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ABD00023302 ENVIRONMENTAL MANUAL Table of Contents I INTRODUCTION A Revision II. REGULATIONS A CWA B. CAA C. NESHAP D. SARA (Superfund) E. RCRA F. CERCLA G. TSCA H DOT I. Spill Prevention Control and Countermeasures 1 SPCC Plan 2. RCRA Hazardous Waste Contingency Plan III AGENCIES A Regulatory B Spill/Release Reporting IV PERMITS A Air Emissions Equipment B Construction of Air Emission Equipment C. Water Pollution Control D. Historical Emissions of VCM E. Air Permitting Process V MANIFESTS A. Examples B. Instructions VI ENVIRONMENTAL OFFICE MAP VII REPORTING AND SPILL CHECKLIST A Yearly Reporting Due Dates B. Release and Spill Reporting 1. Reportable Quantities, SARA 2. Reportable Quantities, CERCLA 3. National Response Typical Questions 4 Spill/Response Report 5. Spill/Release Prevention Report 6. Hazardous Material Release Report C. Superfund Reporting Checklist D Plant Entry of Governmental Agency Personnel 1-2 2-2 2-2 2-3 2-6 2-7 2-9 2-12 2-14 2-15 2-16 2-28 3-2 3-2 4-2 4-14 4-26 4-42 4-57 5-2 5-5 7-1 7-2 7-4 7-5 7-6 7-8 7-9 7-10 7-11 7-14 ABD00023303 ENVIRONMENTAL MANUAL Table of Contents (Continued) VIII a to APPENDIX A Acronyms B Resources C References Trade Associations Example EnvironmentalSituations 1. Rupture Disk Failure 2 Reactor Leaks to Sewer 3 VCM Relief Valve Lifts 4 Oil on Outfall 5 Blend Tank Overflow 6 Acid Spill on Slag 7 Waste Water Permit Violation F Health Effects of Vinyl Chloride 8-1 8-3 8-3 8-3 8-4 8-5 8-6 8-8 8-10 8-12 8-13 8-15 8-16 ABD00023304 INTRODUCTION ABD00023305 INTRODUCTION The purpose of this handbook is to provide instruction and direction to those persons administering environmental policy in the absence of the plant Environmental Coordinator This may be used as a reference manual Because policies and regulations are always changing, it will be important to revise this handbook quarterly It is the responsibility of the Environmental Coordinator to keep this handbook current The second page of this introduction will list the latest revisions and the dates of those revisions 1-1 REVISION First Issue Second Issue ABD00023306 INTRODUCTION ('continued') DATE 06/29/89 04/01/90 1-2 ABD00023307 REGULATIONS ABD0002330 REGULATIONS CWA CAA - CLEAN WATER ACT - CLEAN AIR ACT NESHAP SARA RCRA CERCLA TSCA - NATIONAL EMISSION STANDARDS FOR HAZARD DUS AIR POLLUTANTS - SUPERFUND AMENDMENTS AND REAUTHORIZATION -CT - RESOURCE CONSERVATION AND RECOVERY ACT - COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT - TOXIC SUBSTANCES CONTROL ACT DOT REGULATIONS - DEPARTMENT OF TRANSPORTATION ABD000233G9 CLEAN WATER ACT - CWA The Clean Water Act was passed by Congress in the 1970's It set water quality standards for State and Local Water Quality Management Plans, effluent limitations for direct discharges and pretreatment standards, established the NPDES Permit System which regulates the discharge of pollutants into navigable waters and established rules regarding reporting, preventing and cleaning up spills of oil and hazardous substances CLEAN AIR ACT - CAA The Clean Air Act Amendments passed by Congress in 1970 and 1977 to the Air Quality Act of 1967 It says that prevention and control of ambient and emission air quality standards is the responsibility of state and local governments supervised and approved by the EPA This act formed the following three programs which can be directly enforced by the EPA NAAQS National Ambient Air Quality Standards sets maximum concentration levels for various pollutants to protect public health NSPS Established national emission standards for new sources (New Source Performance Standards) NESHAP National Emission Standards for Hazardous Air Pollutants includes 8 pollutants, one of which is Vinyl Chloride Monomer NAAQS apply to six "criteria" pollutants presently, sulfur dioxide, particulate matter (dust), nitrogen dioxide, lead, carbon monoxide, and ozone The EPA is responsible for reviewing and publishing these standards The NSPS provide nationally uniform standards to prevent individual states from lowering emission standards in order to attract industry They are developed by category of industrial source and are based on the pollution control technology available to that category of source A new source is a modified source that undergoes a physical change, or a change in method of operation, which results in new or increased emission of any pollutant NSPS pertain to sulfur dioxide emissions from coal and oil-fired industrial steam generating units Also particulate matter and nitrogen oxide emission limits were promulgated VOC emissions from this facility come under NSPS 2-2 ABD00023310 ABD00023314 To Vinyl and Support Department Employees interoffice Communication From Date Subiect R. W. Seymour May 20, 1988 ABERDEEN PLANT EARNS ENVIRONMENTAL AWARD Congratulations to the Vinyl Department employees and the employees in their support groups (maintenance, process and project engineering, laboratory, environmental, safety). Aberdeen Plant employees were awarded the Vinyl Institute (a division of The Society of The Plastics Industry, Inc.) Environmental Achievement Award in recognition of outstanding performance for 1987 in the PVC category. Vista Chemical Company's plant in Aberdeen received the first place award for 1987. The award was presented to plant employees today by T. H. Huffman, General Manager, VCM and Polymers, in the vinyl control room. This award was presented to Vista for having a performance index of 100 or a perfect score calculated by a formula developed by the Vinyl Institute. This perfect score means that during the entire year 1987 the Aberdeen plant had no: - relief valve discharges - rupture disk, releases - residual VCM exceedances on slurry - reactor opening loss exceedances - manual vents - incinerator bypasses This achievement is certainly a quality performance every day by all of those involved in preventing VCM releases and in operating equipment properly to ensure minimum emissions possible throughout the year. Congratulations! This is an award you can all be proud of and the achievement benefits our employees and the Aberdeen community. R. W. Seymour Plant Manager rah cc: THH, RDG, RRS ABD00023312 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS - NESHAP NESHAPs are nationally uniform standards oriented toward particular pollutants at the point of emission Vinyl chloride is in this category It applies to new and modified sources that commenced construction after EPA proposed an applicable NESHAP As with NSPS applications for approval of construction or modification must be made and accepted prior to the date on which construction or modifications is commenced The following pages outline the part of the Federal Register that pertains to NESHAPs 2-3 ABD000233|3 NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) 40 CFR PART 61 General Provisions* Sub Part A Definitions 61.02 1. Alternative method 2 Capital expenditure 3. Compliance schedule State Delegation 61 04(b) Bureau of Pollution Control Department of Natural Resources Jackson, MS Prohibited Activities 61.05 Don't modify without written approval from the Administrator (State) Application for Approval to Construct 61.07 Notification of Start-up 61 09 Initial Report 61 10 Waiver of Compliance 61.11 Up to two years Compliance with Standards 61 12 Determine by tests specified in rules Alternate, methods Emission tests 61.13 Withfn 90 days of start up Notify Agency 30 days before test Modification 61 15 ABD0002334j4 A change, operational or physical, that increases emissions is a modification unless it is not a capital expenditure or is routine maintenance Subpart F - VCM Definitions 61.61 In vinyl chloride service Relief valve Leak Exhaust gas 3 hour period Emission Standards for PVC Plants 61.64 Reactors 10 ppm exhaust gas limit ROL Slurry PVC and VCM plant emission standards 61.65 (a) RVD's (b) Fugitives 1. Loading & Unloading 2. Slip gauges 3. Rotating pumps 4 Reciprocating pumps 5. Rotating Compressors 6. Reciprocating Compressors 7 Agitators 8 Leaks from RV's ABD0002331 9 Manual Venting 10 Opening Equipment 11. Samples 12 Leak Detection and Elimination - Approval required i Fixed point monitoring li Definition of a leak lii Subpart V - annual performance test Submit results m next quarterly 13 In process wastewater Emission Tests 61 67 Method 106 Alternate method Method 107 Emission Monitoring 61 68 Reporting 61.70 Quarterly Reports Exception reporting Recordkeeping 61 71 3 years Leaks Emission measurements Daily reactor operating record including T and P ABD0002331 EPA REGULATION PROPOSED 12/24/75 PROMULGATED 10/20/76 PLANT OPERATED UNDER A WAIVER OF COMPLIANCE UNTIL SYSTEMS COULD BE INSTALLED TO MEET THE STANDARD 9/1/78. - STRIP SLURRY TO^ 400 PPM VCM - REACTOR OPENING LOSS 4 20 PPM VCM - NO MANUAL VENTING OF VCM - NO RELIEF VALVE DISCHARGES OF VCM - MINIMIZE FUGITIVE VCM EMISSIONS o RAILCAR UNLOADING LINES o DOUBLE MECHANICAL SEAL ON ROTATING PUMPS AND COMPRESSORS AND AGITATORS o REDUCE VCM IN EQUIPMENT BEFORE OPENING TO ATMOSPHERE o SAMPLES o REQ'U I RED LEAK DETECTION AND ELIMINATION PLAN CONTINUOUS MONITORS PORTABLE MONITORS 0 IN-PROCESS WASTEWATER STRIPPED TO LESS THAN 10 PPM VCM o EXHAUST GASES REDUCED TO ^10 PPM VCM - EMISSION TESTS - EMISSION MONITORING OF INCINERATOR OFFGAS - REPORTING RECORDKEEPING ANNUAL VCM SURVEY OOO'OI - rz/lTOO! ABD00023317 csnraa jo aaarcnN 0001 ABD00023318 VINYL CHLORIDE ANNUAL AVERAGE CONCENTRATIONS PPB /EDGE MARKINGS IN `'f'L S S ABD000233IP 1 PART PER MILLION PPM 1 INCH IN 16 MILES 1 MINUTE EVERY TWO YEARS I PART PER BILLION PPB 1 INCH IN 16,000 MILES 1 SECOND EVERY 32 YEARS /V&rro c ABD00023320 _S_A_R_A_ ______ ABD0002332J. SUPERFUND AMENDMENTS AND REAUTHORIZATIQN ACT OF 1986 - SARA The Emergency Planning and Community Right-to-Know Act is a law included as Title III to SARA SARA Title III represents Congress' response to concerns raised by the disaster in Bhopal, India in December 1984 SARA Title III, Subtitle A Mandates the establishment of State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) with responsibility to develop emergency plans and requires facilities to provide notification and supply information to these facilities SARA Title III, Subtitle B The reporting requirements are the following 302 Notification of identity of facilities subject to emergency planning provisions or those having extremely hazardous substances Vista Safety Director is our emergency notification coordinator 303 Submission of any "necessary" information by identified facilities under 302 to Local EPCs to assist in emergency planning 304 Emergency notification of any release of a CERCLA hazardous substance or extremely hazardous substance into the environment to State ERC or Local EPC A written followup report is also required 311 Submission of material safety data sheets (MSDSs) or list of "hazardous chemicals" to State ERC, Local EPC and local fire department. This is updated every October 312 Facilities must submit "emergency and hazardous chemical inventory forms" to the appropriate State ERC, Local EPC, and local fire department by March 1, 1988 and annually thereafter. Reporting is done in two tiers Tier I Reports give maximum and daily average amounts of hazardous chemicals present at the facility in the preceding year. Tier II Reports give more detailed information on specific chemicals including maximum and daily average amounts present in the preceding year, the manner of storage for the chemical and the specific location of the chemical 313 Annual Toxic Chemical Release Reporting to EPA and designated state officials is done in July of each year Facilities manufacturing or processing more than 50.000 pounds m a year are required to submit the form Facilities using listed toxic chemicals in quantities over 10.000 pounds in a calendar year are also required to submit the form 2-6 ABD0002332g fTITLE III FACT SHEET EMERGENCY PLANNING AND [COMMUNITY RIGHT-TO-KNOW U S. Environmental Protection Agency INTRODUCTION On October 17,1986, the "Superfund Amendments and Reauthonzation Act of1986" (SARA) was enacted into law. One part ofthe new SARA provisions is Title III. the Emergency Planning and Community Right-to-Know Act of1986. Title HI establishes requirementsfor Federal, State, and local governments and industry regarding emergency planning and 'community nght-to-know' reporting on hazardous and toxic chemicals. This legislation builds upon EPA's Chemical Emergency Preparedness Program (CEPP) and numerous State and local programs aimed at helping commumties to bet ter meet their responsibilities in regard to potential chemical emer gencies The community nght-toknow provisions of Title HI will help to increase the public's knowl edge and access to information on the presence of hazardous chemi cals in their communities and releases ofthese chemicals into the environment. Title 111 hasfour major sections: emergency planning (301 303), emergency notification (304), community nght-to-know reporting requirements (311, 312), and toxic chemical release reporting - emissions inventory (313). 301-303: Emergency Planning: ^^Thi e emergency planning sections are designed to develop State and local governments' emergency response and preparedness capa bilities through better coordination and planning, especially within the local community. Title ni requires that the Governor of each State designate a State emer gency response commission by April 17,1987. If a State commis sion is not designated, the Gover nor will operate as the commission until the Governor makes such deslgnanon. While existing State organizations can be designated as the State emergency response com mission, the commission can have broad-based representation Public agencies and departments con cerned with issues relating to the environment, natural resources, emergency services, public health, occupational safety, and transporta tion all have important roles in Title III activities Various public and private sector groups and associa tions with interest and exper tise m Title III issues also can be mcluded in the State commission. The State commission must desig nate local emergency planning dis tricts by July 17,1987, and appoint local emergency planning commit tees within one month after a dis trict is designated The State com mission is responsible for supervis ing and coordinating the activities of the local emergency planning committees, for establishing proce dures for receiving and processing public requests for information col lected under other sections of Title III, and for reviewing local emer gency plans This local emergency planning com mittee must include elected State and local officials, police, fire, civil defense, public health profes sionals, environmental, hospital, and transportation officials as well as representatives of facilities sub ject to the emergency planning requirements, community groups, and the media. No later than Sep tember 17,1987, facilities subject to the emergency planning require ments must designate a representa tive to participate m the planning process. The local committee must establish rules, give public notice of its activities and establish proce dures for handling public requests for information. The local committee's primary responsibility will be to develop an emergency response plan by Octo ber 17,1988 In developing this plan, the local committee will evalu ate available resources for preparing for and responding to a potential chemical accident. The plan must include Identification of facilities and extremely hazardous substances transportation routes Emergency response procedures, on-site and off-site Designation of a community coor dinator and facility coordinator(s) to implement the plan Emergency notification proce dures Methods for determining the occurrence of a release and the probable affected area and population 2-6a ABD000233^3 a quantity greater than its threshold planning quantity is subject to the emergency planning requirements. In addition, the State commission or the Governor can designate additional facilities, after public comment, to be subject to these requirements By May 17,1987, covered facilities must notify the State commission that they are sub ject to these requirements. If a facil ity begins to produce, use, or store any of the extremely hazardous sub stances in threshold quantity amounts, it must notify the State commission within 60 days. Each State commission must notify EPA of all facilities subject to the emergency planning requirements, including facilities designated by the State commission or the Governor 304: Emergency Notification Facilities must immediately notify the local emergency planning com mittee and the State emergency response commission if there is a release of a listed hazardous sub stance that exceeds the reportable quantity for that substance Sub stances subject to this requirement are substances on the list of 402 extremely hazardous substances as published in Federal Register on 11/17/86 and substances subject to the emergency noufication require ments under CERCLA Section 103(a). The initial notification can be by tele phone, radio, or in person Emer gency notification requirements involving transportation incidents can be satisfied by dialing 911, or in the absence of a 911 emergency number, calling the operator. This emergency notification needs to include: The chemical name An indication of whether the sub stance is extremely hazardous An estimate of the quantity released into the environment The tone and duration of the release The medium into which the release occurred Any known or anticipated acute or chronic health nsks associated with the emergency, and where appropriate, advice regarding med ical attention necessary for exposed individuals Proper precautions, such as evacu ation Name and telephone number of contact person. Section 304 also requires the fol low-up written emergency notice after the release. The follow-up notice or notices shall: Update information included in the initial nonce, and Provide informaaon on: - Actual response acuons taken - Any known or anncipated data or chronic health nsks associ ated with the release - Advice regarding medical attenuon necessary for exposed indi viduals. Unnl State commissions and local committees are formed, releases should be reported to appropnate State and local officials 311-312: Community Rightto-Know Reporting Requirements There are two "community nght-toknow" reporting requirements which apply pnmanly to manufac turers and importers Section 311 requires that facilities which must prepare or have available matenal safety data sheets (MSDS) under the Occupauonal Safety and Health Administration (OSHA) reg ulations to submit either copies of its MSDS or a list of MSDS chemi cals to: The local emergency planning committee The State emergency response commission The local fire department If the facility owner or operator chooses to submit a list of MSDS chemicals, the list must include the chemical name or common name of each substance and any hazardous component as provided on the MSDS. This list must be organized in categories of health and physical hazards as set forth in OSHA regu lations unless modified by EPA. If a list is submitted, the facility must submit the MSDS for any chemical on the list upon the request of the local planning com mittee Under Section 311, EPA may establish threshold quantities for hazardous chemicals below which no facility must report. The initial submission of the MSDSs or list is required no later than October 17,1987, or 3 months after the facility is required to pre pare or have available an MSDS under OSHA regulations. A revised MSDS must be provided to update MSDS which were originally submitted if significant new information regarding a chemi cal is discovered. The reporting requirement of Sec tion 312 involves submission of an emergency and hazardous chemi cal inventory form to the local emer gency planning committee, the State emergency response commission and the local fire department The hazardous chemicals covered by Section 312 are the same for which facilities are required to sub mit MSDS or the list for Section 311. Under Section 312, EPA may also establish threshold quantities for hazardous chemicals below which no facility must be subject to this requirement. The inventory form incorporates a two-tier approach. Under Tier I, 2-6c ABD0002332j4 The name, location and type of is the accounting of the total quan business tity of substances brought into a facility versus the amount that is Whether the chemical is manufac shipped out The difference is an tured, processed, or otherwise indication of the amount released used and the general categories of into the environment A report of use of the chemical this study must be submitted by EPA to Congress no later than Octo An estimate (m ranges) of the ber 17,1991. maximum amounts of the toxic chemical present at the facility at The purpose of this study is to any time during the preceding assess the value of obtaining mass year balance information to determine the accuracy of information on toxic Waste treatment/disposal methods chemical releases Also, the study and efficiency of methods for will assess the value of using the each wastestream information for determining the waste reduction efficiency and for Quantity of the chemical entering evaluating toxic chemical manage each environmental medium ment practices at categories of annually facilities In addition, the study must determine the implications of A certification by a senior official mass balance information collected that the report is complete and on a national scale including for use accurate. as part of a national annual quantity toxic chemical release program EPA must establish and maintain a national toxic chemical inventory Other Title in Provisions based on the data submitted This information must be computer acces Section 322 of Title III addresses sible on a national database. trade secrets and applies to emer gency planning, community nght-to- In addition to the requirements for know, and toxic chemical release the emissions inventory in Section reporting Any person may withold 313, EPA will arrange for a mass the specific chemical identify of a balance study to be earned out by hazardous chemical for specific rea the National Academy of Sciences sons Even if the chemical identity using information collected from is withheld, the generic class or cate States that conduct a mass balance- gory of the chemical must be pro oriented annual quantity toxic chemi vided The withholder must show cal release program Mass balance each of the following Key Dates to Remember (Continued from page 2) July 1,1988 (and annually thereafter) Covered facilities submit initial toxic chemical forms to EPA and designated State officials (313(a)) October 17,1988 Local emergency planning committees complete preparation of an emergency plan (303(a)) June 30,1991 Comptroller general report to Congress on toxic chemical release information collection, use and availability (313(k)) The information has not been dis closed to any other person other than a member of the local plan ning committee, a government official, an employee of such per son or someone bound by a confi dentiality agreement, that meas ures have teen taken to protect the confidentiality, and that the withholder intends to contmue to take such measures The information is not required to be disclosed to the public under any other Federal or State law The information is likely to cause substantial harm to the competi tive position of the person The chemical identity is not read ily discoverable through reverse engineering However, even if chemical identity information can be legally withheld from the public, Section 323 pro vides for disclosure under certain circumstances to health profes sionals who need the information for diagnostic purposes or from local health officials who need the information for assessment activities In these cases, the per son receiving the information must be willing to sign a confidentiality agreement with the facility. Information claimed as trade secret and substantiation for that claim must be submitted to EPA This mcludes information that otherwise would be submitted only to State or local officials, such as the emer gency and hazardous material inven tory (312) People may chal lenge trade secret claims by petitioning EPA, which must then review the claim and rule on its validity. EPA must publish regulations governing trade secret claims The regulations will cover the process for submission of claims, petitions for disclosure and a review process for these petitions October 17,1991 EPA report to Congress on Mass Balance Study (313(1)) Secton 305 of Title III authorizes the Federal Emergency Manage ment Agency to provide $5 million 2-6e ABD000233^5 for each of fiscal years 1987,1988, |1989, and 1990 for training grants lo support State and local govern ments. These training grants are designed to improve emergency planning, preparedness, mitigation, response, and recovery capabilities. Such programs must provide spe cial emphasis to hazardous chemical emergencies. The training grants may not exceed 80 percent of the cost of any such programs. The remaining 20 percent must come from non-Federal sources. Under Section 305, EPA is required to review emergency sys tems for monitoring, detecting, and preventing releases of extremely hazardous substances at representa tive facilities that produce, use, or store these substances. EPA will report interim findings to Congress no later than May 17,1987 and issue a final report of findings and recommendations to Congress by Apnl 17,1988. The report must include EPA's find ings regarding each of the following: Status of current technological capabilities to (1) monitor, detect, and prevent significant releases of extremely hazardous substances; (2) determine the magnitude and direction of the hazard posed by each release; (3) identify specific substances; (4) provide data on specific chemical composition of such releases; and (5) determine relative concentration of the con stituent substances. Status of public emergency alert devices or systems for effective public warning of accidental releases of extremely hazardous substances mto any media. The technical and economic feasi bility of establishing, maintaining, and operating alert systems for detecting releases. The report must also mclude EPA's recommendations for: Initiatives to support development of new or improved technologies or systems that would assist the timely monitoring, detection, and prevention of releases of extremely hazardous substances Improving devices or systems for effectively alerting the public in the event of an accidental release. For more information on Title lit and , EPA's Chemical Emergency Prepared ness Program, contact the CEPP Hotline: 1-800-535-0202 (in Washington, D.C. (202) 479-2449) Hours. 8 30 am - 4 30 pm (EST), Monday - Friday This Is NOT an emergency number ' / Guidance/ Assistance Title III - Major Information Flow Requirements 2-6g Vijfo foJyman A Divtsion of Vista Chenwcoi Company ABD000233^ Highway 25 Post Office Box 91 Aberriew, Mmimppi 39730 Phone (601) 369-8111 February 20, 1990 VIS1A Mr J E. Maher Mississippi Emergency Response Commission ? 0 Box 4501, Fondren Station Jackson, Ms. 39216-0501 Dear Sir: Attached is the Section 312 reporting requirements for the Vista Chemical facility m Aberdeen, Mississippi. The Tier II forms have been completed per ^0 CFR Part 370 If you have any questions or comments, please contact F G. Jeanson at (601)369-3637. Sincerely, 'r<^ R V. Seymour Plant Manager cc Jerome Husky Local Emergency Planning Committee Chairman for Monroe County Route 1 Box 275C Greenwood Springs, Ms. 38848 Chief John P. George 125 Vest Commerce Aberdeen, Ms. 39730 2-6h 2-&1 fo rm A p p o N D M B M o 2n(i 0011 ABD0002J328 ABD0002329 ABD00023S30 ABD0002J331 - ,'*<** CCJJ 2-6o ABD0002I-335 <3V C*. r fN 3 V 9 <N 9 c iS -- G Q Oa so %ot C riif 2 9\ : .o I u > ief S* ! li zGiir wi i 219\ _<jl<0n ii J y? aUs1 9 i |2 t; t-i 1?2 25 ssa j B i (3 Somiuu?i llisi 7-6T 2r6w Abbreviation APA BFF* VTT~ fTA RRf WFA ABD00023S42 STORMS IDQVnty ABBKEVEATHJS Description Alcoholypi.