Document np0ev8JjY5ZxX8ERMoDzpBExw

Tenneco Chemicals A Tennew Company P.O Box 116 Burlington. New Jersey 03016 <609) 366-SOOO RETURN RtCtin Kr-UL'LSThU Organics 2nd Polymers Division February 2, 1979 Hr. Eckardt C. Beck Regional Administrator 1). S. Environmental Protection Agency Region 11 26 Federal Plaza New York, New York 10007 Dear Mr. Beck: This is to advise you of a relief valve discharge which occurred at our Burlington Plant on January 24, 1979 (7:15 P.M. - 7:30 P.N.). This was the result of a restriction at the condenser. The 2nd stage relief valve on tf3 recovery compressor lifted and was open for 15 minutes. This problem was detected by our Bendix continuous monitoring system and promptly corrected. Based on the relief valve setting (120 psi) and the system compressor capacity, it is estimated that the vinyl chloride loss was 525 pounds (15 minutes <? 35 lbs./minute). Even though our routine pressure gauge inspection procedures were in effect, this pluggage occurred too quickly to be detected. The pluggage was cleaned immediately, and then the system was checked and found to be operating normally. Very truly yours, TENNECO CHEMICALS R. K. Neugold V'orks Manager RKN:pjd cc: Hr. Harcus Kantz be: Hr. V. P. Anderson Mr. C. S. Flint/Mr. P. T. O'Brien Mr. F. S. Klopp Mr. R. H. Mathis Jtr. J. P. Sandstedt j *.v*.v u- r t>i COLORITE ** /e /*ir*\ 019409 Tenneco Chemicals A Tenneco Company P.0 Bo* 116 Burlington New Jersey 08016 (609) 386-9900 k^.uii JVU n/UL f / / J/ JJ return receipt requested Organics and Polymers Division January 29, 1979 Mr. Eckardt C. Beck Regional Administrator U. S. Environmental Protection Agency Region II 26 Federal Plaza New York, New York 10007 Dear Mr. Beck: This is to advise you of a relief valve discharge which occurred at our Burlington Plant on January 21, 1979. This was the result of an Operator error (failing to open a downstream valve) which caused the 2nd stage relief valves for the 111 and #2 recovery compressors to lift. The problem was detected by our Bendix continuous monitoring system and promptly corrected. Based on the relief valve setting (120psig) and the system compressor capacity, it is estimated that the vinyl chloride loss was 560 lbs. (16 minutes <? 35 lbs./minute). The routine pressure gauge inspection procedures in effect did not catch this operating error because a different Operator closed the valve due to a downstream condenser malfunction. Very truly yours TENNECO CHEMICALS R. R. Neugold Works Manager RRN:pjd cc: Mr. Marcus Kantz BC: Mr. W. p. Anderson Mr. G. S. Flint/Mr. P. T. O'Brien Mr. F. S. Klopp Mr. R. H. Mathis Mr. J. P. Sandstedt COLORITE 0194X0 Tenneco Chemicals ATenneco Company P O Boi IIP Burlinaion, New Jersey 08D16 (609) 36P-9900 CERTIFIED MAIL C773740 RETURN RECEIPT REQUESTED Organics and Polymers Division January 19, 1979 Mr. Eckardt C. Beck Regional Administrator U.S. Environmental Protection Agency Region II 26 Federal Plaza New York, New York 10007 Dear Mr. Beck: This is to advise you of a relief valve discharge which occurred at our Burlington Plant on January 11, 1979. This was the result of interstage restriction at the discharge of the first stage. The 1st stage relief valve lifted and was open for 34 minutes. The problem was detected by our Bendix continuous monitoring system and was promptly corrected. Based on the relief valve setting (50psig) and published venting rates from manufacturer's literature, it is estimated that the vinyl chloride loss was 510 lbs. (15 lbs./minute). In the future, an intensified inspection program w-ith maintenance as required will be incorporated as operating routine, which should improve compressor operating reliability. Very truly yours, TENNECO CHEMICALS / RRN:pjd R. R. Neugold Works Manager COLORITE 019411 Tenneco Chemicals a Tenneco Company PD Box 116 BuMinclon Nr*. Jersey 0BD16 <609) 386-9200 January 15, 1979 Organics and Polymers Division CERTIFIED RETURN RECEIPT REQUESTED Mr. Eckardt C. Beck, Regional Administrator U. S. Environmental Protection Agency-Region II 26 Federal Plaza New York, New York 10007 Dear Mr. Beck: This is to advise you of a relief valve discharge which