Document 3e0461N6ga5poqjvgb5QE114a
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TOC P&M Environmental Affairs
(COMPANY)
S s /f(
INTEROFFICE COMMUNICATION
TO: FOR: FROM: RE:
Tenneco Polymers Carl Stutts R* D. Pruessner ENVIRONMENTAL REVIEW - PASADENA PLANT
DATE: December 28, 1983
Your approval is requested for scheduling the Environmental Review of the Pasadena Plant and affiliated wastewater treatment facilities on February 14-16, 1984.
The proposed agenda and Environmental Review forms are attached. It is requested the forms be filled in prior to the arrival of the review team.
pm Enclosure
cc: Pat Anderson Charles Beresford Lloyd Constant Guy Disch Jim Kachtick Jim Langford Ralph Maynard A1 Smi thi Roger Towe
RECEIVED
DEC S3 3983" TOC LEGAL -P&M
TEN 275
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AGENDA ENVIRONMENTAL REVIEW
TENNECO POLYMERS February 14-16, 1984
TUESDAY - February 14
7:00 p.m.
Supper for the Review Team and Polymer representatives at Dante's Italian Restaurant, 8103 Gulf Freeway.
WEDNESDAY - February 15
8:00 a.m.
Meet with Carl Stutts to conform final plans for Environmental Review.
8:15 a.m.
Meet with Jim Kachtick and staff to go over the information contained in completed Environmental Review forms.
11:30 a.m.
LUNCH (Please bring in sandwiches.)
1:00 p.m.
Meet with Jim Kachtick for plant tour.
4:00 p.m.
Adjourn
THURSDAY - February 16
8:00 a.m. 9:00 a.m.
Visit with maintenance department representative to sight maintenance and calibration records for environmental equipment.
Visit environmental laboratory and sight required records on quality assurance, sample chain of custody, analytical procedures, etc.
+1:00 a.m.
Meet with Polymer representative to go over Dock portion of questionnaire.
11:30 a.m.
LUNCH (Please bring in sandwiches.)
2:30 p.m.
Meet with Carl Stutts and staff to review proposed findings and complete the final report. Provide copies of completed report to Carl Stutts, Jim Langford, Jim Kachtick, Guy Disch, and Bob
Pruessner.
12/27/83
TEN0 276
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T EN N ECO OIL P&M FACILITIES
ENVIRONMENTAL REVIEW
TENNECO POLYMERS - PASADENA PLANT POLYVINYL CHLORIDE FACILITIES
12/27/83
TENO 277
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
Name and address of facility:
Tenneco Polymers Pasadena Plant 4403 La Porte Road P. O. Box 849 Pasadena, TX 77501-0849
February 14-16, 1984
Affiliated with: Tenneco Oil P<5cM
Operations Manager;
^ftcarl StUttS (Name)
nPla_ntiManager
Environmental Representative:
Jim Kachtick (Name)
Mgr.-Environmental Sciences (Title)
Type of operation and/or principal products:
Polyvinyl Chloride
Review Team: Name
Bob Pruessner Roger Towe Charles Beresford Pat Anderson Lloyd Constant
Title
Mgr.Environmental Affairs-TOC Sr.Environmental Eng.-TOC Attorney - TOC Mgr.Environmental Audits-TEN Staff Chemist - Chalmette
(713)479-3411 (Phone)
(713) 479-3411 (Phone)
Phone (713) 757-3306 (713)757-7685 (713)757-8764 (713)757-3604 (504)279-2480
12/27/83
TENO 278
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS ENVIRONMENTAL STAFFING
(1)
Please show the reporting relationship between individuals directly responsible for environmental compliance and the senior manager associated with this facility. (Add blocks as necessary.)
Name Jim Langford________ 'title Director of Operations
Name Title
Name Title
Name Title
Name Title
12/8/82
TENO 279
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
ENVIRONMENTAL STAFFING
(2)
Please list names and title of persons dedicating a significant portion of their time to environmental compliance. This should include those persons responsible for operating environmental control equipment, conducting laboratory environmental analysis, etc.
NAME
TITLE
Approximate percentage (%) of work time dedicated to environmental:
Brief description of environmental responsibility: ________________
Name
TITLE
Approximate percentage (%) of work time dedicated to environmental:
Brief description of environmental responsibility:____________________
NAME
TITLE
Approximate percentage (%) of work time dedicated to environmental:
Brief description of environmental responsibility:____________________
NAME
TITLE
Approximate percentage (%) of work time dedicated to environmental:_____________
Brief description of environmental responsibility:
----------------------------------------------------------------------------------------------------------------- TEN0-28O 12/8/82
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NPDE5 Permit No.:
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (1)
Date Issued:
Date Expires:
Other Water Discharge Permits: Date Issued:
Date Expires:
Discharge permit requirements: Outfall Number(Add additional sheets as necessary.)
