Document 4JewaVKXB4MooKarx6VZwLzmN
TfNNECQ,
TENNECO OIL COMPANY P&M
(COMPANY)
INTEROFFICE COMMUNICATION
TO: T0C-PW1 EMPLOYEE RELATIONS FOR: PAUL CRAVEY FROM: P. J. HUGHES RE: OSHA INSPECTION OF TENNECO POLYMERS PASADENA
DATE: JANUARY 18, 1985
On Thursday, 17 January 1985, Mr. Roy Piggee of the Occupational Safety and Health Administration arrived at the Polymers Pasadena Plant to conduct an industrial hygiene inspection of the facility.
Mr. Piggee was met by Jim Oliver, Safety Superintendent, and Mr. Oliver was informed the survey was a random industrial hygiene survey. Mr. Piggee reviewed the OSHA 200 log and other occupational health reports and policies, surveyed the plant, accompanied by Mr. Oliver, and interviewed several employees. The plant survey and employee interviews were concluded on Friday, 18 January 1985.
Mr. Piggee requested and was provided the following documentation:
o Summary report of December, 1984 VCM personnel monitoring results
o Respiratory protection procedure
o Medical program and evaluation form
In addition, a copy of the VCM training program was requested and is to be provided next week.
The only discrepancy which has been noted to Mr. Oliver thus far is housekeeping in the dryer building due to resin accumulation in this area. Mr. Piggee plans to return to the plant the week of 21 January 1985 in order to do dust sampling in the dryer building area. Equipment is available to do parallel sampling, and it is anticipated that parallel sampling will be done. It is unlikely that sample results will exceed the TLV.
A closing conference to discuss survey results has not been held. I will keep you informed of the status of this survey.
PJH/jw cc: J. P. Kelly
P.'J. Hughes
TENO 861
iff* too*
TENNECO POLYMERS, INC. ENVIRONMENTAL REVIEW-PASADENA PLANT
1985
TENO 862
PAM FACILITIES ENVIRONMENTAL REVIEW
TENNECO POLYMERS - PASADENA PLANT POLYVINYL CHLORIDE FACILITIES
12/20/S4
-1 -
TENO 863
TENNECO OIL P&M ENVIRONMENTAL REVIEW
March 5-7, 1985
Name and address of facility:
Tennec Polymers Pasad na Plant 4403 La Porte Road P. O. Box 849 Pasad na, TX 77501-0849
Affiliated with: Tenn co Oil P&M
Operations Manager:
Frank Koslosky. (Nam J
Director - Operations (TltI3
nvironmental Representative!
Jim Kachtick (Name)
Mer.-Environmental Sciences (Title)
Type of operation and/or principal products:
Polyvinyl Chloride
(713) 479-3411 (Phone)
(713)479-3411 (Phone)
Review Team: Name
Title
Phone
Bob Pru ssner______________ Roger T we________________ Charles Beresford___________ Emile LeRougc_____________ Lloyd Stewart______________
Mgr .Environmental Affairs-TOC
(713)757-3306
Sr.Environmental Eng.-TOC______
(713) 757-7685
Attorney - TOC_____________________ (713)757-8764
Environmental Supervisor-TOC
(504)579-2274
Mgr.Environmental Audits-TEN
(713)757-4100
1/2/85
2 TEN0 864
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS ENVIRONMENTAL STAFFING
a)
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 Russell Bowers Title Vice President-Chemicals
Name Title
Frank. Koslosky Director - Operations
..
1 Name
!
: Title
Harold Fife______________ Administrative Manager
Name Jim Kachtick_____________ Title Manager - Environmental Sciences
-- 5C %
Name Title
12/20/8<f
TENO 865
TENNECO OCL PAM
environmental reviev
TENNECO POLYMERS
ENVIRONMENTAL STAFFING
(2)
Please list name 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 analyses, etc.
