Document Lg6Vrwm49JrL82bZLGamVgNg

ABDOO126893 CONDEA Vista Company - Aberdeen Plant Environmental Systems Procedure Manual Environmental Objectives and Targets Procedure 6.2 Particulate Matter Emissions Fiscal Year 1998/99 1999/00 2000/01 2001/02 2002/03 Goal <= 100 TPSI <= 75 TPSI <= 50 TPSI <= 35 TPSI <= 25 TPSI Actual Performance 80 TPSI 80 TPSI (to date) Page 5 of 5 Revision: 8/3/99 ESP-2 7.0 Revision History Description of the Change Revised procedure to conform to QSP-05 Revision 8/3/99 ABDOO126894 CONDEA Vista Company - Aberdeen Plant Environmental Systems Procedure Manual Environmental Objectives and Targets Procedure 25 TPSI or less in FY02/03 Page 4 of 5 Revision: 8/3/99 ESP-2 5.2.5 The Environmental Incident objective and targets shall be achieved through implementation of the Corrective and Preventive Action procedure outlined in QSP-14. 5.2.6 Many steps have been taken by a subteam headed by the Resin Unit Manager to address particulate emissions. For a complete list of the action steps, refer to meeting minutes. 5.2.7 Corrective action shall be issued for each incident found to be a significant contributor to particulate emissions that occurs after May 1, 1999, as specified by the Aberdeen Plant Corrective and Preventive Action Procedure. 5.2.8 A Preventative action request may be issued by any person upon discovery of a reasonable opportunity to reduce particulate emissions. 6.0 Environmental Measures 6.1 Environmental Incidents Incident Number 9798-1 9798-2 9798-3 9798-4 9798-5 9798-6 9798-7 9798-8 9798-9 9798-10 9798-11 9798-12 9798-13 9798-14 9899-1 9899-2 9899-3 9899-4 9899-5 9899-6 9899-7 9899-8 9900-1 Date Description 7/2/97 7/9/97 7/23/97 7/23/97 8/13/97 8/20/97 8/20/97 8/27/97 10/29/97 3/1/98 4/6/98 4/6/98 5/13/98 6/24/98 7/8/98 9/16/99 1/20/99 1/27/99 1/27/99 1/30/99 5/23/99 6/14/99 7/6/99 NPDES DO violation outfall 001 NPDES DO violation outfall 001 NPDES DO violation outfall 001 NPDES temperature violation outfall 001 NPDES DO violation outfall 001 NPDES temperature violation outfall 001 NPDES DO violation outfall 001 NPDES DO violation outfall 001 NPDES BOD daily max violation outfall 001 Wastewater bypass Wastewater bypass VCM release from railcar valve NPDES daily max ammonia violation outfall 001 NPDES temperature violation outfall 001 NPDES temperature violation outfall 001 Wastewater bypass NPDES daily max ammonia violation outfall 001 NPDES daily max ammonia violation outfall 001 NPDES monthly average ammonia violation outfall 001 VCM release from polishing strainer NESHAP 400 ppm daily average exceedence NESHAP 400 ppm daily average exceedence VCM release from sphere ABDOO126895 CONDEA Vista Company - Aberdeen Plant Environmental Systems Procedure Manual Environmental Objectives and Targets Procedure An environmental objective has been achieved. Page 2 of 5 Revision: 8/3/99 ESP-2 4.3 The Management Review Committee or subteams organized for a specific task, shall establish programs for achieving environmental objectives and targets. Such programs shall be defined in this document. 4.4 The need to revise programs for achieving environmental objectives and targets shall be considered by the Management Review Committee or subteams organized for a specific task, whenever any of the following circumstances apply: An environmental target is not, or likely will not be, achieved. An action step is determined to be inadequate or unnecessary to achieve an environmental target. An environmental objective or target is revised. 4.5 Actual performance, relative to environmental objectives and targets, shall be recorded in section 6.0 of this procedure by the Environmental Department. 4.6 Attainment status of environmental objectives, targets and associated action steps shall be reviewed during Management Reviews. 4.7 The Environmental Manager shall communicate the attainment status of environmental objectives and targets quarterly to plant personnel by written and/or electronic communication. 5.0 Goals 5.1 Environmental Incidents Reduction 5.1.1 It is an objective of the Aberdeen plant to reduce the occurrence of Environmental Incidents by 90% relative to the baseline quantity established by paragraph 5.1.3 of this document. 5.1.2 This objective was selected in order to reduce environmental impacts attributable to the following environmental aspects: Hazardous substance releases to air, water and/or land from Aberdeen plant shipping containers Unpermitted hazardous air pollutant emissions to the air from on-site operations Unpermitted pollutant discharges to the Aberdeen POTW and James Creek Chemical emergency incidents at the Aberdeen plant Oil and hazardous substance discharges to the Aberdeen POTW and James Creek and land on-site Community anxiety about chemical emissions from the Aberdeen plant 5.1.3 The baseline quantity of Environmental Incidents is 35 incidents per year. This value is the number of such incidents during FY96/97. 