Permitted Avg Max
Typical Actual Avg Max
No. of Self-Reporting Violations-Last 12 Mos.
Flow BOD Oil & Grease
Type of Waste Water Treatment System:
Method by which sanitary waste water is treated:
Who is treating sanitary waste?
Sanitary Waste Water Permit No._ Issuing Agency:______________________
Expiration Date:
12/8/82
TENO 281
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (2)
Date and significant findings of last regulatory inspection: Please attach copy of regulatory inspection report.
Do any discharge permits contain a compliance schedule?
YES NO N/A ____ ____ ____
Is the facility meeting the compliance schedule?
____ ____ ____
FLOW AND pH In matters relating to flow, do procedures used conform to the "water measurement manual" (U.S. Dept, of Interior, Bureau of Reclamation) or other procedures approved by the E.P.A?
Primary flow measuring device properly installed?
Primary flow measuring device properly operated and maintained?
Is primary flow measuring device calibrated?
(Last calibration date: ______ ______________ )
Secondary instruments (totalizers, recorders, etc.) properly operated and maintained?
Are continuous pH recording instruments calibrated with pH buffer solutions? Frequency: ______
Are the date, time, and the name of the person who calibrated the continuous pH recording instrument recorded? In a book?___ On the chart?___
Are calibration and maintenance records kept for 3 years on pH and flow measurement equipment?
Are pH and flow measurement data kept for the required threeyear period-?
____ ____ ____ ____
____ ____
____ ____ ____
____ __ ____ ____ ____ ____ ____ ____
____ __ _ ____ ____
____ ___ ____ ____ ____ ____
SAMPLE COLLECTION AND PRESERVATION
Permittee sampling meets requirements and intent of permit?
Details:
____________________ __
12/27/83
TENO 282
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (3)
Permittee is using method of sample collection required by permit? If not, explain method used and the frequency of sampling: __________________________ __________
Sampling locations adequate for representative samples? Parameters and sampling frequency agree with permit? Flow proportioned samples obtained where required by permit? Are composite samples refrigerated at 4C during collection? Are grab samples refrigerated as soon as possible after collection?
Are samples labeled as to location, composite or grab, date and time of collection, and sampler? Are samples collected in the authorized containers for each parameter? Are approved preservatives used for each parameter, when needed? When samples must be preserved, are they preserved at the time of collection?
Are samples analyzed within required holding times? Is the laboratory refrigerator for sample storage kept at 4C? When samples are not to be analyzed immediately in the lab, are they refrigerated at 4C? Are approved cleaning procedures followed in the laboratory for sample containers that are to be reused? LABORATORY METHODS Are EPA approved analytical testing procedures used?(40CFR 136.3) If a diffepent procedure is used, has written approval been received from the necessary regulatory agencies to use this alternate procedure? If part of an approved procedure is changed by you, has written approval been received from the necessary regulatory agencies for this change? Are monitoring and analyses being performed more frequently than required by permit? If YES, are results reported in permittee's self-monitoring report?
12/12/83
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER W
Are parameters other than those required by the permit analyzed? Are the methods used stated on the laboratory report sheet?
YES NO
N/A
LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL Who is responsible for Laboratory Quality Assurance Program?
Are duplicate (precision) samples analyzed with each set of
analyses?
Frequency: ___
Are spiked (accuracy) samples analyzed with each set of analyses?
Frequency: ________________
Are precision control charts prepared and used?
Are accuracy control charts prepared and used?
Are intralaboratory quality control standards used for each permit
parameter? Frequency:
Is satisfactory calibration and maintenance of laboratory in strument and equipment performed?
Are laboratory equipment calibrations and maintenance records kept for the required three-year period?
On analyses which require standards to be used in preparing calibration curves, are the curves prepared by using a blank and at least seven standards?
On analyses which require calibration curves or internal in strument calibration with standards, are blanks and standards analyzed with each set of samples in order to verify the calibration curve?
Are temperatures recorded on ovens(TSS) and incubators (BODs)?
Frequency:___________ __________ ____
Are laboratory analytical balances checked using NBS weights?
