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miRoMEHTAL REVIEW-. IA,C. pASADENA plant 1985 ten 29i3 TENNECO OIL PAM FACILITIES ENVIRONMENTAL REVIEW TENNECO POLYMERS - PASADENA PLANT POLYVINYL CHLORIDE FACILITIES 12/20/84 1- - TEN 2914 TENNECO OIL P&M ENVIRONMENTAL REVIEW March 5-7, 1985 Name and address of facility; Tenneco Polymers Pasadena Plant 4403 La Porte Road P. O. Box 849 Pasadena, TX 77501-0849 Affiliated with: Tenneco Oil P&M Operations Manager: Frank Koslosky. (Name) Director - Operations (Title) " 'environmental Representative: 3im Kachtick (Name) Mgr.-Environmental Sciences (title) Type of operation and/or principal products: Polyvinyl Chloride (713) 479-3411 (Phone) (713)479-3411 (Phone) Review Team: Name Title Phone Bob Pruessner______________ R gerT we________________ Charles Beresford___________ Emile LcRouge_____________ Lloyd Stewart______________ Mgr.Environmental Affairs-TOC Sr.Environmental Eng.-TOC_______ Attorney - TOC___________________ Environmental Supervisor-TOC Mgr.Environmental Audits-TEN (713) 757-3306 (713) 757-7685 (713) 757-8764 (504) 579-2274 (713) 757-4100 1/2/85 -2- TEN 2915 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (I) 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 Russell Bowers Title Vice president--Chemicals Name Title Frank Koslosky Director - Operations ! ! Name i Title Harold Fife____________ Administrative Manager Name Jim Kachtick Title Manager - Environmental Sciences Name Title 5 % 12/20/84 -3- TEN 2916 TENNECO OIL P&M ENVIRON MENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (2) Please list name 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 analyses, etc. Jim Kachtick Manager - Environmental Sciences TITLE Brief description of environmental responsibility: Manage environmental affairs at Pasadena plant to insure compliance with pertinent laws and regulations. File permit applications, reports, and correspondence with regulatory agencies. Review and advise on all projects Irom the environmental aspect. Nelson Turner L'rrV Manager of Quality Assurance Name TITLE Approximate percentage (96) of work time dedicated to environmental: 20% Brief description of environmental responsibility: Supervise NPDES, NESHAP and RCRA analytical testing to insure proper methods and techniques are used. Provide technical assistance in troubleshooting operational problems with waste treatment systems. G orge Harvey(w< ^~________ Quality Assurance Supervisor NAME TITLE Approximate percentage (96) of work time dedicated to environmental: Brief dSscription of environmental responsibility: Oversees sample collection, provides liaison with operations in troubleshooting problems as tney arise. Jadle Pryor A(ecs T Chemist NAME TITLE Approximate percentage (96) of work time dedicated to environmental: 1Q0*_______ Brief description of environmental responsibility: Perform analytical testing for NPDES permit. 12/20/S4 TEN 2917 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (2) Please list name 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 analyses, etc. Joe Frank Robins Offsites Superintendent NAME TITLE Approximate percentage (%) of work time dedicated to environmental: 50% Brief description of environmental responsibility: ManaSe operations of waste treatment system, waste fuels boiler system, loading facilities, water treating system and VCM pipelines. Provides liaison on environmental/operational concerns with TENN-USS and Oxy. -r. /">* /C. Sandy Levine Offsites Production Engineer Name TITLE Approximate percentage (%) of work time dedicated to environmental: 50% Brief description of environmental responsibility: Provide technical service for operation of the offsite facilities. This includes troubleshooting as well as long-range studies and tests in this area._________ _____________ ____ Ed Dromgoole Offsites Operations Supervisor NAME TITLE Approximate percentage (%) of work time dedicated to environmental^ 50% Brief description of environmental responsibility: Supervise operations of waste treatment system, waste fuels boiler, and water treating system. Milton Hackfeld Loading Supervisor NAME TITLE Approximate percentage (%) of work time dedicated to environmental^ 10% Brief description of environmental responsibility: Supervise operations of the product ana raw materials loading facilities, including dock, and pipelines. 