Document omgywR797Q85j16nqN12mMpZ3

FROM: DATE: SUBJECT: P. c. Gowan September 14, 1989 XBVTROKMBMTAL STUDY This document: is being distributed for your information. It was compiled with a number of different objectives and internal audiences in mind. The "Prologue" summarizes these. Please keep in mind that it does not define a total plan or policy upon which to base actions, though several recommendations may be accepted. At this point, I believe that it may be useful as an educational tool, a reference document and a starting point for development of informed consensus. Actions to be taken will be directed through the line organization as appropriate. Please contact me with questions or suggestions and keep in mind that I would be happy to address interested groups within the Company on this subject at your request. Paul C Gowan S&T.012/mlf VAB.0001125083 PROLOGUE This report is intended to address the following questions regarding Vista's environmental situation: Where have we been? Where are we today? What is the outlook for the future? *a How can past performance be improved? It should be viewed as a beginning rather than an end product. The objectives in compiling the information are several: To inform and educate those who may not have closely followed recent developments in the environmental area. To serve as a reference document where appropriate. To identify areas which need further work. To serve as a starting point for development of an informed consensus in the organization. A PCG:dps 8-30-89 VAB.0001125084 i e1 11M i m111 p .............................. nluMfh I 111 a hv vh.l r y ........................................................... VAB.0001125085 Environmental capital commitments are expected to total $50$100MM over the next five years. This large resource requirement is due to increasingly stringent regulations governing allowable chemical emissions to air, land, and water. It is anticipated that the regulatory trend will continue on toward an eventual "zero discharge" standard. This is due to increasing public pressure to eliminate health risks from preventable chemical exposure. Coupled with it is an increasing trend toward local public control of the discharge permitting process. Therefore, a strong incentive exists to ensure that the systems built to address the short-term situation are also compatible with anticipated long-term requirements. Otherwise, some portion of the upcoming investment may ultimately be re-spent. To the degree that Vista successfully anticipates and integrates future requirements into current solutions, a competitive advantage may be obtained over companies which pursue piece-meal approaches. The project to upgrade the Lake Charles Wastewater System is the most expensive ($40+MM) environmental issue in the current plan. It is also an excellent example of the preferred way to approach environmental challenges. It appears to be a flexible, modular system which can be adapted to meet more stringent requirements as they occur. It was developed as a series of alternatives from which informed choices could be made. The selected approach required the smallest initial investment. The detailed design and implementation phase has a full-time project manager. Nevertheless, as far as implementation timing, Vista appears to be in the lower middle of the competitor group surveyed. This indicates that some organizations may have a head start in analyzing and planning for VAB.0001125086 future requirements. w Investments of $35MM and $10MM may be required at Aberdeen and Oklahoma City respectively to reduce residual VCM in PVC resin. About $2MM of environmental items are included in the Ethylene Expansion Project. A $70MM PACOL front-end at Baltimore would address numerous issues, some of which are environmental. These projects are further discussed in the body of the report. The remainder of Vista's current environmental plan is a compilation of several location-specific plans, some further developed than others. None is in final form for the next five plus year period. Many projects have been identified and manpower anticipated to be required has been estimated for most. Few are yet developed to the point of being cost-estimated. This area will require significant work to bring it into full focus. At some locations, external resources are expected to be required for design and implementation. With the recent release of Vista's Environmental Policy Statement, the organization is better equipped to proceed with the discussion and debate necessary to refine the current plan into one which better reflects an organizational consensus. A number of recommendations address issues identified during this three month study. The following is a summary. 1. Environmental decisions should receive broader input and be fully integrated into Business Area strategies. This is a key requirement if the cost burden is to be developed into either a neutral or a competitive advantage. A mm MMMiW rr m mm VAB.0001125087 T IP- 2. In support of the above, greater and earlier R&D Involvement in addressing these issues is warranted. Also technical personnel should be actively encouraged to look at the total system, to develop alternative solutions and to identify returns on incremental/ decremental expenditures relating to those options. 3. An active effort should be initiated to gather and compile information on the developing environmental activities and philosophies of both domestic and foreign competitors. This will provide an additional yardstick against which to assess our own. 4. The above recommendations are all directed toward obtaining additional or better quality facts and viewpoints on which to base decisions. It is proposed that environmental decisions continue to be based upon sound business judgement, taking into account both longand short-term factors, both internal and external. This differs with past tendency to set environmental matters apart from normal business activities because they are externally imposed and viewed to be non productive costs. The magnitude of predicted future expenditures should preclude that approach. 5. Resolve the environmental performance standards to which smaller businesses such as Blane, Premiere, and Vycom will be subject. The same need may exist for offshore joint ventures and trading activities. Competitive issues must be balanced against Vista's liability in the event of a problem. 6. Marketing of streams which would otherwise be considered "waste" poses both opportunities and challenges. 3 VAB.0001125088 Successfully placing streams not currently sold, such - as Ethylene Unit spent caustic and VCM Incinerator HC1, could result in a capital avoidance in the $5MM range and operating/disposal cost avoidance in the $2-5MM per year range. These appear at present to be neither-orn situations and should receive high priority. Several other streams have significant potential for margin improvement/cost reduction, but can be viewed opportunistically. A third category is those currently being sold, but which would quickly become problems if the current customers were lost. Development of contingency plans for these streams may be warranted. 7. Evaluate Vista's off site chemical emergency response readiness via a joint Manufacturing/S&T Team. 8. Consider utilizing additional resources, which may include consultants and contractors, as necessary to catch up on environmental activities. As previously mentioned, this need may exist particularly at Lake Charles. Duration maybe over the next one to two years. 9. Consider whether an intensified R&D effort in PVC compound/dryblend formulation may allow Vista to gain a competitive advantage as regulations tighten on heavy metals, flame, and smoke generation. 10. Consider use of a consultant to assess DOT pipeline compliance. This may be an immediate need. .11 Continue to support development of waste minimization goals by location and for the corporation. Manufacturing locations are underway with identified coordinators and targets to be included in objectives. VAB.0001125089 BACKGROUND VAB.OOOl125090 VAB.0001125091 ENVIRONMENTAL WHITE PAPER BACKGROUND Summary Environmental issues are again assuming a prominent place on the national agenda. This can be seen in legislative initiatives, increasingly visible action by regulatory agencies and a shift in public opinion. This last may be partially attributable to "media events" following newsworthy spills and the public release of industry emissions data. The more astute politicians sense an environmental mandate and are publicly declaring their new-found activism. During the 1970's and early 80's, regulations and procedures were put in place to correct "gross pollution". The emphasis now turns to reduction of the remainder by on the order of 90% in order to protect public health. In the current debates as to what constitutes an "acceptable risk", cost/benefit considerations are notably absent. Objective research data is unavailable regarding human health effects of long term exposure to low chemical concen trations; therefore, decisions will be based on an emotional objective of "zero risk" with reality moving ever closer toward that "zero discharge" standard. While Vista has historically concentrated on remaining in compliance with environmental regulations as they developed, this may not be a cost effective approach in the long term. At Lake Charles, we face a multi-million dollar replacement of existing wastewater treatment facilities in order to comply with tightening standards. A more proactive approach over the years could very well have cost no more than was spent and have avoided the upcoming expenditures altogether or at least to some extent. By approaching the environmental area strategically rather than reactively, Vista can achieve a competitive advantage over those who continue piecemeal programs based on minimizing short term A more compelling reason may be that proactive companies are more likely to obtain public endorsement of their right to operate than are laggards and those who chronically fall short of regulatory standards. This issue is expected to grow in importance with time as discharge permit issues become increasingly subject to control at the local public level. The following is a partial list of environmental issues which affect or will affect Vista: A. Air emissions of organics from wastewater treatment systems. (Anticipated 1990) 1 VAB.0001125092 fi B. Sara Title III reporting - public outcry over industry emissions with probable increased regulations. (In force 1988) C. Definition of "safe" levels of various chemicals in air and water. (Definition debate in progress) D. States establishing individual regulations more stringent than federal. (Increasing trend) E. Much tighter limits for various chemicals in wastewater whether discharged directly or to city treatment system. Examples are: LCCP wastewater BOD reduction of 80-90%; Baltimore benzene from essentially unregulated to parts per billion level; VCM Plant EDC 99.6% reduction. (Imple mentation of new regulations underway) F. Improving analytical ability allows regulation to parts per billion and lower vs. parts per million a few years ago. G. EPA mandated by legislature to "eliminate discharge of pollutants into waters of the United States". (Strategy statement in Clean Water Act of 1972 and 1987 indicating long term direction) H. "Hazardous" waste being redefined to encompass more chemicals in much lower concentrations. (1989 and contin uing) Potentially includes almost everything but waste paper. For example, some off-spec PVC compounds are currently classified as hazardous due to metals content. The proposed regulations would include PVC resin with VCM residuals exceeding about 5 ppm. It has been claimed that shredded paper money from the U.S. Mint is hazardous waste in California due to heavy metals content of the printing ink. I. Federal regulations require tank and pond modifications to minimize potential for release of hazardous materials to groundwater. (Now in force) J. State of Louisiana already expressly prohibits discharge of "pollutants" to groundwater. (Recently in force) K. New regulations will eliminate burning of many "hazardous" materials as boiler fuel. (Anticipated 1989) L. State and Federal regulations being phased in to eliminate any landfill type disposal of many "hazardous" wastes. (Implementation 1989-90) M. "Acceptable Risk" will be decided in local public forum instead of by scientific study! This may become the most 2 VAB.0001125093 f VAB.0001125094 Past Practice/Philosophy When we were Conoco Chemicals, the environmental philosophy was to stay in legal compliance with regulations as they were developed. This was done primarily with closely controlled capital expenditures for equipment at the "end of the pipe" . The equipment was designed to collect a wide variety of waste streams and either dilute or destroy chemicals which would otherwise be emitted directly. In light of current understanding, relatively little was done to the manufacturing processes or operating practices to eliminate, segregate or recycle these wastes other than for yield improvement. As Vista, the basic philosophy of compliance remained initially the same and we achieved the added benefit of Conoco/Du Pont retaining liability for conditions or practices preceding the purchase. This retained liability has resulted in significant cost savings for Vista, but it is far from a panacea and relates very little to many of the issues we face in the near future. For instance, the split of costs to cleanout sludge from equipment in use both before and after the formation of Vista is a topic for negotiation. Costs to reduce emissions from Level A to a lower Level B due to a recent regulatory change belong solely to Vista. Therefore, with the exception of pre-existing groundwater contamination and closure of idled waste treatment ponds, Vista faces future environmental challenges on the same regulatory basis as our competitors. The opportunity exists, however, to manage these expenditures in such a way as to achieve a competitive advantage. At first glance, turning a forced expenditure into an advantage would seem a bit optimistic. But just as the Federal Trade Commission imposes rules to supplement free market forces, so too do the environmental regulators. By so doing, a more or less "level playing field" is created. Just as some organizations achieve a competitive edge within the commercial arena, so too can other constraints be met more efficiently by one group than by another. The difference in performance per dollar expended comes from ceasing to treat environmental costs as a burden and beginning to manage them in the same way as any other aspect of doing business; i.e., Do they make sense to the benefit of the business and how can this benefit be maximized? As an example, consider the Lake Charles Complex wastewater nent system. Between 1960 and 1986, Conoco/Vista spent approximately $10MM capital on facilities which must now be abandoned and replaced because they cannot meet new standards. In 1989 dollars, that cost is about $35MM. Those facilities will consume another $10MM in cleanout and closure cost before they can be abandoned. So, in today's dollars, we expended and committed $45MM to those facilities. 4 a VAB.0001125095 VAB.0001125096 Regulations As things currently stand, a plethora of regulations, both state and federal, deal with environmental issues. These regulations, carrying the force of law, appear to be a maze of overlapping, interlocking and sometimes conflicting set of directives. Fragmented administration, scope, timing and technical particulars abound. Numerous critical (to Vista) interpretations are vague and/or left to the discretion of functionaries in one agency or another. Definitions of what constitutes a hazardous chemical and what concentration is harmful vary from group to group, list to list. New regulations, along with updates, expansions and re-authorizations of existing regulations continue to be issued for review, public comment or in final form on a daily basis. In order to make some sense of it all, consider that there are major areas being 1) Air emissions 2) Wastewater quality 3) Groundwater contamination 4) Hazardous solid waste 5) Non-hazardous solid waste (garbage) During the late 60's and 70's, most of the emphasis (as far as the chemical industry) was being placed on wastewater quality. The intent was to eliminate gross pollution of lakes and streams which caused oil slicks, fish kills and destroyed recreational value. The automobile industry felt the effect of efforts to reduce air emissions from vehicles. In the late 70's, air quality in terms of smoke and sulfuric acid precursors became an issue for the chemical industry. The question of how to dispose of hazardous solid and liquid wastes began to be a constraint. Also, studies were beginning to identify health effects from exposure to various common chemicals. Major cities began to run out of space for conventional garbage dumps. Through the early to mid 80's, concern mounted regarding possible chemical contamination of underground water supplies and allowable limits were "fine-tuned" downward on all the above. The general public saw no new major initiatives and concluded that the Reagan Administration had abandoned the environment. However, the regulators continued to tighten existing standards. It has been estimated that 80-90% of pre-1970 emissions were addressed by regulations to date. A mandate seems to exist to reduce the remainder by another 80-90% within the next several years. (Remember that cost increases geometrically.) Individual states have begun proposing and enforcing regulations which are 6 VAB.0001125097 i much more strict than federal standards. The State of Louisiana is a prime example. The driving force for this new round of cleanup has moved from the visible effects on the environment to an emphasis on protect ing human health. An example is the pending wastewater biotoxicity standards which require survival of microscopic and extremely delicate water fleas as an indicator of non-toxicity. The following is a sampling of actual and proposed regula tions. They are more fully described in the Appendix. I. Air A. EPA - Clean Air Act - Remove 95% of volatile organic organic compounds from wastewater streams before going to treatment. (Proposed) B. EPA - RCRA - Reduce organics from hazardous waste storage, treatment and disposal by 95%. (New in force) C. EPA - NESHAPS - EPA required to set emissions standards which provide ample margin of safety to protect human health. (1987) D. State of La. - New installation may contribute no more than 1/42 of allowable exposure limit at plant fenceline. (Much lower for carcino gens based on health risk factors of 10"A to 10-6. (New) E. EPA - SARA Title III - Industry required to publically release annual inventory of hazardous emissions to air, ground, water. (1987) II. Wastewater A. EPA - OCPSF - Control pollutants by best available technology (80-90% reduction for Lake Charles Complex). (1987) B. EPA - Cleanwater Act - Eliminate discharge of pollutants into waters of U.S. (1972 & 1987) C. EPA - TC - Redefines what materials are hazardous and therefore subject to the extremely strict set of handling/treatment/disposal requirements of RCRA. (Anticipated 1989) VAB.0001125098 ! VAB.0001125099 Public/Legislative Sentiment It ight be said that information and "education" are raising awareness of and sentiments against human health effects Leals in the environment. For many years a vocal percentage of the general public has maintained that industrial decision makers are allowing irreparable harm to be done. After 20-30 years of attempts to dispel that perception, it remains. Unfortunately, as more concrete knowledge became available and past abuses were un covered, we had to concede that to some extent, unwitting harm was done. Regardless that past practices were based on good faith ignorance, for industry to achieve credibility with the general public is extremely difficult at this point. Within the past few months, the first annual reports of hazardous emissions were made available to the public under SARA Tile III "Right to Know" legislation. Nearly everyone can read about tons of chemicals, which the government says are hazardous, being emitted within their general area. This is a frightening prospect, particularly to the uninitiated. This data, coupled with other "media events" such as spills, releases, and cancer corridors has spread concerns across a much larger portion of the populace than the previous vocal few. Topics such as global climate changes and acid rain are now debated at the international level. From that perspective, let's revisit the question of "acceptable risk". Simply stated, this means "What chance of getting cancer from preventable chemical exposure am I willing to accept?" The current debates deal with ranges of 1 in 10,000 to 1 in 1 million. Even these infer emissions of cancer-related materials in the parts per billion to parts per trillion range. There is no reason to believe, however, that the public will accept any given exposure level as being low enough if the opportunity exists to drive it lower still. This is particularly true if the public remains convinced of industrial insensitivity. That is why an eventual zero discharge standard is likely, with the only real questions being "How soon and with how many stops along the way?" The legislators and other elected officials have begun to the of support available ' to environmental activists. Numerous legislative initiatives are making their way through the system as "read my lips" gives way to "clear the air One little-noticed regulatory procedural change is that public comment periods are now a major determinant of outcome. In VAB.0001125100 VAB.0001125101 Other By now, anyone who has not closely followed this area over the past several years may be feeling a bit punchy. The news is not all bad. As with previous regulatory initiatives, real world considerations of jobs and the need to avoid wholesale loss of segments of American industry are apt to temper implementation timing. The sky won't fall, but we will find a way to achieve the required levels of performance. That is not to say that any individual company will not be hurt. It is reasonable to expect that those best able to adapt to changing situations will gain at the expense of those which are unwilling to change. Vista has no apparent fatal flaws such as Love Canal or Bophal. We do have some groundwater contamination by EDC at Lake Charles and benzene at Baltimore, but believe the remediation actions underway have it surrounded. We may be at a disadvantage in PVC reactor stripping. A group is working to define that. We know that a large expenditure is necessary to replace the Lake Charles wastewater treatment system, but believe that to be a prudent, well thought out solution. It is possible that further investigation will uncover other regulatory-driven requirements. However, our competition also must face the same regulations and many have substantial pre-existing liabilities as well. In short, there is no ticking bomb. It should be noted that this conclusion is not necessarily shared by all of Vista's environmental and enviro-legal experts. It has been suggested by some involved in day-to-day environmental activities that a ticking bomb does in fact exist. That bomb is a result of a general complacency and failure to appreciate the seriousness of the challenges facing the Company. This concern stems from a perception that increases in resources applied to the environmental area are being made belatedly and fear that financial restructuring will cause management attention to be directed elsewhere, precluding effective solutions. The management challenges in the environmental area include dispelling that In truth, Vista's regulatory compliance record is not pristine. While most excursions do not result in formal enforcement actions, the trend toward formal proceedings against violators is increasing. Vista Legal has recently assembled the following data on enforcement actions (not all of which are strictly environmental): VAB.0001125102 PLAN DEVEL VAB.0001125103 DEVELOPMENT OF A PLAN Summary To say that Vista currently has a solid, fully integrated and engineered long-range environmental plan would be misleading. That ultimate plan will evolve as the implications of the Corporate Environmental Policy are tested, understood, and interpreted by employees and managers. There exist good location - specific plans, some more fully developed than others. Corporate Policy Statement communication has recently begun. There also exists a good example of the development of a long-range plan directed toward one waste category at one location. This is the LCCC Wastewater Project. The methods and approach used in the development of that project may he applicable to other selected issues. Additional recent examples of longer range thinking include the Baltimore Sewer Project and the environmental aspects of the Ethylene Expansion Project. VAB.0001125104 5. Fully integrated with business area strategy and Objectives In order to achieve a favorable result, any plan must meet certain criteria. There must first be recognition that having some plan is necessary. The plan itself must be consistent with overall organizational objectives. Most importantly, thought leaders and decision makers must be able to "buy in" on the strategy and tactics implied in the plan. * The objective in developing an environmental plan for Vista is to satisfy those criteria. The recognition element is addressed in the "background" section of this document. Consistency derives from the plan objectives as guided by policy; in this case, the Corporate Environmental Policy which is by definition consistent with overall corporate objectives. "Buy in" is anticipated to come from communication, debate, and refinement of the initial proposals contained in this document. An ideal environmental plan might include the following among its objectives: 1. A long-term view vs. short term. 2. An integrated system vs. a sub-optimized "band aid" approach. 