Are glucose-glutamic acid standards analyzed with each set of samples analyzed for BODs?
Is Class A volumetric glassware used for permit-required analyses?
12/27/83
TENO 284
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (5)
LABORATORY DATA REPORTING AND STORAGE Are the following recorded on the laboratory report sheet:
Sample location? Composite or grab? Date and time of collection? Sampler? Date and time analysis started? Analyst? Are sample results kept for the required three-year period? Are quality assurance and quality control records kept for the required three-year period? Commercial laboratory used? Commercial laboratory state certified?
Weeds cut and vegetation growth in ponds removed? Banks and dikes maintained? (Erosion, etc.) Any reports of groundwater contamination from pond(s)?
If Y ES, give details:
YES NO N/A
____ ____________ ____ ____________ ____ ____________ ____ ____________ ____ ____ ____ ____ _________ ____ ____ ____
____ ____ ____
____ ____ ____ ____ ____ ____
_____ ___________ _____ ___________ _____ ___________
Seepage reported? Adequate freeboard (2 feet) to prevent overflow? Effluent release is:
___ Continuous _____ Intermittent ____ Seasonal
12/12/83
TENO 285
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (6)
What is the receiving stream?
YES NO N/A
Is there a formal Spill Control Plan (SPCC)? Has the SPCC been approved by management? Is the SPCC certified by a registered engineer? Has the SPCC been reviewed and updated within the last 3 years? Have there been any reported spills the prior 12 months?
How many? Total amount of spill: _____________________
If more than 2 reported spills within the last 12 months, has the SPCC been revised and certified by a registered engineer?
Is a training program existing to instruct personnel in operation and maintenance of spill control equipment?
Are briefings scheduled to insure adequate understanding of the SPCC plan by company personnel?
12/12/83
TENO 286
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS WATER (7)
How is storm water treated?
YES NO N/A
What is the design basis for storm water treatment?
Do existing discharge permits have storm water requirements? What are the requirements?
12/12/83
TENO 287
TENNECO OIL RAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS DOCK OPERATIONS
(1)
Does this facility operate a ship or barge dock? What materials were transferred across the dock the last 12 months?
YES NO N/A
Additional materials that may be transferred in the future.
Does the spill control plan include the dock facilities? What is the volume of the spill containment for the transfer facility?
What emergency spill containment equipment (booms, absorbent, etc.) are owned and available at the facility?
12/6/82
TENO 288
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
DOCK OPERATIONS
(2)
Have arrangements with other organizations been made lor emergency spill cleanup support?
Who?
YES NO N/A
Do any of the materials transferred or anticipated to be transferred meet the Coast Guard definition of "oil," i.e., oil of any kind or in any form, including but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil"?
If the transferred materials fall within the Coast Guard definition of "oil," an operations manual meeting the requirements of Coast Guard Regulation (CFR 33 Part 154--Oil Pollution Regulations for Marine Oil Transfer Facilities) is required. Has an operations manual been prepared meeting these requirements? (Please provide a copy of the manual.)
(1) If an operations manual has been prepared, has it been sub mitted to the Coast Guard "Captain of the Port" (required no later than March 3, 1983)?
(2) Has the Captain of the Port issued a "letter of adequacy"?
(3) Have amendments to the dock operations manual been made since the issuance of the Coast Guard "letter of adequacy"?
(4) Are copies of the dock operations manual available to dock operations personnel?
(5) Has this facility designated "persons in charge of facility oil transfer operations" and advised the Captain of the Port of this designation in writing?
(6) Are current (annual) hose pressure tests and inspection records available at this facility?
If the transferred materials do not fall within the Coast Guard definition of "oil" but do fall within the requirements of 33CFR126 --Handling of Explosives or Other Dangerous Cargoes Within or Contiguous to Waterfront Facilities--has a dock operations manual been prepared for this facility?
12/6/82
TENO 289
r
TENNECO OIL FfcM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
DOCK OPERATIONS
(3)
(1) If an operations manual has been prepared, are copies available to dock operations personnel?
(2) Does the operations manual contain the following:
A. Documentation that the dock operator is a qualified operator?
B. Dates and results of the most recent cargo hose and piping hydrostatic tests?
C. Cargo information cards listing the following:
a. Cargo identification characteristics (appearance, odor, etc.)?
b. Emergency procedures?
c. Fire fighting procedures?
