Document kJng18bpRQmDoDMgyj3rRZ6B
!
B F GOODRICH CHEMICAL DIVISION
PEDRlCKTOWN PLANT
MARCH, 1979
\ 30 1379
ENVIRONMENTAL STATUS REPORT
Distribution
Environmental Committee
Ji A. Kiel J. P. Moran C. E. McCann C. G. Hertz K. L. Blanton K. A. Jeffers J. M. GlIckman
Pedrt cktown
C. J. Nosal V/. A- Reed J. M. Smith B.A. PrusSnoskl J. M. Fletcher T. S. Nasife J. W. Goetsch
Cl eve I and
W. C. Holbrook J. D. Fannin
U. Lew!s
N. R. Aquino" A. W. Clements W. E. Horton G. F. Krcmar
c. Reid R. D. Hardesty - M. D. Rider C. B. Bened1ct C. E. Titus C. J. Orsborn R. W. Bl rch R. G. Saunders L. Levi J. W. Robben K. D. .Konter
- Niagara Falls ALTC AL'GdP Akron Brecksville, Calvert City Long Beach
Orange Port Neches Louisville Henry
NGC 15015
INDEX
1. Environment Committee Meeting Report 2. EPA - OSHA Goals
(a) Mass Resin - Personnel Monitoring VCM _ Cb) Mass Resin - Building Levels VCM
(c) Suspension/Dispersion - Personnel Monitoring VCM (d) Suspension/Dispersion - Building Levels VCM (e) Latex - Personnel Monitoring AN (f) Compound - Personnel Monitoring Toxic Dusts (g) Compound - Personnel Monitoring Noise 3. EPA - NESHAP VCL Compliance l|. Waste Water Treatment System Data Analysis 5 March Progress Report
NGC l5016
i
subject"
COMPANY _M E.ETJ N CLBEPO RI
n
March - Environmental Comml ttee-_Meet.i ng
OUTSIOE ORGANIZATK7N INVOLVED
Page 1
Q A T E.
I___ VJ9/79
\ i
MEETING PEACE
~
Pedrlcktown
B FG PARTICIPANTS
J.W. Goetsch J.M. Gllckman K.A. Jeffers J.A. Kiel C.E. McCann J .P.- Moran W.A. Reed
T.O. Rings C.J. Nosal
OTHER PARTICIPANTS (NO DISTRIBUTION!
MEE TING C AT r
A/10/79
ADDITIONAL COPIES TO C.T.F.
RESULTS AND COMMITMENTS:
RPEERSSPOONNSIBLE;
1. RevIewedJStatus of 1979 Established EPA-OSHA
ENV
GoaIs:
DEPT
Graphs reviewed are attached for the following areas. A. Mass resin B. Suspension/Dispersion resin
C. Latex D. Compound
r The following was noted; A. Mass resin personnel monitoring results dropped down below the goal of 0,A ppm. One key area currently under Investigation Is the necessity to swing the autoclave hammer blind for every charge. This operation frequently results In minor VCM leaks which have been detected by both personnel monitoring and building monitoring
systems.
B. Suspension/dispersion building monitoring VC1 results were higher iJthan acual in the earlier part of the month. The calibration -problem was finally resolved around mid month.
C. AN personnel monitoring results for regulated tasks show a slight Increase;however, they are well within the 2 ppm permlssable level and ! ppm action levels. The training slide program currently being prepared by corporate should be available by May.
r*
D. Toxic dust monitoring analysis is now being received on a monthly basis from Brecksville. Current task monitoring results indicate we still have occasional exposures'to lead In excess of -200 Ag/m . Compound Is currently experiment4ng with teflon coated
^lead stabllzers.
E. Current dosimeter readings In the compound cuber area are primarily below 90 dbA when the secondary air blaster Is off.
HEPORTED BY
J.A.
BFO'10309 5/7!
Kiel/re
---------------------------
_____________________
~
NGC 15017 ...
________________ __________:
' PRINTEolig iJ.S.A-
Page 2
2. Overall Status for EPA-NESHAP VC1 Compliance Program:
KAJeffers
EPA-VCl attainment chart attached
EPA-NESHAP VC1 attainment has been excellent. The only non attainments reported In March were 3 hours on the Vent Gas Absorber and 1 Mass reactor opening.