3. Implementation managed in the same fashion as other aspects of the business. 4. Compatible with eventual "near-zero discharge" standard. VAB.0001125105 Identify waste minimization options for water, air, and solids associated with wastewater treatment. Identify optimum waste management implemenation Plan. VAB.0001125106 While expensive and time consuming, the result was a comprehensive, objective treatment of an extremely complicated area. Perhaps more importantly, the Radian Study allowed for a clear and decision making process with multiple alternatives from which to select. This provided the ability to deal with the issues in a businesslike manner. The broader representation on the study team, both internal and external, contributed an overall perspective lacking in a one or two person effort. Studies In the past, the study portion of environmental planning has consisted primarily of internal personnel identifying to management the requirements of newly enacted or proposed regulations. Due to the typically short response time allowed by these regulations, communications, and development of action plans tended to be conducted in a crisis type atmosphere. While this approach was successful in focusing attention on the problem, it fostered resentments and misunderstandings which diluted the impact of more forward-looking proposals. Given that internal studies took time away from today's problems , there was concern that they may have been hastily done or might be lacking in long-range objectivity. In the Lake Charles Wastewater Project, Radian Corporation, was retained as a consultant to first develop a comprehensive review of wastewater regulations and regulatory trends. This regulatory assessment took one month and cost about $15,000, excluding the value of time spent by internal people. This portion was completed in November 1988. Radian then continued to develop project alternatives from which Vista would select one strategy and Radian would then proceed to outline a preliminary process design with implementation plan. As part of this effort, Engineering Science, Inc. was retained by Radian as a subcontractor and Vista retained Lyle Tichler and Diana Kocurek of Austin as an additional resource. A Vista Project Team was formed with representatives from PED and three Lake Charles Plants, plus part time involvement by Headquarters Environmental and Legal personnel. This phase involved six months and about $235,000 out of pocket cost. VAB.0001125107 focus . It is not necessary to think of outside consultants in terms of multi-hundred thousand dollars provided that their work is restricted in scope to specific questions. This is borne out by the comparison of regulatory assessment and project development cost for Radian. A positive aspect of QMP and PD&I influences has been the broadening of representation on internal efforts. Early involvement of R&D, Business Area, and Marketing personnel will continue to be a key factor in converting regulatory burdens into competitive * VAB.0001125108 Management Reviews A common complaint from managers has been the tendency for environmental projects to contain no realistic alternatives. The Lake Charles Wastewater Study instead provided four possible approaches encompassing differing costs, technologies, and philosophies. This allowed selection of a combination of source control and "end of pipe" treatment which can be later adapted to meet more stringent requirements. The selected option was also that of least initial cost. (A summary is included in the Appendix.) The project implementation is also proceeding in a businesslike manner with appointment of a full-time project manager to direct detailed engineering and construction. Obviously, not all environmental projects require this type of focus, but providing it for this large project is evidence of Vista's commitment to excellence. As efforts continue to move out of the reactive mode, originators of environmental projects will need to spend additional preparation time identifying positive benefits and developing creative alternatives. Otherwise, the audience will lack a basis for informed business decisions. This issue is further addressed in the Appendix. VAB.0001125109 of Wastes A comprehensive environmental plan will recognize and address major types of wastes/emissions: Air Point Sources Fugitive (Leaks) Wastewater Process Water Cooling Tower/Boiler Blowdown Streams Stormwater Run-off Groundwater Existing Cleanup Future Contamination Prevention Solid Waste - Hazardous Continuous Generation From Spills or Excavation From Old Site Cleanup Scrap Product Solid Waste - Non-Hazardous Trash Scrap Product Innert Materials VAB.0001125110 These wastes have a variety of sources, among which are: Raw Materials Intermediates Products Byproducts Wastes/Losses Processing Supplies Maintenance Supplies Lab Chemicals Office Supplies Transp./Pkg. Supplies Fuels Heels, BS&W, Ash, Coke Contaminated or Surplus Materials Byproducts of Waste Trtmt. Processes Spills, Accidents, Upsets VAB.0001125111 This policy forms the basis of and mandate for future environmental planning. Included in this section are summaries of some possible implications of the policy along with a few examples of this thinking in action. VAB.0001125112 Vista Chemical Company ENVIRONMENTAL POLICY Vista Chemical Company produces and transports chemical products that can potentially impact the environment in the communities in which we conduct business. Vista believes that compliance with all laws and regulations related to environmental quality and public health protection is a minimum standard of acceptable practice. Vista Chemical Company is committed to improving Vista's environmental protection efforts to achieve performance levels exceeding those required by law. Vista recognizes the responsibility we have to our employees, the surrounding communities, customers, carriers, contractors and government agencies to conduct our business activities according to the following environmental principles: Vista will inform and educate employees, surrounding communities, customers, carriers, contractors and government agencies of the health and environmental hazards of the chemicals we make, use and sell. These activities will involve recognizing and responding to community concerns regarding environmental issues. Vista will continually reduce the risk to employees and neighboring communities posed by chemical substances used, produced and transported within our communities. Vista will continue to reduce the potential for emergencies involving chemical releases that would impact the environment and surrounding communities. Vista will foster and maintain an awareness of and sensitivity to environmental responsibility among our employees through an ongoing internal communication program. Vista will maintain an environmental quality assurance program to ensure that operations are in full compliance with Company policies and procedures, governmental permit limitations and regulatory requirements. VAB.0001125113  Vista will determine how each new or existing product can be made, used, handled and disposed of while protecting employee safety, public health and the environment Vista will make safety, health, environmental control and waste minimization essential and integral parts of process and facility design, construction and operation. Vista will reduce waste generation in the air, water and soil through employee involvement and the pursuit of source-control technology to reduce emissions from both the manufacturing process and equipment. Vista will work with the government and other parties in developing responsible laws, regulations and standards to protect employees, surrounding communities and the environment. July 20,1989 VAB.0001125114 Environmental Policy Summary Item Imnact Performance Better Than Required $ Inform & Educate Employees Community People Reduce Risk Used/Produced Transported $/People Reduce Potential for Emergencies (Chemical Releases) $/People Environmental Quality Assurance Program Waste Reduction/Minimization Integral Design Construction Operation Source Control People $ Government/Regulatory Involvement People VAB.0001125115 Corporate Policy Statement 1. A pro-active approach to environmental responsibility. 2. Key differences from previous practice: a. Performance better than required by law as a desired goal. b. Commitment to waste minimization by source control rather than cleanup as it leaves the Plant. Also "designed in" control vs. "added on". c. Emphasis on education and awareness among employees and surrounding communities. Also emphasis on legislative involvement. 3. Why do it? a. Long-term correct approach - minimize resources, rework. b. Regulations directionally headed toward zero discharge. Timing and methods are seemingly the only issues. Unfavorable publicity likely for incidents of noncompliance . c. "Right to know" puts vast amounts of previously confidential information on chemical emissions in hands of public. d. Environmental issues to be increasingly debated in public forms vs. on a technical level. We will need our neighbors on our side. VAB.0001125116 e. CMA membership requirement. Implications of Corporate Policy Statement a. Short Term 1. Higher capital theoretically (probably little if any higher from practical standpoint). 2. More manpower devoted to environmental matters in order to catch up. 3. Higher profile in local communities and in government. 4. More emphasis on planning vs. reacting. 5. Multi-discipline responsibility for environmental excellence. (engineering, R&D, operators, business areas, support groups, in addition to manufacturing management, environmental specialists, legal specialists). b. Long-Term 1. Less Capital - (See Appendix - Look Back Study) 2. Less manpower specifically devoted to environmental problems as responsibility is spread more broadly. 3. Flexible, modular plans which anticipate and allow for changing regulations. VAB.0001125117 v.v\U2_E*3T P L/\ ^ VAB.0001125118 CURRENT FLAN A. Summary This location - specific plan contains some elements of a comprehensive corporate plan along with an identification of open issues and recommendations as to how the organization might proceed from this point. As such, it should be viewed as one interration in the process of discussion, testing and debate from which a consensus will emerge. The question posed to the organization was to identify upcoming environmental projects exclusive of those already in the 1990 or earlier Capital Budgets. The intent was to develop location - specific plans looking forward into the next several years. From these, it was anticipated that an overall plan could be developed. The project lists which resulted were based on brainstorming sessions at the various locations during the summer budgeting period. They consisted of items which were known or anticipated to be necessary, but had not yet been developed to a point where they were ready for budget - quality consideration. Very few were engineered or ready to be cost - estimated. Therefore, due to time and available resources, it was decided to identify the manpower which would be necessary to develop each project and the desired completion time frame for each. At Lake Charles this estimated manpower is a large fraction of the total available technical force, indicating a possible need for outside engineering An issues list has been developed, outling items which need resolution before an overall plan is completed. A limited competitive assessment was also performed which indicated Vista to be somewhat behind in implementation of the Wastewater Project. * VAB.0001125119 B. Project List - Lake Charles Chemical Complex Based on discussions with plant personnel, there is a belief that substantial work remains to achieve compliance with current Environmental Regulations. The magnitude of this effort mitigates against a strong focus on future requirements and proactive projects. However, as previously discussed, the approach taken on the Lake Charles Wastewater Project is a good example of designing to meet current requirements while creating a system which is adaptable to the more stringent demands of the future. A concern expressed by the Plant is to what extent time and available resources will allow similar approaches to the other outstanding issues at LCCC. This concern is reflected in the anticipated environmental project workload summary for process engineers which indicates that a high percentage of available manpower will be required over the next 1-3 years. Outside or headquarters engineering assistance may be necessary on a selective basis if the desired project timetables are to be net. In an effort to bracket the impact of this project list, the following worst case scenario was developed: Assuming no ability to provide internal resources to these projects, what would be required in the next year? The LCCC technical group would then recommend as follows: Regulatory Analysis by outside consultant (priority order). Approximate cost $90M. a. Air b. SARA c. TOSCA d. Hazardous Waste e. Solid Waste 2. Outside (contract) engineering to design and begin implementing solutions. Approximate cost $1HM. The critical restraint (excluding cost) would be Vista's ability to oversee and give direction to contract personnel. The actual situation is probably somewhere between business as usual and that worst case. It is recommended that this issue receive further attention to achieve a better definition of staffing requirements along with completion of project cost estimates. VAB.0001125120 I i li LCCC ENVIRONMENTAL PROJECT AGENDA PROJECT Budgeted Projects DAF Unit modiflcatIon Stormwater Projects (3) AREA LCCP LCCP COST. MS 30 1250 TIMING 1Q90 1Q90 Cooling water leak detection Stormwater tank LCVCM LCLAB 80 100 1Q90 1Q90 T-405 Secondary Containment SPCC Plan MODS. Environmental Lab Equip. Alcohol VOC closed loop sampling Ethylene VOC Anal. Bldg, vents S.400 RX Emission Red. Spent caustic loading system Stormwater & Hydr. min Proj. (2) LCVCM LCVCM LCVCM LCCP LCCP LCCP LCCP LCCP 75 63 50 50 90 4000 250 2700 2Q90 2Q90 2Q90 2Q90 2Q90 2Q90 2Q90 2Q90 REMARKS For Wastewater Project Maybe For wastewater Proj ect Maybe For Wastewater Proj ect VAB.0001125121 I I Ii PROJECT Stormwater & W.W. Proj. (3) LCCC ENVIRONMENTAL PROJECT AGENDA AREA LCLAB COST. MS 1800 TIMING 2Q90 VCM Wastewater Engr. LCVCM 150 3Q90 EO Emission S.600 Baro. Sump Emis. Red. Stormwater HNDLG. LCCP LCCP LCCP 100 2000 2000 3Q90 3090 3Q90 Wastewater HNDLG. LCLAB 1000 3Q90 KOH Benzene Stripper EDC Wastewater Compliance Wastewater Slop Tank Copper Pit Replacement Waste/Hydr. Red. W. W. Treatment MODS. LCLAB LCVCM 1500 1000 LCVCM LCVCM LCCP LCLAB 400 150 2000 800 3Q90 4Q90 4090 4090 4Q90 4Q90 REMARKS For Wastewater Project For Wastewater Project For WasteWater Project For WasteWater Project Maybe For Wastewater Proj ect For Wastewater Project For Wastewater Project VAB.0001125122 LCCC ANTICIPATED ENVIRO. PROJECT WORKLOAD (2) PROCESS ENGRS GEN. LCCP LCVCM LCLAB TOTAL ENVIRO. WORK (1) % OF AVAILABLE ENGRS Process Engrs. - Total Equiv. Manmonths Enviro. Proj ect Requirements (Manmonths) Immediate 1990 1991 1992 1993 1994 1995 Later 17 7 3 204 84 36 27 324 59 48 37.5 145 12 15 21 2 50 74 23 4 101 34 15 5 54 4 13 7 4 28 11 12 23 29 29 6 24 30 45 15 31 17 9 7 9 9 Wastewater Proj. (?) 55 43 98 Note: (1) If projects assumed to be part of the Wastewater Project must be handled Individually, the percentages increase with the largest effect being in early years. Note: (2) This workload Is understood to be In addition to projects previously Identified by 1990 and earlier capital budgets and projects known to be part of the LCCC Wastewater (Black Box) Project. VAB.0001125123 PROJECT______________ Hazardous Waste Disposal Coke Asbestos Waste Paint Sandblasting Sand Filter Cartridges Tank Btms. Solid/Liq. Waste Oil Samples Laboratory Chemicals Contaminated Trash AREA Gen Air Emissions Gen Asbestos Removal Emerg. Release Elim. Program Heater Emissions Red. - NO , C02 Water Issues Gen Bayou Verdine Toxic/Biotoxicity LCCC Wastewater Project Product Stewardship Gen Reduce Residual R.M. Risk Communications Use Communications End User Exposure in products Transportation Gen Railcar Heels/Cleanouts Truck Heels/Cleanouts Railcar Repairs Pipeline Maintenance/DOT Compliance Elimination of Drums/Admin. Changes LCCC GENERAL ENVIRONMENTAL COST TIMING Immed. EST. ENGR. HANHONTHS PROCESS PROJECT 6+ 4+ REMARKS Many are economic issues today Coke immediate problem; complete Abestos elimination at LCCP is estimated S5MM over time; remainder are waste minimization issues at present. Continuing 2000 3+4 6 3+3 S 1993 & 94 limed. limed. limed. 3 3 Non-Capital II It II 2 1 1 1 I' 4 VAB.0001125124 PROJECT Wastes Groundwater Cleanup Old Site Cleanup Catalyst, Sieves Filter Cartridge Disposal AREA Gen Spill Containment Tank High Level Alarms Tank Dike Cleanup Gen Waste Minimization Program Development Gen Contingency Plans Gen Event of CoProduct Market Loss Reduce Volume of Hazardous Materials stored onsite (E.O., ALKYLS, H.F., Benzene, V.C., Chlorine) LCCC GENERAL ENVIRONMENTAL COST TIMING EST. ENGR. MANMONTHS PROCESS PROJECT 6 REMARKS 1990 3+ 2+4 1+1+2 12 ?? Phased completion with desired early start VAB.0001125125 LCCP ENVIRONMENTAL PROJECT AGENDA PROJECT AREA COST Elim. EPA-023 Discharge Violations Elim. RV Discharges to Grade Elim. Spills to Grade or Contain. Off-Spec/Mixed Product Novel Catalyst Disposal Novel Catalyst Contaminated Material Disposal NPU ETO ETO ETO ETO ETO Closed Loop Sampling (Grab & Continous) Fugitive Emissions Sec, 300 Values Alumina Dust Emissions Elim. Rainwater Flooding Fugitive Emissions Subtotal Immediate Alcohol/Ethylene Alcohol Alcohol Alcohol Ethylene Better define fugitive emissions Cooling Tower Emissions/Exchanger Leaks Tank 428 - B2, VOC Definition Subtotal 1990 NPU Alcohol Alcohol Spent Caustic Elim. or Sale Fugitive E.O. Emissions Control E.O. Viking Emissions Control Oxidation RX and Barometric Emissions Acid Holding Pit Emissions Elim. RV Discharge to Grade Subtotal 1991 Ethylene ETO ETO Alcohol Alcohol Alcohol $2750M Elim. Once-Through Cooling Water E.O. Blowdown Pond * Elim. or Synthetic Liners Quench Solids Subject to Land Ban NPU ETO Alcohol TIMING Immed. Immed. Immed. Continuing Before AFE Before AFE Immed. Immed. In Process Immed. Immed. 1990 1990 1990 1991 1991 1991 1991 1991 1991 1991-92 1991-92 1991-92 EST. ENGR. MANMONTHS PROCESS PROJECT 31 21 21 42 31 31 4+3 2 2 10 4+3+3 48 3 4+2+4 J 15 10 3 3 50 4 _4 74 2+1 1 1 12 2+1+1 28 1 3+1+4 _2______________ 11 8 1 1 40 2 _3 55 42 68 Railcar/Truck Loading Emissions Containment Internal Floating Roofs Tanks below 10,000 gal. Closed Loop tank Sampling Ethanol alternate to burning Flare Emissions Sampling NPU Alcohol Alcohol Alcohol Ethylene 1992 1992 1992 1992 1992 6 3 4 1 1 4 2 2 REMARKS Marketing Solution Ideally should be resolved as R&D issues prior to process commerc i a l i zat i on. Marketing Solution ($5MM capital avoidance) See Wastewater Project Issues Possible economic issue Marketing solution with $500M/yr. current incentive increasing to $1MM/yr by 1991 Proposed LA. State Regulation Marketing Solution VAB.0001125126 PROJECT Tempered Water Toxicity? Subtotal 1992 Eliminate Ammonia Emissions Benzene Emissions/Neshap Residual EO in Product Subtotal 1993 Tank Cleanout Method/Disposal Cleanout Tank Dikes Merox Odor Reduction Subtotal 1994 Elim. Dixoane Emission Light Hydrocarbon Odor Elim. ALKYL Containment Catalyst, Sieve, Filter Cartridge Disposal Subtotal 1995 Addressed bv Wastewater Protect (?) Reduce Hydraulic Loading Stormwater Elim. once - through cooling water? Revise surface ditches Underground Lines Sewer System Redesign EPA 018 Outfall Violations Oil Spills, Leaks, Drips EPA 004 Outfall Violations Subtotal W.W. Proj. (?) LCCP ENVIRONMENTAL PROJECT AGENDA AREA Alcohol COST Alcohol Ethylene ETO Alcohol Alcohol Ethylene ETO Alcohol Alcohol NPU/Alcohol/Ethy TIMING 1992 1992-93 1992-93 1993-94 1994 1994 1994 1994-95 1995 1995 1995 EST. ENGR. MANMONTHS PROCESS PROJECT 44 34 24 32 42 64 13 8 44 48 31 11 13 3 4 6 4+6+6 1 2 3 1+3+4 29 14 NPU NPU Alcohol Alcohol Alcohol Alcohol Ethylene Ethylene 1991-92 1991-92 3 3 6 12 12 3 4 12 55 1 1 6 12 12 3 3 10 48 Miscellaneous Additional Issues Turnaround Waste Red/Disposal Elim. Odors Replacements for Freon Sec. 225 BTMS - Min., Recycle, Sell Quench Solids NPU ETO Alcohol Alcohol Prior to next TAR 3 3 3 6 1 1 2 5 REMARKS If leak std. revised to 1000 ppm vs current 10,000 Define administrative changes Marketing Solution VAB.0001125127 LCCP ENVIRONMENTAL PROJECT AGENDA PROJECT Disposal of hot oil contaminated Alkoxide Coke Handling/Disposal Subtotal Mi-sc. AREA Alcohol Ethylene COST TIMING EST. ENGR. HANHONTHS PROCESS PROJECT 43 _5 _3 24 15 REMARKS Incinerate? Economic Issue \ VAB.0001125128 1 PROJECT Invest. RC Vent Handling Scope Bauxite Bed Problem Reduce Fugitive Emissions Elim. Tar Still R. Disk Events Eval. Alt. Direct Chlorination Tech. Red. Potential for Reportable Releases Red. Light & Hvy. Ends Production Alt. Disposal for Lt. & Hvy Ends Close Surface Impoundments Provox In Incin. Area Min. Vents to Incin. Rev. Coke Handling Environmental Lab for LCCC Subtotal Addressed bv Wastewater Project (?) Rev. Sewers/Fix CPS Eval. C. T. Alternatives Upgrade Stream Stripping Elim. Limestone Neutralization Biotoxcity Identification Subtotal AREA Total Enviro. LCVCM ENVIROIIHENTAL PROJECT AGENDA COST 7 TIMING Immed. Immed. Immed. Immed. Immed. Immed. 