YES NO N/A _____ ___
_____ ___ _____ _____
____ ___ _____ ___ _____ ___
12/6/82
TENO 290
I
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
(1) YES NO N/A
What type(s) of PVC resin is produced:
Dispersion resin
Suspension resin
Bulk resin
Does this plant have a fixed vinyl chloride monitoring
system in place to continuously monitor VCM emissions?
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 relief valve discharges were reported in the last 12 months?__
Where did relief valve discharges go?___ Flare ___ Atmosphere ___ Other
Were they reported within the required time (10 days)?
____
FUGITIVE EMISSIONS FROM EQUIPMENT IN VCM SERVICE Are loading and unloading lines in VCM service degassed thru a control system before opening?
____
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?
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
12/27/83
TEN0 291
f
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
(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
_________________ _____ ___________
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?
_____ ____ ____ _____ ____ ____
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? WRat percent is this of total reported values?
c. Incinerator VCM emissions greater than lOppm? What percent of incinerator operating hours?
Is record keeping performed as required?
a. Are records kept two years? b. Are they destroyed after two years?
_____ ____ ____
_____ ____ ____ _____ ____ ____
When was last NESHAPS inspection? (Please provide copy of report.)
12/12/83
TENO 292
TENNECO OIL MtM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (1)
List air construction permits or permit exemptions obtained in the last 12 months:
Description of Permitting Permit Unit Agency
Control Device
Allowed Emissions
Date Issued
1.
2. _
3.
4.
5.
6. ________________
7. _________ __ __________________________________ _______________
List air operating permits presently in force:
Description of Date Expiration Allowed Monitoring
Reporting
Permit Unit Issued Date Emission Requirements Requirements
1.
2.
3.
4. '
____________ _________________________________________ _________
5. __________ ________________________________
6.
7.
8.
9.
12/8/82
TENO 293
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (2)
When was the last air regulatory inspection? __________________' Please provide a copy of last inspection report! (Date)
Describe any noted deficiencies and the corrective action taken:
DEFICIENCY
CORRECTIVE ACTION
1.
2.
3.
4.
5.
6.
12/8/82
TENO 294
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (3)
When was the last air emissions inventory? __________________ _ DATE
List reported emissions rates:
Tons/Year
1. Hydrocarbons
2. Sulfur Dioxide____________________
3. Nitrogen Oxides________ __
4. Carbon Monoxide
5. Particulate
6. Vinyl Chloride
7.
S.
What procedure is followed to report emission excursions to regulatory agencies? Please attach a copy of existing written procedure.
Is this facility monitoring ambient air quality?
Is a quality assurance program used?
.)
12/8/82
YES NO N/A YES NO N/A
TENO 295
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS AIR (4)
What parameters are monitored?
Has air monitoring data shown exceedances of air standards? ____ ___ YES NO "N7A
Is this facility in compliance with or on a schedule of compliance with all applicable emission limitations and standards under the Clean Air Act?
Discussion if required:
YES NO N/A
Does this facility have procedures to insure leaded gasoline is not used in
company vehicles designed for unleaded gasoline?
____ ___ ____
YES NO ~N7A
If this facility dispenses more than 200,000 gallons of gasoline per year, does it
have Stage 1 vapor control system installed?
____ ___
YES NO "n7a
Who is responsible for gasoline health effects warnings?
Is gasoline health effects information posted in vehicle refueling areas?
12/27/83
YES NO N/A TEN0 296
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SOLID WASTE DISPOSAL (1)
Is this facility registered under the Resource Conservation and Recovery Act (RCRA)?
Generator Storer Treater Disposer Transporter
YES NO N/A
_____ _____ ____
_________________ _________________ _________________ _____ ____ ____ _____ ____ ____
What is the registration number?
List any hazardous waste and the amount being generated and show if it is disposed of on or off-site.
ON OFF
List any solid waste and the amount being generated and show if it is disposed of on or off-site.
If this facility is a treater, storer, or disposer (T5D facility), does it have a final RCRA permit?
YES NO N/A _____ _ ____ ____
Has this facility received its RCRA Part B application?
_____ ____ ____
If yes, when is Part B application due? ________
Is Part B application being completed as per 40 CFR 264 <Jc 270? _____ ____ ____
12/27/83
TENO 297
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SOLID WASTE DISPOSAL (2)
If this is a TSD facility which does not yet have a final RCRA permit, is it in compliance with the interim standards?
Are the following prepared: Written Waste Analysis Plan? Is the site secure to prevent unknowing entry or are "Danger-Unauthorized Personnel Keep Out" signs installed?
Written inspection schedule on: (a) Monitoring equipment? (b) Security devices? (c) Operating and structural devices?