-rriHww storage aid Proceartn* Area BrrdirrimiBa and Piopoae Tank, Farm. Vinyl Chloride mmp Tank Farm CaBpaad/DrybifiDd Mamtfacturlng Area Resin Manufacturing Area Raw HalerialsyFinished Product Warehouse ^^rTlIliiMit VartWr4t%m AlBB TabU 1 REPORTING RANGES Rwioe weight Range in Founoa 00 0 01 100 02 1.000 03 10.000 04 100.000 OS 1 000.000 06 10.000.000 07 50.000.000 06 100.000.000 09 500.000.000 10 1 baton 99 999 9.999 99.999 999.999 9.999.999 49.909.999 99.999.999 499.099.999 999.999.999 ttgtartnan 1 bGon N - TabU U - STORAGE TYPES COOES Tvoaa of Srorano A B' C O E' P a H 1 4 x L MN oPa R Above groune tana Batov* ground tana Tanfclnatoa budding Steal arum Ptaaeo or norwnatabo anewCan Carter Slo Ftoar arum Bag Cyflnaar Otoaa boiitoa or lugs ffaatto botaea or mgs Tote bin Tank wagon Rafear Othar Tabu UI - TEMPERATURE AND PRESSURE CONDITIONS COOES Storaes Conations (PRESSURE) 1 , Ambtont prasaura 2 Qrsatar than amove* praawae ** 3 Laaa than ameiant pr--sura (TEMPERATURE) 4 Ambtont tamoaratura 9 Greatar man ameiant lanwarMiae Laaa man ameiant tamoaratura - but not eryoQonie 7 Crvooma aanattona 2-6x ABD00023343 ABD0002334g Intoroffle* Communication J C Ledvina To From Date Subject- F G Jeanson June 15, 1989 SARA SECTION 313 REPORT VISTA Attached is a summary table and the full report for SARA Section 313 reporting requirements. A summary table of 1987 emissions is also attached Major differences between 1987 and 1988 numbers are listed below Chemical lbs 1987 lbs 1988 Catezorv VCM 90,480 73,554 Air (stack emissions) VCM 29,521 3,008 Air (fugitive emissions Barium 1,223 388 Offsite (landfilled) Lead 13,545 6,070 Offsite (landfilled) VCM air emissions were decreased in both the stack and fugitive categories The stack emissions were reduced due to more stringent stripping procedures (higher temperature, longer time held under vacuum). The fugitive emissions were reduced as a result of a bagging study completed on the flanges and valves in VCM service During 1988 a waste, vacuum/vent dust, was sold as a by-product Instead of this material being landfilled, it was sold and used in compound production The amount of barium and lead landfilled was reduced due to this change. Ammonia and chlorine both reported in 1987 did not meet minimum usage requirements for 1988 Sodium sulfate was not reported in 1987. If you have any questions, please refer them to me F G. Jeanson Environmental Coordinator tjs cc RWS, DCS, PJK, CJM, DFJ, JEN, JBA, CLW, DAM, REP, RBN, SCH, BLT, JEL, HGC, MRK 2-6z ABD0002334 1988 SECTION EMISSIONS AIR WATER FUG STACK LAND OFFSITE SECOND TOTAL OFFSITE OFFSITE ANTIMONY BARIUM 00 00 0 0 863 5(2) 863 5(1) 1731 3 (3) 1 (9) 00 61(2) 61(1) 264(6) 2(3) 388 * CAUSTIC Di-N-Octyl Phthalate 0 0 0 0 0 17* 0 0 00 6460(4) 72184(5) 326(9) 0 78970 LEAD 07 00 METHANOL 1-499 0 00 PHTHALIC 00 ANHYDRIDE 00 SODIUM SULFATE 0 0 148,276 0 3018(2) 30(3) 4(9) 0 1932(7) 3018(1) 0 0 00 6070* 0 1932 0 SULFURIC ACID 0 0 00 00 0 VCM(8) 3008* 73,554* 0* 0 00 0 (1) Empty Bags (Sent to Monroe County Landfill) (2) Empty Bags (Sent to Chem Waste Management) (3) Floor Sweep (Sent to Chem. Waste Management) (4) Filter Cake (Sent to Chem Waste Management) (5) Separator Oil (Sent to Stauffer in Baton Rouge to be burned) (6) Stabilizer Spill (Sent to Chem. Waste Management) (7) PA Spill (Sent to Chem. Waste Management) (8) Fugitive emissions were calculated using correlation factors developed from a bagging study done at this plant) (9) API Sludge (Sent to Chem Waste Management) * Represents a reduction from 1987 emissions reported. Notes 1 Ammonia and chlorine were both reported last year. Both of these chemicals did not meet minimum usage requirements for 1988 so they were not reported 2 Sodium Sulfate was not reported last year 2-6aa ABD0002334 SECTION 313 EMISSIONS REPQRTED_FOR 1937 AIR WATER FUG STACK LAND OFFSITE SECOND OFFSITE TOTAL OFFSITE AMMONIA 1-499 0 1466 0 0 0 0 ANTIMONY 00 0 0 31(2) 1223(1) 1255 1(3) BARIUM 00 0 0 495(2) 640(1) 1223 88(6) CAUSTIC 00 00 00 0 CHLORINE 1-499 1-499 00 0 0 0 Di-N-Octyl 0 0 50 0 6880(4) 64967(5) 71847 Phthalate LEAD 07 0 0 7730(2) 5804(1) 11(3) 13545 PHTHALIC 00 ANHYDRIDE 0 0 1012(7) 0 1012 SULFURIC ACID 0 0 00 00 0 VCM (8 ) 29,521 90,480 57 0 00 0 ^-0 (1) Empty Bags (Sent to Monroe County Landfill) (2) Vacuum Dust (Vacuum Dust has been eliminated as a waste in 1988, it is now sold as an offgrade.) (3) Floor Sweep (Sent to Chem. Waste Management) (4) Filter Cake (Sent to Chem. Waste Management) (5) Separator Oil (Sent to Stauffer in Baton Rouge to be burned) (6) Stabilizer Spill (Sent to Chem. Waste Management) (7) PA Spill (Sent to Chem. Waste Management) (8) Fugitive emissions were calculated using EPA's Stratified Emission Factors. 2-6bb ABD00023347 ABD0002334J* RESOURCE CONSERVATION AND RECOVERY ACT - RCRA RCRA regulates discharges into groundwater and some air emissions (e g , incinerators) and general waste management, including spills Focuses on current and future activities The scope of RCRA includes the following three areas 1 Waste Management - regulates disposal of hazardous (Subtitle C) and non-hazardous (Subtitle D) wastes It also regulates the maintenance of underground storage tanks (Subtitle I) 2 Promotes Resource Recovery and Reuse of materials 3 Authority for enforcement, studies, grants, National Ground Water Commission, etc Hazardous Waste Management under Subtitle C is the main area of concern for RCRA It is a program of federal standards with state implementation of cradle to grave tracking of hazardous waste The subject matter includes the manifest system, listing and definition of hazardous waste, inspections and enforcement, site inventory, analysis and testing and exposure and health assessments The EPA Regulations are found m 40 CFR Parts 260 thru 271 2-7 ABD00023349 The following is a list of Manifested Wastes sent from the plant for offsite disposal Waste Waste Oil API Separator Parts Clean Solvent Lead Contaminated Bags Reason Manifested conbustible liquid bariun, cadntum, lead Naphtha combustiole liquid lead, antimony & barium contamination Site Baton Rouge, La., Stauffer Chemical Co. Safety Kleen Corp., Southaven, MS CUM, Emelle, AL Proper Shipping Name. Haz. Class ft I D. No waste cofffcustible liquid N.O.S combustible liquid, NA 1993, RO (0005R, D006R, D008R) waste petroleum Naphtha combustible liquid UN1255 (EPA 0001) 501 non-hazardous MARU11039 Waste No D005R, 0006R, D008R 0001 NH0000 Plasticizer Filter Cake Floor Sweeps API Sludge P A Spill Asbestos Stabilizer Spill plasticizer floor sweeps & ventilation dust hazardous material (lead) hazardous waste (lead) hazardous waste (phthalic anhydride) CUM, Emelle, AL CUM, Emelle, AL CUM, Emelle, AL CUM, Emelle, AL gaskets and insulation to Emelle hazardous waste barium, cadmum CUM, Emelle, AL CUM, Emelle, AL plasticizer filter cake, nonhazardous HAR007363 hazardous wastes solid, N.O.S. ORM-E NA 9189 RQ 0008 MSE 64751 hazardous waste solid N.O.S. ORM-E NA 9189 RQ 0008 MS 007317 hazardous waste solid N.O.S. ORM-E NA9189 (phthalic anhydride) MS 007318 asbestos insulation M$t> 37292 hazardous waste solid N.O S , ORM-E NA 9189 RQ (DOOS, D006) MSE 69245 NHOOOO D008 D008 U190 0005, 0006 Mississippi Hazardous Waste Management Regulations implementing the Resource Conservation and Recovery Act require facilities handling hazardous wastes to prepare and submit a Biennial Report by March 1st of each even numbered year covering the activities during the previous year 2-8 ABD00023350 ABD00023351 COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT CERCLA This CERCLA of 1980 better known as "Superfund" seeks to establish the "no fault" liability of facility owners and operators, generators, and certain transporters of hazardous substances for releases of those hazardous substances Allows governments to spend funds to clean up and then seek reimbursement from liable parties Its principal concern is to address past activities resulting m present releases from waste sites There are four Hazardous Waste Sites at the Aberdeen Plant These four sites are Superfund sites because the waste material contained in these sites (BIS {2ethylhexyl) phthalate) is on the RCRA Hazardous Waste List (U-028) Please refer to the following two pages for site description and location 2-9 6 t _______ lo u N D A tr ENTtAMCt *\ ABD00023352 }t6TJr. wrr tcuNOAay 4'7f* i q/V S/ raomrr "5PF7T .PAST LAMOPIU AMA N*1 FAST lANOTHi ASIA M*.2 ,MST lAMOFttl AUA N*.a SCTftma FITS (3) 28fi.a4f'. AW' MOFflTT OOUNOAIT y^PtUMS BLOW OftOUND / AftSA NA4 1)20 U. SimtNO A * COUAIIZATION |** FOOT o* 23111 fiowiTf tewpAtr uaoij. iSrIr? t t? fiC NOTIFICATION M hazardous WASTE SUE FACtlfTY DRAWING CONOCO CHEMICAL S AM tOUN .MISSISSIPPI |FA IQ.N*. MSO0070)1330 scalsiiIimh40o r%0t (ATTACHMENT TO EPA FORM S900-1) 2-10 ABD00023353 IT-3 HOTIFICAT!OH OF HAZARDOUS WASTE SITE cohoco m e h caL sI ABERDEEN. M is s is s ip p i (ATTACHHENT TO EPA FORK 8 9 0 0 -1 ) A) *9 0 c 0 UU -^3 3 a < JO X X i A 44 44 44 u w 882 o *9 w a 4V4 l/l j 404 lr/el Ds 404 in 5 a0s W 3 03 O S*w iff O o o 44 < Ife O irv r-. e 2 - vc -- W wH3 Ui 3i O S 0 01 44 0 Si 0 L. 44 0 irt O 9 UJ V i/> o IA g o IA O a. a> <s CM s t<nv O ui c - 5 re ra 0 k< 2 *o *ts wn0 < fA re 0u < 4 0us3v -- 0 *re 2 to jr o u_ w --O 0 44 44 < "O C 3 Cre _i *rc3e 0 js re 0 U 0w *e < 0 \n ri/ei ir/ei vre> 3 L. w'i Cl. z c. o mJ < o K > X0 X--0 lr/et X* x44 U ui X wN> 44 e v) V CD h 0 <* N *0" *3 -- C *4 0 vi 19 5 a 98 V) * sr =53 0 *(40 J^j re , f~ &J2 -j vt U0 0* N V) -- (0 J? * ** VI V) 3 5-8 CL U 8S iO/l Z 2 -- ec <o o x - g2 AS O) M-CO 18 404 *--0 S3 b 00 > M0 0-- i-- * re u 0 XM 404) ff 8 *. IA Ui z ABD00023354 A TSCA ABD00023345 TOXIC SUBSTANCES CONTROL ACT - TSCA Enacted in 1976, TSCA has extremely broad regulatory powers over chemical substances and mixtures This regulatory authority is vested entirely in the federal government. The TSCA grants EPA authority to regulate the entire life cycle of a chemical, from its initial manufacture to its ultimate disposal. TSCA has broad information gathering provisions It can require 1 It can require health and/or environmental effect testing of new manufactured chemicals 2 It requires manufacturers and processors to maintain records and submit information on existing chemicals for assessing risks. 3 It requires all manufacturers to keep records on significant adverse reactions to health or the environment alleged to have been caused by a chemical substance or mixtures. 4 It requires the submission of unpublished health and safety studies 5 It has control over new chemicals made or entering the country and requires Premanufacture Notification ("PMN") 90 days before such manufacture or processing of a new chemical. 2-12 ABD00023356 ABD000233^ REGULATION OF POLYCHLORINATED BIPHENYLS (PCBs) TSCA Section 6 (e) requires EPA to promulgate regulations prescribing disposal and labeling methods and prohibiting the manufacture, processing, distribution and use of PCBs except in three instances. Annual reports for PCBs in service or projected for disposal are due by July 1 for previous calendar year. 2-13 ABD00023358 DEPARTMENT OF TRANSPORTATION - DOT The Code of Federal Regulations volume 49 deals with the transportation of Hazardous Wastes and Materials. A hazardous material is a substance capable of posing an unreasonable risk to health, safety, and property when transported in commerce. DOT is concerned with how hazardous materials are identified, packaged, documented, stored, transported, marked, labeled, and placarded The DOT enforces the regulations with fines and/or imprisonment Fines are most often given for failure to use the proper shipping name on manifests and bills of lading and improper placarding The Environmental Coordinator should be consulted when determining any of the following questions 1 Is the material to be shipped hazardous? 2 What is the proper shipping name? 3 Do packages/bulk loads need to be labeled/placarded? 4 What types of labels/placards are necessary for certain chemicals? 5 Is a manifest required for this shipment? 2-14 ABD00023360 ABD00023361 SPILL PREVENTION CONTROL AND COUNTERMEASURE PIAN - SPCC SPCC is located in 40 CFR Part 112 and is regulated by the EPA Owners or operators of non-transportation related facilities which due to their location, could reasonably be expected to discharge oil in harmful quantities must prepare a SPCC Plan SPCC Plans must specify established procedures and methods and equipment and physical structures to prevent discharger of oil An SPCC Plan must be prepared within six months after a facility begins operations and must be certified by a Registered Professional Engineer A copy of our SPCC Plan follows 2-15 ABD00023362 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN April 10. 1989 ABD000233^ SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN April IQ, i?B9 PREPARED BY: F. G. Jj/anson Environmental Coordinator CERTIFIED BY: P. E. of MS No. 5609 ABD00023364 SECTION I SECTION II SECTION III SECTION IV SECTION V SECTION VI SECTION VII SECTION VIII SILL PREVENTION CONTROL AND COUNTERMEASURE PLAN CONTENTS INTRODUCTION PLANT DRAINAGE AND RUNOFF CONTROL INSPECTIONS SPILL CLEANUP REPORTING TRAINING AVAILABLE SPILL CLEAN-UP EQUIPMENT DIKE AND TRENCH INSPECTION REPORT a-is ABD0002336^ SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN INTRODUCTION Federal regulations require that facilities which could reasonably be expected to discharge oil prepare a SPCC Plan (Spill Prevention, Control and Countermeasure Plan) The intent of the SPCC Plan is to minimize the potential for harmful oil discharges to navigable waters within the U S. A harmful oil discharge is defined as any oil discharge which causes a visible sheen on or discoloration of, the surface cf water Harmful oil discharges are prohibited by law. The Aberdeen Plant uses a variety of oil during operations, such as plasticizers, alcohols, lubricants and chemical substances. Most of these oils are handled in diked, curbed or trenched-in areas which dram to the process sever; however, it is possible that oil could be spilled outside of these areas and subsequently run to the storm sewer. In order to trap any free oil which may have been spilled to the storm sewer, there are concrete basins with underflow baffles upstream from each storm sewer outfall. All potential spill areas are under plant security. The plant facilities are enclosed in a fenced area, and all the gates are locked except the main gate where a guard is present at all times PLANT DRAINAGE AND RUNOFF CONTROL Oily substances are stored or handled at several locations within the plant. The following preventive measures have been taken to minimize the potential for an oil discharge from the plant. A. Plasticizer Tank Farm Bulk quantities of plasticizer, alcohol and caustic soda are stored in tanks at the tank farm. The area is enclosed by a three-foot high concrete dike which will contain spills. Oil which is spilled at the tank farm will collect on the surface of the API separator and will subsequently be recovered to the process. All of the tanks at the tank farm have level gauges. The tank levels are checked daily and recorded on a form. The drains on all of the tanks are either blinded or plugged. B. Fuel Storage Area A diesel oil storage tank and a gasoline storage tank are located north of the plasticizer tank farm in a concrete diked area. There is a valve between the plasticizer tank farm and the fuel storage area which can be opened in order to drain the fuel storage pad to the tank farm. ABD000233^ SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II. PLANT DRAINAGE AND RUNOFF CONTROL - Continued C. Alcohol Unloading. Area Alcohol is unloaded from trucks on the south side of the tank farm. The area around the hookup stations is enclosed by a trench in the roadway which, drains to the API separator. Oil which is spilled at the unloading station in any quantity must be cleaned up immediately. This should be accomplished by washing the spilled oil into the trench with water or cleaning up the spilled oil with sorb all. Failure to clean up oil promptly will result in the spreading of the oil into the roadway by vehicles. D. T-450. 460 Area The area around T-450 and T-460 tanks on the east side of the plasticizer building is enclosed by concrete curbing, and the curbed area drains to the API separator. The two above ground tanks which are located within the curbed area have level gauges which are checked daily and recorded on a form. E. Plasticizer Reactor Relief Knockout Tank If a plasticizer reactor were to overpressure or relieve for some reason, the discharge would pass through the plasticizer reactor relief knockout tank. Entrained liquid in the discharge would collect in the tank instead of being discharged to the area around the plasticizer building. Although the tank is normally empty, there is a trench around the tank which drains to the API separator. F. Large Drum Storage Area There is a large drum storage area located on the south side of the east warehouse. This area is enclosed by a concrete dike, fencedin, locked and covered by a roof. There is a valve at the southeast of the dike which can be opened In order to let out rainwater. G. Waste -Oil and Slop Oil Tanks There are two tanks on the north side of the API separator which are used to store waste oil and oil which has been recovered from the API separator. Both of these tanks are surrounded by a concrete dike, and the diked-in areas drain to the API separator. Each tank has a level gauge. a-at) ABD000233^ SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II PLANT DRAINAGE AND RUNOFF CONTROL - Continued H. Empty Drum Storage Pad Empty drums from around the plant are drained and stacked on a concrete pad east of the API separator. The concrete pad is enclosed by a concrete-curb, and oily drainage from the pad is collected in a small sump at the north end of the pad. The sump is pumped out to the waste oil storage tank or the API separator as necessary. If the level in the sump becomes too high, the sump and the concrete pad will overflow to the API separator. I. Lubricating Oil Storage. Area Lubricating oils are stored on a concrete pad east of the truck scales. The pad is surrounded by a trench and a concrete curb, and covered by a roof. There is a dram valve on the south side of the curb which is blanked-off, and is not to be opened under any circumstances. Oil which is collected in this trench must be drummed and transferred to the waste oil sump by the API separator. J Drum Storage _Areas_at Reactor. Units There are small drum storage pads at each of the reactor units which are enclosed by a concrete curb. There areas drain to the process sever. In the event of a chemical spill within these areas, there is a drain valve which can be closed if necessary. K. Firewater System Diesel Oil Storage Tanks There are two small diesel oil storage tanks at the firewater pond deluge building and at pond #5 deluge building. The area under the pond #5 deluge diesel oil storage tanks is contained by a concrete curb; however, if oil is spilled outside of the curbed area the oil will run into the wastewater treatment ponds. The situation at the firewater pond is similar. If diesel oil is spilled outside of the curbing and it runs to the firewater pond, there is an underflow baffle which will keep the oil from being discharged from the plant. L. Emergency Generator Diesel Oil Storage Tank There is a diesel oil storage tank for the emergency generator located just east of the emergency generator building. The area under the tank is concrete and there is a concrete dike to contain any spillage. There is a roof over the tank to prevent rainwater from entering the diked area. M. The Sphere and The Bullets The sphere and the bullets are surrounded by a concrete dike, which will contain VCM that may be spilled during a massive VCM release. a^\ ABD0002336| SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II. PLANT DRAINAGE AND RUNOFF CONTROL - Continued N Storm Water Runoff If there is an oil spill outside of the above areas, there is a possibility that the spill could leach the storm sewer instead of the process sewer. In order to prevent oil from being discharged from the plant via a storm sewer, there is a concrete basin upstream from each storm sewer outfall. These basins have two underflow baffles which will trap any free oil which may get into the stormwater runoff. Oil which collects on the basins must be cleaned up as soon as possible, since the oil will eventually become entrained or dissolved in the stormwater. ABD000233i SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN III INSPECTIONS A Dikes and Trenches All dikes and trenches around potential oil spill areas are to be inspected semi-annually by the Environmental Coordinatoi The attached inspection form must be completed and filed during this inspection. Cracked dikes or plugged trenches must be promptly repaired or cleaned out as necessary B. Storm Sewer Basins The storm sewer concrete basins must be inspected for oil at least once per week by the Environmental Coordinator If oil is observed on the basins during these inspections, or during an inspection by any other employee, the Environmental Coordinator and the Contract Supervisor must be notified The oil must then be cleaned up promptly and the source of the oil identified if possible. IV SPILL CLEANUP In the event of an oil or chemical spill, efforts must be made to prevent the spill from leaving the plant's boundary Any employee who observes a spill must take immediate action to control the spill, and if the spill is too large to control by ordinary means, the Supervisor of the affected area must be contacted. The Supervisor will make an evaluation of the spill and will notify the Operations Supervisor or Superintendent, who will coordinate cleanup of the spill. If the spill enters a storm sewer or approaches a plant boundary, the Environmental Coordinator must be contacted for assistance. Spills which occur to grade should be contained with whatever materials are available and the spill area should be roped off. Spills which enter the plant's sewers should be cleaned up whenever the spill material reaches the concrete settling basins. Sorbent booms should be placed at the storm sever outfall if oil is spilled to the storm sewer. When spilled material is cleaned up, the necessary Safety and Environmental disposal procedures must be used. If there is any doubt concerning the safe and proper cleanup and disposal of certain materials, the Environmental Coordinator must be contacted for assistance. V REPORTING If there is any visible oil discharge from the plant, the incident must be reported to the Mississippi Department of Natural Resources and the National Response Center. The following personnel are authorized to report oil discharges from the plant. The report must be made as soon as possible after becoming aware of the spill, but no later than within 24 hours of the spill. <3 3 ABD000233^0 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN REPORTING - Continued Environmental Coordinator Chief Process Engineer Senior Process Engineer Senior Process Engineer Plant Superintendent Plant Manager Vinyl Operations Superintendent Compound Operations Superintendent Mechanical Superintendent Frank G Jeanson Rendell B. Newton Vernon L Thornhill Steve C. Hillman Doug C. Skokna R. V Seymour Paul J. Kober Ted Nickerson Dan A. Miller 1-324-2329 1-328-0904 369-8952 369-7892 1-327-0679 369-4412 369-7096 369-9025 1-356-6274 The following numbers may be useful when reporting an oil spill. MDNR Between 7 30 a m. - 4 30 p m call. (601) 961-5171 After 4*30 p.m., weekends and holidays call: (601) 961-5340 Soffl Mahaffcy Bob Rogers Jerry Cain Engineering in Training Emergency Coordinator Section Chief National Response Center All Hours 1-800-424-8802 TRAINING Employees engaged in the operation and maintenance of equipment which could reasonably be expected to spill oil are to be trained on the SPCC Plan. ABDOi SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APEENDIX A AVAILABLE SPILL CLEANUP EQUIPMENT (1) VACUUM TRUCKS - Vacuum trucks are available from the following truck service companies: A. RDB Trucking - LOCATION: PHONE: ARRIVAL TIME: Aberdeen, MS 369-9383 15 minutes B. G.B. Smith, Inc. LOCATION: Hattiesburg, PHONE: 649-1220 ARRIVAL TIME: 3.5-4 hours C Industrial Maintenance Cleaning Contractors, Inc. (I.M.C.C.I.) LOCATION: Bessemer, AL PHONE: 205-428-0621 ARRIVAL TIME: 6 hours D. Ergon LOCATION PHONE ARRIVAL TIME Jackson, MS 948-3472 3 hours (2) SKIMMING PUMP Skimming pumps available from RDB Trucking. (3) ALUMINUM BOAT - An aluminum boat Is available from the waste treatment ponds. (4) Spill booms, rolls and pads of oil sorbent materials are available from storeroom to remove oil from the creek or settling pits. (5) Sorbent materials for liquid spills on concrete areas or the ground are available from the storeroom. ABD000233 SPILL PREVENTION CONTROL AND COUNTERMEASURE FLAN &EEEPBU P SPCC PLAN DIKE AND TRENCH INSPECTION REPORT Date._______________________________ Item Plasticizer Tank Farm: Inspector Status VCM Tank Farm Dike: Lagoons Acid Dike: Alcohol Unloading Area: T450, 460 Area: Diesel Oil Storage Areas: Waste Oil and Slop Oil Dikes: Empty Drum Storage Pad* Lubricating Oil Storage Area. Reactor Drum Storage Pads: Large Drum Storage Area By East Warehouse: Plasticizer Reactor Relief Knockout Tank: Firewater System Diesel Oil Storage Tanks: Emergency Generator Diesel Oil Storage Tank: ABD000233^3 SPCC PLAN AND TRENCH INSPECTION REPORT Page 2 The following problems should be checked for and noted, along with any other obvious discrepancies 1 Cracks or damage to dike walls, curbing. 2. Trenches that are full of solid debris and will not dram. 3 Liquid-full trenches or curbed areas. 4 Obvious signs of oil spillage outside of the contained area. 5 Drain valves that are open where the area to be drained does not tie into the process sever system. 6 Write "W 0. Written1' under status column after a work order has been written to correct a discrepancy ABD00023374 ADDENDUM TO S.P.C.C. PLAN RCBA-HAZARDOUS WASTE CONTINGENCY PLAN April 10. 1989 ABD00023375 ADDENDUM TO S.P.C.C. PLAN RCRA HAZARDOUS WASTE CONTINGENCY PLAN April,J.Q. m? PREPARED BY: Frrank G. J eanson^ Environmencal Coordinator CERTIFIED BY Karnes L. White P.E. MS No. 5609 ABD00023^6 ADDENDUM TO S.P.C.C. PLAN RCRA HAZARDOUS WASTE CONTINGENCY FLAN Contents I. INTRODUCTION II. EMERGENCY COORDINATOR III. EMERGENCY PROCEDURES IV ARRANGEMENTS WITH LOCAL AUTHORITIES V AREAS COVERED BY CONTINGENCY PLAN VI REPORTING VII. AMENDING EMERGENCY PROCEDURES VIII. EQUIPMENT A-30 ABD000233'g RCRA HAZARDOUS WASTE CONTINGENCY PLAN I INTRODUCTION Section F, Subpart D (402.7-50 to 402.7-56) of the Mississippi Hazardous Waste Management Regulations require an owner or operator of a hazardous waste management facility to have a contingency plan for his facility. The Contingency Plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous wastes to the air, soil, or surface waters. The plan includes provisions for an emergency coordinator who will assess the possible hazards of any spill, fire, or explosion of hazardous waste. The Emergency Coordinator will implement the Contingency Plan if he deems the emergency situation threatens human health or the environment. Hazardous wastes which are managed at the Aberdeen Plant are waste phthalic anhydride, API sludge, waste barium, cadmium or lead stabilizers, and any waste mixtures containing significant amounts of barium, cadmium, or lead stabilizers. The areas of the plant which are covered under the Contingency Plan are the hazardous waste drum storage area, the API separator and slop oil tank. II. EMERGENCY COORDINATOR At all times, there must be at least one employee on the facility premises or available to respond within a short period of time to an emergency situation involving hazardous wastes. This person has the responsibility for coordinating hazardous waste emergency response measures. The Emergency Coordinator must be: 1. Familiar with the plant layout. 2. Familiar with the location and characteristics of the hazardous waste handled. 