Jim Kachtick
Manager - Environmental Sciences
NAME
TITLE
purLtufi**
Approximate percentage {%) of work time dedicated to environmental: 95X C ^
Brief description of environmental responsibility: Manage environmental affairs at Pasadena plant to insure compliance with pertinent laws ana regulaciMs.
File permit applications, reports, and correspondence with regulatory agencies. Review and advise" on all projects irom the environmental aspect.
Nelson Turner
L/ri-y
/ T> **
/
Manager of Quality Assurance
Name
UTlE
~
Approximate percentage (%) of work time dedicated to environmental: 20*
Brief description of environmental responsibility: Supervise NPDES, NESHAP and RCRA analytical testing to insure proper methods and techniques are used. Provide technical assistance in troubleshooting operational problems with waste treatment systems.
George Harvey
Quality Assurance Supervisor
NAME
TITLE
Approximate percentage (%) of work time dedicated to environmental:
Brief description of environmental responsibility: Oversees sample collection, provides liaison with operations in troubleshooting problems as tney arise.
Jadie Pryor
//*u T
Chemist
Rame
title
Approximate percentage (%) of work time dedicated to environmental:
______
Brief description of environmental responsibility: Perform analytical testing for
NPDES permit.
12/20/84
THNO 866
TENNECO 00. P&M ENVIRONMENTAL REVIEV
TENNECO POLYMERS
ENVIRONMENTAL STAFFING
(2)
Please list name 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 analyses, etc.
Joe Frank Robins
Offsites Superintendent
NAME
TITLE
Approximate percentage {%) of work time dedicated to environmental!
Brief description of environmental responsibility! Mana8e operations of waste treatment system, waste fuels boiler system, loading facilities, water treating system and VCM pipelines. Provides liaison on environmental/operational concerns with TENN-USS and Oxy.
Sandy Levine
Offsites Production Engineer
Name
TITlI
Approximate percentage (%} of work time dedicated to environmental! 50Z
Brief description of environmental responsibility: Provide technical service for operation of the offsite facilities. This includes troubleshooting as well as long-range studies and tests in this area.
To * C
Ed Dromgoole
Offsites Operations Supervisor
NAME
TITLE
Approximate percentage (%) of work time dedicated to environmental!
_____
Brief description of environmental responsibility: Supervise operations of waste treatment system, waste fuels boiler, and water treating system I
To -c
<c
*
Milton Hackfeld
Loading Supervisor
NAME
TITLE
'
Approximate percentage (%) of work time dedicated to environmental!
102
Brief description of environmental responsibility: Supervise operations of the product ana raw materials loading facilities, including dock, and pipelines.
0/S4
xjc /v* 4/ f * '* * f '-J & * * *
C ft tr to C h t. )
TENO 867
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
NPDES Permit No.: TXQ006335
WATER (1)
Date Issued: Oct. 15, 1984*
Other Water Discharge Permits: Date Issued:
Texas Permit No. 00002
Feb. 22, 1983
Date Expires: Oct. 15, 1989
Date Expires: Feb. 22, 1988
* Effective date * Jan. 4, 1985
Discharge permit requirements; (Date EPA denied request for Evidentiary Hearing)
Outfall Number 101
(Add additional sheets as necessary.)
Permitted Avg Max
Typical Actual Avg Max
No. of Self-Reporting ** Violations-Last 12 Mos.
Flow
N/A N/A 1.46
2.42
0
BOD
500
1,000
257
2098
3
Oil & Grease 210 315 11.2
119.4
0
COD
5,200
10,400
603
3840
0
TSS
420 840 175
1150
2
VCM - 0.83
< 0.10
0
Toluene
_
3.75
<0.10
0^
Type of Waste Water Treatment System: Primary Treatment (oil/water separation; equalization; neutralisation)
Activated Sludge
Multi-media Filtration
Method by which sanitary waste water is treated: Package Unit/Effluent goes to activated sludge system
--
Who is treating sanitary waste? Tenneco Polymers, Inc.
Sanitary Waste Water Permit No. N/A
Issuing Agency:N/A Expiration Date:
______
** See Attachment 2
12/20/s*
.6.
