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ABD00315167 ENVIRONMENTAL MANUAL Table of Contents I. INTRODUCTION A. Revision II. REGULATIONS A. CWA B. CAA C. NESHAP D. SARA (Superfund) E. RCRA F. CERCLA G. TSCA H. DOT I. Spill Prevention Control and Countermeasures 1. SPCC Plan 2. RCRA Hazardous Waste Contingency Plan III. AGENCIES A. Regulatory B. Spill/Release Reporting IV. PERMITS A. Air Emissions Equipment B.. Construction of Air Emission Equipment C.. Water Pollution Control D; Historical Emissions of VCM E-. Air Permitting Process V. MANIFESTS A. Examples B. Instructions VI. ENVIRONMENTAL OFFICE MAP VII. REPORTING AND SPILL CHECKLIST A. Yearly Reporting .Due Dates B. Release and Spili Reporting 1. Reportable Quantities, SARA 2. Reportable Quantities, CERCLA 3. National Response Typical Questions 4. Spill/Response Report 5. Spill/Release Prevention Report 6; Hazardous Material Release Report C. Superfund Reporting Checklist D. Plant Entry of GovernmentalAgency Personnel 1-2 2-2 2-2 2-3 2-6 2-7 2-9 2-12 2-14 2-15 2-16 2-28 3-2 3-2 4-2 4-14 4-26 4-42 4-57 5-2 5-5 7-1 7-2 7-4 7-5 7-6 7-8 7-9 7-10 7-11 7-14 A ABD00315168 ENVIRONMENTAL MANUAL Table of Contents (Continued1) VIII. OQU APPENDIX A. Acronyms B. Resources References Trade Associations Example EnvironmentalSituations 1. Rupture Disk Failure 2. Reactor Leaks to Sewer 3. VCM Relief Valve Lifts 4. Oil on Outfall 5. Blend Tank Overflow 6. Acid Spill on Slag 7. Waste Water Permit Violation F. Health Effects of Vinyl Chloride 8-1 8-3 8-3 8-3 8-4 8-5 8-6 8-8 8-10 8-12 8-13 8-15 8-16 A ABD00315169 INTRODUCTION ABD00315170 A INTRODUCTION The purpose of this handbook is to provide instruction and direction to those persons administering environmental policy in the absence of the plant Environmental Coordinator. This may be used as a reference manual. Because policies and regulations are always changing, it will be important to revise this handbook quarterly. It is the responsibility of the Environmental Coordinator to keep this handbook current. The second page of this introduction will list the latest revisions and the dates of those revisions. 1-1 REVISION First Issue Second Issue ABD00315171 INTRODUCTION (continued) DATE 06/29/89 04/01/90 A 1-2 ABD00315172 REGULATIONS ABD00315173 REGULATIONS CWA CAA - CLEAN WATER ACT - CLEAN AIR ACT NESHAP SARA RCRA CERCLA TSCA - NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS - SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT - RESOURCE CONSERVATION AND RECOVERY ACT - COMPREHENSIVE ENVIRONMENTAL RESPCNSE. COMPENSATION, AND LIABILITY ACT - TOXIC SUBSTANCES CONTROL ACT DOT REGULATIONS - DEPARTMENT OF TRANSPORTATION ABD00315174 CLEAN WATER ACT - CWA The Clean Water Act was passed by Congress in the 1970`s. It set water quality standards for State and Local Water Quality Management Plans, effluent limitations for direct discharges and pretreatment standards, established the NPDES Permit System which regulates the discharge of pollutants into navigable waters and established rules regarding reporting, preventing and cleaning up spills of oil and hazardous substances. CLEAN AIR ACT - CAA The Clean Air Act Amendments passed by Congress in 1970 and 1977 to the Air Quality Act of 1967. It says that prevention and control of ambient and emission air quality standards is the responsibility of state and local governments supervised and approved by the EPA. This act formed the following three programs which can be directly enforced by the EPA. NAAQS National Ambient Air Quality Standards sets maximum concentration levels for various pollutants to protect public health NSPS Established national emission standards for new sources (New Source Performance Standards) NESHAP National Emission Standards for Hazardous Air Pollutants includes 8 pollutants; one of which is Vinyl Chloride Monomer NAAQS apply to six "criteria" pollutants presently: sulfur dioxide, particulate matter (dust), nitrogen dioxide, lead, carbon monoxide, and ozone. The EPA is responsible for reviewing and publishing these standards. The NSPS provide nationally uniform standards to prevent individual states from lowering emission standards in order to attract industry. They are developed by category of industrial source and are based on the pollution control technology available to that category of source. A new source is a modified source chat undergoes a physical change, or a change in method of operation, which results in new or increased emission of any pollutant. NSPS pertain to sulfur dioxide emissions from coal and oil-fired industrial steam generating units. Also particulate matter and nitrogen oxide emission limits were promulgated. VOC emissions from this facility come under NSPS. 2-2 ABD00315175 neshap ABD00315176 To: Vinyl and Support Department Employees A Interoffice Communication From: Date: Subject: r. w. Seymour May 20, 1988 ABERDEEN PLANT EARNS ENVIRONMENTAL AWARD VIS Congratulations co the Vinyl Department employees and the employees in their support groups (maintenance, process and project engineering, laboratory, environmental, safety). Aberdeen Plant employees were awarded the Vinyl Institute (a division of The Society of The Plastics Industry, Inc.) Environmental Achievement Award in recognition of outstanding performance for 1987 in the PVC category. Vista Chemical Company's plant in Aberdeen received the first place award for 1987. The award was presented to plant employees today by T. H. Huffman, General Manager, VCM and Polymers, in the vinyl control room. This award was presented to Vista for having a performance index of 100 or a perfect score calculated by a formula developed by the Vinyl Institute. This perfect score means that during the entire year 1987 the Aberdeen plant had no: - relief valve discharges - rupture disk releases - residual VCM exceedances on slurry - reactor opening loss exceedances - manual vents - incinerator bypasses This achievement is certainly a quality performance every day by all of those involved in preventing VCM releases and in operating equipment properly to ensure minimum emissions possible throughout the year. Congratulations! This is an award you can all be proud of and the achievement benefits our employees and the Aberdeen community. Ur R. W. Seymour Plant Manager rah cc: THH, RDG, RRS ABD00315177 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS - NESHAP NESHAPs are nationally uniform standards oriented toward particular pollutants at the point of emission. Vinyl chloride is in this category. It applies to new and modified sources that commenced construction after EPA proposed an applicable NESHAP. As with NSPS applications for approval of construction or modification must be made and accepted prior to the date on which construction or modifications is commenced. The following pages outline the part of the Federal Register that pertains to NESHAPs. ABD00315178 NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) 40 CFR PART 61 General Provisions: Sub Part A Definitions: 61.02 1. Alternative method 2. Capital expenditure 3. Compliance schedule State Delegation: 61.04(b) Bureau of Pollution Control Department of Natural Resources Jackson, MS Prohibited Activities 61.05 Don't modify without written approval from the Administrator (State) Application for Approval to Construct 61.07 Notification of Start-up 61.09 Initial Report 61.10 Waiver of Compliance 61.11 Up to two years Compliance with Standards 61.12 Determine by tests specified in rules Alternate, methods Emission tests 61.13 Withfri 90 days of start up Notify Agency 30 days before test Modification 61.15 ABD00315179 A change, operational or physical, that increases emissions is a modification unless it is not a capital expenditure or is routine maintenance. Subpart F - VCH Definitions 61.61 In vinyl chloride service Relief valve Leak Exhaust gas 3 hour period Emission Standards for PVC Plants 61.64 Reactors 10 ppm exhaust gas limit ROL Slurry PVC and VCM plant emission standards 61.65 (a) RVD's (b) Fugitives 1. Loading & Unloading 2. Slip gauges 3. Rotating pumps 4. Reciprocating pumps 5. Rotating Compressors 6. Reciprocating Compressors 7. Agitators 8. Leaks from RV's ABD00315180 9. Manual Venting 10. Opening Equipment 11. Samples 12. Leak Detection and Elimination - Approval required i. Fixed point monitoring ii. Definition of a leak iii. Subpart V - annual performance test. Submit results in next quarterly. 13. In process wastewater Emission Tests 61.67 Method 106 Alternate method Method 107 Emission Monitoring 61.68 Reporting 61.70 Quarterly Reports Exception reporting Recordkeeping 61.71 3 years Leaks Emission measurements Daily reactor operating record including T and P ABD00315181 EPA REGULATION PROPOSEO 12/24/75 PROMULGATED 10/20/76 PLANT OPERATED UNDER A WAIVER OF COMPLIANCE UNTIL SYSTEMS COULD BE INSTALLED TO MEET THE STANDARD 9/1/78. - STRIP SLURRY T0^ 400 PPM VCM - REACTOR OPENING LOSS 4 20 PPM VCM - NO MANUAL VENTING OF VCM - NO RELIEF VALVE DISCHARGES OF VCM - MINIMIZE FUGITIVE VCM EMISSIONS o RAILCAR UNLOADING LINES 0 DOUBLE MECHANICAL SEAL ON ROTATING PUMPS AND COMPRESSORS AND AGITATORS 0 REDUCE VCM IN EQUIPMENT BEFORE OPENING TO ATMOSPHERE o SAMPLES o REQUIRED LEAK DETECTION AND ELIMINATION PLAN CONTINUOUS MONITORS PORTABLE MONITORS 0 IN-PROCESS WASTEWATER STRIPPED TO LESS THAN 10 PPM VCM o EXHAUST GASES REDUCED TO 4^10 PPM VCM - EMISSION TESTS - EMISSION MONITORING OF INCINERATOR OFFGAS - REPORTING RECORDKEEPING ANNUAL VCM SURVEY -OOO'OT T001 V'7A ABD00315182 B^rai ao HaannN 0001 ABD00315183 VINYL CHLORIDE ANNUAL AVERAGE CONCENTRATIONS PPB W i S SEDGE MARKINGS IN ABD00315184 1 PART PER MILLION PPM 1 INCH IN 16 MILES 1 MINUTE EVERY TWO YEARS 1 PART PER BILLION PPB 1 INCH IN 16,000 MILES 1 SECOND EVERY 32 YEARS i <\ A-s Tng cLt < ABD00315185 SARA ABD00315186 SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 - SARA The Emergency Planning and Community Right-to-Know Act is a law included as Title III to SARA. SARA Title III represents Congress' response to concerns raised by the disaster in Bhopal, India in December 1984. SARA Title III Subtitle A Mandates the establishment of State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) with responsibility to develop emergency plans and requires facilities to provide notification and supply information to these facilities. SARA Title III, Subtitle B The reporting requirements are the following: 302 Notification of identity of facilities subject to emergency planning provisions or those having extremely hazardous substances. Vista Safety Director is our emergency notification coordinator. 303 304 Submission of any "necessary" information by identified facilities under 302 to Local EPCs to assist in emergency planning. Emergency notification of any release of a CERCLA hazardous substance or extremely hazardous substance into the environment to State ERC or Local EPC. A written followup report is also required. 