12/20/S4 yjc />./> /}/t ^ 'Jv-i'-f * 0* > * -t ir t~~ TEN 2918 NPDE5 Permit No.! TX0006335 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (1) Date Issued: Oct. 15, 1984* Other Water Discharge Permits: Date Issued: Texas Permit No. 00002 Feb. 22, 1983 Date Expires: Oct. 15, 1989 Date Expires: Feb. 22, 1988 * Effective date * Jan. 4, 1985 Discharge permit requirements: (Date EPA denied request for Evidentiary Hearing) Outfall Number iqi(Add additional sheets as necessary.) Permitted Avg Max Typical Actual Avg Max No. of Self-Reporting ** Violations-Last 12 Mos. Flow N/A N/A 1.46 2.42 0 BOD 500 1,000 257 2098 3 Oil & Grease 21^ 315 11.2 119.4 0 COD 5,200 10,400 603 3840 0 TSS 420 840 175 1150 2 VCM - 0.83 < 0.10 0 Toluene _ 3.75 <0.10 __ 0^ Type of Waste Water Treatment System: Primary Treatment (oil/water separation; equalization; neutralization) Activated Sludge Multi-media Filtration Method by which sanitary waste water is treated: Package Unit/Effluent goes to activated sludge system Who is treating sanitary waste? Tenneco Polymers, Inc. Sanitary Waste Water Permit No. N/A Issuing Agency: N/A ** See Attachment 2 12/20/84 -6 Expiration Date: N/A TEN 2919 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 001(Add additional sheets as necessary.) Permitted Avg Max Typical Actual Avg Max No. of Self-Reporting ** Violations-Last 12 Mos, Flow 3.0 mgl 5.4 mgl 1.99 Temperature 105F pH 6.0 - 9.0 6.0 - Chromium 10.4 17.7 2.2 Ammonia Floating Solids 100 200 Trace 28 Biomonitoring N/A . Type of Waste Water Treatment System: None 3.63 91 F 11.4 30.5 499 0 0 1 1 2 0 - Method by which sanitary waste water is treated: Who is treating sanitary waste? Sanitary Waste Water Permit No. Issuing Agency: Expiration Date: ** See Attachment 2 12/20/84 -7- TEN 2920 TENNECOOIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (2) Date and significant findings of last regulatory inspection: Please attach copy of regulatory inspection report. May 3, 1984 _________ ________________ (See Attachment 3) Do any discharge permits contain a compliance schedule? YES NO N/A X Is the facility meeting the compliance schedule? x FLOW AND pH In matters relating to flow, do procedures used conform to the "water measurement manual" (U.5. Dept, of Interior, Bureau of Reclamation) or other procedures approved by the E.P.A? Primary flow measuring device properly installed? Primary flow measuring device properly operated and maintained? _X JJC _X Is primary flow measuring device calibrated? How often? Monthly (Last calibration date: 3/4/85) _X Secondary instruments (totalizers, recorders, etc.) properly operated and maintained? X Are continuous pH recording instrument^ calibrated with pH buffer solutions? Frequency: Dally ^ on request X Are the date, time, and the name of the person who calibrated the continuous pH recording instrument recorded? In a book? _X On the chart?___ X Are calibration and maintenance records kept for 3 years on pH and flow measurement equipment? Are pH and flow measurement data kept for the required threeyear period? X SAMPLE COLLECTION AND PRESERVATION Permittee sampling meets requirements and intent of permit? Details: Flow proportional; refrigerated _______ 12/20/84 TEN 2921 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (3) Permittee is using method of sample collection required by permit? If not, explain method used and the frequency of sampling: YES NO N/A X Sampling locations adequate for representative samples? ._x__ ____________ Parameters and sampling frequency agree with permit? _x______________ Flow proportioned samples obtained where required by permit? _x______________ Are composite samples refrigerated at 40C during collection? _x__ ____________ Are grab samples refrigerated as soon as possible after collection? _x______________ Are samples labeled as to location, composite or grab, date and time of collection, and sampler? X__________ Are samples collected in the authorized containers for each parameter? X Are approved preservatives used for each parameter, when needed? _x______________ When samples must be preserved, are they preserved at the time of collection? X Are samples analyzed within required holding times? X Is the laboratory refrigerator for sample storage kept at ^C? X___________ When samples are not to be analyzed immediately in the lab, are they refrigerated at 4C? X___________ Are approved cleaning procedures followed in the laboratory for sample containers that are to be reused? X LABORATORY METHODS Are EPA approved analytical testing procedures used?