3. Familiar with hazardous waste related operations and activities at the plant. 4. Familiar with hazardous waste related records within the plant. 5. Familiar with all aspects of the plant's Contingency Plan. 6. Have the authority to commit the resources necessary to implement the Contingency Plan. 2.-31 ABD000233'g RCRA HAZARDOUS _WASTE_CONTINGENCY PLAN II. EMERGENCY COORDINATOR - Continued The following people will serve as emergency coordinator for the area affected by a hazardous waste emergency. PRW1 STPRAC5 AREA AW CQMftKTO AREA PUNT EXTENSION HOME PHONE Ted Nickerson - Primary Charles Worlow * Alternate Frank Jeanson - Alternate Bruce Trego - Alternate Bob Seymour - Alternate Doug Skokna - Alternate 3635 3657 3637 3618 3606 3610 369-9025 369-2269 1-324-2329 1-327-8673 369-4412 1-327-0679 API SEPARATOR Dan Miller - Primary Frank Jeanson - Alternate Bruce Trego * Alternate Bob Seymour - Alternate Doug Skokna - Alternate 3622 3637 36X8 3606 3610 1-356-6274 1-324-2329 1-327-8673 369-4412 1-327-0679 In the absence of the department heads, the department head will designate another person to perform his duties. The designee will become the primacy Emergency Coordinator for the area affected by a hazardous waste emergency. III. EMERGENCY PROCEDURES The plant has an emergency plan which is implemented in the event of any plant emergency. The plan is included in Section 1.23 of the Plant Safety and Health Manual. In addition to this plan, che Emergency Coordinator must evaluate any emergency situation involving hazardous wastes and determine if the RCRA Hazardous Waste Contingency Plan is to be implemented. If the plan is implemented, the Emergency Coordinator has the following responsibilities: A. Take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other hazardous waste. These measures include, where applicable, stopping processes and operations, collecting and containing released waste, and removing or Isolating containers. B. Monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment, wherever this is appropriate, if the facility stops operation in response to the emergency. C. Provide for treating, storing, or disposing of recovered waste, contaminated soil or surface water. Immediately after the emergency. Q-22L ABD000233 RCRA HAZARDOUS WASTE CONTINGENCY PLAN III. EMERGENCY PROCEDURES - Continued D. Ensure that in the affected area(s) no waste which may be incompatible with the released material is treated, stored, or disposed of until cleanup procedures are completed. If there are any questions concerning the proper handling of hazardous wastes or the means by which a hazardous waste spill should be cleaned up, contact the Environmental Coordinator. IV. r VITH LOCAL AUTHORITIES The following verbal agreement has been made with the local fire department: If outside assistance is required and requested, the firemen who come into the plant will operate under the guidance and leadership of the Shift Supervisor involved with the emergency. V AREAS COVERED BY THE CONTINGENCY PLAN A. Hazardous Waste Drum_Storage Area The hazardous waste drum storage area is the diked and fenced in area south of the east warehouse. This area is used for the storage of drummed hazardous wastes and other drummed materials. B. API Separator and Slop Oil Tank The API separator which is located east of the plasticizer tank farm is used to reclaim oils from the waste water generated during the plasticizer operation. Vaste oils which cannot be reclaimed are stored in the slop oil tank just south of the API. Waste oil from the slop oil tank is periodically shipped to Stauffer Chemical Company who burn the oil for heat recovery. 2.-33 ABD000233^J RCRA HAZARDOUS WASTE CONTINGENCY FLAK VI. REPORTING If the Emergency Coordinator determines that the plant has had a spill or fire that could threaten human health or the environment outside of the Plant, the National-Response Center (1-800-424-8802) should be contacted immediately. The following personnel are authorized to contact the National Response Center: Safety Director Environmental Coordinator Chief Process Engineer Senior Process Engineer Senior Process Engineer Plant Superintendent Plant Manager Vinyl Operations Superintendent Compound Operations Superintendent Mechanical Superintendent Bruce Trego Frank Jeanson Rendell Newton Vernon Thornhill Steve Hillman Doug Skokna Bob Seymour Paul Kober Ted Nickerson Dan Miller 1-327-8673 1-324-2329 1-328-0904 369-8952 369-7892 1-327-0679 369-4412 369-7096 369-9025 1-356-6274 In the event that the Hazardous Waste Contingency Plan is implemented, the time, date, and details of the incident are to be recorded in operating records of the unit affected. Within 15 days of the incident, a written report of the incident must be submitted to the State Solid Waste Division. The report is to include the following information: 1. Name, address, and telephone number of the plant. 2. Date, time, and type of incident (fire or spill). 3. Name and quantity of material(s) involved. 4. The extent of injuries, if any. 5. An assessment of actual or potential hazards to human health or the environment. 6. Estimated quantity and disposition of recovered material that resulted from the incident. ABD000233^ RCRA HAZARDOUS WASTE . CONTINGENCY. PLAN VII. 'INO EMERGENCY PROCEDURES The Contingency Plan must be reviewed and amended, if necessary, whenever: A. Applicable regulations are revised. B. The plan fails in an emergency. C. The plant changes in its design, construction, operations and maintenance in a way that materially increases the potential for releases of hazardous wastes or hazardous waste constituents. VIII. EQUIPMENT A Communications The following communications equipment is available at the plant: (1) two-way radios, (2) five channel Gaitronics system, (3) public address system, and (4) telephone. B. Eire Fighting There are fire extinguishers located throughout the plant. Fire fighting equipment is listed in Section 1.23 of the PVC Health and Safety Manual. C. Spill Cleanup For a list of available spill cleanup equipment, refer to Appendix A of the S.P.C.C. Plan. tjs/RBN disk 3.-3^ ABD00023382 AGENCIES I^Ste- ABD00023383 AGENCIES EPA REGION IV - ENVIRONMENTAL PROTECTION AGENCY MDEQ, BPA - MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY, BUREAU OF POLLUTION CONTROL (PREVIOUSLY THE MDNR, MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES) NRC - NATIONAL RESPONSE CENTER, CERCLA REPORTING MERC - MISSISSIPPI EMERGENCY PLANNING COMMITTEE LEPC - MISSISSIPPI EMERGENCY RESPONSE COMMITTEE ABD000233$4 Ill AGENCIES A The regulatory agencies that the Aberdeen plant deals with and the contacts at each are as follows: ENVIRONMENTAL PROTECTION AGENCY - REGION IV Region IV includes the sates of Mississippi, Alabama, Georgia, Florida, South Carolina, Tennessee, and North Carolina Address. USEPA Region IV 345 Courtland Street Atlanta, GA 30365 Division Contact Phone Number CERCLA Library Freedom of Information Undine Johnson (404)347-5065 (404)347-4216 (404)347-3004 MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY BUREAU OF POLLUTION CONTROL Address: Section Mississippi Department of Natural Resources Bureau of Pollution Control P 0. Box 10385 Jackson, MS 39209 Contact Phone Number N Mississippi Air Emissions Danny Jackson Industrial Wastewater Control Taher Diab RCRA Sam Mabry CERCLA Jim Hardage (601)961-5171 (601)961-5171 (601)961-5171 (601)961-5171 BUREAU OF LAND AND WATER RESOURCES Section Contact Phone Number Director of Bureau Hydrologist Charles Branch Mike Gross (601)961-5265 (601)961-5265 ABD000233^5 III AGENCIES B Spill/Release Reporting NATIONAL RESPONSE CENTER 1-800-424-8802 LOCAL EMERGENCY PLANNING COMMITTEE Emergency Coordinator Jerome Husky (601)369-6439 MISSISSIPPI EMERGENCY RESPONSE COMMISSION Regular Hours In State Out of State Bill Austin 24-hour number 24-hour number (601)960-9000 1-800-222-6362 (601)352-9100 ABD00023386 "P'mUMHM-1 PERMITS i-iz__s___s\ mssfj ABD000233$7 S PERMITS ADMINISTERED BY STATE WATER CWA, NPDES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM AIR CAA, NESHAP CONSTRUCTION- MAJOR PROJECTS GROUNDWATER - MDEQ, BLDR BUREAU OF LAND AND WATER RESOURCES WASTE GENERATOR, EPA IDENTIFICATION NUMBER 4-1 ABD00023388 AIR PERMIT ABD0002339 PERMITS A Operating Permit No 1840-00014 for Air Emissions Equipment An application for a construction permit needs to be submitted for any significant modification to the process or facility which alters the rate or composition of air pollutant emissions A new permit application must be submitted 180 days prior to March 1, 1991, in order to renew this permit This permit gives emissions limitations on our three boilers, nine PVC dryers, particulate matter on 35 baghouses combined, particulate matter from the Compound Production area, particulate matter from the Dryblend area, air contaminants from the Plasticizer Production area, emissions from the VCM incinerators, and emissions covered under NESHAPS 4-2 ABD00023390 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control P. O. Box 10385 Jackson. Mississippi 39209 (601)961 5171 February 24, 1988 CERTIFIED WAIL NO. P-125 260 667 Mr. John Friend, Plant Manager Vista Polymers P. 0. Box 91 Aberdeen, Mississippi 39730 Dear Mr. Friend: Re: Operating Permit No. 1840-00014 Aberdeen, Mississippi Enclosed please find Operating Permit No. 1840-00014 issued for the operation of the air emissions equipment. Operation of the air emissions equipment at the facility shall be in accordance with the terms, conditions, and limitations of the permit. Any significant modification to this process or facility which will alter the rate or composition of air pollutant emissions will cause this permit to become invalid. Should you wish to make such a modification, it will be necessary to submit a new application for a construction permit. This permit expires on March 1 , 1991. A new permit application must be submitted one hundred and eighty (180) days prior to this date m order to renew this permit. Any appeal of this permit action must be made within the 30 day period provided for m Section 49-17-29(4)(b) Mississippi Code of 1972. If you have any questions or if we can be of service, please let me know. Very truly yours, BVW:eb Enclosure Bobby^V. Whitaker North Air Emissions Section 4-3 ABD00023391 STATE OF MISSISSIPPI AIR POLLUTION CONTROL PERMIT TO OPERATE AIR EMISSIONS EQUIPMENT THIS CERTIFIES THAT Vista Polymers Hwy. 25 Aberdeen, Mississippi has been granted permission to operate air emissions equipment In accordance with emission limitations, monitoring requirements and conditions set forth herein. This permit Is Issued In accordance with the provisions of the Mississippi Air and Water Pollution Control Law (Section 49-17-1 et. seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder. Issued this 23rd. day of February. 1988 DIRECTOR BUREAU OF POLLUTION CONTROL^ MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Expires 1st day of March. 1991 Permit No. 1840-00014 4-4 ABD0002339 PART I Page 3 of 11 Pewit No. 1840-00014 b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to Inspect any monitoring equipment or monitoring method required In this permit; and to sample any air emission. 8. After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked In whole or in part during Its term for cause Including, but not limited to: a. Violation of any terms or conditions of this permit. b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or c. A change In any condition that required either a temporary or permanent reduction or elimination of authorized air emissions. 9. For renewal of this permit the applicant shall make application not less than one-hundred eighty (180) days prior to the expiration date of the permit substantiated with current emissions data, test results or reports or other data as deemed necessary by the Mississippi Department of Natural Resources Permit Board. 10. Except for data determined to be confidential under the Mississippi Air & Water Pollution Control Law, all reports prepared In accordance with the terms of this permit shall be available for public Inspection at the offices of the Mississippi Department of Natural Resources Bureau of Pollution Control. 11. The Issuance of this permit does not convey any property rights In either real or personal property, or any exclusive privileges, nor does It authorize any Injury to private property or any Invasion of personal rights, nor any Infringement of Federal, State or local laws or regulations. 12. Nothing herein contained shall be construed as releasing the permittee from any liability for damage to persons or property by reason of the Installation, maintenance, or operation of the air cleaning facility, or from compliance with the applicable statutes of the State, or with local laws, regulations, or ordinances. 13. This permit Is non-transferable. 14. This permit Is for air pollution control purposes only. 4-5 ABD00023393 PART II Page 4 of 11 Penalt No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the boiler, Emission Point 001. Boilers: 1. Springfield No. L680 - 39.9 x lojj BTU/HR 2. Springfield No. L694 - 39.9 x 10b BTU/HR 3. Cleaver Brooks No. OL76 - 59.8 x 10 BTU/hr Such emissions shall be limited and monitored by the permittee as specified below: Boiler No. 1 EMISSION LIMITATIONS Particulate Matter 19.01 lbs/hr Sulfur Dioxide 95.76 lbs/hr Boiler No. 2 Particulate Matter 19.01 lbs/hr Sulfur Dioxide 95.76 Ibs/hr Boiler No. 3 Particulate Matter 26.64 lbs/hr Sulfur Dioxide 143.52 lbs/hr Also Included with this Emission Point Is the Vinyl Chloride Reaction and Monomer Storage Area. (See PART III of this Permit.) 4-6 ABD00023394 PART II Page 5 of 11 Penalt No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the PVC Dryers, Emission Point 002. PVC Oryers: 1. PVC Dryer #1 with Baghouse 2. PVC Dryer #2 with Baghouse 3. PVC Dryer #4 with Baghouse 4. PVC Dryer #5 with Baghouse 5. PVC Dryer #6 with Baghouse 6. PVC Dryer #7 with Baghouse 7. PVC Dryer #8 with Baghouse 8. Fluidized Bed PVC Dryer with Scrubber 9. Resin Reclaim Dryer with Baghouse Such emissions shall be limited and monitored by the permittee as specified below: Particulate Matter: 1. PVC Dryer #1 2. PVC Dryer #2 3. PVC Dryer #4 4. PVC Dryer #5 5. PVC Dryer #6 6. PVC Dryer #7 7. PVC Dryer #8 8. Fluidized Bed PVC Dryer 9. Resin Reclaim Dryer EMISSION LIMITATIONS 19.1 lbs/hr 19.1 Ibs/hr 19.1 lbs/hr 19.1 lbs/hr 19.1 Ibs/hr 19.1 lbs/hr 19.1 Ibs/hr 36.3 Ibs/hr 5.9 lbs/hr 4-7 ABD000233^5 % PART II Page 6 of 11 Penalt No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the PVC Storage and Handling Process, Emission Point 003. Thirty-five (35) baghouses are Included with this Emission Point for control of particulate matter. Such emissions shall be limited and monitored by the permittee as specified below: aiSSION LIMITATIONS Particulate Matter 36.4 lbs/hr - This represents the total mass limit for the entire Emission Point (all 35 baghouse combined). It Is based on a process weight rate of 26.0 tons per hour. 4-8 ABD00023396 PART II Page 7 of 11 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AM) MONITORING REQUIREMENTS During the period beginning February 23t 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Compound Production Area, Emission Point 004. This Includes all cyclones and baghouses associated with the process. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Particulate Matter 12.3 lbs/hr - Based on a process weight of 5.1 tons per hour. 4-9 ABD00023397 PART II Page 8 of II Peralt No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 22, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Ory Blend Production Area, Emission Point 005. This includes all particulate matter collection devices associated with the process. Such emissions shall be limited and monitored by the permittee as specified below: mission LIMITATIONS Particulate Matter 10.9 lbs/hr - Based on a process weight of 4 3 tons per hour. 4-10 ABD00023398 S. PART 11 Page 9 of 11 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Plasticizer Production Area, Emission Point 006. Such air emissions equipment shall be operated as efficiently as possible to provide the maximum reduction of air contaminants. 4-11 ABD00023399 . PART II Page 10 of 11 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Vinyl Chloride Monomer Incinerators, Emission Point 007. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Chlorine (Clg) 0.084 Ibs/hr and 0.368 tons/year Hydrogen Chloride (HC1) 0.086 Ibs/hr and 0.377 tons/year 4-12 ABD000234Q0 5. PART III Page 11 of 11 Penalt No. 1840-00014 PART III OTHER REQUIREMENTS (1) The permittee Is authorized to emit air contaminants from equipment and processes In accordance with the terms and conditions of the National Emission Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR Part 61 Subpart A - General Provisions and Subpart F - Vinyl Chloride. SR--154 4-13 ABD00023401 CONSTRUCTION J PERMIT________ ABD00023402 IV PERMITS B Permit for Construction of Air Emissions Equipment Although we are presently not required to have a Prevention of Significant Deterioration ("PSD") permit, we could trigger that requirement if we have new construction of $1 2MM or modifications of the process We are a major emitting facility because we emit or have the potential to emit 100 tons per year of particulates The new baghouses for the rotary dryers should bring us under the 100 tpy trigger point No new construction may be started on a major source or modification in any area where PSD requirements apply without preconstruction review of air quality impacts Therefore, we submitted a request for construction permits to install new baghouses on our rotary dryers. A copy of that request and consent is attached 4-14 ABD00023403 VistoRoKtnen AOivwonor Vista Chemical Company May 3, 1989 lighwv 25 Post Offica Box 91 Abratan Masnwoot 39730 Phon* 16011369-8111 Mr. Bobby V Whitaker North Air Emissions Section Mississippi Department of Natural Resources Bureau of Pollution Control P.0. Box 10385 Jackson, MS 39209 Dear Mr. Whitaker: Re: Construction Permit No 1840-00014 Aberdeen, Mississippi As ve discussed in a recent telephone conversation, the approved construction permit for a new baghouse on our dryers needs two modifications. The modifications requested are for limitations in fuel and production and volatile organic compounds. When ve discussed the rate of natural gas to the dryers, I gave you an average usage not a maximum. Please change the limitation on natural gas to the dryers to a rate of 180,000 scf per day. During the production of Poly Vinyl Chloride , a certain amount of residual vinyl chloride is contained in the PVC particle. As the PVC particle is handled through our process the vinyl chloride in the particle is given off. When the PVC particles reach our dryers, there is some residual vinyl chloride contained m them. This vinyl chloride is released during the drying process and would be vented out the baghouse. The maximum amount of vinyl chloride released in the drying process would be 0.1 lbs/hr or 0.438 tons/yr. If you have any questions, please give me a call at 369-3637 Sincerely, Frank G. Jeanso Environmental Coordinator c: RWS, RBN 4-15 ABD00023404 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control P O. Box 10385 Jackson, Mtsstssiopt 392894)385 (601)961-5171 -.pnl 13, -?&9 certified mail :;c. ? q65 ou oos Mr. Frank G. Jeansen Environmentai Coordinator Cista Polymers ?. 0. Box 91 Aberdeen, Mississippi 39730 Fear Mr. Jeansen: Re: Construction Permit No. 1340-00014 Aberdeen. Mississippi We nave completed our renew of* the plans and specifications for the above referenced permit and approval is hereoy indicated for air pollution control purposes only. Enclosed please find Construction Permit No. 1840-00014 for the construction of the air emissions equipment and air pollution control equipment. Prior to startup of the air emissions equipment at this facility, a Performance Evaluation Permit must be obtained from the Permit Board. In order to obtain the Performance Evaluation Permit, it vill be necessary to submit certification by a professional engineer registered m the State of Mississippi that construction vas completed m accordance with the approved plans and specifications and a written request for the permit. Any appeal of this permit action must be mace within the 30 day period provided for in Section 49-l7-29(4)(b) Mississippi Code of 1972. If you have any questions or if ve can be of any service, please let me know. Very truly yours 3W:eis Enclosure Bobby V. Whitaker North Air Emissions Section 4-16 ABD00023405 u H STATE OF MISSISSIPPI n i AIR POLLUTION CONTROL n PERMIT y TO CONSTRUCT AIR EMISSIONS EQUIPMENT n THIS CERTIFIES THAT u n Vista Polymers Highway 25 r Aberdeen, Mississippi i has been granted permission to construct air emissions equipment to comply with emission limitations, monitoring requirements and other conditions set forth herein. This permit Is Issued In accordance with the provisions of the Mississippi Air and Water Pollution Control Law (Section 49-17-1 et. seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder. Issued this 11th day of Aprl 1. 1989 i y p MISSISSIPPI NATURAL RESOURCES PERMIT BOARD y n y n y ft i director; bureau of pollution control MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES l f Permit No. 1840-00014 f i i 4-17 ABD00023406 PART X Page 2 of 9 Pewit No. 1840-00014 PART I GENERAL CONDITIONS 1. The plans, specifications, schedules, dates and other data submitted to the Permit Board are filed with and considered as a part of this permit. 2. All air pollution control facilities shall be designed and constructed such as to allow proper operation and maintenance of this permit. 3. The necessary facilities shall be constructed so that solids removed In the course of control of air emissions may be disposed of in a manner such as to prevent the solids from becoming windborne and to prevent the materials from entering State waters. 4 The air pollution control facilities shall be constructed such that diversion from or bypass of collection and control facilities is not needed except (1) where unavoidable to prevent loss of life or severe property damage or (11) when approved by the Mississippi Natural Resources Permit Board. 5. The construction of facilities shall be performed In such a manner as to reduce both point source and fugitive dust emissions to a minimum. 6. The permittee shall allow the Mississippi Department of Natural Resources 8ureau of Pollution Control and the Mississippi Natural Resources Permit Board and/or their representatives upon presentation of credentials: a. To enter upon the permittee's premises where an air emission source is located or In which any records are required to be kept under the terms and conditions of this permit; and b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equipment or monitoring method required in this permit; and to sample any air emission. 7 After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or In part during Its term for cause Including, but not limited to: a. Violation of any terms or conditions of this permit; b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts, or c. A change In any condition that requires either a temporary or permanent reduction or elimination of authorized air emissions. 4-18 ABD00023407 PART I Page 3 of 9 Permit Ho. 1840-00014 8 Except for data aetermined to be confidential under the Mississippi Air & Water Pollution Control Law, all reports prepared In accordance with the terms of this permrt shall be available for public inspection at the offices of the Mississippi Department of Natural Resources Bureau of Pollution Control. 9. The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any Injury to private property or any Invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. 10. Nothing herein contained shall be construed as releasing the permittee from any liability for damage to persons or property by reason of the Installation, maintenance, or operation of the air cleaning facility, or from compliance with the applicable statutes of the State, or with local laws, regulations, or ordinances. 11. This permit Is non-transferable. 12. This permit is for air pollution control purposes only. 13. Approval to construct will expire should construction not begin within one (1) year of the Issuance of this permit, or should construction be suspended for one (1) year or more. 14 This permit shall become void upon completion of construction. The permittee shall furnish the Bureau of Pollution Control written notification of construction completion within 15 days of such date. 15. Prior to startup of air emissions equipment at this source, a Performance Evaluation Permit must be obtained. The permittee shall submit certification by a professional engineer registered In the State of Mississippi that construction completed In accordance with the approved plans and specifications and a written request for the permit. 4-19 ABD00023408 PART II Page 4 of 9 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989, the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 3 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A. PM10 Sulfur Dioxide 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 Ib/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40X verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf oer day. 4-20 ABD00023409 PART II Page 5 of 9 Permit Ho. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 193?, the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse Mo. 4 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. MISSION LIMITATIONS ^articulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A PM10 Sulfur Dioxide Carbon Monoxide 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 6Q, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-21 ABD00023410 PART II Page 6 of 9 Permit Ho. i340-00014 PART II EMISSION LIMITATIONS ANO MONITORING REQUIREMENTS Beginning April 11, 1989*, the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 5 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS ^articulate Matter 2.4 lbs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A PM10 Sulfur Dioxide 2.4 Ibs/hr & 10.5 tons/year 0.004 lb/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 Ib/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 lbs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CER 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60. Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-22 ABD000234U PART II Page 7 of 9 Permit No. i840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April II, 1989; the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 6 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS ^articulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A PH10 Sulfur Dioxide 2.4 lbs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides Volatile Organic Compounds 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-23 ABD00023412 PART II Page 8 of 9 Pemit No. i340-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April ilt 1989. the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 7 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A PM 10 Sulfur Dioxide 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-24 ABD00023413 PART III Page 9 of 9 Permit No. 1840-00014 PART III OTHER REQUIRB4BTTS The operator of the equipment covered by this permit shall operate and maintain this equipment to assure that the emission rates will not, at any time, exceed the rates allowed by the Mississippi Air Emission Regulations. SR-158 4-25 ABD00023414 ABD00023415 VI PERMITS C State of Mississippi Water Pollution Control Permit This NPDES Permit Number MS0001970 expires March 31, 1991, and application for renewal needs to be made 180 days prior to the expiration data It gives effluent limitations and monitoring requirements for the following waste streams 001 002 003 004 Process Water from Pond 6 Outfall South of Pit #2 New Module non-contact cooling water and storm water Pit #1 non-contact cooling water and storm water Once through breathing air pump seal water 4-26 ABD000234^6 MISSISSIPPI DEPARTMENT 0? NATURAL RESOURCES Bureau of Pollution Control P. O. Bor. 10385 Jackson. Mississippi 39209 (601) 961-6171 June 23, 1986 CERTIFIED WAIL NO. P 283 765 578 Mr. John Friend Vista Polymers, Inc. P. 0. Box 91 Aberdeen, Mississippi 39730 Dear Mr. Friend: Re: NPDES Permit No. MS0001970 Enc aed is National Pollutant Discharge Elimination System (NPDES) Permit Num *r MS0001970, which is hereby issued to Vista Polymers, Inc. Please note the effluent limitations, schedule of compliance, monitoring requirements, monitoring reporting dates m Part I of the penult. This permit is issued in accordance with the provisions of the Mississippi Air and Vater Pollution Control Lav (Sections 49-17-1, et. seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder and under the authority granted to the Mississippi Natural Resources Permit Board pursuant to Section 402(b) of the Federal Water Pollution Control Act. If you desire that a Permit Board hearing be held regarding this permit, you must make written application to the Permit Board within thirty (30) days of receipt of this notice; otherwise, the terms, conditions and limitations of this permit become final. JEM:els Enclosure cc: Mr. Robert F. McGhee, E?A (v/encloaure) Mr. Warren Foster NRO (w/enclosure) 4-27 JUN? 6 ABD000234|7 State of Mississippi Water Pollution Control PERMIT To Discharge wastewater In accordance with the national pollutant Discharge Elimination System THIS CERTIFIES THAT VISTA POLYMERS* INC. Aberdeen, Mississippi has been granted permission to discharge wastewater mto Janes Creek r in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I. II, and III hereof. This permit is issued in accordance with the provisions of the Mississippi Water Pollution Control Law (Section 49-17-1 et seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder, and under authonty granted pursuant to Section 402 (b) of the Federal Water Pollution Control Act. MISSISSIPPI NATURAL RESOURCES PERMIT BOARD * 'J2C DIRECTOR. BUREAU OF POLLUTION CONTROL MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Issued: May 9, 1986 Expires: March 31, 1991 Permit No. MS0001970 4-28 o on O o ^ o(A ^s lu oo CS.2 oo eC to v O. Cl. Ha . EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS u 2? ACcOj c/s a 0 aw N c o s. ON o* Xwo 3 X a4> s CJ 8. 3 eoa 8 ae U0) Li <9 3 Vrt (wfl a3 . 0V4i ON W 39 x oeo5os ^ ew xIIE *8 = o. E ss M a a3 <2 s 0 3 a o X > X T13) C o teao 33 eI i CO Xut <uo/>o XCJ 2 a XCJ 3 CO ABD00023418 a1ost I If i Ip oc VuIoIi o CJ 036 0o Q. Cl Eo oE CJ CJ Vl V4 X1 XI -y *o CN CN a. a. a. oE oE Eo J CJ CJ c. E CJ uuu u XXXXX -4I >-3I >43I ,vCOl43I- CM CN fN CJ CM caSocj. o uoaB Xu Xu X -9I I9 Veg* CM CM CJ -0o) Vi o eos 4) X 00 c -4 o3o uO ^O4 0 4) 3 x oo 44 >4 a E 3 CO CO 41 X X <0 <9 U CO CO |4 X C -H 00 333 6oCo 4X34 X0-4) 3 *4 b4 44 ^4 X XX X X 01 3 V 01 Q) 4) 0) V V 3 3 33 3 3 Pu>4. 4v4*. 4uP4x U33W 3U Vi U t333 CO acIQ OB C a) -a x<0 44 41 (39 at 4 xu co 4r44 O X Li 3 C9 41 X "f0tx0 060 eo cn <r obmu li li II ON ocmn II II iI 3 Vi <9 cO u3 CO O ON c (9 X41 *4 uX CO o e 3 44 co > U X oa X )a4) x CO 431 *aQt X O 4 41 hC 4<U4u eCV a 4> sto co caoi o as i4 at at 3 O uat o e ofi at x CO eoo oeo O tft o cm so <n cm IlII I lI I *cOOwo* W*r*o9* xcn9 ccnn -c4m m cm so ON r**. m on cm cm co v_x W ^ f- CM co r** >-' i -4CO "t Ifl I CN CO CM 4 4 VO u4) CO II II H04)0 no C I II ItI T3 >4 <eO9 V *1 H x 4a4 44 U 44 434 44 > O' >4 at v >4 41 o *ao <44 eoo ce 44 >4 4e1 O 44 41 44 Oa. 00 3 c X CO T3 C C0 00 <on B p4 o n 44 U |4 X c co at x at x > oo > 41 O 3 O X oz co V <9 co X X at 44 at 49 41 OO *^>m>o/ cwrinnx cn ON SO -- CM /-\ X 9 J (N PS 44 *4 X l W S4 W j <J 4 Vfl xX mNO CoO X II II t\ x co r4 3 41 co cO 44 at 01 44 Sb xu X Ux 41 O *o at 4i fl 3 CO 41 4i o at -h * -- CO V CO c <4* at 3 s & fl Eg Si *o w c 3 i-4H o C/3 e *3 aoto 3 3 X 44 4i as. oato |4 QJ CO 3 cj at 00 CJ >s ova at o z /s 43J 3 oo co 3 3 H X 3 3 Vi X 00 V X u 434 3 *4 3 4c4 ^4 ev C 4>4 B 33 O u X41 U 3 Qi x 3 a CD co CD a fl fl O 3 *3 3 44 00 41 e e >s r4 ?C 3 3X 4i 3 O O c 4e4 41 3 Vi 3 >. 3 * CJ OO 33 X t 4J 3 X *3 fl X41 3 X e X4J i-4 3 O *3 >. c CO -|cm|o ^41 cm | a n Cl CO Vi r4*5" *3 M 3 3 3 U at U3 at co 41Z 3 44fl 4U 4J c s4 il 443 t3o B 3 44 XCJO CM . <A 4-29 I * 2(b) ABD00023419 or<-y> o o o C/3 O mZ t o<Qo 4C/ o. a. a> 2ea? X0 3 o o 8 c o 3<a S3 u s12 3 g a u yM0i <o 2 g--a> X O *4 -- C/3 n O Xc 0u (0 0U 4441 A X c4a> `3 3* & H OS < Cu CO H Z X z c eo 030 C *r C H ^2v2i O2O <6 S3 0 V u 1w Of 5 a 0 a 5 O' 6 X0 ui 8 >* z A c z V O co Z 0 i III * 5 o H ^ ci 01 O e o *Z o z a seo Va z oo < 5~ CO Z cV 0 X O 5H < H x *o g oe TAM3 M 0 8,-c ?8 eo? Xo H Z s ui 3 -J u. c^ O2 3o X 03 CO 2 Li. U < 00) c03 44 4C4 -4 u03 j to cc ou 0 E wo uufl A u3 W A uCO U il il u u Z4i AM Oc Oc c 0 oc oe os "ZNS, 'ZN'. Z N Z h z mm z mm f4 w* m* t 1 e^ m 00 0B0 00 B 00 E Wcionmn ooCN OCN O% -- CN O "4 -H w4 ^ B B00 00 00 00 BB 1 <0 1z^0mom 0mm cn o cn o ii -m^-ii ii 1 1 1 1 z ii -<- ii ii 1t 1 1 z CO Hu Qyy o<B--u* C0/3 * c3e U 1) (8 Zw Co Ou >. UV 0CL H 3 3 9) 'Xl ou n3 S3 1-1 U>Z. 0B. i-04 HB01 H4OJ XCuBOJ i-H 4oCJO h O- NeH 0Ho3 0a3 uU0eH iAh U 73 o -o 4) 81 O. u to 6 u 40_1l V<30 U<0-y1l 00 CO cH *uo 01 -CH i0*0 f-l JQJ AQH*H CU3 U0 <0H0 U iy-(h(45040C8a10lM<n0c3wJ ua) jo 03 goo B u 01 4J uoc 4931 iA0-)i A41 3 3 03 0Uc 03 u8) *HOu0 40J 0 a0. 0c *e0 v H 0 B 0 U 4J 0 aW0 4D0mJ a40J *CH h0 8C0 n>ns 0 b3e OC 3 U *0 C *0 40J ^*O0 J00C h c y *B4H 0 U A0 T3 U0 H C 0 0 W0t O 03 *0cH0 1-4 n-8 X091 0C W O <H 81 eH 0 ou Woi ^co4 8 X0 Xa -uw 0 x IlH-I 4J 40J ^O C *0 o 0 0 X0 *00 *0rt nCH 91 'O U It >043 00 *0CH XtO-l u0 I0t ISt o 0 0 0 1-1 S u0 a *j *J 0 <0 y0e 0a e 0 0 0a 801 iH*-3Jl X*J It i-0i 0 X 0 0 > h am *0 u0 u0M e 0 B X0 ii--Hy A0 0 C0 0 y0i e3 U0 0 *e0 40J 0 o 0\ e 0 X4J U0 0 u0 00 u 0c 40HJ c3 M0 0 *C0 y0> 0 Oso f0aH. C B0 X0 0 y> x u0 0 0 00 r0-l 0 A0 4J A -Hu 3 0e ayi if-Hl B o X0 0 B U xa. 0a X0 0o B Ho 0 U00 X0 0 *04 TJ Xy0| yi n-l y03i 00 # S0 y0t 0 yOi B3 y0> >4 0 B 0 o0 X0 rJ 0rt WQ. i-H yi u0 yi X0 X3 0 yt B X40J 0> X0 B y0Bt u Xy0j 0 BH 00 X i0y-tl 4V0Ji *-4 n0UB4.IW0BH B 0 0 Vi <0yi y0 40J B cw n0H XH 0H > 0B *M0r4 0 yi nB-l c3 Oa U 0 H3H 0 0 B0H0 y| r<O0nyi IM O 0 3040 0 X 0 0 r0y f0B40 Ut XH 0a yoHi QgB 0 0 0 0 yi Xy0t 0 V0t 0 0 0 X4f4J 3 u0 0c Ay0> yi y0i 0 3 *0rB40 B 0H 0 >H 0 0 0H *3 s 0 V0i 0 OB X0 0 BH B X0 B 04 0 0o A0 yi A4H4 3 0 X0 0 104 yi 00 00 0 ^B4 r0y a n3o-l 6 HM B X0H s C0/3 Moy >4 o cn cn <r 4-30 I-2(b) orOO <r Oto --z *** a Z <r ** cusnuo aCw. H Q EFFLU EN T LIM ITATIO N S AN D M ONITORING REQUIREMENTS uaha-o Xu S3 oNo c o 5 <30 O4). O X OO'' n u u 2 3? 3 4a-1 00 a C3 *2* .-t JS a0> cA to 0. B3 CU sO X4-1 CO O' a -- o c o O' >tO*< xo 00 .. eEt?J> x" *E2 oo *** XwQ"VU. -<G0M(r--A>>v 60S C *S Q5 3o o X X(/> M4> X<2Ct/j9?) S Xu C3/3 ABD00023420 1& 1* .n 3 0 a -j c a u .a M (Q MC O44 v auo c i SO --cH 3 o X0) CO A CO A A o ac c 3 TU3 C0*T(C03 xa 44 0440 4-1 <0 CO X a C CO a H c A TJ cO 3 4-1 H COi CO a3 X Uol C0ao> *i-~Ht CO 44 4-1 CO O Xa u CO 44 e ao X u o> fut Ato O. 4-1 Aa -o 3 CU X s< i <r ** 13 o2 at 12 u 1 < Oi m O' O m 4J c Ii O' m m AccO 44 4041 to 0M1 i I 00 i I UO c C O 01 H 01 B -B Uc04o oco. a (4o04i 4J 44 raH XH ea w 4Sa4 *ac< >ar4 > 44 H M 3O* 44 4a4 4aU a 4H-1 <i Ii e3 4a4 O ^aa4 rH oa <4-1 eo a 4cU 4-1 O4w4 *eoH h a 4acao4 60 eo a Crt 4-1 S a rX-r--tt iI a o 4) X ao CM U4 x4-i aa xi4-Jt aaay a4a4 Qd. So &s "O 43-i 5 <44410 is UA.H01 ca aa A44 a x4a4 a 60 iHa a a X A4UJ 4-1 0 e X4J xraS a Os xa 4a4 Xo. o. a au e oc O a6440 a X^ua4 T3 OC Xa ir-4H a Xa 4a4 a XH 3 4J 4aJ aa3 C 44 60 ta4 aa *cH iHa c ->4 oBcj xa4Joaa 44 hC 4a-i a e Xw a ^4aU aWa X<4Hj C3 ao a *h eo Ha.UaGft Ba Oo Xiu CO r-t S <N cn 4-31 I -2(a) ABD00023421 PARTI Page 5 of 14 Permit No MS0001970 B SCHEDULE OF COMPLIANCE 1 The permittee shall achieve compliance with the effluent limitations specified for discharge in accordance with the following schedule: 2. No later than 10 calendar days following a date identified in the above schedule of com pliance, the permittee shall submit either a report of progress or, in the case of specific actions bemg required by identified dates, a written notice of compliance or noncom pliance. In the latter case, the notice shall include the cause of noncomphance, any remedial actions taken, and the probability of meeting the next scheduled requirement. 4-32 ABD00023422 PARTI Page 6 of 14 Permit No. MS000197C B. MONITORING AND REPORTING 1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. 2. Reporting Monitoring results obtained during the month shall be summarized and reported on a Discharge Monitoring Report Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following the completed reporting month. The first report is due on July 28, 1986. Copies of these, and all other reports required herein, shall be signed in accor dance with Section 6 and 7 of the Mississippi Wastewater Permit Regulations, and shall be submitted to the Mississippi Natural Resources Permit Board at the following address: MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES* BUREAU OF POLLUTION CONTROL P.O.Box 10385 Jackson, Mississippi 39209 3. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304(h) of the Federal Water Pollution Control Act, as amended. 4. Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: a. The exact place, date, and time of sampling; b. The dates the analyses were performed; c. The peison(s) who performed the analyses; d. The analytical techniques or methods used; and e. The results of all required analyses. 5. Records Retention a. AH records and information resulting from the monitoring activities required by this permit (including all records of: analyses performed; calibration and main* tenance of instrumentation; and recording from continuous monitoring instru mentation) shall be retained for a minimum of three (3) yean, or longer if re quested by the Permit Board. 4-33 ABD00023423 PARTI Page 7 of 14 Permit No. MS0001970 b. The permittee shall furnish to the Permit Board, upon request, copies of records required to be kept by this permit 6. Definitions a. The "monthly average*' (applicable to municipal and domestic permits), other than for fecal conform bacteria, is the arithmetic mean of all samples collected in a oDMnonth penod. The monthly average for fecal conform bacteria is the geometric men of all samples collected in a one-month penod. In computing the geometric men, one (1) shall be substituted for sample results of zero. b. The "weekly average** (applicable to mumopal permits), other thn for fecal colifonn bactena, a the anthmetic men of all the samples collected during a one-week penod. The weekly average for fecal cohform bactena is the geomet ric men of all samples collected during a one-week penod. In computing the geometric mean, one (1) shall be substituted for sample results of zero. For teif-momtoring purposes the value to be reported is the single highest weekly average computed during a one-month penod. c. The "daily avenge" (applicable to industrial permits), other thn for fecal coii- foon bactena, is the anthmetic men of all collected in a one-month period. The daily average for fecal cohform bactena is the geometric men of all samples collected in s one-month penod. In computing the geometric men, the value one (1) shall be substituted for sample results of zero. d. The "daily maximum" (applicable to industrial and domestic permits), is the highest value recorded of ny sample collected on ny single day of the calendar month. 4-34 ABD00023424 <. PART II Page 3 of 14 Permit No. MS000I9 PART II A. MANAGEMENT REQUIREMENTS 1. Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified m this permit more frequently than or at a level in excess of that authorized constitute a violation of the per* nut. Any anticipated facility expansions or treatment modifications which will re sult m new, different, or increased discharges of pollutants must be reported by sub* mission of a new NPDES application. If such changes will not violate the effluent limitations specified in this permit, and upon written notice (in Heu of a new NPDES application) to the Mississippi Natural Resources Permit Board, the permit may be modified to specify and limit any pollutants not previously limited. 2. Noncompliance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any provision specified in this permit, the permittee shall notify the Mississippi Pollution Control Permit Board orally within 24 hours of becoming aware of such conditions. A written report shall also be provided within five (5) days of such time and shall contain the following information: a. A description of the discharge and cause of noncompliance; and b. The period of noncompliance, including exact dates and times; or if not cor* reeled, the anticipated time the noncomphance is expected to continue, and steps bemg taken to reduce, eliminate and prevent recurrence of the noncomply* ing discharge. 3. Facilities Operation The permittee shall at all tunes maintain m good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. 4. Advene Impact The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment 5. Bypassing Any diversion from or bypass of wastewater collection and treatment facilities is prohibited, except (i) where unavoidable to prevent loss of life or severe property damage, or (ii) where excessive storm drainage or runoff would damage any facili ties necessary for compliance with the effluent limitations and prohibitions of this permit 4-35 t T>9 ABD00023425 S. PART II Page 9 of 14 Permit No. MSOOOL970 The permittee shall notify the Natural Resources Permit Board orally of each such diversion or bypass within 24 hours of the diversion or bypass, or if the need for the bypass is known m advance, it shall submit pnor notice, if possible, at least ten (10) days before the date of the bypass. 6. Removed Substances Solids, sludges, filter uackwash, or other residuals removed in the course of treat ment or control of wastewaters shall be disposed of-in a manner such as to prevent such materials from entering State waters and in a manner consistent with the Missis sippi Solid Waste Disposal Act and the Federal Resource Conservation and Recovery Act 7. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either: a. In accordance with the Schedule of Compliance contamed in Part I, provide an alternate power source sufficient to operate the wastewater collection and treat ment facilities, or, if such alternate power source is not in existence, and no date for its implementation appears m Part I, b. Provide a method whereby the effluent limitations contained m Part I shall be met upon the reduction, loss, or failure of the primary source of power to the wastewater collection and treatment facilities. B. RESPONSIBILITIES 1. Right of Entry The permittee shall allow the Mississippi Natural Resources Permit Board and the Regional Administrator of the U.S. Environmental Protection Agency and/or their authonzed representatives, upon the presentation of credentials. a. To enter upon the permittee's premises where an effluent source is located or in which any records are required to be kept under the terms and conditions of this permit; and b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equip ment or momtonng method required m this permit; and to sample any discharge of pollutants. 2. Transfer of Ownership or Control This permit is not transferable to any person except after proper notice. In the event of any change in control or ownership of facilities from which the authonzed discharges emanate, the permittee shall notify the Misasnppi Natural Resources 4-36 ABD00023426 i PART II Page 10 of 14 Permit No. MS0001970 Permit Board at least thirty (30) days in advance of the proposed transfer date. The notice should include a written agreement between the existing and new permittees containing a specific date for the transfer of permit responsibility, coverage, and lia bility. 3. Availability of Records Except for data determined to be confidential under tne Misrimppi Water Pollution Control Law, all reports prepared m accordance with the terms of this permit shall be available for public inspection at the office of the mi--Department of Natural Resources Bureau of Pollution Control 4. Permit Modification a. The permittee shall furnish to the Permit Board within a reasonable any relevant information which die Permit Board may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. b. Upon sufficient cause this permit may be modified, revoked, reissued, or termi nated during its term. c. The filing of a request by the permittee for a permit modification, or a notifi cation of planned changes or anticipated noncomphance, does not stay any permit condition. 5. Toxic Pollutants The permittee shall comply with any toxic effluent standard or prohibition (in cluding any schedule of compliance specified in such effluent standard or prohi bition) established under Section 307(a) of the Federal Water Pollution Control Act. 6. Civil and Criminal Liability a. Any person who violates a term, condition or schedule of compliance contained within this permit or the Mississippi Water Pollution Control Law is subject to the actions defined by law. b. Except at provided in permit conditions on "Bypassing" (Part II, A-5), nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncomphance. c. It shall not be the defense of the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. 7. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties 4-37 MDI-5 ABD00023427 part ii Page 11 oZ 14 Permit No. MS0Q0L970 to which the permittee is or may be subject to under Section 311 of the Federal Water Pollution Control Act and applicable provisions of the Mississippi Water Pollu tion Control Law pertaining to spills of oil and hazardous materials. 8. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State, or local laws or regulations. 9. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstance, and the remainder of this permit, shall not be affected thereby. 10. Expiration of Permit The permittee shall not discharge after the expiration date of this permit unless he has submitted a completed application for reissuance no later than 180 days pnor to the expiration date. The Executive Director may grant permission to submit an application later than this, but no later than the expiration date of the pemut. 4-38 ABD00023428 % PART III Page 12 of 14 Permit No. MS0001970 PART III A. REOPENER CLAUSE This permit shall be modified* or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation Issued or approved under Section 301(b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Federal Water Pollution Control Act if the effluent standard or limitation so issued or approved: 1. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or 2. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable. B. TOXIC POLLUTANTS NOTIFICATION REQUIREMENTS The permittee shall comply with the applicable provisions of 40 CFR 122.42. C. CLOSURE REQU: STS Should the permittee decide to permanently close and abandon the premises upon which it operates, it shall so notify the Permit Board no later than 90 days prior to doing so. Accompanying this notification shall be a closure plan which describes how and when all manufactured products, byproducts, raw materials, stored chemicals, and solid and liquid wastes will be removed from the premises such that they will present no potential environmental hazard to the area. Abandonment of the site without providing proper notification as required herein, or without completing all aspects of the closure plan, will constitute a violation of this permit and may result in penalties of up to $25,000. 4-39 ABD00023429 PART III 13 of 14 Permit No. MS0001970 D. BIOSSAT REQUIREMEHTS The Vater Quality Standards of Mississippi require that all waters be free from aubstancea in concentrations or combinations which are harmful to humans, animals, or aquatic life (State of Mississippi, Vater Quality Criteria for intrastate. Interstate and Coastal Waters. Section II.4. Minimum Conditions Applicable to All Vatera, page 3, adopted November 12, 1974). In accordance with such requirements, the permittee is authorised to discharge from outfall(s) 001 (process Vastewater) only in accordance with the following conditions: 1. The permittee shall submit any existing toxicity data for review by Mississippi Bureau of Pollution Control within 30 days of the effective date of this permit. 2. The permittee shall initiate the following series of tests within 60 days of the effective date of issuance of the permit to evaluate wastewater toxicity. The permittee shall conduct a 7-day Ceriodaphnia survival and reproduction test, and Pimephales promelaa (fathead minnows) larval survival and growth test (or use the embryo-larval survival term-' togeneals test) on different concentrations of effluent to determine if the discharge from outfall 001 is chronically toxic. Such testing will determine if the vater affects the* survival reproduction of the teata organisms* Such testing will be conducted using 24-hour composite samples of effluent collected daily. Chronic toxicity will be demonstrated if: 1) there is a 20% or more difference in survival between test organisms exposed to appropriate control water and any serial dilution of the effluent; or 2) there is a statistically significant difference at the S5% confidence level In reproduction between Ceriodaphw< exposed to an appro priate control vater and any serial dilution of the effluent* Dilution vater should be taken from the receiving vater at a point as close as possible to the outfall, but upstream from the sons influenced by the effluent* When the receiving stream has no flow, a substitute dilution vater must have a total hardness, total alkalinity, and specific con ductance vithln 25 percent, and pH within 0.2 units, of the receiving water. 3. a. Such chronic toxicity tests shall be conducted once/quarter (with organism type being alternatively used) for a period of one year following the effective date of the permit. After the first year of testing, fre quency of monitoring will be reduced to 1/6 months for the life of the pexmit* The first 6 month test will evaluate Ceriodaphnia according to the testing requirements in B* 2. The second 6 month test will evaluate Pimephalea promelaa (fathead minnows) according to the testing require ments in B*2* These organisms will be alternatively tested every six 6 months* If any one test during this period indicates the presence of chronic toxicity, then another confirmatory chronic toxicity test will be conducted within 2 weeks. If this confirmatory test indicates the presence of chronic toxicity, then the provisions of Section 3(b) shall apply* If no chronic toxicity is indicated in this confirmatory test, then the pro visions of Section 3(b) will not apply. The results of each toxicity test shall be submitted to Mississippi Bureau of Pollution Control within 2 weeks of completion of testing. 4-40 ABD00023430 i Page 14 of 14 Permit No. MS0001970 b. If the presence of chronic toxicity is confirmed, this will constitute a violation of Part I of this permit. The permittee will then be subject to the provisions of the Section 5. 4. All quality assurance criteria used shall be in accordance with short-term Methods for Eat*ting the Chronic Toxicity of Elluents to Freshwater Organisms, EPA-600/4-85. All test organisms and procedures used shall be in accordance with Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms, Section 12; Cerlodaphnia Survival and Reproduction Test Method 702.0. 5. In the event that after review of the above studies, the Mississippi Natural Resources Permit Board determines the waste stream is toxic to the receiving stream , the permittee shall: A. Provide plans and specifications to reduce the toxicity of the waste discharge to safe levels. (Safe levels will be determined by the Mississippi Natural Resources Permit Board). B. Develop a schedule for implementing this plan. 1 in large rivers, lakes and estuaries the permittee must provide a schematic map showing isopletha of waste concentrations. 4-41 ABD00023431 ABD00023432 3IV PERMITS D Historical Emissions of VCM Attached is a history of VCM NESHAP's enforcement at the Aberdeen plant The plant is no longer undir a compliance plan and hasn't had a release of VCM since 1986. We are presently reviewing the need for Compliance Plan refresher training The second attachment is a copy of the SARA 313 Emissions for all PVC plants in the United States They are listed alphabetically, by stack emissions, by fugitive emissions and total emissions The third attachment is a list of all the SARA 313 Emissions from the Aberdeen plant 4-42 ABD00023433 HISTORY OF VCM NESHAP'S ENFORCEMENT Oct. 20, 1976 Jan. 19, 1977 Feb 2, 1979 Jan. 19, 1980 Apr. 3, 1980 Apr. 7, 1980 Sept 16, 1981 Oct. 16, 1981 Nov 5, 1981 Jan 11, 1982 June 10, 1982 Jan. 13, 1983 Dec. 18, 1983 VCM Neshap's Promulgated VCM Neshap's Becomes Effective RVD 25,500 lbs. RVD 24 lbs. RVD 180 lbs. RVD 36 lbs. RVD 20 lbs. RVD 357 lbs. RVD 89 lbs. RVD 3-7 lbs. RVD 57 lbs. RVD Manual Vent 222 lbs. 229 lbs. D-300 D-400 D-9 D-9 Charge filter T-201 Charge filter Recovered monomer condenser Recovered monomer condenser D-745 ? Feb 1, 1984 After July 20, 1984 Aug. 19, 1985 Sept. 16, 1985 Oct. 25, 1985 Nov. 14, 1985 Dec. 31, 1985 Conoco Sued by DOJ on behalf of EPA July voluntarily becomes a party to the suit. Vista & Conoco agree to settle out of court. $100,000 penalty Agree to submit a compliance plan. Compliance plan submitted to EPA. Suggest 3 projects plus administrative; asks for ROL equivalency EPA asks for more information Vista sends more information EPA tentatively approved plan; they do not approve ROL equivalencies. 1- - 4-43 Mar. 27, 1986 Apr. 1, 1986 Apr. 3, 1986 Dec. 23, 1986 July 27, 1986 Aug 8, 1986 Mar 11, 1987 Apr. 14, 1987 Aug. 6, 1987 Nov 7, 1987 ABD00023434 EPA approves ROL equivalency. AFE for projects submitted. $107,500 1. Reactor valve limit switches 2. Water Stripper T/P recorder 3. New module BD Tank level indicator Conoco EPA Approves compliance plan. Three projects complete. VCM release VCM release MS Bureau of Pollution Control issues complaint releases Vista settles with the State for $2,000 Termination filed on the consent decree Case closed. 2- 4-44 ABD00023435 S. kn hisskms/m lis raooucnai rosm* u ta oi* total StffpMtiM iis p tfiiM rt*i Fugitive stick iinu lo t* veil missims ilk i. x R^ k*SSRS X ss 5" KX X 2 2* S^SSjgS 8 *=s-* *2 S8 2 -3 5-52S8 2 - 2X22^~2 3 XS 2 83 ! 