The status on current major projects Is as follows:
A. Vent Gas Absorber backup incinerator. Incinerator on order with completion slated for August, 1979
B. Vent Gas Absorber corrosion control - drying and neutralization of the feed stream were found to be necessary in order to minimize corrosions. A temporary caustic scrubber Is currently installed and It is felt that corrosion has been tremendously reduced. Investigation on a type of drier' system continues.
C. Wastewater stripper: Backup system currently being Installed.
3. Complaints and Unusual Releases to the Environment:
A. Five complaints were received in March, 1. 3/13/79 " Mr. Shoemaker - odor 2. 3/25/79 - Mr. Gross - PVC dust 3. 3/27/79 - R.R. - EA odor 4. 3/31/79 - Mrs. Shoemaker - PVC dust and odor 5* 3/31/79 " Mrs. Alloway - PVC dust and odor
There were no unusual discharges reported to the NJOEP during the month of March. After an lnvestlagtlon of each of the complaints, It was felt that no significant amount of material. If any, left the plant site. The EA odor complaint reported by the RR was the result of a leaking bottom valve on a full EA car. The plant Is currently formulating a series of projects which will minimize or reduce current nuisance dusting sources.
One EPA reportable unusual release to the environment occurred In March. On 3/20/79, the rupture disc on a stripper vessel in the dispersion resin manufacturing area failed.
C. Four unusual releases were acknowledged during the month, AH were of a relatively minor nature.
A. Training Topic
The plant neighbor complaint procedure was reviewed In detail. Each manufacturing area was^requested to update their surveillance check sheet If necessary. The procedure will be up dated and re-lssued as soon as all manufacturing input Is received.
NGC 15018
Page 3 5. Pertinent Topics of Interest
A. Con-Nosal re-emphasized the importance of a plant wide environmental awareness program. Prevention of unusual discharges (specifically VC1) should take top priority over everything else except for personal safety. Isolation of sources of unusual discharges and appropriate clean up procedures should also take extremely high priority.
B. A plant environmental surveillance will be conducted by .corporate on May 3rd and Ath.
C. USEPA Clean Air Act proposed enforcement regulations and appropriate fine schedule was reviewed.
NOC 15019
VCM ppm
PERSONAL MONITORING RESULTS VINYL CHLORIDE
MASS RESIN POLYMERIZATION - BLDG, 512
Page h
No.
Samples N0-O.5
14 10
0.5^ No.^1,0 3
Range Average ppm No > 1.0 ppm Month YTD
1 *03-1.31 0.36 0.64
*S1.0 ppm Month YTD
92.9 85.0
NGC 15020
PERCENT OF READINGS
Page 5
BUILDING MONITORING RESULTS
VINYL CHLORIDE
MASS RESIN POLYMERIZATION - BLDG 512
100 _j
90
1 GOAL 37% < 1 ppm
80
70
60 < 1 ppm
50 -- 1-5 ppm 40 ~ ^ 5 ppm 30 20
10 -- ----- : ~ -- - -- -----
0 ----- -- j 76 77 78 J F M
-
*
MONTHLY
YEAR TO
AVERAGE
DATE
< 1 ppm
90.7
1-5 ppm
8.0
5"100 ppm
1,2
S'
^100 ppm
0,3
average ppm * In building
1.3
91.4 7.2 1.3 0,3 3.3
NGC
Average ppm In building Is calculated using the following assumptions: any point less than 1 ppm !=0.5 ppm, any point between 1 and 5 ppm = 2.5 ppm, any point between .5 and 100 ppm = 15 ppm, and any point greater than 100 ppm = 500 ppm. These assumptions are based on actual levels for a one week period.
PERSONAL MONITORING RESULTS r ' VINYL CHLORIDE
SUSPENSION/DISPERSION POLYMERIZATION - BLDG. 513
No.
Samples No-0.5 0.5^ Nc\^l .0
13 8
3
Range Average ppm %<1 .0 ppm ppm . Month YTD Month YTP
2 .03-3.16 0.63 0.65 84.6 74.6
NQC 15022
Page 7
BUILDING MONITORING RESULTS vinyl'chloride
SUSPENSION/DISPERSION POLYMERIZATION - BLDG 513
1 uu
1-
30 1
------} \ 80
SI
-- ---
------
-
GOAL 35% <
PERCENT OF READINGS
^<zjj 70
< 60 lcxC!
