Document 3NXamqvpBgK3V9zBzz7jo2wVJ

Memorandum i AIR .A PRODUCTS Z To: P.L.T. Brian Dept.. Corp. Engineering From: A.J. Olglio Dept./Ext.' Corp. Environmental Date. 29 March 1989 Subject: Public Policy Committee Presentation cc: L.C. Ooelp D.C. Emerson T.J. Marriott, Jr. J.K. Spata Thibaut: This is in reply to your questions of March 27, 1989 concerning your Public Policy Committee presentation. Vlnvl Chloride We do not believe vinyl chloride releases at Calvert City and Escambia are having any significant health effects on the public or our employees. OSHA has conservatively estimated safe work place limits are 1 part per million time weighted average (TWA) for an 8 hour work day, and 5 parts per million short term exposure limit (STEL) for a 15 minute period. Based on the 1987 Title III release data and air dispersion calculations by Radian, vinyl chloride concentrations, at and beyond the fence line, are well below OSHA standards at both plants. Table 1 summarizes this data. Plant Calvert City Escambia TABLE 1 Total Vinyl Chloride Released Ibs/vear 25,149 6,000 Concentration Fence-Line.ppb 9.20 0.017 The releases Included episodic, permitted, and fugitive vinyl chloride quantities. Indications are there are no significant health threats to the public from these vinyl chloride releases compared to the OSHA standard. On May 28, 1984, the Escambia PVC plant released about 35,000 pounds of vinyl chloride over 16 minutes. The air dispersion analysis for two cases with conservative wind speed conditions of lmph and 3mph showed concentrations of VCM greater than 100 parts per million at the plant's fence line which exceeds the OSHA STEL. (Please see Appendix) ronu 192017 |4i AP00024805 1 P.l.T. Brian 29 March 1989 Page Two A one-time exposure over a lifetime is not believed to cause chronic health effects. The US Department of Health and Human Services. Fourth Annual Report on Carcinogens. Summary 1985. states that air emissions measured near several vinyl chloride production facilities contained 3.1 to 12.5 parts per billion of vinyl chloride. Please find in the Appendix the DHHS Report on Vinyl Chloride. Lou Doelp's plot (Figure 1) shows that at 2,000 feet from the PVC plants (approximate distance to the nearest receptor (neighbor) at both plants) 5 parts per million may be exceeded under certain worse case conditions for an Instantaneous release that exceeds 1 pound. Table II shows the pounds estimated for each release for the respective plants from January 1984. The DHHS classifies acrylonitrile as a substance that may reasonably be anticipated to be a carcinogen. The DHHS summary on acrylonitrile is attached that notes there is limited evidence of acrylonitrile's carcinogenicity in humans. OSHA considers acrylonitrile a human carcinogen and regulates it as such with a TWA limit of 2 parts per million and a STEL of 10 parts per million in the workplace. The total Title III acrylonitrile emissions for our Wichita plant was estimated by Radian at 3,326 pounds annually. Chemical Group did not have Radian perform any air dispersion analysis on acrylonitrile at Wichita, but intuitively feels it is not a health threat. Gulf Coast Waste Disposal Authority The Gulf Coast Waste Disposal Authority was formed by the Texas State Legislature as a government authority. A federal judge in the late seventies declared the Gulf Coast Waste Disposal Authority facility (GCWDA) a publicly operated treatment works. At one time, EPA wished to declare it an industrial complex. The permitted volume of the GCWDA plant is 55 million gallons per day. Our Pasadena plant discharges 1 million gallons per day on an average about 2% of the total. Superfund Those superfund sites at which we are a potentially responsible party, PRP, resulted from legally disposing of wastes in the 60's and early 70's. Through acquisitions such as Sterns Rogers and GSF Energy, we also are involved In superfund sites as PRP's. We have taken several measures to reduce our potential exposure to superfund and other cleanup liabilities. Among these are: AP00024806 P.L.T. Brian 29 March 1989 Page Three reduced hazardous waste generation reduced hazardous waste disposed in landfills recycling of solvents auditing of disposal companies and sites environmental assessments of acquisitions. Air Products has reduced hazardous waste to landfills in excess of 90*. Only 2* of the estimated 7.6 thousand tons per year of hazardous waste disposed off-site is landfill. The landfills must meet stringent RCRA requirements and government inspections. They also must meet our annual environmental reviews, and In addition, we utilize a consortium of 30 companies (Commercial Hazardous Waste Management Evaluation Group) in which Air Products is a charter member that engages environmental consultants to audit off-site disposal facilities. New Orleans PSG Ammonia - Wastewater The sources of ammonia in the follows: cooling water tower blowd exchanger leaks. Please let me know if you need anything els as , and 1619q Attachments AP00024807 AP00024808 i FIGURE 1 VC1 Instantaneous Release Uw = 0.5 m/sec Minimum Release for 5 PPM at Receptor 1000 PUFF RELEASE for 5 PPM i/i tr- n wa*rc w *-o<=-- AP00024809 R ELEASE IN C ID EN TS VCM RELEASES JAM. 34 - UAR. SO ZZ1 RELEASE AMOUNT RANGES CALVERT CITY [ ESCAMBIA *S AP00024810 DATE 23 JUN 84 25 JUN 84 14 AUG 84 25 AUG 84 IS OCT 84 31 OCT 84 23 NOV 84 20 JAN 85 04 NAR 85 05 NAR 85 21 NAY 85 SO JUN 85 13 AUG 85 04 DEC 85 12 DEC 85 15 DEC 85 29 NAR 88 08 JUN 88 07 AUG 88 13 SEP 88 23 FEB 87 05 NAR 87 18 NAR 87 21 APR 87 28 APR 87 01 NAY 87 27 NAY 87 17 AUG 87 09 SEP 87 14 DEC 87 19 NAY 88 21 AUG 88 14 DEC 88 PLANT JiESHAP/ VCN CERCLA RELEASED CAL N CAL C CAL CAL N CAL N CAL f CAL N CAL N CAL C CAL N CAL .a CAL C CAL J CAL CAL V CAL c CAL c CAL j* CAL r CAL i* CAL c CAL c CAL c CAL N CAL c CAL N CAL N CAL N CAL N CAL C CAL N CAL N CAL N 5485 9 3 38 5288 250 2940 350 50 100 115 10 4590 H 20 2 ?i JV 10 741 20 17 <f 25 2200 157 15 48 340 14 4515 388 3 TABLE rr VCM Releases From Jan. 1984 S*JKHARY RELEASE ANOUNT (IBS.) 1 - 100 100-1000 1000-5000 >5000 CALVERT CITY 13 9 3 2 DISTRIBUTION-* 55 27 12 6 ESCAMBIA DISTRIBUTION-* 2823 13 53 13 20 01 FES 84 28 NAY 84 08 NAY 85 14 JUL 85 13 QCT 85 22 JAN 88 20 NAR 88 15 JUL 88 05 QCT 88 19 OCT 87 18 NAY 88 21 NAY 88 12 OCT 88 23 QCT 88 03 NAR 89 ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC ESC N N C N N N N N C C N A c c c 23300 35000 10 218 212 351 1000 13885 9 2511 548 172 2798 108 271 C <&VtAV,$ AP00024811 ESCAMBIA 1984 VCM EMERGENCY RELEASE AP00024812