Document 0gLv2K1OJYYe8oe4jvEd8penn
TOC P&M Environmental Affairs
ICOMPANY)
/e
INTEROFFICE COMMUNICATION
TO: Tenneco Polymers FOR: Ron Neugold FROM: R. D. Towe RE: ENVIRONMENTAL REVIEW - BURLINGTON PLANT -
DATE: July 12, 1984 -> r
Your approval is requested for scheduling the Environmental Review of the Burlington Plant on September 11-13, 1984.
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 Russell Bowers D. H. Carter Walt Fogelsanger Hal Bees Jim Kachtick Fred Kanzler Ralph Maynard Bob Pruessner A1 Smith Lloyd Stewart
7). JflUAC
R. D. Towe
JUL 12 1984 TOC LEGAL - P & M
TEN03Sj
((
AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - BURLINGTON PLANT
September 11-13, 1984
Tuesday, September 11
11:15 a.m.
Depart Houston Intercontinental on Continental 372.
3:00 p.m.
Arrive Philadelphia airport. Obtain large Avis rent car and drive to Burlington, New Jersey.
About 5:00 p.m.
Check in Hilton on Highway 295 in Mount Laurel,
New Jersey.
"
6:30 p.m.
Supper for the Review Team and Polymer representatives at Charlie's Other Brother in /^Mt. Holly^-'Fred Kanzler will make reservations for ' the Review Team from Houston and the Burlington plant staff.
Wednesday, September 12
8:00 a.m.
Meet with Ron Neugold to confirm 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
6/26/84
1- -
HENO 352
AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - BURLINGTON PLANT
September 11-13, 1984
Thursday, September 13
8:00 a.m.
Review wastewater treatment plant performance status.
9:15 a.m.
Review groundwater monitoring program status.
10:15 a.m.
Review overall closure plan for on-site landfill and future plans for handling the solid waste.
11:15 a.m.
LUNCH (Please provide sandwiches in plant.)
12:00 noon
Draft proposed conclusions of Environmental Review.
1:00 p.m.
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 Kachtick, Guy Disch, and Bob
Pruessner.
2:00 p.m.
Depart for Philadelphia airport.
3:45 p.m.
Catch Continental 371 for Houston.
6:04 p.m.
Arrive Houston.
6/26/84
-2TEN0 353
TENNECO OIL P<5cM FACILITIES
ENVIRONMENTAL REVIEW
TENNECO POLYMERS - Burlington Plant POLYVINYL CHLORIDE FACILITIES
4/28/83
TENO 354
TENNECO OIL F&M ENVIRONMENTAL REVIEW
Name and address of facility;
Tenneco Polymers Burlington Plant P. O- Box 116 Burlington, New Jersey 08016
September 11-13, 1984
Affiliated with: Tenneco Oil P&M
Operations Manager:
Ron Neugold (Name)
Plant Manager (Title)
Environmental Representative:
Fred Kanzler___________ (Name)
"
Environmental Coordinator (Title) "
Type of operation and/or principal products!
Polyvinyl Chloride
Review Team: Name
Title
Roger Towe Hal Hees Pat Anderson Jim Kachtick Lloyd Stewart
alt Fogelsanger
Sr.Environmental Eng.-TOC_____ Attorney - TOC Mgr.Environmental Audits-TEN Mgr.Environmental Sciences-TOC Mgr.Environmental Audits-TEN Plant Engineer-Polymers
(609) 386-9200 (PhoneT
(609) 386-9200 (Phone)
Phone (713) 757-7685 (713) 757-2607 (713) 757-3604 (713) 479-3411 (713) 737-4100 (201) 782-4011
6/26/84
TEN0 355
((
TENNECO OIL PftM ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT ENVIRONMENTAL STAFFING
0) 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 Title Director of Operations
Name Title
Name Title
Name Title
Name Title
6/29/84
TEN0 356
I(
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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:____________________
12/8/82
TENO 357
f(
TENNECO OIL PftM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (1)
NPDE5 Permit No.:
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 Avg 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 358
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TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (2)
Date and significant findings of last regulatory inspection: (Please attach copy of regulatory inspection report.)