-------- - < 1 ppm
0 50
----------1 1-5 ppm
11 *>0 CCL UJ
30
---
--
--
---- -- - --
* ^ 5 ppm
\----20 \
------ --V\
10 -------* s.
0r
4X f -\
-J---------
f
--
*
76 77 78 J F M A M J J A S 0 N D
< 1 ppm
1-5 ppm
5-100 ppm
^100 ppm average ppm * in building
MONTHLY AVERAGE
73.5 17.6
2.6 0.A 3,2
YEAR TO DATE
79.0 17.9
2.8
0.3 2.6
* Average ppm In building is calculated using the following assumptions:
any point less than 1 ppm = 0.5 ppm, any point between 1 and 5 ppm "
2.5 ppm, any point between 5 and 100 ppm 15 ppm, and any point greater
than 100 ppm - 500 ppm. These assumptions are based on actual levels for
a one week period.
tfGC 15023
PERSONAL MONITORING RESULTS ACRYLONITRILE
Page 8
No. Samples
eg *
4
^on-Reg o> 4
Noil.O 3 4
1979
Ra nge 1.0CNo<2.0 No>2.0 ppm
1 0-1.07 0*0
Average ppm'%^2.0 ppm Month -YTP Month YTD
0*32 0,00
0.22 0.08
100 100
100 100
NGC 15024
PERSONNEL HON 1 TOR 1NG RESULTS NOISE
COMPOUND MILL AREA - Bldg 54l
Page 9
%
S. 90dBA
No, Samples
#90dBA 3
% < 90dBA
Month
YTD
23,b
29,6
The data presented here reflects the evaluation of severe! procedures
and controls. 9*
.'
NGC 15025
PERSONNEL MONITORING RESULTS LEAD
Page 10
Pb A a/m3
OSHA STANDARD
No, S^n)ples 5
Average TtsAf3
.Month.
YTO
302 258
-200* gA)3
Month YTD
60.0 55.6
5*
NGC 15026
EPA VCl ATTAINMENT
Page 13
1. Reactor Opening
Pearl No. of non-attainments No. of openings % attainment
Paste No. of non-attainments No. of openings 3 attainment
Mass No, of r^on-attalnments No. of openings % attainment
MARCH 1379
SEMI-ANNUAL REPORT TO DATE
10/21/78
to 2/28/79
o 49 100 %
q
207 100 %
1 227 99.6 %
o 49 100 %
0 207 100 %
16 227 93.0 %
64 792 91.9 %
1
227
99.6 X
8
1125 99.3 %
2. Resin Stripping - Pearl - X attainment Paste - % attainment Mass - % attainment
3. Vent Absorber % attainment
4. Wastewater Stripper % attainment
100 % ' 100 %
100 %
99.6 %
100 %
100 ^ 100 % 100 ^
99-6 %
100 %
99.2 % 96.8 % 90.9 %
96.4 %
91.8 %
NGC 15027
DATE: MARCH, t973
WASTE TREATMENT
TS (ppm)
DS (ppm)
Influent
Primary Effluent
Secondary' Effluent
1900
+1 1135
869 1105
1136
1096
S5 (ppm) 1031
30
ko
VSS (ppm)
COD (mg/1)
934 | 858
BODe (mg/1)
1 192
pH | 9,6
PO4 (ppm)
|-
NH3 (ppm)
|-
' 21 229 144 6.5 1.6 4.7
29 48
-
6.8
0,19
1.1
TURB ( JTU)
COLOR (APHA)
TEMP. (F)
-
Laeoon Activated
Sludee
Calculations
1099 1067
32 21
40
6 7.2
-
Sanitary
(SS)
(VSS)
. 500
384
(Cl)
6.1
Plow (MM) `(EPF) (Reuse) (Total)
12.5 4.5
17.0
Industrial
(MLSS (MLVSS), (DO)
2137 1659 Sludge
5.5
Prim, Iliickenl^isPosal>
% % I(Lbs. Dry)
1.0 7.8 1 213.034
(r
(Inf)
0.22
(SV) I (SVI) 211 98
BOD/COD (Prim) (Lagoon) 0.63 0.15
(F) 78
(SS) 97
81 61
( RSS) 6036
(RVSS) 4618
% Removal
(COD)
(BOD)
95 97
.
