Document 99LEOpKEg6qwZG90maggam8oV
CM /
CHEMICAL MANUFACTURERS ASSOCIATION
May 15, 1985
TO SELECTED EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES
Dear Executive Contact s
As you are aware, a great deal of Congressional attention has been focused on the adequacy of existing regulations for toxic air emissions. In February, Congressman Henry A. Waxman requested information from many CMA members on releases to the atmosphere. Congressman Waxman's request was not coordinated through CMA, and the substance of the request was not clear. However, based on responses to his request. Congressman Waxman compiled a list of 196 "unregulated air toxins".
Recently, CMA received the attached request from Congressman John D. Dingell, Chairman, House Subcommittee on Oversight and Investigations, to obtain information from our members on monitoring and detection systems and emergency response systems. Chairman Dingell has requested CMA to select three specific areas and survey its members with plant facilities located in these areas. We have responded to Chairman Dingell that this survey will be coordinated by CMA and conducted in a timely manner. Cooperation in this survey has been endorsed by the CMA Executive Committee.
Today, we request your assistance in completing this project. An Environmental Management Committee Task Force has selected the following areas to survey:
o New Orleans/Baton Rouge Corridor - includes the Parishes of Ascention, East Baton Rouge, Jefferson, Iberville, Livingstone, Orleans, Plaquemine, St. Bernard, St. Charles, St. James, St. John the Baptist, West Baton Rouge.
o Philadelphia/Wilmington/South New Jersey - includes the Counties of Bucks, PA) Chester, PA; Delaware, PA; Montgomery, PA; Philadelphia, PA; Burlington, NJ; Camden, NJ; Glouchester, NJ; Mercer, NJ; Salem, NJ; and New Castle, DE.
o Niagara Falls/Buffalo - includes the Counties of Erie and Niagara, NY.
CMA has prepared a questionnaire which will facilitate your response to Chairman Dingell*s request. We have enclosed copies of the attached questionnaire to be forwarded to your plant facilities located in the three areas. Our information indicates that your company has the following number of plant facilities within each area:
New Orleans
Philadelphia
Niagara Falls
120
Formerly Manufacturing Chemists Association--Serving the Chemical Industry Since 1B72. 2501 M Street. NW Washington. DC 20037 Telephone 202/887-1100 Tele* 89617 (CMA WSH)
BOR 014573
Executive Contacts May 15, 1985 Page 2
Please notify CMA, (see contact below) if the information on plant facilities in these three ^reas is incorrect. We recognize that there will be additions and deletions to our plant list. The questionnaire has been prepared to respond to the needs of Chairman Dingell and to be responsive to time constraints. Please forward your completed question naire by June 14 directly to:
Mr. William P. Gulledge Chemical Manufacturers Association 2501 M Street, NW Washington, O.C. 20037 (202) 887-1188 All the completed questionnaires will be forwarded directly to Chairman Dingell shortly thereafter. CMA has scheduled two workshops to assist corporate and/or plant personnel in completing the questionnaires: May 24-New Orleans Sheraton, 8:00 a.m, - 12:30 p.m. e May 28-Cherry Hills Hyatt, NJ, 12:00 p.m. - 5:00 p.m. Please contact Ms. Romy Pettersen at (202) 887-1183, as soon as possible, with the names of individuals who will be registering for these workshops. Persons responding to the survey should contact w. p. Gulledge with any technical questions. CMA strongly believes that participation in this effort is vital to communicating to Congress the presence of chemical industry monitoring and detection systems and emergency response systems for hazardous air pollutants. A high response rate on this questionnaire is an essential element for CMA being able to effectively advocate on hazardous air pollutant issues before Congress. We appreciate your timely assistance in this very important effort.
ec: Environmental Contacts
BOR 014574
* CMA QUESTIONNAIRE ON MONITORING AND DETECTION SYSTEMS AND EMERGENCY RESPONSE
(This page will be removed prior to submission to Congressman Dingell. The information given below will be used by CMA and/or its contractor, TRC Environmental Consultants, to contact individuals preparing a given response. Contact will be made as needed to clarify answers. A separate cover letter to be included in your response to Congress man Dingell may also be submitted, if desired.) Name, Title and Phone Number of Key Individual Responding to This Questionnaire
Company/Plant Name and Address
BOR 014575
CMA QUESTIONNAIRE ON MONITORING AND DETECTION SYSTEMS AND EMERGENCY RESPONSE SYSTEMS
1. Company Name -j-2. Location (City, State, County)
PLEASE ANSWER ALL OF THE FOLLOWING QUESTIONS WITH REGARD TO SIC 2800 ONLY.
