Document 2MQ7L32mLVJYOBEXnZbYEgja
CHECK`.1ST
neshaps inspection for vinyl chloride emissions compliance
Inspection Date April 9, 1984 Tnspector's Name Sved Molnuddin
GENERAL
1* Finn's name Tenneco Polymers, Inc._________A_c__c_o__unt No. HG 0713 S
2* Firm's address
Boy 849 Pasadena, Texas 775QX
3? Process designation/product identification (check one or more):
EDC: oxychlorination
balanced
N.A.
VCM: hydrochlorination, dehydrochlorination N.A.
PVC: @ suspension
Q dispersion Q latex
N.A.
bulk
Q solution
copolymer___________
4. Rated and average annual reactor/cracking capacity EDC: Design* ; Normal Max*; Actual_
VCM: Design
; Normal Maxt; Actual_
PVC: Design* 750 mm lbs/yr; Normal Max* 750mm lbs^yfctual 581 mm. lbs/yr
LEAK DETECTION MONITORING SYSTEM
5. Permanent leak detection monitoring system [61.65(8)(i)J
*
-a) Total number of points monitored: 90_______________ b) Number of measuring instruments: 6 ; Type(s) Areas c) Time interval to cycle &11 points: 15 minutes d) Definition of a Leak: 25 PPM two leafrs in a row e) Lower detection limit (LDL) of instrument Less than 1 PPM f) Measurement sequence:Q unchanging program controlled g) Data reduction (check one or more) none 3 hourly 0 shift Q daily Q weekly EJ monthly 0 other (specify)_________________________
* Data may be available from records on file at EPA Regional Offices.
65 . TEN 2966
6. Calibration of leak detection monitoring system [61.65(8)(111)]:
a) List Instnments and data from monitor points which were tested for calibration. (Attach sheets If more space Is required.)
Date & Time
Location In Plant
Every day
Several
Instrum. Iden.
Cal. VCM Instrum. VCM Percent Action
Concen.
Concen. Deviation Required
Areas A Areas B Areas C
5 to 250PPM
5 to. 25 PPM
b) Calibration method used (check one or more)
D None
0 Paragraph 61.65(8)(Hi)(A) - Test Method 106 - 5.2.1, 5.2.3 Paragraph 61.65(8)(i11)(B) Other________________________________________________________________
STACK EMISSION MONITORING SYSTEM
7* Emission (i.e., stack) monitoring system
a) List emission (i.e., stack) sources
Location in
Plant
Ducted Processes
Continuous or Sampling,
Other
Incineratox All
emissions
VCM Vents
and waste gases
Continuous
Number of Monitoring
POlrtts
one
ii
b) Lower Detection Limit (LDL) of Instrument _ Less than 1
66 TEN 2967
8. Calbration of emission monitoring system:
a) List instruments and data from monitor points which were tested for calibration.
Date & Time
Location in Plant
Instrum. Cal. VCM Instrum. VCM Percent Action
Iden.
Concen.
Concen. Deviation Required
* *
*
PORTABLE INSTRUMENT
9. Calibration of portable hydrocarbon detector(s):
a) List instrument^) which were tested for calibration
Date & Time
There are 4 portable monitors. They are calibrated on a --regular be sio-i------------
Location
Instrum. Cal. VCM Instrum. VCM Percent Action
in Plant
Iden.
Concen.
Concen. Deviation Required
1 i
b) Calibration method used (check one or more)
Ncre
B Paragraph 61.65(7)(iii)(A) - Test Method 106-5.2.1, 5.2.3
Paragraph 61.65(7)(iii)(B)
Other
____________
67 TEN 2968
LEAK DETECTION AND ELIMINATION 10* Leak detection and eh.nfnation process [61.65(8)] a) What is the frequency of the "Leak Detection Patrol"?
daily
_
b) Check typical points and equipment which are required to be routinely checked for leaks by the "Leak Detection Patrol" In the following:
0 reactor
storage - heavy
cracking , furnace
0 stripper EDC purification 3 recovery system 3 mixing 3 weighing 3 holding tank
B storage - water & light ends col.
ED heavy ends col.
0i wastewater col..
0 water wash col.
0 water quench col.
0 wash water stripper
3 separation tank 30 dryer
3 blending tank
0 condensers
3 storage - raw
30 RD/SRV
Q storage - finished
B control devices
pumps
Q compressors
B agitator(s) 3 loading B unloading
Q flanges
& valves
G filter strainers
El centrifuges
0 holding bins
silos
Others:
c) What is the average elasped time between the determination of a leak by personnel of the "Leak Detection Patrol" and the plant's personnel taking corrective action for the purpose of eliminating the leak?
Small leaks: As early as possible_________________ "" Large leaks:
d) What is the average elapsed time between the monitoring system alarm becoming activated and the plant's personnel taking corrective action for the purpose of eliminating the leak?
Small leaks: As early as possible Large leaks:______________
DISCHARGES TO THE ATMOSPHERE
11. List any SRV's which do not use RD's or vent to recovery
system or to gas hold tank.
