Document peqvwknRNmg23LoXGZq9XRmBd

I -* M J 01 Acct NO HG-0713-S] Portable 02 Inv Data 4/9/641 THIS AH CONTROL 10i Action Code [ ] Hour/# t 10 1 03 County Harris ] Juriadlctlon [ 070 ] SS: AA[X ] IAt J DAI 04 Co Nob* Tenneeo Polymers, Inc, ]Fad Fac [ ) FA t 05 Fit Nana 1 PSD Fig ( J S02 t 06 Mall 1 Post Office Box 849 1 EFA Cla t 1 voc t 07 Mall 2 ] A1/A2 Ho( 1 t ][ 0B Mail: City Pasadena St Texas zip[ 77501 1 A2 SchYrt J t 1( 09 Location ] Fr Rg Fl[ 1 t 1 ( 10 Near City 11 Group 12 Mgr Naaa 19 C. l.'stuW J] Loe Zip{ 1, TSF Attn[ Frncpl Sanaa [Polyvinyl Chloride am Methanol J 1 13 Title Manager ___________________ 1_____ Phff 713 i-f 479/ 3411 ] 14 Feral t No 15 R-Pt Eng 16 CAFS Ft# 17 Ernie Ft# ][ All NSFS Ft a [ 1 Ft Dcact C-Feralt Engineer Approve / Exempt / Void / Deny / Hold / Dlacuaa____[_ ] All NESHAP Ft a t ] Fred Reg Fol [ T __________________________ 1________________ IB Act Code ] 19 Inveetigat on Typ: burning [ 20 Obser Snpl ] Rule 7/8 [ 21 Src Surv J Vehicle ( 22 Inv Codea 07d 1U It 1 ] Complaint [ j. Saapllng [ ) NSFS t ] Peralt l 1 Nod-Inv ( ] SIF [ J] Site [ ] NESHAP [ Xj Other [ Inv I.D, [SXM 1 J_______ COMPLAINT t DATE RECEIVED 23 [ // J- t / / J 24 [ // JI / / 1 _____LJL___1_ t / / 1 ODOR SMOKE t1 t1 f1 tJ ____LJ_____L } DOST OTHER tJ t 1 t1 I J __L_1__J________ _L 26 REPRESENTATIVE SAMPLES: Saapllng Raau^ta to Follow:- T or N: [ ] TYPE SOURCE POLL'T TIME actual RATE ALLOWABLE RATE ZMAX 27 t H It ]t Jt 1l J t 1 tI f 28 I H ]( - 1 t 1t 1t 1 t 1 t1 t 29 t H H 1t Jt 1t 1 t 1- t 1 t Eaiaaion Rata Code: lb/hr - 01; lb/D - 02; T/T - 03; SCFM - 04; PPM - 05; FFB - 06, J 1 1 ug/H3 - 07; GR/SCT - 08: lb/MBTU - 09; I - 10; None - 11__________________________________ NOV: Rule Rule Local Order 30 l It H It 31 Src t 1 Srct J Srct ] " Srcl 32 Abatement Letter: Y or N: [ 1 Hl/Lo Priority: TCAA .1 t 1 ] Src[ J (Enf. Act. Req. T or N):[ 1 33 If Eniaelon Statua Undeternlned, WhyT Pit Dwn[ ] Fart Opt ] Need Snpl[ ] 7/8[ ] 34 Other [ ] Sched Date ActTyp 35 I / / ) t ] 36 I / / J t ] ID t1 t1 t t Conaenta Coda Lina 37 I Jt H 38 t H It 39 [ ][ ]( Text Entries 40 Feraon Contacted Xachtlck 41 Photoa: Yea No X .h/r. Ihveitlgator(a) I.UihI!::. < Date sjill ^ VI *1 |ITt#tT1 aaa**a r* * ApprovedBSy Fage I of* Fagan Ifclta .... OriginalCanary ... Keypunch Pi tit .... Region Green .... Peralta Goldenrod . . Ella TACB-S1 Fora (10/82) TEN 2521 O Investigator's Ctnrmts Tenneeo Polymers, Ire. Pasadena, Harris Courty o H0-0713-S 4/9/fit . Page ? An annual compliance Investigation was conducted on April 9, 19P* at Tenneeo* Polymers, Inc. nUr1ng this investigation, Richard Glgger of the Fnvtrorrwntal Protection Agency's (EPA) Houston office accompanied me for a MFtHAP overview Inspection, f'r. J. W. faehtlck provided the requested Information during an office conference and later arranged a thorough plant tour, using a portable VCC monitor we checked several valves and detected no leakages. We also observed the company's computer recording systems of Its monitoring points and Its calibration rictliod. %r1nn the plant tour, Hr, Glgger found a minor violation of 1E5HAP Pule 40 CFl> fil .fiS(b) (Q)(11t)(B). The calibration gas cylinders were not marked with Its date of preparation and Its maximum shelf life, wnen this was brought to the attention of Mr, K#chtfek, he replied that the cylinders were received without such Information. Beside this minor violation, the company was found to be In compliance with the Board Pules and Regulations and CPA's Standards for vinyl chloride. * Tenneeo has only two process units at this site. One Is a methanol plant which has been out of service since 1R? and the other is a PVC plant which Is operating at approximately full capacity. The process details are confidential and PVC plant emission sources and enlsslons have teen mpnrted In inn*) $jp report. Therefore, these details will not be presented in this report. However, a general description of the suspension process used In *VC production Is given below. POI.TVIHVI CHldPIDE PPQhUCTIOH bsckoround: Polyvinyl chloride (PVC) resin Is one of the most versatile synthetic resins. Production and uses of this resin In the united States Is estimated to be 5 to 7 billion pounds In a year. The resin Is used In a wide range of end products. The major uses are In pipe and electrical conducts, floor covering, Insulation for electrical wires and cable, water hoses, and phonograph records. PVC can be produced by using one of the following four different-methods: (1) Mspenslon polymerization, (?) Bulk polymerization, (3) Suspension polymerization or (4) Solution polymerization.