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CM CO to <x> r-K co CP> o /j.'ih H fH _L__ t CM fH < (-- O H- ABD00023447 ABD00023448 /L u/ -- Environmental Coordinators To Inforofflca Communication From Dole Subject David Cohen May 20, 1988 AIR PERMITTING PROCESS Please note the following clarification of my May 11, 1988 memo concerning the air permitting process: Sources subject to National Emissions Standards for Equipment Leaks (NESEL), a subpart of the NESHAPs rules, need not also comply with NSPS requirements. (See 40 CFR 61.240(c)). In order to be subject to NESEL, a source must be intended for operation in volatile hazardous air pollutant (VHAP) service. Subject sources include pumps, compressors, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, flanges and other connectors, product accumulator vessels and control devices or systems. "Product accumulator vessel" is defined as any distillate receiver, bottoms receiver, surge control vessel, or product separator in VHAP service that is vented to the atmosphere. A product accumulator vessel is considered to be in VHAP service if the liquid or vapor in the vessel is at least 10% by weight VHAP. VHAPs include benzene and vinyl chloride. As a result of this rule, a valve regulated by a NESEL obviously must comply with the NESEL, but is exempt from any otherwise applicable NSPS. Thus, modification or reconstruction of such equipment may be accomplished without going through the NSPS procedure. Of course, any equipment not regulated by a NESEL is not eligible for this exemption. In addition, please be aware that EPA recently issued a policy memo stating that in reviewing PSD permit applications, the Agency will place the burden on the applicant to justify use of control technology which will not achieve LAER (lowest achievable emissions rate). The two allowable justifications for higher emissions rates than LAER will be technical feasibility and cost. Unless an applicant can justify to EPA such higher emissions rates, LAER will be required. H r a n An UU V 1 \J VWMC1) /bi 52.die 4-57 \'6A1 / L/- ABD00023449 To Environmental Coordinators Interoffice Communication From Dote Subject David Cohen May 11, 1988 AIR PERMITTING PROCESS: PSD AND NSPS OVERVIEW Introduction This memo discusses the basic elements of the PSD and NSPS programs. More specifically, it describes the process of obtaining a PSD permit, and indicates various things to consider when modifying or expanding plant operations. Please bear in mind that this memo describes federal programs. State programs may differ slightly. Also remember that the following is merely a summary of the PSD and NSPS programs. You must carefully read the actual regulations prior to taking any action that may be regulated under these programs. Pursuant to the Clean Air Act, the EPA has established National Ambient Air Quality Standards ("NAAQS") for each criteria pollutant. "Criteria pollutants" include sulfur oxides, carbon monoxide, total suspended particulates, nitrogen dioxide, photochemical oxidants and lead. Each state is divided into air quality regions, and each region is placed in one of two categories -- attainment or non-attainment -- for each criteria pollutant. An "attainment" area for a particular pollutant is an area in which the ambient air quality meets the NAAQS for that pollutant. A "non-attainment area" for a particular pollutant is an area in which the ambient air quality does not meet the NAAQS for that pollutant. It is important to note that a region can be an attainment area for one pollutant and a non-attainment area for a different pollutant. In order to ensure that ambient air quality remains below NAAQS in attainment areas and meets NAAQS in non-attainment areas, the Clean Air Act ("the Act") requires that states promulgate State Implementation Plans ("SIPs"). The SIPs contain pre-construction review procedures for major new sources of air pollution. Additionally, EPA has adopted technology-based New Source Performance Standards ("NSPS"), which set emissions limits on certain new or modified facilities. PSD Issues Each SIP contains Prevention of Significant Deterioration ("PSD") requirements. These requirements apply in attainment areas, as well as in areas that are unclassifiable with respect to the NAAQS. They set maximum allowable increases in ambient air pollutant concentration levels ("increments") for certain 4-58 ABD00023450 It Environmental Coordinators May 11, 1988 Page 2 pollutants, and are designed to ensure that the air quality in attainment areas remains below the NAAQS for those areas. Thus, PSD permits allow facilities to increase the concentration of a specific pollutant, in an area that meets the NAAQS for that pollutant, by a set amount -- a portion of the area's increment. The size of the increment for each area depends on the area's classification. The PSD regulations establish 3 separate classes for air pollution control regions. Class I areas include such things as large national parks and wildlife areas, and allow only minimal increases in pollutant concentration over baseline concentrations. Class II areas provide for larger maximum allowable increases, and Class III areas provide the largest maximum allowable increases. All Vista plants are located in class II areas for all pollutants they emit. PSD permit requirements apply only to major stationary sources and major modifications of stationary sources. "Major stationary sources" are defined as stationary sources, including chemical process plants, which emit, or have the potential to emit, 100 tons or more per year of any pollutant subject to regulation under the Act. Thus, unlike the NAAQS program, the PSD program does not make its category determinations on a pollutant- specific basis. In other words, if a plant is a major stationary source because of a single pollutant, it Is a major stationary source under the PSD program. Fugitive emissions from chemical process plants must be included in determining whether a stationary source is major. 4Mrthat any physical change that occurs at a non-major stationary source will not make the source major unless the change would by itself constitute a major source, i.e., emit, or have the potential to emit, 100 tons or more per year of a regulated pollutant. For example, a source that emits 90 tons per year of SOg is not major. If the source implemented a modification that increased SO2 emissions by 90 tons per year, the modification would not be major. OTcmirsm^-mncm*tfcrmodification in compl mlm year*. vt wi 1V be considered major for all future calculations. , A "major modification" is any physical change in, or change in the method of operation of, a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act. A "physical change or change in the method of operation" does nflt mean routine maintenance, repair or replacement of equipment, various uses of new fuels as specified at 40 CFR 52.21(b) (2) (m j (dj-(e), increased hours of operation, increased rate of production (unless such increase would be prohibited under a federally enforceable PSD permit) or changes in ownership. A "significant" emissions increase is defined as a rate of emissions equal to or greater than the following: 4-59 ABD00023451 MaTn%n88a' C0rdlnat0rs Page 3 Pollutant and Emissions Rate Carbon Monoxide: 100 tons per year (tpy) Nitrogen oxides: 40 tpy Sulfur dioxide: 40 tpy Particulate matter: 25 tpy of particulate matter emissions; 15 tpy of PM10 emissions Ozone: 40 tpy of volatile organic compounds Lead: 0*6 tpy Asbestos: 0.007 tpy Beryllium: 0.0004 tpy Mercury: 0.1 tpy Vinyl chloride: 1 tpy/ Fluorides: 3 tpy Sulfuric acid mist: 7 tpy Hydrogen sulfide (H2S): 10 tpy Total reduced sulfur (including H2S): 10 tpy Reduced sulfur compounds (including H2S): 10 tpy Several exemptions to the PSO rules exist for older facilities (see 40 CFR 52.21(1)(4) and (7)). The requirement of conducting impact and air quality analyses as they relate to any maximum allowable increase for a class II area does not apply to any major modification of a stationary source that was in existence on March 1, 1978, if the net increase in allowable emissions of each pollutant subject to regulation under the Act from the modification after the application of best available control technology would be less than 50 tons per year. In addition, the Administrator may, at his discretion, exempt facilities that submit complete permit applications by June 1, 1988 from various pre-application air quality monitoring requirements. Also, the Administrator may exempt a stationary source or modification from pre-application air quality monitoring requirements for a specific pollutant if the emissions increase of the pollutant from the new source or the net emissions Increase of the pollutant from the modification would cause in any area air quality impacts less than the following amounts: Carbon monoxide - 575 ug/m3, 8-hour average; Nitrogen dioxide - 14 ug/m3, annual average; Particulate matter: 10 ug/m3 of TSP, 24-hour average; i0 ug/m3 ot PM10, 24-hour average; Sulfur dioxide - 13 ug/m3, 24-hour average; Ozone; Lead - 0.1 ug/m3, 3-month average; Mercury - 0.25 ug/m3, 24-hour average; Beryllium - 0.002 ug/m3, 24-hour average; Fluorides - 0.25 ug/m3, 24-hour average; 4-60 ABD00023452 Environmental Coordinators May 11, 1988 Page 4 Vinyl chloride - 15 ug/m3, 24-hour average; Total reduced sulfur - 10 ug/m3, 1-hour average; Hydrogen sulfide - 0.2 ug/m3, 1-hour average; Reduced sulfur compounds - 10 ug/m3, 1-hour average; The administrator may also make such an exemption if the concentrations of the pollutant in the area that the source or modification would affect are less than these concentrations, or the pollutant is not listed on this list. The PSD permit regulations contain five major categories of requirements. Under the first category, "control technology review", major stationary sources and major modifications must meet all applicable emissions limitations under the SIP, as well as all performance standards required by NSPS or NESHAPS. In addition, each new major stationary source must apply the best available control technology ("BACT") for each pollutant subject to regulation under the Act that it would have the potential to emit in significant amounts. Similarly, major modifications must apply BACT for each pollutant subject to regulation under the Act for which the modification would result in a significant flftt emissions increase at the source. Note that throughout the PSD rules, when calculating the total emissions from a source undergoing a major modification, facilities are allowed to "net out" their emissions, i.e., subtract the total decrease from the total increase. Recognize, also, that once the requirement to use BACT is triggered, it applies to each proposed "emissions unit" (any part of a stationary source with the potential to emit any pollutant regulated under the Act) at which a significant net emissions increase in the triggering pollutant would occur as a result of the modification. Be aware also that for phased construction projects BACT determinations must be periodically reviewed and, where appropriate, modified. The second major category of requirements under the PSD permit regulations is "source impact analysis." These regulations require the owner/operator of the proposed new source or modification to demonstrate that the proposed increase m emissions will not cause or contribute to air pollution in violation of any NAAQS in any air quality control region or any applicable maximum allowable Increase over the baseline concentration in any area. The third category is "air quality modeling." This section requires that all estimates of ambient air concentrations be based on the applicable air quality models, data bases and other requirements specified in EPA's modeling guidelines. These models may be modified, or other models may be substituted, only after notice and opportunity for comment by the public, and written approval by the Administrator. 4-61 ABD00023453 k Environmental Coordinators May 11, 1988 Page 5 The fourth category is "air quality analysis." PSO permit applications must contain an analysis of ambient air quality for each pollutant that a new source might emit in a significant amount or for which a modification would result in a significant net increase. In addition, the analyses must include at least a year of continuous pre-application monitoring for such pollutants. Post-construction monitoring as EPA or the state deems necessary may also be required. > The last category is "source information." These regulations require the PSD permit applicant to submit, at a minimum, information on the nature, location, design capacity and typical operating schedule of the source or modification, a construction schedule and various technical information needed to determine which BACT is appropriate. The application must also include an analysis of impairment to visibility, soils and vegetation in the area that would result from the new source or modification. NSPS Issues Separate and apart from the PSD permitting process are the New Source Performance Standards ("NSPS"). NSPS are set out at 40 CFR Part 60, Subparts D through PPP, and specify which processes and types of equipment they cover (see Appendix). These standards are applicable to owners/operators of any stationary source that contains an affected facility, the construction or modification of which is commenced after the date of publication of any proposed NSPS applicable to that facility. Sources subject to National Emission Standards for Hazardous Air Pollutants ("NESHAPs") must also comply with any and all applicable NESHAPs. An "affected facility" is any apparatus to which a standard is applicable. "Modification" Is defined as any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted. The following are jjfli considered modifications: 1. routine maintenance, repair and replacement; 2. increased production that can be accomplished without capital expenditure (Note: "capital expenditure" means an expenditure for a physical or operational change to an existing facility which exceeds the product of the applicable "annual asset guideline repair allowance percentage1' specified in the latest addition of IRS publication 534 and the facility's existing basis, as 4-62 ABD00023454 Environmental Coordinators May 11, 1988 Page 6 defined in section 1012 of the Internal Revenue Code. The total expenditure for a physical or operational change to an existing facility may not be reduced for any "excluded additions" as defined in IRS publication 534. For obvious reasons, I recommend that anybody who believes his plant might be eligible for this exemption work with the Tax, Environmental and Legal Departments to determine whether the exemption applies); 3. increased hours of operation; 4. certain changes in type of fuel or raw material used; 5. addition of a system or device whose primary function is to reduce air pollutants, unless the new device or system is less environmentally beneficial than the one it replaces; 6. relocation or change in ownership of an existing facility. Facilities must achieve compliance with all applicable standards within 180 days of the completion of any modification that requires compliance with such standards. In addition to the foregoing, existing facilities must comply with NSPS upon undergoing reconstruction, regardless of whether such reconstruction effects any change in emissions. "Reconstruction" is defined as the replacement of components of an existing facility to such an extent that the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, and it is technically and economically feasible to meet the applicable standards set forth under NSPS. "Fixed capital cost" is defined as the capital needed to replace all the depreciable components. An owner/operator planning to replace components, where the fixed capital costs of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility must notify the Administrator of the proposed replacements 60 days (or as soon as practicable) before construction of the replacements commences. The notification must include various items specified at 40 CFR 60.15(d). Upon receipt of the notification, the Administrator has 30 days to determine whether the proposed replacement constitutes reconstruction. 4-63 ABD00023455 Environmental Coordinators Hay 11, 1988 Page 7 Owners/operators of facilities subject to NSPS standards must notify the Administrator of the following things: 1. the date construction or reconstruction of an affected facility is commenced, within 30 days of the date of commencement; 2. the anticipated start-up date of an affected facility, not more than 60 days nor less than 30 days prior to such date; 3. the actual date of initial start-up of an affected facility within 15 days after such date; 4. any non-exempt physical or operational change that may increase emissions of any air pollutant to which a standard applies, within 60 days or as soon as practicable before the change is commenced; 5* the date upon which continuous monitoring system performance commences, not less than 30 days prior to such date; 6. the anticipated date for conducting opacity observations, and the type of test to be used, not less than 30 days prior to such date; In addition, owners/operators of facilities subject to NSPS standards must maintain extensive records regarding operations and monitoring at the facility (see 40 CFR 60.7(b), (c) and (d)j. NSPS regulations also require affected facilities to conduct performance tests, as specified in 40 CFR 60.8, opacity observations as described in 40 CFR 60.11, and continuous monitoring, as specified at 40 CFR 60.13. As you can see, the PSD and NSPS programs are extremely complex. Accordingly, I urge you to scrutinize the regulations and consult with the Legal and Environmental Departments in Houston whenever you consider modifying or expanding plant operations. David Cohen /bi 32.die.1 4-64 ABD00023456 h APPPWX The following is a list of standards of performance for new stationary sources (NSPSs): Subpart 0 - Subpart Da - Subpart Db Subpart E Subpart F Subpart G Subpart H Subpart I Subpart J Subpart K - Subpart Ka - Subpart Kb - Subpart L Subpart M - Standards of Performance for Fossil-Fuel Fired Steam Generators for Which Construction is Commenced After August 17, 1971 Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978 Standards of Performance for Industrial Commercial-Institutional Steam Generating Units Standards of Performance for Incinerators Standards of Performance for Portland Cement Plants Standards of Performance for Nitric Acid Plants Standards of Performance for Sulfuric Acid Plants Standards of Performance for Asphalt Concrete Plants Standards of Performance for Petroleum Refineries Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction Reconstruction, or Modification Commenced after July 23, 1984 Standards of Performance for Secondary Lead Smelters Standards of Performance for Secondary Brass and Bronze Production Plants 4-65 ABD00023457 Subpart N Subpart Na - Subpart 0 - Subpart P - Subpart Q Subpart R Subpart S - Subpart T - Subpart U Subpart V Subpart W Subpart X - Subpart Y Subpart Z Subpart AA - Subpart AAa - Standards of Performance for Primary Emissions from Basic Oxygen Process Furnaces for Which Construction is Commenced After June 11, 1973 Standards of Performance for Secondary Emissions from Basic Oxygen Process Steelmaking Facilities for Which Construction is Commenced After January 20, 1983 Standards of Performance for Sewage Treatment Plants Standards of Performance for Primary Copper Smelters Standards of Performance for Primary Zinc Smelters Standards of Performance for Primary Lead Smelters Standards of Performance for Primary Aluminum Reduction Plants Standards of Performance for the Phosphate Fertilizer Industry: Wet-Process Phosphoric Acid Plants Standards of Performance for the Phosphate Fertilizer Industry: Superphosphoric Acid Plants Standards of Performance for the Phosphate Fertilizer Industry: Diammomum Phosphate Plants Standards of Performance for the Phosphate Fertilizer Industry: Triple Superphosphate Plants Standards of Performance for the Phosphate Fertilizer Industry: Granular Triple Superphosphate Storage Facilities Standards of Performance for Coal Preparation Plants Standards of Performance for Ferroalloy Production Facilities Standards of Performance for Steel Plants: Electric Arc Furnaces Constructed After October 21, 1974 and on or Before August 17, 1983 Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 7, 1983 4-66 ABD00023458 % Subpart GB Subpart CC Subpart DD Subpart EE Subpart FF Subpart GG Subpart HH Subpart KK Subpart LL Subpart MM Subpart NN Subpart PP Subpart QQ Subpart RR Subpart SS Subpart TT Subpart UU Srtpart-VV Subpart WW - Standards of Performance for Kraft Pulp Mills Standards of Performance for Glass Manufacturing Plants Standards of Performance to Grain Elevators Standards of Performance for Surface Coating of Metal Furniture Reserved Standards of Performance for Stationary Gas Turbines Standards of Performance for Lime Manufacturing Plants Standards of Performance for Lead-Acid Battery Manufacturing Plants Standards of Performance for Metallic Mineral Processing Plants Standards of Performance for Automobile and LightDuty Truck Surface Coating Operations Standards of Performance for Phosphate Rock Plants Standards of Performance for Ammonium Sulfate Manufacture Standards of Performance for the Graphic Arts Industry: Publication Rotogravure Printing Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations Standards of Performance for Industrial Surface Coating: Large Appliances Standards of Performance for Metal Coil Surface Coating Standards of Performance for Asphalt Processing and Asphalt Roofing Manufacture Standards^of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicalv Manufacturing Industry Standards of Performance for the Beverage Can Surface Coating Industry 4-67 ABD00023459 Subpart XX - Standards of Performance for Bulk Gasoline Terminals Subparts AAA EEE Reserved Subpart FFF Standards of Performance for Flexible Vinyl and Urethane Coating and Printing Subpart GGG Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries Subpart HHH Standards of Performance for Synthetic Fiber Production Facilities Subpart III Reserved Subpart JJJ Standards of Performance for Petroleum Dry Cleaners Subpart KKK Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants Subpart LLL Standards of Performance for Onshore Natural Gas Processing; S02 Emissions Subparts MMM NNN Reserved Subpart 000 Standards of Performance for Nonmetallic Mineral Processing Plants Subpart PPP Standard of Performance for Wool Fiberglass Insulation Manufacturing Plants 37.DLC.1 4-68 ABD00023460 TO R W SEYMOUR FROM: V E MESSICK DATE APRIL 4, 1988 SUBJECT:PERMITS FOR DEBOTTLENECKING PROJECTS BELOW IS MY UNDERSTANDING OF PERMITTING REQUIREMENTS FOR DEBOTTLENECKING PROJECTS WE NEED TO WORRY ABOUT THREE TYPES OF PERMITS. 1 NESHAP THIS IS TRIGGERED BY THE AMOUNT OF MONEY SPENT IF WE EXCEED 12 5% OF THE BOOK VALUE OF THE ASSETS, A PERMIT IS REQUIRED FORAN EXPANSION THIS WOULD BE ABOUT $1.25MM THIS APPLICATION IS SUBMITTED THE STATE. THEY MAY CONSULT REGION IV, BUT WLM THINKS TIMEFRAME IS TOO SHORT FOR THEM TO SUMBIT TO REGION IV FOR REVIEW. REGION IV HAS TYPICALLY ASKED SOME DETAILED QUESTIONS ABOUT EXPANSIONS IN THE PAST. 2. STATE PERMIT WE ARE PERMITTED FOR 455MM POUNDS PER YEAR. EMISSIONS ON PRODUCTION ABOVE THIS AMOUNT ARE NOT PERMITTED HOWEVER, EARLIER IN THE YEAR, RAF HAD A CONVERSATION WITH BOBBY WHITAKER, OUR REPRESENTATIVE IN THE STATE DNR BOBBY INDICATED GOING TO 465MM POUNDS PER YEAR WOULD NOT BE A PROBLEM SINCE NO CAPITAL PROJECT HAS BEEN INSTALLED. THE STATE DEFINES A NEW FACILITY TO INCLUDE "ANY EXISTING FACILITY MODIFIED OR RECONSTRUCTED... THAT EMITS DUST, FUMES, MIST, SMOKE, OTHER PARTICULATE MATTER, VAPOR, GAS OR ANY COMBINATION THEREOF FROM THE SAME PROCESS OR RELATED OPERATION " A NEW FACILITY REQUIRES A PERMIT THE PERMIT APPLICATION MUST BEAR SIGNITURE AND REGISTRATION NUMBER OF THE PROFESSIONAL ENGINEER(REGISTERED IN THE STATE OF MISSISSIPPI) RESPONSIBLE FOR THE DESIGN OR REVIEW OF THE NEW FACILITY AN APPLICATION FOR A PERMIT TO CONSTRUCT MUST BE SUBMITTED AND APPROVED PRIOR TO THE START OF ACTUAL CONSTRUCION OR INSTALLATION. 3. PSD PERMIT THE MAJOR ISSUES FOR DETERMINING IF A PROJECT NEEDS A PSD PERMIT ARE: A IS THE FACILITY A MAJOR SOURCE? A FACILITY IS A MAJOR SOURCE IF IT EMITS MORE THAT 100 TONS PER YEAR OF ANY ONE POLLUTANT WE HAVE CHECKED TWO THINGS--PARTICULATES AND NOX EMISSIONS RAF AVERAGED 44 ROTARY DRYER DATA POINTS FROM WHEN WE USED TO STACK SAMPLE IN 1978-1980 THESE AVERAGED 7 POUNDS PER HOUR THE VARIABILITY WAS LARGE USING THIS DATA AND EMISSION DATA FROM THE FLUID BED DRYER, RAF CALCULATED PARTICULATE EMISSIONS OF 123 TONS PER YEAR WE WILL HAVE TO ADD SILO AND BOILER PARTICULATES TO GET THE TOTAL OUR ACTUAL EMISSIONS MAY BE LOWER THAN 123 TONS PER YEAR WE SHOULD PROBABLY HIRE A CONTRACTOR TO STACK SAMPLE TO DETERMINE ACTUAL EMISSIONS. WLM STILL SAYS WE HAVE A PROBLEM BECAUSE PAGE 1 4-69 ABD00023461 4 WE CAN LEGALLY EXCEED THE 100 TON PER YEAR NUMBER HE THINKS WE WOULD HAVE TO BE LEGALLY BOUND TO LESS THAN 100 TONS PER YEAR OUR PARTICULATE PERMIT LIMIT IS ABOUT 770 TONS PER YEAR. NOX EMISSIONS ARE ABOUT 45 TONS PER YEAR WITH PERMITTED EMISSIONS ABOUT 85 TONS PER YEAR JCL AND WLM SAY THAT OKLAHOMA CITY IS NOT A MAJOR SOURCE, SO THEY DO NOT NEED A PSD PERMIT THEY SAY THAT OKLAHOMA CITY IS GETTING A NESHAP AND A STATE PERMIT FOR THEIR CONDENSER PROJECT B THE NEXT ISSUE IS THAT OF A MAJOR MODIFICATION THIS IS DEFINED AS "ANY PHYSICAL CHANGE IN OR CHANGE IS METHOD OF OPERATION OF A MAJOR STATIONARY SOURCE THAT WOULD RESULT IN SIGNIFICANT NET EMISSIONS OF ANY POLLUTANT SUBJECT TO REGULATION UNDER THE ACT " THE REGUALTIONS ALSO STATE THAT "A PHYSICAL CHANGE OR CHANGE IN METHOD OF OPERATION SHALL NOT INCLUDE (A) ROUTINE MAINTENANCE, REPAIR AND REPLACEMENT. " C SIGNIFICANT FOR VINYL CHLORIDE MEANS EMISSIONS THAT EXCEED ONE TON PER YEAR OUR SLURRY EMISSIONS IN 1987 AVERAGED 208 PPM. THIS MEANS THAT MODIFIDATIONS THAT EXCEED ABOUT 9 6MM POUNDS PER YEAR ADDITIONAL PRODUCTION REQUIRE A PSD PERMIT D IF OFFSETS ARE USED TO REDUCE EMISSIONS, A PSD PERMIT IS NOT REQUIRED HOWEVER, THIS EFFECTIVELY LOWERS THE LEGAL LIMITS FOR EMISSIONS E ATTACHED IS A QUOTE THAT RAF RECIEVED ON PREPARATION OF THE PERMIT BY A CONTRACTOR AN ISSUE UNDER THE BACT ANALYSIS WILL BE THAT OF CONTINUOUS STRIPPING. VELDON E MESSICK C RAF. WLM, JCL. FGJ, JEN, EJM PAGE 2 4-70 ABD00023462 % Scott Environmental Technology Inc PLUMSTEADVILLE, PA 189*9 PHONE (215) 766-8861 TWX 510-665-9344 March 29. 1988 SET Proposal No. 0113-03-2888-79 Mr. Dick Frohreich Environmental Manager Vista Polymers Highway 25 Aberdeen. MS 39730 Dear Mr. Frohreich: Presented herein is a summary of the services offered as assistance to Vista Polymers in the development of a Prevention of Significant Deteriora tion (PSD) permit for a planned plant expansion. Services are summarized by the major PSD permit areas and an estimated ceiling cost is presented for each area. BACT Analysis Scott will conduct an evaluation to determine what the Best Available Control Technology (BACT) will be for reduction of emissions from the subject facility. This will involve evaluation of several control options including analysis of costs, environmental residuals, and energy Impacts of each option. A very important consideration will be coordination with the design engineers who are designing the plant expansion. In a report which will become part of the PSD permit application, Scott will summarize all of the options which were studied and present the rationale for selection of one option as BACT for this application. Cost - Not To Exceed $12,000 Air Quality Analysis Scott will search and evaluate all available ambient vinyl chloride and PM-I0 monitoring data in order to establish baseline pollutant concen trations in the area of the source. Five years, of meteorological moni toring data will also be obtained. Additional to this, Scott will obtain land use and population Information for an area within 3000 meters of the source. In order to address the requirement of an emission inventory within the region of the source, Scott will obtain Mississippi Emission Data System (MEDS) information for the area. All sources in the area will be reviewed and summarized in a report along with the air quality and meteorological data. Cost - Not To Exceed $8,000 4-71 TROY MICHIGAN / SAN BERNARDINO CALIFORNIA / HOUSTON TEXAS / WHEELING ILLINOIS SOUTH PLAINFIELD, NEW JERSEY / FREMONT CALIFORNIA / WAKEFIELD MASSACHUSETTS I LONGMONT COLORADO Mr. Dick Frohreich Vista Polymers ABD00023463 Marcn 29, 1988 0110-03-2888-79 Air Quality Modeling Scott will conduct dispersion modeling of predicted source vinyl chloride and PH-10 emissions by the ISCST model in order to determine the impact of the source on the ambient air quality of the area. The results of the modeling will be compared to the available increment for each pollu tant. The results will also be added to the background concentrations to evaluate potential violation of primary and secondary ambient air quality standards. Modeling will be conducted by two procedures. The first proce dure will include a screening analysis using the EPA worst case meteorolog ical conditions. Modeling will also be conducted using the five years of meteorological data obtained during the Air Quality Analysis. All modeling will be conducted in strict accordance with EPA modeling guidelines. Cost - Not To Exceed $6,000 Secondary Impact Assessment Scott will perform an analysis of the impact of the proposed source on the visibility, soils, and vegetation of the area. There are no firm EPA guidelines on this section of the permit application therefore the analysis will be conducted and presented according to the general guide lines of an environmental impact statement. Cost - Not To Exceed $4,000 This completes the summary of the services offered by Scott for this project. We appreciate this opportunity to be of service to Vista Polymers and we pledge our very best efforts toward the successful completion of the PSD permit application. If you have any questions or need any further information, please do not hesitate to contact me or Mr. Arthur Nunn. RPN:tae Robert P. Newman, P.E. ^ Marketing Manager Environmental Services Group 4-72 ABD00023464 B ABD00023465 V MANIFESTS Storage, shipment and disposal of hazardous wastes are regulated under RCRA Shipment and delivery of hazardous wastes can only be made by authorized transporters and management facilities using the manifest procedures The following is a list of wastes that we ship using the manifest system WASTE STATE MANIFEST USED Waste Oil API Separator Louisiana Parts Cleaner Solvent Mississippi Lead Contaminated Bags Alabama Plasticizer Filter Cake Alabama Floor Sweeps* Alabama API Sludge P A Spill* Asbestos Alabama Alabama Alabama Stabilizer Spill* Alabama WHO SUPPLIES THE MANIFEST Vista/LA State form Safety Kleen/MS State form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form The following is a copy of each of the types of manifest used m the above list * Temporarily shipped to Louisiana due to Alabama ban on hazardous materials Additional form, LA state form 5-1 ABD00023466 ''TATE OF LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY HAZARDOUS WASTE DIVISION P O BOX 44307 BATON ROUGE LOUISIANA 70804 % Pleaee onnt or type (Form designed for um on ante (12-ortchl typewriter I corm Approved 0M6 No 2050-0039 Expiree 9-; 5-2 6-094-01 ABD00023467 Tee'e 0< nt or tvoe :rm aesianeo ror use on e>ite i 12 cucni typewritert Porm Aooruvea OMBNo 2050-J039 Expire* 9-30-81 A UNIFORM HAZARDOUS i Generator s US EPA ID No A/ASTE MANIFEST HSD007031Z30 Manifest Document No ij | 61365 | Page i i rtormauor u< the shitfed areas of * ! s not renuiraa ov Fedecakin* venerator s Name ana Mailing Address A State Manrtest-Document Numtwmor _____ om m o.. o c c c p r n n F OF FFOFRAt REGULATIONS 40 PART 262 20 15 So6cia* Handling instruction* and Additional Information 8^2Q 0609l836 IF UNDELIVERABLEi RETURN TO GENERATOR* FOR RECYCLE 36l365 *-<>94-01-6134 02 16 GENERATOR'S CERTIFICATION l hsreoy o*ctar* tnai tn# contents or this conaignmem trs fully and *ocuratety dwmcM aoov* ov proper shipping name and are gamueo pacxea marxaa ana laoeieo ana ar* in ail r*tp*ct* in proper conation tor tranaoon Dy hignway ecognang to applicant* intemaoonat and national govemmam rtgteapons. if i am a targa Quantity generator I certify tfial I hav* a program m piao* to reduce the volume ana ttnoaty of waat* g*n*rat*d to the degree I hav* 3Bt*rmn*a to m economically practiced* ana tftct l nave selected tn* pracocaue matnoa of treatment atorag# or Oiapoew currantfy aveuap** to me which minimize* tn* praeent and future tnreet to human neertft ana the environment OR. if I am e amail Quantity generator l have mao* a gooo faith effort to minimize my waste generation ano aeieo the Peel waste management method that la avatiabM to me and that l can attoru. p-- Oat* en'Typeo Nam* . aAmes /A. EbuiAei^ Je.