TEN0 868
NPDES Permit No.:
TENNECO 0!L 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 001
(Add additional sheets as necessary.)
Permitted Avg Max
Typical Actual Avg Max
No. of Self-Reporting ** Violations-Last 12 Mos.
Flow
3.0 mgl 5.4 mgl
1.99
Temperature
105F
PH
6.0 - 9.0
6.0
Chromium
10.4
17.7
2.2
Ammonia
Floating Solids
100 200 Trace
28
Biomonitoring
N/A
Type of Waste Water Treatment System:
None -
3.63 91F 11.4 30.5 499
0 0 1 1 2
0 H
Method by which sanitary waste water is treated:
Who is treating sanitary waste?
Sanitary Waste Water Permit No. Issuing Agency:Expiration Date:^
** See Attachment 2 12/20/84
-7-
TEN0 869
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (2)
Date and significant findings of last regulatory inspection: Please attach copy of regulatory inspection report.
Hay 3, 1984
(See Attachment 3) Do any discharge permits contain a compliance schedule?
YES NO N/A X
Is the facility meeting the compliance schedule?
X
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? How often? Monthly (Last calibration date: 3/^85)
_X __X __X _X
Secondary instruments (totalizers, recorders, etc.) properly
operated and maintained?
^
Are continuous pH recording instrument^ calibrated with pH buffer solutions? Frequency: Dally * on request
X X
Are the date, time, and the name of the person who calibrated
the continuous pH recording instrument recorded? In a book? _X On the chart?___
X
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 three* year period?
X X
SAMPLE COLLECTION AND PRESERVATION Permittee sampling meets requirements and intent of permit?
Details: Flow proportional; refrigerated
_
12/20/84
TENO 870
TENNECO OIL PftM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER
(3)
YES
Permittee is using method of sample collection required by
permit? If not, explain method used and the frequency of
X
sampling: _______
Sampling locations adequate for representative samples? Parameters and sampling frequency agree with permit?
.X X
Flow proportioned samples obtained where required by permit? Are composite samples refrigerated at 4c during collection?
X X
Are grab samples refrigerated as soon as possible after collection? Jt__
Are samples labeled as to location, composite or grab, date and time of collection, and sampler?
X
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?
X X
X X X
X
Are approved cleaning procedures followed in the laboratory for sample containers that are to be reused?
X
LABORATORY METHODS
Are EPA approved analytical testing procedures used?(40CFR 136.3) X
If a different 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
-9-
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (4)
Are parameters other than those required by the permit analyzed? Are the methods used stated on the laboratory report sheet?
YES NO N/A __ X _____
X ____
LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL
Who Is responsible for Laboratory Quality Assurance Program? Nelson Turner
Are duplicate (precision) samples analyzed with each set of
analyses?
Frequency: 1%
Are spiked (accuracy) samples analyzed with each set of analyses?
Frequency: 100%
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:
100%
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: once/month
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
- 10 -
TENO 872
TENNECO OIL PAM 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 E5, give details:
Seepage reported?
Adequate freeboard (2 feet) to prevent overflow?
Effluent release is:
X Continuous
Intermittent
* Will be used for biomonitoring in future.
Seasonal i
12/12/83
- 11 -
TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
WATER (6)
What is the receiving stream? Houston Ship Channel
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:
x __ * __ x __ x __ _____ x
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 874
TENNECO OIL PfrM ENVIRONMENTAL REVIEW
TENNECO POLYMERS WATER (7)
How is storm water treated? Part of storm water collected in a retention pond, which is normally pumped to waste treatment unit. Other storm water is discharged untreated to the Houston Ship Channel.
YES NO N/A
What is the design basis for storm water treatment? The first 430,000 gallons of rainfall are collected in the storm water retention pond._________ ___________
Do existing discharge permits have storm water requirements? *X What are the requirements?
N/A
* Application of storm water discharge permits as required by new NPDES regulations will be submitted by the deadline of/March 26, 1985.]