311 312 Submission of material safety data sheets "hazardous chemicals" to State ERC, Local department. This is updated every October. (MSDSs) or list of EPC and local fire Facilities must submit "emergency and hazardous chemical inventory forms" to the appropriate State ERC, Local EPC, and local fire department by March 1, 1988 and annually thereafter. Reporting is done in two tiers. Tier I Reports give maximum and daily average amounts of hazardous chemicals present at the facility in the preceding year. Tier II Reports give more detailed information on specific chemicals including maximum and daily average amounts present in the preceding year, the manner of storage for the chemical and the specific location of the chemical. 313 Annual Toxic Chemical Release Reporting to EPA and designated state officials is done in July of each year. Facilities manufacturing or processing more than 50.000 pounds in a year are required to submit the form. Facilities using listed toxic chemicals in quantities over 10.000 pounds in a calendar year are also required to submit the form. 2-6 A ABD00315187 tf. TITLE III FACT SHEET EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW U.S. Environmental Protection Agency EPA J INTRODUCTION On October 17,1986, the "Superfund Amendments and Reauthorization Act of1986" (SARA) was enacted into law. One part ofthe new SARA provisions is Title III: the Emergency Planning and Community Right-to-Know Act of1986. Title 111 establishes requirementsfor Federal, State, and local governments and industry regarding emergency planning and 'community right-to-know' reporting on hazardous and toxic chemicals. This legislation builds upon EPA's Chemical Emergency Preparedness Program (CEPP) and numerous State and localprograms aimed at helping communities to bet ter meet their responsibilities in regard to potential chemical emer gencies. The community right-toknow provisions ofTitle HI will help to increase the public's knowl edge and access to information on the presence of hazardous chemi cals in their communities and releases ofthese chemicals into the environment. Title HI hasfour major sections: emergency planning (301 303), emergency notification (304), community right-to-know reporting requirements (311, 312), and toxic chemical release reporting - emissions inventory (313). 301-303: Emergency Planning: ^BThe emergency planning sections are designed to develop State and local governments' emergency response and preparedness capa bilities through better coordination and planning, especially within the local community. Title III requires that the Governor of each State designate a State emer gency response commission by April 17,1987. If a State commis sion is not designated, the Gover nor will operate as the commission until the Governor makes such des ignation. While existing State organizations can be designated as the State emergency response com mission, the commission can have broad-based representation. Public agencies and departments con cerned with issues relating to the environment, natural resources, emergency services, public health, occupational safety, and transporta tion all have important roles in Title III activities. Various public and private sector groups and associa tions with interest and exper tise in Title III issues also can be included in the State commission. The State commission must desig nate local emergency planning dis tricts by July 17,1987, and appoint local emergency planning commit tees within one month after a dis trict is designated. The State com mission is responsible for supervis ing and coordinating the activities of the local emergency planning committees, for establishing proce dures for receiving and processing public requests for information col lected under other sections of Title in, and for reviewing local emer gency plans. This local emergency planning com mittee must include elected State and local officials, police, fire, civil defense, public health profes sionals, environmental, hospital, and transportation officials as well as representatives of facilities sub ject to the emergency planning requirements, community groups, and the media. No later than Sep tember 17,1987, facilities subject to the emergency planning require ments must designate a representa tive to participate in the planning process. The local committee must establish rules, give public notice of its activities and establish proce dures for handling public requests for information. The local committee's primary responsibility will be to develop an emergency response plan by Octo ber 17,1988. In developing this plan, the local committee will evalu ate available resources for preparing for and responding to a potential chemical accident. The plan must include: Identification of facilities and extremely hazardous substances transportation routes Emergency response procedures, on-site and off-site Designation of a community coor dinator and facility cooidinator(s) to implement the plan Emergency notification proce dures Methods for determining the occurrence of a release and the probable affected area and population 2-6a ABD00315188 a quantity greater than its threshold planning quantity is subject to the emergency planning requirements. In addition, the State commission The time and duration of the release The medium into which the release occurred The local emergency planning committee The State emergency response commission comment, to be subject to these requirements. By May 17,1987, covered facilities must notify the State commission that they are sub ject to these requirements. If a facil ity begins to produce, use, or store any of the extremely hazardous sub stances in threshold quantity amounts, it must notify the State commission within 60 days. Each State commission must notify EPA of all facilities subject to the emergency planning requirements, including facilities designated by the State commission or the Governor. 304: Emergency Notification Facilities must immediately notify the local emergency planning com mittee and the State emergency response commission if there is a Release of a listed hazardous sub stance that exceeds the reportable quantity for that substance. Sub stances subject to this requirement are substances on the list of 402 extremely hazardous substances as published in Federal Register on 11/17/86 and substances subject to the emergency notification require ments under CERCLA Section 103(a). The initial notification can be by tele phone, radio, or in person. Emer gency notification requirements involving transportation incidents can be satisfied by dialing 911, or in the absence of a 911 emergency number, calling the operator. This emergency notification needs to include: The chemical name An indication of whether the sub stance is extremely hazardous An estimate of the quantity released into the environment Any known or anticipated acute or chronic health risks associated with the emergency, and where appropriate, advice regarding med ical attention necessary for exposed individuals Proper precautions, such as evacu ation Name and telephone number of contact person. Section 304 also requires the fol low-up written emergency notice after the release. The follow-up notice or notices shall: Update information included in the initial notice, and Provide information on: - Actual response actions taken - Any known or anticipated data or chronic health risks associ ated with the release - Advice regarding medical atten tion necessary for exposed indi viduals. Until State commissions and local committees are formed, releases should be reported to appropriate State and local officials. 311-312: Community Rightto-Know Reporting Requirements There are two "community right-toknow" reporting requirements which apply primarily to manufac turers and importers. Section 311 requires that facilities which must prepare or have available mate rial safety data sheets (MSDS) under the Occupational Safety and Health Administration (OS HA) reg ulations to submit either copies of its MSDS or a list of MSDS chemi cals to: The local fire department. If the facility owner or operator chooses to submit a list of MSDS chemicals, the list must include the chemical name or common name of each substance and any hazardous component as provided on the MSDS. This list must be organized in categories of health and physical hazards as set forth in OSHA regu lations unless modified by EPA. If a list is submitted, the facility must submit the MSDS for any chemical on the list upon the request of the local planning com mittee. Under Section 311, EPA may establish threshold quantities for hazardous chemicals below which no facility must report. The initial submission of the MSDSs or list is required no later than October 17,1987, or 3 months after the facility is required to pre pare or have available an MSDS under OSHA regulations. A revised MSDS must be provided to update MSDS which were originally submitted if significant new information regarding a chemi cal is discovered. The reporting requirement of Sec tion 312 involves submission of an emergency and hazardous chemi cal inventory form to the local emer gency planning committee, the State emergency response commission and the local foe department The hazardous chemicals covered by Section 312 are the same for which facilities are required to sub mit MSDS or the list for Section 311. Under Section 312, EPA may also establish threshold quantities for hazardous chemicals below which no facility must be subject to this requirement. The inventory form incorporates a two-tier approach. Under Tier I, 2-6c ABD00315189 The name, location and type of is the accounting of the total quan business tity of substances brought into a facility versus the amount that is Whether the chemical is manufac shipped out. The difference is an tured, processed, or otherwise indication of the amount released used and the general categories of into the environment. A report of use of the chemical this study must be submitted by EPA to Congress no later than Octo An estimate (in ranges) of the ber 17, 1991. maximum amounts of the toxic chemical present at the facility at The purpose of this study is to any time during the preceding assess the value of obtaining mass year balance information to determine the accuracy of information on toxic Waste treatment/disposal methods chemical releases. Also, the study and efficiency of methods for will assess the value of using the each wastestream information for determining the waste reduction efficiency and for Quantity of the chemical entering evaluating toxic chemical manage each environmental medium ment practices at categories of annually facilities. In addition, the study must determine the implications