- c5n 17 Transporter i Acknowledgement of Receipt of Material* Printeo/Typed Name t Signature V&m Month Day Year Oata Month-Day Year jr<n ;2 18 Transoortef2 Acknowledgement of Redeipj^rf Matenaia Printed/Typed Name Oats Month Day Year '9 Discreoancy indication Space J U-1 -- x-pt'r- 4 'f'> V f j ?- ?c 2CL. Facility Owner or Operator Certfffcatlon of receipt of hazardous materials covered by this manifest except as noted in item 19 -nmpa/Typed Name r.nerri tL (.0 u n r\tU 5> T - iicl <L1 >j UJ tn -A Form 6700-22 iRev 9 88) previoua editions oosotete 23 :R!GINAL - ^GT'JRN TO GEN,EATOR 5-3 - Mopfh Day Year |L PT SAFETY KLEcN CCRP 90280 6 ABD00023468 HAZARDOUS WASTE MANIFEST iAs Required By The Alabama Department of Environmental Management) Mmh orint or type /Form designed tor tree enefitefl2-prtch) typewriter ) UNIFORM HAZARDOUS WASTE MANIFEST 1 Generator a US EPA ID No : A'* Msrvfest mss i<>,G7n si, abq ia?WfT/ J aeneratora Name sod Mailipg. Address -T-vok- A-. i j "1 'Vi=>*k*-cr<rT?v^. 4 Generator a Phone I _ _ t ) xX, " - "'ll fnapory^^Company Nyne o US EPA ID NumMr Fonn tcomeo. OMB Nrv 20SMM Earn *-- Intormauory irv areas it not mtwii toy Fad*si law / uanaeoner 2 Company Name ' _ 9 Designated Facility Name and Site Address CHEMICAL WASTE MANAGEMENT INC 5 metis Facility Alabama Hr^twev 1 7 at Mile Marker 163 1*111 Ol i is i7|.?|S1bl3g1^J US EPA ID NumMr It uT US EPA ID Nuimxr US11 DOT Description UndudmgProperSAwpeig Neme. Haiwd C/a*a. and ID Humbert |12. Comatnar* | 1 {No Type 13. Total Quantity I1M4*MS WWo a f'/asT' C.zejr" Mors -- f+aTL^O^dtoCA i, b ii+o.'z-ci.f~dLQ^ ujuus^-e CapIfi. , CWM Profile Number/Mj |Q|3J? ifejM if iSTfifi. |C3 Sbi <d ,vi,oS ORm --& 1 C ^^^CvVMP^/^mtjeryif c a.IeOL M fb^r-r- Atovv --W.Z^gPioiXS MS IfCWM Profile Number /73&<" d r", *r -. r o i :^9iS- SC i j-^2 DM 1 i Ai5ib |Q '\ CWM Profile Number Ml 1 1 M 1 ... S Special Handling instructions and AddmonaiirtotTnetion- -fKe I c_o<vWMc^f- V * v GENERATORS CERTIFICATION I r<efaov aeciare mat ine contents oi tnis consignment are luiiy and accurately oescnoea aDove ov proper snioomg name and are classified packed marked and labeled and are m all respects m prooer condition lor transport bv nighwev jccoramg to aoo`icabie international and national government regulation* * i am a large quantity generator l cenrfy that I have a orogram m olace to reduce the volume end toxicity ol wane generated to (he degree economically practicable anO that I have selected the practicable method ol treatment storage or disposal currently available to me which m 'uturetnreat to human health and the environment OR if I am a small Quantity generator i have made a good teith ailort to minimize my waste -e t>eSt waste management memod that is available to me and mat l can allord Printed/Typed Name Signature mb* mwim end _ Me--to Otf Veer vt_ u *o ^27) si. * -V ^ -L. 17 Trsnsoorter 1 Acknowledgement of Recnpt of Meiensls -wrcmt c.H-rt-e*. 18 Tferwooner E Acknowledgement of Receipt of Materials \vZU^ Chit* ~~ Memh Dey - Yew iQ<i2Hi>i9 Pnmed/Typed Name Signature If--I Oer- Yew 19 Discreoancy indicstion Space ^ i- 4'J m^ i> w // ! r~ 7 '" till A '0 Facility Owner or Operator Pnntea/Typed Name Certification of receipt of hazardous matensta covered by this manifest except as noted in Item *19 ^ ' /A / Signature/f M. Dey Yew - 1*# aSx (V 5-4 ABD00023469 L SHIPPING PAPERS INTRODUCTION Biggest Source ofViolation Activity and Shipment Delay It has been this authors personal experience that thevast majority ofviolation activityand shipment delay is caused by Shipping Papers not prepared in accordance with 49 CFR (or other applicable regulations). Any Inspector, State Trooper, Enforcement Person, or Carrier Accep tance Person, worth their salt will start their inspection with the Shipping Paper. Obviously ifeveryone looks at it and it is not correct problems will result We at GSI recommend as strongly as we can that emphasis be placed on insuring that theShipping Papers are correct This will help Emergency Response Personnel respond effectively to accidents or incidents involving the shipment elimi nate potential enforcement activity, and limit potential customer problems that result when a shipment is de layed. Use By Emergency Response Personnel Once thestupment leaves the Shipper's facilityand enters the transportation system it is subject to those "condi tions normallyincident to transportation"aswell as those that are not "normally incident" to transportation such as vehicleaccidents, punctureddrums, etc, In theevent ofan accident or tnctdent involving the shipment Emergency "U.S. DOT vs "Normal" Shipping Paper" The term "Shipping Paper" as normally used within the transportation system means the piece of paper or docu mentation used for piece count, billing, accountability and other purposes involvedwith the day to daytranspor tation of Hazardous as well as non hazardous materials. As used m 49 CFR the terra "Shipping Paper" means documentation containing the specific Hazardous Mate rials information required by 49 CFR. Except for shipments of Hazardous Wastes (172315) 49 CFR does not require the use of any specific form. The system is flexible enough to permit the use of ANY form so long as the required 49 CFR information is on theform (171.8). As a practical matter by Highway it is very com mon to see the normal "Straight Bill of Lading" used for shipments of both hazardous and non hazardous goods. On the other hand, although not required by 49 CFR, the air industry requires the use of a particular Document called the SHIPPER'S DECLARATION FOR DAN GEROUS GOODS. GSI CR: Hazardous Waste Manifest, BS GSI CR: SHIPPER'S DECLARATION, C33 Response Personnel will have to \ make IMMEDIATEdecisions as to how to handle il The Shipping Paper provides VITAL INFORMATION needed to make these decisions such as but not limited to the Proper Shipping Name, Hazard Class, the Identification (ID) Numberand the amount of material involved. Definition of "DOT 49 CFR" Shipping Paper To be in compliancewith 49 CFR whatever"form" is used as the Shipping Paper MUST contain the information REQUIRED by: 172402 containing the Basic Description requirements consisting of: 1. Proper Shipping Name (172402(a)(1)). The ID (UN/NA) Number from Column #3A of the HMT-172.101 is a required entry on the Shipping Paper. It is keyed to the "Emergency Response Guidebook". This Guidebook gives Emergency Response personnel information relative to the Hazards associated with the material, recommended responses, and other actions such as evacuation etc Obviously if the ID Number is not on the Shipping Paper or otherwise visible Emergency Re sponders will not have the benefit of this quick cross reference. Lives could hang in the balance. 2. Hazard Class (172402(a)(2)). 3. ID (UN/NA) Number (172.202(a)(3)). 4.1-3 above in sequence (172402(b)). 5. Quantity of Material (172402(a)(4)). 172403 containing Additional Description requirements which MAY apply to a particular Basic Description. 172404 containing the Certification and Signature re quirements. A39 (0888) 5-5 ABD00023470 i General Applicability Multiple Pag? Shipping Papers As a general rule if a Hazardous Material is offered for transportation the person offering it MUST describe the material on a Shipping Paper in the manner required bv 49 CFR (172.200(a)). A Shipping Paper may consist of more than one page PROVIDED each page is numbered consecutively AND the First Page bears a notation specifying the total num ber of pages included in the Shipping Paper as follows: Exceptions Page l of 3 "Normal" (Commercial) Shipping Papers are generally required to transport most materials. Hazardous as well as non hazardous. Except for Hazardous WastesandSubstances, "DOT Shipping Papers" ARE NOT normally required for shipments of materials: 1. Identified by the letter *A" or "W* in Column #1 of the HMT-172.101 except when offered or in tended for transportation by the mode indicated, "A* for Air and/or "W* for Water. 2. That are ORM D's except when offered or mtneded for transportation by air. (172.200(b)) GSI CR: "A" "W","AW\ A15 Hazardous Materials and NON Hazardous Materials On The Same Shipping Paper When a Hazardous Material is shown on the same shioDingpapertwitha non hazardous material thedesmption ot the HAZARDOUS MATERIAL must: 1. Be shown first (17Z201(a)(l)(i)). OR 2. Entered in an ink of a contrasting color. (I72.201(a)(l)(ii)). In this case the description can be located anywhere on the shipping paper and/or intermixed with the non hazardous 4a OT Uim* HM & TVpe Straight Bill DESCRIPTION AND CLASSIFICATION (Proper Shipping Name. Hazard Class. UN/NA Number) 1 flat Grandmas Kites 9 Drums X Acetone, Flammable liquid, UNI 090 IDnsms X Flammable liquld.n.o.a. (Acetone.Xylene) Flammable liquid, UNI 993 ToolOuaatjy (Wt/Vol) ioo lbs 4320 lbs 960 lbs FIGURE SP-1 General Shipping Paper Description Requirements All required shipping descriptions must: 1 Be pnnted (manually or mechanically), in english. and legible (172301(a)(2)). 2. Contain no codes or abbreviations except as au thorized or required (172.201(a)(3)). i.e. Abbre viations for the quantity (net or Gross) of the Hazardous Material being described (172302(c)(1)); RQ for "Reportable Quantity" (172.203(c)(2)); Ltd Qty for "Limited Quantity" (172.203(b)). ma,en.l enmes. OR 3. Be identified by the entry of an "X" placed BE FORE the Proper Shipping Name in a Column captioned "HM" (172.201(a)( l)(iii. If this op tion is used the Hazardous Materials may be placed anywhere on the Shipping Paper as illus trated in Figure SP-1. "Grandma's Kites", the firstentryon theShippmg Paper,is not a Hazard ous Material; is listed firston the Shipping Paper, and the Hazardous Materials are not entered in an ink of a contrasting color so the "X" must be placed in the "HM Column for each of the Haz ardous Material entries. A40 (0888) 5-6 ABD00023471 t GSI COMPLIANCE PRACTTCE- Use the "HM" Col umn Option. Put an "X" in the "HM Column" as a stan dard practice when entering Hazardous Materials on the Shipping Paper EVEN IF the Shipping Paper onlv has Hazardous Materials on il This avoids having to select an Option and the decision as to whetheror not the selection of one of the Options is necessary for a particular ship ment. Technical Name Exception 49 CFR currently (Q&87) penmts the "technical" or chemical group names of a material to be entered (in parentheses) between the Proper Shipping Name and Hazard Class (172.202(d)). The Flammable liquid, n.o.s. (Acetone, Xy lene) entry in Figure SP-1 illustrates this entry for a Flammable liquid mixture containing "Acetone" and "Xylene". THE ABCs OF THE BASIC DESCRIPTION (172.202) To insure compliance with 49 CFR all Shipping Papers, including Hazardous Waste Manifests, must contain a Basic Description containing the following information m sequence: A. Proper Shipping Name The FIRST Item in the sequence is the Proper Shipping Name listed in Column #2 of the Hazardous Material Table 172.101 for the Hazardous Material (172.202(a)(1)). The entries Acetone and Flammable liquid, n.o.s. in Fig ure SP-1 show this entry. GSI CR: Proper Shipping Name, A3; Marking, Proper Shipping Name, A27 GSI RECOMMENDATION- Include the "Technical" or chemical names in parenthesis for most Proper Ship ping Names ending with the letters "n.o.s." as required bv applicable UN regulations (ICAO by air and the IMDG Code for water). As a practical matter most Proper Shipping Names end ing with the letters "n.o.s." being offered for transporta tion by air or water under the appropriate International Regulations will require the addition of one or more chemical names in parenthesis immediately after the the letters n.os. ui the listed Proper Shipping Name. Pending rule changes to 49 CFR (HM-126C and HM181) will require basically the same type of entry for domestic shipments within the next few years. GSI CR: Air, C. N.O.S. Name Rule C13 B. Hazard Class The SECOND Item in the sequence should be the HAZARDCLASS listed in Column #3 ofthe Hazardous Material Table.101 for the Hazardous Material (172.202(a)(2)). The entries Flammable liquid after the Proper Shipping Names in Figure SP-1 illustrate the Hazard Class entry. GSI COMPLIANCE PRACTICE- Although there are some exceptions to this requirement we at GSI recom mend that the HAZARD CLASS be used at ail times. GSI CR: Classification, A10; Placarding, A51 C. Identification (UN/NA) Number The THIRD Item in the sequence is the Identification Number including the "UN"'or "NA" prefix listed in Column #3(A) of the Hazardous Material Table 172.101 for the entry (172.202(a)(3)). This is illustrated by the entries UNI090 and UNI993 m Figure SP-1 GSI CR: CoL #3A A14, UN/NA No Marking A27 E. Quantity of Material Except for empty packagmgs, compressed gas cylinders, and packagmgs having acapacityof more than 110 gallons such as Cargo Tanks the "Total Quantity'* of the material covered by the Basic Description, including the units of measurement, must be entered on the Shipping Paper (172.202(a)(4)). The TOTAL QUANTITY entry may: 1. Be given weight OR volume or as otherwise appropriate. 2. Appear either before OR after OR both before and after the Proper Shipping Name, Hazard Class and Identification Number information on the Shipping Paper and may be abbreviated (172.202(c)). 3. Be either the "net amount" of the material in the package or the "Gross Weight", the weight of the material in the package plus the packaging, as appropriate. Generally the "net" figure is used for air or Hazardous Waste shipments and the "Gross Weight" for Highway Shipments. D Required Sequence of Basic Description The ProperShipping Name, Hazard Class,and Identifica tion Number MUST BE IN SEQUENCE with nothing between them. All the entries m Figure SP-1 are tn this this sequence (172.202(b)) The entries in the `TOTAL QUANTITY" Column of Figures SP-1 through SP4 illustrate these entries. GSI Compliance Procedure- Always include the Quantity ofthe Matenaleven ifan Exception applies. As a practical A41 (08881 5-7 ABD00023472 matter the "Gross Weight" is going to be included for most, non Cargo Tank, highwayshipments and will be the Figure most often used. GSI CR. Air- P. C3S elsewhere the Additional Description information should be entered AFTER the Basic Description information on the Shipping Paper as shown by the Ltd Qty and RQ entries m Figure SP-2 Prohibited Entries Additional Description Entries A material not meeting the definition of a Hazardous Material may not be described on a Shipping Paper using either a DOT Hazard flaw or a UN/NA Number (l7?-2Q2(e)). A packageof "Paint" havinga Flash Point of 25CPF may not be described on a Shipping Paper by any of the following descriptions: Paint, Flammable liquid, UN1263 Paint, Flammable liquid Paint, UN1263 It should be described simply as Paint A. DOT Exemptions If the Basic Description describes a Hazardous Material being shipped under a DOT Exemption the notation "DOT-E" followed by the "Exemption Number" as signed must be entered in association with the Basic Description (172.203(a)). A shipment being shipped under "DOT Exemption # 1234" must have the entry DOT-E 1234 entered on the Shipping Paper after the Basic Description as shown for the AJdrin entry m Figure SP-2. GSI CR. Air-Auih.Column, W C41 THE A EC's OF ADDITIONAL DESCRIPTION REQUIRE MENTS (172.203) In any case where a Shipping Paper is required it will, at a minimum, contain a Basic Description. In addition, one OR more of the Additional Description requirements contained in Section 172.203 MAY or MAYNOTapply to a given Basic Description. Each paragraph m 172.203 rep resents a potential Additional Description Item that could be required. If one or more of the Additional Description Items specified m 172203 applies to the the Hazardous Material described in the Basic Description the appropri ate entries must be made. If none apply to the particular Basic Description hen no Additional Description informa tion has to be entered. GSI COMPLIANCE PROCEDURE- As a general rule EXCEPT where specifically required to be placed H. Limited Quantity Ifa material is offered for shipment as a "limited quan tity" the words Limited Quantity or Ltd Qty must be entered on the Shipping Paper after the Basic Descrip tion (172.203(b)). TTiis entry is illustrated by the entry Ltd Qty after the Butane entry in Figure SP-2. GSI CR: Limited Quantities, A19 C. Hazardous Substances At a minimum the Letters RQ must be entered on the Shipping Paper either before or after the BasicDescrip tion IF the material covered by the Basic Description is regulated as a Hazardous Substance as shown m the AJdrin entry in Figure SP-2 (172.203(c)(2)). In addition, except for Hazardous Wastes. IF the name(s) of the consmuent(s) causing it to be regulated as a Hazardous Substance, as listed in the Appendix to 172101, Straight Bill N&Of Uim IIM DESCRIPTION AND classification <& Type (Proper Shipping Name. Hazard Claaa. UN/NA Number) 2 Bn X Aldrin, Poison B, NA2761, DOT-E1234, RQ 25 bn X 1 fix X ; Bx X Butane, Flammable gas, UNI 075, Ltd Qty Hazardous substance, liquid, n.o.s., ORM-E NA9188 (n-Butyl phthalate) RQ Magnesium metal, Flammable Solid, UNI 869 Dangerous When Wet FIGURE SP-2 A42 5-8 Tout Otaotay (Wl/Von 30 lbs 250 lbs 150 lbs 60 lbs ABD00023473 is not part ofthe Proper Shipping Name it must be entered in parenthesis in association with the Basic Description as illustrated m the Hazardous substance liquid, n.o.s. entry m Figure SP-2 (172.203(c)(1)). it is part of the Basic Description or has been added m accordance with 172.2Q3(k)(2). GSI CR: Air, USG-34, C43 GSICR. Haz. Substances, Bl, Air, USG-01, C42, Hazardous Wastes, A44 D. Dangerous When Wet If the package is required to be labeled with a'DANGEROUS WHEN WET" label the entry Danger ous When Wet MUST be entered on the Shipping Paper m association with the Basic Description (172.2Q3(j)). This entry is shown m the Magnesium metal entry m Figure Sp-2. GSI CR. Labeling, A35, Air, USG-12, C42 E. Poisons-lnhaintion Hazard Name- If the Proper Shipping Name does not contain the the name of the compound or primary constituent causing it to meet the definition of a a "Poison", as defined in 49 CFR, 'he name of the compound or principal constituent causing it to meet the definition of a "Poison" must also be listed m association with (after) the Basic Description for the matenaL The name used may be either the technical name of the material or any name for the material that is listed in the NIOSH Registry (National Institute for Occupational Safety and Health) (172.2Q3(k)(l)). Poison- IF the material meets the definition of a Poison under 49 CFR and the fact that it is a `"poison" is not disclosed by either the Proper Shipping Name, or the Hazard Class the word "Poison" must be entered on the SHIPPING PAPER in association with the Basic Descrip tion as shown in the Waste Ally! alcohol entry in Figure SP-3 (172^03(k)(2)). GSI CR: Air, USG-I1, C43 F. Hazardous Wastes Shipments of Hazardous Wastes must be described on a specific form, the Uniform Hazardous Waste Manifest (EPA 8700-22), prepared m accordance with 40 CFR 262^20 (17205(a)). The instructions for preparing this formfor Blocks otherthan 11. aresufficientlyexplainedin the Appendix to 40 CFR Pan 262 and will not be ex plained in this text. Except as noted below, the descnption of a Hazardous UNIFORM HAZARDOUS WASTE MANIFEST LGMnun US EPA ID No. MihTm Dnnwwm No. 1 ?* 1 or UCOMM1 No. tvt* UTote OuMHf 14U(M Wl/Vol WwMx a. Waste Allyl alcohol. Flammable liquid, UN109S, RQ Poison- Inhalation Hazard b. Hazardous waste solid, iloa, ORM-E, NA9189 RQ (EPA EP toxicity) 10 DM 1500 ZMttMMjgjjg P 10 DM 4400 P FIGURE SP-3 Poison-Inhalation Hazard- If the Basic Description covers a material meeting the inhalation toxicity cntena of 173.3a(b)(2) packaged in primary containment units of more than one (1) liter capacity the words "Poison-Inhalation Hazard" must be entered in association with the Basic Description (172.203(k)(4)) The Waste Allyl al cohol entry in Figure SP-3 illustrates (his point. The word "Poison" in this entiy is not required if Waste on the Manifest is the same as for any other Hazardous Material: 1. The word Waste must be added preceding the Proper Shipping Name if it Is not pan of the Proper Shipping Name appearing in Column #2 of the HMT-172.101 as illustrated by the Waste Allyl Alcohol entry tn Figure SP-3 If the word Waste is part of ihe Proper Shipping Name appearing m Column #2 of the HMT172.101 leave where n is as illustrated by the A43 {tvwsi 5-9 ABD00023474 Hazardous waste solid, n.o.s. entrv in Figure SP-3 (I72.101(c)(10)). Except for the requirement that the Quantity of Material covered by the Description be m Items 13 and 14 and that the Unit of Measurement be entered in Item 14 be as specified in the Appen dix to Part 262 of40 CFR all the Basic and Addi tional Description Items required by49 CFR will beentered in Block 11 ofthe Uniform Hazardous Waste Manifest as illustrated in Figures SP-3 and SP-4 below. Container Number and TVpe: Item 12 requires an entry forthe "Number" (No.) and "Type" of containers being used to transport the Haz ardous Waste. The entry for the "Type" of containermust beas specified in the Instruc- For Characteristic Waste the words: EPA igmtability; EPA corrosivity; EPA reactivity; EPA EP toxicity, as appropriate or The appropriate D Number. The letters RQ must also be added to the Basic Description of a Hazardous Waste that is regulated as a Hazardous Substance m the same manner as required for any other Hazardous Substance (172.203(0)^2)). GSICR: Hazardous Substances, C.A42 UNIFORM HAZARDOUS WASTE MANIFEST LCwwwUS EPA ID No. Mwfet OnrM--M No. 1 PaW 1 ot n iicfvww-------f-- --|fr-fTT`itmrr--|^rm imHtThr} ii amn No. TVj* Ouaoucf U. UlM i W(/Vd WmmN* a. Waste Flammable liquid, iuu. Flammable liquid, UN1993 (AfMooc/Xyieo*) or (F003) RQ I TT 4000 G FIGURE SP-4 ttons for Item 12 in the Appendix to Part262 of 40 CFR. These entnes are illustrated in Figures SP-3 and SP-4. 