does this facility have an annual inventory of PCBs? (Please make available copies of PCB inventory.) Are annual PCB inventories retained for five (5) years? Do annual reports contain: A. Date and source of PCB articles, chemicals, and mixtures received? B. Date and type of article, chemicals, and mixtures removed from service? C. Accounting of amount received, amount removed, and amount remaining at facility? Are all transformers and capacitors containing PCBs labeled? Are transformers not containing PCBs labeled "NO PCB"? Is PCB containing equipment that is not in service properly stored in a marked PCB storage area? 12/8/82 TENO 263 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS POLYCHLORINATED BIPHENYLS (PCB) (2) Does the PCB storage area meet the following requirements: YES NO N/A A. Roof to prevent rain water from reaching PCB items? _____ ____ ____ B. Spill containment to contain twice the internal volume of the largest PCB article? _________________ C. Containment area not have any drains, valves, expansion joints, sewer lines or other openings. Dofcs storage facility meet these requirements? _____ ____ ____ D. All articles marked with the date they are placed in storage? _____ ___________ E. All articles in storage checked for leaks at least every 30 days and records of checks maintained? _____ ____ ____ Does this facility have a program to eliminate existing PCBs? _____ ____ ____ Describe program. TENO 264 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS COMMUNITY RELATIONS (1) How many complaints were received from neighbors or other interested parties the last 12 months? _______ What percent of the neighborhood complaints received relate to: Air Water Noise Spills Solid Waste Disposal Other TOTAL _______ _______ _______ _______ _______ _______ 100% What percent of the complaints investigated relate to this facility? Describe briefly how complaints are handled and name individual(s) responsible for handling complaints. If written procedures exist, please attach a copy. When is the senior line manager responsible for local operations informed of citizen complaints? Who is responsible for reporting complaint information to the senior line manager? Does this facility have an emergency contingency plan? Has the emergency contingency plan been updated in the last 12 months? (Please make available a copy of the emergency contingency plan for the Review Team.) 12/8/82 _______________ YES NO N/A _____________ _ YES NO 1^7A TENO 265 / ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS COMMUNITY RELATIONS (2) What individual is responsible to make timely reports of the occurrence of emergencies to TOC P&M Environmental Affairs Department (Houston)? Briefly describe activities this facility has participated in the last 12 months to enhance community relations. Typical activities are providing speakers for civic clubs and other local organizations, participating in county (parish) fairs, supporting youth groups such as Little League, Scouting, etc., providing information to newspapers, radio or television. 12/8/82 TENO 266 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (1) The following items represent commendable performance or innovative solutions to environmental regulatory requirements that may have applications in other TOC Facilities. 12/8/82 TENO 267 SUMMARY TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT (2) THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION: DOES LOCAL INDIVIDUAL RESPONSIBLE MGMT FOR COMPLETION OF DATE FOR COMPLETION TENO 268 7/14/81 i TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (3) Unresolved questions raised as a result of the Environmental Review. Question #_____ Responsible party: Date for answer: Answer: Date answered: 12/8/82 TENO 269 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (*> COMMENTS 12/8/82 TENO 270