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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VI
1201 ELM STREET DALLAS, TEXAS 75270
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PLAINTIFF'S EXHIBIT
SEP 1 0 1979
Mr. R. V. Mattern, Superintendent Environmental Conservation Shell Chemical Company Post Office Box 2633 Deer Park, Texas 77536
Dear Mr. Mattern:
RE: Request For EPA Inspection Report
Enclosed is a copy of the EPA air inspection report you requested.
Please note that certain information (i.e., company drawings, letters, and state emission inventories) originally supplied by your company to the inspector have not been included, since it is assumed this information is already in
your possession.
If you have any questions please call me at (214) 767-2755. My apologies for the delay in responding to your request.
Sincerely yours,
SH-2412
John R. Hepola Chief, Engineering Section Air Compliance Branch
ORH/lbs
Enclosure
EN V1R0NMENTAL
-Y 7-/3-^ ...
RETURN TO EVC FILE -COPY IN VC FILE
FOR EVC INFO ONLY con ert/f. cutr CMC.
"
DPMC-09109
LAM 002998
) .
INFORMATION CHECKLIP
1. Date of Inspection: OctoDer 121 1973________
and October 20, 1978 Time in 9*30 Time Out 3iOO
2. Name of Inspectors: 1^a^P..J,.lolwoa---------
3. Time In:
-^n.oo
Time Out: 12:30
2a. Confidentiality Statement given toi Chunk Rivero 4. Persons contacted during plant inspection:
Chur^V
Senior Staff Engineer, Environmental Reg3.
Dick Slyker Senior .Environmental Engineer
Phil S'chwin Manager Environmental Operations
5. Name and mailing address of facility: Shell Chemical Co. Deer Park Manufacturing Comnlex
P. 0. Box 2633 Deer Park. TX 77516
6. location of facility (include county osr parish) ;
Off Hwy. 22$ in Deer Park, TX Harris "County .
____________
7. Number of Air Quality Control Region: (AQCR) 2l6
.8 Name and title of person responsible for facility:
Address:
R. G. Dillard. General Manager,
Shell Chemical Co. Deer Park ftanul'actaring Complex P. 0. Box 2633
Deer Park, TX 77536
Telephone No. : ' 713-U76-U371
DPMC-09110
LAM 002999
9. Name and title u person responsible for environmental matters:
Address
ft* Mattern, Sunt, . Environmental Conserve f^nn
Shell Chemical Co.
Deer Park Manufacturing Comnlex P._0. Box 26^3 Deer Pgrk-j TT 7753A
Telephone No.t: .7l3-k7^k37l-
10-
Name and address of corporate president or chief executive officer:
John Bookrot-President
Shell Oil Co.
1 Shell Flaza, Houston, TX
11- State of Incorporation:
OaI wow__________________
12-
Describe ownership and corporate structure: Stock Como any
13- Were any. processes or units not in normal operation during
inspection? ye3___________
t
If yes, explain- 0?2. ethvlen'e products, and VCM were down. EPU was down for good.
14-
Describe and give dates of any process changes or modifications and any new construction since August 1971- Describe and give dates for any process changes or modifications and any new con struction which are planned for the facility.
See Attachments (l)j' (2)
DPMC-09111
LAM 003000
15. Plant Process
..
a. In addition to your impressions of how the facility is
operating, describe all processes at the facility and in
clude the following information See
Trocess
* Data sheets of E.I.Q. 1) Emission points of each unit in each process (include fugitive sources) . See Process Data Sheets of E.I.Q.
2) Operating schedule (describe any seasonal or other
operational variations) .See pqge 1 of E.I.q.
3) Schematic drawing of the various processes^ including
control equipment and emission points. See,(Process Data 4) Describe allsfefii%S5.^n^pontrol equipment and which
unit or process emission it controls. Sef^rocess Datasheet
...........5)
If any unit is a combustion unit, include the followii heat, sulfur, and ash content of each fuel burned; average and maximum amount of each fuel burned per hoi and the design capacity of unit. See E.l.Q.^'cover memo
6) \
Attachments (2),(3)
If any uint is an incinerator, include the type of wa burned, the design and actual burning rate, the numbe: of combustion chambers, and the temperature in the secondary combustion chamber. See E.I.Q., cover memo, and
7) If the facility is a pulp and paper mill, include the average dry solids content and average density of the
...........................
