Document 2q1a50rko4ZB7MjjBg6q46Rqb

*#U- *' I NTER-OFFICE MEMO TENNECO OIL P&M to See Copy To fbom w. R. Fogelsanger Subject At At Flemington Date March 9, 1983 Copy to,__ Rr"ffTT)onovan H. R. Horton W. R. Smickle A review of our Environmental Compliance is scheduled for April 19-22, 1983. A group from TOC will conduct the review. In preparation for this audit, they have requested us to assemble certain information which will help the process to move smoothly. Please complete the attached sheets which are in your area and return to me by April 4 to allow me time to assemble the complete package. I have initialed the items in each area. Thank you. WRF: ms Enel. A fEN 4536 TENNECO OIL P&M ENVIRONMENTAL REVIEW. TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NE5HAPS) (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 _____ _X X __ When sampling, are sample containers purged into a closed process system? Are unused portions of samples (10% or more VCM by weight) returned to the process? X __ X ___ 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 lOppm? _______ What percent of incinerator operating hours?____________ if' Is record keeping performed as required? a. Are records kept two years? b. Are they destroyed after two years? 10/27/82 TEN 4537 TENNECO OIL P&M ENVIRONMENTAL REVIEW* TENNECO POLYMERS COMMUNITY RELATIONS (1) How many complaints were received from neighbors or other interested parties the last 12 months? What percent of the neighborhood complaints received relate to: Air Water Noise Spills Solid Waste Disposal Other TOTAL 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?__ DoS 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.) 12/8/82 -t; ` ,> f , . -V ^ ** * ' . :r ; ;*' 7;.> - , ' '"-7 . X'V, `->, m . , -7- il "7 ' - -T r =:7; ' 4;:- V v.v j/,'.'-v,V;V-T':- -> - .**, ' *- `v ; ..v&r:'- . -,;i TENNECO OIL P&M ENVIRONMENTAL REVIEW '<77 *77 __ '-.A V' 7"* . - :^,v7 . * ;r` . TENNECO POLYMERS (WAP AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) (1) YES NO N/A CepH What type($) of T*VQ resin is produced: Dispersion resin Latex resin Bulk resin Does this plant have a fixed vinyl chloride monitoring system in place to continuously monitor VCM emissions? _k 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 emergency manual vent valve discharges to the atmosphere M# were reported in the last 12 months? , , Were they reported within the required time (10 days)? 0J \ ^ FUGITIVE EMISSIONS FROM EQUIPMENT IN VCM SERVICE Are loading and unloading lines in VCM service degassed thru P<\/ a control system before opening? __ X 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? P 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 ________ __ A / X * 4- v 10/27/82 TEN 4539 inter-office memo TENNECO CHEMICAL_ LS,* INC ToShift Foremen/Poly Foremen FromR. A. Donovan Subjectrpa Sampling/Monitoring ATRiemington ATRiemington Date October 14, 1981 Copy to p, Benn W, Schomp Please be reminded that the following, procedures as regards EPA samples and charcoal tube monitoring are presently in effect. I. Waste Water Stripper Samples Take bottoms samples on the 12-8 shift Monday, Wednesday and Friday and have them brought to Q.C. Lab by 0800 hours. Also, take recovered vinyl acetate samples at same time as Waste Water Stripper samples. II. EPA Slurry Samples Take 4 oz. EPA slurry sample at request of Analytical Services and have them brought to Q. C. Lab as soon as possible after they are taken. III. Reactor Opening Samples These samples are to be taken by J. Durant as they were previously taken. IV. Charcoal Tube Monitoring The Shift Foreman will coordinate this program with W. Smickle. The foreman will be responsible for issuing the pumps and do cumenting the person's activities and other pertinent information for the monitoring period. When possible, W. Schomp will work with W. Smickle in this area. RAD:ms tp rN 4540 90-2164 inter-office memo TENNECO CHEMICALS, INC. To Operating Personnel at Flemington From R. A. Donovan at Flemington Subject REACTOR PRESSURE VENTING TO STRIPPERS date June 24, 1981 Copy to If the need arises to vent reactor pressure to strippers in an attempt to control the batch use the following procedure: 1. Close automatic steam valves if open. 2. Close 1" steam line if in use. 3. Close manual block valves in steam lin at stripper. 