Document 99oDRG6R13KpXEV4bk5pRnNg6
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TOC PAM Bnvi romantal Affairs
(COMPANY)
INTEROFFICE COMMUNICATION
TO: Tenneco Polymers FOR: Rod Neugold FROM: R. D. Pruessner RE: ENVIRONMENTAL REVIEW
DATE: May 17, 1985
Your approval is requested for scheduling the Environmental Review of the Burlington Plant on July 23-25, 1985.
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.
P Enclosure
pc: Charles Beresford Russell Bowers Walt Fogelsanger Jim Kachtick Fred Kanzler Frank Koslosky Ralph Maynard A1 Smith f Lloyd Stewart
/tfgR. D. Pruessner
RECEIVED
MAY 17 1985 toclegaip&m
TENO 426
LTV* g*1-A
AGENDA
ENVIRONMENTAL REVIEW Tenneco Polymers - BURLINGTON PLANT
July 23-25, 1985
Tuesday, July_23
11:15 a.m. Depart Houston Intercontinental on Continental 372.
3:00 p.m. Arrive Philadelphia airport. Obtain large Avia car and drive to Burlington, New Jersey.
About 5:00 p.m. Check in Hilton on Highway 295 in Mount Laurel,
New Jersey.
6:30 p.m.
Supper for the Review Teas and Polymers' representa tives at the Village Inn, Route 541. Fred Kanzl r will please make reservations for the Review Team (5 people) from Houston and the Burlington plant staff.
Wednesday, July_24
8:00 a.m. Meet with Ron Neugold to confirm final plans for Environmental Review.
8:15 a.m. Meet with Fred Kanzler and staff to go over the information contained in completed Environmental Review forms.
11:30 a.m. LUNCH
1:00 p.m. Meet with Fred Kanzler for plant tour.
4:00 p.m. Adjourn
5/17/85
1- -
TEN0 427
(
AGENDA
ENVIRONMENTAL REVIEW Tenneco Polymer* - BURLINGTON PLANT
July 23-25, 1985
Thursday, July_25
8:00 a.m. Review wastewater treatment plant performance status.
9:00 a.m. Review groundwater monitoring program status.
10:00 a.m. Review overall plan for future handling of solid waste and the dewatering facilities.
11:15 a.m. LUNCH (Please provide sandwiches in plant.)
12:00 noon Draft proposed conclusions of Environmental Review.
1:00
p.m.
Meet with Ron Neugold and staff to review proposed findings and complete the final report. Provid copies of completed report to Ron Neugold, Fred Kanzler, Jim Kachtick, Frank Koslosky, Russell Bowers and Bob Pruessner.
2:00 p.m. Depart for Philadelphia airport.
3:45 p.m. Catch Continental 371 for Houston.
6:04 p.m. Arrive Houston Intercontinental.
5/17/85
2- -
TEN0 428
fr
TENNECO OIL P&M FACILITIES
ENVIRONMENTAL REVIEW
TENNECO POLYMERS - Burlington Plant POLYVINYL CHLORIDE FACILITIES
5/15/85
TENO 429
TENNECO OIL PAM ENVIRONMENTAL REVIEW
Name and address of facility:
Tenneco Polymers Burlington Plant P. O. Box 116 Burlington, New Jersey 08016
July 23-25,1985
Affiliated with: Tenneco Oil P&M
Operations Manager;
Ron Neugold_______________ (Name)
Plant Manager____________________ (Title)
Environmental Representative;
Fred Kanzler (Name) ~
______
Environmental Coordinator (Title)
Type of operation and/or principal products:
Polyvinyl Chloride
(609) 386-9200 (Phone)
(609) 386-9200 (Phone)
Review Team: Nam
Title
Phone
Bob Pruessner Charles Beresford Jim Kachtick Lloyd Stewart Walt Fogelsanger
Mgr. Environmental Affairs-TOC Attorney - TOC Legal Mgr.Environmental Sciences-TOC Mgr.Environmental Audits-TEN Plant Engineer-Polymers
(713) 757-3306 (713) 757-8764 (713) 479-3M1 (713) 757-4100 (201) 782-4011
5/15/85
TEN0 430
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TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT 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 H. R. Bowers_____________ Title Vice President - Chemicals
Name
Frank Koslosky
Title Director of Operations
Name Title
Name Title
Name Title
5/15/85
TENO 431
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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.