1993-94 1993-94 1992 1992 1991 1993-94 7 EST. ENGR. MANMONTKS (Process/Proiect) 1990 1991 1992 1993 Total 2/0 1/0 4/1 2/0 1/0 4/0 - * 6/2 1/0 - 0/1 - 2/2 2/2 6/2 6/2 - - 1/0 2/2 4/1 - - - - 2/4 - 4/1 2/0 3/2 - 1/3 3/0 - - - - - 2/2 3/1 0/2 - - 2/1 2/1 1/0 6/3 4/2 9/6 10/2 6/3 5/1 4/4 8/4 6/4 5/1 21/3 23?12 is7io 7/6 66/31 Remarks Economic Issue Immed. Immed. Immed. 1991 1992 4/0 2/4 0/2 6/6 3/0 3/3 - - 6/3 8/2 6/4 3/4 * 17/10 2/0 4/2 2/2 - 8/4 2/0 4/1 - - 6/1 19/2 19/14 575 43/24 If . II II II II 34/5 42/26 20/18 7/6 109/55 4 VAB.0001125129 C. PROJECT LIST - BALTIMORE PLANT The Baltimore Plant's Environmental Vision is as follows: Short Term - Compliance with all applicable regulations. Long Term - Work toward zero discharge. A. Apply state-of-the-art environmental technology to all new installations. B. Stop emissions at the source rather than by adding "end-of-pipe" equipment. There is a strong belief at the plant that replacement of the front end with a PACOL unit would significantly improve both safety and environmental cost/performance. As compared with current operation, the project would achieve the following benefits: 1. Eliminate production of HC1 with its attendant problems of marketing, disposal/destruction cost, hazardous sludge production, wastewater contamination, environmental/safety capital requirements. 2. Eliminate the majority of plant corrosion-related equipment repair & maintenance costs. 3. Eliminate storage, transportation, handling, emissions of chlorine. 4. Eliminate tetralins from LAB product - (Quality). 5. Upgrade byproduct values. 6. Potential for improved community relations. 7. Improved operating efficiencies. VAB.0001125130 Ii The PACOL Project is in the early stages of definition with probable timetable of 3 years and $70MM to complete. A major sewer replacement project is underway at Baltimore. Due to leaks and associated groundwater contamination potential, some action was necessary. The approach chosen (suspension of sewer lines inside a #- concrete-lined, grating-covered trench) is a good example of the sort of forward thinking we want to encourage across the company. While allowing easy detection/repair of leaks (as would be the case if run in overhead piperacks), the system continues to operate by gravity flow, avoiding problems of power outages. This type installation should be evaluated as a potential standard for new and replacement sewer systems. The Plant also has a very good regulatory agenda document which is included for reference. It describes in-force and pending regulations along with the impact and response necessary to comply. Other locations might consider whether a similar approach would be helpful for communication and planning purposes. Since this location was undergoing a strike in addition to budgeting activity, efforts were concentrated on assembling the project listing and further definition of cost, timing and manpower requirements was postponed. VAB.0001125131 I l1 BALTIMORE ENVIRONMENTAL PROJECT AGENDA PROJECT AREA COST M$ BUDGETED PROJECTS W.W. VENT COLLECTION SYSTEM PROCESS SEWER REPLACEMENT 700 650 VENT COLLECTION IMPROVEMENT 950 TIMING 2Q90 2Q90 3Q90 STXS VOC EMISSION CONTROL PROCESS SEWER REPLACEMENT 100 500 4Q90 4Q90 BALTIMORE ENVIRONMENTAL PROJECT AGENDA VAB.0001125132 PROJECT AREA ANTICIPATED PROJECTS WATER RECYCLE REPLACE RIVETED TANKS IN BENZENE SVC. ELIM. BZ RELIEF VALVES TO GRADE BZ CONTROL TOWER - REPL.AND/OR SPARE ELIM. IN-GROUND PROCESS TANKS ACID PIT REPL. /UPGRADE ACID PIT SLUDGE HANDLING FUGITIVE EMISSIONS REDUCTION TANK FARM REVISIONS - LONG TERM GROUNDWATER REMEDIATION PUMP SEAL REPL. - BZ SVC. REMOVE TRACE MATERIAL FROM PRODUCT ALTERNATE DISPOSAL FOR SPENT SULFURIC RAILCAR/TRUCK UPGRADE - HAZMAT LAB ANALYTICAL EQUIPMENT ASBESTOS REMOVAL EQUIP. CLEARING REV. - BZ SVC. ELIM. GROUNDWATER INTO STORM DRAINS CONTAMINATED DIRT DISPOSAL * PACOL FRONT END COST M$ TIMING 1000 1000-1500 100 200/YR 70,000 VAB.0001125133 I I I' To: Frcm: Date: J. P. Warner June 27, 1989 Subject: BALTIMORE PAOOL UNIT - KEOCMfENDAXICN PGR A nFTT7lTTFD STUD* A number of preliminary evaluations for a Baltimore PAOOL Unit have been made since the LCXAB plant began operations. Each of these previous studies concluded that there was not sufficient justification to pursue a PAOOL Unit. A new evaluation has just been completed by PED and Baltimore which concluded that there is justification and recommends that a detailed evaluation be con ducted. The changes in the conclusions are based upon: (1) There is increasing pressure to reduce or elimi nate tetxalins in LAB. (2) There is a potential that a Baltimore PAOOL Unit with AICI3 alkylation will produce high quality dialkylbenzenes that can be moved into the syn thetics lubricants market at high margins. (3) There is a continual deterioration in the HC1 market while disposal costs are escalating rapidly. (4) There is a higher efficiency associated with a PAOOL Unit since Define and Paid Energy Recovery projects have cane on line. (5) There is a realization that the ccnmunity safety issues associated with the transportation of chlorine and hydrochloric acid will make permits for the project easier to obtain. The new evaluation shews a 13% IKR based upon a capital cost of 70 million dollars. Average revenues for the project were derived from the following sources: VAB.0001125134 I I I' L. R. Bauer June 27, 1989 Variable Costs Iirprovements (not including HCL) Maintenance Savings Increased 7050 Margins - Improved Quality HC1 Marketing and Disposal Cost Avoidance Ability to use Tetralins Against Competition Sale of HCl Business Chlorine and HCl Transportation Safety Issues 8,800 2,400 2,200 3,000 1,900 Not Included Not Included Not Included Not Included (excluding 7050) HCl Environmental Projects Not Included 1,100 Not Included The Capital requirement of 70 million dollars is larger than that included in any of the previous studies. The increase is due to a better definition of the facilities outside of the project's battery limits. The project costs are brokendown as follows: PAC0L Unit Revisions to Distillation and Alkylation Outside Battery Limits 30 Ml $ 10 MM $ 30 MM $ Total: 70 MM $ A presentation on this issue was made to Ron Bryan and Tom O'Brien at the last Plant/Business Area meeting. Ron agreed with our recommendation but wanted to check with upper management before committing manpower to the detailed study. It is our recommenda tion that the study be pursued based upon our preliminary economics and on the need to be prepared if the Tetralins becomes a major issue in the American LAB market. J. Paul Warner /nw cc: JAD, TP0, RB, GEH - Houston A.A. Salah - LOOP JOGr, JOGi, JRP, JJR, DIM, ACP, MAF VAB.0001125135 i l I* J. P. Warner Date R. B. Merriam June 2, 1989 Subject: Capital Experelitunes Due To HC1 - 1985 thruucfr 1991 - Per your request, attached is the graph of capital expenditures for projects related to HC1 from 1985 through 1991. We do not have and projects projected for 1992 so this data is not included in the graph. Also attached is the list of projects and the associated capital that make up the graph. VAB.0001125136 I BALTIMORE PLANT CAPITAL EXPENDITURES RELATED TD HCL AND MURIATIC ACID c'/u * '>fit r YEAR l1 VAB.0001125137 1985 - 1991 FY 1985 D-344 Replacement Acid Piping Upgrade, Phase I Primary Deoiler Replacement F-36/50 Weak Acid Circulation System T-247 Roof Replacement Total $93,186 85,263 195,168 44,778 89,397 $508,000 FY 1986 Secondary Deoiler Replacement Acid Piping Upgrade, Phase II Total FY 1987 Acid Sewer Recovery, Phase I Acid Piping Upgrade, Phase III Acid Pit Overflow Protection Spare HC1 Absorber T-10 Floor Replacement Crude Tank Bottcm Replacement Total $219,000 183.608 $403,000 $245,000 95,000 90,000 83,070 165,000 210.000 $888,000 4th Acid Tank $600,000 Absorber Vent Line Replacement 120,000 Acid Pit Foam and Fume Protection 65,000 HC1 Fume Scrubbing Isproveraents 140.000 Acid Filter Replacement 120.000 Acid Dilution 285.000 Spare Critical Equipment (Absorber Only) 60,000 Water Wash Drum Replacement 210.000 Crude Neutralization Inprovements 130.000 Caustic Settling Drum Replacement 170.000 Total $1,900,000 Acid Pit Scubber D-24 Replacement Acid Sewer Benzene Control Secondary Benzene Tower Total $120,000 50,000 1.750.000 1.600.000 $3,520,000 VAB.0001125138 EL122Q Crude Neutralization Inprovements Acid Filter Replacement Deoiler Tenperature Control Second Acid Pit Cover D-201 Replacement Acid loading Spill Prevention underground Acid Sewer Elimination Total $800,000 125,000 200,000 400,000 400,000 250,000 400.000 $2,575,000 $2,000,000 VAB.0001125139 11 t To: Paul Gowan Interoffice Communication Fran: D. L. Mahler July 7, 1989 PEAMT RBODIATCPV aCTMnfr Jim Gibson indicated that you would like to review the attached document prior to visiting Baltimore this month. Please give me a call if you have any questions. /dwt. Dave Mahler Director of Environmental Control /ma JUL TO 89 VAB.0001125140 * T?F!n TT ATOPY AGENDA BAUTM3RE CHEMICAL PLANT 1. EFFLUENT GUIDELINES FOR OCPSF FACILITIES 2. ORGANIC TOXICITY CHARACTERISTIC 3. MARYLAND TOXIC AIR POLLUTION REGULATIONS 4. NESHAP - BENZENE RECONSIDERATION 5. IAND DISPOSAL BAN 6. VOC REGULATION REVISIONS 7. RCRA DEFINITION OF "TANK1* 8. REPORTABLE QUANTITY ADJUSTMENTS 9. BURNING OF HAZARDOUS WASTE IN BOIIERS FOR ENERGY RECOVERY ASBESTOS NESHAP REVISIONS 11- OIL POLLUTION PREVENTION REGULATION 12. DISTILLATION N5PS 13. SOCMI REACTOR NSPS 14. SMALL BOILER NSPS 15. REFINERY WASTEWATER SYSTEMS NSPS 16. AIR TOXICITY CHARACTERISTIC FOR HAZARDOUS WASTE H O 4-12-89 Rev. 4-19-89 VAB.0001125141 ABSTRACT: EPA has issued regulations which limit the discharge of toxic pollutants from organic chemicals, plastics and synthetic fibers manufacturing facilities to United States waters and publicly owned treatment works. IMPACT: Wastewater discharged to the Baltimore City sewer will need to comply with strict concentration limits for 47 listed chemicals by 11/90. Pertinent limits include: . Benzene - 57 ppb monthly average, 134 ppb daily maximum. . Toluene - 28 ppb monthly average, 74 ppb daily maximum. . Phenol - 19 ppb monthly average, 47 ppb daily maximum. . Chlorobenzene - 142 ppb monthly average, 380 ppb daily maximum. . Methylene chloride - 36 ppb monthly average, 170 ppb daily maximum. ENDING ACTION STEPS: . Complete design, construction and successful startup of all projects identified in the plant's compliance plan by 11/90. . Purchase the GC/MS and provide lab space, manpower and analytical methods to operate it by 11/90. . Submit quarterly progress reports to the City. . Institute process monitoring and control procedures. 4-12-89 Rev. 7-7-89 VAB.0001125142 page 1 of 2 ABSTRACT: EPA has proposed to expand the criteria for identifying ^ . 4t 4* * I ^ ^ ft l Final 6/86 Earliest date - 8/89 Probable date - ?/90 6 norths after final IMPACT: This regulation will have a major inpact on nearly every Mary wastes which are currently nan-hazardous could become classified as hazardous wastes. Any treatment, storage and facility which complies with RCRA facility standards. Noted The following wastes at the Baltimore plant will become subject to this new hazard identification criteria. . Wastewater solids, including acid pit spoils. . Slip solids. . Excavation dirt. . Trash. . Tank bottoms stored in excess of 90 days. . Any material which is spilled or leaked onto or into the ground. Pertinent thresholds are expected to be 0.5 ppm benzene and 1,000 ppm toluene. Liquids will be analyzed directly for hazardous constituents, whereas solids and sludge will be extracted and analyzed using the Toxicity Characteristic leaching Procedure (TCLP). FENDING ACTION STEPS: . Complete construction and startup of Phase I of the SOB frac tionation improvements. Design, construct and startup Phase II of the SOB fractionation inprovements if necessary. . Purchase the GC/MS, headspace analyzer and zero headspace extractor, and provide lab space, manpower and analytical procedures to operate this equipment by the effective date. . Stabilize wastewater solids and acid, pit spoils off-site and close the jersey barriers operation if the OTC effective date precedes start-up of the pretreatment standard projects. VAB.0001125143 2. (cant.) SENDING ACTION STEPS (cant.) . dose out the slip and remove the dam. page 2 of 2 . Develop procedures to clean out tanks within 90 days of removal from service. out solids as hazardous waste. permanent DPA slurry operation. This will likely involve a 4-12-89 Rev. 4-19-89 VAB.0001125144 3. MARYLAND TOXIC AIR FOUHE1GN REGOIATICNS page 1 of 2 ABSn&CT; Facilities which discharge listed toxic air pollutants (TAPs) must quantify TAP emissions and demonstrate that ambient TAP concentrations outside of the facility do not exceed health- Final and highly All 5/88 8/88 - 7/90 - 7/92 IMPACT: Preliminary modelling indicates that benzene emissions are impacted by this regulation. All other TAP emissions should screen-out without any additional controls. The plant will need to install Best Available Control Technology (BACT) on all benzene emission sources as follows. . Collect, store and treat benzene contaminated wastewater in closed processes. BACT will probably be the Refinery Wastewater . Eliminate venting from benzene containing storage tanks. BACT will be the Volatile Organic Liquid Storage New Source . Tie-in all remaining benzene containing tanks, vessels and vents (excluding D-201) to the VCS or other appropriate control . Maintain compliance with the benzene fugitive emissions NESHAP. A compliance plan can be submitted by 7/1/90 if compliance cannot be obtained by that date. Modelling studies for benzene, chlorine and hydrochloric acid must be submitted by 7/1/90. Modelling studies for toluene and xylenes must be submitted by 7/1/92. PENDING ACnCN STEPS: . Complete construction and startup of the VCS tank monitoring project and follow-up with necessary improvements. . Provide benzene emissions controls for T-185 tank, the new wastewater stripper, the new process sewer, the new wastewater transfer tanks, T-150 tank and the weak AICI3 liquor tanks. 4-12-89 Rev. 7-7-89 1 VAB.0001125145 I 3- (cent.) Page 2 of 2 PENDING ACTION STEPS (cont.) . Rencdel anticipated and current (as of 7/90) benzene, chlorine, and hydrochloric acid emissions by 7/90. . Submit a benzene emissions reduction occpliance plan by 7/90 and a special permit application if modeling does not screen- 4-12-89 Rev. 4-19-89 VAB.0001125146 ABSTRACT: EPA must reconsider NESHAPs for all benzene sources as a result of the recent NRDC vs. EPA vinyl chloride decision. Target benzene sources include LAB plants, benzene storage tanks, benzene fugitive sources and benzene containing wastewater treat ment units. TIMETABLE Fined 9/89 ?/90 IMPACT: Ary additional Federal benzene emissions requirements are not expected to exceed requirements posed by Maryland's Toxic Air Pollutant regulations. However, additional recordkeeping, monitoring and enforcement are expected based on historical NESHAP FENDING ACTION STEPS Proceed with Maryland toxic air pollution steps. Monitor the progress of PA NESHAP activities. 4-12-89 Rev. 4-19-89 VAB.0001125147 5. IAND DISPOSAL BAN ABSOBCT: Hazardous wastes are to be banned from land disposal in accordance with a schedule specified by RCRA. Hazardous wastes 'which exhibit the organic toxicity characteristic will be banned from land 6 months after promulgation of the organic * it % _________________________________________________* ________i_ J _______ Final Same as OTC final action Same as OTC effective Immediate when final IMPACT: Unless a variance is granted by EPA, wastes which are hazardous because of benzene contamination will be banned from land disposal on the effective date of the organic toxicity (6 months promulgation). which are disposed of on land include: . Tank bottoms with lew BIU value. Treatment alternatives will need to be identified for any such PENDING Acne** STEPS: locate incineration or other treatment capacity for wastes subject to the land disposal ban. Wastes which will most likely be subject to the land disposed, ban include benzene dryer molecular sieves, spent AICI3 liquor carbon, spent HC1 carbon and benzene contaminated tank bottoms. 4-12-89 Rev. 4-19-89 VAB.0001125148 6. VOC REQOIAIICN REVISIONS ABSTRACT: EPA has instructed Maryland to revise its VOC regula tions in order to further reduce hydrocarbon emissions in the Baltimore area. Maryland will adopt piecemeal changes throughout IMPACT: Several changes are expected which will impact the Baltimore plant. . The VOC storage tank MSES will be adopted as the standard for all VOC storage tanks in the Baltimore area. . The 200 lbs/day VOC emission control cutoff will be lowered to 100 lbs/day. The STXS plant VOC emissions inventory is currently 135 Ib/day. . Seme type of fugitive emissions monitoring program will be Once any of these changes are adopted, a compliance plan can be submitted if additional time is needed to attain compliance. PENDING ACTION STEPS: negotiate new requirements with the AMA. . Implement STXS plant controls as required. . Submit compliance plans as required. 4-12-89 Rev. 4-19-89 VAB.0001125149 7. RCRA EEFTNITICN OF TANK*' ABSTRACT: This isnp involves a troublesome EPA interpretation of an existing regulation which is resulting in the development of a new regulation. In two separate proceedings (EPA vs. Brown Wood, EPA vs. Kdppers) EPA has alleged that structures which require earthen backfill for structural support are surface iinpoundtnents and not tanks. Opposite decisions were obtained on these cases, leaving a final decision to the Administrator of the EPA. The EPA has subsequently announced that it intends to promulgate a new FORA definition of "tank" throu^i the rulemaking process. TIMETABLE: 10/89 IMPACT: Several inground concrete units on-site may became classified as surface impoundments if earthen backfill is shown to provide structural support. Surface impoundments which contain hazardous waste must obtain KCRA permits and be provided with secondary containment, leak detection, leachate collection and groundwater monitoring. In addition, the land disposal ban for wastes with a pH less than 2 is already in effect. FEUDING ACTION STEPS: which can be made to any such units. . Provide structural revisions or secondary containment if required. 4-12-89 Rev. 7-7-89 VAB.0001125150 8. REPCKIABEE QUANTITY ADJUSTMENTS ABSTRACT: EPA has preposed to adjust reportable quantities for certain carcinogens, including benzene. The reportable quantity for benzene will potentially be lowered from 1,000 lbs to 10 lbs. With limited exceptions, releases in excess of a reportable quantity must be reported to the National Response Center, the Action Proposal Final Date 3/87 ?/89 IMPACT: A continuous release report for benzene emissions will have to be made annually. Nan-continuous release reporting will have to be made for sudden releases in excess of the reportable quantity. F991DEENG ACTION S . Annually report to the National Response Center continuous benzene releases from storage tanks and wastewater treatment units in excess of 10 lbs/day. . Develop and inplement procedures to immediately report non routine benzene emissions in excess of 10 lbs. 4-12-89 Rev. 4-19-89 VAB.0001125151 9. BURNING OF HAZARDOUS WASTE IN BOUERS FOR ENERGY RECOVERY ABSTRACT: EPA has proposed stringent standards for boilers which bum hazardous waste for energy recovery. In addition, RCRA TUMbTAHTK ; Action Proposal Final Date 5/87 ?/90 Effective 6 months after final IMPACT: This regulation will have no impact on the Baltimore plant if waste hydrocarbons transferred to the fuel oil tank remain non-hazcirdous. PENDING ACTION STEPS: Proceed with SOB fractionation improvement plans. 4-12-89 Rev. 7-7-89 VAB.0001125152 TTMigrararig; Action IMPACT: Changes to the asbestos waste handling and storage operation by T-l tank could be required. Asbestos objects such as FENDING ACTION STEFS: . Monitor development of this regulation. . Continue to aggressively remove asbestos from the Baltimore plant. 4-12-89 Rev. 4-19-89 ! VAB.0001125153 I 11. OIL FOIIDT1CN FKEVENTTCN KEGUIATICN ABSTRACT: In response to the Ashland Oil spill incident, EPA is reviewing the adequacy of existing oil pollution prevention regulations. A task force has developed reccranendations which are to be adopted in two phases. Final ?/90 IMPACT: Unknown FENDING ACTION SEEPS: Monitor the development of this regulation. 4-12-89 Rev. 7-7-89 VAB.0001125154 new and modified distillation units. TTMITraRTR; Action Proposal Fincil Effective Date 12/83 Immediate when final for sources constructed after 12/83 IMPACT: This regulation will control hydrocarbon emissions from W-l and W-6 tower, and airy other new distillation units which vent to the atmosphere. FEUDING ACFICN STEPS: Monitor the development of this regulation. 4-12-89 Rev. 4-19-89 t VAB.0001125155 i I' TTM^TTAHTlRit: Action Proposed Final Effective Date * * * IMPACT: Qnoe proposed, any new reactor will become an affected facility. Emissions from affected reactors will be regulated by PENDING ACCrCN S Monitor the development of this regulation. 4-12-89 Rev. 4-19-89 VAB.0001125156 ABSTRACT: EPA is developing a New Source Performance Standard for new and modified small boilers (less than 100 M* BKJ/hr). TTMRTAKTF; Final 6/89 9/90 Immediate when final for sources IMPACT: After proposed, art/ new or modified snail industrial boiler will be regulated by this NSPS. FENDING ACTION STEPS Avoid the need for a third boiler, if at 4-12-89 Rev. 4-19-89 VAB.0001125157 15. REFINERY WASTEWATER SYSTEMS NSPS ABSTRACT: EPA has issued a New Source Performance Standard for new and modified petroleum refinery wastewater systems. The NSPS TIMETABLE: Action Proposed. Final Date 5/87 11/88 IMPACT: This NSPS does not directly impact the Baltimore plant, however it is likely that EPA will follow-up with a SOCMI waste- NSPS. Maryland will probably consider this NSPS to be Control Technology units to Maryland's toxic air pollution regulation IENDlEMS ACFICN STEPS: Proceed to install a closed sewer and wastewater collection system as currently planned. 