None
Location in Plant
Comments
i
68 TEN 2969
i? If a pressure gage Is located between rupture disc (RD) and safety relief
valve (SRV), list points In the plant where the gage Indicates a higher than
normal pressure, typically 0 to 5 pslg. (Note: While In conmon use In plants,
a pressure gage between RO and SRV is not a requirement of
Standard.)
Identify those RD/SRV points which are in PVC plants by check (<) In column 3.
RD/SRV Identification
Location In Plant
PVC Service
Inspector's Comments
None
13f List vents, other than emergency types, which are vented to the atmosphere and not connected to a recovery system, and whichare suspected of having had short and/or long periods of emissions exceeding the limits specified in Sections 61.62, 61.63, 61.64 and 61.65.
Vent Identification
Location In Plant
Location of Nearest Monitoring Polnt(s)
Two Storage Tanks Two reactors
Storage Reaction
yes yes
rUGITIVE EMISSIONS
14. Investigate and witness the plant's standard operating procedure [61.65(c)] for fugitive emission sources [6.1.6S(b)(l), (b)(2), (b)(5), (b)(6) and (b)(7)] and list any possible deficiencies.
Pertinent Fugitive Emission Source
Location In Plant
Possible Deficiency
Same as leak detection system
69 TEN 2970
15. Are plant personnel following the establ-shed standar operating procedures?
.0
Yes No
16. If the response to the above Is "NO", list pertinent fugitive emission source, location In plant and action required where the established standard operating procedure is not being followeo.
Pertinent Fugitive Emission Source
Location In Plant
Action Required
17* List equipment, location in plant, identification In the process of .
any pump, compressor and agitator which is not equipped as seal-less
or with a double mechanical seal or double outboard seal, and
does not duct emissions through a control system, or maintain
proper pressurization between seals or equivalent.
None
Equipment
Location In Plant
Identification In Process
Inspector's Comments
-
18.* Incoming raw material received by:
Shell is the supplier
Pipeline
Truck
Q Rail
Barge
19* Finished product material shipped by:
Pipeline
0 Truck
Rail
Q Barge
70 TEN 2971
PFACTORS AND FURNACES 20? Give the nunber of reactors for each capacity. EDC: Capacity Number_______________________
PVC: Capacity 35000 Gallons Number 10 Reactors
VCM (Hydroch1orination): Capacity Number
21? Give the number of cracking furnaces.
Not applicable
VCM(dehydrochlorination): CapacityNumber
CONTROL DEVICES
22* List control devices, location in plant, major entering streams, major
exiting streams, vent location.
Control Device
Location In Plant
Two incine rators South end
Major Entering Streams
Major Exiting Streams
Vent Location
.Nitrogen sweep Incinerator stack systeni, VCM leu. compressors
South ena, neai flar .
i 71
TEN 2972
STACK EMISSIONS
23. List plant's performance specifications of stack emission continuous monitoring Instrumentation:
a) Stack Identification The results have been approved by EPA.
b) Mean value,, calculated from a series of absolute measurements made by using the equipment specifications and procedure of reference Test Method 106 (see APPENDIX A);
c) Number of measurements used to calculate the mean value;
d) Accuracy,percent of the mean value;
e) Calibration error,percent of each calibration gas mixture value;
f) Zero drift (2 hr.), percent of calibration span;
g) Zero drift (24 hr.), percent of calibration span;
h) Calibration drift (2 hr.), percent of calibration span;
i) Calibration drift (24 hr.), percent of calibration span;
j) Response time,
_____________ (Time required from the insertion
of a known vinyl chloride concentration gas sample into the
stack and the stack instrument indicating a value 952 of the
known vinyl chloride concentration).
24. If more than one stack was tested, and if the other test data were
significantly different from the above data, use attach sheets to .provide
the information obtained from other stack tests'.
4 N/A
25. Were the stack emission tests made under conditions of maximum production rate?
Yes
No
N/A
If the response is No, give the percent of maximum production rate under which the stack emission tests were made:percent.
26. Were all stack samples analyzed within 24 hours? Yes Q No
' If the response is No, give elapsed time, to the nearest hour, from taking sample to its being analyzed:_ hours.
N/A
72 TEN 2973
27* List deviations or substitutes from reference Test Method 106 equipments
materials and procedures which are required In conducting the stack
emission test.
N/A
Equipment/Materials/Procedure Identification
Deviation or Substitutes From Test Method 106
Inspector's Comments
INPROCESS WASTEWATER
28. Identify any inprocess wastewater stream and location in plant which is mixed with another water stream prior to the reduction of vinyl chloride concentration to 10 ppm or less.
None
Inprocess Wastewater Stream Identification
Location In Plant
Identification of Process Step
Inspector's Comments
REACTOR OPENING LOSS 29. Briefly describe the plant's procedure to determine the emission due to opening the reactor. VCM vapors are removed by heating and vacuuming. They make as much as fifty batches in each reactor before opening. Three samples are being analyzed for VCM per opening.