of A certification by a senior official mass balance information collected that the report is complete and on a national scale including for use accurate. as part of a national annual quantity toxic chemical release program. EPA must establish and maintain a national toxic chemical inventory Other Title III Provisions based on the data submitted. This information must be computer acces Section 322 of Title III addresses sible on a national database. trade secrets and applies to emer gency planning, community right-to- In addition to the requirements for know, and toxic chemical release the emissions inventory in Section reporting. Any person may withold 313, EPA will aitange for a mass the specific chemical identify of a balance study to be carried out by hazardous chemical for specific rea the National Academy of Sciences sons. Even if the chemical identity using information collected from is withheld, the generic class or cate States that conduct a mass balance- gory of the chemical must be pro oriented annual quantity toxic chemi vided. The withholder must show cal release program. Mass balance each of the following: Key Dates to Remember (Continued from page 2) July 1,1988 (and annually thereafter) Covered facilities submit initial toxic chemical forms to EPA and designated State officials (313(a)) October 17,1988 Local emergency planning committees complete preparation of an emergency plan (303(a)) June 30,1991 Comptroller general report to Congress on toxic chemical release information collection, use and availability (313(k)) The information has not been dis closed to any other person other than a member of the local plan ning committee, a government official, an employee of such per son or someone bound by a confi dentiality agreement, that meas ures have been taken to protect the confidentiality, and that the withholder intends to continue to take such measures The information is not required to be disclosed to the public under any other Federal or State law The information is likely to cause substantial harm to the competi tive position of the person The chemical identity is not read ily discoverable through reverse engineering. However, even if chemical identity information can be legally withheld from the public, Section 323 pro vides for disclosure under certain circumstances to health profes sionals who need the information for diagnostic purposes or from local health officials who need the information for assessment activities. In these cases, the per son receiving the information must be willing to sign a confidentiality agreement with the facility. Information claimed as trade secret and substantiation for that claim must be submitted to EPA. This includes information that otherwise would be submitted only to State or local officials, such as the emer gency and hazardous material inven tory (312). People may chal lenge trade secret claims by petitioning EPA, which must then review the claim and rule on its validity. EPA must publish regulations governing trade secret claims. The regulations will cover the process for submission ofclaims, petitions for disclosure and a review process for these petitions. A October 17,1991 EPA report to Congress on Mass Balance Study (313(1)) Secton 305 of Title III authorizes the Federal Emergency Manage ment Agency to provide $5 million 2-6e ABD00315190 A for each of fiscal years 1987,1988, 11989, and 1990 for training grants to support State and local govern ments. These training grants are designed to improve emergency planning, preparedness, mitigation, response, and recovery capabilities. Such programs must provide spe cial emphasis to hazardous chemical emergencies. The training grants may not exceed 80 percent of the cost of any such programs. The remaining 20 percent must come from non-Federal sources. Under Section 305, EPA is required to review emergency sys tems for monitoring, detecting, and preventing releases of extremely hazardous substances at representa tive facilities that produce, use, or store these substances. EPA will report interim findings to Congress no later than May 17,1987 and issue a final report of findings and recommendations to Congress by April 17,1988. The report must include EPA's find ings regarding each of the following: Status of current technological capabilities to (1) monitor, detect, and prevent significant releases of extremely hazardous substances; (2) determine the magnitude and direction of the hazard posed by each release; (3) identify specific substances; (4) provide data on specific chemical composition of such releases; and (5) determine relative concentration of the con stituent substances. Status of public emergency alert devices or systems for effective public warning of accidental releases of extremely hazardous substances into any media. The technical and economic feasi bility of establishing, maintaining, and operating alert systems for detecting releases. The report must also include EPA's recommendations for: Initiatives to support development of new or improved technologies or systems that would assist the timely monitoring, detection, and prevention of releases of extremely hazardous substances. Improving devices or systems for effectively alerting the public in the event of an accidental release. ;F6rmpm orifJltie Ui and \- EPA's Chemical Emergency Prepared* ness Program;contacttheCEPP 1-800-535-0202 (in Washington. D.C. (202) 479-2449) Hours: 8:30 am - 4:30 pm (EST), , Monday Friday;:;''; This Is NOT an emergency number Guidance/ Assistance Title III - Major Information Flow Requirements 2-6g Vista Polynws A Division at Vista Chemical Company ABD00315191 Highway 25 Post Office Box 91 Aberbeer. Mississippi 39730 Phone 1601) 369*8111 A February 20, 1990 VISTA Mr. J. E. Maher Mississippi Emergency Response Commission ?. 0. Box 4501, Fondren Station Jackson, Ms. 39216-0501 Dear Sir: Attached is the Section 312 reporting requirements for the Vista Chemical racility in Aberdeen, Mississippi. The Tier II forms have been completed per -0 CFR Part 370. If you have any questions or comments, please contact F. G. Jeanson at (601)369-3637. Sincerely, \r<^ R. W. Seymour Plant Manager cjs cc: Jerome Husky Local Emergency Planning Committee Chairman for Monroe County Route 1 Box 275C Greenwood Springs, Ms. 38848 Chief John P. George 125 West Commerce Aberdeen, Ms. 39730 2-6h fo rm O M B f t o 2d-i( ABD00315193 ABD00315194 20*0 007? ABD00315195 ABD00315196 A Fofm A p o ^ ^ M )M a No 2050 6072 ABD00315197 A ABD00315198 2-6o -- pj* ?<>S0 0t)>2 ABD00315200 Apnnmi^no 200-0f.02 -ON P opfi -- p-s- ^^B >***V ^-- U* ni* jj 3 o rs -- rs 1/N r*i rs. fs On r* r* X t- 2C > 8- Z a<. V-. C 22 C-- -- cj li. ac as l M 9 a >o m >- _ EUM Cx* o < s m j1 c E z 02 c c c < H 00 Z w ON t: vC z en o_ sc N-- mm > z s to J fl COs c w O' 00 >? o __ , ON C. : so Oo O0a > !| e0.. * sO 2$ ?* a * r m z vO o pn C/3 l z os <c UJ c*s , o sO a* ABD00315206 5 9 aXC* uu s > CH sQcuc o-i < c 0 2 > c 1 Ss gis| .rta3. o . Iwli |__ Ui s2 s S oisg5| 5,,6a i= SilSi it* 2-6w Abbreviation APA EFT VET CDA RM/V RW WFA ABD00315207 storage idomtcn Mammas Description Alcohol^Plasticizer Storage and ProccoRing Ares- Bailerbousa end-Propane Tank-Fam Vinjrl Chloride Tank Farm (Vayrant/Dryfalcnd Manrfncrartng Area Resin Marofacairing Area Raw Materials/Finished Product Warehouse Ua*ft witnpwr faHHH/m Area A Table i reporting ranges Range weight Range m Poieiee- 00 0 99 01 ioo wo 02 1.000 0.900 03 10.000 00.009 04 100.000 999.009 05 1.000.000 0.900.000 06 10.000.000 49.009.090 07 50.000.000 99.009.999 08 100.000.000 490.909.990 09 500.000.000 999.999.999 10 ibOM Mgher men 1 boon s Table a - STORAGE TYPES COOES Tveae of Storaoe A B' C 0 E P a H- 1 J K L. M- N O~ P" Q R* Above ground tent Below grand tern Ten* tote* butting Steal mum Pi--eo or mwwwie draw-- Can Carte* sue ffberaum Beg Box Cyflndar- Gtaaa oottiee or Noe Plaaao ootd--or fuga Tote ttv TenO wagon Raiear Othar Table in - temperature and pressure CONOfTTONS COOES Storage Conomona (PRESSURE} 1 , Ambtant ereaeure 2 Greater man amount ereeaure* 3 tarn dtan amount preaaure (TEMPERATURE) 4 Ambient temooranre 5 Greater man ametem temperature 6 Laaa man ametent temperature ** but not eryogente 7 Crvogane gunemani 2-6x *i !: 1 I i ,I I \j I IS *5 ^ HN.!| * k <k* I 5 * i>; 5 111 i I I i i i ABD00315208 S7'AM /' 2-6y appd: date: ABD00315209 To: J. C. Ledvina A Interoffice Communication From: Date: Subject: F. G. Jeanson June 15, 1989 SARA SECTION 313 REPORT VISTA Attached is a summary table and the full report for SARA Section 313 reporting requirements. A summary table of 1987 emissions is also attached. Major differences between 1987 and 1988 numbers are listed below: Chemical lbs 1987 lbs 1988 Cateeorv VCM 90,480 73,554 Air (stack emissions) VCM 29,521 3,008 Air (fugitive emissions) Barium 1,223 388 Offsite (landfilled) Lead 13,545 6,070 Offsite (landfilled) VCM air emissions were decreased in both the stack and fugitive categories. The stack emissions were reduced due to more stringent stripping procedures (higher temperature, longer time held under vacuum). The fugitive emissions were reduced as a result of a bagging study completed on the flanges and valves in VCM service. During 1988 a waste, vacuum/vent dust, was sold as a by-product. Instead of this material being landfilled, it was sold and used in compound production. The amount of barium and lead landfilled was reduced due to this change. Ammonia and chlorine both reported in 1987 did not meet minimum usage requirements for 1988. Sodium sulfate was not reported in 1987. If you have any questions, please refer them to me. F. G. Jeanson Environmental Coordinator tjs RWS, DCS, PJK, CJM, DFJ, JEN, JBA, CLW, DAM, REP, RBN, SCH, BLT, JEL, HGC, MRK 2-6z ABD00315210 1988 SECTION 31? EMISSIONS AIR WATER FUG. STACK LAND OFFSITE SECOND TOTAL OFFSITE OFFSITE ANTIMONY BARIUM 00 00 0 0 863.5(2) 863.5(1) 1731 3 (3) 1 (9) 00 61(2) 61(1) 264(6) 2(3) 388 * CAUSTIC Di-N-Octyl Phthalate 0 0 0 0 0 17* 0 0 00 6460(4) 72184(5) 326(9) 0 78970 LEAD 07 0 0 3018(2) 3018(1) 6070* 30(3) 4(9) METHANOL PHTHALIC ANHYDRIDE 1-499 0 0 0 00 0 0 0 1932(7) 0 0 0 1932 SODIUM SULFATE 0 0 148,276 0 0 00 SULFURIC ACID 0 0 00 00 0 VCM(8) 3008* 73,554* 0* 0 00 0 (1) Empty Bags (Sent to Monroe County Landfill) (2) Empty Bags (Sent to Chem. Waste Management) (3) Floor Sweep (Sent to Chem. Waste Management) (4) Filter Cake (Sent to Chem. Waste Management) (5) Separator Oil (Sent to Stauffer in Baton Rouge to be burned) (6) Stabilizer Spill (Sent to Chem. Waste Management) (7) PA Spill (Sent to Chem. Waste Management) (8) Fugitive emissions were calculated using correlation factors developed from a bagging study done at this plant) (9) API Sludge (Sent to Chem Waste Management) * Represents a reduction from 1987 emissions reported. Notes: 1. Ammonia and chlorine were both reported last year. Both of these chemicals did not meet minimum usage requirements for 1988 so they were not reported. 