Personnel training? "No Smoking" signs for ignitable or reactive waste? Preparedness and prevention? Contingency Plan? Arrangements with local authorities?
YES NO
Are manifests used with each off-site load of hazardous waste?
Are all hazardous waste manifests accounted for?
Is manifest record system properly maintained? Is an annual hazardous waste summary provided to the State? (Provide a copy.)
Is hazardous waste held over 90 days? Has any drummed waste been held over 90 days?
What is the present inventory of drummed waste? Number of drums
Is each drum dated when hazardous wastes are placed in the drum?
What is the present inventory of empty drums?
12/12/83
TENO 298
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (3)
How are empty drums disposed of?
Are any empty drums given (sold) to employees or neighbors?
Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material?
What types of hazardous waste treatment are accomplished on site?
Solar Evaporation Processing for Detoxification Incineration Neutralization Landfarming Fixation prior to burial Recycling Biological Other
Has TOC provided closure costs of on-site treatment and storage facilities?
What is estimated cost?Who estimated cost?
Are ponds used in hazardous waste treatment?
Are ponds in natural clay?
Are ponds lined with clay?
How thick?
What freeboard is maintained in ponds?_____________________
What is expected 24-hour rainfall in a five-year period?______
Does this facility have an ongoing groundwater monitoring program?
If facility has a final RCRA permit, what phase of GW monitoring
exists at present? Detection___ Compliance___ Corrective Action
If facility is still in interim status, is GW monitoring program in compliance with the interim status requirements?
12/27/83
TENO 299
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (4)
How many monitoring wells are used?_
How many wells are upgradient?___
How many wells are downgradient?____
How deep are the monitoring wells?__________________________
What are the wells monitored for? (40 CFR 265.92)
1. Set 1 Parameters: _______________
2. Set 2 Parameters:
3. Set 3 Parameters:
4. Other:
Have initial background concentrations been established for all of the parameters analyzed?
YES NO N/A _____ ____ ____
Does this background information indicate any groundwater contamination?
_____ ____ ____
If so, has a groundwater quality assessment program been established
as per the interim status regulations?
_____ ____ ____
What has been the total cost of the groundwater monitoring program? ________
What were the costs for the last 12 months? _
Are monitoring-well results reported to state?
___ ____ ____
What is the depth of the shallowest aquifer currently used?
12/12/83
TENO 300
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (5)
Does this facility operate water wells?
What depth?__________ How many?
List private drinking water wells near this facility.
Owner
Depth
1.
2.
3. ______________________________________________
4.
List industrial/commercial water wells near this facility.
Owner
Depth
Water Use
1.
2. _________________________
3. ___________________________________________
4. ____________________________________ _______
List municipal or public water wells near this facility.
Owner
Depth
Water Use
1. ___________________________________________
2. _____________________________
3. ___________________________________________
4.
Has this facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal?
What discrepancies did they note?
Have these discrepancies been corrected? (Provide a copy of last regulatory inspection.)
YES NO N/A
12/12/83
TEN0301
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (6)
OFF-SITE DISPOSAL
If off-site hazardous waste disposal is used:
What is the name of the facility?
Name
Permit Number
1.
2.
3.
Do you have a copy of their current RCRA permit? Do you have a copy of their current state permit(s)? Have you visited this facility in the last 12 months? Did the evaluation confirm this site is satisfactory for disposal of your facility's hazardous waste? (If a written evaluation report was made, please attach.)
Are DOT approved containers and labeling used for off-site delivery of hazardous waste?
Estimated annual cost of off-site disposal?_________________
Has this off-site facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal?
What discrepancies did they note?____________________________
YES NO N/A ____ ____ ____
____
____
Have these discrepancies been corrected?
12/12/83
TENO 302
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
UNDERGROUND STORAGE (1)
Does this facility have underground storage tanks?
_____ ____ YES NO ~n7a
Please tabulate information on underground storage including fuel tanks.
Tank Identification
Tank Volume
Material of Construction
Tank Age
Material Stored
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
How often is stored product inventory reconciled? _________________ What program is followed to insure early detection of potential leaks?
12/12/83
TENO 303
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
POLYCHLORINATED BIPHENYLS (PCB) (1) YES NO N/A
Does this facility have an annual inventory of PCBs? (Please make available copies of PCB inventory.)
Are annual PCB inventories retained for five (5) years?