5.1.4 Environmental Incident targets are as follows: 21 or less incidents in FY97/98 5 or less incidents in FY98/99 ABDOO126896 CONDEA Vista Company - Aberdeen Plant Environmental Systems Procedure Manual Environmental Objectives and Targets Procedure 3 or less incidents in FY99/00 3 or less incidents in FY00/01 3 or less incidents in FY01/02 Page 3 of 5 Revision: 8/3/99 ESP-2 5.1.5 The Environmental Incident objective and targets shall be achieved through implementation of the Corrective and Preventive Action procedure outlined in QSP-14. 5.1.6 The following corrective and preventative actions have been taken to prevent recurrence of environmental incidents that occurred during the baseline period: Obtained NPDES permit modification to remove erroneous COD limitation. Maintain inventory of hydrogen peroxide to be used in the event of low dissolved oxygen content of effluent Installed filters and pit covers to reduce suspended solids in stormwater pit effluent. Reworked baghouses on storage silos to reduce suspended solids in stormwater effluent Established procedure to route centrate water through cooling towers to reduce effluent temperature Conducted study of firewater system and installed hardware to require manual selection of wastewater as firewater to eliminate unnecessary wastewater bypasses. Installed additional aeration to lower effluent ammonia concentrations. Removed process outfall from James Creek to Aberdeen POTW to reduce impact on James Creek 5.1.7 Corrective action shall be issued for each environmental incident that occurs after May 1, 1999, as specified by the Aberdeen Plant Corrective and Preventive Action Procedure, QSP-14. 5.1.8 Preventative action request may be issued by any person upon discovery of a condition that could potentially cause an environmental incident. 5.2 Particulate Matter Emission Reduction 5.2.1 It is an objective of the Aberdeen plant to reduce particulate emissions by 90% relative to the baseline quantity established by paragraph 5.2.3 of this document. 5.2.2 This objective was selected in order to reduce environmental impacts attributable to the following environmental aspects: Particulate Matter (PM) emissions to the air from on-site operations 5.2.3 The baseline quantity of particulate emissions is 250 total particles per sq. inch (TPSI) as found on the monitoring stands. Reductions in particulate emissions shall be determined relative to this baseline quantity. 5.2.4 Particulate Matter emissions reduction targets are as follows: 100 TPSI or less in FY98/99 75 TPSI or less in FY99/00 50 TPSI or less in FY00/01 35 TPSI or less in FY01/02 ABDOO126897 CONDEA Vista Company - Aberdeen Plant Environmenta! Systems Procedure Manual Environmental Objectives and Targets Procedure Page 1 of 5 Revision: 8/3/99 ESP-2 Approved by: Environmental Manager ____ Date: 1.0 Purpose and Scope This document establishes environmental objectives and targets for the Aberdeen plant, programs for achieving the objectives and targets, and procedures for establishing, reviewing and revising the objectives, targets and programs. 2.0 Responsibility The Environmental Manager is responsible for reviewing and approving this procedure. 3.0 Definitions Particulate Matter Emissions - The release (stack or fugitive) of solid particles from the process to the atmosphere. Of primary concern are visible particles (primarily PVC) that cause public nuisance. Environmenta/ /ncfdent - An incident that meets any of the following criteria: A extremely hazardous substance release that is reportable under 40 CFR Part 355. Release of 5,000 pounds or more of a 112r flammable substance. An exceedance of an NPDES or Aberdeen City wastewater discharge permit limitation, or a failure to conduct discharge monitoring that is required by such permits. An exceedance of a Vinyl Chloride NESHAP limitation or standard. An event requiring evacuation or shelter-in-place of the community. Clean-up activity beyond fenceline. 4.0 Procedure for Establishment, Revision, and Review of Environmental Objectives. Targets and Associated Action Steps 4.1 The Management Review Committee shall establish environmental objectives and targets, giving consideration to legal and other requirements, significant environmental aspects, technical and economical feasibility and the views of interested parties. Such objectives and targets shall be consistent with the CVC SHE policy, and shall be defined in this document. 4.2 The need to revise environmental objectives and targets shall be considered by the Management Review Committee whenever any of the following circumstances apply: New or modified activities occur that substantially change the environmental impact of Aberdeen plant activities, products or services. The environmental impact of an environmental aspect is determined to be substantially different than previously determined. There is a substantial change in legal or other requirements, technical or economic feasibility, or the views of interested parties that relates to a significant environmental aspect or environmental objective.