NAME
TITLS
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:_____________________
5/15/85
TENO 432
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (1)
NPDES Permit No.:
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:
2/17/83
TEN0433
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (2)
Date and significant findings of last regulatory inspection: (Please attach copy of regulatory inspection report.)
YES NO N/A
Do any discharge permits contain a compliance schedule? 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? How often? _____ 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: __________ ________________________
5/15/85
TENO 434
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (3)
Permittee is using method of sample collection required by permit? If not, explain method used and the frequency of sampling: ____________________________________________ _
YES NO
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 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?
5/15/85
TENO 435
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 Commercial laboratory used? If so, name: ________________ Commercial laboratory state certified? ________________ 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 NB5 weights?
Are glucose-glutamic acid standards analyzed with each set of samples analyzed for BODs?
Is Class A volumetric glassware used for perm it-required analyses?
6/26/84
TENO 436
TENNECO OIL P&M ENVIRONMENTAL REYIEW
TENNECO POLYMERS - BURLINGTON PLANT
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? Ar sample results kept for the required three-year period? Are quality assurance and quality control records kept for the required three-year period?
Weeds cut and vegetation growth in ponds removed?
Banks and dikes maintained? (Erosion, etc.)
Seepage reported?
Adequate freeboard (2 feet) to prevent overflow?
Effluent release is:
Continuous
Intermittent ____ Seasonal
What is the receiving stream?
5/15/85
(f
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
WATER (6)
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:
YES NO N/A _____ ____ ____
___________ _____ _____ _____ ____ _____ ____ ____
_________________
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?
Is this facility a "major facility" as defined in the New Jersey Water Pollution Control Regulations, i.e., N.J.A.C. 7:1 E-1.3(k)?
If so, has a Discharge Prevention, Containment or Countermea sure (DPCC) Plan and Discharge Cleanup and Removal (DCR) Plan been prepared in accordance with N.J.A.C. 7:1 E-4.5 and 7:1E-4.21?
Have the DPCC and DCR Plans been approved by the NJDEP, Division of Water Resources?
Have the DPCC and DCR Plans been approved by management?
Have the DPCC and DCR Plans been reviewed and evaluated in the last three years?
Has the NJDEP, Division of Water Resources ever inspected this facility for compliance with the DPCC and DCR Plans?
If so, when?
Results:
____________________
6/26/84
TENO 438
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TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
WATER (7) YES NO
How is storm water treated?
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 439
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)
(1) YES NO N/A
What type(s) of PVC resin is produced:
Dispersion resin Latex 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 device(s) 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
__________
____________
5/15/85
TENO 440
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TENNECO OIL PJcM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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?________________________________ What 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.)
4/25/83
TENO 441
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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.
List air operating permits presently in force:
Description of Date Expiration Allowed
Permit Unit Issued Date
Emission
1.
2.
3.
4.
5.
6.
7.
8.
9.
Monitoring Requirements
Reporting Requirements
12/8/82
TENO 442
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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*
Is this facility now in compliance with Subchapter 16 of the New Jersey Regulations (this subchapter addresses VOS)?
Comments:___ ____________
______________ _______
Is this facility now in compliance with Subchapter 17 of the New Jersey Regulations (this subchapter addresses TVOS)?
Comments:_______________________________ ________ _____
6/23/83
TENO 443
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
AIR (3) When was the last air emissions inventory?
List reported emissions rates: 1. Hydrocarbons 2. Sulfur Dioxide 3. Nitrogen Oxides 4. Carbon Monoxide 5. Particulate 6. Vinyl Chloride 7.
8.
DATE Tons/Year
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? (Please provide quality assurance records.)
12/8/82
___ _ ___ YES NO ____ ___
YES NO
N/A n7a
TENO 444
(c
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 N/A
If this facility dispenses more than 200,000 gallons of gasoline per year, does it
have Stage I vapor control system installed?
____
YES NO N/A
Who is responsible for gasoline health effects warnings?
Is gasoline health effects information posted in vehicle refueling areas?
12/8/82
YES NO ~N7A TEN0 445
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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.
YES NO N/A
Is any hazardous waste disposed of in a landfill as free liquid?
If so, were arrangements made for another type disposal
of this waste after May 1985, since this practice then
prohibited?
