Document 0z70pVGMejRKRJxGeQREkdMJ

 > Uh'A 00001 1534 AMMERMAN MEDIA TRAINING TO: JIM RUTLEDGE Interoffice Communication FROM: DATE: John D. Olson February 23, 1987 SUBJECT: EFFECTIVE MEDIA COMMUNICATIONS SEMINAR VISTA As you requested, I'm sending you the attached information as confirmation of my plans to attend the Ammerman Enterprises seminar on March 9 and 10, 1987. J0HN D. OLSON PROCESS SUPERINTENDENT JDO/lo sfzJs Name: John D. Olson Title: Process Superintendent Location: Vista Polymers- Oklahoma City PVC Plant 5200 S.E. 59th Street P. 0. Box 15360 Oklahoma City, OK 73071 Vista's Oklahoma City Plant manufactures polyvinyl chloride resin (PVC) for downstream processing by customers to produce PVC plastic pipe and house siding. The plant employs 49 people. The Process Superintendent is in charge of the plant's production department, consisting of 4 Shift Supervisors and 16 Operators. The plant maintains a 24-hour operation staffed by Production personnel on a rotating shift schedule. Maintenance and Office personnel provide support on a regular, 40-hour week work sched ule . Potential problems at the OKC PVC Plant are those common to many modern chemical processing plant. These include: - The plant process utilizes vinyl chloride monomer (VCM) as a feedstock. VCM is a highly flammable, carcinogenic materi al. Several million pounds of VCM are stored and processed in the plant at any given time. Extreme caution must be utilized in handling the VCM to ensure safe operation of the plant. - EPA and OSHA regulations strictly limit quantities of VCM that can be emitted to the atmosphere. Established operat ing procedures are utilized to ensure compliance with these regulations. - A residential neighborhood and several other manufacturing facilities are located within Jj-mile of the plant. A significant gas release or fire at the plant could affect these neighbors. - Safety procedures and policies must be strictly followed and enforced at the plant to ensure the safety and health of plant personnel. Biography John Olson the youngest of the three children of Edwin and Easther Olson was born on December 25, 1954. John spent his first eighteen years in the small town of Russell, Kansas. Aside from attending twelve years of public school, John spent his time in Russell involved in football, wrestling, track, band, and many outdoor sports including hunting and fishing. John held several part time jobs such as furniture delivery, farm work, house shingling, road construction, and gopher for the City Electrical Department. John graduated high in his high school class and elected not to attend college the following year. Rather, he obtained a job building houses and was later employeed as a grain *\ Biography (Cont'd) elevator operator. After a year away from school, John enrolled in the University of Kansas at Lawrence, Kansas. Four years later John graduated from K.U. with a B.S. degree in Chemical Engineering. In July of 1978, -John obtained a job with Conoco in Ponca City, Oklahoma. John worked as a Chemical Engineer in the Chemicals Division of Conoco's Process Engineering Department. John's job assignments involved process engineering design work for Conoco's PVC manufacturing facilities in Oklahoma City, Oklahoma and Aberdeen, Mississippi. In April, 1980, John was transferred to the Oklahoma City PVC Plant as a Process Engineer. He spent the next four years involved in the design, construction, and opti mization of chemical processing equipment at the Plant. In June, 1984, John was promoted to the position of Process Superintendent at the Oklahoma City Plant. The Plant became a part of Vista Chemicals in July, 1984, as the result of a leveraged buyout of the ConocoTs chemical operations. John, currently is still the Process Superintendent at Vista's Oklahoma City PVC Plant. He resides in Norman, Oklahoma. His Interests and hobbies Include snow skiing, golf, scuba diving, hunting, boating, guitar, and stereo equipment. A upA 000011587 Tot Jim Rutledge - Houston itorofflce ommunicotion From: Gary Foshee - LCCP Dote: January 26, 1987 Subject; Effective Media Communications Seminar VISTA This letter will confirm my plans to attend the seminar and provide the information you requested: Title: Chief Process Engineer Lake Charles Chemical Plant Address: Vista Chemical Company Lake Charles Chemical Plant Old Spanish Trail P. 0. Box 727 Westlake, LA 70669 I was bom-and raised in Louisiana, graduated from Louisiana Tech University and worked three years for Dow Chemical Company before joining Vista as a Process (Chemical) Engineer in 1969. Since then, I have worked as Senior Process Engineer at LCCP, Chief Process Engineer at LCVCM and currently Chief Process Engineer at LCCP. The Chief Process Engineer is responsible for the supervision of the Process Engineering Department. This position is expected to supervise this function to maximize effective operation and provide technical expertise to the operating departments. In addition, the position directs Process Engineering recruitment, career development ; of Process Engineers, and initiates cost effective programs and projects. There are three (3) Senior Process Engineers reporting to me with fifteen (L5) Process Engineers reporting to the Senior Process Engineers. The Chief Process Engineer reports to the Director of Technical Services who reports to the Plant Manager. The plant .produces chemicals derived from oil and natural gas. The chemicals produced in the plant are ethylene, alcohols, normal paraffin, methyl chloride, solvents, and alumina as a byproduct of alcohol production. Other smaller byproducts streams are produced and must be either sold or handled in an environmentally acceptable manner. A waste water treatment system which usually works very well has some problems in cold weather operation and takes a lot of attention during this time.. There are many Federal, State, and Local environmental regulations that must be complied with. The Process Engineering Department is made up mostly of young chemical engineers with less than four (4) years experience. UPA 0009U-'3b Jim Rutledge January 26, 1987 Page 2 If you would like additional information I would be glad to provide it. G. L. Foshee tm MPA o000115 RPR MEDIA PLANNING .