12/12/83
13 -
TENO 875
TENNBCO OIL MM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
DOCK OPERATIONS
0)
Does this facility operate a ship or barge dock?
What materials were transferred across the dock the last 12 months?
Methanol
Ortho-xylene C
Ammonia
( a ^ y j________________
2 Ethyl Hexanol
s>
S)
YES X
Additional materials that may be transferred in the future.
rPropylene
Iso-butyraldehyde
V
Does the spill control plan include the dock facilities?
What is the volume of the spill containment for the transfer facility?
Two 20-gallon drip pans
X
What emergency spill containment equipment (booms, absorbent, etc.) are owned and available at the facility?
Vacuum truck
Backhoe with front-end loader
12/6/82
- 14 -
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
DOCK OPERATIONS
(2)
Have arrangements with other organizations been made for emergency spill cleanup support?
YES NO N/A X
Who? All-Waste Service, Inc.; Brovning-Ferris Industries;
Malone Marine Services; Petterson Marine
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?
X
X X X X
X
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
- 15
TENO 877
TENNECO OIL PAM 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 X
X X
X X X
12/6/82
- 16 -
TENO 878
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? Incinerator System
______ --X
_X _x
How many relief valve discharges were reported in the last 12 months? ^ (See Attachment 4)
Where did relief valve discharges go? x Flare x Atmosphere ___ Other
Were they reported within the required time (10 days)?
_jj
FUGITIVE EMISSIONS FROM EQUIPMENT IN VCM SERVICE Are loading and unloading lines in VCM service degassed thru a control system before opening?
X ____ __
Are slip gauges used in the VCM loading/unloading operation?x
Are slip gauge emissions reduced via a control system?
_____ ________ X
If controlled--what is the control mechanism? N/A
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?
_X _X __X
Are all compressors equipped with double seals or equivalent? a. Positive pressure maintained between seals?
b. Double seal interspace vented to a control system?
x ~3C
Are all agitators equipped with double seals or equivalent?
x
a. Positive pressure maintained between seals?
_____ ____
b. Double seal interspace vented to a control system?
_____ ____ _jc
c. Other
_________________________ __________________ __________________
* Three discharges to atmosphere; one discharge to flare.
12/27/83
- 17
TENO 879
TENNECO OIL WtM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
f,
I
S~ * 7
^
1,
*`
V
to T <
Are relief valves connected tp/a process line,
recovery system, or equivalent? aefltlallsall discharge to If not, are they equipped with rupture discs? /flare^system.
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) r turned to the process? No unuseda portions remain.
Is the VCM content of equipment reduced as required before opening to atmosphere?
Does this plant have a formal leak detection and elimination
program?
* _X
a. Has the program been approved by the EPA Administrator? __X
b. What is the plant definition of a "leak"? Two consecutive 25 ppm analyses. --------------
Is the VCM content of "in process wastewater" reduced as required?
X
Does this plant have Standard Operating Procedures incorporating the VCM fugitive emission requirements?
__X
Are emissions data reported in Semiannual Report as required?
__X
**
How many reported exceedances were there the last 12 months for:
a. Residual VCM content of stripped PVC slurry? 0 What percent is this of total reported values? 0%
b. Reactor opening emissions?18_____ What percent is this of total reported values?__ 8.9%
c. Incinerator VCM emissions greater than lOppm? 6 What percent of incinerator operating hours? "0.14%
Is record keeping performed as required?
a. Are records kept two years? b. Are they destroyed after two years?
X
X _____
X
When was last NESHAPS inspection? April 9. 1984 (See Attachment 5)
(Please provide copy of r port.)
..
* TACB approved program in June, 1984.
u i+
** Last two semi-annual reports (covering September 1, 1983 through August 31, 1984)
12/12/83
- 18 -
TEN0 880
TENNECO OIL PAM 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 Allowed Device Emissions
Date Issued
1, None
2. -
3.
4.
y
6.
7.