4-12-89 Rev. 7-7-89 VAB.0001125158 16. AER TCKJCTTY CHARACTERISTIC FOR HAZARDOUS WASTE ABSTRACT: EPA intends to develop test procedures and threshold concentrations for wastes which contain volatile hazardous constituents. Wastes which contain threshold amounts of listed organic chemicals will be classified as hazardous wastes. This new characteristic will supplement the organic toxicity TIMETABLE: Action Final IMPACT ? > will have no impact are set at lcwer levels than the TCLP PENDING ACFICN STEPS: Monitor the develconent of this reoulation 4-12-89 Rev. 4-19-89 VAB.0001125159 With completion of projects currently underway and planned for 1990, the plant personnel feel they will be in relatively good shape with the exception of one major potential expenditure. The possible need for External Steam Stripping (as opposed to current In- Reactor Stripping) of product to remove Residual VCM is a potential $20-30MM item. Current regulations do not force the change, but it is anticipated that regulations will tighten sufficiently within the next five years to require it. It is believed that major resin competitors (possibly excepting Air Products) already use this technology. Georgia Gulf recently voluntarily agreed to a lower residual level than our current practice will achieve. Therefore "Best Available" treatment has a now (and unfavorable to Vista) definition. A Vista team is currently assessing this situation to develop a recommendation with expected proposal early calendar 1990. With the exception of a major project such as External Stripping, plant personnel believe that staffing is adequate to address anticipated project work. A question exists concerning administrative requirements such as communication, training and legislative involvement implied in the corporate policy statement. For purposes of completeness, cost estimates should be performed for the anticipated project list. VAB.0001125160 ABERDEEN ENVIRONMENTAL PROJECT AGENDA Proiect___________________________ Area Budgeted Projects New Module Piping Upgrade TC Wastewater Compliance Phthalic Anhyd. Waste Elim. Plasticizer Process Improvements Plant Sewer Revisions Cost. M$ 59 1,350 125 175 300 Timing 1Q90 2Q90 2Q90 2Q90 3Q90 Remarks Maybe Maybe Maybe Anticipated Projects External Steam Stripping Reduction of Unknown Product Residuals Old Site Cleanup Alt. Disposal of Paper Bags With Hazardous Resid. Collection/Recycle of Non-Haz. Bags & Cardboard Recycle Water From Waste Treatment Alt. Handling RX culls & Vac Vent Dust Complete Decontamination Of Junked Equipment PVC Customer Scrap Recycle Asbestos Removal Transite Siding Removal Repair/Repl. Leaking Sewers 20-30,000 1-5 yrs. Long Term Long Term 5-6 yrs. 5+ yrs. 10 yrs. Contingency Long Term Unknown Ongoing Contingency 5 yrs. VAB.0001125161 E. Project List - OKC The Oklahoma City Plant has a situation very similar to Aberdeen in that they seem to be in. relatively good shape except for the Potential External Steam nm /cm K15uM"M') Internal resources are believed to be adequate to address the anticipated project load. Though claiming a short-term focus, management seems to have for several years been looking to future requirements and generating creative solutions That sort of sustained effort is key in achieving cost e ffective performance VAB.0001125162 A number of issues or areas requiring further work are listed below. In many cases, agreement on philosophy is required, after which technical and implementation efforts will follow naturally. In a minority of cases the issue to be resolved is technical only. 1. Degree to which smaller businesses, such as Blane, Premiere and Vycom, will be accountable against corporate policies and programs. This is a thorny issue involving staffing, capital, margin and competitive considerations weighed against liability, publicity and consistency questions. The solution would seem to include combinations of further distancing these operation from the rest of the organization from a liability standpoint, providing additional support from headquarters and working togther to clearly define expectations. 2. Resolution of the perception that environmental jobs by their nature will result in a "dead end" career path. This long-standing concern could be addressed from several standpoints. The broadening of environmental responsibility throughout the organization will help. This is addressed both directly and indirectly throughout this report, including the Corporate Environmental Policy. It is suggested that management and supervision watch for opportunities to interact with environmental professionals and to recognize positive contributions. A challenge also exists for environmental professionals to move away from the "siege mentality" and to deal with managers on a non-emotional basis. Part of the problem is that it is assumed (whether or not correctly) that one would operate in other jobs similarly to the one currently held. Many other jobs lack the "hammer" of regulatory development to influence action in the organization. If a manager has seen little evidence of an individual's capability to influence without a hammer, he may question whether the capability exists. 3. The general issue of product liability is purposely not addressed in this report. ^ Involvement of Vista's International businesses in corporate environmental planning. NNC, NAA and the Indonesian Alcohol Operation contain elements of the smaller business question, but are probably of less liability concern due to being non-domestic joint ventures none of which are majority owned by Vista. However, fairly extensive trading and direct export sales activities also exist. Since differing laws and standards exist in each location in which business is done, the question of prudent training and of Vista's International activities may require additional work. This could be an appropriate area for use of one or more consultants to assess the situation. VAB.0001125163 5. A related matter is the concern that foreign companies operating under less stringent regulations may obtain a competitive advantage over domestic producers such as Vista. This might be an issue appropriately addressed through the several trade organizations to which Vista belongs. Among these are Chemical Manufactures Association (CMA), National Petroleum Refiners Association (NPRA), Society of Plastics Industry (SPI), Vinyl Institute, Soap and Detergent Association (SDA) . Within each of these and other industry groups, various environmental, safety and trade issues are included among the agenda items. 6. PVC recycling is potentially of interest to Vista and certainly to the industry. Plastics recycling in general is a media issue due to the developing crisis of lack of space in municipal landfills. While numerous studies indicate that plastics are a small part of landfilled trash, this portion is essentially there forever once buried. (Other studies have shown that newspapers and food don't biodegrade either in some landfills, but that is a technical irrelevancy to Environmentalists.) Vista is currently working with several companies through the Vinyl Institute to develop a workable system for collection of PVC containers from consumers and recycle of that plastic into another product such as pipe. This could be a joint demonstration plant with a 25MM lb./yr. capacity. The Polymers Business Area is leading this continuing effort. 7. Heavy metals, such as barium, cadmium and lead in PVC compounds/dryblends. This issue stems from redefining what materials will be classified as "hazardous" in the future. Though an industry issue, it may offer an opportunity for Vista to achieve a competitive advantage if reformulation work in progress can produce a product line free of these "bad actors" without noticeable loss of performance in customer applications. In the extreme case, together with flame, smoke and other PVC "safety" issues someone with breakthrough formulation technology could setup a marketing coup similar to the DuPont Freon situation. By publically dropping and, by inferrance, denouncing freon after having developed the only viable (though lower performance) substitute, DuPont may have the market essentially to itself for some period of time. In any event, a significant R&D activity will probably be required at some point and smaller compounders may be at a disadvantage. The decision to be made is whether to attempt to lead or follow. 8. Integration of environmental decisions into mainstream business activities. This is a recurring theme throughout the report and requires conscious acceptance by responsible managers. It is suggested that applicable environmental plan review and revision be included as a topic on Business Steering Team agendas. This can provide a means for deeper involvement of R&D and support groups along with better integrated overall direction and priority-setting. VAB.0001125164 9. Environmental activities, programs and philosophies of domestic competitors is partially addressed elsewhere in this report. However, it is an appropriate item for ongoing follow-up and documentation. Limited information may be gathered from published documents such as lOK's, permit filings, enforcement actions, SARA Title III filings, news releases, . However, these sources are incomplete and may be misleading or fail to address the specific areas of interest to us. A more reliable and timely sources is informal conversations with our counterparts in those organizations via trade group meetings or other circumstances which present on opportunity. Quite a bit of information is likely gathered and then not fully utilized now due to lack of documentation and assembly. It is recommended that gathering and compiling this type information be institutionalized as follows: a. Managers and employees be encouraged to gather and write down information which may be obtained from normal contacts. b. This information be routed to one group which has the responsibility to periodically compile and publish an assessment. This could be the Environmental group or any one of several others. 10. Other items previously mentioned in the section dealing with "Studies" include: a. Assessment of DOT pipeline regulations. Consultant assistance is recommended. Based on the findings, an implementation plan may need to be developed. Individual plants now have the pipeline responsibility, so implementation may proceed naturally once requirements are defined. b. Resolution of whether External Stripping is required for reducing residual VCM in PVC. As previously mentioned, a Vista team is currently evaluating this $40-50MM question. Most other PVC producers appear to have previously made the switch for large reactors. The expenditure is included in recapitalization forecast capital for 1991. c. Assessment and plan development for Lake Charles air emission with assistance from consultant recommended. This would be a smaller and perhaps less expensive version of the Wastewater Project effort. d. Resolution of Baltimore Process Revisions (PACOL front end). As previously mentioned, a team is doing a preliminary assessment of this $70MM project. The outcome of a decision whether or not to proceed could have significant impact on environmental capital and expense requirements at Baltimore. VAB.0001125165 11. A mostly technical issue is that of assuring the integrity of underground sewer systems. This an decision similar to that made in the Wastewater Project to convert ponds and lagoons to above-ground tanks. That decision was prompted by regulations designed to protect soil and groundwater from contamination due to seepage or leaks. Similar regulations for sewers do not now exist, but might be anticipated eventually. It might be wise for new construction or as opportunities occur to consider either putting sewers above ground or in lined trenches a la Baltimore. This is unfortunately a multimillion dollar proposition, but so is remediation if the integrity of these systems cannot otherwise At the least, system integrity should be assessed by each location on a periodic basis. 12. Portions of the Plan propose marketing solutions as a means of dealing with specific waste streams. These solutions may or may not be entirely realistic, but the potential exists for substantial savings of capital and/or expense if the efforts are successful. A summary is provided below for information and input into priority-setting. The streams are grouped into three categories. a. "Must Do Something" - The current situation is or will soon become unacceptable and marketing the stream is a desirable option vs. alternatives. b. "Improvement Opportunity" - While no external forces are currently acting to change how the stream is handled, the opportunity for cost savings or margin improvement exists. c. "Contingency" - Current handling is acceptable, but loss of that market would create a significant problem. i w t VAB.0001125166 INCENTIVE TO MARKET PLANT STREAM Must Do Something LCCP Ethylene Spent Caustic ANNUAL VOLUME (MMLB) 17.0 LCVCH Incinerator HCL 11.0 CAPITAL AVOIDED S4-6MM S500M Improvement Opportunity ABD Stormwater Pit #1 Solids 0.1 ABD LCCP Stormwater Pit #2 Resin 0.1 Pressed Biological Solids 16.6 - ? LCCP LCCP LCCP LCCP Molex Sieves - Current 1nventory Molex Sieves - Every 3-5 years Ethanol Solution 0.7 0.4 Total 3.8 - *0.1M-S3MM Quench Unit Solids 8.4 * DISPOSAL COST AVOIDED OPERATING COST AVOIDED EST. SALES REVENUE $1MM/Yr. S4HM/Y r. ? $1.8MM/Yr. 7 IV * $3M/Yr. S3M/Y r. S500M/Yr. * - ? ? ? S185M S28M/Yr. STG. ? S120M - ? 0 If Remains Burnable S500M/Y r. ? S270M 1 * REMARKS Problem in Wastewater System as-is. Current ly neut ra l i zed wi th l imestone causing fune problem and sol ids disposal. Caust ic neutralization option is capitaL and operating cost. Offsite disposal is S4MM option. Annual accunulation of compound. Hazardous due to metals content. Annual accunulation of resin. Non-hazardous currently. Non-hazardous landfilled now. Substantial cost increase if it becomes hazardous. Based on non-hazardous landfill. One sieve replacement. a Currently burned. Based on non-hazardous landfill. VAB.0001125167 Page 2 PLANT LCLAB STREAM Alkylate Bottoms ANNUAL VOLUME (MMLB) CAP1TAL AVOIDED 4.0 Excess DISPOSAL COST AVOIDED OPERATING COST AVOIDED EST. SALES REVENUE $1-2.5MM/Yr. (S204M) $840M LCLAB Acid Soluble Oil (ASO) 1.1 ? $275-700M/Yr. ($42M) ? Contingency LCCP MeCl Spent Hcl 13.8 $1-2MM ? - ? LCCP Recovered Oil From 17.9 ? * 9 ? Wastewater LCCP/LCLAB LCVCM Nickel and Paladium Catalyst Variable Light and Heavy Ends 1.1 LT > 9.9 Hvy> N/A $0.3-7.25HM N/A $5.5MM/Yr. N/A Varies $4.5-1,1MM/Yr. ? REMARKS Currently sold to refinery. Could be burned as fuel at same value until regulations change. Then would requi re capital or incineration. Currently burned as fuel. If regulations change as expected, would require incineration or capital to modify heaters. Non-issue based on MeCl shutdown date. Disposal problem otherwise due to high organic content. Currently sold to Conoco Refinery as part of HAD stream at $920M/Yr. revenue. If contract volume limit is enforced, this stream or the actual HAD stream from ethylene will need another home. Currently sold for precious metal recovery based on assay. Should not become an issue. Currently sold. Light ends to Vulcan for $55M/Yr. revenue. Heavy ends go to PPG at net negative revenue. One Alt. is $7.25MM capital and$1.lMM/Yr. OP. cost for UOP technology to convert streams to Anhydrous HCl for recycle in process. On-site incineration is another option at $0.3MM VAB.0001125168 Page 3 PLANT STREAM ANNUAL VOLUME (MMLB) CAPITAL AVOIDED ABD Vacuum Vent Dust 0.5 > Millscrap 1.3 > S0.4MM VRP 1.6 > ABD Pond Resin 1.7 $0.1MM ABD Reactor Culls 0.5 > $0.3MM Sifter Overflow 0.08 > ABO LCCP Ethylene Methyl Chloride Normal Paraffin De-Box Resin 10.6 HAD LAC Butadi ene P&P MOG HOG 18.1 26.6 33.6 21.3 60.2 133.3 Spent HCL Spent Sulfuric Acid 13.8 1.1 MR Solvent (Raffinate) Unstabilized Gasoline N.P. Off-gas LPA Solvent 957.0 151.1 10.8 148.2 ' - - - DISPOSAL COST AVOIDED OPERATING COST AVOIDED $35M/Yr.> S37M/Y r.> S48M/Yr. $2M/Y r. *46M/Yr. $2M/Yr. S32M/Y r.> $2H/Yr. > S280M/Y r. S5M/Y r. - EST. SALES REVENUE REMARKS capital and $4.5MM/Yr. OP. cost. THis also requires additional S0.5MM capital for caustic neutralization. Offsite incineration is $5.5MM/Yr. $17M Current S200M Current $640M Current If current markets were lost, capital and operating cost reflect a scrap compound line. Disposal is option in interim. S435M Current Currently sold. Alternate capital to prevent material reaching pond to improve marketability and margin. $10M $12M Current Cur rent Currently sold. Alternate capital for Grinder & Dryer to market beyond single current customer. S3.2MM Current Currently sold. Probable non-issue. S0.5-7.0MM S0.5-5.0MM S2.0-5.0MM S2.0-5.0MM $0.5-2.0MM $1.0-3.0MH Burnable N/A N/A N/A Burnable Burnable S0.9MM Current $2.9MM Current S3.0MM Current S2.8MM Current S3.0MM Current S10.2MM Current S1.0-2.0MM Undetermined $0.25-1.OHM $0.5-1.0MM Undetermined Undetermined Undetermined Undetermined N/A N/A Burnable N/A N/A Subtracted from Raw Cost 73.2MM Current 11.6MM Current N/A 11.3MM Current Page 4 PLANT Ethoxylation Alcohol STREAM ANNUAL VOLUME (MMLB) Off-spec Mixed Ethoxylate 1-2 SSO Thermal Olefins Solvent & Stripper Overhead Growth Reaction Hotwash Solvent Butanol Fuel Gas 40.0 92.2 3.0 11.8 12.7 CAPITAL AVOIDED Undetermined DISPOSAL COST AVOIDED N/A OPERATING COST AVOIDED EST. SALES REVENUE S0.3-0.7MM Current REMARKS S1.0-7.0MM $4.OMM Undetermined $0.2-0.5MM Undetermined N/A N/A Undetermine Burnable Flared $6MM Potential 4.9MM Current 0.2MM Current 3.1MM Current 0.1MM Current j VAB.0001125170 13. Development of contingency plans. A number of non-primary-product streams are currently being sold to Conoco or others for blending or extraction of valuable components. In most cases, the loss of these markets would result in significant containment or treatment/disposal problems if alternate markets were not quickly available. Assuming success in marketing additional streams as indicated above, the potential problems increase. Developing and documenting a set of contingency plans may be a worthwhile team project given that production of Vista's primary products could be impacted on short notice. 14. Included "for the record" are the following items for which appropriate actions are already underway: a. Groundwater Cleanup b. Definition of waste emissions. minimization goals including fugitive air 15. An essentially technical issue is that much work remains, particularly at Lake Charles, on resolution of wastewater biotoxicity. The proper action seems to be underway, but it should be noted that the Wastewater Project cannot presently be guaranteed to solve the problem. To date, no Lake Charles plant wastewater has passed this "water flea survival" test and the causes are not yet isolated. Therefore the requirements are undefined at this time. 16. Chemical emergency response readiness. Other than being referred to in the Environmental Policy, this is not specifically an environmental issue. The Exxon Valdez situation highlights the difficulty of dealing with transportation-related incidents in remote locations. Plant incidents, while the potential may be greater, seem to raise fewer concerns due to the proximity of equipment, people and supplies to deal with the situation. A joint manufacturing/S&T team may be appropriate for addressing offsite response ability and needs. 17. Environmental manpower has previously been evaluated by a Team and recommendations were issued in late 1988. A summary and current status is included below. It should be noted that some overlap may exist between these recommendations and the Lake Charles engineering requirement identified by the project list. However, my sense is that the needs identified are essentially separate and may be additive. Further resolution is required. 1t VAB.0001125171 EXECUTIVE SUMMARY ENVIRONMENTAL MANPOWER TEAM (Nov. 1988) I. BACKGROUND: As a result of discussions at the Vista Annual Environmental Meeting, a team was formed to evaluate and recommend changes to address Environmental Manpower staffing needs. Pursuant to this goal extensive data were collected and analyzed. Based upon the results of the data analysis, the team recommends a total of five permanent positions be approved to assure our immediate compliance goals are achieved. A second tier of four dedicated positions are recommended for purposes of maintaining environmental program continuity and addressing longer term needs. Attrition in the environmental area is a significant area of vulnerability for Vista. Beyond immediate needs the team identifies two other significant deserving attention. Environmental awareness at many levels is lacking, particularly among non-environmental/non-operational personnel. Environmental training is a fundamental need at all levels surveyed. Unless environmental awareness is elevated, both these interrelated areas will be a long term detriment to the environmental, engineering, and operational efforts of the company. A third tier of recommendations involving temporary engineering assignments is made to address these areas. Further work is needed to expand awareness and training into the business and marketing areas, and the recommendations within this report address this problem. The recommendations are made to respond to immediate compliance demands, well as to modify the organization. The intent is to ultimately reduce the need to further professional environmental manpower, through addressing environmental at the source, rather than awaiting development of a crisis situation. II. Recommendations: The Team is making recommendations in three areas of priority. The three groupings reflect a phased approach to satisfy immediate and longer term needs. The Priority I recommendations are based on immediate manpower needs to satisfy existing short term compliance demands. We view these as recommendations to assure a minimal level of achievement of our compliance goals. Priority II needs reflect both longer term demands as well as insuring program continuity as personnel changes occur. Priority III recommendations reflect the company's need to create environmental issues awareness Process Superintendents, Plant Managers, Business Area and Marketing personnel, or serve in other supervisory capacities. VAB.0001125172 1 I' Where an immediate manpower need is recommended in the near term. No further assessment was performed to determine whether additional manpower, beyond the scope of the recommendation, is needed at any specific location. Further assessment by each individual location is needed for identification of manpower needs beyond the scope recommended by this report. Staffing Additions: Priority I To Assure Compliance (1 to 6 month implementation) Status 9-89 D LCCG: LCCP/LAB - Add 1 Senior Environmental Coordinator LCVCM - Add 1 Environmental Coordinator Offer Outstanding Done Houston Environmental - Add 1 Program Manger OKC - Add 1 Environmental Coordinator S&T - Add 1 Environment Coordinator* Done Done No Progress Priority II To Assure Program Continuity (6 to 12 month implementation) Status 9-89 Baltimore - Add 1 Environmental Coordinator Blane - Add (or dedicated 1 Environmental Coordinator Houston - Add 1 Environmental Coordinator R&D - Add (or dedicated 1 Environmental Coordinator Done ti VAB.0001125173 I To: Paul Gowan From: J. C. Ledvina August 11, 1989 Subject: Environmental Planning at Other Companies Paul, At your request, I have phoned several contacts at other companies to discuss the degree to which they are proactively spending money in anticipation of future environmental regulations. A number of people within Vista have expressed an interest in knowing whether other companies are contemplating or doing projects similar to the LCCC "Black Box*'. This survey is an attempt to provide some perspective an that issue. From the information that I was able to obtain it appears that Vista behind BF Goodrich. Mobay. Borden, Rohm & Haas, Union Carbide and C=> i mpnundmen ts. We are at Georoia-Gul f and DuPont. We are ahead of Conoco and Oxy In the survey, I askgd <~nntacts what their companies were doing about surface impoundments in anticipation of the Toxicity Characteristic (TC) being promulgated. Since the TC regulation is a significant part of the reasoning for Vista's work on the "Black Box", asking what other companies are doing an this seems to be a reasonable basis for evaluating our degree of proactivity relative to other companies. Following are comments by company to the question "What is your company doing about surface impoundments in anticipation of TC?" Georgia-Gu 1 f - Will probably have a problem with TC at one site. They are in the process of testing wastewater at that site to determine if constituents are present above the an tic i (Da ted regulatory level. At another plant, source control work was