3 Ifthe Hazardous Waste is alsoregulated as a Hazardous Substance and the Proper Shipping Name does not con tain the name of the Hazardous Substance as listed m the Appendixto 172.101 one ofthe following must be entered in (parenthesis) as an Additional Description Item in Item 11 of the Uniform Hazardous Waste Manifest as illustrated in Figures SP-3 and SP-4 (172.202(c)(1)): The Name of the Hazardous Substance as listed in the Appendix to 172.101 or The Waste Stream Number if a Waste Stream is involved or A44 (0nw 5-10 Pages A45-A43 Reserved. ABD00023475 CERTIFICATION addition to the manual signature of that person. The Certification must be on the Shipping Paper con taining the Basic Description The person who signs the Certification is saying on, BEHALF OF THE COM PANY, that everything has been properly descnbed, packaged, marked, labeled etc. GSICR. Air-Cert, AA -CC , Page C41 No Certification Required Certification for Highway & Rail Transportation If highway and/or rail is the mode of transportation the Certification in i72.204(aXl) should be used. This Certification is commonly prepnnted on Bills of Lading used for Highwayand Rail transportation ofHazardous Matenals. Certification for Water Shipments If water is involved in the transportation ofthe Hazard ous Material the Certification in i72.204(aX2) should be used because it is also m compliance with the provisions of IMO (Section 9, paragraph 9 4 of the General introduction). Use ofthis Certification will also cover the highway portion of the transportation by inserting the words ' 'highway and water" where the appears in the body of the Certification (172.204(aX2)). Except for Hazardous Wastes no Certification is re quired for Hazardous Materials offered for transporta tion by motor vehicle AND transported in a cargo tank supplied by the earner OR by the shipper as a private earner unless the Hazardous Material is to be reshipped or transferred to another earner (172.204(bXI)) Nocertification is required forthe shipmentofan empty tank car by rail (172.204(b)(2)). Certification bv Air If air is involved in the transportation of the Hazardous Matenal the Certification in 172.204(cX1) AND 172.204(C)(3), with the appropnate entrydeleted should be used. As a practical matter this information is prepnnted on a red bordered (hatched) form known as the ' 'SHIPPER'S DECLARATION" which is used by most air earners in the world. This Certification also coversthe highway portion of thetransportation to and from the airport. GSI CR* Air- Transport Details Box, C36; Certifica tion, C41 SIGNATURE The required Certification mustbe LEGIBLY signed by a pnnctpal, officer, partner, or employeeof theshipper or their agent (172.204(d)(1)). Except for Hazardous Waste Manifests and Air Shipments the signaturemay be manual, by type writer,or by other mechanical means (172.204(d)(2)). Hazardous Waste Manifests and Air Shipments Hazardous Waste Manifests will have the name of the person signing the certification typed or pnnted along with a manual signature in Item 16 of the Uniform Hazardous Waste Manifest. For Air Shipments the SHIPPER'S DECLARATION FOR DANGEROUS GOODS will have the name and position of the person signing it printed or typed in the Signature Box in A49 (08/871 5-11 ABD00023476 ENVIRONMENTAL OFFICE MAP ABD00023477 6-1 ABD00023478 ABD00023479 VII REPORTING AND SPILL CHECKLISTS The following table lists all environmental reports due during the year and the due date DATE REPORT DUE Jan 28 and the 28th day of every month NPDES, Discharge Monitoring Report form (EPA No 3320-1) to MDNR for preceding months water discharge data March NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall March 1 (even no yrs) RCRA Hazardous Waste Shipments Activities Report March 1 SARA 312, Emergency and Hazardous Chemical Inventory forms to State ERC, Local EPC, and Local Fire Department March 15 NESHAP, RVCM report for December, January, and February March 31 NESHAP 1st quarter Bleeder Valve Survey June NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall June 15 NESHAP, RVCM report for March, April, and May June 30 NESHAP 2nd quarter Bleeder Valve Survey June 30 NPDES, Bioassy of outfall using cenodaphnia June 30 SPCC Plan Survey July 1 SARA 313, Toxic Chemical Release Reporting to EPA and State Officials July 1 TSCA, Annual report for PCBs in service or projected for disposal for previous calendar year September NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall September 15 NESHAP, RVCM report for June, July, and August September 30 NESHAP 3rd quarter Bleeder Valve Survey October 31 SARA 311, updated MSDS sheets to State ERC, Local EPC and Fire Department December .4 NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall December 15 NESHAP, RVCM report for September, October, November December 31 NESHAP, 200 VCM Service Valve Survey and Bleeder Valve Survey 4th quarter December 31 NESHAP Annual VCM Flange and Valve Survey December 31 NPDES, Bioassay of outfall using pimephales promelas December 31 SPCC Plan Survey 7-1 ABD00023480 To Distribution itarofftce ommunicotion From Dot Sub)ct F. G. Jeanson January 4, 1989 RELEASE AND SPILL REPORTING One of the requirements of the Emergency Planning and Community Right-to-Know Act of 1986, commonly referred to as SARA, is the reporting of releases of certain substances to the environment (Section 304). The report is to be made to the emergency coordinator of the local emergency planning committee and to the Mississippi Emergency Response Commission. This reporting requirement is in addition to the Superfund or CERCLA section 302(a) reporting to the National Response Center which we have been doing for some time. Naturally, the substances and conditions requiring notification are not the same for each of the reports. Table I lists the substances used in the plant that require SARA release reporting. Table II lists the substances used in the plant that require CERCLA section 302(a) release reporting. The tables also show the reportable quantity for each of the substances. The regulations concerning when reporting is required are complex; therefore, the Environmental Coordinator should be contacted Immediately in case of a spill or release to help determine if it requires reporting. In general, a spill or release of any substances in excess of the reportable quantity except for federally permitted discharges (most vinyl chloride emissions are federally permitted) must be reported. Any non-permitted release of a gaseous material in excess of the reportable quantity will require reporting for both SARA and CERCLA 302(a). If greater than the reportable quantity of a liquid or solid is spilled on concrete and totally contained before it reaches any soil, the spill does not need to be reported by either SARA or CERCLA 302(a). If greater than a reportable quantity of a liquid or solid is spilled on the ground but the spill does not leave the plant boundary. It needs to be reported to CERCLA 302(a) only. If greater than the reportable quantity leaves the plant boundary, the spill will also need to be reported under SARA. Attached is a form listing the questions usually asked when a release is reported to the National Response Center [CERCLA 302(a) list]. This form should be filled out by the operating personnel in the area where the release occurs prior to the phone call. Also attached is the Mississippi Emergency Management Agency Hazardous Material Pelease Report form. When notifying the emergency coordinator of the local emergency planning committee and the Mississippi Emergency Response Commission of a SARA release, the information in boxes 1 through 9 must be provided. 7-2 ABD00023481 -fc % Distribution 1/04/89 Release and Spill Reporting Page 2 In addition to the verbal report of a SARA release, a written followup emergency notice is also required setting forth and updating the information required to be reported in the verbal report and to Include additional information with respect to: 1. Actions taken to respond to and contain the release. 2. Any known or anticipated acute or chronic health risks associated with the release, and 3. Where appropriate, advice regarding medical attention necessary for exposed individuals. This written report is to be sent to the emergency coordinator of the local emergency planning committee and to W. E. Austin, Special Projects Officer, SARA Title III, Mississippi Emergency Response Commission, F. 0. Box 4501, Fondron Station, Jackson, MS 39216-0501. The written report is to be submitted as soon as practicable after the release. The written report should be submitted within ten days as a maximum. F. G. Jeanson Environmental Coordinator rah attachment 7-3 ABD00023482 S. Report to: TABLE I SARA REPORTING MATERIALS 1. Jerome Huskey Emergency Coordinator, Local Planning Committee Work Phone: 601-369-6439 Pome Phone: 601-369-6439 2. Mississippi Emergency Pesponse Commission 1-800-222-6362 In State (24-Hour Number! 1-601-352-9100 Out of State (24-Hour Number) 1-960-9000 Regular Hours (Bill Austin) Material Ammonia Chlorine Di-n-octyl Phthalate Hydrazine Hydroquinone Sulfuric Acid CAS Number 7664-41-7 7782-50-5 117-84-0 302-01-2 123-31-9 7664-95-9 Reportable Quantity Pounds 100 10 5000 1 1 1000 7-4 ABD00023483 % % TABLE II CERC1A 302fa~> MATERIALS Report to: National Response Center 1-800-424-8802 Material Ammonia Antimony Trioxide Asbestos (Friable forms only) Chlorine Di-n-octyl Phthalate Hydrazine Lead Stearate Lead Sulfate Mercury Methanol Phthalic Anhydride PCB's Sodium Hydroxide Sulfuric Acid Vinyl Chloride Unlisted Hazardous Wastes: Characteristic of Corrosivity Characteristics of EP Toxicity Arsenic D004 Rarium D005 Cadmium D006 Lead D008 Characteristic of Ignitability Characteristic of Reactivity 7-5 Reportable Quantity Pounds 100 1000 1 10 5000 1 5000 100 1 5000 5000 10 1000 1000 1 100 1 1000 1 1 100 100 ABD00023484 i 5* NATIONAL RESPONSE CENTER TYPICAL QUESTIONS 800*424-8802 1. Name of person reporting che spill and/or release: 2. Company represented: Vista Polymers Inc. 3. Mailing address and phone number: P. 0. Box 91, Aberdeen, Mississippi 39730(601) 369-8111 4. Plant location: Highway 25 South 5. County: Monroe 6* Site of spill: 7* Material spilled: 8. Time and date of spill: 9. Wind direction* wind speed, barometric pressure: 10* Did spill enter a waterway: 11. Water body affected: [ ] Yes [ ] No 12. Source of spill: 13. Cause of spill: 7-6 NATIONAL RESPONSE CENTER TYPICAL QUESTIONS Page 2 ABD00023485 S- 14. Was equipment in operation at the time: 15. Size of spill: [ ] Yes [ ] No 16. Was there any property damage from the spill: [ 1 Yes [ ] No 17. Corrective action taken to stop spill: 18. Did company personnel conduct cleanup: [ 1 Yes [ ] No 19. Has the affected equipment been repaired: [ 1 Yes [ ] No 20. Was anyone hurt: [ ] Yes [ ] No a 21. Was any evacuation needed: [ ] Yea ( ] No 22. Have any other agencies been notified of the spill: [ ] Yes [ 1 No 23. Do we have any plans to notify any other agency: [ ] Yes [ ] No 1 Time and date incident reported to National Response Center: 2. Nana of person accepting report: 3. Other lnforaatlon requested: ___ 4. Signed: ___________________________ ABD00023486 SPILL/RELEASE REPORT TO BE FILLED OUT BY SHIFT SUPERVISOR TIME PERSON REPORTING SUPERVISOR LOCATION NAME NAME DATE DATE DEPT TYPE OF MATERIAL ESTIMATED AMOUNT DURATION CAUS E WIND DIRECTION, SPEED, BAROMETRIC PRESSURE DID MATERIAL ENTER GROUND DID MATERIAL ENTER STORM SEWER DID MATERIAL LEAVE THE PLANT IS MATERIAL ON SARAOR CERCLALIST (SEE ATTACHED TABLES) IF SO, DID THE SPILL/RELEASE EXCEED THE REPORTABLE QUANTITY______________________ WHAT ACTION WAS TAKEN TO STOP SPILL________________________________________________________ WHAT ACTION WAS TAKEN TO CLEAN-UP SPILL DISTRIBUTION: RWS, DCS, FGJ, TFL, RBN, OPERATIONS SUPERINTENDENT, OPERATIONS ENGINEER, DEPARTMENT SUPERVISOR 7-8 ABD000234&7 i SPILL/RELEASE PREVENTION REPORT TO BE FILLED OUT BY DEPARTMENT SUPERVISOR SPILL/RELEASE THAT OCCURRED___________________________________________ RECOMMENDATIONS OR ACTION TAKEN TO PREVENT RECURRENCE DEPARTMENT SUPERVISOR ENVIRONMENTAL COORDINATOR OPERATIONS SUPERINTENDENT PLANT SUPERINTENDENT PLANT MANAGER DATE DATE DATE DATE DATE 7-9 ABD00023488 <. -i MISSISSIPPI KHRBGKNCT MANAGEMENT AGKNCT HAZARDOUS MATERIAL RELEASE REPORT 1 Release Location l. Data ---------- /-----------1------- 1. Tl at 5. Contact for further information: NI --i . Tl t 1 a : 4. Coapany Ni City: s t 11 t Cl 91 6 Release Infonation a ) N a a of tab ea > b) NA/tm ---- CASI C) III, t>llti t M d ) Data of Rail : a> T l *a of lalaiiai f) Dinilai of I t) Ral ana occirrad lata Air a vttar grand b) sibituca la aitraaii r biiirdiu rtl (bar liat la 40 era ill) a H 7. ITenontmriml precautions 8. Anticipated Health Risks 9 Person reporting rel Niaai Tl til: Addrai City: Sx at 11 p: MEMA-III-1 [0CT87] 10. Notified: O Pallatloa caatrol lidlel oil(il a a 1 Kaaai Qatar tl Ml 11. Emergency Action Required: a xni stitt o Local 12. Person taking report: 7-10 ABD00023489 h ATTACHMENT A Superfund Reporting Checklist I. Below RQ II. Above RQ Report? No 1.0 Air A. NESHAPS 1. VCM a). In VCM service i) Process Vent 1. Less than lOppm VCM for 3 hr. TWA 2. Exceeds lOppm std by less than RQ 3. . Exceeds lOppm std by more than RQ 11) RV/RD release HI) RV/RO leak iv) Other leaks Not In VCM service D Process Vent 11) RV/RD release 111) RV/RD leak iv) Other leaks Massive Release No No Yes No No No Yes Yes Yes No Yes 2. BENZENE a). In benzene service D Process vent 1. In compliance with standard 2. Above standard by less than RQ 3. Above standard by more than RQ id RV/RD release no RV/RD leak Iv) Other leak No No Yes Yes No No 7-11 ABD00023490 Not in benzene service i) Process vent ii) RV/RD release ill) RV/RD leak iv) Leak Massive release B. SIP 1. Release from specifically regulated point a). In compliance with regulation b). Above regulatory limit by less than RQ c). Above regulatory limit by more than RQ 2. Fugitive leak if SIP has fugitive control requirements C. OTHER 1. Continuous or routine releases 2. Significant increase in continuous or routine release 2.0 Water A. NPOES regulated discharge 1. Permit exceedance caused by spill of hazardous substance 2. No permit exceedance 3. Permit application identifies substance and amount (concentration) 4. Stormwater outfall B. Spills 1. Ground a). Inside Plant i) Volatile ii) Nonvolatile, nonporous surface ill) Nonvolatile, porous surface iv) Sewer (See NPDES) Yes Yes Yes No Yes No No Yes No No Yes Yes No No Yes Yes No Yes -2- 7-12 ABD00023491 b). Outside Plant 3.0 Seepage to the Ground A. From impoundment - episodic B. From sewer lines - episodic C. From underground pipeline - episodic D. Initial detection of continuous release E. Subsequent continuous releases 4.0 Discharges to POTW's A. Pretreatment standard exists exceed standard by RQ amount B. No Pretreatment Standard - Spill RQ amount Yes Yes Yes Yes Yes No Yes Yes WLM07/089 -37-13 ABD00023492 . To Distribution jmtr Interoffice Communication From Date Subject F G Jeanson February 3, 1989 PLANT ENTRY OF GOVERNMENTAL AGENCY PERSONNEL VISTA Each person from a Governmental Agency is to complete and sign the attached Request for Entry form before being allowed into the plant If the person will not sign the form, ask what the problem is He will likely have an objection because of Item 6, the indemnification section Then ask him if he would sign tne form if Item 6 is crossed out. If he says yes, cross out Item 6 Both the Agency person and the Plant representative are to initial the cross out. If the person will not sign the form under any circumstances, contact the Manager He will then determine whether to allow the person entry into the plant. A supply of the Request for Entry forms will be kept by Terry Sullivan. Contact me if you have any questions about using the form F G Jeanson Environmental Coordinator Cjs C. RWS, DCS, JEN, JEL, DWH, PJK, JEB, HGC, TFL, GAM, BLT, SCH, VLT, RBN, REP, RAH, TJS, ENGINEERS 7-14 ABD0002349*fi3r RIQCSST tor entry 1. "v name is I represent by che laws of che (Uniced States) (Stace of . My business address Is (agency or bureau) wMch Is estabilshe Ky official, title or position is 2. In my official capacity, i .a requesting adalsslon co (plane or facility) , for the purpose of: ( ) a. gathering scientific research information ard/or studying technology development, under (statute or popular name of act) ( ) b. making a regularly scheduled inspection of the facilities, under (statute or popular im of aecl ( ) c. caking samoles of water, air, or _________ type of air monitoring equipment type of veeer cr soil sampling equipment __ water chemical analyses (tests and methods) soil chemical analyses (tests and methods) iocatlon(s) for sampling ______________________ (cirele) ( ) d. making a special inspection of the facilities for che following purooses: under (statute or popular name of act) ( ) e. gathering evidence for pending or potential criminal or civil proceedings, under (acetate or popular name of act) ( ) f. ocher; specifically s under (scatute or popular name of aee) 3. I specifically wish to see the following units or activities: 7-15 ABD00023494 u I agree to provide sollt saooies of all samoLes of whatever nature obtained, <>nd to furnish you all analytical results from all tests conducted. 5. 1 -nderstand chat 1 will be furnished a guide and such ocher assistance as 1 nay reoulre for information or safety. I agree to comply with all safety regulations and instructions, whether written or oral, while on the premises. 6. I agree to indemnify and hold you harmless from and against any loss, coses, expense or liability arising out f any loss, claim, or eause of action for loss of or damage to ay property or equipment, or that of my easloyees or agents, and Injuries to or death of persons caused by, resulting from or Incidental to the entry authorized hereby; provided, however, that except for loas of or damage to my property or equipment, or chae of sy employees or agents, such indemnification and hold harmless shall noe apply to claims for lots, damage, Injury or death If caused by your sole negligence. 7. I, and my employees and ageaea, agree to treat and maintain as eonfldsnelsl property of the Agency, and, except as is necessary to perform the work envisioned hereunder, shall not use or disclose to others, either during the term of this entry or thereafter, any information (including any technical Information, experience, or field daea) regarding products, plans, programs, plants, processes, coses, equipment, operations, or customers which may be disclosed eo or come within my knowledge, or chat of my employees or agents, during the entry authorized hereby. The provisions of this paragraph shall not apply eo any information, referred to herein which l can establish (1) has been published and has become pare of ehe public domain, other than by ay or ay employees or agents aces or omissions, (11) has been furnished or eade known to me by third parties (ocher chan chose acting dlrecely or lndlreecly for or on behalf of you) as a matter, of Icgel right and without restriction on disclosure, or (ill) is required by law to be disclosed* (Daee) (Visitor) (Time) Visit authorized by: (Title) ________________ (Agency or Bureau) (Plane or facility) 7-16 ABD00023495 i r ABD00023496 ACRONYMS 1 CAA - Clean Air Act 2 CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act 3 CFR - Code of Federal Regulations 4 CWA - Clean Water Act 5 BDAT - Best Demonstrated Available Technology 6 EP Toxicity - Extraction Procedure Toxicity 7 EPA - Environmental Protection Agency 8 FR - Federal Register 9 HSWA - Hazardous and Solid Waste Act of 1984 10 LEPC - Local Emergency Planning Committee 11 MDEQ - Mississippi Department of Environmental Quality 12 MDNR - Mississippi Department of Natural Resources, now MDEQ 13 MERC - Mississippi Emergency Response Center 14 NAAQS - Nation Ambient Air Quality Standard 13 NESHAP - National Emission Standard for Hazardous Air Pollutants 16 NPDES - National Pollutant Discharge Elimination System 17 NSPS - New Source Performance Standard 18 OCPSF - Organic Chemicals, Plastics, and Synthetic Fibers 19 OSHA - Occupational Safety and Health Administration 20 PDS - Prevention of Significant Deterioration 21 RCRA - Resource Conservation and Recovery Act 22 RIM or R1L - Regulatory Interpretative Memorandum or Letter 23 ROL - Reactor Opening Loss 24 SARA - Superfund Amendment and Reauthorization Act 8-1 ABD00023497 ACRONYMS - (Continued) 25 SDWA - Safe Drinking Water Act 26 SMU - Solid Waste Management Unit 27 SPCC - Spill Prevention, Control and Countermeasure 28 TC - Toxicity Characteristic 29 TCLP - Toxicity Characterstic Leaching Procedure 30 TSCA - Toxic Substances Control Act 31 TSDF - Treatment, Storage or Disposal Facility 32 UST - Underground Storage Tank 8-2 ABD00023498 RESOURCES: Environmental Department Legal Department Engineering R&D Tom Grumbles Joe Ledvina Bill McClain Dave Cohen Tom Heller Allen Nielsen Houston Houston Houston Houston Houston Houston X3445 X3446 X3278 X3548 X6886 X3308 REFERENCES: AP-42 SW-846 40 CFR FR Newsletter White Books Compilation of Air Emission Factors Test Methods for Evaluating Solid Wastes Code of Federal Regulations - Vol (10 books) 40 Federal Register Daily "Inside EPA" "Environmental Policy Alert" "Environmental Reporter" Bureau of National Affairs TRADE ASSOCIATIONS; VI - Vinyl Institute SPI - Society of Plastics Industries CMA - Chemical Manufacturers Association SDA - Soap and Detergent Association CSMA - Chemical Specialty Manufacturers Association MMA - Mississippi Manufacturers Association LCA - Louisiana Chemical Association TCC - Texas Chemical Council MCIC - Maryland Chemical Industry Council AIM - Associated Industries of Mississippi VCSA - Vinyl Chloride Safety Association 8-3 ABD00023499 VIII APPENDIX Example Environmental Situations The following pages have seven environmental situations which could happen at this plant The steps necessary to control and report the situations follow each situation For any environment*] situation which occurs there are five steps to complete Step one and two should be completed at the same time so that any aid needed m controlling the situation can be given The five steps are 1 CONTROL THE SITUATION 2 NOTIFY THE ENVIRONMENTAL COORDINATOR AND/OR THE CHIEF PROCESS ENGINEER 3 DETERMINE QUANTITY OFMATERIAL RELEASED 4 DETERMINE WHAT AGENCIES TONOTIFY 5 REPORTING 8-4 ABD000235Q0 r- 1. Rupture Disk Failure SITUATION A rupture disk on D-700 reactor prematurely fails lift What actions should be taken9 The relief valve doesn't ACTION STEPS 1. CONTROL THE SITUATION a Kill batch b Recover reactor c As soon as time permits, replace rupture disk and give blown rupture disk to Environmental Coordinator or Chief Process Engineer, m the mean time, continue with list 2 NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3 DETERMINE QUANTITY OF MATERIAL RELEASED a. See example of next page 4 DETERMINE WHICH AGENCIES TO NOTIFY a Because the relief valve did not lift, this incident is not a release. It is a leak which should be included in the yearly SARA 313 Emissions Report (Fugitive). 5 REPORTING a Since this incident is not a release, there are no immediate reporting requirements Do not forget to include pounds leaked as part of the fugitive emissions in the SARA 313 Emissions Report 8-5 ABD000235CU 2. Reactor Leaks to Sever SITUATION An operator charging a reactor shuts off the high pressure service water and opens the catalyst bomb drain without shutting the automatic valve to the reactor The reactor contents leak to the sewer. What do we do novr? ACTION STEPS 1. CONTROL THE SITUATION a. Prevent further release 1. Close automatic valve 2 Close backup manual valve is necessary b. Flush sewer with water to prevent VCM vapor cloud 2 NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3 DETERMINE QUANTITY OFMATERIAL RELEASED a In this situation VCM is released A good estimate of the quantity can be obtained by the following formula. (ppm of VCM in water) x (gallons of water) x (8 34 gal/lb) 1,000,000 parts - pounds of VCM released 4. DETERMINE WHICH AGENCIES TONOTIFY a. If pounds of VCM released is over 1 pound, the release is reportable under CERCLA 302(a) materials b If pounds of VCM release is under 1 pound, stop after completing 5 (a). 5. REPORTING a. Supervisor or Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 of this manual for copy of report b. Report needs to be filled out as soon as situation is under control b. Environmental Coordinator or Chief Process Engineer 1 Call the National Response Center a 1-800-424-8802 b Notified immediately c Typical questions asked are located in Section 7, Page 9 of this manual d Questions need to be answered before calling e. No written report is needed 8-6 ABD000235G2 2 Reactor Leaks to Sewer (Continued) 5 REPORTING 2 Mississippi Department of Environmental Quality, Bureau of Pollution Control a See Section 3, Page 2 for address, phone number and Administrator b Send copy of report sent to EPA, Section IV 3 EPA, Region IV - send report a Report per Regulation 61 64 (a)(3) which reads Within 10 day* of any discharge to the atmosphere from any manual vent valve, the owner or operator of the source from which the discharge occurs shall submit to the Administrator a report in writing containing information on the source, nature and cause of the discharge, the date arwi time of the discharge, the approximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loaa (the calculation of the vinyl chloride loss) , the action that was taken to prevent the discharge, the measured adopted to prevent future discharges b This example violates Regulation 61 65 (b)(5) manual venting of gases which reads Manual Venting of Cases Except as provided in 61,64 (a)(3), all gases which are manually vented from equipment in vinyl chloride service are to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm (average for 3-hour period), or equivalent as provided in 61 66 c See Section 3, Page 2 for address and phone number and Administrator 4 Spill Prevention Report a See Section 7, Page 9 of this manual for copy of this report b Report must be completed before reporting to EPA 8-7 ABD00023503 3 VCM Relief Valve Lifts SITUATION A D-745 relief valve lifts caused by over pressure What now? VCM is emitted to the air ACTION STEPS 1. CONTROL THE SITUATION a Kill reactor and split batch to open reactor if available b Recover reactor that relief valve lifted on first c Monitor VCM levels throughout the unit. Use judgement to determine if evacuation alarm is necessary d Determine wind direction e If release is considered to be big enough, tell people in the neighborhood via plant emergency speaker f If levels are high evacuation of the neighborhood should be considered This decision should be made in consultation with as many members of Plant Management as possible g If situation is determined as emergency 1 See Emergency Plant for further actions 2 Contact LEPC or Police Department 3 Notify Mississippi Emergency Response Commission 1-800-222-6362 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. Estimate time relief valve was open using reactor pressure indication, eye witness accounts, and any other information available b Use orifice, pressure, and time release data to estimate pounds of VCM released 4 DETERMINE WHICH AGENCIES TO NOTIFY a If pounds of VCM released is over 1 pound, the release is reportable under CERCLA 302(a) materials. b If pounds of VCM released is under 1 pound, stop after completing 5 (a) 5. REPORTING a. Supervisor of Area in which release occurred 1 Spill/Release Report a. See Section 7, Page 8 this manual for copy of report b Report needs to be filled out as soon as situation is under control 8-8 ABD00023504 3 VCM Relief Valve Lifts (Continued) 5 REPORTING b Environmental Coordinator or Chief Process Engineer 1 EPA, Region IV a See Section 3, Page 2 for address and phone number and Administrator b Report per Regulation 61 65 (a) which reads Relief Valve Discharge Except for an emergency relief discharge, there is to be no discharge to the atmosphere from any relief valve an any equipment in vinyl chloride service An emergency relief discharge a discharge which could not have been avoided by taking measures to prevent the discharge, the owner or operator of the source from which the relief valve discharges occurs shall submit to the Administrator a report in writing containing information ou the source, nature and cause of the discharge, the date and time of the discharge, the approximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loss (the calculation of t-H* vinyl chloride loss), the action that was taken to prevent the discharge, ami measures adopted to prevent future discharges 2 Mississippi Department of Environmental Quality, Bureau of Pollution Control a. See Section 3, Page 32 for address, phone number, and Administrator b Send copy of report sent to EPA, Section IV 3 Spill Prevention Report a See Section 7, Page 9 of this manual for copy of the report b Report must be completed before reporting to EPA 8-9 ABD00023505 v 4. Oil on Outfall SITUATION A drum of Lube oil falls from a fork truck crossing the railroad tracks north of the 600 series silos. The barrel bursts open and oil goes into a sewer You are in charge, what do you do? ACTION STEPS 1 CONTROL THE SITUATION a Prevent further spill b Prevent oil from entering sewers by use of dikes, absorbent booms or clay, or other methods available c Determine type of sewer 1 Process a Go to Step 2 (Notify Environmental Coordinator and stop 2 Storm a Go to next step d. Check place where water leaves plant for oil Even if oil is not observed, place absorbent boom in the stream e. Check Storm Water Pit to which sewer drains for oil f If oil is present, use the following as needed 1. Absorbent booms on outfall 2. Pump Storm Water Pit to process sewer 3 Vacuum Truck (See SPCCP Section 2, Page 25 of this manual) 2 NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3 DETERMINE QUANTITY OF MATERIAL RELEASED a Each situation is different Use your best judgement 4. DETERMINE WHICH AGENCIES TO NOTIFY a Any oil sheen leaving the plant boundary and entering a water stream must be reported per the Clean Water Act and the Aberdeen Plant Spill Prevention Control and Countermeasures Plan, Section 2, page 16 of this manual 5 REPORTING a Supervisor of Area in which release occurred 1 Spill/Release Report a See Section 7, Page 8 of this manual for copy of report b Report needs to be filled out as soon as situation is under control 8-10 ABD00023506 4 Oil on Outfall (Continued) 5 REPORTING b. Environmental Coordinator or Chief Process Engineer 1. National Response Center - If oil leaves the plant property a. 1-800-424-880^ b. Notify immediately c. Typical questions asked are located in Section 7, Page 6 of this manual d Questions need to be answered before calling e. No written report isneeded 2. Mississippi Department of Environmental Quality, Bureau of Pollution Control a See Section 3, Page 2 for address, phone number, and Administrator b Notify within 24 hours of incident 3 Spill Prevention Report a. See Section 7, Page 9 of this manual for copy of report 8-11 ABD00023507 5 Blend Tank Overflow SITUATION A blend tank overfills and slurry flows into a storm sewer required7 What actions are ACTION STEPS Any waste water that discharges outside of the plant boundary that normally goes to a process sewer is considered a bypass 1 CONTROL THE SITUATION a Prevent additional material from entering Storm Sewer by use of dikes, valving, or any other manner possible 2 NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a Estimate quantity of waste water in pounds and gallons b Estimate quantity of VCM 4 DETERMINE WHICH AGENCIES TO NOTIFY a Under the Clean Water Act any Waste Water Bypass must be reported to the Mississippi Department of Environmental Quality (MEDQ) b Under CERCLA 302 (a) if more than 1 pounds of VCM is released, the incident is reportable as explained in this manual under the situation REACTOR LEAKS TO SEWER 5 REPORTING a Environmental Coordinator or Chief Process Engineer 1 Mississippi Department of Environmental Quality, Bureau of Pollution Control a See Section 3, Page 2 for address, phone number, and Administrator b Notify within 24 hours of incident 8-12 ABD00023508 6 Acid Spill on Slag SITUATION A H2SO/ truck entering the plant hits the weighscale building and bleaks off a valve The acid spills onto the concrete and slag What would you do? ACTION STEFS 1 CONTROL THE SITUATION a Isolate and rope off area b Any personnel in the area must wear protective equipment including breathing apparatus c Prevent further spill if possible d Contain spill by use of dikes, damming drains and ditches, etc e Notify the Safety Director and Environmental Coordinator as soon as possible f Neutralization of liquid inside containment dike 1 Dilute liquid with water to raise pH 2 Add Soda Ash (only if dilution does not work) until pH is above 60 3 Pump liquid in dike to Process Sewer g Neutralization of soil/slag 1 Test pH of soil a The soil needs to be tested to determine if it is contaminated If the pH is greater than 5 and less than 10, no treateraent is necessary b If the soil pH is less than 5 or greater than 10, neutralization of the soil should be done See Environmental Coordinator for proper neutralization techniques 2 NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3 DETERMINE QUANTITY OF MATERIAL RELEASED a Estimate quantity of H2S04 that left plant boundary without being treated Consult Environmental Coordinator for help 4 DETERMINE WHICH AGENCIES TO NOTIFY a If greater than 1000 pounds of Sulfuric Acid is spilled on concrete and totally contained before it reaches the soil, the spill does not need to be reported to any Agency b If greater than 1000 pounds of Sulfuric Acid is spilled on the ground but the spill does not leave the plant boundary, it needs to be reported under CERCLA 302 (a) only c If greater than 1000 of Sulfuric Acid leaves the plant boundary, the spill also needs to be reported under SARA 8-13 ABD00023509 6. Acid Spill on Slag (Continued) 5. REPORTING a. Supervisor of Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 of this manual for copy of report b. Report speeds to be filled out as soon as situation is under control b Environmental Coordinator or Chief Process Engineer 1 In-Plant Spill Prevention Report a. See Section 7, Page 9 of this manual for copy of report CERCLA 302 1. (a) National Response Center a 1-800-424-8802 b Notify immediately c. Typical questions asked are located in Section 7, 6 of this manual d Questions needs to be answered before calling e. No written report is needed Page SARA 1. Emergency Coordinator, Local Planning Committee a Immediate notification Jerome Husky (601) 369-6439 b Written notification A written follow up emergency notice is also required setting forth and updating the information required to be reported in the verbal report and to include additional information with respect to. 1. Action taken to respond to and contain therelease. 