. .spent liquor entering each recovery furnace.
b. Production and Emission Data
. 1) Products, Process
including intermediates.
H6urly
Product
Design
Production Rates Average . Maximum
See Process Data sheets of E.I.Q.
2) Raw Material Rates.
. ' Process or Unit .
Feed Material
*_ X'See Process Data Sheets*of E.I.Q.
Consumption Rates Average . Maximum
LAM 003001
DPMC-09112
3) Flue C v low Rate.
Process or Unit:
Emission Point
Flue Gas Exit Rate
Average
Maximum
See Stream Composition and Stack Data Sheets of E.I.Q.
.
V
4) Stack Height and Diameter.
Process or Unit?
Emission Point
See Stream Composition and Stack Data sheets ii^S.I.Q.
Stack Height
Stack Diameter
5) Pollutant Emission Bates.
Process Emission
Emission
Rates
or Unit Point
Pollutant Averaqe Maximum
See Stream Composition and STack Data sheets in E.X,.3.
Method Determined
n See Attachment(L) for undate of emission rates to year 1977. All source #'s
16.
not listed in Attachment (u) are zero 3ince thejr are" now going to flares. Complete hydrocarbon checklist if facility is located in
Louisiana, A*QCR*s 184 and 186 in Oklahoma, and the following
counties in Texas: Aransas, Bexar, Brazoria, Calhoun, Dallas.
El Paso, Galveston, Bardin, Harris, Jefferson, Matagorda,
Montgomery, Nueces, Orange, San Patricio, Tarrant, Travis and
Victoria.
.
*
17.
Are any of the following materials used or produced at this
facilitys Asbestos, Beryllium, mercury, vinyl chloride, or polyvinyl chloride? If so, explain fully.)Vinyi chloride is
nroduced at this facility &Ut kent in a '* closed-system". VCM loading facilities have monitors that check for 0.5 bpm VCM in the atmosphere..
__
t
(4/ Asbestos is. used for insulation and in*the CAU Unit in the chloroaldehyde
membrane of an electrolytic process. jl**-
$S
._ . ------------------------------------------
(j) Hg is used in the lab as well
manometric purposes.
*
.
LAM 003002
DPMC-09113
age
No.
4.
H' OCARBON CHtCKllSl
This checklist snould be filled out only for hydrocarbons with with vapor pressures greater than 1.5 psia at storage conditions,
.
Capacity _______(units)
Type*1*
Product Stored
: rapurrressu* e
Storage
(Units)
Tomp
1 Vapor (2)
Pnn tr^nl c
Ppmar't'c
-
1500 gals 500 gal3
300 gals
unleaded gasoline
leaded gasoline
leaded ~ gasoline
*
> 1.5
i;5
i.5
! ambient
.; ambient
amoient -
submerged f .11 vanor *re cove v
b) o foC- ' f Afcan'V'
3UDmerged fi vanor recove: v
9
S . ...E.T.(p p_______________
,
anH
i+.+.a hrr'ont. (1 )
C
ai-ln'i+.-< <-vna1
*
%
.
.
.*
1-
-
'
-
* >"
-
-
* `
-
*
*
,,*
8
\
-
tnotes -
(1) C = fixed roof; F = floating roof; P = pressure; 0 - open top;
. S = spheroid; H = horizontal; U = underground
*
*(2) N = none, CY = conservation vents; F = floating roof (SS .** single seal; DS= dou!
seal); VR = Vapor recovery (describe) VD = vapor disposal (describe); VB = vapo
balance; SF = submerged fill *
*1
.
DPMC-09114
---------------------
LAM 003003
Are there loading facilities for volatile hydrocarbons? yes , 6 of them
*
If yes, obtain answers to following: ^or an3wers 3ee leading and Unloading J ^ sheets of E.I.Q.
* a. What products are loaded?
See fe.T.l.:
b. What is the vapor pressure of the products under actual stora
conditions?
_
See E.I.Q.
c. Are the loading facilities- equipped with a vapor collection a disposal system? Describe. some are, some aren*t
d. What are the capacities of the trucks, tank cars or trailers
loaded?
trucks 000 to 3000 galsl rail cars 10,00(jto 30,000 gals.
e. What is the through- put per day-of the loading facilities,
averaged over 30 days?