GENERAL FACILITIES INFORMATION
3. What are the major product lines of this facility according to the 2800 Series SIC codes listed below? (please check all that apply)
______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ______ ____ _ ______ ______ ______ ______ ______ ______ _____ ______ ______ ______ ______ ______ ______ ______ ______ ______
Alkalies and Chlorine Industrial Gases Inorganic Pigments Industrial Inorganic Chemicals Plastics Materials, Synthetic Resins and Nonvulcanlzable Elastomers Synthetic Rubber Cellulosic Manmade Fibers Synthetic Organic Fibers Botanical Products Medicinal Chemicals and Biological Products Pharmaceutical Preparations Soap and Other Detergents Specialty Cleaning, Polishing, and Sanitation Preparations Surface Active Agents, Finishing Agents Perfumes, Cosmetics and Other Toilet Preparations Paints, Varnishes, Lacquers, Enamels and Allied Products Gum and Wood Chemicals Cyclic Crudes, Cyclic Intermediates, Dyes and Organic Pigments Industrial Organic Chemicals, Not Elsewhere Classified Nitrogenous Fertilizers Phosphatlc Fertilisers Fertilizers, Mixing Only Pesticides and Agricultural Chemicals, Not Elsewhere Classified Adhesives:and Sealants Explosives Printing Ink Carbon Black Chemicals and Chemical Preparations, Not Elsewhere Classified
4. Approximately how many products are produced at this facility? Number of Products
BOR 014576
5. How many process units are present in your facility?
(A "process unit" is defined as components assembled to produce, as intermediate or final products one or more chemicals. A process unit should be able to operate independently if it is provided with sufficient feed or raw materials and storage facilities for the product.)
Number of Process Units
6. Please list all materials that are used at this facility in the manufacture of chemicals for commercial distribution. This would include raw materials, isolated intermediates and products. (Do not include un-isolated intermediates or research quantity materials not intended for commercial distribution.)
(Use additional pages as necessary) 2
BOR 014577
L7. What is the approximate population within: 1-100 101-10000
1/2 Mile 1 Mile 2 Miles 5 Miles
1001-10000
10001100000
Greater than 100000
8. How many company employees work at this facility?
OPERATIONAL CONTROLS
9. In this facility, approximately how many of the following devices are used for operational control of process units, and material handling and storage?
Quantity
0
1-10
11-100 101-1000 1001-10000 Over 10000
Vibration Monitoring Corrosion Monitoring Stress Monitoring Temperature Sensors Pressure Sensors Flow Sensors Level Indicators pH Meters Specific Gravity
Indicators Oxygen Detectors Specific Gas Analyzers
(e.g., chlorine, H^S) Gas Chromatographs Oxidation-Reduction
Potential Indicators Moisture Detectors
_____ _____ _____ _____ _____ _____ _____ _____
_____ _____
_____ _____
_____ _____
_____ _____ _____ _____ _____ _____ _____ _____
_____ _____
_____ _____
_____ _____
Explosive Vapor Monitors _____ _____
_____
_____
_____
_____
10. Which of the above devices would be used for prevention, early warning, or detection of potential or impending releases? Explain.
3 BOR 014578
11 Are there other procedures/systems in use which would help prevent upset releases to the atmosphere? Please explain.
12. Please Indicate how the outputs of the devices listed below are generally monitored.
Indicate the approximate number of devices monitored by each method.
Directly Wired
Local
Control Room Chart
to Process
Indicator Indicators
Recorders Control System
Vibration Monitoring Corrosion Monitoring Stress Monitoring Temperature Sensors Pressure Sensors Flow Sensors Level Indicators pH Meters Specific Gravity
Indicators Oxygen Detectors Specific Gas Analyzers
(e.g.t chlorine, H2S) Gas Chromatographs Oxidation-Reduction
Potential Indicators Moisture Detectors
Explosive Vapor Monitors
Other (explain):
13. Which of the following guidelines determine frequency of inspection and maintenance
on these control devices?-----
Prompts from
Standard Product
Preventive
Operating Quality Malfunction Maintenance
Safety
Procedures Control Indicator
System
Procedures
Vibration Monitoring Corrosion Monitoring Stress Monitoring
4 BOR 014579
Temperature Sensors Pressure Sensors Flow Sensors Level Indicators pH Meters Specific Gravity
Indicators Oxygen Detectors Specific Gas Analyzers
(e.g,, chlorine, H^S) Gas Chromatographs Oxidation-Reduction
Potential Detectors Moisture Indicators Explosive Vapor Monitors Other (explain): _________
Is this facility subject to routine inspections or audits? If so, please discuss types of audits (e.g. environmental, industrial hygiene or safety), frequency and scope.