occurred at our Burlington plant on January 5, 1979. The second stage relief valve on our No. 5 recovery compressor lifLed as a result of ice blockages in the condenser discharge line. The discharge lasted from 1924 to 1939 hours; based on pressure setting and published venting rates, it is estimated that 525 lbs. of vinyl chloride was emitted. We believe that in this instance the discharge was directly related to meteorological conditions. Should you require additional information, please contact me. Very truly yours TENNECO CHEMICALS, INC. RRN:JPS/eg cc: Mr. Marcus Kannz JR. R. Neugold Works Manager (Orig. signed by J. p. SandsLedi) COLORITE 019412 Tenneco Chemicals A7eir>eco Compa'i)' p o bd he puftiriBIS'i Me* Jersey OB316 (609) 386-9200 January 10, 1979 Organics and Polymers Division Mr. Eckardt C. Beck, Regional Administrator U. S. Environmental Protection Agency - Region II 26 Federal Plata New York, New York 10007 Dear Mr. Beck: This is to advise you of a relief valve discharge which occurred at our Burlington plant on December 19, 1978. This was the result of a build-up of scrap polymer in the in-line strainer, downstream from the No. 3 recovery compressor. The 1st stage relief lifted, remaining open for a period of 20 minutes (1650-1710 hours). The problem was detected on our Bendix continuous monitoring system and corrected as expeditiously as possible. Based on the relief setting (50 psig) and published venting rates from manufacturer's literature, it is estimated that the vinyl chloride loss was 600 pounds (30 pounds VCM per minute). In the future an intensified inspection program with maintenance, as required, will be incorporated as part of routine production operations and observation of compressor serviceability. We recognize that this notification should have been made within ten days of the incident; the delay is an administrative error which occurred as a result of the Holiday Season and year-end vacation schedules. Should you require additional information in this regard, please contact me. Very truly yours, TENNECO CHEMICALS. INC. RRN:JPS/cg R. R. Neugold Works Manager (Orig. signed by J. P. Sandstedt) COIiORITE 019413 Tenneco Chemicals ATenneco Company P.0 Bon 649 Passaer.a leias77501 (713)479- 3411 January 19, 1979 (JWK-9-79) Mr. Bill Stewart Executive Director Texas Air Control Board 8520 Shoal Creek Blvd. Austin, Texas 78758 Dear Mr. Stewart: The following information is presented concerning a discharge of vinyl chloride monomer to the PVC plant flare system at Tenneco Chemicals' Pasadena, Texas complex resulting from the leakage through a relief valve under circumstances described below. Inasmuch as most of the vinyl chloride monomer released from the process was destroyed by combustion in the flare, the incident may not be a release to the atmosphere within the scope of Section 6.65a of the National Emission Standards for Hazardous Air Pollutants-Vinyl Chloride. The incident occurred about 11:00 p.m. on January 16, 1979. The source of the vinyl chloride monomer was the apparent leaking through of the thermal relief valve on the VCM charge filters (L-302C&D). This relief valve discharges to the PVC flare system. The vinyl chloride collects in the flare knockout drum, where it slowly evaporates and is burned at the flare tip. The majority of the safety relief valves in the PVC plant discharge to the flare system for burning rather than going directly to the atmosphere. It is estimated that 10-20 pounds of vinyl chloride were discharged to the flare system. This estimation is based on the appearance and duration of the flaring. Tne flare was found to be smoking slightly on the night of January 16. An investigation as to the source of the discharge to the flare system was initiated by Operations supervision. Subsequently, the thermal relief valve on the VCM charge filters (two parallel filters in the set) was found to be leaking through. The filters were taken out of service and depressured, stopping the leakage. The relief valve was subsequently replaced. Additionally, an Investigation is continuing in regard to possible nodlflcatlons to this relief valve system. COLORITE 0194X4