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MM inter office memo TENNECO CHEMICALS, INC. TO From Subject J. T. Sweeney G. I. Rozand VCM MONITORING DATA 10/30 - 11/5 AT Flemington AT Piscataway date copy to November 18, 1976 d . Bord W. R. FogeIsanger W. F. Gabel The weekly data submitted for the above period dramatically highlights the kind of problems that have been apparent at Flemington for the last two weeks. Levels averaged 2.2 in the reactor room and 19 in the recovery room. Moreover, you had 73 excursions greater than 25 in the reactor building and 52 excursions greater than 25 in the recovery room. If our definition of a leak for EPA consideration is accepted at 25, your operation is generating far too many leaks! It is assumed that our leak detection program will be operational on January 19, 1977. Plan for increased maintenance in the recovery area and we will expedite installation of reactor opening CAR. You will be plagued with having to deal with these leaks for EPA, much more so than you have been concerned as far as OSHA is involved. No longer can we ignore the levels above 25 ppm because no personnel are exposed! EPA demands your attention and remedy regardless of personnel exposure, as you know. My understanding is that the VCM weekly data for the next reporting period shows a reactor level at 1, which of course is more in line with norm. ,, ~"s /! GIR:tm Gordon . Rozand 009991 * QO-H 64 ( 1 1" 3) TENNECO INTER-* FFICE MEMO CHEMICALS, INC. To J, T. Sweeney At Flemington date December 27, 1976 From R. A. Lojewski AT Flemington Subject VCM Exposure Data and TWA - Flemington Plant Area Monitoring System Period: December 11, 1976 to December 17, 1976 Copy to W, D. Bord C. N, Brown* R F, Fanter W,, R, Fogelsanger W,, F,, Gabel D, M, Hershkowitz F, W, Kanzler W. Miringoff P. M. Reed S. Robbins Mo K, Rosen G I. Rozand F. Toca Re J. Young TWA Only* Attached are Plant summaries (Tables I-III). Table IV lists all excursions at or above 100 ppm including the number of incidents. Table V shows the TWA by job classification calculated from the data in Tables I-III. Graph #1 shows the percentage of readings above 1 and 5 ppm VCM for the Reactor Building while Graph #2 shows the weekly averages for the Reactor Building and the Pilot Plant. This report period there will not be an analysis of the Plant data by W. D. Bord due to him being on vacation. The Plant was in operation seven days for this report period running at about 81% utilization. The four G.C.'s were on computer control. Area Reactor Building Recovery Comp. Room Pilot Plant General Area Parshall Flume Total 10,991 1,374 4,662 6,871 666 >1 N% 4121 1357 739 205 66 37 99 16 3 10 >5 N% >25 N1 >100 N% 847 8 106 1198 87 123 16 0.3 1 17 0.2 1 3 0.5 0 1 9 0.02 0.01 0 4 7 0 1 0 0.04 0.5 0 0.01 0 All readings greater than or equal to 100 ppm VCM are tabulated in Table IV. Twelve readings at or above 100 ppm occurred this report period reflecting seven separate incidents. Three incidents occurred in the Reactor Building affecting the center aisle 1st floor, VCM day tank area and the stairwell in hallway 2nd floor. Four incidents occurred in the Recovery Compressor Room affecting #1 and #2 recovery system. One incident occurred in the General Area affecting the VCM transfer pumps in the tank farm. No incidents occurred in the Pilot Plant during this report period. RALrms /f7 A. R. A. Xojewski^ 000936