- The common characteristic of all process Is conversion of gaseous VCM to the granular PVC. The suspension process Is the most comon method of polymerization. This method accounts for about of the total pYC produced In the United States. Tenneeo uses this technology; therefore. It Is described below In detail. Suspension Polymerization; Tenneeo has ten PVC reactors with the capacity of about gallons each. The reactor Is charged with water, monomer, catalyst and other additives depending on the quality of the end product desired. The reaction takes place under pressure. Initially the reactant temperature Is raised tp start the reaction. It Is an exothermic reaction; therefore, a certain tenperature Is maintained by using hret transfer Jackets. When the monomer conversion has proceeded tn a desired degree the reaction Is stopped. The unreacted monomer Is sent back to the recovery system. The resin slurry Is then transferred to five slurry tanks. The unreacted VCM from the' slurry Is removed by means of a stripping method. There are five slurry strippers. The slurry fron toe reactors Is pumped through', screening units, and stored In slurry tanks. The mixed slurry is then sent to continuous stripping columns where VCH is reduced to helow 400 ppm. The recovered VCM, Is sent to the storage tank tor recycling. The non-condensibles are passed' through a chilled condenser and a carbon hod before belnq fed to the Incinerator where VCM 1$ reduced to belnvi 10 ppm. Heavy fractions from the bottom of the strippers are also incinerated. TEN 2522 o Investigator's rodents Tenneco Polymers, Inc. Pasadena, Harris County o >10-0713-S ' 4/9/94 Page J The stripped slurry Is filtered through centrifuges where a large amount of water Is removed. Finally, the resin Is dried by using hot air dryers. The fines are controlled by cyclone separators. The dried product Is screened Into different sires and smcl f Icatlons. The final product Is pneumatically transferred to silos. The particulates at the silos are controlled by bag filters. The company uses a closed system for PVC loading fren the silos to the railcars. About of the relief valves throughout this plant are tied to a flare. It Is net a steam Injected flare. The company has claimed that the flare has 95X efficiency; however, FPA does not accept It (the flare) as a control device which can reduce the vr,M concentration to below 10 ppm. All other process vents are Incinerated as required by HFSHAP standards to bring the VCM concentration below 10 pp-. The compliance status of this account with TACH Pules and Regulations Is as follows: Oeneral Pules (Chapter lol) Rule 101.4 * In Compliance (IC). ho odors of any kind were detected. During Octoher/hovryii>er 19>'3, Harris County pollution Control Department (HCPCO) received several c<vpla1nts regarding an onion-like odor fron this plant. On' October 31, 19H3, HCnco Issued a notice of violation to Tenneco for confirmed odor nuisance. Later, the cenpany corrected this problem and achieved compliance. For details, please see Tenneco's letter of 12/13/R3 to HCPCD. Rules 101.6 and 101.7 - 1C. The company submits Its plant upset and scheduled maintenance reports to TAC1*. In 19G3, they reported about 12 cases of VC'I releases fron various relief valves. These releases were flared. Rule 101.10 - 1C. The company has accomplished the requirements of the i960 E.I. This report Is caiplete and in order. Rule 101.20 - IC. The company Is found to be In compliance with all applicable NE5MAP regulations, except a minor violation of Rule 40 CFR 61.65(b)(0)(111)(B) for the leak detection and elimination program. The date of the vinyl chloride calibration gas cylinder preparation and its maximum shelf life were not narked on tne cylinders. Region 7 has sent a letter to Tenneco regarding this matter and asked the company to correct the problem as soon as possible. Please see the HESHAPS Inspection Checklist. Rule ini.23 _ hot Applicable (HA). The-company does not have any approved bubble plan. Regulation I (Chapter 111) Rule 111.1 - HA. Ho outdoor burning Is conducted at this plant. Pule 111.2 - IC, The company Informs TACB and HCPCIl before conducting fire fighter's training. a' Rule 111.3 - hA. Tenneco does not handle any material which Is capable of Igniting spontaneously. Rule 111.11 - NA, There Is no Incinerator to burn garbage. A contractor hauls off the non-industrial solid waste to an approved landfill. Rules 