Document 3JRRwGVRynx6dXVkd4zGdbMLE
BFGOODR!CH CHEMICAL DIVISION PEDRICKTOWN PLANT
JULY - AUGUST, 1979
ENVIRONMENTAL STATUS REPORT
DISTRIBUTION
ENVIRONMENTAL COMMITTEE
J.A. KIEL Q^dk
J.P. MORAN / C.E. MCCANN T.D. RINGS K.L. BLANTON K.A. JEFFERS
B.H. RAYNOHA W.A. REED
PEDRICKTOWN
C.J. J.M. B.A. J.M. T.S. J.W. R.V.
NOSAL SMITH PRUSINOSKI FLETCHER NASIFE GOETSCH TEBBUTT
CLEVELAND
W.C. HOLBROOK J.D. FANNIN J.W. LEWIS ^^ALTEMATEN.R. AQUINO A.W. CLEMENTS W.E. HORTON G.F. KRCMAR
C. REID R.D. HARDESTY M.D. RIDER K. J. KILROY C.E. TITUS C.J. ORSBORN R.W. BIRCH R.G. SAUNDERS L. LEVI J. W. ROBBEN K. D. KONTER A. WATERS
NIAGARA FALL: ALTC ALGC AKRON BRECKSVILLE CALVERT CITY LONG BEACH ORANGE PORT NECKES
LOUISVILLE HENRY PLAQUEMIHE
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NOC 14957
INDEX
Environment Committee Meeting Report EPA - OSHA Goals
(a) Mass Resin - Personnel Monitoring VCM (b) Mass Resin - Building Level VCM (c) Suspension/Dispersion - Personnel Monitoring VCM (d) Suspension/Dispersion - Building Level VCM (e) Latex - Personnel Monitoring AN (f) Compound - Personnel Monitoring Toxic Dusts (g) Compound - Personnel Monitoring Noise EPA - NESHAP VC1 Attainment Waste Water Treatment System Data Analysis - July and August July and August Progress Reports
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NGC 14958
B.F.GOODRICH CHEMICAL COMPANY MEETING REPORT
SUBJECT
JULY/AUGUST ENVIRONMENTAL COMMITTEE MEETING
OUTSIDE ORGANIZATION INVOLVED
ME ETING PLACE
Pedricktown, N.J-.
BFG PARTICIPANTS
K.L. Blanton T.D. Rings K.A. Jeffers J.M. G1ickman J.A. Kiel C.J. Nosal W.A. Reed J.P. Moran
RESULTS ANO COMMITMENTS:
OTHER PARTICIPANTS INO DISTRIBUTION]
I.'EET ING DATE
8/W79 and 9/7/79
.DOITIOMAL COPIES TO. C .T .P .
1 . Reviewed status of 1979 established EPA-OSHA goals
Graphs reviewed are attached for the following areas:
A. Mass Resin B. Suspension/Dispersion Resin C. Latex D. Compound
The following was noted:
A. Mass continues their on-going program to identify and correct relatively minor fugitive emission VCM leaks. A considerable amount of time is spent in this area by all area personnel. Problems have been occurring with the G.C. and Mass Is considering expediting the conversion of their unit from the 7,000 series to the 9,000 series.
B. Susfrension/Dispersion continues to make improvements. Point 6 located on the 2nd. floor by Dispersion has accounted for approximately
35% of the readings 'p 1 ppm.
C. Latex AN readings continue low. The AN training program was critiqued and found to be very beneficial.
D. Compound noise personnel monitoring results continue to improve. The
0SHA cuber room noise citation can be abated through the use of
administrative controls;however, the approach is to utilize a
combination of engineering controls and operational controls to abate
the_citation. A progress letter was sent to 0SHA on 9/17/79. T
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Compound toxic dust.personnel monitoring area is very active. Theflab
AA unit is in operation and results are available in 2k hrs. This* is
extremely helpful for training and followup. Special self contained
power ventilated combination hard hat/respirator have been received and exper1emented with. The equipment was very well accepted.