List air operating permits presently in force:
Description of Date Expiration Allowed Monitoring Permit Unit Issued Date Emission Requirements
Reporting Requirements
1. R-4545
10/19/77 -
(F-8 Waste Fuels Boiler)
440 ppm SO2 None
0.10 lb particulate/ifu <lQt opacity
None
.2 R-944B
6/7/82
(PVC Plant)
852.8 T/Y VOC None 14.2 T/Y particulate
None
12/S/82
- 19 -
TENO 881
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (2)
When was the last air regulatory inspection? April 9, 1984 (Se.e Attachment 5) Please provide a copy of last inspection report. (Date)
Describe any noted deficiencies and the corrective action taken:
DEFICIENCY
CORRECTIVE ACTION
1. Incomplete tagging N_________Cylinder was properly tagged
.2 of VCM calibration gas_________________________________________
J 3. cylinder________________/
4.
5.
6.
12/8/82
- 20 -
TEN0 882
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (3) When was the last air emissions inventory? __
List reported emissions rates: 1. Hydrocarbons 0 ' 2. Sulfur Dioxide ' 3. Nitrogen Oxides 4. Carbon Monoxide 5. Particulate 6. Vinyl Chloride 7. 8.
1980 DATE
Tons/Year 795.2 0 2,022 1 1,114 A 3.6 7.1
What procedure is followed to report emission excursions to regulatory agencies? Please attach a copy of existing written procedure. Telephone notification of emission to ^regulatory agencies by operations
shift supervisor. Written notification by Manager - Environmental
Sciences within required time period.
Is this facility monitoring ambient air quality? **
Is a quality assurance program used? (Please provide quality assurance records.)
X
YES X Ye3
___
NO ___ NO
N7A* N/A
* Per participation in Houston Regional Monitoring System.
12/8/82
- 21 -
TENO 883
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
AIR (4)
What parameters are monitored?
SO?, TSP, Ozone, CO, N0V_____________________________
Meteorological Data
Has air monitoring data shown exceedances of air standards? X ___ ____ Te5 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:
Jt__ ___ YES NO "N7A
Does this facility have procedures to insure leaded gasoline is not used in
company vehicles designed for unleaded gasoline?
_X__ ___
YES NO ~N7A
If this facility dispenses more than 200,000 gallons of gasoline per year, do s it
have Stage 1 vapor control system installed?
____ ___ x
YES NO N7A
Who is responsible for gasoline health effects warnings? Leon Cox
Is gasoline health effects information posted in vehicle refueling areas?
__ ___ YES NO ~N7A
12/27/83
- 22 -
TEN0 884
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SOLID WASTE DISPOSAL (I)
Is this facility registered under the Resource Conservation and Recovery Act (RCRA)?
Generator Storer Treater Disposer Transporter What is the registration number? TXD 043749092
YES NO N/A X X
List any hazardous waste and the amount being generated and show if it is disposed of on or off-site.
See Attachment 6
ON OFF ^
List any solid waste and the amount being generated and show if it is disposed of on or off-site.
Plant trash - 10,000 yd^/yr( S?&
)
X
wJji^TES_ NO N/A
Is any hazardous waste disposed of in a landfill as free liquid?
If so, have arrangements been made for another type disposal of this waste after May 1985, since this practice will then be prohibited? 'Currently imHgrTriwai
X ______
X
Does this facility produce, distribute, or bum any fuel derived from hazardous waste? Discuss: Liquid hazardous wastes burned in Fo
X
If this facility is a treater, storer, or disposer (TSD facility), does it have a final RCRA permit?
Has this facility received its RCRA Part B application?
If yes, when is Part B application due?
Is Part 3 application being completed as per 40 CFR 264 & 270?
X X
12/27/84
- 23 -
TEN0 885
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SOLID WASTE DISPOSAL
(2)
II 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 N/A X
X T
IT T
Are uniform manifests used with each off-site load of hazardous waste?
Are all hazardous waste manifests accounted for?