WATER TREATMENT
TS (ppm)
DS (ppm)
SS (ppm)
VSS (ppra)
COD (mg/1)
PO4 (ppm)
Recycle Reuse Potable Clarified
--
924 898
--
27 19
-
-
-
pH Fe
Cl
TURB
COLOR TEMP.
(ppm) (ppra) (JTU)
(APHA)
(F)
4,7
7.2 1 .0
0.86
56
7-0 1.8
-
64
TO W.A.
FROM
Reed
" J.A. Kiel SUBJECT
^
MARCH PROGRESS REPORT
FIELD POINT OR DEPT. & BLDG. NO. FIELD POINT OR DEPT. & BLDG. NO.
J. w 4'-.
DATE YOUR LETTER
DATE THIS LETTER 3/28/79
Significant Accomplishments
1. The EPA-NESHAP VCl semi-annual report was prepared, reviewed, and presented to USEPA-Reg Ion II on 3/1V79-
2. A one year extension from 3/18/79 to 3/18/80 of our current OSHA Noise Citation in the compound cuber area was requested and granted on 3/13/79*
3. Prepared fHS on proposed large poly expansion,
k. Implemented spill control and counter-measure plan tsecondary containment systems), throughout plant. Specific plans reviewed with Latex and Mass. Plans to be reviewed with Compound, and Pearl/Paste in April. Engineering to prepare plot plan maps which will be posted throughout the plant.
General Information1 2 3 * 5
1. Issued monthly environmental committee meeting minutes and environmental status report.
2. EPA-NESHAP VCl compliance for the month of March has been very good.
3. Prepared NJDEP permit for relocated styrene storage tank. Currently preparing permit for DM water degassifler and VGA backup Incinerator.
k. Held meeting on compound noise citation and developed action plan to Implement and evaluate a series of both engineering and administrative controls.
5. Developed a series of specific departmental goals and also prioritized the departmental backlog of Safety, Housekeeping, and operational projects. The environmental departmental members plan to take a more active role In the design engineering aspects of the departments operational responsibilities In the future.
Active Projects
l. Developing a plan to clearly define level of VCM Fugitive Emissions In PVC polymer!za-tlon areas. Also developing a specific list of projeats which haye reduced fugitive emission levels to 20% of EPA's projections.
2. Providing process engineering input on VGA backup Incinerator, Incinerator Is on order and is projected for delivery in May,
3. Preparing Inventory of all drummed materials in the plant. All material will either be worked away to waste treatment, disposed of at an acceptable environmental facility or be stored In an appropriate location.
Bfc-45f,-D ii/77 li-hci ,:5A
cc:
K.A. Jeffers
J.M, G1 (ckman
W.A. Reed
E.J, Clegg C.J. Nosal
NGC 15029
4. Completed or developed plans for completion of all OSHA Acrylonitrile standard related projects. Compliance In this area remains excellent.
Operational
1. Ach!eved1,exceeds requirements*1 rating In ail areas of March Safety and Housekeeping Inspection.
2. Developed and Implemented plan to control waste activated sludge based on sludge age. This control parameter was recommended by Cleveland and appears to be effective thus far.
3. Started training Dick Green, new environmental technician on 3/29/79
4. Completed monitoring well testing for waste chemical processing and treatment facility.
Goals
1. Complete and submit to NJDEP Air pollution permit applications for styrene tank JMG/KAJ
relocation, geon latex storage, degassifier vacuum pump. Incinerator,
JAK
NBA storage tank, and 7 proposed new PVC resin baghouses.
2. Complete drum Inventory and disposal recommendations and future storage area designations.
KAJ
3. Complete implementation of spill control plan and develop PM program. Finalize format for NJDEP plan and review with Cleveland.
KAJ/EC
4. Review departmental goals with W. Reed
JAK
5. Issue OSHA personal monitoring 1978 summary to all monitored personnel.
JMG
15030
tfGC