done to reduce constituent levels in wastewater below regulatory levels. Georg ia-Gu 1 f does not have an active project to replace surface impoundments with tanks yet. However, surface impoundments that were considered environmental problems have been replaced with tanks. Impoundments, such as those in the wastewater treatment unit that are causing no known environmental problem are not replaced. Ga-Gulf will wait to seen how the TC regulations develop. Dxv -- The Oxy corporate office is not pushing the plants an pond replacement. The Pasadena plant has proposed money in the 1990 budget to do something on TC/surface impoundmen ts. They don't know what that "something" is yet. My contact at the Oxy/Cain Chocolate Bayou Plant says that Oxy seems to be disorganized on this issue. Conoco - Conoco is at the evaluation stage. They are doing analytical work to determine which surface impoundments will be impacted by the TC. No proactive surface impoundments have been done. AiC_PrgduCS ~ Have two surface impoundments that may be impacted. My contact was not sure what they were going to do, but he isn't the person most knowledgeable on this subject. IXjPontL - My contact was unaware of surface impoundment replacements within EXjPont that were done in anticipation of regulations. A few years ago, the Chambers Works installed,a tank-based wastewater treatfrent plant but that was before TC was an issue. However, tanks were chosen becauge of a perception that they were more environmentally acceptable than surface impoundments. DuPont has done analytical work to characterize wastewater. They are installing a steam stripper an the Ethylene Unit at Sabine to remove benzene from wastewater. That project is currently under construction. The Cape Fear. NC plant is looking at getting out of surface impoundments but for reasons other than TC; apparently, to avoid groundwater contamination. VAjlcan - They have replaced some surface impoundments at Geismar. No Rohm & Haas - They closed out their Deer Park Plant surface impoundments except for two impoundments in the wastewater treatment plant. The wastewater treatment plant will need to be revised to meet the OCPSF effluent guidelines. When that occurs they plan to go to a tank-based system. They are doing feasibility studies and engineering now. The Deer Park Plant is planning to make each operating unit do primary treatment their wastewater before pumpino it in above ground sewers to the secondary. Mobay - This past May, Mobay took five surface impoundments out of service at their Baytown Plant and replaced them with above ground tanks. Plants Ws/,in Kansas City, and Bushy Park (PA?) replaced surface impoundments with tanks for reasons other than TC. Dow -- Dow is moving away from surface impoundments on storage of concentrated materials. They continue to operate impoundment-based wastewater treatment plants in their US facilities. They have replaced impoundments in a German plant and the Ft. Saskatchewan plant. Dow is looking toward the year 2000 and trying to predict what the regulatory situation wiJ^L be. Decisions on surface impoundments will be based on that prediction. biol -- They are putting together projects to but will not implement until 1 treatment svst their The tanks are out of PVC settling become firmer. equipped with double BF Goodrich - All surface impoundments at all plants, with one exception, have been taken out of service and replaced with tanks. The one exception is a pond that follows biological treatment and is used only occasionally for flood control. That pond will be eliminated later this year. Lbion Carbide - My contact is at the Texas City Plant which has several Company Ethyl BFG Borden Formosa Monsanto Shell Oil GA Gulf Dow PPG Carbide Hercules DuPont INDUSTRY ENVIRONMENTAL COST DATA Data Source Environmental Capital Expenditure ($MM) 1990 1989 1988 1987 1986 1985 Comments 10K 645 10K 1.7 10K 2.0 1.7 - 1986 Ann. Rpt. 17.2 23.4 (Taiwan) (Taiwan) 10K 65-75 36 1988 Enviro. O&O $207MM 10K 245 170 1988 Enviro. O&O $415MM 10K 10K 150 150 105 Fcst. Enviro. at 10% of Cap. Exp. ( Financed by Revenue Bonds ) 10K 30 27 26 19 Article 50-60+ $50-60MM is for wastewater at Texas City only. Article 30 3/4 of Enviro. total is for wastewater. Article 100-200 VAB.0001125176 INDUSTRY ENVIRONMENTAL COST DATA Comoanv Ethyl BFG Borden Formosa Monsanto Shell Oil GA Gulf Dow PPG Data Source 10K 10K 10K 10K 10K 10K 10K 10K 10K Fines Paid (M$} Old Site Cleanup Cost 398 in 1989, 395 in 1987 $11MM 1988 (+$38MM Accrual) 1000 in 1988, 90 in 1985 35 sites Cost? 80 plus 4-wk shutdown in 1985 $19MM in 1988, $23MM in 1987 103 sites (Fcst $120MM after tax at one site) 204 in 1987 225 in 1987, 36 in 1986 46 Sites $25-30MM/yr. Fcst. Consent Decrees 6 1986-89 2 1985-88 1 1987 2 1987 2 1987 2 1986-87 VAB.0001125177 jiii'iUN i>* 111 "i I ' 4 * iv n~ i if. vim .ii^ ! i ,! ip ml p.nii . ll (. ij*'1 r vt ^.i.i miMM1 ' U' HLp.i m1--"tf ^vouv - PuftN i i I l I I i i l i I r i l i i j I I I i | I I I VAB.0001125178 Priority List The following proposal for the relative order in which environmental opportunities might be explored is intended primarily as a thought jogger. The actual order is likely to be different in many cases as a result of local issues or industry initiatives. ENVIRONMENTAL WASTE MINIMIZATION PRIORITIES 1. Meet Regulatory Limits 2. Groundwater Remediation 3. Reduce Hazardous Waste - Normal Production (Process, Supplies, Lab, Maintenance, Turnaround Contractors) 4. Reduce Potential for Hazardous Material (Product, Waste, Raw Material, Intermediate, etc.) - Spill/Release Old Site Remediation 6. Reduce Hazardous Constituents/Characteristics of Products 7. Reduce Non-Hazardous (Nuisance) Emissions - Dust, Smoke 8. Reduce Non-Hazardous (Visible) Emissions - Steam, Cooling Tower Vapor, Colored/Dirty Looking Water 9. Reduce Volume of Non-Hazardous Waste Leaving Plant Site 10. Reduce/Eliminate Storage of Non-Hazardous Waste On Site VAB.0001125179 li *>: niJ:ip m 'T+- M What is Waste? As the organization begins coming to grips with development of a waste minimization program, the definition of a waste is becoming an issue. Having heard many of the arguments and concluding that no definition is perfect or without exception, the following is proposed as a working model pending better insight: A waste is any material which enters a process and (A) remains or (B) leaves without a positive price tag on it. Recycled containers such as trucks and railcars are excluded. Under this definition, products and materials sold as byproducts are not wastes. Anything which goes into the air, ground, or water is a waste. Any byproduct which we pay someone to take is a waste. As an extreme, vented steam could be termed a waste, though obviously not a hazardous one. Catalyst sold for recovery of metal would not be a waste, even though it is likely that waste would be generated in the recovery process by others. If on the other hand, Vista paid someone to recover metal from catalyst to which we retained title, the waste from that process would be a Vista waste. As with any definition, loopholes can be found in this one. Purists would say that byproducts sold below raw material value should be termed a waste and that such things as dewatering of sludge to reduce volume are not true waste minimization efforts. No doubt some regulator will be address the issue one day. Until then, Vista should pick almost any reasonable basis and begin moving forward. In the end, the only impact of differing definitions will be the percentage magnitude of reportable improvements. Regulations and good business judgement will determine the degree to which resources are allocated toward the effort. Definition of 11 Pro-active11 Since words are subject to different interpretation, it might be useful to describe the intended meaning of "pro-active" as used in this report. PRO-ACTIVE - Taking action before being forced to do so by regulations. The intent, however, is to take such action only when indicated by sound business judgement to be more cost effective in the longer term than other alternatives. This might also include considerations such as enhancement of community or regulatory officials' perceptions of corporate responsiveness on a selective basis. Most "pro-active" opportunities are apt to come from a more complete review of possible alternatives when addressing a given regulatory issue. An example might be the cleanup and disposal of accumulated sludge in a tank. Option one might be to handle the situation now at a cost of $100 per ton. Option two might be to wait until next year when the sludge level interferes with normal operation. Option two is probably preferable given that limited information. However, if it is known that this particular sludge is scheduled to be re defined as hazardous waste a few months hence and that hazardous waste disposal will cost $600 per ton, the option one "pro-active" approach makes more sense, all else being equal. The same principal applies to proposed capital expenditures. Often, by making provision for future equipment additions or by attacking a waste at the source instead of later in the process, large benefits may derive from small incremental expenditures. By encouraging an assessment of the return on incremental dollars, more opportunities to improve cost performance may become visible. The day may arrive when 11 pro-active" comes to mean other than 1 good business practice, but in view of the magnitude of work required to simply stay current, that day may not be near for Vista. In preparation for discussions regarding taking that next step to "extremely pro-active", the following thought joggers may be helpful. ^:-.l Cri i irj I;.--: I -hl I'.n.-J-i. J t rtl r- ,| i ---u. VAB.0001125182 PRO Potentially Good P.R. Satisfies Sense of Morality If Correct, May Save $ Long Term Re-defines ''Best Available" which Becomes New Min. for Competitors Enhance Long-Term Competitive Position Via Efficiency Improvements Consistent with QMP Principles Directionally Minimizes Liability A Trading Chip In Regulatory Negotiations CON Will Not Get Enough Credit from Public Penalizes Current Earnings Some Competitors Will Not Follow Unless Forced by Regulation Some Foreign Competitors may not be subject to even the basic U. S. requirements Possible Low to No Immediate Return on These Discretionary Investments Debt Load Takes Priority Requires Leap of Faith from Relatively Successful Past Practice Hard to Sell on Businesslike Basis HI -i : - . im >.t- -r- I s 1. inn.- -.-nit-?:i.cvi( -tioetiHfrjLH mi yu J=T: = liUtmtt rip MF-rat: r'liaa-qi rjiraifr'-'1 :i--. VAB.0001125183 VAB.0001125184 i i-r.-. AGENCY EPA REGULATION CLEAN AIR ACT (CAA) UPDATE AREA AIR EPA RESOURCE CONSERVATION AIR RECOVERY ACT (RCRA) APPENDIX C REGULATIONS PURPOSE VOLATILE ORGANICS (VOC) FROM WASTE WATER TREATMENT SYSTEMS. IMPLEMENTATION TIMING 2 - 5 YEARS (BY STATES) EPA PRELIMINARY DRAFT APRIL *88 EPA FINAL DRAFT OCT. '90 ORGANICS FROM HAZARDOUS STG/TREATMENT WASTE STORAGE TANKS AND JUNE <89 AND IMPOUNDMENTS DISPOSAL SPRING *90 COMPLIANCE 2 YRS - VENTS 90 DAYS-LEAKS CONTROL STRATEGY EFFECT ON VISTA 1) REDUCE VOC 95% PRIOR TO AIR CONTACT AND RECYCLE /RECOVER. STATE BY STATE - MAY BE INITIALLY IN OZONE NON ATTAINMENT AREAS.PROBABLY AFFECT REFINERIES FIRST. 2) CONTROL VOC IN COLLECTION /TREATMENT SYSTEM. 1) IF WASTE STREAM HANDLED IS 10% OR MORE TOTAL ORGANICS ALL STATES - NEW EXISTING SOURCES (RCRA CURRENTLY EXEMPTS WASTEWATER TREATMENT SYSTEMS PERMITTING) [TANK EXEMPT, IMPOUNDMENTS OR BOTH?] (A) REDUCE EMISSIONS FROM ALL VENTS BELOW 3 LB/HR OR 3.1 TON/YR. CURRENT RCRA - VCM HVY ENDS TANK. OR (B) REDUCE ORGANIC EMISSIONS BY 95%. VAB.OOOl 125185 v CONT'D AGENCY REGULATION AREA SUPERFUND AMENDMENT AND REAUTHORIZATION ACT (SARA) TITLE III - COMMUNITY RIGHT TO KNOW NATIONAL EMISSIONS STDS. FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) AIR AIR 4 APPENDIX C REGULATIONS PURPOSE ANNUAL REPORTING OF INFO TO PUBLIC ON EMISSIONS TO AIR, LAND AND WATER CAA REQUIRES EPA TO ESTABLISH STDS WHICH PROVIDE AMPLE MARGIN OF SAFETY TO PROTECT HUMAN HEALTH IMPLEMENTATION TIMING CONTROL STRATEGY EFFECT ON VISTA (C) LEAK DETECTION /REPAIR PROGRAM FOR ALL PUMPS & VALVES 2) IMPOUND MENTS & TANKS CONTAINING UASTE1S GREATER THAN 500 PPM TOTAL ORGANICS (A) COVERED/VENTED TO REOUCE EMISSIONS 95% OR <B) WASTES PRETREATED TO REMOVE ORGANICS IN FORCE N/A COMPLYING DEVELOPMENT IN PROGRESS BZ, VCM ONLY ONES TODAY FUTURE * BUTADINE, EO BZ STG TKS a BALT. SLURRY DUMP FROM PVC REACTORS 400 PPM VCM VAB.0001125186 % AGENCY STATE OF MARYLAND REGULATION AIR TOXICS STATE OF LA. AIR TOXICS AREA AIR AIR EPA ORGANIC CHEMICALS, WASTE PLASTICS & SYNTHETIC WATER FIBERS (OCPSF) APPENDIX C REGULATIONS PURPOSE CONTROL EMISSIONS OF AIR TOXICS SUCH AS BZ CONTROL EMISSIONS FROM NEW INSTALLATIONS IMPLEMENTATION TIMING FY91 POLICY IN FORCE CONTROL LIST OF CONVENTIONAL AND PRIORITY POLLUTANTS FINAL DEC '67 IMPL. DEC <90 OKC, BALT. IMPL. W/NEW PERMIT ABD, LCCC. CONTROL STRATEGY EFFECT ON VISTA DETERMINE BY AIR EMISSIONS DISPERSIONS MODELING MOST REDUCE BE REDUCE BZ AIR EMISSIONS FROM BALTIMORE PLANT PER MODELING ALREADY COMPLETED NEW PROJECT MUST NOT CONTR1B. MORE THAN 1/42 OF TLV TO AMB. AIR AT FENCELINE AND NOT MORE THAN SPECIFIED RISK LEVEL FOR CARCINOGENS. DEMONSTRATE BY AIR DISPERSION MODELING. CURRENTLY EXCEED SOME LEVELS AT LCVCM AND LCCP. EXAM PROJECT DIRECTLY AFFECTEO. MASS LOADING LIMITS (BASED BEST AVAILABLE TECHNOLOGY) WILL APPLY ON RENEWAL OF NPDES PERMIT (SEPT 91) WILL REQUIRE 80 - 90% REDUCTION FOR LCCC. ALSO REQUIRES PRETREATMENT IF DISCHARGE INTO CITY SEWER SYSTEM. .. i i. - i' >y i-if- iH.-i i * 11 7-i+n-F"j Tir*i,hr- '-n-'r* r:lrhTj,w^rr ' .ijl- ivi'-N1 91 S-: t* `t r *1 :Jt. 4.- * if-tfrt'i'-- 'r-i fl-z -1- ---:TM It m "z-r.v I Ir * r- VAB.0001125187 1PJ**W)S^ AGENCY STATE OF LA. STATE OF LA. LEGIS/ EPA REGULATION REVISION TO SURFACE WATER QUALITY STANDARDS COMPILING STATUS & CONTROL STRATEGY FOR WATER TOXICS IN CERTAIN STATE WATERWAYS FOR SUBMISSION TO EPA CLEAN WATER ACT AREA WASTE WATER WASTE WATER APPENDIX C REGULATIONS PURPOSE PROTECT DESIGNATED USES OF STATE WATERWAYS IMPLEMENTATION TIMING ? ELIMINATE DISCHARGE OF POLLUTANTS INTO WATERS OF THE US. IN FORCE SUBMIT TO EPA 2/89 CONTROL STRATEGY EFFECT ON VISTA EXPECT TOUGHER THAN FEDERAL i EPA TO; 1) ISSUE EFFLUENT LIMITATION GUIDELINES STDS FOR newIexiSTING INDUSTRIAL DISCHARGES 2) ENSURE MAINTENANCE OF EXISTING WATER USES THROUGH UATER QUALITY STANDARD PROGRAM (TECHNOLOGY BASED) STATES TO: 1) DEVELOP LIST OF IMPAIRED WATERS (BIOTOXCITY) CALCASIEU RIVER AND BAYOU VERDINE '4' r^t# - '* >--n- - l--1-!-'* . . r_. [. *-piai> !'>* * -<-*. * **i f -i *'-v 11 5, xj -'rtF-JL' ' !'V lH llt-nWHi. t*iir I : l-|l ?- VAB.0001125188 &.h. AGENCY REGULATION AREA EPA TOXIC CHEMICAL WASTE LEACHING WATER PROCEDURE (TCLP) (PART OF RCRA) OTC TC STATE OF LA. NARRATIVE STANDARD GROUND WATER APPENDIX C REGULATIONS PURPOSE PERMITS IMPLEMENTED 6/92 FINAL 12/89 REDEFINES HAZARDOUS WASTE IMPLEMENTATION TIMING 2) IDENTIFY POINT SOURCES CAUSING IMPAIRMENT 3) DEVELOP INDIVIDUAL CONTROL STRATEGIES FOR EACH POINT SOURCE (PERMITS) 4) REVISE WATER QUALITY STANDARDS EVERY 3 YEARS SEPT 89? CONTROL STRATEGY PROHIBIT DISCHARGE OF POLLUTANTS INTO GROUND WATER ADOPTED EFFECT ON VISTA BENZENE, TOLUENE, EDC, VCM AFFECTED. IF NOT REDUCED TO TO PPB LEVELS, WOULD RENDER WASTE WATER TREATMENT SYSTEMS "HAZARDOUS WASTE IMPOUNDMENTS11 SUBJECT TO RULES REQUIRING HIGH COST LINERS, WASTE TREATMENT, REPORTING, ETC. fr !- V-Yf' -tJm :|h l-V 1-41 n H";'Iff `r T 1*^ A'l H1|. i-; rtf,I- . I . I V* -I' -wb-r p-; - i.. ii. .4 m>'-. a.-ii-i. **>*>.. -- h. -v 'f * i - -t :: n' iVT-T I U Plf*; Itf-HMIX- . - v b--fr VAB.0001125189 41- t V-- t: J`f*' -sir'll = Hi' hi 1:-l : t. >u ,,i ..mi K* AGENCY EPA REGULATION RCRA STATE OF LA. UPGRADE OF NONHAZARDOUS SOLID WASTE RULES EPA BURNING & BLENDING EPA RCRA * * 1 li-nrH- If- -w 4 -+t<> .r-| | ^d| -1-| Pt-i i AREA GROUND WATER APPENDIX C REGULATIONS PURPOSE MINIMIZE POTENTIAL FOR RELEASE OF HAZARDOUS MAT. FROM WASTE TANKS & IMPOUNDMENTS TO GROUND WATER IMPLEMENTATION TIMING IN PLACE DESIGN REQUIREMENTS GROUND WATER AS ABOVE NON-HAZARDOUS AIR? HAZ. WASTE REGULATE WHAT MATERIALS MAY BE BURNED AS FUEL HAZ. WASTE TANKS TO HAVE SECONDARY CONTAINMENT PROPOSED DRAFT SPRING 89 FINAL 12/89? SOME COMPLIANCE PERIOD BUT UNKNOWN FINAL SPRING 89 ANTIC. EFF SEPT 89 EXISTING 1flitIP'i 1 'SHW CONTROL STRATEGY CORROSION PROTECTION, SECONDARY CONTAINMENT, LINERS, LEACHATE COLLECTIONS, MONITORING EFFECT ON VISTA NONE-IMMEDIATE (CURRENT RCRA PERMITTING EXEMPTION FOR WASTE WATER TREATMENT UNITS) OTHERWISE REQUIRES FOR IMPOUNDMENTS DOUBLE LINER, SINGLE LEACHATE COLLECTION SYSTEM, GROUND WATER MONITORING COVERS HVY ENDS TKS VCM, THREE DRUM STG AREAS AT LCCC, NO RCRA FACIL. 8 OTHER LOCATIONS ALL LCCC IMPOUNDMENTS AND OLD DISPOSAL SITES REQUIRE SYNTHETIC LINER, LEAK DETECTION/REMOVAL SYSTEM TIMING?? SECONDARY CONTAINMENT FOR HAZ. WASTE TANKS MUST REMOVE BZ FROM BALT. SPRUNG OIL BTMS TO ALLOW CONTINUED USE AS BOILER FUEL W/O RETROFIT OF MON. EQUIPMENT, RCRA ( HAZ WASTE ) PERMIT, ADMIN. PROGRAMS, ETC. LCVCM 452 TANK MUST HAVE SEC. CONT. BEFORE CAN GO INTO HEAVY ENDS SERVICE VAB.0001125190 h- rWH^irv U '4 -d p 4 *-wj KT-b||-u d-p-. i|| -i^-^ f y-- + > - |-vkh'1 it- ls*n4nHrM>r B APPENDIX D LAKE CHARLES WASTEWATER A LOOKBACK STORY This story is not to justify Rich Gerlach's having saved plant presentations from the Blauvelt/Gerhart era, though without the data from them, the story probably could not have been assembled. During the 1960-86 period, on the order of $10MM capital was spent on installations which will be abandoned after completion of the wastewater project. Based on Nelson cost indices, this to about $35MM at today's cost. In addition, approximately $10MM will be spent to clean out, close up and mop up behind those abandoned installations. Portions of the wastewater project which more or less directly replace those installations total $21MM in 1989 dollars. (An additional $11MM will also be spent on "enabling" equipment, not including $0-2.5MM in MeCl.) Interesting, but so what? The "so what" is that with perfect foresight about the same money could have been spent "way back when" and we would need spend nothing or very little today or until 1995-98. The technology being proposed already existed when the previous investments were made. Were we just dumb? No, each technical and investment decision made sense at the time, taken individually. The problem was that the sum of the individual decisions was a patchwork instead of a coordinated whole. (Lest anyone think this story to be an attack, the author had input to some of those decisions also.) While no guarantee exists that a similar story won't appear 15 or 20 years from now, the LCCC Wastewater Project has been approached with best efforts at developing a long term, modular and flexible system to carry the complex into the future. NOTE: Though it is true that operating cost differences between the new and old systems were disregarded, so also were the cost and resource diversion involved in redesign, following up violations, writing lookback stories, etc. s' 4f * ..r. i . i Ij %.; f H VAB.0001125191 II H 4JI 41 >' - ' H- rl ! .. * -t-i-T LCCP WASTEWATER PROJECTS TO BE ABANDONED (Probably Significant on Low Side) Project Date Holding Pond API Separator Sand Filters Aerated Lagoons Polishing Pond Other Water Projects Flow Meas./Pol. Pond Imp. Misc. Proj. Stormwater Ponds Segr. B.D. Streams DAF Unit Stormwater Diver. Rev. Sludge Dewate ring Oil/Water Separator Covers Wastewater Compliance NPDES Runoff Compliance 1960 1971 1968 1971 1972? 1968-74 1974 1974-77 1976 1976 1977 1978 1981 1983 1983 1986 LCCP SubTotal Orig. Cost 0.25? 0.57 0.20? 1.28 0.05? 0.38 0.02 0.50? 0.24 0.17 0.75? 0.30? 0.60? 0.91 1.08 0.23 7.53? $MM Current Cost 1.3 1.9 0.8 4.2 0.2 1.3 0.05 1.1 0.5 0.4 1.4 0.5 0.9 1.1 1.3 0,3 30.0 VCM Lagoons VCM Copper Pond VCM Acid Pits VCM CPS Repl. VCM SubTotal 1970 1980 1985 1986 0.40 * 1.91 0,15 2.46 2.1 ? 2.1 0.2 4.4 Total LCCC 10.00 35.0 VAB.0001125192 LCCC WASTEWATER PROJECT ITEMS DIRECTLY REPLACING ABANDONED PMENT OR TECHNOLOGY 1tern ASU Pond Upgrade Ale. Baro. C.T. Hydr. Load Red. WAO-Spent Caustic Stormwater Tanks Tank Based ASU Replacements 1989 $ Cost 1.6 .55 2.0 4.2 4.6 _Ll8 20.8 Date 1991 1990 1989/90 1990 1992 1992 Cost As Of Inst. Date 1.76 .55 2.0 4.2 5.5 9.4 23.4 Pond Closures Groundwater Treatmt. Cleanup 8.0 _Lu5 9.5 1992-97 1989PV 9.9 1,5+ 11.4 MeCl Unit Shutdown 1991 30.3 35.0 NOTE: "Enabling" equipment not listed here. s-l 'I r l.'i ? <. ` I*' >' r. d-. > T.-t -Iner ti-f ' ^ WW>B 1 |1 f* fl I Hi- HJBW t V- W: -L :q F'll'T'iilV :*< VAB.0001125193 .. : J- |r- . I. in.-4 *llh- .. *'* .% .. i . r- MELSON COST INDEX CONSTRUCTION INDEX If II II It It II 11 II II II flt II It tt H H It x: ..zizssss:; INDEX <1946 * 100) :z=zszzzzs::zszzsxzzs:SSSSSZZ8SZ1 1 1 PUMPS | 1 1tj 1 YEAR | COMPR j 1 " J == | 1 1946 j 100.0 j 1 1947 j 117.2 j l 1948 j 127.0 j 1 1949 j 135.9 j 1 1950 j 138.2 j 1 1951 j 155.9 j 1 1952 j 155.6 | 1 1953 j 162.5 j 1 1954 j 166.5 j 1 1955 j 172.2 j 1 1956 j 192.0 j 1 1957 j 206.7 j 1 1958 j 214.7 | 1 1959 j 226.9 j 1 1960 j 228.3 j 1 1961 | 228.8 j 1 1962 j 222.5 | 1 1963 j 224.3 j 1 1964 j 231.5 j 1 1965 j 245.6 j 1 1966 j 260.5 | 1 1967 | 272.2 j 1 1968 | 284.4 j 1 1969 j 298.6 j 1 1970 j 313.1 j I 1971 j 330.6 j 1 1972 j 337.5 j 1 1973 j 346.9 j 1 1974 j 416.3 j 1 1975 j 509.8 j 1 1976 j 538.6 j 1 1977 | 574.9 j 1 1978 | 619.5 j 1 1979 j 1 1 1980 j 1 1 1981 j 880.6 { 1 1982 j 944.1 j 1 1983 j 944.5 j i 1984 | 950.5 j 1 1985 | 969.9 j 1 1986 j 982.6 j 1 1987 | 995.3 j 1 1988 j 1,027.8 j 1 1989 j 1 1990 1991 1992 1993 1994 1995 1996 1997 1 ELECT | MACH j J 100.0 j 113.0 j 127.6 J 130.9 j 134.9 j 154.3 j 152.4 j 156.4 j 160.0 j 162.5 | 175.0 j 188.9 j 192.7 j 195.8 j 195.2 j 192.1 j 189.5 j 187.7 j 186.4 | 186.2 j 190.5 | 196.1 j 198.2 | 201.7 j 208.6 | 241.5 j 216.3 j 220.2 j 244.9 | 275.6 | 287.2 | 299.2 j 323.1 | 1 1 431.4 | 453.8 | 469.0 j 486.5 | 497.0 j 504.6 | 511.5 j 519.7 j 1 I NT- | COMB j ENGINE j ZZSS88 1 100.0 I 109.0 j 116.9 | 124.8 j 126.0 | 146.1 j 146.5 j 148.1 j 150.5 j 153.2 j 164.0 | 173.9 j 178.3 | 178.5 j 180.7 j 181.2 j 183.4 j 181.5 j 184.9 j 186.4 | 188.7 | 192.0 j 198.9 j 207.4 j 217.0 j 226.1 j 233.3 j 238.3 j 270.2 | 319.8 j 348.3 | 376.9 | 412.7 j 1 1 576.9 j 627.7 j 653.7 j 663.1 | 666.7 j 676.9 | 690.3 j 702.3 j 1 1 CONT | INSTR j 100.0 j 113.0 j 120.0 j 122.0 j 127.8 j 142.3 j 146.2 j 151.8 | 154.6 j 162.9 j 182.1 j 187.4 j 194.9 j 201.0 | 202.5 j 207.5 j 214.8 j 224.5 j 225.3 j 221.5 | 299.7 j 232.3 | 239.1 j 252.8 j 278.8 | 304.2 | 328.4 | 338.0 j 376.5 j 420.5 | 466.4 j 484.1 j 518.7 j 1 1 623.4 | 652.5 | 675.2 j 696.8 | 713.7 | 733.3 | 744.4 j 748.8 j 1 1 HEAT | EXCH j SH J 100.0 j 115.0 j 130.0 | 133.0 j 140.0 j 152.0 j 165.8 j 174.9 j 171.1 j 156.8 j 190.7 j 203.6 j 181.2 j 178.9 j 194.0 | 188.1 j 183.6 j 189.1 j 206.1 j 218.4 j 235.2 j 237.9 j 223.4 j 235.8 j 253.8 | 268.0 | 274.3 j 313.7 j 501.3 j 553.9 j 478.5 j 454.0 j 496.0 j 1 1 727.3 j 635.9 | 541.7 j 530.9 j 520.0 j 524.7 j 577.7 j 664.1 j 1 Ml SC I EQUIP j AVG j SSMM j 100.0 I 114.2 j 122.1 | 121.6 | 126.2 | 145.1 j 153.3 j 158.8 | 160.7 j 161.5 j 180.5 j 192.1 j 192.4 j 196.1 j 200.0 j 199.5 j 198.8 j 201.4 j 206.8 | 211.6 j 220.9 | 226.1 | 228.8 j 239.3 j 254.3 j 268.7 ( 278.0 j 291.4 j 361.8 | 415.9 j 423.8 j 438.4 j 474.1 j 515.4 | 578.1 j 647.9 | 662.8 j 656.8 j 665.6 j 673.4 j 684.4 j 703.9 j 732.5 j 1 M II II II It N H U II H ft* M 11 II It 11 II II II II II II fle UN J 5. H 11 '1 it II l* EZZSSSZSSZZS; I MATL j COMP j SSBZX3 1 100.0 I 122.4 | 139.3 j 143.6 j 149.5 j 164.0 j 164.3 j 172.4 j 174.6 j 176.1 j 190.4 j 201.9 j 204.2 | 207.8 j 207.6 j 207.7 j 205.9 j 206.3 j 209.6 j 212.0 | 216.2 | 219.7 j 224.1 j 234.9 j 250.5 j 265.2 j 277.8 j 292.3 j 371.3 j 421.0 j 445.2 j 471.3 j 516.7 j 573.1 j 629.2 | 693.2 j 707.6 j 712.4 j 735.3 j 739.6 | 730.0 | 750.0 j 802.8 1 II II II II II II II H LABOR COMP 1 j NELSON INDEX II II II If It II II II 100.0 j 113.5 j 128.0 j 137.1 j 144.0 j 152.5 j 163.1 j 174.2 j 183.3 | 189.6 j 198.2 j 208.6 j 220.4 j 231.6 | 241.9 j 249.4 j 258.8 j 268.4 | 280.5 | 294.4 j 310.9 j 331.3 j 357.4 j 391.8 | 441.1 | 499.9 | 545.6 | 585.0 | 623.6 | 678.5 j 729.4 j 774.3 j 824.2 j 879.0 j 951.9 j 1,044.2 j 1,156.5 j 1,234.8 j 1,278.1 j 1,297.6 j 1,330.0 | 1,397.6 j 1,405.6 j 1 100.0 117.0 132.5 139.7 146.2 157.2 163.6 173.5 179.8 184.2 195.3 205.9 213.9 222.1 228.2 232.7 237.6 243.6 252.1 261.4 273.0 286.7 304.1 329.0 364.9 406.0 438.5 468.0 522.7 575.5 615.7 653.0 701.1 756.6 822.8 903.8 976.9 1,025.8 1,061.0 1,074.4 1,089.9 1,123.0 1,164.5 tzo S on V - *2.1 /-*!