Document MVyaDEYBDR5xKXno6RrXvYyM

f INTER-OFFICE c. MEMORANDUM Tenneco Chemicals, Inc. TO: Dr . S. R. Sheeran FROM: W. P. Anderson AT: Saddle Brook AT: Saddle Brook SUBJECT: PASADENA PLANT FEBRUARY 26-27, 1974 DATE: March 11 , 1974 COPY TO: D. R. Keck J. F. Kilcullen P. A. Lobo,i /V H. E. O'Connell C. G* Thompson T. T* Zuhl \Jh_^ The following notes cover miscellaneous items of environmental nature dis cussed during the course of my visit to Houston the week of February 25. 1. PASADENA PLANT N.P.D.E.S. PERMIT We have heard nothing further on our application, nor as far as we know, has anyone else on the Ship Channel since a group of permits were issued in July - August 1973. 2. CONSTRUCTION STATUS - PASADENA WASTE TREATMENT PROJECT Our present estimate gives a 50/50 chance of making the June 1 target date. Barring something unforseen, we should not be later than June 15. . 3. TEXAS ENFORCEMENT AGENCIES Although both the Texas Air Quality Board and the Texas Water Quality Board have had rather large turnovers in appointed personnel, it appears that Messrs. Barden and Yantis are still in good standing as executive secretaries of the two Boards, so no major policy shifts are anticipated. 4. AMMONIA IN EFFLUENT We are consistently not meeting the ammonia limits in our T.W.Q.B. permit. The new system may provide enough reduc tion, however, that is questionable. We decided to make an unsolicited progress report to the T.W.Q.B. staff outlining the work being done on this problem. By keeping the staff posted on our activities, we hope to avoid having to appear before the Board to file a formal application for a variance with the accompanying public exposure. TEN 3928 Dr, S. R, Sheeran Pasadena Plant Feb. 26-27, 1974 Page 2 3/11/74 5. PVC PLANT - PERMIT REQUIREMENTS At the time we filed for our T.A.Q.B. permit, engineering was not far enough along to permit including all the details of stack heights, etc. required in the application. Messrs, Churchwell, Hourihan, and I went over the permit application in detail to identify if additional information was required. Mr. Hourihan will furnish these details to Mr. Churchwell for transmission to the T.A.Q.B. staff. I was informed that contracts have been placed for the carbon absorbers on the slurry tank and monomer recovery system vents. After returning here, I learned that there have been some problems in the pilot absorbers. 6. COMPLIANCE WITH T.A.Q.B. REGULATION V - (Hydrocarbon Emission Control) This regulation requires control of hydrocarbon emissions from stationary sources. Three point sources remain: (1) V.C.M. plant vents, (2) Carbon water sump vents, and (3) V.C.M. tank car purges. It is anticipated that the first two will be diverted to existing flares or incinera tors before the 1975 deadline. The last is a very small source and can be reduced still further by modification of unloading practices. 7. G.C.W.D.A. FACILITIES CONTRACT I sat in on a meeting with G.C.W.D.A. to review a first draft of this contract. The only point of disagreement was over who is to operate the secondary plant which will be owned by G.C.W.D.A. The best compromise to avoid split responsibility between primary and secondary treatment phases and to avoid possible prejudice to the tax exempt status of G.C.W.D.A. is for G.C.W.D.A. to operate both sections under contract. 8. E.P.A. OIL SPILL CONTAINMENT AND CONTROL REGULATION I spent some time on this with Jack Adams of Tenneco Inc.'s Industrial Ecology Department. This regulation is vague and we could not come up with any sound guidelines on.applicability or format of plans. We need to get some guidelines out to the plants on this, and I will continue trying to develop some thing useful on the subject. WPArab W. P. Anderson TEN 3929