REPORTED BY 0FG-U3O9 9/71
Jim A. Kiel/re
NOC 14959
PRINTED
U.S.A.
July/August Environmental Meeting Page 2:
2. Overall Status of EPA-NESHAP VC 1 Attainment Program EPA-VCl Attainment Summary is attached: EPA-VC1 attainment has been excellent for both months. The semi-annual report was submitted to EPA. The VGA back up incinerator installation is almost complete. Start up is scheduled for early October and a stack test is scheduled for October 18, 1979* An extremely thorough review for all VC1 handling systems that potentially could experiences reportable rupture disk/relief valve discharge continues. Selective BV type rupture disks will be replaced with S~90 type rupture disks- Several other alternatives are also under investigation including reactor RV, burp system modifications and power failure emergencies.
3 Complaints and Unusual Releases to the Environment A. One complaint was received during July (odor-Latex premix spill), and one complaint in August (noise-railroad tracks). There were four plant Ammonia odor complaints. Two unusual releases were acknowledged in July (Latex premix spill and suspension leaking change gasket). Eight unusual releases were acknowledged in August (3 to waste treatment, 2 - VCM fugitive, 2-PVC dusting, and 1 EPA reportable 3*^ lb RVCM recovery system).
A * Pertinent Topics of Interest A. Reviewed status of proposed PVC expansion. B. Reviewed NJDEP petroleum and hazardous material spill control plan. C. Revieweff* 1980 environmental project. D. *Reviewed 9/5/79 Hurrican David and tornado near miss.
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NGC 14960
PCRSONAL MONHORING RESULTS VINYL CHLORIDE
MASS RESIN POLYMERIZATION - BLDG. 512
.'CM, 3 pm
-GOAL
1579
H;
<
Rdnoe Averaqe ppm % ^ 1 . 0 ppm
Semples No-0-5 0-5C No.<1.0 No> 1.0 ppm KonUT YTD . FTonth YTD
18 14
2 0.01-5.20 0.55 0.65 88.9 88.5
NGC 14961
BUILDING MONITORING RESULTS VINYL CNLOP.IDE
,, .MASS RESIN POLYMERIZATION - BLDG 532
PERCDNT OF READINGS
MONTHLY AVERAGE
YEAR TO DATE
< 1 ppm
92.30
92.67
1-5 ppm
5.68
6.18
5-100 ppm
1.8A
1.07
0r-H 0
5-
>, 100 ppm
0.19
average ppm * In building
1.83
1 .]A
*
NGC 14962
Average ppm In building Is calculated using the following assumptions: any point less than 1 ppm = 0.5 ppm, any point between 1 and 5 ppm = 2.5 ppm, any point between 5 and TOO ppm = 15 ppm, and any point greater than 100 ppm = 500 ppm. These assumptions are based on actual levels for
a one week period-
PERSONAL MONITORING RESULTS VINYL CHLORIDE
SL'SPEHSION/DISPERSIOH POLYMERIZATION - BLDG. SB
GOAL
1379
No. Sa.Tip 1 es No-D-5 0.
No,--1 - 0 No> 1.0
-s nge Average ppm X<= ).Q ppm ppm Month YTD Month" YTD
25 20
J
4 0.03-2,07 0.35 0.7^ 8A.0 79-8
NGC 14963
BUILDING MONITORING RESULTS VINYL CHLORIDE
SUSPENSION/DISPERSION POLYMERIZATION-- BLDG 513
PERCENT OF READINGS
MONTHLY AVERAGE
YEAR TO OATE
< 1 ppm
84.44
82.97
1-5 ppm
12.98
14.24
5-100 ppm
2.48
2.64
^100 ppm
0.10
0.16
average ppm * in building
1.62
1.94
NGC 14964
* Average ppm In building is calculated using the following assumptions:
any point less than 1 ppm = 0.5 ppm, any point between 1 and 5 ppm 2.5 ppm, any point between 5 and 100 ppm = 15 ppm, and any point greater than 100 ppm = 500 ppm. These assumptions are based on actual levels for
a one week period.