Starting 9/1/85, generators must certify on their manifests that they have a program in place to reduce the volume and/or quantity and toxicity of their hazardous waste. Does this facility have such a program?
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?^
68
Number of drums
Is each drum dated when hazardous wastes are placed in the drum?
What is the present inventory of empty drums?_
66
See Attachment 7
Number of drums
12/27/84
24 TENO 886
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (3)
How are empty drums disposed of? Empty drums are crushed and shipped to CWM's Class 1
site for disposal.______________________
YES NO N/A
Are any empty drums given (sold) to employees or neighbors?
_____ X _____
Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material?
X ____ _____
What types of hazardous waste treatment are accomplished on site?
xx
Solar Evaporation Processing for Detoxification
Incineration Neutralization
Landfarming Fixation prior to burial Recycling
Biological Other____________________________
____ ______ _____
_____
x X
x X x
x x
Has TOC provided closure costs of on-site treatment and storage facilities?
___________ X
What is estimated cost? N/A
who estimated cost? N/A
Are ponds used in hazardous waste treatment?
_____ x ___
Are ponds in natural clay?
_____ ____ X
Are ponds lined with clay?
___________ X
How thick? N/A
What freeboard is maintained in ponds? N/A
What is expected 24-hour rainfall in a five-year period? 10"
Does this facility have an ongoing groundwater monitoring program?X_ ___
If facility has a final RCRA permit, what phase of GW monitoring
exists at present? Detection___ Compliance Corrective Action
N/A
If facility is still in interim status, is GW monitoring program in compliance with the interim status requirements?
_______________X
12/27/83
25
TENO 887
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (4)
How many monitoring wells are used?
How many wells are upgradicnt?
N/A
How many wells are downgradient?
N/A
How deep are the monitoring wells?
N/A
What are the wells monitored for? (40 CFR 265.92) N/A
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?
YE5 NO N/A X
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?o _____N_/A________________________
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
- 26 -
TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
Solid Waste Disposal (5)
Does this facility operate water wells?
What depth? 800 ft
How many? 2 *
List private drinking water wells near this facility.
Owner
Depth
1. None within one mile
2. _____ 3. __ 4. _
List industrial/commercial water wells near this facility.
Owner
Depth
Water Use
1. Shell
2. _
890 ft. Potable/Industrial
3.
4. __________________________________ _
List municipal or public water wells near this facility.
Owner
Depth
Water Use
1, None within one mile
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?
N/A
Have these discrepancies been corrected? (Provide a copy of last regulatory inspection.) See Attachment 8
* Four other wells are permitted, but not normally in use.
12/12/83
27 -
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. Chemical Waste Management-Port Arthur TXDOOQ761262
2. Chemical Waste Management-Lake Charles LAP000777201
3. Rollins Environmental Servlces-Baton Rouge LAD01039515 ^
4. Rollins Environmental Service^-Deer Park TXD055141378 ^
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.)
YES NO N/A __X
X _X
X
See Attachment 9
Are DOT approved containers and labeling used for off-site
delivery of hazardous waste?
eoo /
Estimated annual cost of off-site disposal? $130,000 ^
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? See Attachment 9_______
Have these discrepancies been corrected? See Attachment 9
*
* Neither CWM-Port Arthur or Rollins Environmental Services-Deer Park are currently accepting wastes that we generate.
12/12/83
- 28 -
JEN0 890
TENNECOOIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
UNDERGROUND STORAGE (1)
Does this facility have underground storage tanks?
X "yeT no n7a
Please tabulate information on underground storage including fuel tanks.
Tank
Identification
Unleaded
1. gasoline
2.
Leaded gasoline
3.
Tank Volume
1000 gal 3000 gpl
Material of Construction
carbon
steel csaterbeoln
Tank
23 yrs 23 yrs
Material
Stored unleaded
gasoline leaded gasoline
4.
5.
6.
7.
8.
9.
10.
How often is stored product inventory reconciled?