(40CFR 136.3) X If a different procedure is used, has written approval been received from the necessary regulatory agencies to use this alternate procedure? X If part of an approved procedure is changed by you, has written approval been received from the necessary regulatory agencies for this change? X Are monitoring and analyses being performed more frequently than required by permit? If YES, are results reported in permittee's self-monitoring report? X 12/12/83 -9- TEN 2922 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER W Are parameters other than those required by the permit analyzed? Are the methods used stated on the laboratory report sheet? LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL Who is responsible for Laboratory Quality Assurance Program? Nelson Turner Are duplicate (precision) samples analyzed with each set of analyses? Frequency: _________ Are spiked (accuracy) samples analyzed with each set of analyses? Frequency: 100% Are precision control charts prepared and used? Are accuracy control charts prepared and used? Are intralaboratory quality control standards used for each permit parameter? Frequency: 100% Is satisfactory calibration and maintenance of laboratory in strument and equipment performed? Are laboratory equipment calibrations and maintenance records kept for the required three-year period? On analyses which require standards to be used in preparing calibration curves, are the curves prepared by using a blank and at least seven standards? On analyses which require calibration curves or internal in strument calibration with standards, are blanks and standards analyzed with each set of samples in order to verify the calibration curve? Are temperatures recorded on ovens(TSS) and incubators (BODs)? Frequency: once/month Are laboratory analytical balances checked using NBS weights? Are glucose-glutamic acid standards analyzed with each set of samples analyzed for BODs? Is Class A volumetric glassware used for permit-required analyses? 12/27/83 - 10 - TENNECOOrL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (5) LABORATORY DATA REPORTING AND STORAGE Are the following recorded on the laboratory report sheet: Sample location? Composite or grab? Date and time of collection? Sampler? Date and time analysis started? Analyst? Are sample results kept for the required three-year period? Are quality assurance and quality control records kept for the required three-year period? 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(s)? If Y ES, give details: YES _X __X _X X X x __ _JX X __ Seepage reported? Adequate freeboard (2 feet) to prevent overflow? Effluent release is: X Continuous _____ Intermittent _____ Seasonal * Will be used for biomonitoring in future. _X 12/12/83 - 11 - fEN TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (6) What is the receiving stream? Houston Ship Channel YES NO N/A Is there a formal Spill Control Plan (SPCC)? Has the SPCC been approved by management? Is the SPCC 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? Total amount of spill: X X ____ __ X ____ __ X ____ __ x __ If more than 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? _____ ____ x X x 12/12/83 - 12 - TEN 2925 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (7) How is storm water treated? Part of storm water collected in a retention pond, which is normally pumped to waste treatment unit. Other storm water is discharged untreated to the Houston Ship Channel.___________________ ______________ YES NO What is the design basis for storm water treatment? The first 450,000 gallons of rainfall are collected in the storm water retention pond. Do existing discharge permits have storm water requirements? * What are the requirements? N/A _____ _X * Application of storm water discharge permits as required by new NPDES regulations will be submitted by the deadline of/March 26, 1985. ) 12/12/83 TEN 2926 13 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (I) Docs this facility operate a ship or barge dock? What materials were transferred across the dock the last 12 months? Methanol Ortho-xylene L ^SS) AjuuKmia______ _______________________________ 2 Ethyl Hexanol ( Tji/ - u; s > YES NO N/A X Additional materials that may be transferred in the future* Propylene --------------------------------- 7* Iso-butyraldehyde f ----------------------------------------- Does the spill control plan include the dock facilities? What is the volume of the spill containment for the transfer facility? Two 20-gallon drip pans What emergency spill containment equipment (booms, absorbent, etc.) are owned and available at the facility? Vacuum truck Backhoe with front-end loader 12/6/82 14 rEN 2927 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (2) Have arrangements with other organizations been made for emergency spill cleanup support? YES NO N/A X Who? All-Waste Service, Inc.; Browning-Ferris Industries; Malone Marine Services; Petterson Marine ___ Do any of the materials transferred or anticipated to be transferred meet the Coast Guard definition of "oil," i.e., oil of any kind or in any form, including but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil"?