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