2. Sodium Sulfate was not reported last year. 2-6aa ABD00315211 SECTION 313 EMISSIONS REPORTED FOR 1987 AIR WATER FUG. STACK LAND OFFSITE SECOND OFFSITE TOTAL OFFSITE AMMONIA 1-499 0 1466 0 0 0 0 ANTIMONY 00 0 0 31(2) 1223(1) 1255 1(3) BARIUM 00 0 0 495(2) 640(1) 1223 88(6) CAUSTIC 00 00 00 0 CHLORINE 1-499 1-499 00 0 0 0 Di-N-Octyl 0 0 50 0 6880(4) 64967(5) 71847 Phthalate LEAD 07 0 0 7730(2) 5804(1) 11(3) 13545 PHTHALIC 00 ANHYDRIDE 0 0 1012(7) 0 1012 SULFURIC ACID 0 0 00 00 0 VCM(8) 29,521 90,480 57 0 00 0 : 'S' (1) Empty Bags (Sent to Monroe County Landfill) (2) Vacuum Dust (Vacuum Dust has been eliminated as a waste in 1988, it is now sold as an offgrade.) (3) Floor Sweep (Sent to Chem. Waste Management) (4) Filter Cake (Sent to Chem. Waste Management) (5) Separator Oil (Sent to Stauffer in Baton Rouge to be burned) (6) Stabilizer Spill (Sent to Chem. Waste Management) (7) PA Spill (Sent to Chem. Waste Management) (8) Fugitive emissions were calculated using EPA's Stratified Emission Factors. 2-6bb ABD00315212 RCRA ABD00315213 RESOURCE CONSERVATION AND RECOVERY ACT - RCRA RCRA regulates discharges into groundwater and some air emissions (e.g., incinerators) and general waste management, including spills. Focuses on current and future activities. The scope of RCRA includes the following three areas: 1. Waste Management - regulates disposal of hazardous (Subtitle C) and non-hazardous (Subtitle D) wastes. It also regulates the maintenance of underground storage tanks (Subtitle I). 2. Promotes Resource Recovery and Reuse of materials. 3. Authority for enforcement, studies, grants, National Ground Water Commission, etc. Hazardous Waste Management under Subtitle C is the main area of concern for RCRA. It is a program of federal standards with state implementation of cradle to grave tracking of hazardous waste. The subject matter includes the manifest system, listing and definition of hazardous waste, inspections and enforcement, site inventory, analysis and testing and exposure and health assessments. The EPA Regulations are found in 40 CFR Parts 260 thru 271. 2-7 ABD00315214 The following is a list of Manifested Wastes sent from the plant for offsite disposal Waste Waste Oii API Separator Parts Clean Solvent Lead Contaminated Bags Reason Manifested combustible liquid bariun, cadmium, lead Naphtha combustible liquid lead, antimony & bariun contamination Site Baton Rouge, La., Stauffer Chemical Co. Safety Kleen Corp., Southaven, MS CUM, Emelle, AL Proper Shipping Name. Haz. Class & I.D. No. waste combustible liquid N.O.S. combustible liquid, NA 1993, RQ (D005R, D006R, DC06R) waste petroleum Naphtha combustible liquid UN1255 (EPA D001) 501 non-hazardous MARU11039 Waste No. D005R, D006R, D008R D001 NH0000 Plasticizer FiIter Cake Floor Sweeps API Sludge P. A. Spill ^Asbestos Stabiliter Spill plasticizer floor sweeps & ventilation dust hazardous material (lead) hazardous waste (lead) hazardous waste (phthalic anhydride) CUM, Emelle, AL CUM, Emelle, AL CUM, Emelle, AL CUM, Emelle, AL gaskets and insulation to Emelle hazardous waste barium, cadnium CUM, Emelle, AL CUM, Emelle, AL plasticizer filter cake, nonhazardous MAR007363 hazardous wastes solid, N.O.S. ORM-E NA 9189 RQ 0008 MSE 64751 hazardous waste solid N.O.S. ORH-E NA 9189 RQ D008 MS 007317 hazardous waste solid N.O.S. ORM-E NA9189 (phthalic anhydride) MS 007318 asbestos insulation MSD 37292 hazardous waste solid N.O.S., ORM-E NA 9189 RQ (0005, D006) MSE 69245 NH0000 0008 0008 U190 0005, 0006 Mississippi Hazardous Waste Management Regulations implementing the Resource Conservation and Recovery Act require facilities handling hazardous wastes to prepare and submit a Biennial Report by March 1st of each even numbered year covering the activities during the previous year. 2-8 ABD00315215 r " I CERCLA^ ABD00315216 A COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT CERCLA This CERCLA of 1980 better known as "Superfund" seeks to establish the "no fault" liability of facility owners and operators, generators, and certain transporters of hazardous substances for releases of those hazardous substances. Allows governments to spend funds to clean up and then seek reimbursement from liable parties. Its principal concern is to address past activities resulting in present releases from waste sites. There are four Hazardous Waste Sites at the Aberdeen Plant. These four sites are Superfund sites because the waste material contained in these sites (BIS {2ethylhexyl} phthalate) is on the RCRA Hazardous Waste List (U-028). Please refer to the following two pages for site description and location. 2-9 3 5 J ,` - a m i' ABD00315217 NOTIFICATION QL HAZAPOQUS MfltfTJLSJg FACIUTT OBAWINO CONOCO CHEMICALS AalKOUNAUSStSSIfft CPA IO.N. MSOOO7O3I330 SCALE \ Inch* 400 Ft (ATTACHMENT TO 2-10 HOTirlCATION OF HAZARDOUS WASTE SITE ABD00315218 n-z & 4) k u 3 <_ JO *o 4) u 0 - -j: *o V u 3 .X c "Jo *re *re 0 k a k L. w u kft 01 k 4) k 4) k U332 u *rt 0) k <A k4) irt 4> k V) 5 re 5 4) k (rAe X 0 n E s u 0 *0 4k) u 3 03 --a. 0 i o o oo --v rg e g < a. < k 4> C O ao w4; *5 Oo cm mo r*. toOfi -i 2? -- \0 -- wi *m 3 UI3U 0) (0 S w < a) *-- ***u A O 9 moo LA CM o N uj u IA ooo in CoM ' V m* CM m z **6 *b * 3 re re re *T5 S re 4) 4J 4) 3 uu u < < 0L. V JJ *T5 *" 4) in x 0 re k w < ik 0 c J3 u- ik *D Cc re re _j --j 3 O -3-- ^ 4) .o re 4) *U V 4) Vto re *--' Cl. k Irt V* re re c_ u. < E 3 u < H O 1- $ 4) .--4e> w<0> > 2 o uj x *- V) IA CO U4) (A N **>" *--0 Co *vf*>l fin. M* So oj Hc5 * 58 55 * 0. i~ vt w4) w4) Nw --0 ><9 *ifJi (3A *$ re. u<4 ss OVI X s <0 tQ lU-4J 0n C flj -- O 1f9 O) CO U <SJ A V O 4) k * *-- * re 3 u E w re > k4) k4> -- wt re re re -- J re u X 4) 0) k kl ^ ^ /Ft u- a. e ml UJ t-J 1 z < ABD00315219 TSCA ABD00315220 A TOXIC SUBSTANCES CONTROL ACT - TSCA Enacted in 1976, TSCA has extremely broad regulatory powers over chemical substances and mixtures. This regulatory authority is vested entirely in the federal government. The TSCA grants EPA authority to regulate the entire life cycle of a chemical, from its initial manufacture to its ultimate disposal. TSCA has broad information gathering provisions. It can require: 1. It can require health and/or environmental effect testing of new manufactured chemicals. 2. It requires manufacturers and processors to maintain records and submit information on existing chemicals for assessing risks. 3. It requires all manufacturers to keep records on significant adverse reactions to health or the environment alleged to have been caused by a chemical substance or mixtures. 4. It requires the submission of unpublished health and safety studies. 5. It has control over new chemicals made or entering the country and requires Premanufacture Notification ("PMN") 90 days before such manufacture or processing of a new chemical. 2-12 ABD00315221 PCBs ABD00315222 A REGULATION OF POLYCHLORINATED BIPHENYLS (PCBs) TSCA Section 6 (e) requires EPA to promulgate regulations prescribing disposal and labeling methods and prohibiting the manufacture, processing, distribution and use of PCBs except in three instances. Annual reports for PCBs in service or projected for disposal are due by July 1 for previous calendar year. 2-13 ABD00315223 ABD00315224 A DEPARTMENT OF TRANSPORTATION - DOT The Code of Federal Regulations volume 49 deals with the transportation of Hazardous Wastes and Materials. A hazardous material is a substance capable of posing an unreasonable risk to health, safety, and property when transported in commerce. DOT is concerned with how hazardous materials are identified, packaged, documented, stored, transported, marked, labeled, and placarded. The DOT enforces the regulations with fines and/or imprisonment. Fines are most often given for failure to use the proper shipping name on manifests and bills of lading and improper placarding. The Environmental Coordinator should be consulted when determining any of the following questions: 1. Is the material to be shipped hazardous? 2. What is the proper shipping name? 3. Do packages/bulk loads need to be labeled/placarded? 4. What types of labels/placards are necessary for certain chemicals? 5. Is a manifest required for this shipment? 2-14 ABD00315225 SPCC_PLAN ABD00315226 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN SPCC SPCC is located in 40 CFR Part 112 and is regulated by the EPA. Owners or operators of non-transportation related facilities which due to their location, could reasonably be expected to discharge oil in harmful quantities must prepare a SPCC Plan. SPCC Plans must specify established procedures and methods and equipment and physical structures to prevent discharges of oil. An SPCC Plan must be prepared within six months after a facility begins operations and must be certified by a Registered Professional Engineer. A copy of our SPCC Plan follows. 2-15 ABD00315227 A SPILL_J?REVENTIQN CONTROL AND COUNTERMEASURE PLAN AprmO^JL989 -\U ABD00315228 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN April 10. 1989 A PREPARED BY: F. G. J^sanson Environmental Coordinator CERTIFIED BY: James L. White P. E. of MS No. 5609 ABD00315229 SECTION I SECTION II SECTION III SECTION IV SECTION V SECTION VI SECTION VII SECTION VIII SPILL PREVENTION CONTROL AND COUNTERMEASURE PTAN CONTENTS INTRODUCTION PLANT DRAINAGE AND RUNOFF CONTROL INSPECTIONS SPILL CLEANUP REPORTING TRAINING AVAILABLE SPILL CLEAN-UP EQUIPMENT DIKE AND TRENCH INSPECTION REPORT A-* ABD00315230 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN INTRODUCTION Federal regulations require that facilities which could reasonably be expected to discharge oil prepare a SPCC Plan (Spill Prevention, Control and Countermeasure Plan). The intent of the SPCC Plan is to minimize the potential for harmful oil discharges to navigable waters within the U. S. A harmful oil discharge is defined as any oil discharge which causes a visible sheen on or discoloration of, the surface of water. Harmful oil discharges are prohibited by law. The Aberdeen Plant uses a variety of oil during operations, such as plasticizers, alcohols, lubricants and chemical substances. Most of these oils are handled in diked, curbed or trenched-in areas which drain to the process sewer; however, it is possible that oil could be spilled outside of these areas and subsequently run to the storm sewer. In order to trap any free oil which may have been spilled to the storm sewer, there are concrete basins with underflow baffles upstream from each storm sewer outfall. All potential spill areas are under plant security. The plant facilities are enclosed in a fenced area, and all the gates are locked except the main gate where a guard is present at all times. PLANT_DRAINAGE_AND RUNOFF CONTROL Oily substances are stored or handled at several