-'xjr CO OI ' -0*0J UPA 0OOOU59O ^ t- PVC Makers Look for Growth As Environmental Fears Ebb Producers of polyvinyl chloride are confident that the market for this plastic will continue to grow, as environmental fears, particularly in the plumbing, elec trical conduit and food packaging areas, are allayed. According to the Vinyl Institute, a trade association representing leading producers of the plastic, the market for US-produced PVC should grow by 9 percent this year, to 7.3 billion pounds (including exports). Although they expect growth to slow down to around 3 percent next year as new tax legislation and changing interest rates im pact construction, which accounts for over 60 percent of the total PVC market, the longrange projections for the market are opti mistic. Piping, draining and vent applications, which currently account for about 3 billion pounds of demand per year, should more than double in the next three to five years, says Ray Gottesman, executive director of the institute, as designer's and builders' percep tion of the plastic change. Similarly, demand for food-grade resin in packaging applications should reach almost 600 million pounds by 1988, he says. In a recent survey of 550 architects, builders and code officials throughout the country, most professionals praise the durability of the material and say they plan to use more of it in the future, particularly in electrical conduit applications. According to the study, sponsored by the institute, siding and plumbing pipe applica tions currently have the highest recognition levels among building professionals. Lower recognition levels were found for window, flooring and gutter uses. According to Mr. Gottesman, this represents a chal lenge to the industry to communicate the benefits of vinyl products more broadly. Controversy has surrounded the use of PVC in electrical wire and cable and plumb ing pipes since 1982, when the first Fire Tox icity Conference issued data on PVC's toxic ity in fire situations. This same year, a study conducted by James Montgomery consulting engineers in California showed that PVC plumbing pipe leached harmful chemicals into drinking wa ter. Not surprisingly, the Vinyl Institute was founded that year, to modify what producers feared were developing misconceptions about the plastic. Despite the fact that PVC has been fully approved by EPA and NSF for use in plumb ing and wiring applications, and that the three national model building codes univer sally approve its use in piping and electrical conduit, there has been a movement to block its use in plumbing pipe in California, where union plumbers filed a suit restricting its use in 1979. In 1982, they were granted a court order halting new approvals of PVC pipe. Makers of vinyl have long hoped that the elastic would fully replace metal in water Continued on Page 33 :rt^fri&#8,`I9tf6 CHEMICAL MARKETING REPORTER PVC Producers Continued from Page 9 pipe applications. Not only do they con tend that PVC is environmentally safer han copper, which leaches amounts of metal and lead from solder in excess of EPA limits, they say the plastic shows ower sedimentation and higher corro sion resistance, requires no welding, costs less than metal pipe and can be installed in little more than half the time needed for copper. California plumbers, citing the results of . the Montgomery study, allege that PVC leaches hazardous levels of trichloromethane and chloroform. They also claim that the organic solvent cement used to join the piping leaches unacceptable levels of MEK, cyclohexanone, THF and other organic compounds. Furthermore, they say, NIOSH has questioned the validity of the solvent ce ment labelling. According to Mr. Gottesman, the Mont gomery study contained many procedural in accuracies. For example, phthalate esters, used only in flexible PVC production, were found in the leachate, suggesting that flexible tubing, rather than the rigid PVC used in pipe, was used in the test. As far as the solvent cement issue is con cerned, he says, organic levels dissipate after eight months; a thorough flushing of the pipe before use will eliminate the problem. The California Housing and Community development, pressured by plumbers union groups, contracted additional studies of PVC >iping and recommended a complete Envi ronmental Impact Report. EIR STILL PENDING Four years later, the report is still not finished. As Mr. Gottesman explains, the first consulting firm hired to conduct the study, botched the procedure. Now HCD wants to conduct the test in conjunction with the Uni versity of California. Last year, the Vinyl Institute conducted a study in conjunction with McKesson Environ mental Services, using a "worst case" plastic pipe system with CPVC, and contrasting leachate levels with those of a traditional copper pipe system. Control of the project was turned over to the consultant, and results submitted this July showed no carcinogens leached from either the CPVC or the solvent cement, and only trace amounts of other organics, in the part-per-billion range. In contrast, the metal system leached po tentially hazardous amounts of copper and lead from solder. Other non-lead soldering materials such as arsenic were also found in the metal pipe leachate. Meanwhile, California plumbersare deter mined to fight use of PVC and other plastics. While plastics producers maintain that plumbers really fear the effects PVC will have on their revenues, as ease of installation leads to increased "do-it-youself" plumbing, the California Pipe Trades Council maintains '.hat public health is its primary concern. John Gorman, a representative for the group, questions the validity of the McKesson test, citing "lack of forthrightness" on the part of plastics producers in previous tests. In Leonardini versus Shell Oil Company, a case which came to trial in Sacramento last year, he says, it was found that fittings used to join polybutylene pipes were leaching trioxane, formaldehyde and other carcinogens. While the plumbing pipe controversy con tinues in California and the state reviews the McKesson tests, other states have fully ap proved its use in water pipe. Some controversy continues to surround PVC's use in electrical cable. The NEC had restricted its use to buildings of three stories and under. Recently, this restriction was re moved, a major victory for PVC producers. The National Institute of Building Sciences has been working to develop new material testing methods which may potentially help PVC, shifting the focus away from toxicity alone to factors equally important in a fire: flame spread and ignitability. Focusing on toxicity alone is too simplistic an approach, says Gene Brewer, president of NIBS. Although toxicity levels must be con sidered, he says, materials considered toxic continue to perform best in a fire. Ruling out potential toxicity destroys other properties which may be equally im portant in saving lives. Currently, Mr. Brewer says, the Institute is developing one standard evaluation procedure to be used by architects, contractors and interior design ers alike. The National Center for Fire Research and the National Bureau of Standards are close to completing a fire hazard computer model, evaluating not only toxicity but flame spread and other performance factors. This new approach, says Mr. Gottesman, can only have a positive impact on the vinyl market. Toxicity problems are not being ig nored, however. NIBS's Brewer says that material mixes are being evaluated to lower toxicity levels. Several polyolefin producers are also working on developing non-halogenated wire technology. Cross-linked polyethylene, which is cur rently being used with ATH in non-halo- genated electric cable, specified by the US Navy, has not yet had any sizeable impact on the market. Although Union Carbide Corporation has developed a line of polyethylene products which, it hopes, may eventually replace PVC in construction, Mr. Gottesman says that it has not yet penetrated the commercial