YES NO N/A
Do any discharge permits contain a compliance schedule? Is the facility meeting the compliance schedule?
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?
Is primary flow measuring device calibrated?
(Last calibration date: )
Secondary instruments (totalizers, recorders, etc.) properly operated and maintained?
Are continuous pH recording instruments calibrated with pH buffer solutions? Frequency:
Are the date, time, and the name of the person who calibrated the continuous pH recording instrument recorded? In a book?___ On the chart?___
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?
SAMPLE COLLECTION AND PRESERVATION
Permittee sampling meets requirements and intent of permit?
Details:
___________ _____ ___
2/3/83
TENO 359
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER
(3)
YES NO N/A
Permittee is using method of sample collection required by
permit? If not, explain method used and the frequency of
____
sampling: ._____________________________ _________________________ _
Sampling locations adequate for representative samples?
Parameters and sampling frequency agree with permit?
Flow proportioned samples obtained where required by permit?
Are composite samples refrigerated at 4C during collection?
Are grab samples refrigerated as soon as possible after collection?
Are samples labeled as to location, composite or grab, date and time of collection, and sampler?
Are samples collected in the authorized containers for each parameter?
Are approved preservatives used for each parameter, when needed?
When samples must be preserved, are they preserved at the time of collection?
Are samples analyzed within required holding times?
Is the laboratory refrigerator for sample storage kept at 4C?
When samples are not to be analyzed immediately in the lab, are they refrigerated at 4C?
Are approved cleaning procedures followed in the laboratory for sample containers that are to be reused?
LABORATORY METHODS
Are EPA approved analytical testing procedures used?(4QCFR 136.3)
If a different procedure is used, has written approval been received from the necessary regulatory agencies to use this alternate procedure?
If part of an approved procedure is changed by you, has written approval been received from the necessary regulatory agencies for this change?
Are monitoring and analyses being performed more frequently than required by permit? If YES, are results reported in permittee's self-monitoring report?
12/12/83
TENO 360
TENNECO OIL PA:M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER 0
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 Commercial laboratory used? If so, name: Commercial laboratory state certified? Who is responsible for Laboratory Quality Assurance Program?
Are duplicate (precision) samples analyzed with each set of
analyses?
Frequency:
Are spiked (accuracy) samples analyzed with each set of analyses?
Frequency:
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:
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:
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?
6/26/8^
TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
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?
Weeds cut and vegetation growth in ponds removed? Banks and dikes maintained? (Erosion, etc.) Any reports of groundwater contamination from pond(s)?
If YES, give details:
Seepage reported? Adequate freeboard (2 feet) to prevent overflow? Effluent release is:
_____ Continuous _____ Intermittent _____ Seasonal
What is the receiving stream?
6/26/84
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (6)
Is there a formal Spill Control Plan (5PCC)?
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:
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?
Is this facility a "major facility" as defined in the New Jersey Water Pollution Control Regulations, i.e., N.J.A.C. 7:1E-I.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. 7:1 E-4.5 and
7: IE-4.21?
Have the DPCC and DCR Plans been approved by the NJDEP, 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?__________________
Results:
______
___ .
6/26/84
/
TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
WATER (7) YES NO N/A
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?
12/12/83
TENO 364
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
(I) YES NO N/A
What type(s) of PVC resin is produced:
Dispersion resin Latex resin Suspension 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 relief valve :ischarges were reported in the last 12 months?__
Where did relief valve discharges go?___ Flare ___ 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 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
12/27/83
TENO 365
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 IQppm? 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 366
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TENNECO OIL WcM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
AIR (1)
List air construction permits or permit exemptions obtained in the last 12 months:
Description of Permitting Permit Unit Agency
Control Device
Allowed 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
Reporting Requirements
1. _______________ 2. ________________
3. ______________ _
4. ______ _______________ __
3. _____________ ______
6. ______
7. __
8. _____________ _ 9. ______________________________________________________________
12/8/82
TENO 367
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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:________________
___________
Is this facility now in compliance with Subchapter 17 of the New Jersey Regulations (this subchapter addresses TVOS)?