^ If the transferred materials fall within the Coast Guard definition of "oil," an operations manual meeting the requirements of Coast Guard Regulation (CFR 33 Part 154--Oil Pollution Regulations for Marine Oil Transfer Facilities) is required. Has an operations manual been prepared meeting these requirements? (Please provide a copy of the manual.) _________ (1) If an operations manual has been prepared, has it been sub mitted to the Coast Guard "Captain of the Port" (required no later than March 3, 1983)? (2) Has the Captain of the Port issued a "letter of adequacy"? X X (3) Have amendments to the dock operations manual been made since the issuance of the Coast Guard "letter of adequacy"? X 0 Are copies of the dock operations manual available to dock operations personnel? X (5) Has this facility designated "persons in charge of facility oil transfer operations" and advised the Captain of the Port of this designation in writing? (6) Are current (annual) hose pressure tests and inspection records available at this facility? X X If the transferred materials do not fall within the Coast Guard definition of "oil" but do fall within the requirements of 33CFR126 --Handling of Explosives or Other Dangerous Cargoes Within or Contiguous to Waterfront Facilities--has a dock operations manual been prepared for this facility? X 12/6/82 - 15 TEN 2928 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (3) (I) If an operations manual has been prepared, are copies available to dock operations personnel? (2) Does the operations manual contain the following: A. Documentation that the dock operator is a qualified operator? B. Dates and results of the most recent cargo hose and piping hydrostatic tests? C. Cargo information cards listing the following; Cargo identification characteristics' (appearance, odor, etc.)? b. Emergency procedures? c. Fire fighting procedures? YES NO N/A X X __ X X X X 12/6/82 - 16 - TEN 2929 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 resinx Suspension resin x __ Bulk resin Does this plant have a fixed vinyl chloride monitoring ______ X system in place to continuously monitor VCM emissions? _X Do exhaust gasses meet the less than lOppm VCM limit? __X What sort of control devices are used to reduce VCM exhaust gases to lOppm or less? Incinerator System How many relief valve discharges were reported in the last 12 months? ^ (See Attachment A) Where did relief valve discharges go? x Flare x Atmosphere Other 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 con^trolled--what is the control mechanism?. I -HI N/l A1^ < " - 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* * Three discharges to atmosphere; one discharge to flare. 12/27/83 - 17 - TEN 2930 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) ^ i-'S ->ro-h ,U T > " I a* * ' * 7^ Are relief valves connected h/aprocess line, recovery system, or equivalent? Esgentiallyall discharge to If not, are they equipped with rupture discs? ~/flare^system. YES NO N/A X 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? No unused portions remain. Is the VCM content of equipment reduced as required before opening to atmosphere? X X X 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"? Two consecutive 25 ppm analyses. X X Is the VCM content of "in process wastewater" reduced as required? x Does this plant have Standard Operating Procedures incorporating the VCM fugitive emission requirements? x Are emissions data reported in Semiannual Report as required? -- ** How many reported exceedances were there the last 12 months for: x a. Residual VCM content of stripped PVC slurry? 0 What percent is this of total reported values? 0% ______ b. Reactor opening emissions?18_ What percent is this of total reported values? 8.9% c. Incinerator VCM emissions greater than lOppm? 6 What percent of incinerator operating hours? " 0.14Z Is record keeping performed as required? a. Are records kept two years? b. Are they destroyed after two years? __X X ___ _____ X When was last NESHAPS inspection? April 9. 