BOR 014580 5
Please complete questions 15 through 23 for each process unit including related storage and handling. (Copy additional question sheets for each unit as required.)
EMISSIONS MONITORING AND DETECTION (ROUTINE AND ALLOWABLE)
15. Identification of Process Unit _____________________ __________________________________ -- 16. Identify ambient chemical monitoring systems or devices used at this process unit.
Fixed Point, Continuous Monitoring
______
Displays Real-Time Concentration
____ _
Signals at Predetermined Concentration _____
Portable Gas Detectors t ______
Detector Tubes
Personal Dosimeters (Digital Display or Alarm) ______
Industrial Hygiene Sampling Monitor
Grab Samples
______
Detection of Odors by Operating Personnel
______
Other (describe)t
______ ______________________________
17. For the devices/systems listed above in Question 16, where are sensor and sampling points located?
Ls s$
a s s
/ / JC
fr hs3g$,
k c las fe*
H N?
Fixed Point Continuous Monitoring
Portable Gas Detectors
Detector Tubes
Personal Dosimeters (Digital Display or Alarm)
Industrial Hygiene Sampling Monitor
Grab Samples
Detection of Odors by Operating Personnel
Other (describa)
Please explain sensor location rationale.
6 BOR 014581
18. Identify any stack or vent monitor systems or devices used at this process unit.
Grab Samples Fixed Point, Continuous Monitoring
______
Displays Real Time Concentration Signals at Predetermined Concentration
Flame detectors (e.g. Flares) Other (describe): __________________________ ________
BOR 014582 7
19. * What guidelines determine how often ambient and in-stack/vent monitoring devices are used?
,
- >"-I
|| i?
,,
IJ
aI, 1S*"P*m$*o1ta|m**8831*zr.T1
luofOl# fxHtwo* sSo**L *
AMBIENT Fixed Point Continuous Monitors Portable Gas Detectors
Detector Tubes Personal Dosimeters Industrial Hygiene Sampling Monitors Drab Samples
Ddor Monitoring Dther
IN-STACK/VENT
Drab Samples
Fixed Point Continuous Monitor Flame Detector te.g., flare]
Dther
20. What guidelines determine frequency of inspection and maintenance on-` ambient and in-stack devices?
AMBIENT Fixed Point Continuous Monitors portable Cas Detectors
Detector Tubes personal Dosimeters Industrial Hygiene
Sampling Monitors Crab Samples bdor Monitoring`
pther
IN-STACK/VENT
Crab Samples
Fixed Point Continuous Monitor
name Detector te.g., flare)_______
father
-8-
BOR 0X4583
Please list the specific chemicals or classes of compounds detected by ambient and in-stack systems.
Ambient
Chemicals
Grab Samples
________ .-________ --
Personal Dosimeters
_
Continuous Monitors _____________
Portable Gas Detectors ________________ _________________________________ .
Detector Tubes
_______
Industrial Hygiene Sampling Monitors
'
Detection of Odors
Other
___________________________________________.________________
In Stack/Vent
Grab Samples
_______________________________________________ ________
Continuous Monitors___
Flame Detectors
_
Other
___________________________________________________________
22. How are routine emissions to the atmosphere determined for this process unit?
Measured Calculated by:
Material Balance EPA Emission Factors Process Design Engineering Estimates Other (describe):
Please consent on how often these are updated and how they are recorded.
9 BOR 014584
23. How are routine emissions to the atmosphere determined for storage units?
_________
_________
__ _______ _________ _________
Measured Calculated by:
Material Balance EPA Emission Factors Process Design Engineering Estimates Other (describe) :
___________
Please comment on how often these are updated and how they are recorded.
PERIMETER AND COMMUNITY MONITORING PROGRAMS
24. If appropriate ^ please describe additional monitoring programs, (perimeter, community, etc.) and the frequency of such monitoring.
25. Please indicate the meteorological parameters that are monitored at this facility.
Unit Location
Plant Property
Off-Property Sites
Vlnd Direction Vind Speed Temperature Sigma Theta Delta Temperature Relative Humidity/ Dev Point
NON-ROUTINE RELEASES AND EMERGENCY RESPONSE
26. For each of the following systems, please Indicate the chemicals in use at this facility for vhlch this type of monitoring system would provide an Indication of an unintentional or non-routine release to the atmosphere.