Comments:_____
___
6/23/83
TENO 368
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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
Te5
____ YES
___
no
___ NO
n7a"
-- N/A
TENO 369
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TENNECO OIL F&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
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 N/A
If this facility dispenses more than 200,000 gallons of gasoline per year, does it
have Stage I vapor control system installed?
____ ___ ____
YES NO N/A
Who is responsible for gasoline health effects warnings?
Is gasoline health effects information posted in vehicle refueling areas?
12/8/82
____ ___ YES NO "N7A
TEN0 370
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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.
If this facility is a treater, storer, or disposer (T5D facility), does it have a final RCRA permit?
YES NO N/A _____ __ _ ____
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 <51 270? _____ _ ___ _
12/27/83
TENO 371
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 ignitabie 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?
Has 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 372
TENNECO OIL PfcM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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?
Does this facility have an ongoing groundwater monitoring program?
If facility has a final RCRA permit, what phase of GW monitoring exists at present? Detection___ Compliance___ Corrective Action
If facility is still in interim status, is GW monitoring program in compliance with the interim status requirements?
6/26/84
TENO 373
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
SOLID WASTE DISPOSAL (4)
How many monitoring wells are used?
___________________
How many wells are upgradient?
How many wells are downgradient?
How deep are the monitoring wells?
What are the wells monitored lor? (40 CFR 265.92)
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 _____ _______
Does this background information indicate any groundwater contamination?
_____ ____ ____
If so, has a groundwater quality assessment program been established
as per the interim status regulations?
_____ ____ ____
What has been the total cost of the groundwater monitoring program? _____ _ . What were the costs for the last 12 months?
Are monitoring-well results reported to state?
___________ _____
What is the depth of the shallowest aquifer currently used?
Do you receive hazardous waste from off-site?
_____ ____ __ _
2/24/84
TENO 374
(
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
SOLID WASTE DISPOSAL (5)
YES NO N/A
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.
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? (Provide a copy of last regulatory inspection.)
12/12/83
TENO 375
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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? 3/2/83
TENO 376
((
TENNECO OIL WtM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
UNDERGROUND STORAGE (1)
Does this facility have underground storage tanks?
___________ YES NO N7A
Please tabulate information on underground storage including fuel tanks.
Tank Identification
Tank Volume
Material of Construction
Tank Age
Material Stored
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
How often is stored product inventory reconciled? _________________ _ What program is followed to insure early detection of potential leaks?
3/2/83
TENO 377
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 378
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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. Does 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.
12/8/82
TENO 379
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
COMMUNITY RELATIONS
(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?
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.)
YES NO N/A Tes Wn7a
12/12/83
TENO 380
((
TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT COMMUNITY RELATIONS
(2) What individual is responsible to make timely reports of the occurrence of emergencies to TOC P<5cM 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
TEN0 381
(
TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
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 382
TENNECO OIL P&M ENVIRONMENTAL REVIEW
SUMMARY ---------IS--------TENNECO POLYMERS - BURLINGTON PLANT THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION:
ITEM# DESCRIPTION , SPECIFIC IMPROVEMENT NEEDED
DOES
LOCAL INDIVIDUAL RESPONSIBLE MGMT FOR COMPLETION OF AGREE. CORRECTIVE ACTION
DATE FOR COMPLETION OF IMPROVEMENTS
TENO 383
5/18/83
((
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 answer: Answer:
Date answered:
12/8/82
TENO 384
r
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS SUMMARY (4)
COMMENTS
12/8/82
TENO 385