73
,%
ON REVIEW OF RECORDS
NESHAPS INSPECTION FOR VINYL CHLORIDE EMISSIONS COMPLIANCE
Review Date 04/09/84
Reviewer's Name Syed Moinuddln
Firm's Name__________ Tenneco Polymers, Inc.______________________________
Firm's Address
P.O. Box 849 Pasadena, Texas 77501
_____________________
EMISSION (STACK)
Please see Tenneco's semi-annual reports of March 12, 84
and September 14, 83. 1. Review of hourly Uyes Uno average from continuous stack emission.
Zt Number of stack emissions (continuous emissions for 1 hour or more) which exceeded limits specified in Sections 61.62, 61.63 and 61.64:
3. Were there additional emissions which were not properly and accurately reported in the appropriate Semi-annual Report?
Yes 0No
4. If the response to No. 3 is Yes, list date, time, emission point location, duration, estimated integrated emission, and the cause or causes of emission. (Attach sheets if more space is required.)
| Date tt
Time
Location In Plant
Duration
Est. Integrated Emission
Cause or Causes '
Action Taken
-
LEAK DETECTION SYSTEM
5. Review of (check one or more) Qhourly Dshift ^Qdaily monthly average from leak detection system.*
Oweekly
* Data may be available from records on file at EPA Regional Offices.
74 TEN 2975
6. Number of times one or more monitoring points Indicated emission levels exceeded the value for the leak definition (See CHECKLIST 5 (d):
7. List date, time, monitoring point location, duration, estimated Integrated emission and the cause or causes of emission of those leaks in No> 6. (Attach sheets if more space Is required.)
Date & Time
1-23-84 2-13-*8*4 3.-14-84 3-30-84 4-03-84
Location In Plant
Duration
E-309 K-301D
C-306 C-307 C-343
Un known Unknown
fill Ilft II II II II
*
Est. Integrated Emission
125 PPM 100 PPM
200 PPM 120 PPM 150 PPM
Cause or Causes
Action Taken
Orifice fit ting Fixed
Thermal wel 3 Tightend
Threads
Liquid leg
replaced
Orifice bli id replaced
Flex speel
cracked
replaced
ATMOSPHERIC DISCHARGES
8t List information of emergency discharges to the atmosphere. None
} Date & Time
Location in Plant
Duration
Est. Integrated Cause or Inspector's
Emission
Causes
Conments
75 TEN 2976
L
9. Determine from plant records whether temperature, pressure, flow ratefs) and/or other process variables and/or If equipment failures (l.e., reduced flow rate of cooling water, defective temperature controller, etc.) gave rise to the necessity of the emergency dlscharge(s) from PVd reactors. List the date, time, location In plant and the con dition^) which appear to have produced the need for an emergency dlscharge(s),
None
Date & Time
Location In Plant
Conditions
10.. List the dates and time when similar or equivalent conditions existed as In No. 12 and for which an emergency discharge was not reported.
None
Date & Time
Location In Plant
Conditions
76
11. Review the leak detection records of those monitoring points nearest the locatlon(s) and down stream in No. 13 on those dates and times where conditions existed which appear to give rise to the necessity of emergency discharge. List date, time, location in plant and the emission levels of the nearest monitoring points.
None
Date & Time
Location In Plant
Emission Level of Monitoring Points
12. List the date, time, location in plant from the tabulation In No. 14 where the owner/operator appears not to be In compliance with the NESHAPS vinyl chloride standard and Its amendments.
None
Date A Time
Location In Plant
Inspector's Comments
.<
77
TEN 2978
mEACTOR OPENING LOSS
13t Review analytical records of vinyl chloride concentration In reactor vapor space to determine "reactor opening loss" of reactor (and s+ripper where applicable), prepolymerization and post polymerization vessels. List date, vessel identi fication, and batch Identification where emissions exceeded standard.
Oate
Vessel
Batch
Identification Identification
Inspector's Comnents
For c etails please see Tenneco's sen i-annual report of Septe mber 14, 1983 and March 12, 19 4.
RESIN. SLURRY, WET CAKE AND LATEX SAMPLING
14* Review analytical records of vinyl chloride concentration in polyvinyl-,
chloride resin, slurry, wet cake and latex to determine the weighed t
average residual vinyl chloride concentration in all grades of poly
vinyl chloride resin processed through the stripping operation on each
calendar day. List date, vessel identification, and batch identifi
cation where -missions exceeded standard.
None
Date
Vessel
Batch
Identification Identification
Inspector's Comments
i
78 TEN 2979
RECORDKEEPING
15. Review and assess the recordkeeping as required In the standard In the listing below, and comment on each with respect to completeness, form and ease of reference.
Record
Stack emission monitoring
Leak detection monitoring *
Leaks detected by "Leak Detection Patrol"
Stack emission tests
Reactor opening emissions
Inprocess waste water emissions
Resin, slurry, wet cake and latex emissions
Inspector's Conments In compliance In compliance
In compliance
Not required
8 excursions from Sept. 1, 83 thru -- Pnlii-iiarH ?Q 1QD4
In compliance
In compliance .
79 TEN 2980