Chemicals
On-Site Monitoring By Operating Personnel (e.g. visual, odor)
Personnel Monitors
In-Stack Monitors
Process Equipment Monitors
11 BOR 014586
In-Process Area Monitors Process Unit Perimeter Monitors Plant Perimeter Monitors Community Monitors
Comments
For each type of monitoring system described above, select one chemical and provide an explanation including the following:
Number of Sensors Location of Sensors Type of Recording System Location of Alarms Rationale for Selecting Monitoring System
On-Site Monitoring By Operating Personnel (e.g. visual, odor)
Personnel Monitors
Chemicals
In-Stack Monitors
Process Equipment Monitors
In-Process Area Monitors
12 BOR 014587
Process Unit Perimeter Monitors
Plant Perimeter Monitors
Community Monitors
Comments
28. Is there an emergency response plan at this facility? Yes No
29. Please identify the title of the person(s) designated to contact public safety officials in the event of an emergency.
30. Should this person be unavailable on-site* who is on-call to respond* (title);
Comments
___ ________________
31. What is the estimated lag-time between detection of a release requiring emergency action and contacting public safety officials?
Comments
32. How often are plant emergency response procedures reviewed/revised?
_________ ______ ___
Every 6 months 6 Months to 1 Year
1 to 2 Years 2 Years or more
13 BOR 014588
Please identify agencies with which this facility coordinates its emergency response plans;
Local Fire Department Local/County Police Local Civil Defense State Police Industry Mutual Aid Assn. Federal Emergency Management Agency (FEMA) Hospital Emergency Rooms Other(please explain)
34. Indicate the number of times per year this facility regularly participates in the following?
Emergency Response Drills with Public Safety Personnel (e.g. fire department) Emergency Response Drills with Federal Agencies (e.g., Coast Guard) Emergency Response Drills with Mutual Aid Association Other (please explain)________________________________________ _
35. What company resources are available to assist public safety officials in the event f an emergency?
_______ _______ _______ _______ _______ _______
Personnel Equipment Technical Assistance to Evaluate Impact Communication Network Trained Emergency Response Team Other (please explain)_________________ _______________________
36. Please describe the emergency response procedures/systems employed at this facility (Include key highlights of special features, e.g., automation, use of special equip ment, dispersion modeling, training drills etc.)
14 BOR 014589
37. Please describe your system, computerised or otherwise, for predicting the speed and direction of a releases.
15 BOR 014590
Please Indicate which of the following emission reporting requirements apply to your facility.
EMISSION REPORTING REQUIREMENTS
38. FEDERAL NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Fossil Fuel-Fired Steam Generators [incinerators [Nitric Acid Plants Sulfuric Acid Plants Wet-Process Phosphoric Acid Plants Super Phosphoric Acid Plants [Dlammonlum Phosphate Plants Triple Super Phosphate Plants Granular Triple Phosphate'Storage Facilities Stationary Gas Turbines Lime Manufacturing Plants Ammonium Sulfate Manufacture [Equipment Leaks in the Synthetic Organic Chemical Manufacturing Industry Synthetic Fiber Production Facilities Other
39. FEDERAL NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPs)
Mercury Vinyl Chloride Equipment Leaks of Benzene Other ____ ___ _________________________
40. STATE EMISSION REPORTING REQUIREMENTS
(Please answer for the state where the facility is located.)
I. Delaware
______ Report of discharge in absence of permit or in excess of permit conditions ({6028 of Delaware Environmental Protection Lav)
______ Report of excess emissions from facility required to install continuous monitoring system (Regulation No. XVII, 14.1; Regulation No. XX, f 1.2(3))
Report of emission of potentially hazardous particulate matter (Regulation No. V, 7)
Other
16 BOR 014591
41. LOCAL EMISSION REPORTING REQUIREMENTS Does the city, town, county or other local entity in which this facility is located have laws or regulations which require reporting of chemical emissions? ________ If so, please provide the following information as to each such requirement.
Data Reported Responsible Agency Frequency of Reporting Penalties for Late, False, or No Report
42. EMISSION REPORTING REQUIREMENTS IN PERMITS AND SIP's
Please provide the following information for permit or State Implementation Plan (SIP) provisions which require reporting of chemical emissions by this facility.
Data Reported___________________________
Responsible Agency. Frequency of Reporting Penalties for Late, False, or No Report
*
43. Please indicate, for the reporting requirements which apply to this facility, whether you believe these requirements are adequate, onerous, duplicative or otherwise unnecessary. Also suggest any possible improvements in these requirements.
18 BOR 014593
NOTE:
Emission reporting is also required under the Comprehensive Environmental Response, Compensation and Liability Act (Superfund).
Section 10$ requires reporting of any release of a hazardous substance in excess of the reportable quantity. Since this requirement applies to all facilities, CMA will address this requirement In its portion of the overall response to Congressman Dingell.
44. OTHER
If there are other Issues in Congressman Dingell's letter you wish to address, please use the space below:
BOR 014594 19