Do annual reports contain:
A. Date and source of PCB articles, chemicals, and mixtures received?
B. Date and type of article, chemicals, and mixtures removed from service?
C. Accounting of amount received, amount removed, and amount remaining at facility?
Are all transformers and capacitors containing PCBs labeled? Are transformers not containing PCBs labeled "NO PCB"? Is PCB containing equipment that is not in service properly stored in a marked PCB storage area?
Does the PCB storage area meet the following requirements:
A. Roof to prevent rain water from reaching PCB items? B. Spill containment to contain twice the internal
volume of the largest PCB article? C. Containment area without any drains, valves,
expansion joints, sewer lines or other openings. Does storage facility meet these requirements? D. AH articles marked with the date they are placed in storage? E. All articles in storage checked for leaks at least every 30 days and records of checks maintained?
Does this facility have a program to eliminate existing PCBs?
Describe pTogram.
When are PCB's expected to be eliminated from this facility? 12/27/83
TENO 304
!
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE (1)
Name of pipeline:___________________________________________
When was pipeline constructed?
What is pipe diameter?
Length of pipeline?
What products are transported?
Normal operating rate and pressure:__________________________ ________________
Maximum operating rate and pressure:______________________
Date of latest hydrostatic test:_____________________________ __________________
Do current DOT regulations require additional pressure testing? __ _
YES NO N/A
How often are pipeline rights-of-way inspected?
Who conducts these inspections?___________________ ___________________________
(Provide a copy of a typical inspection.)
How often are navigable waterway crossings inspected?
Are all line markers provided as required?
Do the markers contain the proper wording as required as well as
emergency phone numbers?
How many pump stations are on this pipeline?_
What is the source of power?
Electric Yes___ No___
N/A
Gas
Yes___ No___
N/A
Diesel
Yes___ No___
N/A
What provisions are made to shut down pumps in event of pipeline leak?
12/8/82
TENO 305
(
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE (2)
Are herbicides used to control right-of-way vegetation growth? YES NO
If herbicides are used--what kind is used?
N/A
How applied?
Aerial_____
Ground
Are licensed applicators used to apply herbicide?
_______________
YES NO N/A
Have adjacent land owners complained about herbicide problems?
YES NO N/A
If so, give brief description.
Is cathodic protection provided for the pipeline?
____ ____
YES NO N/A
What type?
How often is cathodic protection current measured?
How often is cathodic protection pipeline to ground potential
measured?
(Please provide representative records of cathodic protection maintenance.)
How is the "Public Education" provision of 195.440 administered?
What material, if any, is discharged from the pipeline during testing or cleaning?_________________________ _____________ How often?_____________________________________ __________ Where?___________________________________________________ What is final disposition of material?______________________
12/8/82
TENO 306
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
COMMUNITY RELATIONS (I)
How many complaints were received from neighbors or other interested parties the last 12 months?
Is this a decrease compared to the previous 12 months?
_______ _______
What percent of the neighborhood complaints received relate to:
Air Water
Noise
Spills Solid Waste Disposal Other
TOTAL
_______ _______ _______ _______ _______
100%
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?
Does 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.)
_______________ YES NO N/A
"y"E$ no ~n7a
12/12/83
TENO 307
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
COMMUNITY RELATIONS (2)
What individual is responsible to make timely reports of the occurrence of emergencies to TOC P&M Environmental Affairs Department (Houston)?
Briefly describe activities this facility has participated in the last 12 months to enhance community relations. Typical activities are providing speakers for civic clubs and other local organizations, participating in county (parish) fairs, supporting youth groups such as Little League, Scouting, etc., providing information to newspapers, radio or television.
12/8/82
TENO 308
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SUMMARY (1)
The following items represent commendable performance or innovative solutions to environmental regulatory requirements that may have applications in other TOC Facilities.
12/8/82
TENO 309
TENNECO OIL P&M ENVIRONMENTAL REVIEW
, TENNECO POLYMERS
SUMMARY --m--
THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION: DOES
LOCAL INDIVIDUAL RESPONSIBLE MGMT FOR COMPLETION OF ITEM fr DESCRIPTION SPECIFIC IMPROVEMENT NEEDED AGREE CORRECTIVE ACTION
DATE FOR COMPLETION OF IMPROVEMENTS
TEN0 310
8/16/83
I
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS SUMMARY (3)
Unresolved questions raised as a result of the Environmental Review. Question #
Responsible party: Date for answer: Answer:
Date answered:
12/8/82
TEN031
(
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS SUMMARY (V
COMMENTS
12/8/82
TEN0 312