** Z,i7. 01125194 I-****'-., 11^. 1989 Must Do 7.2 LCCC Black Box 2.0 Proactive 1.4 1990 8.2 11.7 0.9 APPENDIX E ENVIRONMENTAL CAPITAL COMMITMENTS FORECAST (RECAP BASIS') ;991 3.0 0 1.8 1992 5.0 8.0 2.0 1993 5.0 0 2.0 SUB TOTAL }994 28.4 5.2 21.7 1 8.1 0 1.0 1995 1.0 1996 9.2 1997 6.0 1998 TOTAL 37; 9 Subtotal 10.6 External Stm. Strpg. 0 20.8 0 4.8 15.0 45 0 7.0 0 58.2 6.2 0 TOTAL 10.6 20.8 49.8 15.0 7.0 103.2 6.2 VAB.0001125195 J|T" lHI-^ I "t Vr^-I-W t I I -H-l;-- |FW*--<<*-- "' P*JlW4f+*"*-"IHI H ' HI- -I - -IS-.P-- AIR WASTEWATER 1989 1990 1991 1992 1993 (1) VOC Industrial Wastewater Control Strat{eI*gies RCRA Air Emission Control Requirements (3) OCPSF Effluent Limitations Water Quality Based Effluent Limits!*) GROUND WATER WASTE MINIMIZATION Prohibition on Discharge to(6G) round Water: RCRA Deal gn Requirements Closure of Surface Impoundments (7) OTC Promulgation Retrofitting and Permitting Housekeeping Improvements Stormwater Segregation Treatment in Tanks to Reduce Concentrations/Remove/Recover s Contaminants i i 2000 -> (5) -> No Discharge 6-T (1) See Table 1-1 (2) See Table 1-2 O) Sea Tab1e 1-3 (4) See Table 1-4 (5) See Table 1-5 (6) See Table 1-6 (7) See Table 1-7 Figure 1-1. Short- and Long-term Regulatory Trends Applicable to the Vista Lake Charles Wastewater Treatment System VAB.0001125196 .K-llp-u l-Jt'KI ''iTF rr-e(i,' I +c Nv.-i.e; . JJtHt 'i-'T" .-I ts^I. I-Ml ^ ................... .IhPiH.I--- i IFJO'tM ip -| iipir* 1 .VO- -ViViVl-r MMIU tT#. -L-hI | IlirT T f 4 Consultant (Radian') Directional Recommendations - Wastewater LCCC 1. Prevent, eliminate, minimize waste generation .2 Implement practices which concentrate, remove, destroy, recycle organics in wastewater 3. Segregate waste streams for differing management (stormwater, others) 4. Improve housekeeping 5. Long Term - Alter/replace feedstocks, alter/replace production technology, redesign end products if necessary m ' ij'rnik^'r1' i l-'r iv . ?! ' - -i ' - I' -h r (--+ .s-iir-iM! JifPtrty :-fli Hlwfi- IvWi -n f`r + i- - - - pJ -v ..... -i VAB.0001125197 1 |1T "V r-- -4 ! If I- " N .'-Sr. . j-'-'nn i-i-iiipJuewfH.-fcHh ii. 41 i_"i i;- k.' -4 1 > :h 1-. .lip .iL^L.ihik. j Lk) r i| in i j.. ' h- >- i- .1 i PHASE I LCCC WASTEWATER PROJECT - RADIAlt ESTIMATES (MARCH 1989) PROJECT Total Cost________ 1989 % Jan. Est. War. Est. 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 Total A. Stormwater Segregation * 1. MECL Stormwater* 0* 2. LAB Water Collection 458 3. Ethylene Stormwater 1,080 4. Alcohol Stormwater 1,530 5. VCM Stormwater 36 3,104 3.1 3.1 .46 1.08 1.53 .04 B. Wastewater Treatment 1. ASU Pond Upgrade 1,600 2. ASU Treatability 250 Study 3. Biotoxicity Study 43 4. LCCC Stm. Stripper 1,978 5. LAB Water Treatment 1,985 6. VCM Stm. Stripper 1,426 Upgrade 7. VCM C-500 FD.TK/ 290 T-110 8. VCM SPCC Study 75 9. Alcohol OAF Unit 825 10. Repl. Ale. Baro C.T. 550 11. ALC. Acid Holding Pit 90 12. Hydraulic Load 2,000 Reduction a. ALC 600 b. VCM 400 c. Ethy 750 d. NPU/ETO 250 11,112 5.0 11.1 .25 .04 1.98 1.99 1.43 0.29 .08 .82 .55 1.76 .60 .40 .75 .25 C. Wet Air Oxid. - Spent Caustic 5.6 4.2 4.28 D. MeCl Stripper 0 13.7 ____ 18.4 ____ 2.83 ______ 13.89 ____ 1.86 18.6 . i. . .ik j. 1..,.. + ..i j- fAHiPrb'eW l;i> - ip i- Iraqi -dp ^i- iH .. ^ ..... . 11 li h1" jr-J-- i| :in-| . |T Hr .. .1 |i . 1.,^;%.^' r t hC' T I ' s' !. ' I' -p" 'lisf- VAB.0001125198 PHASE II LCCC MASTEMATER PROJECT - RAD 1AM ESTIMATES fMARCH 19891 PROJECT______________ Total Cost 1969 > Jan. Est. Har. Est. E. Stormwater Treatment (Tanks) 3.8 4.6 1989 1990 1991 1992 5.53 1993 1994 1995 1996 1997 1998 Total F. Tank Based ASU G. NPU Coalescer 4.2 7.8 8.0 12.7 9.38 15.3 i H -p. ' |*H4 T ' 1 -I '........................i-1 T f ' ' r 'i: i t !( ''ur..................v >r i-frv i *p--t u-.r if--r -> j rPB"? r ^ra-Qir . v^-nre*1"^~auiri 4' V''CJHIfJ ii iV'Ji 'i>i -pi ** -n +- |i Hi M-v* .--q i M Hn VAB.0001125199 Ml >IK*J(I 1,4.4 Jlgpl I J" PHASE 111 LCCC MASTEUATER PROJECT - RADIAM ESTIMATES fMARCH 19891 PROJECT______________ Total Cost 1989 $ Jan. Est. Mar. Est. H. PACT/MAO PACT/WAO - Engr. PACT/UAO - Const. 465 ,188 10.2 4.7 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 Total .64 5.87 I. Incinerator Incinerator - Engr. 600 Incinerator - Const. 5,400 6.0 16.2 6.0 10.7 .72 7.56 .72 .64 5.87 7.56 14.8 I ! "? M>Ub < i *\+ \< wib. ,|>r. +pu * 4p r h=f^ Sk.. mf '1414, N-l, |lf. 1 . iHUppA.i- ... : -j -ih-h -f-m-hj '* H-HH + .W "-T-: Vi-d- !l.| f "wi: to *-t 1 w.j-hi !^r> - y -`i- i-- 'H -li'-H fii-Hl-'i "I / VAB.0001125200 NOT INCLUDED IN CAPITAL {EXPENSE ITEM COST 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 TOTAL Pond Closures Partial Holding Pond-ENGR. 65 Holding Pond Closure Cleanout N, S Lagoons & % Stormwater Pond 586 2066 Close % Stormwater Pond & Sand Filters 368 Close REM. Impound^ ments-ENGR. 339 Close REM. Impound ments -CONST. 3050 Digester Closure 1000-2000 1.5 .07 2.48 4.27 Groundwater Treatment VCM Radian Prelim. Design Partial 700 250 . 70 .25 8924 2.45 .06 0 2.99 0 0 0 4 10.2 0 i ki-iif i 1 i:: +- -p -i 4 : I . -i n n f? . jj i -r i ji -| M l r-J< u: rLi Hr! ................ if. -HI T** T ' I1'- 4^ n . !: VAB.0001125201 '-IVdi ....................... - H -r|. -Sr *Vfi K + fv** i\ -+T! - 'I' E- rhi ^ L'i-:bih -I ti-HlPJ". Ji. e-1,141,,1 i. -ffn -Fi ihv^-m 3^4" l> i|" I'm . i v-itt-hi: -h*. 'hl. ir- . .. rw. |- FIGURE I SUMMARY LCCC Wastewater Implementation Plan Major Impact i i 1 Impoundment ASU System for LCCC i I Tank-based ASU System for LCCC i i i V PACT:WAO Mod. Tank-Based ASU i i i i V LCCC Incinerator i i V i i Major Projects 1 2 3 4 5 6 7 8 9 *90 *91 PHASE I *93 *94 95 *96 97 *98 PHASE II PHASE III Treatability Study 1 LCVCM ASU Modif. Hydr. Reduction Proj. 2 Biotoxicity Analysis Stormwater Segr. Projects 3, Steam Stripper System 4, Upgrade (LCLAB & LCVCM) New Groundwater Stripper (LCVCM) 5 Barometric C.T. Repl. (Alcohol) New LCCC Steam Stripper. Tank-based ASU for LCCC Tank-based stormwater trmt. system 1 2 3 4 5 Clean-out N. & S. Lagoon, Holding Pond and 1/2 St. Water Pond Close Holding Pond, sandfilters, 1/2 St. Water Pond PACT:WAO Modifications to ASU Solid Filters Close VCM ASU and 1\2 St. Water Pond Incinerator Close N. and S. Lagoon 2000 l l * m- -Si S-.-i - J-li-. - - b;. J-b*;- i II-- . - i- J!K *-i- TV-'*'1*--^ ^ , m 1 Hfniljl J? 'WUi - W-\i- Ik-* Li?: ;* -ir t p-tr p- -Ht Jt+l*'-T' y !** ' %-rvi|i-q . s 11* miih f v-n = <rJ +F+ . r.-kj t .-i: _jc- ..-ih J '* LT*-- VAB.0001125202 V I i "V V: 4 , < I, l-y ETHOXTLATES UNIT NORMAL PARAFFINS UNIT \*p+* V T- *h - i* r ETHYLENE UNIT POTENTIAL BENZENE/ TOLUENE LADEN WATER (CURBED AREA) SPENT CAUSTIC 1r H'-iX *.* 3. *- ., s;. w? -J- r ftc * * 4 ,- -1* 'VV ' hk ir *>''' QUENCH WATER STEAM PLAICl ALCOHOL UNIT PROCESS WASTEWATER AND TANK TRUCK/RAILCAR LOADING AREA CLASS I STORMWATER I VCM PLANT PROCESS WASTEWATER/ CLASS I STORMWATER GROUNDWATER 4. LAB PLANT PROCESS WASTEWATER .. - j t ;Z >< :' V ' ^ "I = `t 4- I'. t' ^r STORMWATER i ii: ?t if* - . ! 1 .'p- n ' 1 r.- . ;.j: . .ij*:.p .& --^k I ii <*.< -iri t t * .. Pi .1 -p ji -V- H * ' - !, ;* . ** h.'; . " V i* ^ A* ' < i .' -'A" * -b. l j . . i- ` * A ( .I ' pr _ j * *' i> _ -. *j - :* A- J FIGURE 2 K''* t ' 4 r V >- 'F Y VF- LCCC WASTEWATER PROJECT PHASE I - BLOCK FLOW DIAGRAM Pr . .* . .: % *j j *p __ " * - >iAPI UNIT i-------- ^ K fa _ ^ -r * 4 ^ i* * I`4- i. ` J f \- z % *b i' " - s: *r W .. . ^ .' ' '* * a * `,h.. *. v ' m- \ + ' *'' * . i -** . .7. ^ . ,t; . > - '^ - -** *i - 't ' ^ " * V .\ . " -\ ~ + *""*" ^' r . I ,rji -1 1 * 4 ^- *, "p ; ,,r rf ' .-. -fZ ,- rT %^ 4 /J'.J - j- ^ n/. .* -s; ^ : Jr"- i-1 > j* F P^ p ** * r .-n, - t r * NEW L. Jank VISTA BUSINESS AREA r,OR NEW WET AIR OXIDATION NEW REDUNDANT STRIPPER f- `b * - r-. b V ,V DOX UNIT EXAM W QUENCH STRIPPERS NEW ALCOHOL IN-UNIT TREATMENT TO NEW LCCC ------1 STRIPPER * > r. ^ > " -y F V * *: 'f r , --F V- ,r - " T '"P .1 1 -- `/i, ` / f . _ _ pi- ^ V T * Ji--- * : '" *J'T" b * 1. * * ^ '"j- REVISED LCVCM ASU SYSTEM S-*r OUTFALL I c *L TANK VCM STRIPPER w NEW CARBON TREATMENT ^RECYCLE TO LCVCM %. iw 1.' 4? i-> . . rs _ * .*< -F .-i rl, '.r * - * -< r- - * f, 4 ,# NEW STORMWATER r 1^ LAB STRIPPER ^DIRECT DISCHARGE :,.i p + -f-r 4-i< ----Tlli - 1 '(.* - * * +`J: II1 I ri ?< ^ 4:^<p|| :i -: .-k rt if * * 1, > - in si p i. 1.1 1 4iig .ip.,- , K|.- -i|- - . -s,- f -- f" VAB.0001125203 .H_r..--r 1: . N t- *,s ** V- N ? - . - .cr l-- P>.H *4< . * !-: ik^ fv' .*&: fr- J CTHOXYLATC3 UNIT NORMAL PARAFFINS UNIT PROCESS WATER STORMWATER ETHYLENE UNIT POTENTIAL BENZENE^ TOLUENE LADEN WATER (CURBED AREA) 4 SPENT CAUSTIC -m QUENCH WATER w CLASS I STORMWATER (SURFACE RUNOFF) ALCOHOL UNIT WASTEWATER AND TANK TRUCK/RAILCAR LOADING AREA CLASS I STORMWATER VCM PLANT PROCESS WASTEWATER 1 STORMWATER GROUNDWATER LAB PLANT PROCESS WASTEWATER i***K L. jr y v ^S^rK: - j fit r rj;^ v -, ^ k - * *. W - V r *i\- - ^J 4fe.-:.V Xr' 41 ` r ': H f1 ^ *T *S ' > STORMWATER * 1 vt`I > ;". , I ,' J - i ': ?. :.!-. -^ *' l f-m . & K i * * t,. 1 1> JCi k*. l*p -R .I / ;J"J- " '1 I* I %,. "* t * ., .- +* R _. -S----H * u. - I*x o - - 1r -, r ; : :> ' :> ! ; _> , 1 * * :* *- v- p. -A . * T ** , . -H 'i . / r ` > - * -: -v^,- \' . ' -T- ;- 4, r * " ^4 ... Ah . FIGURE 3 " V V* * -'* T. r. * *. s. . LCCC WASTEWATER PROJECT PHASE M ~ BLOCK FLOW DIAGRAM A- J 1 -- ' > ;i* NEW I f API UNH I , - * * * r - - - *?** ^ -\ - - ^ r- rrT `` f- * 1 ` '. w 7r '-7*^ -- > ;'' '. ^ - '- - < ..> * . . r' :X ^ ,1 * A" ; f * " C-H^7 * x .^ ^ - "i * * ' 1 ^ - . ipj- fc p T. - r* ' .**'.' -i, * i. . ': ` r : 1 - -- -T vVv`>;. - .- *i V -L. : T' * /H . > .iST.sr.v>^ r-'^' * ' #' J. <^ '- ; 7 . *. -Jh ^ T *' -t - J"vv*- " -+ .- p 4. - - T /r * -. I* I. _ >P J xlS^r;'t>`s^ ^ A' ' rr*r\ "^ V3f- ,* " :"?% ^- ', -- *> -'- ' .>.* ? J > T^-sf.r-i-'*-;-- .v.^ _ X -r H h^l r *, 1 H . + ,_i H ' ,.. -V5,> ^ ' v; - ' - . ' r- '' *\-y.~* ` \ * j ^1 `T : V- > 4 rJ : ' * A fiI . *1 j - d .. p ' 4 , *-- . ^ 1- *. A .0. -i <t * IT ^* V V r i-- - L- .-. ` ' \-3 * ` *' . ^ -'I :;' Tt ' r 3-^-T-'' Jf : 1,' -"J' x --* '7"J r ' ' ,^ `-..-Lf;-.:!-- j: -" . L " J -~ *' - -- P' * ." "- NEW TANK OR ........................................................................................ I VISTA BUSINESS AREA L NEW WET AIR I OXIDATION DOX UNIT EXAM QUENCH NEW LCCC STRIPPER j- - i' * - J T- ^ Vx w\--r " V * ', * ` * -,- ^ : + * --. .... ^j* . - X,, T V5 fc* - * '^ *^ NEW 1 LCCC ASU< SYSTEM 4 " f IL d ,T . .i + m * Ti. OUTFALL -m- 4 -- 1 I ALCOHOL. NEW IN--UNTT TREATMENT 4 i I r*n H_TA^J VCM STRIPPER N f NEW STRIPPER L I------- ~'l . CARBON treatment *> RECYCLE TO LC\CM V li ),, _ r. j. * t - * _.v*i : --^' r- ` _i , V -1 F - - --v; r' z. /! r ,n "-r - ^: - : *t *. '. *s.'x' NEW ` NEW STORMWATER STEAM TANK/DAF STRl +^ CPI NEW 1 STORMWATER I --T L I LAS STRIPPER l A N. 4s i. ' iV 7. VAB.0001125204 p-% + * ^ ij- .i S- I f'flT ,..|rt^. . . ii-iWM'i-: -r ^ ! : -y-ffj.-i T'J-'-.r jj'. i r - ir yi:?^r T-l* i wlT*nh n-e'4 <*> ip :Ur: noM LCCC WASTEWATER STUDY 1. STUDY OBJECTIVES 2. REGULATORY REVIEW 3. REVIEW OF OPTIONS 4. COST 5. FUTURE ACTIONS VAB.0001125205 WASTEWATER TEAM LCCP LCVCM LCLAB PED LEGAL ENVIRONMENTAL DUANE EVERY MIKE HAYES JIM SHAMBURGER SANDRA CORKRAN PAUL HIPPMAN TOM HELLER MIKE WISELEY BILL McCLAIN JOE LEDVINA + " i - . I-. i ,r 'h-mlli ||r:; - i-' . - -j .: . VAB.0001125206 ....................... I . !. : V. . ..................Tl- + .. . M . LCCC WASTEWATER STUDY INITIATED BY LOUISIANA DEQ PERMIT REQUEST - LCCC SOURCE SURVEY - $250M CONTRACTOR-BASED STUDY INITIATED OCTOBER 1, 1988 (TO BE COMPLETED MARCH, 1989) STUDY OBJECTIVES 1. EVALUATE REGULATORY IMPACT (NEXT 30 YEARS) 2. IDENTIFY WASTE MINIMIZATION OPTIONS AIR SOLIDS WATER 3. IDENTIFY OPTIMUM WASTE MANAGEMENT IMPLEMENTATION PLAN lIM t. r* -I I r-:- r 1 >* || rill' rfc --r-i ll^l.i iJWialiimj.w * m R.h VAB.0001125207 LCCC WASTEWATER STUDY TASK 1.0 TASK 2.0 TASK 3.0 TASK 4.0 TASK 5.0 REGULATORY REQUIREMENTS WASTE CHARACTERIZATION PROCESS SELECTION AND DESIGN TECHNOLOGY ASSESSMENT ALTERNATIVE DEVELOPMENT CONCEPTUAL DESIGN PRELIMINARY DESIGN FINAL REPORT - IMPLEMENTA TION PLAN ...... . : a!-I iVf I" Ul VAB.0001125208 I I b I r-Jii'Tii. AIR REGULATIONS EXISTING SARA 313 EXPECTED AIR TOXICS ORGANIC EMISSION CONTROL REPORT EMISSIONS OF TOXICS ANNUALLY REQUIREMENT CONTROL OF SARA 313 CHEMICALS TO 10-6 HEALTH RISK REQUIRE 95% REDUCTION FROM 1987 LEVELS OF HYDROCARBON EMISSION FROM SEWERS, DITCHES, SUMPS, TANKS, IMPOUNDMENTS, OR OTHER TREATMENT UNITS IN WASTEWATER SERVICE (INCLUDING WATERS AND RESIDUALS) I i- VWHUli|H--r mtU-M-EF^Btia-1 -Jl-r- vr+i'*- H-J: xiiw.-f*-*-*- fr '--S II. I] Hl| --IflNr'lM'rt k-il.i. l VAB.0001125209 WATER REGULATIONS EXISTING REQUIREMENT ORGANIC CHEMICALS, PLASTICS, SYNTHETIC FIBERS EFFLUENT GUIDELINES WASTE LOAD ALLOCATION FOR BAYOU VERDINE EXPECTED BIOTOXICITY LIMITATIONS ON EFFLUENT DISCHARGE SIGNIFICANT REDUCTIONS FROM EXISTING PERMIT FOR CONVEN TIONAL POLLUTANTS (APPROX. 80% FOR BOD). APPROXIMATELY 50% REDUCTION FOR BOD AND TSS. REQUIREMENT 80% SURVIVAL OF TEST SPECIES IN EFFLUENT WATER. ORGANICS, METALS, CALCIUM SALTS, AND CHLORIDES ARE SUSPECTED MAJOR CAUSES. BIOTOXICITY LIMITATIONS BASED ON RECEIVING WATER QUALITY 80-100% SURVIVAL OF TEST SPECIES IN EFFLUENT DISCHARGE WATERS. " IT-!": I'K,M . |' r- -- I -V^ir 'Ih't'll r ! hhr|.-.-! f- I-' 4 . |l H VAB.0001125210 T1-- k w?ry.- 1711. L -I",fin. -Li ...-.j*.,- 1. L V '. ^ I I ............................'I.*- -1: SOLID EXISTING DEFINITION OF A SOLID WASTE DISPOSAL UNIT INCLUDES SURFACE IMPOUND MENTS CONTAINING OR COLLECTING WASTEWATER. DIRTY' STORMWATER, 'CLEAN* STORMWATER FROM PROCESS AND PROCESS OFFSITE AREAS, AND NONHAZARDOUS RESIDUES. EXPECTED LINER REQUIREMENTS REQUIREMENT DOUBLE OR SINGLE SYNTHE TIC LINERS AND LEACHATE COLLECTION SYSTEMS WILL BE REQUIRED FOR ALL NONHAZARDOUS SOLID WASTE SURFACE IMPOUNDMENTS. EXPECTED TOXICS WASTE LOAD ALLOCATION FOR BAYOU VERDINE BASED ON WATER QUALITY STANDARDS FOR TOXICS DETECTION LIMITS FOR TOXICS IN EFFLUENT WATERS. r i 11 0 |1- * I-II ; 11 ) I h),u . L-I-Pt, ri VAB.0001125211 ,1 ...i; j|. .i'j. si" 'M 1-- a p^i tl - i r i Kff.il ,< n .. i- V: . "M HAZARDOUS WASTE REGULATIONS EXISTING LINERS FOR LAND DISPOSAL FACILI TIES SECONDARY CON TAINMENT FOR HAZARDOUS WASTE TANKS I I AIR EMISSION CONTROLS FROM HAZARDOUS WASTE EQUIPMENT REQUIREMENT ALL HAZARDOUS WASTE IMPOUNDMENTS MUST HAVE DOUBLE SYNTHETIC LINERS AND LEACHATE COLLECTION. TANKS MUST BE CONSTRUCTED SO THAT LEAKS FROM TOP, SIDES, OR BOTTOM CAN BE DETECTED IMMEDIATELY. DIKE AREAS MUST BE SEALED AND HAVE CAPACITY TO STORE THE TANK CONTENTS PLUS A 25 YEAR FLOOD. TANK, VALVE, PUMP SEAL, COMPRESSOR SEAL EMISSION STANDARDS FOR HYDROCARBONS FROM HAZARDOUS WASTE TANKS AND EQUIPMENT. k- f r-.vimiEtM.i* r.' ft. I^MHH H-^|-- hM|Hfc ~*T-W1 .rfi^fiiTi-:^ .-\u- . VAB.0001125212 v" 'fi ....................>; EXPECTED ORGANIC TESTING CHARACTERISTIC (OTC (WAS TCLP)) DESIGN REQUIRE MENTS FOR CONVEYANCE DEVICES AIR EMISSION CONTROL REQUIRE MENTS LANDFILL BANS WASTE MINIMIZATION REQUIREMENT RECLASSIFIES WASTES WHICH CONTAIN LOW LEVELS OF ORGANIC POLLUTANTS FROM SOLID WASTE TO HAZARDOUS WASTE. FACILITIES CON TAINING THESE WASTES MUST MEET HAZARDOUS WASTE STANDARDS. A NO DISCHARGE OR MIGRA TION TO GROUNDWATER STANDARD FOR PIPES, DITCHES, ETC., TRANSPORTING HAZARD OUS WASTES. A CONTROL REQUIREMENT FOR HYDROCARBON EMISSIONS FROM ALL RCRA UNITS, INCLUDING CONVEYANCE DEVICES. HAZARDOUS WASTE LAND DIS POSAL WILL CONTINUE TO BE LIMITED WITH ADDITIONAL CLASSES OF HAZARDOUS WASTES PROHIBITED FROM LAND DISPOSAL. NUMERICAL REQUIREMENTS FOR WASTE ELIMINATION VAB.0001125213 .r|K-*Tii-im-Hr si:rr-njisi-ii-ir-ii :Mrr- jjj !|r 111'1' *13*1 'I, SPR- 1 , -I ftJ >L,'1 IT... .r ... {[, h n u, - ' .y*.. .| j . p. , STORMWATER SEGREGATION OBJECTIVE: IDENTIFY REVISIONS WHICH WOULD SEGREGATE 'CLEAN* STORMWATER FROM `PROCESS AREA* STORMWATER. TO ADDRESS: a. b. c. STORMWATER COMPLIANCE ALCOHOL FLOODING REDUCE HYDRAULIC LOADING (MeCI, WASTE MIN.) 46% RED. - ELIMINATE OPEN DITCHES/REVISE PIPING - GRADING/CURBING FOR SEGREGATION - TANK FARM PIPING REVISIONS FOR SEGREGATION 63% RED. - ALT. 1 ITEMS - ADDITIONAL IN-UNIT CURBING - CATCH RAINFALL ON EXIST ROOFS ALT. 3 - TRIPLE COST 60% RED. - ALT. 1 ITEMS - ALT. 2 ITEMS - ROOFING OVER H.C. SOURCES I '' : " 1* i 1 |iw -F' 'll.' '11 ; <> t t VAB.0001125214 * 1 I1 ,.| 1.1 Ijj m|s^` h *p- i I. V WASTE MINIMIZATION CLEAN STREAM SEGREGATION OBJECTIVE; IDENTIFY REVISIONS WHICH WOULD SEGREGATE PROCESS VOTER NOT REQUIRING TREATMENT TO ADDRESS: a. b. c. STORMWATER COMPLIANCE ALCOHOL FLOODING REDUCE HYDRAULIC LOADING (MECL, WASTE MIN.) COOLING TOWER BLOWDOWN FROM ALCOHOL TO DIRECT DISCHARGE COOLING TOWER AND BOILER BLOWDOWN STREAMS FROM ETHYLENE TO DIRECT DISCHARGE BOILER BLOWDOWN AND ZEOLITE REGENERANT STREAMS FROM STEAM PLANT TO DIRECT DISCHARGE LIME PIT WATER RECYCLE (STEAM PLANT) INSTALLATION OF RECIRCULATING COOLING VOTER SYSTEMS IN ETHOXYLATE AND NORMAL PARAFFIN COOLING TOWER BLOWDOWN FROM LCVCM TO DIRECT DISCHARGE MISCELLANEOUS STEAM CONDENSATE RECOVERY SYSTEMS, FREEZE PROTECTION, AND MODIFIED SAMPLE LOOP PROJECTS 1 .J-l I- Cl ! -i y-f '-I- ! Tr. n; !: ! ! y !+>:< - -'-i ^r.4 -B-trpl |j : -T' VAB.0001125215 . 11 f - i : + " M rip.1, f' I--M r1- si Ti ir- |; - I rq -I 'y- I i- I -H 1 M1 I!' M: CHEMICAL OXIDATION PHOTOLYSIS OXIDATION CHEMICAL PRECIPITATION VOLATILIZATION (GAS STRIPPING) HYDROLYSIS SOLVENT EXTRACTION WET AIR OXIDATION MEMBRANE PROCESSES MOLECULAR SIEVES ION EXCHANGE ACTIVATED CARBON ADSORPTION PROCESSES FILTRATION COALESCE DEWATERING (CENTRIFUGATION AND PRESSURE FILTRATION) DISTILLATION RESIN ADSORPTION EQUALIZATION/NEUTRALIZATION OIL SEPARATION (GRAVITY AND FLOTATION) COAGULATION AND FLOCCULATION BIOOXIDATION PROCESSES (AEROBIC AND ANAEROBIC) PHYSICAL-BIOLOGICAL PROCESSES CLARIFICATION/THICKENING CRYSTALLIZATION PROCESSES EVAPORATION PROCESSES THERMAL DESTRUCTION PROCESSES I : r S| | Hfc r... HIT :+ 'i rLt|;r4^1 1 4i-i'-l|:-N.-i;rN ~x>Mlk|^ ....................... VAB.0001125216 EXISTING AND/OR PROPOSED BASE CASE SOURCE TREATMENTS/ WASTE MINIMIZATION PROJECTS EXAM (ETHYLENE UNIT) EXISTING STEAM STRIPPING IN LCLAB AND LCVCM EXISTING OIL-WATER SEPARATION IN NORMAL PARAFFIN UNIT AND LCLAB m TANKS AND VESSELS VENT TO CONTROL DEVICES l SECONDARY CONTAINMENT ON HAZARDOUS WASTE TANKS AND PIPING SECONDARY CONTAINMENT ON PROCESS WASTEWATER SEWERS i i*t I HtH* 7 rn-ftLfl'iW* r.'l.i-'iiri * . *1 r?* Hiti.-"n,tmii-........... VAB.0001125217 DESCRIPTION 1 ONE END-OF-PIPE LCCC TREATMENT SYSTEM 2 SOURCE CONTROL WITH ONE END-OF-PIPE LCCC TREATMENT SYSTEM 3 SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT SYSTEMS LCCP/LCLAB AND LCVCM 4 ZERO WATER DISCHARGE -t . 1 T- ii i VnV" -,k I: i-;l inrc. i k ji. i ni- VAB.0001125218 CASE 1 END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE AND SECONDARY OIL-WATER SEPARATION (TANKAGE, DAF, STEAM STRIPPER) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE PRIMARY OIL-WATER SEPARATION (UPGRADE) OF COMBINED PROCESS WASTEWATERS AT THE END-OF-PIPE (CPI) SECONDARY OIL-WATER SEPARATION OF COM BINED PROCESS WASTEWATERS AT THE END-OFPIPE (DAF UNIT) VOLATILIZATION (STEAM OR NATURAL GAS STRIPPING) EQUALIZATION/NEUTRALIZATION (TANKAGE/ VESSELS) POWDERED CARBON ACTIVATED SLUDGE TREAT MENT (ASU WITH POWDERED CARBON) TERTIARY FILTRATION RESIDUALS MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION AND WET OXIDATION OF POWDERED CARBON WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER CASE 2 SOURCE CONTROL WITH END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OIL-WATER SEPARATION, AND STEAM STRIPPING (TANKAGE, DAF, STEAM STRIPPER) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) * ' - ft -t--*. - .in . . u . f-H, -T- i,%* -11* f - - ii * A.if.i .3 if i- VAB.0001125220 CASE 2 (CONTINUED) END-OF-PIPE TREATMENT - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION RESIDUAL MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION AND WET AIR OXIDATION OF POWDERED CARBON VAB.0001125221 V 0*f (A VJM W t cfiw c Odl SOURCE CONTROL WTTH ENO OF PIPE TREATMENT (Tneftitov* *00rw**$ mmrnm mmnsaMi (tiMtyMi Un4 S# If (XAM P (VI* API 0** *hi pto LCVAB LCVCM w<_,Hrmm wA vHyHvjh^tpePviUwlPvlNM c- IAP ? I ' OMf 0* Mi F*aiUy (IXCP, LCVCm SI Co*inf T S HmN< Pr UMi M LCVCM Mm mrnmmmm t f*yM un* | Wlr TrHMM 1LCCP. LCUS. *<LCVCM) fYiiiv'sw*: _J 3 0*0 t i * It OMy ** SIMt SIM Qi % i *< I VM Iftl Ib* r* Micc^'icua; J -i-1-!* =:' i.i *' :'pl 'r:: * ^IXJ^TT^fcr" *. VAB.0001125222 r.H^ * M - CASE 3 SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OILWATER SEPARATION, STEAM STRIPPING, FILTRATION, AND GRANULAR ACTIVATED CARBON ADSORPTION (TANKAGE, DAF, STRIPPER, CARBON) CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS t - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONTROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) ..s-OTtf-Tdp. i.-JiT t -* <='.i . !|F|- -Hi+w IWO* I VAB.0001125223 -f :11.< --1 'f* h '' j - I. M CASE 3 (CONTINUED) LCCP/LCLAB WASTEWATER END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION LCVCM WASTEWATER END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION RESIDUAL MANAGEMENT (SOLIDS, SOLVENTS, VOC'S) BY INCINERATION, WET AIR OXIDATION OF POWDERED CARBON AND THERMAL REGENERATION OF GRANULAR CARBON VAB.0001125224 VAB.0001125225 CASE 4 ZERO WASTEWATER DISCHARGE STORMWATER MANAGEMENT ALTERNATIVE #1 WITH RETENTION-STORAGE, SECONDARY OIL-WATER SEPARATION, STEAM STRIPPING CLEAN STREAM SEGREGATION AND DIRECT DISCHARGE SOURCE CONTROLS - COALESCING FILTERS APPLIED TO ALCOHOL AND NORMAL PARAFFIN WASTEWATERS - WET AIR OXIDATION AND NEUTRALIZATION/ PRECIPITATION APPLIED TO ETHYLENE SPENT CAUSTIC WASTEWATER - PRIMARY OIL-WATER SEPARATION UPGRADE AND SECONDARY OIL-WATER SEPARATION APPLIED TO LCLAB WASTEWATERS (CPI UPGRADE, DAF) - VOLATILIZATION UPGRADE APPLIED TO LCVCM WASTEWATERS (EXISTING STRIPPER UPGRADE) - DISPERSED OIL EXTRACTION AND STEAM STRIPPING (PROVIDED BY EXAM) APPLIED TO ETHYLENE WASTEWATERS - REDUNDANT SOURCE CONTROL SYSTEM (TANKAGE, DAF, STEAM STRIPPER) CASE 4 (CONTINUED) END-OF-PIPE TREATMENTS - EQUALIZATION/NEUTRALIZATION - POWDERED CARBON ACTIVATED SLUDGE TREATMENT - TERTIARY FILTRATION - TERTIARY EQUALIZATION - REVERSE OSMOSIS AND ASSOCIATED PRETREATMENTS RESIDUALS MANAGEMENT (SOLIDS, BRINES, SOLVENTS, VOC's) BY INCINERATION, BRINE CONCENTRATION, AND WET AIR OXIDATION OF POWDERED CARBON VAB.0001125227 T?jr I L ... ,F ^ r I Jr- le- i.