build ing wire and cable market. Another remaining snag concerning PVC use in food packaging and bottles has been removed, as the FDA has approved the plas tic for food packaging applications (see p. 5). In 1974, vinyl producers first ran into prob lems when the FDA ruled that the plastic could not be used in liquor bottles. Once new processing techniques were developed, which remove all traces of VCM from food- grade packaging resin, vinyl makers reap plied to FDA for packaging approval. The comment period of the evaluation process ended in June, but, subsequently, en vironmental concerns were raised alleging that incineration of PVC would lead to in creased dioxin emission levels. Mr. Gottesman reports that several recent tests have shown that incinerator operating procedure, rather than PVC controls dioxin emission. Municipal garbage, he says, already emits n certain level of dioxin, most of it from paper, which is treated with chlorine. These tests, he says, prove conclusively that PVC adds only an insignificant amount of dioxin to the total. Although complete FDA approval is still pending, based on these findings, the outlook for the plastic in food applications is good, Gottesman asserts. In light of strong demand this year and months of depressed pricing earlier, prices for PVC have finally started to firm. An October price hike was fully successful, moving pipe grade prices to 30 cents per pound. Currently, producers are uniting be hind 1 to 2 cents per pound increases which took effect December 1. Shintech and Formosa were the first to move prices for the resin; since then, B.F. Goodrich, Air Products and Occidental have all posted December 1 increases. norm 11 f,9? 1-0 i..;pA OGOOU RPR MEDIA PLANNING f 8 6 --f 87 vCa\ A ^ to: Plant managers, communication contacts Interoffice Communication From: Date: Jim Rutledge September 25, 1986 subject: If--Needed Statement on AirEmissions This nif-needed,r statement has been approved for use in answering media inquiries on air emissions from your plant should the need arise. It contains specific reference information on the major chemicals made or used at Vista*s plants, along with approved responses to questions that would likely be encountered during press interviews. This updated and expanded statement supersedes the material included in the earlier **If-Needed document on Air Emis sions,1* dated Feb. 28, 1986. Please destroy all copies of that document and replace them with the present statement. Please note that while the actual and permitted emission totals included in this statement are correct as shown, a few of the numbers have "caveats" associated with them--for example, some of the some of the permitted plant emissions are for "new equipment1* only. In keeping with the general nature of this document, however, we have chosen not to in clude this kind of detailed information because it might only cloud the issue for the press. If you have any questions regarding the attached material or need assistance in responding to a media inquiry, please let me know. Please also continue to keep me advised of all lo cal press calls or contacts. Thanks for your help. cc: REL, RTF, JAD, TGG, WLM, DAK, MSR, JCB, DLM ,PA 000oU-'94 If-Needed Statement AIR EMISSIONS All Vista plant locations Date approved for use: September 18# 1986 Use the following material only in response to specific questions from the media: Does Vista use or manufacture hazardous chemicals? Vista Chemical uses and manufactures a number of chemicals in volumes large enough to be of concern in the event of an emergency. However, these chemicals are strictly controlled and monitored. Our plants have been carefully designed and built to handle them safely. Our employees who work with these chemicals have received detailed special training. All of these precautions make an accident which could injure a member ofthe public extremely unlikely. Do you routinely release any of these chemicals to the atmosphere? Yes. Air emissions from our manufacturing processes are regulated by state and federal environmental agencies. These agencies have issued permits to Vista regulating our air emissions. Vista currently operates under 43 different environmental permits which specify allowable air emissions for chemicals ranging from sulfur dioxide and nitrogen oxide, which come from fuel burning processes such as steam generation, to hydrocarbon products. In addition, two compounds produced and used extensively by Vista--benzene and vinyl chloride monomer--are stringently regulated under the Clean Air Act as hazardous air pollutants. The amount of permitted emissions is generally determined by health effects data and by best available control technologies for our manufacturing processes. How can you justify releasing these hazardous chemicals, some of which are known cancer-causers, into the atmosphere on a routine basis? Vista Chemical and the regulating agencies believe that the permitted quantities will not harm the employees who work in our plants or members of the public and the environment nearby. The chemicals we use, manufacture or which come from our fuel-burning processes are well understood, common chemicals which have been used for years throughout UFA 000011595 Air Emissions Page 2 (* the industry and which have been studied at length. The effects of exposure to them are well known. Safety and health precautions for properly handling them have been developed, installed and regularly tested at our plants. Our plants' emissions are controlled so that the concentration ofcancer-suspect chemicals in the air in the plants is as low as feasible, typically less than one part per million. With those concentrations in our plants, we know that concentrations in the air further away from our plants are even lower. Chemicals which have been shown to cause cancer have done so only at relatively high concentrations over long periods of time. Based on the large amount of scientific data available from studies done over the past two decades, low level or short term exposure to these chemicals does not create a hazard. We believe there is a more than adequate margin of safety for our employees and the public. The amounts of these chemicals routinely released have been greatly reduced over the years, because it makes good business sense and because of more rigorous governmental regulations. We've spent more than $3.2 million in the past five years just to protect the air around all ourplants. Why is it necessary to release chemicals to the atmosphere? Why don't you just make your plants leak-proof? It's not possible to make a chemical plant 100 percent leak-proof, or to burn fuel without emitting some pollutants. We employ the best available technology and operating procedures to keep emissions at very low levels which are safe for employees and the neighbors of our plants. Besides the routine emissions to the atmosphere, do you have accidental releases? Very infrequently. We must immediately report these releases in accordance with the appropriate state or federal regulations. No accidental release of a chemical from a Vista Chemical