1984 (See Attachment S) (Please provide copy of report.) . .. * TACB approved program in June, 1984. -to A-* ** Last two semi-annual reports (covering September 1, 1983 through August 31, 1984). 12/12/83 TEN 2931 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. None 3. 4. 5. 6. 7. List air operating permits presently in force: Description of Date Expiration Allowed Monitoring Permit Unit Issued Date Emission Requirements Reporting Requirements 1. R-4545 10/19/77 - (F-8 Waste Fuels Boiler) 440 ppm SO2 None to 6 ,, 0.10 lb particulate7STU <2b% opacity None 2. R-944B 6/7/82 (PVC Plant) 852.8 T/Y VOC None 14.2 T/Y particulate None 12/8/82 - 19 - TEN 2932 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (2) When was the last air regulatory inspection? APril 9 1984 (See Attachment 5) Please provide a copy of last inspection report^ (Date) Describe any noted deficiencies and the corrective action taken: DEFICIENCY CORRECTIVE ACTION 1. Incomplete tagging N_________ Cylinder was properly tagged 2. of VCM calibtation gas 3. cylinder ____________ J 4. ____________ __ ___________________ 5. _________________________ 6. 12/8/82 - 20 - TEN 2933 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (3) When was the last air emissions inventory? List reported emissions rates: 1. Hydrocarbons 2. Sulfur Dioxide 3. Nitrogen Oxides 4. Carbon Monoxide 5. Particulate 6. Vinyl Chloride 7. 8. __ 1 QfiO - DATE Tons/Year 795.2 J/ 0 2,022 1,114 l 3.6 7.1 What procedure is followed to report emission excursions to regulatory agencies? Please attach a copy of existing written procedure. Telephone notification of emission to regulatory agencies by operations t shift supervisor. Written notification by Manager - Environmental Sciences within required time period. Is this facility monitoring ambient air quality? * Is a quality assurance program used? (Please provide quality assurance records.) x ___ YES NO X ___ YES NO ____ N/A ___ N?X" * Per participation in Houston Regional Monitoring System. 12/S/82 - 21 - TEN 2934 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR w What parameters are monitored? SO?, TSP, Ozone, CO, N0,,_____________________________ Meteorological Data___________________________________ Has air monitoring data shown exceedances of air standards? X __ ____ 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: _X__ ___ _____ YES NO "N7A Does this facility have procedures to insure leaded gasoline is not used in company vehicles designed for unleaded gasoline? X YES NO "N7A If this facility dispenses more than 200,000 gallons of gasoline per year, does it have Stage 1 vapor control system installed? X YES NO n7A Who is responsible for gasoline health effects warnings? Leon Cox Is gasoline health effects information posted in vehicle refueling areas? X YES "NO "N7A 12/27/83 - 22 TEN 2935 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 What is the registration number? TXD 043749092 YES NO N/A X __X ___ ___ ___ ___ List any hazardous waste and the amount being generated and show if it is disposed of on or off-site. See Attachment 6 List any solid waste and the amount being generated and show if it is disposed of on or off-site. Plant trash - 10,000 yd^/yr w~'->. .* *'* ) ON OFF Y X Is any hazardous waste disposed of in a landfill as free liquid? If so, have arrangements been made for another type disposal of this waste after May. 1985t since this practice will then be prohibited? [Currently 11n H p y~~Tnvotx.j^at-^ Does this facility produce, distribute, or burn any fuel derived from hazardous waste? Discuss: _______ ___________________ X ^ Liquid hazardous wastes burned in F8 If this facility is a treater, storer, or disposer (TSD facility), does it have a final RCRA permit? Has this facility received its RCRA Part B application? If yes, when is Part B application due? Is Part B application being completed as per 40 CFR 264 6c 270? 12/27/84 - 23 - TEN 2936 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (2) If this is a TSD facility which does not yet have a final RCRA permit, is it in compliance with the interim standards? Are the following prepared: Written Waste Analysis Plan? Is the site secure to prevent unknowing entry or are "Danger-Unauthorized 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 uniform manifests used with each off-site load of hazardous waste? Are all hazardous waste manifests accounted for? Starting 9/1/85, generators must certify on their manifests that they have a program in place to reduce the volume and/or quantity and toxicity of their hazardous waste. Does this facility have such a program? 