locations within the plant. The following preventive measures have been taken to minimize the potential for an oil discharge from the plant. A. Plasticizer Tank Farm Bulk quantities of plasticizer, alcohol and caustic soda are stored in tanks at the tank farm. The area is enclosed by a three-foot high concrete dike which will contain spills. Oil which is spilled at the tank farm will collect on the surface of the API separator and will subsequently be recovered to the process. All of the tanks at the tank farm have level gauges. The tank levels are checked daily and recorded on a form. The drains on all of the tanks are either blinded or plugged. B. Fuel Storage Area A diesel oil storage tank and a gasoline storage tank are located north of the plasticizer tank farm in a concrete diked area. There is a valve between the plasticizer tank farm and the fuel storage area which can be opened in order to drain the fuel storage pad to the tank farm. ABD00315231 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II. PLANT DRAINAGE AND RUNOFF CONTROL - Continued C. Alcohol Unloading Area Alcohol is unloaded from trucks on the south side of the tank farm. The area around the hookup stations is enclosed by a trench in the roadway which, drains to the API separator. Oil which is spilled at the unloading station in any quantity must be cleaned up immediately. This should be accomplished by washing the spilled oil into the trench with water or cleaning up the spilled oil with sorb all. Failure to clean up oil promptly will result in the spreading of the oil into the roadway by vehicles. D. T-450- 460 Area The area around T-450 and T-460 tanks on the east side of the plasticizer building is enclosed by concrete curbing, and the curbed area drains to the API separator. The two above ground tanks which are located within the curbed area have level gauges which are checked daily and recorded on a form. E. Pla_st_iclz_er Reactor_Relief Knockout Tank If a plasticizer reactor were to overpressure or relieve for some reason, the discharge would pass through the plasticizer reactor relief knockout tank. Entrained liquid in the discharge would collect in the tank instead of being discharged to the area around the plasticizer building. Although the tank is normally empty, there is a trench around the tank which drains to the API separator. F. Large Drum Storage Area There is a large drum storage area located on the south side of the east warehouse. This area is enclosed by a concrete dike, fencedin, locked and covered by a roof. There is a valve at the southeast of the dike which can be opened in order to let out rainwater. G. Waste Oil _an<L_Slop_0il Tanks There are two tanks on the north side of the API separator which are used to store waste oil and oil which has been recovered from the API separator. Both of these tanks are surrounded by a concrete dike, and the diked-in areas drain to the API separator. Each tank has a level gauge. -2t) ABD00315232 * SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II. PLANT DRAINAGE AND RUNOFF CONTROL - Continued H. Empty ppim Storage Pad Empty drums from around the plant are drained and stacked on a concrete pad east of the API separator. The concrete pad is enclosed by a concrete-curb, and oily drainage from the pad is collected in a small sump at the north end of the pad. The sump is pumped out to the waste oil storage tank or the API separator as necessary. If the level in the sump becomes too high, the sump and the concrete pad will overflow to the API separator. I. Lubricating Oil Storage Area Lubricating oils are stored on a concrete pad east of the truck scales. The pad is surrounded by a trench and a concrete curb, and covered by a roof. There is a drain valve on the south side of the curb which is blanked-off, and is not to be opened under any circumstances. Oil which is collected in this trench must be drummed and transferred to the waste oil sump by the API separator. J. Drum Storage Areas at Reactor Units There are small drum storage pads at each of the reactor units which are enclosed by a concrete curb. There areas drain to the process sewer. In the event of a chemical spill within these areas, there Is a drain valve which can be closed if necessary. K. Firewater System Diesel Oil Storage Tanks There are two small diesel oil storage tanks at the firewater pond deluge building and at pond #5 deluge building. The area under the pond #5 deluge diesel oil storage tanks is contained by a concrete curb; however, if oil is spilled outside of the curbed area the oil will run into the wastewater treatment ponds. The situation at the firewater pond is similar. If diesel oil is spilled outside of the curbing and it runs to the firewater pond, there is an underflow baffle which will keep the oil from being discharged from the plant. L. Emergency Generator Diesel Oil Storage Tank There is a diesel oil storage tank for the emergency generator located just east of the emergency generator building. The area under the tank is concrete and there is a concrete dike to contain any spillage. There is a roof over the tank to prevent rainwater from entering the diked area. M. The .Sphere and The Juliets The sphere and the bullets are surrounded by a concrete dike, which will contain VCM that may be spilled during a massive VCM release. ABD00315233 A SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN II. PLANT DRAINAGE AND RUNOFF CONTROL - Continued N. Storm Water Runoff If there is an oil spill outside of the above areas, there is a possibility that the spill could reach the storm sewer instead of the process sewer. In order to prevent oil from being discharged from the plant via a storm sewer, there is a concrete basin upstream from each storm sewer outfall. These basins have two underflow baffles which will trap any free oil which may get into the stormwater runoff. Oil which collects on the basins must be cleaned up as soon as possible, since the oil will eventually become entrained or dissolved in the stormwater. ABD00315234 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN III. INSPECTIONS A. Dikes and Trenches All dikes and trenches around potential oil spili areas are to be inspected semi-annually by the Environmental Coordinator. The attached inspection form must be completed and filed during this inspection. Cracked dikes or plugged trenches must be promptly repaired or cleaned out as necessary. B. Storm Sever Basins The storm sewer concrete basins must be inspected for oil at least once per week by the Environmental Coordinator. If oil is observed on the basins during these inspections, or during an inspection by any other employee, the Environmental Coordinator and the Contract Supervisor must be notified. The oil must then be cleaned up promptly and the source of the oil identified if possible. IV. SPILL CLEANUP In the event of an oil or chemical spill, efforts must be made to prevent the spill from leaving the plant's boundary. Any employee who observes a spill must take immediate action to control the spill, and if the spill is too large to control by ordinary means, the Supervisor of the affected area must be contacted. The Supervisor will make an evaluation of the spill and will notify the Operations Supervisor or Superintendent, who will coordinate cleanup of the spill. If the spill enters a storm sewer or approaches a plant boundary, the Environmental Coordinator must be contacted for assistance. Spills which occur to grade should be contained with whatever materials are available and the spill area should be roped off. Spills which enter the plant's sewers should be cleaned up whenever the spill material reaches the concrete settling basins. Sorbent booms should be placed at the storm sever outfall if oil is spilled to the storm sewer. When spilled material is cleaned up, the necessary Safety and Environmental disposal procedures must be used. If there is any doubt concerning the safe and proper cleanup and disposal of certain materials, the Environmental Coordinator must be contacted for assistance. V. REPORTING If there is any visible oil discharge from the plant, the incident must be reported to the Mississippi Department of Natural Resources and the National Response Center. The following personnel are authorized to report oil discharges from the plant. The report must be made as soon as possible after becoming aware of the spill, but no later than within 24 hours of the spill. =3-a 3 ABD00315235 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN V. REPORTING - Continued Environmental Coordinator Chief Process Engineer Senior Process Engineer Senior Process Engineer Plant Superintendent Plant Manager Vinyl Operations Superintendent Compound Operations Superintendent Mechanical Superintendent Frank G. Jeanson Rendell B. Newton Vernon L.Thornhill Steve C. Hillman Doug C. Skokna R. W. Seymour Paul J. Kober Ted Nickerson Dan A. Miller 1-324-2329 1-328-0904 369-8952 369-7892 1-327-0679 369-4412 369-7096 369-9025 1-356-6274 The following numbers may be useful when reporting an oil spill: MDNR Between 7:30 a.m. - 4:30 p.m. call: (601) 961-5171 After 4:30 p.m., weekends and holidays call: (601) 961-5340 " Eorl Mahaffey Bob Rogers Jerry Cain Engineering in Training Emergency Coordinator Section Chief National Response Center All Hours 1-800-424-8802 VI. TRAINING Employees engaged in the operation and maintenance of equipment which could reasonably be expected to spill oil are to be trained on the SPCC Plan. ABD00315236 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APPENDIX A AVAILABLE SPILL CLEANUP EQUIPMENT IS (I) VACUUM TRUCKS - Vacuum trucks are available from the following truck service companies: A. RDB Trucking - LOCATION PHONE ARRIVAL TIME Aberdeen, MS 369-9383 15 minutes B. G.B. Smith, Inc. - LOCATION Hattiesburg, PHONE 649-1220 ARRIVAL TIME 3.5-4 hours C. Industrial Maintenance Cleaning Contractors, Inc. (I.M.C.C.I.) LOCATION Bessemer, AL PHONE 205-428-0621 ARRIVAL TIME 6 hours D. Ergon LOCATION PHONE ARRIVAL TIME Jackson, MS 948-3472 3 hours (2) SKIMMING PUMP - Skimming pumps available from RDB Trucking. (3) ALUMINUM BOAT - An aluminum boat is available from the waste treatment ponds. W Spill booms, rolls and pads of oil sorbent materials are available from storeroom to remove oil from the creek or settling pits. Sorbent materials for liquid spills on concrete areas or the ground are available from the storeroom. ABD00315237 SPILL PREVENTION CONTROL AND COUNTERMEASURE PIAN APPENDIX B SPCC PLAN DIKE AND TRENCH INSPECTION REPORT Date: Item Plasticizer Tank Farm: Inspector: Status VCM Tank Farm Dike: Lagoons Acid Dike: Alcohol Unloading Area: T450, 460 Area: Diesel Oil Storage Areas: Haste Oil and Slop Oil Dikes: Empty Drum Storage Pad: Lubricating Oil Storage Area: Reactor Drum Storage Pads: Large Drum Storage Area By East Warehouse: Plasticizer Reactor Relief Knockout Tank: Firewater System Diesel Oil Storage Tanks: Emergency Generator Diesel Oil Storage Tank: % ABD00315238 SPCC PLAN AND TRENCH INSPECTION REPORT Page 2 The following problems should be checked for and noted, along with any other obvious discrepancies: 1. Cracks or damage to dike walls, curbing. 