1.
0.
0.
AN ppm
0. o. o. o.
D.
0. 0.
PERSONAL MONITORING RESULTS ACRYLONITRILE
No. Samp!
-l-Reg 3 Non-Reg
3 8
1979
NoS 1 .0
3 8
Range Averaqe ppm `
1.0 <No^ 2.0 No >-2.0 ppm Month
YTD Month
0.0-0.37 0.21 0.0-0.A1* 0.12
0.21 0.08
100 100
ppm YTD
100 100
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Noe 14963
PERSONNEL MONITORING RESULTS LEAD
OSHA STANDARD
3 979
No, Sampl es 13
Average* Xg/nf
.Month.
YTD
85.0
131.3
% 52doa g/W3
Month YTD 84.6 64.3
i The Averages are computed using the 1og-transformatIo 7 technique.
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NOC 14966
PERSONNEL MONITORING RESULTS NOISE
COMPOUND MILL AREA - Bldg
* 90dBA
No. Samples 6
if < 90d BA
MontTi
6
% < 90dBA
Month
YTD
100 55.7
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NGC 14967
EPA VC1 ATTAINMENT
=-
-
July, 1979
REACTOR OPENING
PEARL No. of Non-attainments No. of Openings % Attainment
1 47 97 -9%
PASTE No. of Non-attainments
- No. of Openings
% Attainment
0 203 100%
MASS No. of Non-attainments No. of Openings % Attainment
0 326 100%
RESIN STRIPPING
PEARL - % Attainment
PASTE - % Attainment
MASS - % Attainment
100% 100% 100%
VENT ABSORBER . % Attafnment
100%
WASTEWATER STRITPER % Attainment
100%
UNUSUAL^D1SCHARGES Number of Unusual Discharges
0
SEMIANNUAL REPORT TO
DATE
10/21/78 TO
02/28/79
2 258 99.2%
1 996 99.9%
1 1507
99,9%
16 227 93-0%
64 792 91.9%
8 1125 99.3%
100% 100% 98.0%
99,2% 96.8% 90.9%
99.82
96.4%
100% 2
91.8%
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NOC 14968
EPA VC1 ATTAINMENT
REACTOR OPENING LOSS
PEARL No. of Openings No. of Non-Attainments
% Attainment
PASTE No. of- Open i ngs No. ofcNonnAttainments
% AttsJ'nment
MASS No. of Openings No. of Non-Attainments
% Attainment
RESIN STRIPPING
Pearl - X Attainment
Paste - % Attainment
Mass - % Attainment
VENT GAS ABSORBER
% Attainment
WASTEWATER STRIPPER
% Attainment
AUGUST, 1979
SEMIANNUAL REPORT TO DATE
3/01/797/31/79
33 0
TOO %
199 0
TOO %
226 0
TOO %
33 0
TOO %
.199 0
100%
296 0
TOO %
258
2
99-2 %
996 J
99.9 %
T 507 0
TOO %
TOO % TOO % TOO %
TOO %
100 %
1 00 %
3 00 X 300 X 93.0 %
9^*5 %
99.5 %
99.8 %
100 %
TOO %
TOO %
UNUSUAL RELEASES
No. of EPA*Report.able 9"
T2
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KAJ/re
NGC 14969
DATE:
JULY, 1979
WASTE TREATMENT
-------- "
Influent Primary Effluent SecondaryEffluent
Lagoon
Activated Sludge
Calculations
TS (ppm)
1638
DS (ppm)
762
1166
SS (ppm)
f
876
VSS (ppm)
749
4o |<M 26
COD
BOD5
(mg/1) (mg/1)
938 294 357 224
1145
1105
40
24
51
-
pH PO4 NH3 TURI3 (ppm) (ppm) (JTU)
8.9 - -
-
6.6 2'i 8, 3.8
7.1 0.45
0.81
1200
1164
36
21 .