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? Has any drummed waste been held over 90 days? What is the present inventory of drummed waste? 68 Number of drums Is each drum dated when hazardous wastes are placed in the drum? What is the present inventory of empty drums? 66 See Attachment 7 Number of drums YES NO N/A X 12/27/84 - 24 - TEN 2937 TENNECO OIL P&M ENVIRONMENTAL REVIEW \ TENNECO POLYMERS Solid Waste Disposal (3) How are empty drums disposed of? Empty drums are crushed and shipped to CWM's Class I site for disposal._____________________________ ____________ YES NO N/A Are any empty drums given (sold) to employees or neighbors? _____ X Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material? _X 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______ ___________ X ____________X ____________X ______X ______X ____________X ____X ____________X X Has TOC provided closure costs of on-site treatment and storage facilities? ___________ ___ X What is estimated cost? N/A______ Who estimated cost? N/A Are ponds used in hazardous waste treatment? _____ X ___ Are ponds in natural clay? _____ _________ X Are ponds lined with clay? _______________ X How thick? N/A _____ What freeboard is maintained in ponds? N/A What is expected 24-hour rainfall in a five-year period? 10" Does this facility have an ongoing groundwater monitoring program?X If facility has a final RCRA permit, what phase of GW monitoring exists at present? Detection___ Compliance___ Corrective Action___ N/A If facility is still in interim status, is GW monitoring program in compliance with the interim status requirements? _______________ X 12/27/83 - 25 - TEN 2938 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS Solid Waste Disposal (4) How many monitoring wells are used? N/A How many wells are upgradient? N/A How many wells are downgradient? N/A How deep are the monitoring wells? N/A What are the wells monitored for? (40 CFR 265.92) N/A 1. Set 1 Parameters: ____________________________ 2. Set 2 Parameters: 3. Set 3 Parameters: ____________________________ 4. Other: Have initial background concentrations been established for all of the parameters analyzed? YES NO N/A _______________X Does this background information indicate any groundwater contamination? X If so, has a groundwater quality assessment program been established as per the interim status regulations? _____ _________ * What Jsas been the total cost of the groundwater monitoring program?_ N/A What were the costs for the last 12 months? Are monitoring-well results reported to state? _______________ Y_ What is the depth of the shallowest aquifer currently used? ^00 12/12/83 - 26 - TEN 2939 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS Solid Waste Disposal (5) Does this facility operate water wells? What depth? 800 ft How many? 2 * List private drinking water wells near this facility. Owner Depth 1, None within one mile 2. ______________________ 3. _____ ________________________________________ 4. _____ ____________________________________ List industrial/commercial water wells near this facility. Owner Depth Water Use 1, Shell890 ft. 2. Potable/Industrial 3. 4. List municipal or public water wells near this facility. Owner Depth Water Use None within one mile 2. 3. if. Has this facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note? NM YES NO N/A X pL***-^ -t-* + l I 5 Have these discrepancies been corrected? (Provide a copy of last regulatory inspection.) See Attachment 8 * Four other wells are permitted, but not normally in use. 12/12/83 - 27 - TEN 2940 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. Chemical Waste Management-Port Arthur TXD0Q0761262 2. Chemical Waste Management-Lake Charles LAD000777201 3. Rollins Environmental Services-Baton Rouge LAD01039515 4. Rollins Environmental Servicer-Deer Park TXD055141378 Do you have a copy of their current RCRA permit? YES NO N/A X Do you have a copy of their current state permit(s)? X Have you visited this facility in the last 12 months? X 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.) X See Attachment 9 Are DOT approved containers and labeling used for off-site delivery of hazardous waste? ^ t 0 0j <? s> o / X Estimated annual cost of off-site disposal? $130,000 Has this off-site facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note? See Attachment 9 Have these discrepancies been corrected? See Attachment 9 * Neither CWM-Port Arthur or Rollins Environmental Services-Deer Park are currently accepting wastes that we generate. 