2. Trenches that are full of solid debris and will not drain. 3. Liquid-full trenches or curbed areas. 4. Obvious signs of oil spillage outside of the contained area. 5. Drain valves that are open where the area to be drained does not tie into the process sever system. 6. Write "W.O. Written" under status column after a work order has been written to correct a discrepancy. <a-7 ABD00315239 ADDENDUM TO S.P.C.C. PLAN RCRA HAZARDOUS WASTE CONTINGENCY PLAN April 10. 1989 ABD00315240 ADDENDUM TO S.P.C.C. PTAN RCRA HAZARDOUS WASTE CONTINGENCY PTAN April 10. 1989 h PREPARED BY: u. JtA Frank G. Jeainsoiv' Environmental Coordinator CERTIFIED BY: fames L. White P.E. MS No. 5609 ABD00315241 ADDENDUM TO S.P.C.C. PLAN RCRA HAZARDOUS WASTE CONTINGENCY PLAN Contents I. INTRODUCTION II. EMERGENCY COORDINATOR III. EMERGENCY PROCEDURES IV. ARRANGEMENTS WITH LOCAL AUTHORITIES V. AREAS COVERED BY CONTINGENCY PLAN VI. REPORTING VII. AMENDING EMERGENCY PROCEDURES VIII. EQUIPMENT % ABD00315242 RCRA HAZARDOUS WASTE CONTINGENCY PLAN I. INTRODUCTION Section F, Subpart D (402.7-50 to 402.7-56) of the Mississippi Hazardous Waste Management Regulations require an owner or operator of a hazardous waste management facility to have a contingency plan for his facility. The Contingency Plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous wastes to the air, soil, or surface waters. The plan includes provisions for an emergency coordinator who will assess the possible hazards of any spill, fire, or explosion of hazardous waste. The Emergency Coordinator will implement the Contingency Plan if he deems the emergency situation threatens human health or the environment. Hazardous wastes which are managed at the Aberdeen Plant are waste phthalic anhydride, API sludge, waste barium, cadmium or lead stabilizers, and any waste mixtures containing significant amounts of barium, cadmium, or lead stabilizers. The areas of the plant which are covered under the Contingency Plan are the hazardous waste drum storage area, the API separator and slop oil tank. II. EMERGENCY COORDINATOR At all times, there must be at least one employee on the facility premises or available to respond within a short period of time to an emergency situation involving hazardous wastes. This person has the responsibility for coordinating hazardous waste emergency response measures. The Emergency Coordinator must be: 1. Familiar with the plant layout. 2. Familiar with the location and characteristics of the hazardous waste handled. 3. Familiar with hazardous waste related operations and activities at the plant. 4. Familiar with hazardous waste related records within the plant. 5. Familiar with all aspects of the plant's Contingency Plan. 6. Have the authority to commit the resources necessary to implement the Contingency Plan. a-31 ABD00315243 RCRA HAZARDOUS WASTE CONTINGENCY PLAN II. EMERGENCY COORDINATOR - Continued The following people will serve as emergency coordinator for the area affected by a hazardous waste emergency. DRUM STORAGE AREA AND COMPOUND AREA Ted Nickerson - Primary Charles Worlow * Alternate Frank Jeanson - Alternate Bruce Trego - Alternate Bob Seymour - Alternate Doug Skokna - Alternate PLANT. EXTENSION 3635 3657 3637 3618 3606 3610 HOM__PHONE 369-9025 369-2269 1-324-2329 1-327-8673 369-4412 1-327-0679 API SEPARATOR Dan Miller - Primary Frank Jeanson - Alternate Bruce Trego - Alternate Bob Seymour - Alternate Doug Skokna - Alternate 3622 3637 3618 3606 3610 1-356-6274 1-324-2329 1-327-8673 369-4412 1-327-0679 In the absence of the department heads, the department head will designate another person to perform his duties. The designee will become the primary Emergency Coordinator for the area affected by a hazardous waste emergency. III. EMERGENCY PROCEDURES The plant has an emergency plan which is implemented in the event of any plant emergency. The plan is included in Section 1.23 of the Plant Safety and Health Manual. In addition to this plan, the Emergency Coordinator must evaluate any emergency situation involving hazardous wastes and determine if the RCRA Hazardous Vaste Contingency Plan is to be implemented. If the plan is implemented, the Emergency Coordinator has the following responsibilities: A. Take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other hazardous waste. These measures include, where applicable, stopping processes and operations, collecting and containing released waste, and removing or isolating containers. B. Monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment, wherever this is appropriate, if the facility stops operation in response to the emergency. C. Provide for treating, storing, or disposing of recovered waste, contaminated soil or surface water, immediately after the emergency. 3- 33l ABD00315244 A RCRA HAZARDOUS WASTE CONTINGENCY PLAN III. EMERGENCY PROCEDURES - Continued D. Ensure that in the afected area(s) no waste which may be incompatible with the released material is treated, scored, or disposed of until cleanup procedures are completed. If there are any questions concerning the proper handling of hazardous wastes or the means by which a hazardous waste spill should be cleaned up, contact the Environmental Coordinator. IV. ARRANGEMENT WITH LOCAL AUTHORITIES The following verbal agreement has been made with the local fire department: If outside assistance is required and requested, the firemen who come into the plant will operate under the guidance and leadership of the Shift Supervisor involved with the emergency. V. AREAS COVERED_BY THE_CONTINGENCY PLAN A. Hazardous Waste Drum Storage Area The hazardous waste drum storage area is the diked and fenced in area south of the east warehouse. This area is used for the storage of drummed hazardous wastes and other drummed materials. B. API Separator and Slop Oil Tank The API separator which is located east of the plasticizer tank farm is used to reclaim oils from the waste water generated during the plasticizer operation. Waste oils which cannot be reclaimed are stored in the slop oil tank just south of the API. Waste oil from the slop oil tank is periodically shipped to Stauffer Chemical Company who burn the oil for heat recovery. 2.-33 ABD00315245 RCRA HAZARDOUS WASTE CONTINGENCY PLAN VI. REPORTING If tiie Emergency Coordinator determines that the plant has had a spill or fire that could threaten human health or the environment outside of the Plant, the National-Response Center (1-800-424-8802) should be contacted immediately. The following personnel are authorized to contact the National Response Center: Safety Director Environmental Coordinator Chief Process Engineer Senior Process Engineer Senior Process Engineer Plant Superintendent Plant Manager Vinyl Operations Superintendent Compound Operations Superintendent Mechanical Superintendent Bruce Trego Frank Jeanson Rendell Newton Vernon Thornhill Steve Hillman Doug Skokna Bob Seymour Paul Kober Ted Nickerson Dan Miller 1-327-8673 1-324-2329 1-328-0904 369-8952 369-7892 1-327-0679 369-4412 369-7096 369-9025 1-356-6274 In the event that the Hazardous Waste Contingency Plan is implemented, the time, date, and details of the incident are to be recorded in operating records of the unit affected. Within 15 days of the incident, a written report of the incident must be submitted to the State Solid Waste Division. The report is to include the following information: 1. Name, address, and telephone number of the plant. 2. Date, time, and type of Incident (fire or spill). 3. Name and quantity of material(s) involved. 4. The extent of injuries, if any. 5. An assessment of actual or potential hazards to human health or the environment. 6. Estimated quantity and disposition of recovered material that resulted from the incident. ABD00315246 RCRA HAZARDOUS WASTE CONTINGENCY PLAN VII. AMENDING EMERGENCY PROCEDURES The Contingency Plan must be reviewed and amended, if necessary, whenever: A. Applicable regulations are revised. B. The plan fails in an emergency. C. The plant changes in its design, construction, operations and maintenance in a way chat materially increases the potential for releases of hazardous wastes or hazardous waste constituents. VIII. EQUIPMENT A. Communications The following communications equipment is available at the plant: (1) two-way radios, (2) five channel Gaitronics system, (3) public address system, and (4) telephone. B. Fire Fighting There are fire extinguishers located throughout the plant. Fire fighting equipment is listed in Section 1.23 of the PVC Health and Safety Manual. C. Spill C3.3finup For a list of available spill cleanup equipment, refer to Appendix A of the S.P.C.C. Plan. tjs/RBN disk ABD00315247 AGENCIES ABD00315248 iH AGENCIES EPA REGION IV - ENVIRONMENTAL PROTECTION AGENCY MDEQ, BPA - MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY, BUREAU OF POLLUTION CONTROL (PREVIOUSLY THE MDNR, MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES) NRC - NATIONAL RESPONSE CENTER, CERCLA REPORTING MERC - MISSISSIPPI EMERGENCY PLANNING COMMITTEE LEPC - MISSISSIPPI EMERGENCY RESPONSE COMMITTEE ABD00315249 .