111.21 and 111.2? - IC. *o visible emissions were observed from the plant flares and stacks. Rule 111.23 - IC, There were no visible emissions fron the enclosed buildings. Rule 111.25 - HA. Tenneco does not have any stack with flow rate of 100.000 acfn or greater. TEN 2523 O Investigator's Comments Tenneco Polymers, Inc. Pasadena, Harris County o Hfi-0713-S 4/9/C< Page 4 Pule 111.41 - t;A. The company is located In the attainment area for particulates. Rule 111.51 - IC. The sources of particulates ere the silos and the loading racks. Emissions at these points are controlled by baghouses and by closed system loading of railcars. Rule 111.52 - In Apparent Compliance (I*C), No property line sampling has been conducted to determine actual ground level concentration (C.LC) of particulates. As mentioned under Pule 111.51. Tenneco has adequate control equipment for particulates; therefore, the net MC Is assumed to be negligible. Rule 111.53 * VA. There are no steam generators with 2500 nn Btu per hour heat Input. Regulation M (Chapter 112) Rule 112.5 - I At". Natural gas and low sulfur waste oil are the fuel for boilers end Incinerators. Emissions of sulfur dioxide at these sources Is expected to he >/ell below the Unit specified by this rule. Rule 112.7 - I AC. Because of the low sulfur fuel the net CIC for sulfur dioxide Is expected to be less than 0.2? ppn averaged over any 30 minute period. Rule 112,31 NA, There are no sources of hydrogen sulfide. ^Mulatlon 111 (Chapter 11?) Wme 113.3 - NA. There are no sources of Inorganic flunrldcs as beryllium compounds. Regulation V (Chapter 115) Rule 115.101 - IC. Tenneco has a total of 13 fixed roof tanks. Emissions at these tanks are controlled by six chilled condensers. The temperature at these condensers is being monitored on a routine basis to check and maintain their efficiency. VCI* Is helng stored In two spherical pressure tanks which are equipped with safety relief valves. Rule 115.102 - CA, There are n'o floating roof tanks. Pule 115.111 - tf. VCr Is loaded and unloaded under a closed system. Vapors from the methanol loading and unloading operations are controlled by water scrubbers. Rule 115.131 - IC. Tenneco has two above-ground gasoline storage tanks for plant vehicle use. fine Is for leaded gasoline (3000 gallon capacity) and the other Is for unleaded gasoline (1000 gallons capacity). During 19R3. consumption of gasoline was below 50,000 gallons. The tanks arc eqi^ped with Submerged fill pipe. Oasollne frm the trucks is transferred to these tanks by a closed system. ** Rule 115.141 - NA. There ere no oil/water separators. Rule 115.163 - IC. There are no vents from the PVC and methanol plants that tare discharged directly to the atmosphere. Rule 115.172 and llf.,173 - NA. Tenneco does not have any degreaser or conveyor of solvent cleaning system, however, there Is a closed cleaning system, tetrahydrofuran for overhead condensers on the reactors. No VOC emissions are exacted at this point. o Investigator's Cements Tenneco Polymers, Inc. Pasadena, Harris County o MG-i)7n,,S 4/9/R4 Page 5 Rule 115.271-.275 - 1C, Currently, Tenneco Is In compliance with VCK leak" detection and monitoring program (NESMAP an CFRtftubpart F), for details please check NEShAP Checklist. The company Is also working on a TACil fugitive emissions control plan and Intends to suhnit the plan by December 31, 19M, (Rule 115.27S). Regulation VI (Chapter 115) Rule 116.1 and lir.a _ ic. A list of permits Issued to Tenneco Is attached. Permit C-7694 tor the methanol expansion Is still outstanding. PJ-3 was suhmltted on November 2, 1951 hut due to econcnlc reasons the plant has been Shutdown since 1W. Hr. kachtlek stated that this plant will remain shutdown for an Indefinite period of time. Regulation Vll (Chapter 117) Rule 117.1 - ?`A. Tenneco does not have any steam generators with more than 600,non lb/hr steam capacity. Regulation VIII (Chapter 115) Rule 11?.5 - IC, On April 11, 19P.4, Tenneco suhmltted a plan to reduce VOC emissions during an air pollution episode. Regulation Ilf (Chapter no) Rule 119,? - h'A. Tenneco dor* not have any catalyst regenerators which omit carbon monoxide-. Conclusion During this investigation, Tenneco appeared to be In co*pl1ance with-all TACB Rules and Regulations and applicable NESHAP standards regarding vinyl chloride monomer except for a minor violation as noted In Pjile 101.70. The company does not have any outstanding.Board Orders, Court Orders or compliance plan. s:- Reglon 7 SH/als i' K> TEN 2525