12/12/83 - 28 TEN 2941 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS UNDERGROUND STORAGE (1) Does this facility have underground storage tanks? X YES NO *n7a Please tabulate information on underground storage including fuel tanks. Tank Identification . Unleaded 1 gasoline 2. Leaded gasoline 3. Tank Volume 1000 gal 3000 gal Material of Construction carbon steel carbon steel Tank Age 23 yrs 23 vrs Material Stored unleaded gasoline leaded gasoline 4. 5. 6. 7. 8. 9. 0. How often is stored product inventory reconciled? Weekly_____________________ What program is followed to insure early detection of potential leaks? These tanks are being replaced with above ground tanks. This should be completed by March, 1985._____________________________ 12/12/83 29 TEN 2942 TENNECO OR. P&M ENYIRONMENTAL REVIEW TENNECO POLYMERS POLYCHLORINATED BIPHENYLS (PCB) (1) YES NO As of July 2,197$, did this facility contain in service, stored for future use, or stored for disposal: A. 50 or more large high or low voltage PCB capacitors? B. One (1) or more PCB transformers? C. 45kgs (99,U 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? _____ X ________ X _____ X _____ X 12/20/84 - 30 - TEN 2943 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (1) Name of pipeline! Tenneco VCM Pipeline from Shell When was pipeline constructed?4/14/73 What is pipe diameter?V] Length of pipeline?____________ 5,400 ft. What products are transported? VCM Normal operating rate and pressure:_________________________ _________ Maximum operating rate and pressure! Date of latest hydrostatic test! 4/14/73 at 2225 psig Do current DOT regulations require additional pressure testing? ___ _X_______ YES NO N/A How often are pipeline rights-of-way inspected? Annually Who conducts these inspections? Tenneco Personnel (per annual cathodic protection (Provide a copy of a typical inspection.'?6'^ n How often are navigable waterway crossings inspected?________ ________________ Are all line markers provided as required?Yes__ Do the markers contain the proper wording as required as well as emergency phone numbers?]^ How many pump stations are on this pipeline?_ One What is the source of power? Electric Yes x No___ N/A___ Gas Yes___ No___ N/A___ Diesel Yes___ No___ N/A___ What provisions are made to shut down pumps in event of pipeline leak? Notification by "hot line" between Shell and TPI. Local shutoffs at pumps. Remote air-operated valves on storage spheres. 12/8/82 - 31 - TEN 2944 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (2) Are herbicides used to control right-of-way vegetation growth? If herbicides are used--what kind is used? ____ __X YES NO N/A How applied? Aerial_____ Ground Are licensed applicators used to apply herbicide? ____________ x YES NO N/A Have adjacent land owners complained about herbicide problems?____________ X YES NO N/A If so, give brief description. Is cathodic protection provided for the pipeline? ^ What type? Magnesium Anode Beds YES NO How often is cathodic protection current measured? Annually How often is cathodic protection pipeline to ground potential measured? Annually (Please provide representative records of cathodic protection maintenance.) How is the "Public Education" provision of 195.HO administered? N/A( -t-. -*jPivh / '<*- v y a & s - j N/A What material, if any, is discharged from the pipeline during testing or cleaning?_____ Water_____________________________ How often? Initial startup of pipeline only Where?______ TCI plant________________________________________ What is final disposition of material? WaSte Treatment Unit 12/8/82 - 32 - TEN 2945 TENNECO OIL P&M ENVIRONM ENTAL R EVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (1) Name of pipeline: Tenneco VCM Pipeline from B. F. Goodrich When was pipeline constructed? 12" ~ 4/14/73; 6" - 11/13/80; 4 - 11/13/80 What is pipe diameter? 12"; 6", 4" Length of pipeline? 12" - 13,800*; 6" - 770*; 4" - 1,200* (total 15,770') What products are transported?