48
7 7.0
-
-
Sanitary
(SS) v
(VSS) *
Flow (MM) (EFF) (Reuse) 11.1 4.5
Industrial
(Cl)
(MLSS) (MLVSS) (DO)
(02t) (SV) ' (SVI)
10.2
2566.
. Prim, (Total) %.
15.6 1.0
1943
4.8
Sludge
Thickened**1 sPosa^
X f (Lbs Dry)
'10.0 263, 271
9
( Inf) 0.31
137 , 55
BOD/COD
(Prim) (Lagoon)
0.63
0.15
(F) 86
(SS) 96
COLOR (APHA)
TEMP. (F)
--
< t 1
-
91' 81
USS) 6441
(RVSS) 504?
% Removal
(COD) I <!$D> 95 1
WATER TREATMENT
Recycle Reuse Potable
Clarified
TS (ppm)
DS (ppm)
SS (ppm)
VSS (ppm)
COD (mg/1)
PO4 (ppm)
--
-- -
-
-- -- -
-
909 879
30 17
-
-
pH Fe Cl TURB (ppm) (ppm) (JTU)
--
7,0
1,0
3,0 <M2
-
6.8 2. 1
-
COLOR (APHA)
-
TEMP . (F)
-
65 77
* Denotes tank out of service.
NGC 14970
I
DATE: AUGUST - 1979
WASTE TREATMENT
TS (ppm)
Influent
Primary Effluent
Secondary Effluent
1797 *1 936
913.
DS (ppm) 635
908
880
SS (pp-cn)
VSS (ppm)
mo 29
969
V' ' 18
33 21
COD
bod5
(mg /1) (mg /1)
10AA
238
300 186
AS
pH 8.6 6.5 7.0
P04 (ppm)
-
nh3 (ppm)
-
TURB (JTU)
-
2.7 A.7 0.37 1.0
COLOR (APHA)
TEMP. (F)
1 i1 1
-
*
Lagoon Activated
Sludge
Calculations
qfcS QJR
____ 17 ____ kl___ _ _____ R____ 7_n___
Sanitary
(SS)
(VSS)
(Cl) 7.8
Flow (MM) (EFF) (Reuse) (TotaL)
.^7
A.5 19.2
Industrial
(MLSS) (MLVSS) (DO)
(02T)
2380
1785
3.9 11
Sludge Prim. ThickenadtDisposal)
% %. CLhs... Dry) (Inf)
(SV) ' 105
(SVI) A5
BOD/COD (Prim) (Lagoon)
1.2
8.6 250.208
0.23 0.62
0.12
(F) 91
(SS) 97
78 83
(RSS) 6687
(RVSS) 5158
% Removal
(COD)
(BOD)
96 98
WATER TREATMENT
Recycle Reuse
Potable
Clarified
TS (ppm)
DS (ppm)
SS (ppm)
VSS (ppm)
COD (mg/1)
PO4 (ppm)
--
-- -
-
-- -
--
-
8AA 817 27 16
-
-
pH Fe Cl TURB (ppm) (ppm) (JTU)
- - A.2 6.9 1.6 0.60
-
6.8 1.8
-
COLOR (APHA)
-
TEMP. (F)
-
63
81
'O r
Chemical Division
Inter-Organization Correspondence
SIGNIFICANT ACCOMPLISHMENTS
1. Permits for the large poly and paste expansions were approved by
the State. The Federal EPA will be requesting information regarding these psrmits.