2 Any known or anticipated acute or chronic health risks associated with the release, and 3. Where appropriate, advice regarding medical attention necessary for exposed individuals. This written report is to sent to Emergency Coordinator of the Local Emergency Planning Committee and to W. E. Austin, Special Projects Office, SARA Title III, Mississippi Emergency Response Commission, P. 0 Box 4501, Fondron Station, Jackson, Mississippi 39216-0501. The written report should be submitted within ten days as a maximum. 8-14 ABD00023510 7. Waste Water Permit Violation SITUATION The test results from EnviroLab returns with a BOD of 45 ppm at Outfall 001 (Pond 6 effluent) What should we do? ACTION STEPS 1 CONTROL THE SITUATION a At this point there is not much that can be done since the BOD test is a five day test (results are 5 days old when they are reported to us) b Make sure all the aerators are on and check for any visible oil c Investigate why the BOD is high Were there any spills? d The daily max values are not as important to the EPA and MDEQ as the monthly average To decrease the monthly average, take extra (more than one a week) samples while the BOD level is below the monthly permit level 2. NOTIFY THE ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a The ppm of BOD in the Outfall 001 is reported by EnviroLab, 1-323- 7744, our contact is Bob Schubert The co-op process engineer receives results every Monday 24 hours composites are samples from Tuesday morning to Wednesday b The pounds/day of BOD in the stream 001 is calculated by pounds/day - ppm x GPM x 0 012017 The GPM of the Outfall 001 can be obtained from the totalizer located at the outfall and the coop keeps a record of these results 4 DETERMINE WHICH AGENCIES TO NOTIFY a Since 45 ppm is above the permit limit of Outfall 001 (see p 4-29), it is necessary to contact the State of Mississippi Bureau of Pollution Control, Industrial Water Section Be sure to check the BOD pounds/day and COD pounds/day for compliance before reporting 5. REPORTING a Environmental Coordinator 1. NPDES Monthly Report 8-15 ABD00023511 TECHNICAL INFORMATION COMMUNITY HEALTH EFFECTS 0F VINYL CHLORIDE Prepared By* The Vinyl Inecltuee Health, Safety, & Knvlrooaeat Cooaittee Iesuedt August 1, 1986 rh i 8-16 ABD00023512 -r I. SUMMARY This document reviews the toxicity and human health effects of ambient exposure to vinyl chloride (VC), the raw material used in the production of polyvinyl chloride (PVC). It summarises the extensive and rigorous federal regulation of the YC/PVC industry, and comperes quantitative risk feasements with actual health observations of individuals in non-occupations! settings. A review of the world scientific literature ahowa no cosmiunlty health Impact* associated with exposure to VC emissions from VC/PVC manufacturing facilities* II. INTRODUCTION Vinyl chloride Is the basic building block for producing the most versatile plastic yet developed -- polyvinyl chloride and Its copolymers with other monomers. Most of the seven billion pounds of VC produced annually in the United States is converted Into PVC used In thousands of products in the home and in Industry -- products such ss wallcoverings, upholstery, flooring! house siding, water pipes, sever pipes, luggage, clothing, automotive parts, medical devices, food wrap, windows, doors, wire insulation, garden hosee, and phonograph records. PVC is a polymer produced from VC through a chemical reaction celled polymerization. VC Is converted Into PVC by suspension, emulsion, bulk or solution polymerisation methods. PVC resins can be extruded, molded or calendered Into diverse shapes, sizes, and colors. Mechanical characteristics can be controlled to produce forms that are rigid, flexible, or In a liquid form such as latexes, pastas, and adhesives. vinyl chloride became of Industrial importance approximately fifty yeare ago when Semon (1933) discovered that the polymer could be converted Into ueeful articles by plasticization with phthalate asters. Commercial development began first in Europe and then In the United States in the late L930's. It was not until the early 1950's that widespread coneumcr applications developed. PVC la now e mature product, and Its growth rate falls in step with the Gross National Product. III. HEALTH HISTORY Acute Toxicity Vinyl chloride la a strong anesthetic at 8-12Z in animals and humans* Death follows rapidly after unconsciousness sets in If exposure is not rndtttnd quickly (Petty et al, 1930). No major histological changes ware reported after 100 days at exposures of 50,000 ppm (Kuebler, 1964). Reversible liver effects at 100*500 ppm led to a recommendation of a 50 ppm TWA axpoeore limit (Torkelaon, Oyen, and Rowe, 1961), but the American Conference of Governmental Industrial Hygenlsts adopted instead a recommendation by Tele scientists of 500 ppm. This Is the value later accepted by 08HA end it served until 1974. Lehman and Flury (1943) termed vinyl chloride to be "one of the least dangerous of the chlorinated hydrocarbons". 8-17 ABD00023513 S- Cosmnmlty Health Effects of Vinyl Chloride P|e Two There ere no other known scute huaen physiological effects froa vinyl chloride exposure. The odor threshold la bout 1,000 ppa. The high heet of vaporisation causes a substantial part of a large spill to liquify and presents the danger of froatblte. Vinyl chloride la flamabla over Cha range of 3.6-33X in air, and extreae care must be taken to avoid apllla and laaka for that reaaon. Moat measurement and warning systems were designed to hold plant atnoapherea below the flammable limits. Retrospective estimates of typical time-weighted average personal exposures for polymerisation workers In England have been estimated (Barnes, I960) as follovsi 1945 to 1955 1955 to 1960 1960 to 1970 Mid 1973 1975 1,000 ppm (or above) 400 to 500 300 to 400 150 5 In some jobs, particularly the cleaning of polymerisation reactors, exposures in the thousands of ppm range were experienced for short periods. (See Purchase, et el, 1965 and Barr, 1986 for reviews of the toxicity of VC). Chronic Health Effects The first clear indication of chronic health problems associated with VC came in the 1960's in men who entered VC polymerisation reactors to remove build-up of polymer from the walla. Some of these men developed aero-osteolysis, a disease resulting in softening of bones in the fingers (Suciu, at al, 1963f Harris and Adams, 1967 Cook, et al, 1981). Modification of working practleaa has led to the elimination of this disease in workers In PVC plants. In the lata 1960's, Professor P.L. viola of the 8olvay Coa^eny tried to reproduce aero-osteolyals In rats by exposing Cham to high concentrations of VC for long periods. He failed to produce aero-oeteolytlit but ha reported an increase In incidence of a variety of tumors at various sites. For the first time, it had been suggested that VC ves an animal carcinogen. (Viola, 1969, 1970t Viola, Blgottl and Capuco, 1971). Aa a direct result of the Viola work, four West European VC/PVC manufacturing companies in Italy, France, Belgium, and England supported a comprehensive study of the animal toxicology of VC by Professor C. Maitonl, Director of the Institute of Oncology at Bologna. Maitonl's work which extended over eight years has proved to be the most comprehensive study of VC toxicology (Maitonl et al, 1984). By the end of 1972, Maltoni had found a rare tumor angiosarcoma of the liver (ASL), In Borne of the exposed rats and confirmed that VC la Indeed en animal carcinogen. These early findings were reported at an international symposium In 1973 (Maltoni, 1977). Maitonl raccmmemded epidemiological Investigations and madlcal controls of exposed workers end early in 1974, a U.S. company announced that they had found three A8L caaee in employees et one of their PVC polymerization plants. This finding led to the conclusion thee VC wee a human carcinogen beceuee It gave rise to s rare tumor whose only other known etiological agenea in man were thorium dioxide, arsenic and possibly anabolic steroids. 8-18 ABD000235H ~oiu.i ruj Commit? Health Effects of Vinyl Chloride Page Three A8L la a very rare tumor. Lea* chan 20 cases per year from all these causes occur in this country. A review (Popper, t al, 1978) of all caaee reported In the United Staces for Che period 1964-1974 revealed 167 caaee, of which 19 were aecrlbed at that Cine co occupational VC exposure, 26 co thorium dioxide given medically, and 9 co arsenic in Fowler's solution, alao used medically. Tha remainder were of unknown etiology, vleh no connection Co VC. The high level of Interest In this specific cumor Is such that any* subsequent cases associated with environmental expoaure Co VC would nose certainly have been reported, and none have. For a tine, NIOSH published a susoary of VC-related cases (Falk, ec al, 19B1), but ehla task was token over first by John Stafford of ICI, England (Foreman, et al* 1985) and latar by Brian Bennett also of ICI. The 1986 update of VC-related ASL cases shows a total of 38 casta In che United Staces and 120 worldwide. All of theae casaa involve high occupational exposures to vc. The average ASL latency period (years from first exposure to diagnosis) in the United Staces has been 25 years, but with a median of about 22 years. The latency period In Europe, particularly In Germany, has been somewhat shorter, approximately 19 years. All the U.S. occupational casta, and almost ail aueh cases in the rest of the world are cloaely associated with the Job of reactor cleaning, which was once done manually at the end of Cha polymerisation eyele. There is clustering of cases in relatively few pleats and the majority of plants have hsd no cases. Differing work programs and job progressions may have had some effect on reducing races at various planes. An industry-sponsored epidemiological survey of workers In the VC/PVC Industry covered 8,384 men with at least one year of exposure before 1973 (Tdberahaw and Caffey, 1974). The expected excess of ASL was found. There were alao suggestions of an excess of cancers at other sites. This study was expanded to 10,173 workers (Coopar, 1981), where suggested excess of brain and respiratory < canctrf continued to be seen without, however, an aaaoelaeion between the brain cancer and exposure. In addition, moat of tha lung eanoor cases come from the same facility, with many plants having no catot* A follow-up study of this expanded cohort to determine the status of tha workers as of the end of 1980 la underway. 8everal studies have been made of che general population using ASL aa the marker disease in an effort to detect an association with possible environmental expoaure to VC. There was no association with living near a plant manufacturing or using VC in the general U.S. survay conductad by tha Cancer For Disease Control (Popper et al, 1978i Falk, et al, 1981). Brady et al, (1977) surveyed 26 ASL deaths in Mew York State between 1970 and 1975, and found five who lived nearer plants handling VC than did Chair matched controls, but could not establish a direct connection with the disease to exposure. Ten cases of ASL In Wisconsin were examined for possible connection with VC exposure, and none was found (Fieehtnar et al, 1976). Baxter et al, (1977) found no relationship between distance of residence from VC emitters snd the 47 cases of ASL in the general population of Greet Britain reported in 1963-1973. A later update (Baxter et al, 1980) found one case where the person had lived che laat six years of hia Ufa near a PVC plant and thrae casaa where the men had worked in che plasties fabricating industry but for whom chart were no records co indicate exposure co VC. 8-19 ABD00023515 S Community Health Effects of VlnyL Chloride Pag* Four The leek of relationship between residence near vinyl chloride operation* and casee of unknown etiology was confirmed. Sarlc et al, (1976) studied the deaths during the years 1968*1971 In an area surrounding a PVG pleat that had been in operation since 1949 and in which three workers had died of ASL. No relationship was found for liver or for lung or bronehlal cancer and place of residence for the general population. A similar study for communities near a Swedish plane thae had operated since 1945 and had foua^ four ASL caaea showed (Blinder and Pershagen, 1978) no unexpected elevation of fetal mortality, deaths from all cancers, or cancer of the liver or lunge during the years 1961-1974. Pancreatic cancer In malea was elevated in the age group over 60. All ASL cases in Holland alnca 1950 (27 cases) vara studied, end none had any traceable contact with VC (Dalderup et al, 1976). Iturra (1976) observed an excess of cancer deaths In a city in Canada with a PVC plant compared to a similar nearby city. This difference was principally found In malea aged 20 to 64t which is not indicative of e general pollution effect. The author drew no conclusion as to why the condition existed. Representatives of the Environmental Protection Ageney have stated that it has been unable to establish a link between living near VC nanufaecuring end using plants and ASL. There are about 20 cases of ASL per year In Che United States that cannot be escribed to one of Che known causes of Che disease. There ere alao about 5 in Europe each year. Accordingly, chere will be one case of AJL among the 5 million - S mile neighbors of VC/PVC facilities abouC every two years by chance alone. Thla has been seen In the studies in New York by Brady, et el, (1970), and in Connecticut (Heath and Landrigan, 1974). Those states have cancer registries, which ere of greet value. In one case, s Jury award wee made to the estate of an individual who died of ASL, and who had lived ths last four years of his life near a PVC plant. Inasmuch as that peraon alao had occupational exposure to VC and exposure to ochsr ASL causative agents, it cannot be concluded that ambient VC exposure caused his ASL (In Gresso, Civil Action No. 78-1562, D.N.J.). A thorough study (Chlazse, et si, (1977), Chlsaae, (1980)) of more than 15,000 employees of PVC fabricators found no evidence of VC-related health effects in that group, which was estimated to have been exposued to at laaat 15 ppa VC for many years. The disease ASL is often difficult to diagnose (Block, 19741 Heath, Flak end Creech, 1975), Isalmost invariably fatal within a short time, and presents e verlsty of symptoms, Including portal fibrosis end hypertension with splenomegaly and varices, proliferation of the sinusoidal lining, mogalocytosla, and thrombocytopenia (Thomas and Popper, 1973i Cadlgk et el, 1975). Metastasis is frequently Involved. These symptoms are vary similar to those seen In the mouse (Schaffner, 1978) and rat (Feron and Krees, 1979) and the pathology also is similar (Cordon et al, 1975). No really adequata early warning testa have been devised (Whelan et el, 19761 Lengbein et al, 19931 Tamburro and Creenberg, 1981), although the gamoMglutamyl tranepepsidese test Is promising, together with ICC clearance end SCOT. Radiographic liver scene and tomography and sonography (Koliebtfltc at al, 1981) are said to ba useful confirmatory tests. 8-20 ABD00023516 Community Health Effect# of Vinyl Chloride Page Five In summary* VC le a classical procarcinogen* and la clearly a human carcinogen, caualng ASL in a email percentage of highly expoaed workera. There la auggeaclve evidence tnat it may be a weak general carcinogen at high concentration#* perhaps through an inrnmnoauppreaaive mechanism* but more date are required to confirm this suspicion. Several studies of large populations have not shown a connection between general aabient exposure and an increased Incidence of cancer. ^ IV. FEDERAL REGULATION OP VC/PVC INDUSTRY The prlaary federal agenciee regulating the VC/PVC industry are the Occupational Safety and Health Admlniatratlon (OSHA), which la part of the U.S. Department of Labor, the U.S. Environmental Protection Agency (1PA)* and the Pood and Drug Admlniatratlon (PDA). OSHA regulation focuses on worker health while EPA addresses the control of chemicals outside the workpiece. PDA oversees uses of PVC that involve foods* drugs* cosmetics* and medical devices. A. The Occupational Safety and Health Administration The allowable occupational exposure for vinyl chloride of 1 ppm on an 8-hour time weighted average (TWA) Is set by the OSHA workpiece standards at 29 C.F.R* 1910.1017. This was adopted In 1974* after extensive public hearings* and became effective in April 1975. OSHA first set an emergency temporary standard of 50 ppm and proposed a permanent limit of nondctectable exposure by a test sensitive to 1 ppm* OSHA then promulgated a final standard of an 6-hour TWA of 1 ppm* and a 15-minute celling of 5 ppm. In brief* the regulation aetai 1. A level of 0.5 ppm VC below which no action la required* This generally exempts moat PVC fabrication plants and laboratories end many monomer plants. 2. A regulated area where exposures are above 0.5 ppm which restrlttft entry to authorised persons. 3. Hedlcsl examination requirements and exposure record retention for specified employees. 4. A list of acceptable respirators. 5. Monitoring and alarm systsms for the workpiece* and routine measurement of worker exposure. Labeling and signs for regulated areas and containers of vinyl chloride and PVC. 7. Work procedure! for heeardoua operation*. 8* Training prograaw for employees. 8-21 ABD00023517 V Coommlcy Health Effects of Vinyl Chloridt ?4|S SIX 08HA also has a Hazard Communication Standard (HCS), 29 C.F.R. 1910.1200* which provides labsling requirements complementary to the CSKA Vinyl Chloride Standard. Articles made from PVC are exempc from labeling requirements under the standard. B. Environmental Protection Agency 4 EPA regulates the release of vinyl chloride under several statutes* Including the Clean Air Act, Clean Water Act* Safe Drinking Water Act* Resource Conservation end Recovery Act (RCRA)* Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund)' and the Toxic Substances Control Act (TSCA). 1. Air Standard (40 CFR 61.60) The EPA standard established in 1976 specified the following conditional e. Fugitive emissions controls by leek patrols and design standards for pump and compressor seals* agitators * and loading davicaa* b. Work practlcaa for veaaal openings and sampling. c. Stripping requirements for residual oononar In raslna and wastewater. d. Abatement of specified point source emission* to 10 ppm* e. Prohibition of relief valve dischargee* except for emergencies* f. Extensive monitoring* reporting and recordkeeping requirements. g. Specific analytical procedures. EPA eatlnated that this standard would result In a 95% reduction of VC emissions to ths atmosphere from VC/PVC manufacturing plants and rsduet tha 5 mils annual average VC anblent air concentration from 17 parti per billion (ppb) to less than 1 ppb. 2. Water Rasnlationa Vinyl chloride la listed as a priority pollutant under Section 307(a) of the Clean Water Act* and a Water Quality Criteria Document has bean prepared. This subjects VC and PVC manufacturing plants to special considerations when waste water discharge permits are issued pursuant to EPA regulations. As part of its regulation of carcinogens in drinking water' EPA has published a final Reeonsended Maximum Contaminant Level (XMCL - a non-binding guideline) for VC in drinking wetsr of aero (see 50PR 46880* Mov. 13* 1965 for this amondawnt to 40 CPR 141*50*) 8-22 ABD0002351<8 Cosamralty Health Effect# of Vinyl Chloride Pag* 8m However, EPA Indicated that a "Justifiable" way to determine the absence of vinyl chloride would be by setting a defined, #cate-of-the-art detection limit sensitive to approximately i ppb, (49FR 24,330, 24,347 - June 12, 1984). EPA has also proposed a maximum contaminant level of 1 ppb for vinyl chloride in drinking water. (See 50 FR 46,902 - Nov. 13, 1985). 3. Waste and Spill Regulation 0 The EPA Issued a rule under which certain VC manufacturing distillation residues are listed as hatardoua wastes whan disposed (49 FR 5308). This rule requires that all such wastes are to be dlapoeed of only by RCRA-approved procedures. When disposed of, commercial grade VC Is classified ss a hatardoua waste under the Resource Conaervaclon and Recovery Act (RCRA), because of lta toxic and lgnltable characteristics. Any disposal la subject to regulation under RCRA. EPA has proposed additional RCRA regulations (51 PR 21648, June 13, 1986) which apply to all wastes containing VC. These proposed regulations define wastes as hazardous when the VC level in the extract by a specified test method exceeds 50 ppb. Congrtas has specified an interim l pound reportable quantity for vinyl chloride. Releasee to the environment in excess of 1 pound are regulated under CERCLA. 4. New Product Manufacture The EPA also administers the Toxic Substances Control Act (T8CA) which establishes health end environmental regulations for both new end existing substances. No one may manufacture or use e aubetenco which la not on the Agency's official inventory, unless the Premenufeeturlng Notice procedures are followed. C. Pood end Drug Administration PVC is widely used for food contact applications. In early 1986, the Pood and Drug Administration (FDA) confirmed the safety of PVC for all food-contact applications and withdrew an outstanding proposal to limit Its use in food packaging. (See 51 FR 4173 - February 3, 1986), An accompanying new proposal would set various residual vinyl chloride levels for different food contact materials. Among ocher things* PM found that "vastly improved production technology (alnca 197S) has made it possible for manufacturers to succeed in reducing the level of residual vinyl chloride monomer in vinyl chloride polymer." The comawnt period on the February 3, 1986 FDA proposal closed on June 5, 1966 without any adverse consents on the haaleh or safety of PVC. This PDA proceeding lands further support to the inherent safety of human exposure to PVC. PDA regulates the use of PVC in medical davleaa and drug packaging on e caee-by-caee basis. 8-23 ABD00023519 v Community Health Effects of Vinyl Chloride Pegs Eight V. COMMUNITY HEALTH CONCEEMB Aa wee dlecueaed In Section IV, VC Is * very strictly regulated subsfence. The EPA estimated that the 1976 standard would reduce the annuel average exposure of the persons living within 5 miles of VC/PVC facilities by 95% (from 17 ppb to about 0.85 ppb.) An EFA report (1965) states thee current industry performance has resulted in actual emissions that are significantly lass than that predicted amount. Many authors have attempted to develop quantitative risk assessments for low level exposures to VC. (See Barr, 1982 and Purchase, 1985 for review)* Soot have Incorporated human data (Cthrlng, et al, 1979, Anderson* et ai, I960, Purchase, et al, 1985) and only cheee predict resulta which are compatible with the absence of any observed effects on humans from ambient exposures. The remaining estimates all used variations of the EFA upper limit model (Anderson, 1983) and overstate the probability of risk by several orders of siagnltude* There Is no confirmed case on record in which a member of the general population has been harmed by exposure to vinyl chloride. That feet sett the upper limit of lifetime risk at leas chan 0.3 predicted cases of cancer per 1 million for exposure to 1 ppm of VC. Becauee Che date show Chet Industry emissions have been reduced by 99.99% (rather then the 95% estimated by EFA), Che actual risk Is lass than 0.1 case of cancer In the nest 70 years among the 5 million presumed to be exposed to VC from living within 5 miles of a VC/FVC facility. Dr. Richard Wilson of Harvard (1979) has attempted to help people understand this method of stating the risks of every day occurrences* Ecdi of the following activities for example, Is predicted co result In one death per million peopiei smoking 1.4 cigarettes (due to cancer, heart disease)i drinking H liter of wine (due co cirrhosis of the liver)i traveling 6 minutes by canoe, 10 mllea by bicyle, 300 miles by car, or 1,000 milts by Jet (dun to an accldent)i and having one chest X-ray taken in e good hospital (duo to caneer caused by radiation). We conclude, therefore, that there is no basis for concern by persona living near VC-ualng or producing facilities for any health effects from exposure to ambient concentrations of VC now being experienced. 8-24