__________ VCM Normal operating rate and pressure: ?80 gpm at 200 pslg Maximum operating rate and pressure: 350 Pm at 300 pslg Date of latest hydrostatic test: 12" - 11/13/80 at 2225 pslg; 4" and 6" - 11/13/80 at 750j Do current DOT regulations require additional pressure testing? ___ X _____ YES NO N/A How often are pipeline rights-of-way inspected? Annually Who conducts these inspections? Tenneco personnel - per annual cathodic protection inspection (Provide a copy of a typical inspection.) How often are navigable waterway crossings inspected? Are all line markers provided as required? Yes Do the markers contain the proper wording as required as well as emergency phone numbers? Yes How many pump stations are on this pipeline ? One What is the source of power? Electric Yes X - Gas Yes___ No___ No___ N/A___ N/A;___ Diesel Yes___ No___ N/A___ What provisions are made to shut down pumps in event of pipeline leak? Notification by "hot line" between Goodrich and TPI. Local shutoff at pumps. Remote air-operated shutoff valves on storage spheres. 12/8/82 - 33 - TEN 2946 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (2) Arc herbicides used to control right-of-way vegetation growth? If herbicides are used--what kind is used?_______ X YES NO N/A How applied? Aerial_____ Ground Are licensed applicators used to apply herbicide? _____________ YES NO N/A Have adjacent land owners complained about herbicide problems?_____________ YES NO N/A If so, give brief description. Is cathodic protection provided for the pipeline? _____________ YES NO N/A What type? Magnesium Anode Beds How often is cathodic protection current measured? Annually How often is cathodic protection pipeline to ground potential measured?_________ Annually__________________________________ (Please provide representative records of cathodic protection maintenance.) See Attachment 10 How is the "Public Education" provision of 195.440 administered? What material, if any, is discharged from the pipeline during testing or cleaning?______ Water________________________________ How often? Initial startup of pipeline only Where?______ TCI plant __________________________________ _ What is final disposition of material? Waste Treatment Unit 12/8/82 - 34 TEN 2947 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS COMMUNITY RELATIONS/EMERGENCY PLANS (1) How many complaints were received from neighbors or other interested parties the last 12 months? Is this a decrease compared to the previous 12 months? None Yes Describe briefly how complaints are handled and name individual(s) responsible for handling complaints. If written procedures exist, please attach a copy. / Anv complaints are routed to Director - Operations. He assigns someone from plant to follow up, depending on nature of complaint: When is the senior line manager responsible for local operations informed of citizen complaints? ASAP Who is responsible for reporting complaint information to the senior line manager? Frank Koslosky Does this facility have an Emergency Contingency Plan? Of so, please make a copy available.) See Attachment 11 Has the Emergency Contingency Plan been updated in the last 12 months? Does this facility have a system set up to make timely notifica tion of the occurrence of emergencies to TOC P&M (Houston)? What individual is responsible to make timely reports of the occurrence of emergencies to TOC P&M Environmental Affairs Department (Houston)? Jim Kachtick YES NO N/A _X 1/8/85 05 - TEN 2948 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS COMMUNITY RELATIONS/EMERGENCY PLANS (2) With what local agencies has this facility discussed emergency procedures? (e.g. Sheriffs Department, Fire Department, etc.) Channel Industries Mutual Aid Organization Which of these agencies have been given Material Safety Data Sheets (MSDSs) or hazardous substance information sheets to make them more knowledgeable about th facility's principal products? ___________________________________________________________________ None List the principal products for which MSDSs or hazardous substance information sheets have been provided to local agencies: __^ None Does this facility have a "neighbor warning" plan established, such as coordination with local sheriff or police, telephone calling system, etc? X YES NO 757a" 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. Individuals from the Pasadena plant participate in various Tenneco-sponsored activities, such as Volunteers In Action, Houston Chamber of Commerce, etc. 1/7/85 - 36 - TEN 2949 TENNECO OIL P&M 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 - 37 "V TEN 2950 TENNECO OIL PftM t ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY 2} THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION: DOES LOCAL INDIVIDUAL RESPONSIBLE DATE FOR TEN 2951 8/16/83 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 answers Answer: Date answered: 12/8/82 - 39 - TEN 2952 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (4) COMMENTS 12/8/82 TEN 2953 40