plant has ever caused a death or serious injury to a member of the public. We've studied the causes of these releases and have made engineering or operational changes to prevent their recurrence. gpA 0000U59 Air Emissions Page 3 A Why haven't you reported these releases to people in the communities surrounding your plants? Because the releases have not been of a quantity which would cause injury to the public, and an evacuation of the community has never been required as a result of the releases. Could such an accidental release lead to a Bhopal-type accident at one of your plants? Because the chemicals we handle are not as toxic as methyl isocyanate (MIC), and because of the strict controls and procedures we use in our manufacturing processes, we believe that that the possibility of an incident similar to that which happened in Bhopal is very remote. Our plants are well designed and are maintained, inspected and operated by well trained, experienced personnel. In the event of a large gas release, a catastrophic loss of life (such as occurred in Bhopal) is highly unlikely because we do not have any materials as toxic as methyl isocyanate. In addition, we have emergency procedures for dealing with gas leaks if one were to occur and we are working with local authorities to improve procedures for protecting the public in the event of an emergency. Have you made any changes as a result of Bhopal? Due to the extent of the tragedy at Bhopal, we instituted a formal program to reassess our existing safety systems and emergency procedures. This assessment included a study ofmaterials present in the plant, our handling, processing and storage of those materials, employee training and emergency response procedures. We wanted to be certain that we are operating our plants in a manner that is safe and which will prevent any tragedy from occurring in our plant communities. We've also broadened our studies to include the surrounding communities. Our work at our Lake Charles plants is a good example. We have joined together with other local industry members as well as medical, governmental, police and fire agencies in a committee to improve our communication and understanding. That committee is examining such topics as availability of emergency medical care, a direct public warning system and evacuation routes which might be needed in the unlikely event of a major catastrophe. UPA 000011597 Air Emissions Page 4 r * What sort of warning system or evacuation procedure do you have for the public? Current procedures call for alerting and providing assistance to local authorities who have the authority to handle evacuation in the event of a disaster. At our Lake Charles complex, we are connected by special phone lines with other major plants and governmental agencies in the area, so that we can warn or be warned of emergencies. More direct methods of notifying people in the surround communities are being studied. Which chemicals listed by the EPA, or otherwise classified as acutely toxic, does Vista Chemical use or manufacture? 1. Chlorine is used as a feedstock at our Lake Charles VCM Plant and the Baltimore LAB (linear alkylbenzene) Plant. 2. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant 3. Hydrogen fluoride is used as a catalyst at our Lake Charles LAB Plant 4. Sulfur trioxide is used as a feedstock at our Hammond Premium Sulfonation Plant. 5. Hydrogen chloride is used as a feedstock at our Lake Charles Chemical Plant and at our Lake Charles VCM (vinyl chloride monomer) Plant. Muriatic acid, its liquid form, is manufactured at our Baltimore LAB Plant; a small amount is also produced in our VCM Plant incinerator unit. In addition, we use or manufacture much smaller quantities of: 1. Sulfur dioxide 2. Nitric acid 3. Sulfuric acid 4. Isopropanol (isopropyl alcohol) 5. Methanol (methyl alcohol) [See reference section for more detail.] Which of the chemicals you use or manufacture are volatile organic compounds? 1. Ethylene dichloride (EDC) and 2. Vinyl chloride monomer (VCM) are made at our Lake Charles VCM Plant. VCM is also used as a feedstock at our Aberdeen and Oklahoma City PVC plants. MPA 000011598 Air Emissions o Page 5 3. Benzene is a feedstock at our Baltimore and Lake Charles LAB plants, and a - byproduct containing benzene is manufactured at our Lake Charles Chemical Plant. 4. Methyl chloride is manufactured at our Lake Charles Chemical Plant. 5. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant. 6. Ethylene is manufactured at our Lake Charles Chemical Plant and is used as a feedstock at that plant and at the Lake Charles VCM Plant. 7. Butadiene is manufactured as a byproduct at our Lake Charles Chemical Plant. 8. Propylene is manufactured as a byproduct at our Lake Charles Chemical Plant. 9. Various light alcohols, such as butanol, are manufactured at our Lake Charles Chemical Plant. In addition, we use or manufacture much smaller quantities of: 1. Methanol (methyl alcohol) 2. Toluene 3. Xylene 4. Chloroform 5. Isopropanol (isopropyl alcohol) (See reference section for more detail.] What do you do about tiny leaks, ones that are so small that even people working in the plant would not notice? We have a system offixed point monitors in our plants to detect quantities of the of the most hazardous VOCs in the air as small as one part per million, or less. When these chemicals are detected, an operator is notified. Then, employees using portable detection equipment can pinpoint the leak and repair it. What chemicals are produced by your fuel-burning processes? 1. Particulates are emitted at all ofour plants, except Hammond. 2. Sulfur oxides (SOx) is emitted by all of our plants. 3. Nitrogen oxide (NOx) is emitted by all ofour plants, except Hammond. 4. Carbon monoxide is emitted by all of our plants, except Hammond. Reference UPA 0000M5 Air Emissions -Tonnages of actual emissions Chemical Actual emissions (tons per year) Nitrogen oxides (NOx) Aberdeen 49.8 Baltimore LCCP LCLAB LCVCM OKC 109.4 854 54.6 204 16.51 TOTAL 1,288.31 Hydrocarbons Aberdeen 5.7 Baltimore Benzene Toluene/xylene Chlorinated Others Baltimore, total 14.9 11.3 22.1 1.4 14.9 49.7 LCCP Benzene 1,3-Butadiene Ethylene oxide Propylene Toluene Others LCCP, total 8 1 4 2 7 934 956 LCLAB Benzene Other LCLAB, total 1.58 5.43 7.01 LCVCM Ethylene dichloride Chlorinated, other than VCM Other LCVCM, total 0.82 0.07 12.82 13.71 Oklahoma City 0.34 TOTAL 1,026.76 Actual emissions, by tonnage 1 Permitted emissions (tons per year) Basis unregulated 3522.5 83.60 198.5 22.0 3,826.60 state regs. state permit fed. permit state permit state regs. - -- -- -- -- -- 149.7 total hydrocarbons -- -- -- -- fed. permit -- -- -- -- 1132 1132 -- -- - - -- state permit - -- -- 8.46 total combined hydrocarbons -- -- fed. permit 1.06 state permit 0.09 16.65 17.80 state permit state permit - - 1,307.96 - VOC = volatile organiccompound. UpA 000011600 Air Emissions Actual emissions, by tonnage 2 Chemical Actual emissions (tons per year) Sulfur oxides (SOx) Aberdeen Baltimore Hammond LCCP LCLAB LCVCM OKC TOTAL 0.2 259.2 0.73 . 