Weekly
What program is followed to insure early detection of potential leaks? These tanks are being replaced with above ground tanks. This should be
completed by March, 1985.
_________
_________
___
12/12/83
- 29 -
TENO 891
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
POLYCHLORINATED BIPHENYLS (PCB)
(I)
YES NO N/A
As of July 2, 1978, did this facility contain in service, stored for future use, or stored for disposal:
A. 30 or more large high or low voltage PCB capacitors?
B. One(1) or more PCB transformers?
C. 45kgs (99.4 lbs) or more PCB chemical substances or PCB mixtures?
Does the facility contain other PCBs, PCB equipment (e.g., lectromagnets, electric motors, hydraulic systems, heat
transfer systems, compressors), or containers of PCBs or PCB mixtures?
X X X
X
12/20/84
- 30
TENO 892
TENNECO OIL MtM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE (1)
Name of Pipeline! Tenneco VCM Pipeline from Shell
When was pipeline constructed?
4/14/73
What is pipe diameter?
4"
Length of pipeline?
5,400 ft.
What products are transported? VCM
Normal operating rate and pressure;
Maximum operating rate and pressure; Date of latest hydrostatic test; 4/14/73 at 2225 psig
Do current DOT regulations require additional pressure testing? ____,, x ___
YES NO N/A How often are pipeline rights-of-way inspected? Annually Who conducts these inspections? Tenneco Personnel (per annual cathodic protection (Provide a copy of a typical inspection.^eCt n
How often are navigable waterway crossings inspected?_ Are all line markers provided as required?__ Yes
N/A
Do the markers contain the proper wording as required as well as
emergency phone numbers?
Yes
How many pump stations are on this pipeline?_
One
What is the source of power?
Electric Gas Diesel
Yes x Yes___ Yes___
No___ No___ No___
N/A, N/A N/A.
What provisions are made to shut down pumps in event of pipeline leak? Notification by "hot line" between Shell and TPI. Local shutoffs at pumps. Remote air-operated valves on storage spheres.
12/8/82
- 31 -
TENO 893
TENNECO OIL WcM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE (2)
Are herbicides used to control right-of-way vegetation growth? If herbicides are used--what kind is used?____
_______ X_ ____ YES NO N/A
How applied?
Aerial_____
Ground
Are licensed applicators used to apply herbicide?
Have adjacent land owners complained about herbicide problems?
If so, give brief description.
____________ x YES NO N/A ____________ X YES NO N/A
Is cathodic protection provided for the pipeline?
_____________
What type? Magnesium Anode Beds______________________
YES NO N/A
How often is cathodic protection current measured? Annually
How often is cathodic protection pipeline to ground potential
measured ?Annually
(Please provide representative records of cathodic protection maintenance.)
How is the "Public Education" provision of 195.440 administered?
N/A( -n n'<j
What material, if any, is discharged from the pipeline during
testing or cleaning?
Water_____________________________
How often? Initial startup of pipeline only__________
Where?
TCI plant_______________________________
What is final disposition of material? Waste Treatment Unit
12/8/82
- 32 -
TENO 894
TENNECO OIL WtM ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE
(1)
Name of pipeline: Tenneco VCM Pipeline from B. F. Goodrich
When was pipeline constructed? H" ~ 4/14/73; 6*' - 11/13/80; 4 - 11/13/80
What is pipe diameter? 12"; 6'*. 4". Length of Pipeline? 12" - 13,800'; 6" - 770'; 4" - 1,200' (total 15,770')
What products are transported?VCM Normal operating rate and pressure: 280 gpm at 200 psig Maximum operating rate and pressure: 350 gpro at 300 psig Date of latest hydrostatic test: 12" - 11/13/80 at 2225 psig; 4" and 6'* - 11/13/80 at 750p
Do current DOT regulations require additional pressure testing? ____ X _____
YES NO N/A
How often are pipeline rights-of-way inspected? Annually Who conducts these inspections? Tenneco personnel - per annual cathodic protection
inspection
(Provide a copy of a typical inspection.)