\ III. AGENCIES A. The regulatory agencies that the Aberdeen plant deals with and the contacts at each are as follows: ENVIRONMENTAL PROTECTION AGENCY - REGION IV Region IV includes the sates of Mississippi, Alabama, Georgia, Florida, South Carolina, Tennessee, and North Carolina. Address: USEPA Region IV 345 Courtland Street Atlanta, GA 30365 Division Contact Phone Number CERCLA Library Freedom of Information Undine Johnson (404)347-5065 (404)347-4216 (404)347-3004 MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY BUREAU OF POLLUTION CONTROL Address: Section Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39209 Contact Phone Number N. Mississippi Air Emissions Danny Jackson Industrial Wastewater Control Taher Diab RCRA Sam Mabry CERCLA Jim Hardage (601)961-5171 (601)961-5171 (601)961-5171 (601)961-5171 BUREAU OF LAND AND WATER RESOURCES Section Contact Phone Number Director of Bureau Hydrologist Charles Branch Mike Gross (601)961-5265 (601)961-5265 ABD00315250 III. AGENCIES B. Spill/Release Reporting NATIONAL RESPONSE CENTER 1-800-424-8802 LOCAL EMERGENCY PLANNING COMMITTEE Emergency Coordinator Jerome Husky (601)369-6439 MISSISSIPPI EMERGENCY RESPONSE COMMISSION Regular Hours In State Out of State Bill Austin 24-hour number 24-hour number (601)960-9000 1-800-222-6362 (601)352-9100 ABD00315251 PERMITS ABD00315252 PERMITS ADMINISTERED BY STATE WATER CWA, NPDES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM AIR CAA, NESHAP CONSTRUCTION- MAJOR PROJECTS GROUNDWATER - MDEQ, BLDR BUREAU OF LAND AND WATER RESOURCES WASTE GENERATOR, EPA IDENTIFICATION NUMBER Vista Mymers A Division of Vista Chemicol Company ABD00315253 Highway 25 Post Office Box 91 Aberdeen, Mississippi 39730 Phone {601) 369*8111 * December 2, 1989 VISTA Mr. Danny Jackson North Air Emissions Section Mississippi Department of Environmental Quality Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39209 Dear Mr. Jackson: Enclosed please find an application for revising our current operating permit. Vista Polymers is currently a major stationary source. Per the attached revisions in our permit, we desire to become a minor source. Having the capability to become a minor source is due to the installation of 5 state of the art baghouses on our PVC dryers. These baghouses will reduce our current particulate emissions 75-100 tons per year. The emission limitations for particulates and sulfur dioxide in our operating permit have been reduced below 100 tons per year. All other pollutants are currently below 100 tons per year. Call me at 601-369-3637 if you have any questions concerning the application. Sincerely, Frank G. Jeanson Senior Environmental Coordinator /tjs attachment cc: RWS, JCL, PJK, JEN, RBN ABD00315254 * STATE OF MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES BUREAU OF POLLUTION CONTROL P.O. BOX 10385 JACKSON, MISSISSIPPI 39209 For Agency Use FACILITY NUMBER Date Received APPLICATION FOR PERMIT TO CONSTRUCT AND/OR OPERATE AIR EMISSIONS EQUIPMENT - GENERAL FORM Month Day Year APPLICATION FOR: CONSTRUCTION X PERMIT RENEWAL - PLEASE CHECK APPROPRIATE BOX 1. Name, Address, Location, and Telephone Number A. Name Vista Polymers* A division of Vista Chemical Company B. Mailing Address of Applicant l. Street Address or P.O* Box p o. Box 91 2- city Aberdeen_________________________ 4. Zip Code 39730__________________ C. Location of Facility 3. State Mississippi 5. Telephone No. 601-369-8111 1. Street Highway.25 2. City Aherrfpen 4. Zip Code 39730 3. State Mississippi 5. Telephone No. 601-369-8111 D. if the facility is located outside the City limits, please provide a sketch or description showing the approxirrate location and attach to this application. 2. SIC Code 2821 3. Number of Employees 252 4. Principal Product' Polwinvl Chloride 5. Principal Raw Materials y-tnvl chloride Monomer 6. Principal Process Polymerization of VCM to_PVC___________ ___ 7. Maximum amount of principal product produced or raw material consumed per day 8. 7aT Check here if operation which generates air pollutant emissions occurs all year X , or specify the months the operation occurs: (B) Specify how nany days per week the operation occurs: 7' (C) Specify how many hours per day the. operation occurs: 24_____________________ __________ 9. If this application is for existing facility permit renewal only, has the facility been modified in any way (including production rate, fuel, and/or raw material changes) during period covered by the Operating Permit______Yes ______No or since 1972?Yes ____________ No If Yes, give year(s) in which modification(s) occurred. .10. ALL APPLICATIONS MUST BE SIGNED BY THE APPLICANT. I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate, and that I am the owner or chief corporate officer, or his designated representative, responsible for complying with air pollution control laws and regulations. __ W. Seymour_____________ ______ Printed Name oorf Ppeerson Signing /h/$7%7 Date Appl icatiOT Signed Plant Manager Title Signature of/Applicant PLEASE CCWPLETE FOLLOWING PAGES WHERE APPLICABLE ABD00315255 N FOR-ALL APPLICANTS, WHETHER NEW CCNSIHUCTXCN, EXISTING FACILITY; OR RENEWAL CXUTROL EQUIPMBir COVERED UNDER THIS APPLICATION - PLEASE CHECK ALL. APPLICABLE AND INDIC? NUW3ER OF UNITS; PARTICULATE EMISSIONS CONTROL EQUIPMENT 1. Cyclone<s) 15 2. . Water Scrubber ^ 3. Baghouse 65 4. Electrostatic Precipitator GASEOUS EMISSIONS CONTROL EQUIPMENT 1. Water Scrubber 2 2. Activated Carbon Bed 2 WAstfE DISPOSAL SYSTEJB 1. Solid Waste Incinerator 2. Liquid Waste Incinerator 3. Wood or Other Waste Fuel Recovery Boiler 5. Venturi Scrubber 6. Cyclonic Baghouse .7. Cyclonic Scrubber 8 other Vent Sock 13 9. Vent niter 2 - 3. - Other 4. Gaseous Waste Flare 5. Liquid Waste Flare 6. Other VCM Incinerator - 2-- . Pneumatic Conveying System 36 Other (please describe) All use narticulate emission control equiment~Hsted a FOR' ALL APPLICANTS FUEL BURNING EQUIPMENT (Except for Refuse Disposal) This form has 3 pages; each is a continuation of the. equipment information f romthepagebefore. Please fill in as completely as possible, listing all fuel burning equipment. Reasons should be given explaining any data not filled In. PACE 1 1. Fill in company name and address, plus year for which data is given (if existing facility) at top of page. Use data for most recent calendar year available. 2. Reference Number. Use an identifying number for each boiler, furnace, kiln, etcr;. and use. the same-reference number on each of the three pages to identify information for-- the same unit. - 3. Manufacturer and Model Nurber. Nameplate data for boiler, furnace, kiln, etcw-Waste ga flares and stationary internal combustion engines should also be included on-this form 4. Rated Capacity in Millions of BTU per hour. 5. Type of Burner Unit. Use Codes (1*) at bottom of form. If not listed put (11) and speci; 6. Usage.'Type of fuel-burning equipment. Use. codes. (2*) at bottom of form. -Ifloot-lister put (5) anet-specify; 7 Beat Usage. Percent of heat used for process anchpercent for space heating.-- ABD00315256 Ik I 1 - n cn cn * J i - ] r* rs r* 9 cn - o H FUEMBURNING EQUIPMENT iEuccnt lo r Btfusa Dwaoiall S p rin g fie ld Lo. L694 Cleaver Brooks No. 0L76 Ocn or co F- tO oi s aX 01 "0O) O -S0O-) O. < n J! - -- W iz 'it r> r** r> >s> 3 y o Otoa to to <35 X X X r 9To < a> CO ON I ncn o cn 91 to Q0 1 at t c ! i ! ?ii to oO. ra 0 CO t-oJ c R a J. q V T3 5 u. 5C 9 C oo c sT, 11/1 o CO !j il s Cvj CO cn CO 3 *N 1?|||5 iJilii d b^ r I pAQ ItFOB AGENCY USE ONLY! 1 R *a iM U ABD00315257 Is S to Is 0 ~ 01 -- o c*| 44 4- - M - H44- Jii8*1 =3 *-- S'--* -- > OZ ax m o X pw CM O- NoJ f* - *'s. - I-- > ax .X *-- CM O ill iL Lu !`l a <n o in bu O l/> r~ u. T at in 1| m O U9 U O J= O X ow O -C CO o r>, r*. 4- O 44 I'i d- 4- r*4 il Q. a. . o. . 3 3 9 -X .X OO TJ m % IS CO a ca 0) 0) in L ) - u o s- (0 CL a cl L. CL w 3s 3X 3S 44 > l-> 44 O 44 IO f- id - Z 4- X 2 : S 2 S ss^ is "jl m CO oO in in CO co illi r-- 1 CO 2 jt i - ro ro CO r lO ro CO CO CO CO CO CO If! CO CO CO * |? li r-- CVJ CO co CO CO - % >1 44 u d Q. <o u 3 rX 44 Id u o 'a; in <s . at 44 LLt rt F U E L SUPPLIERS: Ful Typ Natural Gas M ississip pSiupplViera lle y Gas Company/American C e n t r a l Gas Company Powdle Gas Company Propane______________ ABD00315258 PAGE 1 *Sodfv Units of MciMUra Used ABD00315259 o\ !>: x> o HV 5* CO rv oo X cm r- <n CM a oo 0 *i 1^1 Eoo i!h Os citnfi e' en Or- nO JJi go 51 as 00 r-* oO X CM r-* m m CM * 00 1*1 ill cn m MANUFACTURING PROCESS OPERATIONS ooo) 4ckoJoi 1W 5 5 O (c0 I co 1 8 ! i II Ca>O Vh < *cd sCO co (u00) < co u3 CO od VM oo oa Oh cH m cO ot-l 4J a s3 Q CO Oa U os >P-, > p-> uo 'O3' o MANUFACTURING PROCESS OPERATIONS PAGE 1 Number of E m in o n P oints To A ir ABD00315260 *3 +0 i Si aa c 1 i1 <3! o *H X \o co m 00 oo \D nO o r*** X -hC -<0 eg u o eg eg eg NO O O vr eo ON A eg O m jll r-i \m0* *<r <N o m H 1 1 s m9 a 01 i< m c 0 lf 4. * c 31 !X 8 0 1- & 0. *0 c 01 CQ > u a ii ii m o o 0) 0) < a 0 H 4J O 3 X O *4 &4 Vj 0) N H a H 4J CO (0 H Qj NO o o (0 V4 o 4J n) M 0) c H O 3 M s o r> r-. 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CM INC1M444. ac4j4 r u. 10 in in m in oin om m in o 00 COr CM CO i1 in ti 10 fN 1 CM CM CM CM CM CM o oo O o O o ooO o o o o rf f ABD00315262 A c te d 50 G3 28 28 l 1 i 4 <3 ft ] o 1s ft IU | J 1I- kaa s s 2 2 * a o iu e 1_ u cr> *0*> O (O CM ocr** Ol 1/1 Q. VcoO k (0 n ft a j 2 k> o i l/) o CJ &>, = s3 1{ Ik (U 1 K CM * <3f4 a ft|l 1 at>ik M I1s* i "5 rx. VO co i1 X Ik r>x H '1 n CO oo a* ** lO <* Cl Cl Ol Ol Ol Cl Cl Cl Ol Cl Cl Cl Ol Ol Ol Cl Ol Ol Cl Ol 91 in co in in co CO in in CO CO cino in CO &tu 3 & oi. = orx. m 10 to f"* l/l > CO CO *? CO CO *Col aoi o cc Cl 0) 0> 01 i4 X 11 XX p0a1w 01 Ik Ik VO o to l/l s > CO CD CO CO 01 *oo s c ei 01 1C 1 X 0) u. "O01 o c Cl 01 .-24 X 01 Ik * in in CtoM CJ i/i >> CD CD 00 CO -0o) 0o1 ec 01 01 01 01 1C X i XX 01 01 Ik - Ik O O oo oo o CO oo o o *"* I # ; 1" f-- >+CM CO CO 3 co CO CO CO CO CO CO CO oo oo o Q in oo o o vO V0 Cl Cl Ol Cl CO CO Ol CM CO m 10 i CM O o 1 CO CO oo oo CO CO oo o o CoO o CO o o X' 9 MANUFACTURING PROCESS OPERATIONS ABD00315263 \ a w J at & - at at at . 1 -Itl i* 1 ID j *- a9 - co 1 3 1 i j j l8 8 i i 2 aj ID CM WO > CO CO _ 0) _ e 0) 0) i X 0) Lu il 0 5 0lb wf O o m Jii l 51 1 | W> lb CO CJ iIsf S "5 fO CO o i 3 X vroO h r-. i 8E CO o e\t o tt *t at at at at at at N at V* at t X at at )* at a* at at u ata at at at at - at at at at at at at at at at at at ID ID po - CO ID CO ID CO ID co ID CO ID - co ID co ID CO ID co LD ID CM CM ia to > 0 CO CO CO a Of TJ o c 4> cQ) at O 1 xX fmam> p4^) lu lu o o o o ' ID CO to UD CM ID LD CM ID ID CM ID >> > CO co CO CO *3* CO CO CO CO ID CM ID > CO a CO ID CM ID > TCOT CO ID CM ID : co T 00 ID CM ID > CO r CO CJ "O o <0 a 0J *ao> oo a u o aj 0) a o _o o> "O 2o C cce (0 a 0) a Q> fr0nmJ p9av> | 24 24 i11 X paMj X fm0m) X 0J X V lu Lb. Lu LU C ec <y a) oQ>) 0J 0J F* - 24 . 24 24 1 11 X o X 0) X11 Lu iu lu S a F0^1 24 l X 41 lu o o o o O o o o 1-- CO o O o CT o o r~ CCOM CO CM o LD ID ID ID CM LD CO CO CO CO oo ID V<Oo CCOO CO CO CO co CO CO CO CO o ooo ID ID CO CO CO CO CO o o CO o vo CO CO co co CO CO C3 CO oooo co co o a CM CM vo o CO CO CO at CoO ' co o o o CM CO CO o o CO o o ro1 o o t CO o o ID va r> i CO o 1 CO a i CO o t co o o ooo r i ABD00315264 11 i i A ctual t i HI i J & ' 2 aa Cl a C* a cn 40 f 0* IK A. | co CO l co 3 3 - % fc4 Ol C* aa a Cl i* fr *0 a\ o> o\ a Cl Cl Cl c Cl in in CO CO m a in co co co 52 !4 o*% o> % Cl a a a Cl a a a in m - in in co co co ro fc E s } i i 2 i a LT> co CO in CM in r> a CO CO CO (__ 01 X3 o -o o o s e c0011 e01 0x x cj ) Li. u. x0) u. 82 05 o -s o oo o o m in CM CM m in >> aa aa i-- oj OJ *o *c o s 2o e0011 c 0J a SS ti X Q> X0} LU u. oo oo m CM in > a a ^. 0) o o in in CM CM in in > aa a GO . 0) 0) *s o o c001) e001) e00)) V/ 3 111 X0} X0) X0) * u. 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Lu in CM in > a a - r0) *o o S e0J 0J 3 X0) LU aa in in >> aa aa r0J 0J a "C $ e0J 0J il - X 0J LU e 0J 0J X1 0X) LU ooo oao " o oo o o oo f-- 0 0 3 -1 8 0 0 3 -2 1 27 * *SsS8 1 O tl LfJ in Ul> i 1------------ <8 : u CO O CO o m CO CO o mm in a a aa a co CO ao oo CO co co a a a ooo co a -o co a aa oo co a a i ii z CSJ CO CO SO ii 8E H o I co o o CM aa CM CM CM aaa CM CM CM1 CO o oo co in CM CM CM t1 CO o CO ' O cCoT oOO CM CM CM CM CO a CO a o r-. a a CM CM CM CM 1 11 1 CO CO CO CO o oo o o oo o V N UJ 0 1 - cu s- M ABD00315265 -1 Itf 1 & at 8 Ot o at X Cl at ct lr at at at at at at at at at s i a "T 00 LO CO L.O CM VO s a CO a; 0) 5 ft a o a .o s i i ce 0) at ? 