2. The Atomic Absorbtion Spectrophotometer was set up on 7/23. Dust monitoring samples were analyzed ON 7/26.
3. Issued report on waste chemical processing and treatment facility monitoring well analysis.
GENERAL INFORMATION
1. Conducted monthly environmental meeting.
2. Submitted Quarterly Solid Waste Manifest summary to the State 7/18.
3. Survey of requirements and condition of dumpsters completed and
ISSUED 7/20.
4. Submitted renewal for tailings conveying system (Bl-iJi/5E 1J1)
CERTIFICATE #13280. ^
5. Reorganisation of NJDEP permits completed.
6. Annual monitoring well data submitted to NJDEP.
7. Vacations* J.A. Kiel 7/16 - e/5 J.M. GLICKMAN - 6/29 - 7/15
ACTIVE PROJECTS
1. NJDEP Spill Plan - continue to prepare plan which must be submitted
* - - BY 9/1/79.
2. Fugitive PVC Dust Control - Review status and priorities on/
ESTABLISHED LIST OF PROJECTS.
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3. OSHA - Lead Program - Personal monitoring results continue to look
ENCOURAGING. CONSIDERABLE EMPHASIS HAS BEEN PLACED ON TRAINING AND DEVELOPMENT OF TECHNIQUE.
NGC 14972
Page 2.
ACTIVE PROJECTS (CONT. )
h. OSHA Noise Program - Sound absorbent panels were installed
ABOVE * 1 CUBER. IMPROVEMENT IN PERSONAL
Monitoring results continue with implementation
GN REVISED PROCEDURES AND CURTAILMENT OF SECONDARY AIR BLASTER.
5. OSHA Acrylonitrile - Annual training of all appropriate personal
COMPLETE.
6. VCM INCINERATOR - INCINERATOR RECEIVED AND SET. STARTUP SCHEDULED for late August.
7. Review *nd order necessary materials to recondition sanitary system.
a. Complete investigation work and recommend corrective action on corroded aerators.
OPERATIONAL
1. Sanitary system taken down fdr repairs.
2. Submitted GPO for concrete work.
GOALS
1. Prepare alternate RR track layouts so as to facilitate movement of additional cars associated with proposed PVC expansion and minimize neighborhood train noise.
2. Complete draft on NJDEP spill plan.
3. Complete?- review and order necessary materials to recondition sanitary system.
a. Complete engineering layout work on identified safety and housekeeping projects.
5. Complete OSHA personal monitoring summary and issue same.
6. Prepare NJDEP air permits for new product collector on two mass product tanks and four silos 1-4J.
7. Cdmplet investigation work and recommend corrective ACTION
CQRRODElf AERATORS.
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8. Complete reorganization of, and refiling of general environmental RECORDS.
NGC 14973
LE/LP
'cJ Uv^L 'ti,
Chemical Division
Inter-Organization Correspondence
To J. m. Fletcher
Fron^yJ . A. Kiel
Location Pedricktown * Department
Location Pedricktown Department
Subject AUGUST ENVIRONMENTAL PROGRESS REPORT
Date 8/29/79.
SIGNIFICANT ACCOMPLISHMENTS
1. NJDEP approved permits for the proposed phased PVC expansion were received. Additional information was submitted to the EPA o complete the PSD application. Approvability review will*-take a projected four (4) weeks or until 10/1/79. BFG attorney's reviewed the entire PSD applicability with respect to both the current regulations and proposed modification based on a recent court decision in Alabama. BFG contends that PSD does not apply.
2. Prepared and submitted NJDEP petroleum and hazardous sub stance spill control plan.
3. Issued NESHAP-VCM semiannual report.
4. Completed budget review for Department 5159.
GENERAL INFORMATION
1. Conducted monthly environmental meeting.
2. NJDEP obtained 24 hour waste water treatment influent and treated effluent sample on 8/8/79.
3..
NJDEP inspected waste chemical processing and treatment facility on 8/27/79. Four (4) 55 gal drums of dried sludge was sent to Kentile for manufacture of experimental floor tiles.