How often are navigable waterway crossings inspected?
Ar all line markers provided as required?
Yes
Do the markers contain the proper wording as required as well as
em rgency phone numbers?
Yes
How many pump stations are on this pipeline? One
What is the source of power?
Electric Yes X
Gas Yes___
Diesel
Yes___
No___ No___ No___
N/A___ N/A___ N/A___
What provisions are made to shut down pumps in event of pipeline leak? Notification by "hot line" between Goodrich and TPI. Local shutoff at pumps.
Remote air-operated shutoff valves on storage spheres.
12/8/82
- 33 -
TEN0 895
TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
HIGHLY VOLATILE LIQUID PIPELINE (2)
Are herbicides used to control right-of-way vegetation growth? If herbicides are used--what kind is used?_____________________
X YES NO N/A
How applied?
Aerial_____
Ground
Are licensed applicators used to apply herbicide?
Have adjacent land owners complained about herbicide problems?
If so, give brief description.
____________ x_ YES NO N/A
___________ X
YES NO N/A
Is cathodic protection provided for the pipeline?
X______________
What type? Magnesium Anode Beds
YES NO N/A
How often is cathodic protection current measured? Annually
How often is cathodic protection pipeline to ground potential
measured ?Annually (Please provide representative records of cathodic protection maintenance.) See Attachment 10
How is the "Public Education" provision of 195.440 administered?
What material, if any, is discharged from the pipeline during
testing or cleaning?Wacer How often? Initial startup of pipeline only
Where?
TCI plant
What is final disposition of material? Waste Treatment Unit
12/8/82
- 34
TEN0 896
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
COMMUNITY RELATIONS/EMERGENCY PLANS
(1)
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?
Describe briefly how complaints are handled and name individual(s)
r sponsible for handling complaints. If written procedures exist,
please attach a copy.
^/
Any complaints are routed to Director - Operations. He assigns someone from plant to follow up, depending on nature of complaint;
When is the senior line manager responsible for local operations informed of citizen complaints?
ASAP
Who is responsible for reporting complaint information to the senior line manager?
Frank Koslosky
Does this facility have an Emergency Contingency Plan? (If so, please make a copy available.) See Attachment 11
Has the Emergency Contingency Plan been updated in the last 12 months?
Does this facility have a system set up to make timely notificati n of the occurrence of emergencies to TOC P&M (Houston)?
What individual is responsible to make timely reports of the occurrence of emergencies to TOC P&M Environmental Affairs Department (Houston)?
Jim Kachtick.
YES NO N/A
_X
1/S/S5
- 35 -
TENO 897
TENNECO OH. P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
COMMUNITY RELATIONS/EMERGENCY FLANS
(2)
With what local agencies has this facility discussed emergency procedures? (e.g. Sheriffs Department, Fire Department, etc*)
Channel Industries Mutual Aid Organization
Which of these agencies have been given Material Safety Data Sheets (MSDSs) or hazardous substance information sheets to make them more knowledgeable about the facility's prmcIpaTproducts? ______________________________________________________________________
None
List the principal products for which MSDSs or hazardous substance information sheets have been provided to local agencies: _____________--
None
Does this facility have a "neighbor warning" plan established, such as coordination with local
sheriff or police, telephone calling system, etc?
X ____
"yET no "n7X"
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.
Individuals from the Pasadena plant participate in various Tenneco-sponsored
activities, such as Volunteers In Action, Houston Chamber of Commerce, etc.
1/7/85
- 36 -
TENO 898
TENNECO OIL FftM 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 Faciliti s.
12/S/S2
37 -
x TENO 899
TENNBCO 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 DESCRIPTION SPECIFIC IMPROVEMENT NEEDED AGREE CORRECTIVE ACTION
DATE FOR COMPLETION OF IMPROVEMENTS
u
00
TEN0 900
S/16/8)
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/S/S2
39 -
TEN0 901
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS
SUMMARY 0
COMM ENTS
12/S/S2
- 40
TENO 902