4. Isolate No. 3 vacuum pump. 5. Adjust recovery line valves at stripper appropriately. 6. Open recovery valve at reactor. AT NO TIME SHOULD PRESSURE FROM A REACTOR BE VENTED TO A STRIPPER WHEN THE MANUAL STEAM BLOCK VALVE IS OPEN!! TEN 4541 90-2184 nter off,CE memo TENNECO CHEMICALS, INC. To ALL OPERATING PERSONNEL at Flemington From D. Hershkowitz at Flemington Subject STRIPPER 4-OZ. EPA SAMPLES date November 12, 1980 copy to Distribution IT IS ABSOLUTELY ESSENTIAL THAT EACH 4-OZ. EPA SAMPLE BE FULLY LABELED. THERE ARE TO BE NO EXCEPTIONS TO THIS. BE SURE THE FOLLOWING INFORMATION IS INCLUDED: BATCH NUMBER TIME REACTOR NUMBER FORMULATION NUMBER STRIPPER NUMBER OPERATOR INITIALS ALL SAMPLES ARE TO BE BROUGHT TO Q. C. AS SOON AS POSSIBLE, AND NOT ACCUMULATED IN THE REACTOR BUILDING. THANKS, cc: 4 Shift Foremen 4 Poly Foremen W. Schomp R. Thorsen 12 Reactor Operators P. Benn R. Donovan W. Fogelsanger D. Scofield J. Sweeney M. Wagshul Dennis TEN 4542 90-2184 INTER-OFFICE MEMO TENNECO OIL P&M To R, A. Donovan From W. R. Fogelsanger Subject Unloading At Flemington At Flemington Date March 17, 1983 Copy to y. Kachtick J. T. Sweeney As a part of control of VOS emissions required by the State of New Jersey, we have notified them that the vapor recycle system is in use during the TCE truck unloading operation. Please instruct your operators in the use of this system and assure yourself that it is being utilized. The TOC audit team scheduled for a visit in late April,and will probably want to see the system. I would like to call on you to explain its operation. Thank you. WRF:ms WT Fogelsanger Environmental Coorinator rEN 4543 inter office memo T E N N E G 0 CHEMICALS, INC. To J. P. Sandstedt t. at Piscataway Date July 11, 1977 F ROM Subject R. A. Donovan at Flemington Slurry Equivalency Program Follow-up Flemington Copy to 'D. M. Hershkowitz C. F0 Rothenbeck , G. I. Rozand J. T. Sweeney To provide verification that the EPA requirements for stripping copolymer slurry are met at Flemington, the following program has been initiated. This program consists of two parts. 1) Two samples of stripped slurry will be analyzed each J V week for VCM content. These samples will be taken on \ arbitrarily selected days. \ 2) For batches that are not analyzed, achievement of the critical checkpoints will be noted indicating that each batch has been stripped according to the procedure which will enable the EPA regulation to be met. So that this program may operate effectively, the following arrangements have been made. Production will provide samples to Analytical Services when they are requested. It will be the respon sibility of the Analytical Services to request samples each week, on arbitrarily.selected days. Analytical Services will analyze the samples and maintain a log of the results. To insure that item 2 is being accomplished, a revision to the "Reactor Charge Sheet" has been made to indicate that the critical checkpoints in the EPA stripping procedure are being met. The achievement of these critical checkpoints will be noted by Production during the normal processing of each batch. The revised "Reactor Charge Sheet", indicating the checkpoints, i^ attached for your consideration. call. If there are any questions on the program, please feel free to RAD :ms "R* A. Donovan rBhj4S44