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 vvv 000004057 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 VVV 000004058