--iT+f !v+i-: 11' IttSSTruSlIUMV 1 VAB.0001125228 COMMON ADVANTAGES REDUCE AND/OR ELIMINATE THE RELEASE OF TOXICS TO THE AIR (REDUCTION OF SARA 313 EMISSIONS) REDUCE THE AMOUNT OF SOLID RESIDUALS GENERATED DURING TREATMENT (EXCEPT CASE 4) (MINIMIZATION, LAND BAN) v PROVIDE GREATER SYSTEM OPERATION PERFORMANCE RELIABILITY (100% COMPLIANCE) PROVIDE GREATER FLEXIBILITY FOR SYSTEM RETROFIT AND/OR EXPANSION (NO DOUBLE SPENDING) REDUCE THE OVERALL LAND REQUIRE MENTS FOR WASTEWATER TREATMENT VAB.0001125229 PIPE TREATMENT (MAJOR PHILOSOPHY ITEMS ADDRESSED) 1. NO SURFACE IMPOUNDMENTS 2. COMPLETE GED STORMWATER SEGREGATION (MINIMUM) 3. BYPASS OF 'CLEAN" STREAMS 4. IN-UNIT TREATMENT: SOURCE CONTROL HAZARDOUS CHEMICALS: STEAM STRIPPING/ WET AIR OXID. FREE OILS/ALCOHOLS: COALESCERS SOLIDS: CPI/FILTERS 5. ABOVE-GROUND TREATMENT FACILITY 6. ONE BIOLOGICAL TREATMENT SYSTEM FOR LCCC 7. STORMWATER TREATMENT (DAF, STEAM STRIPPING) VAB.0001125230 b -- - - ---1-r-in H*`W1! -MlK--.jl ttV LV k- : 1\*f: fr' <-r. SP: 11; r: .1: +\ -fi'yrt 'I f\* * +V. m J < -I' Is I ,-(^1 <1:: tlf-- * t j....................' tir ^ n> < u: i COST CASE 1 2 3 4 ONE END-OF-PIPE LCCC TREATMENT SYSTM SOURCE CONTROL WITH ONE END-OF-PIPE LCCC TREATMENT SYSTEM SOURCE CONTROL WITH SEPARATE END-OF-PIPE TREATMENT SYSTEMS FOR LCCP/LCLAB AND LCVCM ZERO WATER DISCHARGE 40.3 37.5 40.1 VAB.0001125231 * i- -!i**vMSjr'iA.--- .:hh,*i L|U HLfff ^' 'Ll -w :i--i:ivf i? MF*-i- m.- Ij:.r. '-.-it: i- --*.c 'tl -i'fr:!!>*'J htfry-iM r.- ! 1-0 I|%-. I- fl fl | '"'.''nn ..............f COST FORECAST ($MM) 4 WASTEWATER TREAT. 7.4 6.0 STORMWATER WAO (SPENT CAUSTIC) 10.6 8.1 0 6.6 STORMWATER TREAT. TANK-BASED ASU Y * PACT/WAO INCINERATOR (SAME) FY96* (SAME) 3.8 8.0 10.2 6.0 16.2 . . - i...,. -T|l _ :-U-" - pi : I-- '* ' H "" Vttrt `H ' MWI# ^1 utl [IIWlB U f. -ffsr -i i- P-M r 5 Epild' S' IHJ-r-H : V : VAB.OOOl125232 APPENDIX K (Partial> The following is a sampling of articles which provide random industry, environmentalist, regulatory agency and media viewpoints on regulatory issues. These articles can be quickly skimmed by reading the underlined passages. i VAB.0001125233 FORTUNE JULY P. 1989 THE ENVIRONMENT Bush wants to put a bigger broom to the skies, but most major pollutants have fallen. How dangerous is all this stuff now? And how fast do we need to move? by Edmund Faltermayer Meteerotogist Vfewy Aiwji studies what's killing traaa an North Carolina's Mount Mtchoff. EQRGE BUSH campaigned as a foursquare environmentalist, claiming that he wants to be the most ecology-minded occupant of the White House since Tcddv Roosevelt. Congress is more than eager to go along. After eight years of inactivity, it is primed to make the air fresher and the world brighter. But does the evidence justify the expense of the President's new clean-air proposals? Do the health hazards and the damage to crops, forests, and lakes cry out for legislation that could cost industry and consumers up to SI9 billion a year by the mid-1990s? Compared with other threats--drug Report** ASSOCIATE Sandra L. Kirsch gangs, slum schools, the budget and trade deficits--a tainted atmosphere seems less urgent. Besides, this is one enemy that is on the run (see charts opposite), thanks to the S34 billion a year the U.S. already spends on pollution abatement. But the progress appears to be slowing. Some acceleration of the cleanup makes sense, even though the research so far--some of it frightening--is largely inconclusive. Among the President's goals: Drastically reducing airborne toxic chemicals. About half these substances--a grab bag of 320 poisons--emanate from in dustry. By applying the best abatement techniques or devices available, factories would reduce their wastes so that cancer deaths associated with them--1.500 to 3,000 a year, the Environmental Protection Agency says--would fall 75% to 90% by the mid-J990s. Cutting sulfur dioxide emissions, the main ingredient in acid rain, almost in hall by the year 2000. Coal-burning electric utilities in the Midwest and Appalachia would carry out and pay for most of the cleanup. Power companies would also have to reduce nitrogen oxides, another contrib utor to acid rain escaping from their stacks. Breaking an impasse on ozone. A saint in the stratosphere, where it filters radia tion from space, ozone is an irredeemable sinner at ground level, where it is the nasti est ingredient in smog. Some 81 urban ar eas theoretically face federal "sanctions"-- bans on new factories, for one--because they have been unable to reduce maximum ozone readings to an EPA health standard that was set in 1979. The President wants stricter controls on auto tailpipe emissions, from which ozone forms, and on fuel va pors that escape from vehicles and gas sta tions. His plan would also phase in methanol (which is easily made from natu ral gas) and other clean-burning motor fu els, and would restrict the use of volatile, ozone-creating chemicals at petroleum re fineries. paint shops, and dry-cleaning es tablishments. Under the cleanup plan all but the three most ozone-prone cities would meet the EPA standard by the year 2000. The exceptions--Los Angeles. Hous ton. and New York City--would get a re prieve until 2010. Bush's offensive against ozone, the most persistent of the main pollutants, is hard to quarrel with. It is also difficult to oppose the President's clampdown on air toxics, which are believed to be linked to respira tory illnesses and birth defects as well as to cancer. But in the proposal to wring out acid rain, the politics have leaped ahead of the science. Proof that acid rain 125234 Cone *d < -Ih-V s - | . -M- FORTUNE JULY 1". 1989 Cont'd ing trees and fish is still not established. And while Washington worries about mountain lakes, concerns about the health effects of sulfur dioxide have been widely overlooked. stein. former EPA research chief and now director of New Jersey's Environmental and Occupational Health Sciences Insti tute, able job of cleaning up." For all its ambition, the Administration's plan is not as drastic as clean-air bills al ready circulating in Congress. Nor does it embrace some of the draconian steps that Los Angeles authorities have called for in a 20-year smog-fighting plan, which may ul timately require electric cars on those ten- OU SURE CANT say that about airborne toxics, which were largely ignored when the country went after the six-pack of pollut ants. Because of legal hurdles under pres- been able to set lane freeways. emissioos-Siandan' Commendabiy, the Bush plan allows for Air toxics include the flexibility. Power companies, for example, benzene that leaks from refineries and would be allowed to pick their own method cars, solvents like acetone, bits of synthet for bringing down sulfur dioxide and could ic rubber, and chemicals with names like even trade pollution permits among them l,2-dibromo-3-chloropropane (just call it selves. The President also advocates that DBCP). Also on this rogue's roster are industry use the cheapest, most cost-effec metals--cadmium and mercury--suspend tive measures in the early years. Thus, be ed as tiny particles in the air. fore the big spending must kick in, After the Bhopal disaster in India, researchers can learn more about pollu Congress passed a law requiring factories tion's health risks. And the country can get to disclose how much of these toxics they a clearer idea of how far and how fast it emitted. In March the EPA announced really needs to go. the total: 2.7 billion pounds in 1987. "The 4 It has already come a long way. For, numbers are staggering," says Senator more than a decade the EPA has set "air- Frank Lautenberg of New Jersey, who to quality criteria" for six major pollutants, gether with Representative James Florio, mostly expressed as the maximum allowa a candidate for governor of the same ble parts per million. The six are lead, state, held a press conference in April to sulfur dioxide, nitrogen dioxide, oaniciis- dramatize the problem. They stood at iaxes, carbon monoxide, and ozone. what they called "toxic ground zero" for ozone, says Dr. Bernard Gold amid the refineries and petrochemical plants near Newark Airport, where esti mated emissions are 110 times the nation al average. Lautenberg has introduced one of several bills that would force industry to button up. The President, too, is indignant, saving at his dean-air announcement: "People who live near industrial factories should not have to fear for their health." The neighbors' increased chances of getting cancer, according to the EPA, may be as high as I in 1.000. Still, keep a few facts in mind before making wide detours around Newark. The cancer risks assume day and night exposure over u 70-year lifetime and are based on animal studies open to debate. An EPA investigation several years ago shows that people mav have mnrt* tn fcnr from even/dav pollutants, such as cigarette smoke and paint thinners. ihqp frnm rhe chemical plant next door. For two days some 350 residents of Elizabeth and Bay onne. New Jersey--"ground zero" country for sure--wore monitors so sensitive they registered the effect of a visit to the dry cleaner. The dosage of volatile air toxics from those satanic industrial plants, it turned out, was a fraction of the total in haled--anywhere from one-half to oneseventieth, depending on the pollutant. The total intake of perilous stuff was no greater than in a tight industrial city in North Caro lina used for comparison, or the farm town T978 '87It978 '871T978 Sine* the nation declared war on six major poMutaata In the 1970s, four have been driven safely below the EPA*s standards (indexed '8711978 '8711978' * 8711973*V '*-V '87 here at 100). Carbon monoxlda is a problem in congested areas, while ozone, the lung-burning ingredient in smog, remains too high. VAB.OOOid:?2S5 FORTUNE JULY r. 1989 Coat'd THE ENVIRONMENT of Devil's Lake. North Dakota. Other million tons is not much firmer than research suggests that airborne metal dust near factories may be a more se an acid cloud. Last year the agency disclosed that 2.7% of all the miles of rious worry than toxic chemicals. Even if the health effects of air I streams surveyed in the East were acidic, and blamed industry and the toxics are hard to nail down, industry automobile for most of it. Yet an in lobbyists are not inclined to resist this terim report of the National Acid cleanup. Jon Holtzman dent of the Chemica Association, savs health V M Precipitation Assessment Program, a $500 million, ten-year interagency study that still has a year to go. found jhe debate over toxic no proof that acidity in streams and sequential if the public thinks there's lakes is getting worse. too much." Cancers caused by air Neither did the interim report in toxics are believed to have fallen 50% Fill er up: California taats clean-burning methanol fuoL dict acid rain as a destroyer of forests. since 1970. but the President's fur- -- Here the evidence is decidedly mixed. ther cleanup seems like a good idea. At a A ten-million-ton-a-year reduction in sul Maple syrup production in the province of cost of roughly S2 billion a year when in fur dioxide "has become the threshold of Quebec, whose decline in recent years had full swing, it is the least expensive part of credibility" within the beltway. Congress, been partly blamed on acid rain, rebounded his clean-air plan. led by Senate majority leader George 69% last year. According to the U.S. Forest Mitchell of Maine, is so determined to bat Service, the culprit killing trees at the sum AR MORE CONTROVERSIAL is tle acid rain that anything below eight dig mit of North Carolina's Mount Mitchell, the the proposed assault on acid rain-- its would have seemed the proverbial drop highest mountain in the East, is not pollu politically the sexiest item on in the bucket. tion but an insect called the balsam woolly Bush's checklist. Canada, where Yet sulfur dioxide emissions have al adelgid. which feasts on Fraser firs. Even so, much acid rain lands, has pressured Wash ready fallen 20% since 1977. to 20 million a combination of acid fog and ozone mav ington to cut way back. President Reagan tons a year, despite a huge increase in coal have made trees on this and other Easte stalled while awaiting more data. But his consumption by utilities. Scrubbers under summits more vulnerable to bugs, weatht. successor proudly telephoned Prime Minis construction at new power plants promise and drought. Volker Mohnen. an atmo ter Mulroney just before announcing his further, albeit slow, improvement. Nearly spheric chemist at the State University of proposal to halve sulfur dioxide emissions all cities are below the EPA health standard New York in Albany, who monitors the ef to ten million tons a year. for both sulfur dioxide and nitrogen diox fects of acid rain in the Northeast, says pol Why the hurry? Explains economist Paul ide, each of which can return to earth as lution should be brought down a lot even Portney of Resources for the Future, an en acidic fog, rain, or snow. though its role in forest damage has not been vironmental research group in Washington: The science underlying that magic ten firmly established. Health concerns, largely overlooked in the crusade to save the trees and fish, mav turn out to be one of the best reasons to keep whittling away at the emissions that cause acid rain. About 25,000 of the country's ten million asthmatics are prey to violent bouts of constricted breathing when the sulfur di oxide level is high but still within the EPA's health standard. Because of this the agency has considered--but dropped for now-- adopting a stiffer criterion. The EPA is also looking more closely at so-called acid aerosols (no kin to aerosol sprays in consumer products) that can form from both sulfur dioxide and nitrogen ox ides. A Harvard study, which has been fol lowing the respiratory health of 18,000 children and 10.000 adults in six cities since 1974. has found that children's bronchitis rates go up when the aerosols rise. Other researchers have noticed higher hospital ar missions--even a small but significant num ber of premature deaths--following an increase in sulfate particulates that are asso Based on 1988 data, thaso areas can't gat peak oxona readings below the EPA maximum. ciated with acid aerosols. The EPA may eventually set a separate air-cya^|g^Q@^25236 Cont *d JULY 17. 1989 FORTUNE Cont'd THE ENVIRON ness of breath while playing tennis or golf 2 on summer days in Los Angeles. And the i EPA says ozone's damage to crops is cost 8 ing farmers S2.5 billion a year nationwide. In 1984 Dr. Henry Gong Jr., associate chief of UCLA's pulmonary disease divi sion, put 17 Olympic and other cyclists through one-hour tests in a smog cham ber at various ozone levels. They pedaled vigor ously for most of the period, using 80% of their lung capacity, and then made an all-out effort as if approaching a finish line. When Gong revved up the ozone to the federal standard of 0.12 ppm, he says, the cyclists "couldn't tell the difference" over normal air. But a level of 0.20 ppm "significantly compromised them. They couldn't ride as long or as hard." Other research has shown that at that level, the lung capacity of healthy people decreases by about 15%. Af ter repeated one-hour exposures, the effects diminish, suggesting that the body adapts. dard for acid aerosols. But until more is ic health emergency." But what if such exposures go on for years? known, the President's attack on acid rain, Anyone coming to the subject cold They have in Glendora, an affluent sub which could raise residential electric bills might wonder what the fuss is about. Some urb of 50,000 at the foot of the haze-ob as much as 20% in the Midwest, may be tOO million Americans live in those 81 ur scured San Gabriel Mountains, which trap overkill. ban areas that exceed the federal ozone the smog moving east from Los Angeles. standard, but the numbers overstate the Glendora was America's ozone capital last risks. A city "violates" the standard if only year, breaching the federal standard of 0.12 by far the most toxic of the usual one of several monitoring stations has a ppm on 148 days. But the number of alerts outdoor reading above 0.12 parts per million (ppm) has fallen significantly. The last second- mental physician Goldstein. Sun for one hour on two separate days in an en stage alert, which comes when ozone hits shine and two parents produce ozone at tire year. Even in the Los Angeles area, the 0.35 ppm, was about ten years ago. Four ground level: nitrogen oxides, which result readings on 35 monitors are below that lev teen first-stage alerts, called at 0.20 ppm, from any kind of combustion, and volatile el 95% of the time. During the 1984 Olym took place in the 1987-88 academic year. organic compounds (VOCs) tike gasoline. pics in Los Angeles, athletes did not But because of unusually good climatic The destructive offspring is a variant of ox complain about smog. So what's the big conditions, only three occurred in the ygen composed of three atoms instead of deal? school year just ended. During the alerts, the usual two. It can hardly wait to get rid To begin with, the Olympians benefited typically in the late afternoon, a black flag of the loosely attached extra atom, which from good weather and strict temporary with the letters S-M-O-G goes up at the oxidizes--or burns--anything from paint measures to reduce freeway congestion. high school. To the grousing of athletes to soybean crops to the inside of your lungs. Every year thousands of healthy people ex and coaches, outdoor team practice is de The tailpipes on today's new cars emit perience chest pains, coughing, or short layed for about an hour and a half until 76% less nitrogen oxides and 96% __ __ readings drop back to a safer level. less VOCs than those of a generation ago. But vehicle traffic has soared, and other ozone outputters--manu er. Gone monitors bicyclists in a UCLA smog chamber. More than 1,100 nonsmoking *** Glendorans age 7 to 59 participated in the only study of the long-term effects facturing companies and utilities-- have cut back less or not at all. A 2 of ozone on humans. A team led by ^1 Dr. Roger Detels, a UCLA epidemiol typical city's ozone concentrations ogist, compared the volunteers' lung declined only 9% between 1979 and 1987. With no new legislation, im functions with those of a similar-size group in Lancaster, a town beyond the provement would continue for a hills and far (ess polluted. The subjects while as older cars are scrapped. But were retested five years later. Every with traffic still increasing, total VOC emissions--and ozone--will start to climb around the turn of the century. David Hawkins of the one's lung capacity increases through the late teens and then goes into a steady decline. But the Glendora group had somewha^l Natural Resources Defense Council, to begin with. Mor an environmental group, contends lung capacity grew more slowly there. Cone fd FORTUNE JL'tt I 19$9 Cont'd THE ENVIRONMENT Vinyl cWoridt plants Uka ona in Loniaiana havt wwitttd Urtt amounts of air toxica. healing r ^uirwubu IUU50 kins of the Natural Resources Defense Council likens the effect to that of repeated sunburn, which turns the skin leathery. Eastern and Midwestern ozone may have a partner in crime. Dr. Morton Lippmann. a deputy director of New York University's Institute of Environmental Medicine, who ran the New Jersey summer camp study, suspects that acid aerosols aggravate the lung damage. Is ozone shortening people's jives? Nobody knows. Lippmann says, `but it could be reducing the quality of life at the end of our lives.'1 Fran rw -Assneiarinn adds. "We may O reduced lung func tion or c ung disease as adults." ______________________________ tatistics deplorable: "We're talking billions for ex- penditures to cut ozone, when only pennies are needed for research that might give us the answers." For now, jogger Goldstein is putting his running shoes where his mouth is. During heat waves he gets his run in ear ly near his New Jersey home, before the sun sends the ozone climbing. and adults' declined more rapidly than in Lancaster. The S2.5 million study had meth odological pitfalls, but strongly suggests that ozone is bad stuff. Says Detels: "We've looked at other possible explanations for the differences in the two groups, and haven't been able to find them." Don't cry just for Glendora. Your own community may have ozone problems too. in most of metropolitan Los Angeles, says Dr. Jack Hackney of the University of Southern California, a longtime pollution researcher, ozone episodes come in short but intense bursts. In the East and Midwest, cities exceed the federal standard fewer days per year--typically 20 or so in the New York City area. Peak readings are lower, with New York reaching 0.21 ppm for at least one hour last year to Glendora's 0.34. But the ozone in the Northeast Corridor, particular ly during heat waves as the air travels from one city to the next, extends far. Kennebunkport. Maine, was repeatedly above the federal standard last summer, as a deputa tion of environmentalists reminded the President when he was preparing his legisla tion. Even when the readings are not espe cially high. Eastern and Midwestern ozone can linger at. or just below, the federal stan dard for most of the day. Instruments in Camden. New Jersey, of ten pick up ozone levels that average more than 0.10 ppm over eight hours. Such read ings occurred on 38 days over a three-year period in the mid-1980s. That put the area just over the Occupational Safety and Health Administration's all-day standard for exposure on the job. As recent studies at the EPA's smog chamber in North Carolina show, that's high enough to affect anyone outside, from kids to carpenters. At that level and even lower, the lung capacity of 22 nonsmoking males who exercised mod erately but with rest periods over 6.6 hours--walking briskly up a slight in cline--dropped by 7% on average, which the researchers found statistically signifi cant. Just as meaningful, the loss of lung power became progressively greater after each hour of exposure. In normal air the next day, the test sub jects regained full breathing capacity. But recovery may take longer after a prolonged ozone spell. That was the experience of children at a New Jersey summer camp who were examined several years ago after four successive days in which readings shot past the federal standard for at least an hour. Their lungs were impaired for up to a week after dear skies returned. Based on what has been learned in animal tests, re searchers believe that in long episodes ozone bums away cells that take five to ten days to regenerate. Years of burning and F HIS HUNCHES are right, the air Icleanup should not just coast along un til hundreds more bicyclists have huffed and puffed in smog chambers and thousands of citizens have paraded past epidemiologists. How big a bill should industry and consumers be required to pay ? Says Portney of Resources for the Future, who has been working on cost-benefit stud ies of the Los Angeles 20-year plan and who has felt his own lungs burning there: "We may not want to spend every last dime to get ozone down to the EPA standard ev erywhere. But we will probably want to spend a lot to lower it." Whatever the right goal, let's also be look ing for ways to achieve it at the lowest cost. James Lents, a tail Tennessean in charge of air pollution control for the Los Angeles area, believes his region's plan will prompt an outpouring of money-saving business in novation. Under the proposal, furniture makers must drastically reduce volatile emissions when applying varnish. Lents asks, "What if we come up with a better method of coating the product? Is that bad?" A debt-laden nation with such a big agen da has no choice but to pinch pennies, even on something as precious as the planet. Es pecially when the dimensions of some parts of the problem are still as hazy as New York City on a smoggy summer day. g ChamicaiWMMMay 17, 1989 SPECIAL REPORT he diverse field of water treatment is growing ever Tmore complex. Legislation and regulatory concerns are to a large degree driving growth in the industry; they've been the focus of previous special reports on water treatment [CW, May 18. 