51 0.43 0.438 ==0.07 312.01 Permitted emissions (tons per year) Basis 1752 unregulated 12 5673.7 16.28 12.88 22 7,488.86 state regs. state regs. state regs. state permit fed. permit state rees. - Carbon Monoxide Aberdeen Baltimore LCCP LCLAB LCVCM OKC TOTAL 5.7 9.1 186 0.15 3 1.87 205.82 91.25 326.8 17.3 9.39 unregulated 444.74 state regs. state permit fed. permit state permit state regs. - Particulates Aberdeen Baltimore LCCP LCLAB LCVCM OKC TOTAL 2.3 20.3 98 6.7 62.4 23.3 213.0 157 - 1030.6 14.39 79.65 386.6 1,668.24 state regs. state regs. state permit fed. permit state permit state regs. - Vinyl chloride monomer Aberdeen OKC LCVCM 40 31.5 4.23 TOTAL 75.73 97 53.04 11.09 161.13 fed. reg. fed. reg. state, fed. regs. & state permit - Hydrogen chloride ( HCI or muriatic acid) LCCP LCVCM OKC 0 12 0.043 TOTAL 12.043 3.6 12.41 -- 16.01 state permit state permit - H2S04mist Hammond 0.01 2.6 state regs. A VOC ss volatileorganiccompound. UP'fit OOOOi i.601 Air Emissions Combustion products *1 Reference -Combustion products Particulates Plant Aberdeen Baltimore LCCP LCLAB LCVCM OKC TOTAL Actual emissions based on natural gas (tons per year) 2.3 20.3 98 6.7 63.42 __________OJS__________ 191.52 Permitted emissions (tons per year) Basis 157 state regs. state regs. 1030.6 14.39 79.65 38.5 state permit fed. permit state permit state regs. 1,320.14 Primarily carbon particles from incomplete fuel combustion, but also includes ash, sand or dirt. NOTE: The permitted numbers listed above are for fuel oil. The actual emissions are from natural gas. Sulfur oxides SOx Plant Actual emissions (tons per year) Aberdeen Baltimore Hammond LCCP LCLAB LCVCM OKC___________ 0.2 259.2 0.73 51 .43 0.38 _________ 0.07 TOTAL 311.83 Permitted emissions (tons per year) Basis 1752 unregulated 12 5673.7 16.28 12.88 22 state regs. state regs. state regs. state permit fed. permit state permit state regs. 7,488.86 Major component is sulfur dioxide. Other components may include sulfur trioxide. Sulfur dioxide (SO2) is a colorless, nonflammable gas with a strong suffocating odor. It dissolves in water to form weak but corrosive sulfurous acid. This mist is odorless, but is very irritating at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. EPA402 Sulfur trioxide (SO3) is a colorless, fuming liquid that reacts with moisture in the air to form a visible sulfuric acid mist. This mist is odorless, but is very irritating at low A VOC = volatile organic compound. EPA 402 = chemical classified by EPA as one which could produce acute adverse health if accidentally released. Air Emissions Combustion products 2 A concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. EPA 402 Nitrogen oxides (NOx) Plant Actual emissions (tons per year) Aberdeen Baltimore LCCP LCLAB LCVCM QKC 49.8 109.4 854 54.6 204 16.51 TOTAL 1,288.31 Permitted emissions (tons per year) Basis unregulated state regs. 3522.5 state permit 83.60 194.7 fed. permit statepermit 22.0________ state regs. 3,822.80 Primarily nitrogen dioxide, a yellow-brown fuming liquid or a reddish-brown gas with a pungent acrid odor at detectable levels. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. Carbon monoxide Plant Aberdeen Baltimore LCCP LCLAB LCVCM OKC________________ TOTAL Actual emissions (tons per year) 5.7 9.1 186 0.15 8.5 ________1.87 211.32 Permitted emissions (tons per year) Basis 91.25 326.8 17.3 9.39 unregulated 444.74 state regs. state permit fed. permit state permit state regs. Carbon monoxide (CO) is a colorless, odorless gas. The toxic effect of high concentrations is oxygen starvation of the body's cells. CO effects are considered to be reversible as long as brain damage or heart failure has not occurred. yp& 00001160a VOC a volatile organic compound. EPA 402 = chemical classified by EPA as one which could produce acute adverse health if accidentally released. Air Emissions Use or manufacture 1 Reference --Major use or manufacture Chlorine Plant LCVCM Actual emissions (tons per year) 9.6 Permitted emissions (tons per year) Basis Chlorine is a major feedstock at our Lake Charles VCM Plant, arriving by pipeline or rail tank car. We use it to make vinyl chloride monomer, the major ingredient in polyvinyl chloride (PVC), a plastic with hundreds of uses from vinyl siding and food packaging to plastic pipe and record albums. Chlorine is also used as a feedstock at our Baltimore LAB (linear alkylbenzene) Plant to make a major ingredient in industrial and household cleaning products, such as detergents. Its most common usage is in water treatment plants. Chlorine is a heavy, greenish-yellow gas at normal temperatures and has a pungent, irritating odor which is detectable at very low levels. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high concentrations can damage tissues in the respiratory system resulting in breathing difficulties. Severe exposures could be fatal. Chlorine is also present at most of our other plants in cylinder quantities for water treatment purposes. E PA 402 Hydrogen fluoride (HF) Plant Actual emissions (tons per year) LCLAB 0 Permitted emissions (tons per year) Basis 0- Hydrogen fluoride is used as a catalyst at our Lake Charles LAB Plant. It arrives at the plant by truck. We use it to make the chief active ingredient in such products as laundry detergents and dishwashing liquids. It is a colorless fuming liquid which rapidly vaporizes in the atmosphere to a gas, which reacts with moisture in the air to form a visible cloud. HF is very irritating to the skin, eyes and respiratory tract at low concentrations. Exposure to high concentration in air can burn the skin and damage lung tissue. Lung damage resulting from severe exposures could be fatal. EPA 402 A UPA 000G11604 VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 2 Sulfur trioxide (SO3) Plant Actual emissions (tons per year) Hammond 0 Permitted emissions (tons per year) Basis 0- Sulfur trioxide is a major feedstock at our Hammond Premium Sulfonation Plant. We use it to make the active ingredients in such products as laundry detergents and dishwashing liquids. It comes to our plant through a pipeline from the Stauffer Chemical plant adjacent to our property. Sulfur trioxide is a colorless, fuming liquid that reacts with moisture in the air to form a visible sulfuric acid mist. This mist is odorless, but is very irritating at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. EPA 402 Ethylene Oxide (EO) Plant Actual emissions (tons per year) LCCP 4 Permitted emissions (tons per year) Basis - Ethylene oxide is a feedstock in the ethoxylation unit at the Lake Charles Chemical Plant. We use it to make ingredients which have a multitude of uses, including cleaning and personal care products. It is shipped to our plant by rail tank car. Ethylene oxide is a highly flammable and reactive gas at room temperature. We handle it under pressure in a liquid form. At high concentrations, it has an ether like pungent odor and is irritating to the eyes, nose and throat. Exposure to extremely high concentrations may result in lung injury and accumulation of fluid in the lungs and death. It is regulated as a cancer-causing agent. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. EPA 402, VOC 'v`PA 00001 160 VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 3 Vinyl chloride monomer (VCM) Plant Actual emissions (tons per year) Permitted emissions (tons per year) Basis Aberdeen 40 97 fed. regs. OKC 31.5 53.04 fed. regs. LCVCM 4.23 11.09 state, fed. regs ______________________________________________________________________ & state permit TOTAL 75.73 161.13 Vinyl chloride monomer is produced at our Lake Charles VCM Plant, and is a key feedstock at our Aberdeen and Oklahoma City PVC plants. VCM is shipped from Lake Charles and arrives at Aberdeen and Oklahoma City by rail tank car. We use it to make polyvinyl chloride (PVC), a plastic with hundreds of uses from vinyl siding and food packaging to plastic pipe and record albums. Vinyl chloride monomer (VCM) is a colorless gas and a liquid under pressure. Vapors can form flammable mixtures in air. Burning VCM generates hydrogen chloride (HC1), a strongly irritating gas which, in high concentrations, can damage tissues in the respiratory system. High levels of exposure to VCM over long periods of time can cause cancer in humans. VCM is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC Benzene Plant Baltimore LCCP LCLAB TOTAL Actual emissions tons per year Permitted emissions (tons per year) Basis 11.3 149.7 total VOCs State regs. 8- 1.58 8.46 total ______________________________ hydrocarbons fed, permit 20.88 Benzene is a key feedstock at our Baltimore and Lake Charles LAB plants. We use it to make LAB, the active ingredient in many household and industrial detergents and other cleaning products. It arrives at Baltimore by barge and tank truck, and at Lake Charles by rail tank car and tank truck. In addition, we manufacture a relatively small quantity of benzene in our ethylene unit at the Lake Charles Chemical Plant. Benzene is a clear, colorless liquid with a aromatic odor. It can form explosive and flammable mixtures with air. Overexposure can cause dizziness, nausea, vomiting, unconsciousness. Severe exposure for 15 to 30 minutes may be fatal. High levels of exposure over long periods of time are believed to cause cancer in humans. VOC up* VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. A Air Emissions Use or manufacture 4 Methyl chloride Plant LCCP Actual emissions (tons per year) 0 Permitted emissions (tons per year) Basis 98.9 state permit Methyl chloride is made at our Lake Charles Chemical Plant. It is used by our customers to make products such as synthetic rubber, silicones and refrigerants. It is shipped from our plant by rail tank car. It is a colorless liquid or gas with a faint, ether-like odor and sweet taste. Severe exposures may result in narcotic effects, such as dizziness, and affect other body systems, such as the kidneys, liver and blood. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC Ethylene dichloride Plant Actual emissions (tons per year) LCVCM 0.86 Permitted emissions (tons per year) Basis 1.06 state permit Ethylene dichloride (EDC) is manufactured at our Lake Charles VCM (vinyl chloride monomer) plant. We use it to make VCM, the key ingredient in a common plastic, PVC (polyvinyl chloride). We use it on site and do not routinely ship any outside the plant. After it is made, it is held in tanks until it is needed in the VCM manufacturing process. It is a colorless, oily liquid with a chloroform-like odor. High exposure can cause intoxication, nausea, vomiting and depression of the central nervous system. Severe exposures may affect other body systems such as the kidneys and liver. The National Institute for Occupational Safety and Health has recommended that it be handled in the workplace as if it were a carcinogen in man. voc Hydrogen chloride (muriatic acid) Plant Actual emissions (tons per year) LCCP 0 LCVCM 12 OKC_________________________ 0.043 TOTAL 12.043 Permitted emissions (tons per year) Basis 3.6 12.41 state permit state permit 16.01 Hydrogen chloride (HC1) is used at our Lake Charles Chemical Plant to manufacture methyl chloride, an ingredient in such products as synthetic rubber, silicones and re- v'FA 00001 1607 VOC = volatile organic compound. EPA 402 = a chemical classified by the ERA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 5 frigerants. Mixed with water, it forms muriatic acid. The Lake Charles VCM Plant uses HC1 in the production ofvinyl chloride monomer (VCM), and also produces med ium strength (15-22%) muriatic acid in its incinerator unit. Muriatic acid is manu factured at our Baltimore LAB Plant. We ship it from the plant in rubber-lined tank cars. Muriatic acid is used in processing metals and gelatin and making pharmaceuticals and chemicals to develop photographs. Hydrogen chloride is a colorless gas, but reacts with moisture in the air to form a visible cloud. It has an irritating, pungent odor and is detectable at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High exposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal. Ethylene Plant LCCP LCVCM Actual emissions tons per year Not measured specifically934 total hydrocarbons Not measured specifically-- 12.82 total hydrocarbons 0.07 chlor. hydrocarbons Permitted emissions (tons per vear) Basis Not permitted specifically1,132.1 total hydrocarbons Not permitted specifically16.65 total hydrocarbons 0.09 chlor. hydrocarbons state permit state permit Ethylene is manufactured at our Lake Charles Chemical Plant and is used as a feedstock at that plant to make industrial alcohols and at the Lake Charles VCM Plant to make VCM, the major ingredient in a common plastic, PVC (polyvinyl chloride). We transfer it by pipeline and do not routinely ship it out of the Lake Charles complex. It is a colorless flammable gas with a sweet odor at high concentrations. It is a simple asphyxiant, meaning that it displaces oxygen in the air. Severe exposure may result in narcotic effects, such as dizziness, progressing to unconsciousness due to lack of oxygen. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC up, 00001160b VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 6 A Alcohols, light Plant LCCP Actual emissions (tons per year) Not measured specifically934 total hydrocarbons Permitted emissions (tons per year) Basis Not permitted specifically1,132.1 total hydrocarbons state permit Light alcohols, including butanol, ethanol and hexanol are manufactured at our Lake Charles Chemical Plant. We ship them by tank cars, tank trucks and in drums They are used to make various industrial and consumer products including plasticizers (chemicals which make plastics flexible). These are colorless flammable liquids. Exposure to high vapor concentrations may cause irritation to the eyes, nose and throat. Severe exposures will result in narcotic effects, such as dizziness, leading to unconsciousness. VOC Propylene Plant LCCP Actual emissions (tons per year) 2 Permitted emissions (tons per year) Basis - Propylene is manufactured at our Lake Charles Chemical Plant. We ship it by railcar to other chemical manufacturers who use it to make a variety of products, including plastics. It is a colorless flammable gas with a sweet odor at high concentrations. It is a simple asphyxiant, meaning that it displaces oxygen in the air. Severe exposure may result in narcotic effects, such as dizziness, progressing to unconsciousness due to lack ofoxygen. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC 1,3 Butadiene Plant LCCP Actual emissions (tons per year) 1 Permitted emissions (tons per year) Basis -- Butadiene is manufactured at our Lake Charles Chemical Plant. We ship it by railcar to other chemical manufacturers who make a variety ofproducts, including synthetic rubber. It is a colorless flammable gas with an aromatic odor. Inhalation of high concentrations is irritating to the eyes, nose and throat. Severe exposures may result in narcotic effects, such as dizziness, leading to unconsciousness. These UFA 00001160 VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 7 A effects could potentially be fatal. Exposure to high concentrations over long periods of time has been shown to cause tumors in laboratory animals. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC Sulfur dioxide (SO2) Plant Actual emissions (tons per year) Hammond 0.73 Permitted emissions (tons per year) Basis 12 state permit Sulfur dioxide (SO2) is a byproduct produced at our Hammond Premium Sulfonation Plant, where we make the active ingredients in such products as laundry detergents and dishwashing liquids. We send the sulfur dioxide through a pipeline to the Stauffer Chemical plant adjacent to our property. It is a colorless, nonflammable gas with a strong suffocating odor. It dissolves in water to form weak but corrosive sulfurous acid. This mist is odorless, but is very irritating at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. EPA 402 Methanol (methyl alcohol) We use methanol as a feedstock at the Lake Charles Chemical Plant to make methyl chloride, an ingredient in synthetic rubber, silicones and refrigerants. It is brought to our plant by barge. It is a clear colorless flammable liquid with an alcohol odor. Overexposure can result in dizziness, visual impairment, nausea, and irritation of the eyes nose and throat. Severe exposures could result in unconsciousness and respiratory failure. EPA 402, VOC Nitric acid It is used in small quantities in laboratories or as a process additive at several of our plants. It is a fuming colorless or yellow corrosive liquid. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High xposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal. EPA 402 MPA 00011610 VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. Air Emissions Use or manufacture 8 Sulfuric acid Itis used in small quantities in laboratories or as a process additive or processing aid at several ofour plants. It is a dense, oily, colorless, odorless liquid that is strongly corrosive and nonflammable. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High exposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal. EPA 402 Toluene Xylene Plant Baltimore LCCP TOTAL Actual emissions (tons per year) 22.1 7(toluene only) 29.1 Permitted emissions (tons per year) Basis 149.7 total VOCs state permit -- Toluene and xylene are used as feedstocks at our Baltimore LAB Plant to make ingredients for industrial and household detergents. They are clear colorless flammable liquids with an aromatic odor. Exposure to high concentrations can cause irritation of the eyes, nose and throat. Severe exposures may result in unconsciousness and could be fatal. These chemicals are volatile and disperse quickly in the environment to low concentrations. VOC Chloroform It is inadvertently manufactured in small quantities as a byproduct at our Lake Charles VCM Plant and is used in small quantities as a laboratory solvent in several of our plants. It is a clear, nonflammable sweet smelling liquid. High exposures to chloroform may cause headache, dizziness and unconsciousness. Severe exposures may result in kidney and liver damage. EPA 402 Isopropanol (isopropyl alcohol) It is used in laboratory quantities at several of our plants. A clear colorless flammable liquid with an alcohol odor. Exposure to high vapor concentrations may cause irritation to the eyes, nose and throat. Severe exposures will result in narcotic effects, such as dizziness, leading to unconsciousness. E PA 402, VOC UFA 00001 VOC = volatile organic compound. EPA 402 = a chemical classified by the EPA as one which could produce acute adverse health effects if accidentally released. I If-Needed Statement AIR EMISSIONS All Vista plant locations Date approved for use: [ Draft as of 5/13/86| IMS'* Use the following material only in response to spedfic questions from the media: Does Vista use or manufacture hazardous chemicals? Vista Chemical uses and manufactures a number of chemicals in volumes large enough to be of concern in the event of an emergency. However, these chemicals are strictly controlled and monitored. Our plants have been carefully designed and built to handle them safely. Our employees who work with these chemicals have received detailed special training. All of these precautions make an accident which could injure a member of the public extremely unlikely. Do you routinely release any of these chemicals to the atmosphere? Yes. Air emissions from our manufacturing processes are regulated by state and federal environmental agencies. These agencies have issued permits to Vista regulating our air emissions. Vista currently operates under 43 different environmental permits which specify allowable air emissions for chemicals ranging from sulfur dioxide and nitrogen oxide, which come from fuel burning processes such as steam generation, to hydrocarbon products. In addition, two compounds produced and used extensively by Vista-benzene and vinyl chloride monomer-are stringently regulated under the Clean Air Act as hazardous air pollutants. The amount of permitted emissions is generally determined by health effects data and by best available control technologies for our manufacturing processes. How can you justify releasing these hazardous chemicals, some which are known cancer-causers, into the atmosphere on a routine basis? Vista Chemical and the regulating agencies believe that the permitted quantities will not harm the employees who work in our plants or members of the public and the environment nearby. VPA 000011412 Air Emissions Page 2 The chemicals we use, manufacture or which come from our fuel-burning processes are well understood, common chemicals which have been used for years throughout the industry and which have been studied at length. The effects of exposure to them are well known. Safety and health precautions for properly handling them have been developed, installed and regularly tested at our plants. Our plants' emissions are controlled so that the concentration of cancer-suspect chemicals in the air in the plants is as low as feasible, typically less than one part per million. With those concentrations in our plants, we know the concentrations in the air further away from our plants are even lower. Chemicals which have been shown to cause cancer have done so only at relatively high concentrations over long periods of time. Based