_____ ____ ____
Does this facility produce, distribute, or burn any fuel derived from hazardous waste? Discuss:
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 B application being completed as per 40 CFR 264 <5c 270? _____ ________
5/15/85
TEN0 446
TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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 N/A
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 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?_ Number of drums
5/15/85
TENO 447
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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?
YES NO _____ ___
__________
N/A
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?
6/26/84
TENO 448
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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? (If so, please provide list of back ground concentrations.)
YES NO N/A _____ ____ ____
Does this background information indicate any groundwater contamination? (Make data available.)
_____ ___________
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?
5/15/85
TENG 449
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TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
SOLID WASTE DISPOSAL (5)
YES NO N/A
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.)
12/12/83
TENO 450
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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? 3/2/83
TENO 451
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
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?
3/2/83
TENO 452
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
POLYCHLORINATED BIPHENYLS (PCB) (I)
As of 3uly 2, 1978, did this facility contain in service, stored for future use, or stored for disposal:
YES NO N/A
A. 50 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., electromagnets, electric motors, hydraulic systems, heat
transfer systems, compressors), or containers of PCBs or PCB mixtures?
An annual inventory of PCBs is required if the facility has PCB equipment (equal to or greater than is shown in A,B,or C above).
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?
12/8/82
TENO 453
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TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS - BURLINGTON PLANT
POLYCHLORINATED BIPHENYLS (PCB) (2)
Does the PCB storage area meet the following requirements:
YES NO N/A
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 not have any drains, valves, expansion joints, sewer lines or other openings. Does storage facility meet these requirements?___________ _____
D. All 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 program.
12/8/82
TENO 454
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TENNECO OIL PAM ENVIRONMENTAL REVIEW
TBNNECO POLYMERS -- FLBMINGTON PLANT
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?
What percent of the neighborhood coaplaints received
relate to:
Air
Water
Noise Spills
Solid Waste Disposal
Other
TOTAL
____________ _____
____________ _ ______ 100*
What percent of the coaplaints investigated relate to this facility?
Describe briefly how coaplaints are handled and naae individual(s) responsible for handling coaplaints. (If written procedures exist, please attach a copy.)
When is the senior line manager responsible for local operations informed of citizen coaplaints?
Who is responsible for reporting coaplaint information to th senior line manager?
YES NO N/A Does this facility have an Emergency Contingency Plan? (If so, please Bake a copy available.)
Has the Emergency Contingency Plan been updated in the last 12 months?
Does this facility have a system set up to make timely notification f the occurrence of emerg ncies to TOC PAM (Houston)?
5/15/85
TENO 455
TENNECO OIL P*M ENVIRONMENTAL REVIEW
TENNECO POLYMERS -- FLEMINGTON PLANT
COMMUNITY RELATIONS/EMERGENCY PLANS (2)
What individual is responsible to sake timely reports of the occur rence of emergencies to TOC P&M Environmental Affairs Department (Houston)?
With what local agencies has this facility discussed emergency proce dures? (e.g. Sheriff's Department, Fire Department, etc.)
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 principal products?
List the principal products for which MSDSs or hazardous substance information sheets have been provided to local agencies:
Does this facility have a "neighbor warning" plan established, such as
coordination with local sheriff or policy, telephone calling syst ms,
etc.?
YES______ NO______ N/A
Briefly describe activities this facility has participated in the last 12 months to enhance community relations. Typical activities ar 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.
5/10/85
TENO 456
/(
TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - BURLINGTON PLANT
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 457
TENNECO OIL P&M ENVIRONMENTAL REVIEW
SUMMARY
----------125----------
TENNECO POLYMERS - BURLINGTON PLANT
THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION:
ITEM # DESCRIPTION , SPECIFIC IMPROVEMENT NEEDED
DOES
LOCAL INDIVIDUAL RESPONSIBLE MGMT FOR COMPLETION OF AGREE. CORRECTIVE ACTION
DATE FOR COMPLETION OF IMPROVEMENTS
TENO 458
5/18/83
f(
TENNECO OIL PAM 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
TENO 459
<I
TENNECO OIL P&M ENVIRONMENTAL REVIEW
TENNECO POLYMERS SUMMARY (4)
COMMENTS
12/8/82
TENO 460