See E.I.Q. ______________________________________
. Aire provisions made to prevent spills during the attachment disconnection of filling lines? Describe. yeg
p icKyp sumn collection systemsj from which tank truck ^umr it uo and t.-aVp
!Trlaj1. " lnclnerawrs- AU line, and vaK,r recovery hoses on. blevn vitn N2 before disconnecting and purged to condensers.
DPMC-09115
LAM 003004
Are there water separat rs at this facility? yi. If yes, obtain answers to followingi
a.- What hydrocarbons are separated? cracked oil from Ethylene Unit, Aromatics, gas nil, and lub oil.
b. What is the vapor pressure of the hydrocarbons separated? in the neighborhood of l.g paia.
c. How many'gallons of hydrocarbons enter the water separator per day??
d. Is the separator equipped with a vapor loss control device? Describe. Ie3 a concrete slab is over API Oil Sererator.
Pumps and Compressors
Are pumps and compressors handling, volatile hydrocarbons, equipped with
mechanical seals or equivalent?. Most but not all. Some oumns still have racking
glands.
*
'
lam 003005
DPMC-09116
Waste,Gas Disposal
Are there any ethylene emissions from the facility? yes
If yes, obtain answers to following:
a. Will the ethylene stream support combustion without use of
auxiliary fuel?
no
b. Are the ethylene emissions burned in a direct--flame afterburne or an equally effective device? ye3
If yes, what is the combustion temperature and retention time?
?
Organic Solvents
*Vre there any organic solvent emissions from the facility? vea
If yes, obtain answers to following:
a. What organic solvents are emitted? ketone, methyl ethyl
________
See nainting section^f^I*soDutinol, methanol, caroinol, isonronyl ether, and ethanol.
b. What is the maximum amount of organic solvents emitted per hour
See E.I.Q. How determined?
________Quantify used x solvent t-jJt x #/gal < 2000 #/ton
c,, What is the maximum amount of organic solvents emitted per day?
See E.I.Q.
.
How determined?
LAM 003006
DPMC-09117
. 'd. Are the emiss; is controlled? yes,no
-escribe. Chilled water
condensers, scruDoers, vents to incinerators and flares, floating roofs, recycle
recovery systems, and refrigerated condensers.
Flares
Are flares utilized at this facility? ye3 7 . 0f them
If yes, obtain answers to followings
a. How many flares are used and to what processes are they
..connected?
e.
Ground flare, 0P2, 0?3, AMS, HIPA, GNECE flares. 0P2 flare is connected to the 0P2 Olefins Process. 0F3 flare is connected to the 0P3 Olefins ^recess.
Gxpunci Level laEL.f.s. connected.to ..the 03 Process ,-HIP-A Flare is connected -to-------A Sovenet Process, VCM Process, and Glycerine and Assoc. Products Process, ANS Flare is connected to the VCM Process, A Solvent Process, G Solvent Process.
GNECE Flare is connected to the VC Unit and Glycerine and Assoc. Products Proce3. EPHlar-a-is conneoted-tO the Ethanol Facility and Geroitol-Uni-t. It was connected"^ the Ethylene Production Unit but it was Permanently shut down on 10/20/73. b. Do the flares ever "smoTce"? yes Describe.
They smoke -when not enough steam is applied and in an emergency. >
c. Describe the flare.*- Mostly John Zink. All have smokeless Rated Capacity
LAM 003007
DPMC-09118
Shell Oil Company Shell Chemical Company
A Division of Shell Oil Company
Deer Park Manufacturing Complex P.O. Box 100
Deer Park, TX 77536
August 1, 1985
Ms. Vicky Wang ; Texas Air Control Board 5555 West Loop, Suite 300 Bellaire, Texas 77401
Dear Ms. Wang:
Attached please find copies of our 1984 Asbestos Report and a permit for our fire training grounds, which you requested as part of your annual refinery inspection.
If further information is needed, please call me at 476-7515.
Very truly yours.
be: EGB Satellite Env. Con. Chron (2)
KAS roc
DPMC-09119
LAM 003009