on the large amount of scientific data available from studies done over the past two decades, low level or short term exposure to these chemicals does not create a hazard. We believe there is a more than adequate margin ofsafety for our employees and the public. The amounts of these chemicals routinely released have been greatly reduced over the years, because it makes good business sense and because of more rigorous governmental regulations. We've spent more than $3.2 million in the past five years just to protect the air around all our plants. Why is it necessary to release chemicals to the atmosphere? Why don't you just make your plants leak-proof? It's not possible to make a chemical plant 100 percent leakproof, or to burn fuel without emitting some pollutants. We employ the best available technology and operating procedures to keep emissions at very low levels which are safe for employees and the neighbors ofour plants. Besides the routine emissions to the atmosphere, do you have accidental releases? Very infrequently. We must immediately report these releases in accordance with the appropriate state or federal regulations. No accidental release of a chemical from a Vista Chemical plant has ever caused a death or serious injury to a member of the public. We've studied the causes of these releases and have made engineering or operational changes to prevent their recurrence. 'FA 000 Air Emissions 4 Page 3 0 Why haven't you reported these releases to people in the communities surrounding your plants? Because the releases have not been of a quantity which would cause injury to the public, and an evacuation of the community has never been required as a result of the releases. Could such an accidental release lead to a Bhopal-type accident at one of your plants? Because the chemicals we handle are not as toxic as methyl isocyanate (MIC), and because of the strict controls and procedures we use in our manufacturing processes, we believe that that the possibility of an incident similar to that which happened in Bhopal is very remote. Our plants are well-designed and are maintained, inspected and operated by well-trained, experienced personnel. In the event of a large gas release, a catastrophic loss of life (such as occurred in Bhopal) is highly unlikely because we do not have any materials as toxic as methyl isocyanate. In addition, we have emergency procedures for dealing with gas leaks if one were to occur and we are working with local authorities to improve procedures for protecting the public in the event of an emergency. Have you made any changes as a result of Bhopal? Due to the extent of the tragedy at Bhopal, we instituted a formal program to reassess our existing safety systems and emergency procedures. This assessment included a study of materials present in the plant, our handling, processing and storage of those materials, employee training and emergency response procedures. We wanted to be certain that we are operating our plants in a manner that is safe and which will prevent any tragedy from occurring in our plant communities. We've also broadened our studies to include the surrounding communities. Our work at our Lake Charles plants is a good example. We have joined together with other local industry members as well as medical, governmental, police and fire agencies in a committee to improve our communication and understanding. That committee is examining such topics as availability of emergency medical care, a UFA GOOD!1614 Air Emissions Page 4 direct public warning system and evacuation routes which might be needed in the unlikely event of a major catastrophe. What sort of warning system or evacuation procedure do you have for the public? Current procedures call for alerting and providing assistance to local authorities who have the authority to handle evacuation in the event of a disaster. At our Lake Charles complex, we are connected by special phones with other major plants and governmental agencies in the area, so that we can warn or be warned of emergencies. More direct methods of notifying people in the surround communities are being studied. Which chemicals listed by the EPA, or otherwise classified as acutely toxic, does Vista Chemical use or manufacture? 1. Chlorine is used as a feedstock at our Lake Charles VCM Plant and the Baltimore, Maryland, LAB (linear alkylbenzene) Plant. 2. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant 3. Hydrogen fluoride is used as a catalyst at our Lake Charles LAB Plant 4. Sulfur trioxide is used as a feedstock at our Hammond, Indiana, Premium Sulfonation Plant. 5. Hydrogen chloride is used as a feedstock at our Lake Charles Chemical Plant and at our Lake Charles VCM (vinyl chloride monomer) Plant. Muriatic acid, its liquid form, is manufactured at our Baltimore, Maryland, LAB (linear alkylben zene) Plant; a small amount is also produced in our VCM Plant incinerator unit. In addition, we use or manufacture much smaller quantities of: 1. Sulfur dioxide 2. Nitricacid 3. Sulfuric acid 4. Isopropanol (Isopropyl alcohol) 5. Methanol (methyl alcohol) [See reference section for more detail.] C>* * JU. MPA 0000 1 1,515 (j 1 A-- Air Emissions Page 5 (A Which of the chemicals you use or manufacture are volatile organic compounds? 1. Ethylene dichloride (EDC) and 2. Vinyl chloride monomer (VCM) are made at our Lake Charles VCM Plant. VCM is also used as a feedstock at our Aberdeen, Mississippi, and Oklahoma City, Oklahoma, PVC plants. 3. Benzene is a feedstock at our Baltimore, Maryland, and Lake Charles LAB (linear alkylbenzene) plants, and a byproduct containing benzene is manufactured at our Lake Charles Chemical Plant. 4. Methyl chloride is manufactured at our Lake Charles Chemical Plant. 5. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant. 6. Ethylene is manufactured at our Lake Charles Chemical Plant and is used as a feedstock at that plant and at the Lake Charles VCM Plant. 7. Butadiene is manufactured as a byproduct at our Lake Charles Chemical Plant. 8. Propylene is manufactured as a byproduct at our Lake Charles Chemical Plant. 9. Various light alcohols, such as butanol, are manufactured at our Lake Charles Chemical Plant. In addition, we use or manufacture much smaller quantities cf: 1. Methanol (methyl alcohol) 2. Toluene 3. Xylene 4. Chloroform ee reference section for more detail.] my IeaksTones that are so small that even people working in the plant would not notice? We have a system of fixed point monitors in our plants to detect quantities of the of the most hazardous VOCs in the air as small as one part per million, or less. When these chemicals are detected, an operator is notified. Then, employees using portable detection equipment can pinpoint the leak and repair it. `PA 000011616 Air Emissions Page 6 What chemicals are produced by your fuel-burning processes? 1. Particulates are emitted at all of our plants, except Hammond. 2. Sulfur oxides 3. Nitrogen oxide isjemitted by all seven ofour plants. i^mitted by all of our plants, except Hammoiid* 4. Carbon monoxide is emitted by all ofour plants, except Hammond. 0X /V ox . y r;;' ~fcrtr gpA 000011617