4. Discussed NJDEP spill control program with prime contractor, Mid Atlantic Refinery Servicing and gave them a very brief tour of the plant.
5. bestir Stumpe, Cleveland Office, visited the plant for two
deys*to review the NJDEP spill control plan and promulgated
modification to the effluent permit program "NPDSS".
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6. Cerl Reid and Pete Collee, Niagara Falls, visited the plant for two days to review waste water treatment operations.
NGC 14974
GENERAL INFORKATI OH (Continued):
2
8/29/79
7. Reviewed waste water treatment plant operation with represen tation from Vineland Chemical Company.
ACTIVE PROTECTS
1. NJDEP Spill Plan -- Plan complete and submitted on 8/31/79. To comply with provisions in plan, a very extensive training and engineering program will be required. It is anticipated that at least six (6) months of engineering will be required to comply with all provisions of the plan.
2. Fugitive PVC Dust Control - Received Torrid Dust Collector ana Carter Day Dust Collector. Both units will be installed in Mass in September. The Torrid will be evaluated and if acceptable six (6) additional units will be ordered for Mass and^suspension. Silo relief valves were rebuilt but baghouse barter pressure still poses a problem. The new Torrid units wil3s- resolve this issued. Flush trenches will be installed by the silos to facilitate cleanup and a wind screeiwill be installed on the Worth side of the drier roof.
3. CSKA. - Lead Program - The AAS unit is in opeation and personal monitoring results are available oh a 24 hour basis. New self contained positive flow hard hat/respirator units were received for experimentation. The compound area really likes them. They will comply with the OSHA standard and will result in a net cost savings over disposable 3M respirators. Experimenta tion continues with coated stabilizers with a much stronger involvement from Cleveland.
4. OSHA - Noise Program - Program continues with no major changes. It is strongly felt that compliance can be achieved under "no problem conditions", hov/ever, the plant approach is to reduce operator noise exposure under all normal and projected minor operational problem conditions.
5. OSHA.-VCM Monitoring - All corrections were completed and the summary printout for 1978 monitoring results will be issued to each employee in September.
6. VCii Incinerator - Incinerator installation has been put on rush due to potential problems with the VGA. The installation is expected to be complete the week of 9/10/79. The unit will be test run the week of 9/17/79 and a stack test is scheduled for 9/26/79.
7. 129 apriority Pollutants - Review data and regulations with
Chemical Group Task Force on 8/30/7S.
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NGC 14975
OPERATIONAL
3 8/29/79
1. An AR was prepared to replace the utility area interceptor pumps. Under current emergency conditions a pump will be relocated from the surface water runoff interceptor pump.
2. An AR was prepared to recondition the sanitary waste water treatment system. The system is currently down and materials are on order. The sanitary waste is being hyperchlorinated
to 10 ppm and is pumped directly to the industrial waste equalization tank.
3. An AJ< v/as prepared to replace the industrial waste water treatment chemical flask mix tank* The tank currently has several emergency patches.
4. All concrete work for the safe handling of chlorine cylinders was ^completed. Material is on order to provide cylinder racks.
a
5. Evaluation continues on the corroded aerators. Special' checks will be performed and a price for a replacement cone will be requested.
GOALS
1. Conduct a risk/benefit review of RR track modificaticns and day switching.
2. Complete sanitary system 'reconditioning*
3. Install and evaluate Torrid I>ust Collector in Mass. Prepare liJDEP permits for four (4) additional units for Mass ana two (2) for Pearl.
4. Prepare training and operational manual for incinerator. Assist in startup and shake down of system and conduct stack testis
5., Establish plant environmental goals for 1S80.
6. Complete identifiable projects outlined in trial environmental surveillance.
7. Complete job description updates and all appropriate'personal performance appraisals.
J?JC:bjc
cc:
C.K. No sal K. A. Jeffers J.ii. Glickman E.C. Clegg Pile
NGC '4976