1988. p. 18). This year, we've peppered the perspective with insight from producers and users of water treatment goods and services. Chemical companies are concerned with the enormous financial burdens imposed by current legislation and regula tions. They argue that some requirements are redundant And in certaincases, practical technology doesn't yet exist to meet the government's water purity standards. While the regulations will clearly benefit water treatment firms, they may well threaten small chemical companies' stnncen laws. Mew treatment technology is emerging fast, especially in automation, substitutes for environmentally unacceptable treatment chemcials. and alternative container and delivery svstems. _____ chemical comoanies deal t minimization are becoming increasingly important INDUSTRY TOUGH NEW RULES The chemical industry lost a major battle over wafc ons t spring when the U.S. Court of Appeals for the Fifth Circuit in New Orleans sweepingly rejected its challenges to EPA wastewaterregulations. The March 30 court decision, which upholds EPA's 1987 Organic Chamii tation guidelines, will require new tech* its some i ,uuu chemical The chemical industry also faces tougherregulations on a variety ofother fronts. On May 2 EPA sought to nearly double the number of pollutants sub ject to federal standards under the Safe Drinking yVatar Art The agency now has limits oantsbut or a total of 83 contaminants hy June. The action could signifi- cantly affect industry, because such standards are used as ref erence levels in the cleanup of hazardous-waste sites under both Superfund and Resource Conservation and Recovery Act (RCRA) laws. Meanwhile, legislative ini tiatives under ____ Act, reauthorized bv Congress in 1987. will nonpoint source pollution and toxic not spots" in waterways. And EPA recently proposed new regu lations on t " mean additional pollution controls for the chemical industry. * In mid-April EPA released statistics to detail the potential water-pollution problem. As part of its first comprehen sive inventory of chemicals emitted * into the nation's water, air. and land. EPA noted that 9.7 billion pounds of chemicals were released in bodies of water, and 1.9 billion pounds were sent to municipal wastewater-treatment plants. To be sure, the environmental sig nificance of the numbers is undeter- mined. For one thing, sodium, sulfate constituted 95% of the reported re leases. and EPA has proposed--in re sponse to an industry petition--to de lete that chemical from the toxic-emis sion reporting list because it has deter mined the chemical has no apparent adverse human-health or environ mental effects. The other five percent consisted primarily of 12 chemicals, some of which are regulated bv EPA. Hltfi price tag. The New Orleans court decision could--bv EPA estimates--cost industry some S500 mil lion/vear. Indeed, experts sav ths tougher limits wiil roughiv Hrmhl* rha price of treating wa.VBwatPr The deci sion could be particularly crippling for small manufacturing plants: some in dustry observers predict a substantial number will be driven out of business by the costs of the new regulations. The EPA rules set tough limits discharge of pollutants jn several categories. Based on what it determined were (BATs), the agency estab lished limits also limit* conventional pollutants based on best-oraft^ai-^h- nologies (BPTs). Finally, the EPA regulations include .pretreatment standards for ubliclv owned treatment works (POTWs). The rules have been a Ilong time coming. Ori^EkffiLM)!125239 Cont. Chemica!weK/May 17, 1989 Cont. SPECIAL REPORT proposed in 1974 and 1976, they were analysis in setting BPT limitations. hard work. But, he adds, "it can be finally issued by EPA in November CMA also objected strongly to the achieved. " 1987. Almost immediately, the regula technical basis used in establishing the The battle is all but over. While tions were legally challenged in sepa BATs and the resulting limits on efflu CMA has petitioned for a limited re rate petitions by facturers Syntheti turers Associa and the emical Manufac- ), as well as ent releases. CMA argued, for example, says Perelman. "that (EPA) distorted data" by questionable methods to de termine limits possible with BATs. hearing on a few points in the court decision, others say they will not con tinue the legal struggle. In any case, says Campbell, "industry needs to get cal companies. Tak ing issue with dif ferent specifics, the groups generally FEDERAL LAWS AFFECTHQ WATER QUALITY _____ revised in treatment and disinfection, radionu on with it. Clearly, companies can't stop and wait; they have to be in the compliance 1987, provides grants for wastewa clide control, and a ban on lead solder mode. Industry tech- ter treatment plants and sets limits and pipes. representatives of rules. But in March. th rnnrt-- siding with EPA on discharge of pollutants. Recent amendments address nonpoint source pollution, toxics, sludge disposal, and estuarymanagement He ^ uthorized in 1984, protects groundwater by requiring stronger, safer tanks for underground should not think there is any realis tic hope of turn ing this around. " storage of chemicals and petroleum Despite its in e are disap pointed with the ruling of the court," says Charles Malloch, Monsanto's director of regula tory management. "Faced with highly technical issues, it appears the court gave great deference to [EPA's] judg requires EPA to set national drink ing water standards, protects drink ing water from underground waste injection, and provides special pro tection for wellheads located in sole-source aquifers. EPA must issue regulations for 83 contami nants by June 1989. The 1986 amendments will impose new bur dens on the drinking-water indus try, requiring further surface-water and establishes a system of response to petroleum spills and financial lia bility rules for tank owners. ___ reauthorized in 1988, provides EPA with authority to act swiftly to protect groundwater in emergencies. A primary goal is to preventtoxics at hasHdous-waste sites from leaching into groundwater. Source: Congressional Research Service volvement in the court case, says Monsanto's Malloch. his company has been actively moving to meet the regulations since 1987. "In some cases we'll have to scratch," he says, "but we will meet them." ments." Suggests Douglas Kliever, a lawyerwho represented SOCMA in the case, "the regulations will have an adverse impact on U.S. industry, with out commensurate environmental benefits." Small chemical plants could have particular economic problems comply ing with the regulations, says Kliever. because they lack the economies-ofscale associated with larger plants. Moreover, many of the small facilities tend to be batch producers for whom control of effluents will prove more difficult, he suggests. In its petition, SOCMA argued that a separate cate gory with less stringent pretreatment requirements be established for small chemical plants that discharge wastewater into POTWs. According to EPA's estimates, says Kliever, about half of small plants will be significantly and negatively affected. "No doubt," he adds, "we will lose some plants and some products " due to the costs of compliance. Meanwhile, CMA challenged tech nical procedures and economic analy ses EPA used to develop the regula tions. CMA counsel Dell Perelman says that while EPA is bound to "look at economics" in establishing the regula tions. it failed to use appropriate cost- Even the best or most appropriate technology cannot meet the standards all the time. Given EPA's own method ology, explains Hugh Campbell, con sultantmanager forthewastewatertreat ment consultant group in Du Pant's engineering department, even a model plant will be in compliance only 99% of the time because of effluent variabil ity. "It really puts you in a Liable situ ation." says Campbell. "We wanted EPA to acknowledge the problem and deal with it on a formal basis. But we got no relief hom the court. " Not surprisingly. EPA strongly sup ports both the regulations and the proc ess by which they were developed. Dov Weitxnan, EPA's acting assistant gen eral counsel for effluent guidelines, paints out that the final regulations were the result of over a decade of analysis, visits to industry, and several preliminary drafts. Indeed, he says, the cost analysis "was probably as detailed as (any) the EPA ever did." In deterxning BATs. explains Weitman. the agency extensively ana lyzed the best performing facilities in the industry. The purpose ofthe regula tions. he savs. was to see that tfie entire industry improved to the level of performer.' Uetting there, he acknowledges, will entail expense and The main thrust of the Clean Water Act continues to be construction of wastewater treatment facilities; nearly S50 billion has been distributed since 1972 to aid communities in build ing plants. EPA is still developing and improving the pretreatment program that requires industries to treat their wastewater before discharging it into POTWs. The agency is forcing 1.500 municipal wastewater treatment plants that handle more than 80% of all in dustrial wastewater discharged to such facilities to develop effluent limits for industries responsible. While most of the facilities have developed a plan, many are just begin ning to implement them, and one EPA report says that at least 47% of the POTWs with approved programs may still not be in compliance. Another area getting increased at tention from EPA is nonpoint source pollution, such as rain runoff from farms, urban areas, and construction sites, contributing as much as 65% of water pollution. The 1987 revisions to the Clean Water Act require states to develop control programs and identify waters where standards are not being met. EPA has just completed work on a strategy for controlling such pollution, but funding woes have held up any real Vii01125240 4 I ChemicalweeK/May 17. 1989 Cont. C91T; JffuflTaiArLTJu .PKFJsUdrrUiKP.TJ. some ofthe standards." Gomperts claims handle a 10- to 20-miLlion gallon-per- Baker contends. He that the Kodak water day (MGD) system. While he agrees calls for logical and fair treatment system is one that the large prices such systems rules that could not of the best. Still, those command will generate intense devel onlv lead to a better last few parts per bil opment and competition, he doesn't environment but also lion will be elusive. He expect a low-cost solution to result any "make the plavine field cites a common equa time soon. even" for all competi tion in wastewater Gomperts--whose plant treats 30 tors in the business. treatment: The equip MGD and could handle six MGD ment and chemicals more--doesn't expect new develop needed to remove the ments to solve the problem to any great Fast 5% of the organics extent. "There are a lot of neat little water treatme: stream mav technologies, but they are just not tHejjtuv down the river cost ud to twice as applicable to a 36-MGD stream. I've oesnt spend a dime much as t_________ been going to the trade shows for the ere 1 remove the first 95%. past five years, and I haven't seen much could compete Numbers vary widely progress, not in large scale systems. All by company, effluent the refinements are for 2-MGD plants ut as Monsanto characteristics, and or smaller." environmental protec condition ofthe receiv The developers of treatment tech tion manager Mike ing stream. "We've nology "are just not responding to our Foresxnan says. "We been throwing around needs at this stage, but it's hard to get are looking at regula numbers like 50 or 75 people to take a risk. There really should tions that have been million (dollars be something else (besides regulation] through a lot ofreview. come into full comnli to spur development," says Campbell. So while we may not ance with the new EPA But he is hopeful: "Maybe new tech like them, there is no organic effluent guide nology will be coming, now that the sense standing around lines. And that's iust market is there. " and yelling about it. Metals and Shirting tbs load. New methods The realization is that inorganics are com notwithstanding, wastewater treatment we have deadlines to pletely another thing." facilities must always be viewed as meet if we are going to stav in business and KailMMS Thwt isn't much continue to operate." of he adds. part of the whole processing line. Doug Keilman. di Changes anywhere in that line will rector of environ affect the whole system. He does believe permit-review hear mental affairs for Hercules, savs. "A 3M (St. Paul. MN). for example, -*1 ings for individual sites will allow the basic biological unit will do the job installed a wet scrubber on a new ro company a chance to work with regula most of the time, but there isn't much of tary kiln, which just moved the con tors. ironing out compliance problems a margin for error. It's so much easier to tamination from outgoing air to outgo and perhaps proposing changes and get the first 95% than it is to get the last ing water. The company recycled 60% alternatives. 5%. especially with OCPSFguidelines of the water and precipitated the rest of Several industry experts observe in the 5-to-10-parts-per-billion range." the particulate withasimple limetreat- EPA mav intentionally set new efflu- "As vou invest * ent levels at the outer edge of the exist oodles more money --____mern- But a high vol ume of sludge re ing technology to force development of to get that last per sulted. new systems and methods. "That might centage." notes Gom not be the intention." says Hugh perts, "usually you Russell Susag. di Can the product rector of environ Campbei 1. manager ofwastewater treat have to add some ment for Du Pont, "but that will be the thing to get some support the mental regulatory af fairs for3M. notes that outcome--and that is not a fair ball- thing else out. And game. " everything you add water treatment this is often the case with scrubbers. And One engineer responds a bit less you've got to pull out subtly. "That's great." he exclaims. "but again. That means research? steam or air stripping the waste stream only they're not the ones who have to pay oxidize -- with returns the pollutants for all the new stuff." ozone, with chlorine, to the air. "As you get In light of the failed court chal with ultraviolet down to that nth de lenges. Bob Gomperts, general super light--or filler or sorb. But then what? gree. you are actually generating large visor of wastewater treatment at East- We'd have to put in another incinerator amounts of secondary waste and using (Rochester. NY), notes a for that sludge." lots of energy to do it." he says. strategy that is just now paying off: Even when capital is available for Nevertheless. Susag feels that his "We spent our money investigating and specialized treatment, there may be no company can increase the efficiency building treatment technology, rather good way to spend it. On the more and reliability of its exisiting svstem. than in court." exotic: tertiary treatment methods, such "We won't need the exotic methods if 95/5. New regulations are a groat as carbon sorption and reverse osmo the svstem is reliable." obstacle in terms of time and money, sis. Dow s Ki patrick thinks the tech Um is Isss. "There is work to be because the law of diminishing returns nology might not even exist--at a prac done on optimizing the cost of waste has replaced economy of scale. tical scale and a reasonable price--to treatment." says Monsanto's Fores^gi^Q^125241 Cont. ChemicaiweeK/May 17. 1989 Cont. SPECIAL REPORT progress, says lim Horn, policy direc tor for EPA's Office of Water. Congress has also established a pro gram to deal with "toxic hot spots.*' States must list waterways that don't * meet health and aquatic protection standards and propose cleanup strate gies. This can involve tracing pollution back to an industrial source. EPA must approve such cleanup plans by June for states that have submitted lists, and waters are scheduled to be in compli ance in three years. In December 1988. EPA proposed that thousands of industrial sources apply for permits to deal with storm water discharges. New manufacturing facilities will have to install collection ponds to allow pollutants to settle be fore the water is released into water ways. The agency also has issued a contro versial proposal to regulate contami nants in sludges produced by munici pal sewage-treatment plants. Such measures, say industry observers, are sure to eventually affect some of the chemical facilities that relv on POTWs. hottest adopted their own ornun _______ _ water pollution. taction programs. Among the toughest because it is the only major area stil are Florida's systems for classification, unregulated at the federal level through monitoring, and wastewater-discharge a comprehensive law. EPA reports that permitting. And Iowa has placed a tax at least 8,000 wells across the U.S. have on the sale of pesticides and hazardous been closed or degraded because of household chemicals to help pay for contamination. Late last year, theagency groundwater cleanup. confirmed that 46 pesticides had been But even as more rules take effect, detected in the groundwaterof26 states some observers see a fundamental regu due to normal agricultural use. latory shift horn specific technology- Both houses of Congress approved based discharge limits to ones based on money for further groundwaterresearch water quality. The move, explains but didn't enact the bills before last Monsanto's Malloch. means the next year's session ended. Anyway, says round of permits will start requiring Velma Smith, director of groundwater companies to run programs for the Environmental Policy identifying anv toxics in waterways Institute (Washington. DC), "the envi a.nd eliminating the toxicity ronmental community will be pressing than just responding to specific li for a bill that requires more than re on a list orf poluluuttaannttss.. Ti hnat,. nhe says, search. We want a national regulatory will "make it more complex" for com program for groundwater." This year, panies. And while he is not opposed to that's not likely: Congress is too the change, he adds. "Let's make sure wrapped up in Clean Air Act revisions that it is done-right. Ft to make much notable progress on groundwater. CONRAD MA CKERRON Meanwhile. in Washington ent federal policv. some state i with David Rotman WATER TREATMENT RESTRICTIONS SINK IN For several years, chemical compa nies have sought to minimize or mod ify effluent streams, anticipating the day when costly regulations would mandate such treatment. That day has arrived. And one source savs the price ew will be "at least a couple of billion [dollarsl on top of what we already have in place." ~~ ost firms use a series of treatment levels: pretreatment to remove specific substances and return others to the process: primary systems to screen, filter, skim, and settle: secondary treatment with * biological activity; and added tertiary chemical systems. But the expense of such methods pales compared to what is now required. "The cost nf further rerinr- L I the pollutants ini an ef- uent stream is tremendous." savs Steve Kilpatrick, water issues manager with the Envi ronmental Quality Depart ment of Dow Chemical. Two Wilmington. DE giants have tried to quantify the tremen dous costs: capital budget for domestic ponminn control isS3Q milling. thre^imrtere nf which will go for wastewater treatment: somewhere betwe Faced with such expenses, "we challenged the EPA Organic Chemi cals. Plastics, and Svthetic Fibers (OCPSF) regulations and failed. " states Jim Baker, associate director of envi ronmental affairs for Union Carbide's chemicals and plastics business. He savs Carbide's main far-ill exas City, TX. designed in mope tion with Sterling Chemicals (Hous- i). was _____ _________ __________ ____striai wastes. Yet the new regulations require additional pretreatment. "It will take S50 to $60 million for Carbide to meet the OCPSF guidelines, halt ofwhich will be redundant. " Baker predicts. Variances and removal cred its--which allow removal of a given substance at one site to compensate for pollutants at other locations--won t be "practically available'' until 1992. he maintains. What everyone in the chemical * industry wants is "logical and fair regu lation. uniformly applied." according to Baker. "We support the wise use of all resources, and that includes the time and money of the regulatory agencies." he says, implying that the gov ernment's resources might benefit business and the envi ronment more with a different type of regulation. Chemical companies aren't opposed to clean, water--"We drink the water, we swim in it. and we fish in it." savs Baker-- but they question the logic behind some of the rules. "We're not sure the tech- 1125242 Cont. CMmicaiweK/Mav 17 1999 Cont. "There's great incentive to modify the 3M took the theory one step further. processes, to reduce waste [requiring "We had a problem with ammonia in treatment]. That is where the money one waste stream." Susag relates. "We will be. All the easv stuff has alreadv w would have had to spend more than a been taken out." million dollars on a removal system. As regulations get tougher, the costs But instead we spent that money on a of waste treatment factored into the concentration system, and now we whole cost of manufacturing can tip the balance against marginally profit* able products or obsolescent processes that might have to be completely re placed. "We have to look at processes that aren't efficient." savs Foresman. "We have to figure, do we really need the product?* In some cases the answer i*s_ I no. He also believes forward thinking can save a lot of money down the pipe. While it is impossible to predict which substances considered safe today may be restricted in the future, manv efflu- ent professionals are forcing research and development staffs to take edu cated guesses. Foresman espouses a simple philosphy: The key question is. "Can the product support the [water treatment] research?" Decades ago. questions like these weren't asked; waste treatment was simple. "We started in the 1960s with the settling ponds and have backed up into the system since then." says 3M's Susag. "Now those same ponds are called `polishing ponds.' at the very end of the treatment process. " And such "backing up" goes all the way to the design stage of new prod ucts and processes. Ail developments must undergo an environmental re view to ze if any hazardous or exces sive wastes will be put into the effluent stream. Such reviews, as well as recov ery and recycling, go on at most com panies. says Susag. Om man's moot.... Recycling does not have to mean just returning process chemicals to the system. At Colgate- Palmolive's Jeffersonville. IN plant, surplus acid from a manufacturing line is used to adjust the pH of the equaliza tion basins, and condensate from the power/steam plant is used to maintain biological activity in the activated sludge basins during harsh weather. Recycling doesn't have to be re stricted to a given process, a given fa cility. or even a given state. "One of our plants in Alabama was treating zinc j chloride as waste in its effluent." Susag 1 relates. "Then we discovered that an I other plant, in Connecticut, was buv- 1 mg zinc chloride as a raw material. So : we started shipping the stuff up to Connecticut." Thecost of shipping still i allows a considerable savi ngs--for both 1 sites. I I recover the cost of treatment by selling the ammonia as a feedstock for fertil izer. " Making the whole business profit able could be the ultimate advance ment in water treatment. GREGOR Y DL MORRIS VAB.0001125243