Document N2x4gg2g9Jwgo2x87DVK3dQNE
TO:
Distribution
Interoffice Communication
FROM: DATE:
SUBJ:
E. R. Taylor August 23, 1989
STATUS ON THE 1987 VCM AUDIT ACTION STEPS
VISTA
The last VCM Plant environmental audit was conducted in 1987. Attached is a brief summary of the action steps resulting from this audit. This information is being submitted for the general records and should serve as a basis for the next audit. Please note many of the responsible party individuals have changed from the original audit progress report.
Let me know if you have any questions.
.104
Attachment
Distribution: R. A. Conrad, D. R. Booth-LCVCM, M. G. Hayes-LCCP T. G. Grumbles, J. C. Ledvina
VVV 000004G56
ACTION STEPS FROM 1987 VCM PLANT ENVIRONMENTAL AUDIT
PRIORITY ITEMS
STATUS
RESPONSIBLE PARTY
1) Handling of coke, heavy ends, and
exchanger bundle cleaning
Done-issued handling procedures
2) Minimization of Incinerator bypasses
ON-GOING
3) Review of labelling, drum specifi
cations for collecting and storing
hazardous waste, and satellite
storage practices
Done issued proce dures , more work is required on satellite storage practices
4) Review of storage and disposal
practices of used oil at the
Ethylene Terminal
Done-used oil is sent to VCM
5) Review of land disposal ban for
Halogenated Organic Compounds and its affects on plant disposal
practices
ON-GOING
6) Retrofilled FCB-contamlnated trans
formers are to be retested for PCBs
for a 90 day period
Done-all trans formers are tested
7) Routine removal and proper handling
procedures for sample bottles of
chlorinated hydrocarbons
Done-part of lab procedures
8) Determination of any air emission
rules apply to the Oxygen Clean Room vapor degreaser
Done-JCL memo
9) Develop a protocol for diesel storage Unwritten procedure
tanks used by contractors to be
to use earthen dikes
in an area where spills can be
controlled
10)
Determination on whether the Lab sump is subject to the underground tank requirements
No-is not subj ect
ID
Louisiana annual fee system for underground storage applicability
Done
12)
Sample of VCM is to be retested for PCBs
ON-GOING
ERI/JGC WPB Fibre Drum Team
EFT/ALB ERT
BF ERT/PLF Houston ERT/HOA
ERT/JCL JRA PLF
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PAGE 2
PRIORITY ITEMS
STATUS
RESPONSIBLE PARTY
13)
VCM leaks detected visually should be Incorporated into the leak detection repair program, added/ deleted valves as a result of project work should be incorporated into the program
14) Obsolete records to be discarded after consultation with Legal
15)
Determined the regulatory status (PCB's) of the transformers at the Ethylene Terminal (GSU owns)
16) VCM sample return system needs to be installed before Nov. 88
17)
Determination and control of EDC losses to the sewer in Blocks I and II
In progress
BJH/APR/SAC
No current time frame
Complete-is not Vista's
SAR/ERT ERT/BF
Done
Plant Engineer
Completed study by the EDC reduction team
EDC Reduction Team
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