0t at a -^ 1 iut i XX 0) at u. u. in CO irno UO u CM o VO M > (J m at a 3 at -a +> o at 03 < e O> at 4-> x at 3 a < in -^4 I -X X U at at a u. to o mco in CM VO > a er a at _o e ct at t X at u. si o s Ik o o s &o oa wI r-- H oo oa r-- o o *" m ^11 m r- r- 1 i2> i CM CM J s3a I| CO CO CO CO oo P*> 1.0 CM CO CO o i i CM CJ z ik OV at CM at li z o CO CO i CO CO oo oo CM CO CO CO 11 co co oo oo a CO a o at o CO 1 CO o o i I i i r 1 f w i ABD00315266 1 I l & o X *4 - * C* o\ 91 Ot CM Ot at Ii Viu*t oo e 5 - 39 -D -n o CO coo 1 2 1 i 1s I C o e o e CD oc ] l/l ui /) c/> 2 OJ .o a 0) Q 2 i - 44 cC 4C4 4J c <e <a <0 (Q a. a. a. a. si 251! eIk ut | H in LT) oo in o ion r-- o n <n e <n coo o ro in co m CO 1 1 CcT c 9Oe^) Ul V) ID 22 4c4 44 C 4J e rI--Q pfBO r*<"a a. Q. & c O) l/l -- 4-> c - f*<*0 a. CcD ID a o 4-> e rO -CL. p fIB 1 CO > CO CO i 4Im4 => - CoM. o1 CO 1 OC. U_ 1 -Ll. l/l <J I s - 44 -o . u. . a> e o * uoO in o mo r-- in o in Of-- ion o o o CO * 51 5 a lO o io O i CM CM r 1 ul> M If l r- VO r- o m ID -3 o o o o o o lO CM CM CM r-* lO rs o r* o oOO m lO CM CO 1 CM CM r-. r> VO oo m m CM oo i X Uf5 m CO C9 mm CO CTi Si 1 CM 1 coi ir if a* o o oo s o r oo in in m CO CO CO in o rs, i <oor oo oo m lf> ID CO CO O CO1 cni 1 oo OoT o o oo CM oo ao NOTE 2: No p a rtic u la te emissions MANUFACTURING PROCESS OPERATIONS ABD00315267 1 w 1 1 * CM cn CM o O' CM &o o> O' O' 1 1 -5 1 l/) e S t CO a s s 3 * CO hu OD 4 U) l (U aA a ac 1e s 41 i 41 i 14 Ccl X Q) U. ( 1 0c1 o 1m 1 - CO CD - o CD 01 -o o c 01 01 14 0) s X& o al 3 ib e0 o CD CD o o CO H o CO lO -- O' O' O' O' O' O' m" CM CM S"`^ W t1t `1` in in co ro 11 t,i i1i CO r* wCD-i uu cr CO CO *-- 01 01 *o oo ee 01 01 01 01 14 X XX 01 0) ^9 Li_ Lu 0co) 01 so * .i JC (J u l/l CO i/) -M +J * Ca 01 > 5* - Oo LO m oo CO CO OoO ooO m o || i *1 i 3 |||>lb u 1 Ji i ib UD CD O O' 1 1 f-- r-. CroO o CD 5 X9 b CM O' o rCO CM CO CO m h SE (H 1 O CD d1* O 1 o p>. i o 004-16 004-18 004-19 004-20 004-21 004-23 i aO' O' 11 11 1I1 1 11 C4 CM OO r-* CO oo m m in CM CM oo ro nros O' rm** Oun' 1.0 CrM- CM C*M1r CD O CM Oo rr MANUFACTURING PROCESS OPERATIONS ABD00315268 MANUFACTURING PROCESS OPERATIONS M lk ro P u ls a l re D u s t C o lle c to r 1F I-4 8 ABD00315269 Actual t w & -a a a\ jj 1 Uf ii "8 - tcno I i 3 1 E 1 1 1S 3 2 1 sl SSg. Ul| H o CO ||^ m a 331 1 V) lIs ii X* tT m CM n X n CO 1 t ii ii r* n i o o } 9 ABD00315270 i 1 l 1 IFO R AG ENCY USE O N LV | & 44 oi 44 01 *Cl H01 Ol Ol 01 01 01 Ol 0011 * 4041A 4014 >014 01 01 01 01 01 01 44 01 - 0011 44 44 01 01 0O1l 01 Ol it t i i i UlI -- j 13 s - LcfoJ uCOn CuOn -- C1O0 s ocn irno cino - mco imn in cn it i 2 2 to 3 1E >| - iCt>c/nMa1 CO C>11/M01 CC^OO C1M0 oc>an CO in Ci/Mi ca CO 1CG>CO0OO CO io >* CvcnoD Ci>cnMa co - C>i^cnMa CO in >CM CvcOa - Cm>cMa co N . ui ro a ]8 | - -ao; - *4o) 4) OS *s4Oo1 4J o s4oo) T0O3 g 03 so 41 n4o1 S jl J1 a c<0u) - M1 X41 c44)) e4011 caa>> | X 4) ^| . X 4) AC X0i3 - Ik u. Lk lk . c4a)t ea4)i 4C41) c441) - c441) c V | X 03 1C l pXoto 1C X 0) ..-S* pX411 AC1 4X1 .X X411 lk u. Li- lk U. Lk xu . .CXl to - 10/i .44 >c41 - 4>c441 a! Os ? So "Hi o o oo Oo QO OCO oo oo - O CO S OCO in vrn N a ill 1 1 f<3 Is : "5 r>. r- r- n* co CO mco n CO CO CO o o o i? 8 T 0CO1 01 CO 0CO1 0011 gj 6E 1 o CM1 o cn un oo ld o VO CM CM r~ CM CM CM il 11 co 00 cn CO CO CO ooo cn ' CoO ccno o cn CO es un in *o o 1in0 in3- in mini oo ImDi oo r-. iooni m - ^un *inT CO in oo oi mi oo o moo oeg CoM ini - CM in1 oo oo MANUFACTURING PROCESS OPERATIONS ABD00315271 V r. ABD00315272 V- Actual f-- Ul -- -- ! CM CM 04 CM CM CM in CM CM CM 1 1 1 e <3 1 *|S 3s 1 1 - 11 t1 s Sa 2 I 1 1 2 I l 0oe) V c: o co JcO ll Sr|ion. w1 H i ii 11 1 i i 3|3 ill 1 1A t t t i 1 1 iii c* Jr r r** r" o o o o ! it fi X* er CM r <r CM CM CM ! Ducted to 006-7 1 o i VO fVooO1. o r*. Oc) s IA <S 8 *4 - 44 ao3 C<0 c c o ii oo 1 ii I 1 ti cCoO in CM O J or-- ' COr : 11 zco 0c) s 11 1 11 r** r-- oo CM CM 1- 1I- o> co * too o 9 Q| A e> / * 0c) OcoJ z Su ^ IA'- 4IQJ .O +* 5 i/I O -o OJ U 3 e *i 11 1 o> t$/v_ eC oo &u >na .a saC.L 10 eo OJ *o o V +j *o *3 ncnj 1 1 >* a <0 -3 4> O r-* o CM r*. o OJ pa S a +U34 aUXJ UVI 4Z3(<X0A419 JHsnC--s 404) fiO r4o3--S3ns ii S6 (a ooo1 CM tOoo CO too <oooir to to o o o r-1 co 1 Vo0 too VO o o oo <OOT1 -o O to1 o . tot o .o CM O o o rV r ABD00315273 ABD00315274 r --ABD00315276 h PAGE 3 MANUFACTURING PROCESS OPERATIONS (FOR AGENCY USE ONLY! Rafaranca Number 001 002 003 004 005 006 ^ 007 Partialiatas 12 FmMom* Sulfur Oxidaa 0 24.5 lb/hr 84.4 ton/yr 1.3 lb/hr 5.7 ton/yr 0.2 lb/hr 0.9 ton/yr 0.5 Ib/hr 2.2 ton/vr 0 0 0 0 0 Others (Specify by ehemicalcomposition) Basie*-- for -- Estimation VCM 8.7 a\ lb/hru; Calculation See 38.3 ton/vr Appendix Calculation See Appendix Calculation See Appendix Calculation See Appendix Calculation See Appendix (Agency Commit! Only) 00 'T 0.084 lb/hr Calculation HCi 0.086 lb/hr See 0 0 CO 0.040 lb/hr Appendix NO 0.0436 lb/hr X or HCi CO NO X 0.368 ton/yr 0.377 ton/yr 0.175 ton/yr 1.91 ton/yr U) VCM emii sions are collet ted by the EPA < SomDiiance Svs :ems and rou :ed to the incinerator for the destruci ion of VCM. -- (2) This numb er includes drye t no. 1 which wi Ll only operat e 35Z of the year (8.0 lb/hr x .35 x 8760 hr/y r x 1 ton/2000 1 >). i *PImm Sxprsw Emimonsas Tom par Vaar and Poundi par Hour and IdaimHy Unita Balnf Uaad. - REFUSE DISPOSAL AND INCINERATION ABD00315277 o sO 3 C Ik e S *ik8 V) eo e 1 I 3 %V ! S5l a 2 >. *5 : Q 5*6 " 3o | Oc O5 ^& K X 85 <3 * 9 5 3 a O *1 Disposal M ethod Codes 1. Open B urning 6. Burned in Bofler or Furnance 2. Landfill (No Burning) 3. Incinerator (Complete rest o f Form ) A6. O ther (Specify) 4. Conical Burner (TeePee) ABD00315278 PAGE 2 s (AGENCY USE QWLY>_______________ 5. Auxiliary Fuel: Type Amount/Year {Specify Units) Heat Content Percent Sulfur Percent Ash Supplier's Name 6. Pollution Control Equipment: Manufacturer Model Number X Efficiency Type GPM Water Flow (If Wet Scrubber) 7. Stack Data: Height Inside Exit Diameter Exit Gas Velocity Exit Gas Volume Exit Gas. Temp. 8. Estimated Emissions From Refuse Incineration: Name: Particulates Tons/Year Sulfur Oxides a- Basis of Estimates ' V 1 Feet Feet Feet/Sec. SCFM F7r- * ' -rrr6.**' ... ---- ABD00315279 A ADDITIONAL INFORMATION 1. Two copies of construction site plot plan. 2. Two copies of detailed equipment drawings* 3. Two copies of a detailed explanation of the process and control, equipment 4. Two copies of a flow diagram of theof the process or operation: showing control devices* SIQ3ATURES: if for construction, the application must be submitted in duplicate-and bott copies should also be signed and stamped by an engineer registered in the State, of Mississippi. If application is for Existing Facility or Renewal of Permit to Operate* registered engineer*s signature not required. All signatures and stamps-must-be originsj on all copies* not photocopies. TYPED NAAB & MISSISSIPPI REGISTRATION NUWER SIGNATURE OF ENGINEER REGISTERED IN MISSISSIPPI Seal of Engineer Registered in Mississippi ABD00315280 APPENDIX I. Reference Number Identification A. Vinyl Chloride Reaction Storage Area B. PVC Dryer Area C. PVC Storage and Handling D. Compound Production Area E. Dry Blend Production Area F. Plasticizer Production Area Calculations A. Vinyl Chloride Emissions - 001 B. Particulate Emissions 1988 - 002 C. Particulate Emissions 1990 (Estimated) - 002 D. Particulate Emissions Limitations (Proposal) E. Particulate emissions 1988 - 003 F. Particulate Emissions 1988 - 004 G. Particulate Emissions 1988 - 005 H. Incinerator Emissions 1988 - 007 I. Refuse Disposal 1988 III. Proposed Particulate Emissions Limitations IV. Sulfur Dioxide A. Proposed Sulfur Dioxide Limitations B. Boiler Emission Calculations - 1988 t* ABD00315281 OPERATING PERMIT REVISION APPLICATION REFERENCE NUMBER IDENTIFICATIONS A. VINYL CHLORIDE REACTION AND STORAGE AREA Reference Number Area and Item 001-1 Railcar Unloading Stations 001-2 PVC Reactor D-300 001-3 PVC Reactor D-400 001-4 PVC Reactor D-500 001-5 001-6 PVC Reactor D-600 PVC Reactor D-700 001-7 001-8 PVC Reactor 741 PVC Reactor 742 001-9 PVC Reactor 743 001-10 001-11 001-12 PVC Reactor 744 PVC Reactor 745 Evacuation Jet - Old Module 001-13 Evacuation Jet - New Module 001-14 Slurry Dump Systems - Old Module 001-15 Slurry Dump Systems - New Module 001-16 Slurry Dump Systems - 745 Reactor 001-17 Slurry Dump Systems - D-700 Reactor 001-18 Slurry Blend Tank 550 001-19 001-20 001-21 Slurry Blend Tank 551 Slurry Blend Tank 552 Slurry Blend Tank 553 001-22 Slurry Blend Tank 646 001-23 Slurry Blend Tank 647 ABD00315282 Operating Permit Revision Application Page 2 A. VINYL CHLORIDE REACTION AND STORAGE AREA - Continued Reference Number Area and Ttem 001-24 Slurry Blend Tank 648 001-25 Slurry Blend Tank 649 001-26 Slurry Blend Tank 650 001-27 Slurry Blend Tank 651 001-28 Slurry Blend Tank 652 001-29 Slurry Blend Tank 653 001-30 Slurry Blend Tank 654 001-31 Slurry Blend Tank 655 001-32 Slurry Blend Tank 407 001-33 Slurry Blend Tank 501 001-34 Slurry Blend Tank 502 001-35 Slurry Blend Tank 747 001-36 Normal Kill Solution Mix Tank 001-37 Normal Kill Solution Charge Tank 001-38 Suspending Agent Tank D-103 001-39 Slurry Blend Tank (Low Mol) ABD00315283 Operating Permit Revision Application Page 3 B. PVC DRYER AREA Reference Number 002-1 002-2 002-3 002-4 002-5 002-6 002-7 002-8 002-9 Area and Item PVC Dryer No. 1 PVC Dryer No. 2 PVC Dryer No. 4 PVC Dryer No. 5 PVC Dryer No. 6 PVC Dryer No. 7 PVC Dryer No. 8 PVC Dryer No. 9 PVC Resin Reclaim Dryer A ABD00315284 Operating Permit Revisions Application Page 4 c. PVC STORAGE AND HANDLING Reference Number 003-1 003-2 003-3 003-4 003-5 003-6 003-7 003-8 003-9 003-10 003-11 003-12 003-13 003-14 003-15 003-16 003-17 003-18 003-19 003-20 003-21 003-22 003-23 Area and Item PVC Silo 281 Bag House No. 1 PVC Silo 281 Bag House No. 2 PVC Silo 282 Bag House No. 1 PVC Silo 282 Bag House No. 2 PVC Silo 475 Bag House PVC Silo 476 Bag House PVC Silo 478 Bag House PVC Silo 479 Bag House PVC Silo 490 and 491 Bag House PVC silo 492 Bag House PVC Silo 493 Bag House PVC Silo 575 Bag House PVC Silo 576 Bag House PVC Silo 577 Bag House PVC Silo 578 Bag House PVC Silo 675 Bag House PVC Silo 676 Bag House PVC Silo 677 Bag House PVC Silo 678 Bag House PVC Silo 679 Bag House PVC Silo 680 Bag House PVC Silo 681 Bag House PVC Silo 682 Bag House ABD00315285 Operating Permit Revision Application Page 5 C. PVC STORAGE AND HANDLING Reference Number 003-24 003-25 003-26 003-27 003-28 003-29 003-30 003-31 003-32 003-33 003-34 Continued Area and. Item PVC Silo 683 Bag House PVC Silo 684 Bag House PVC Silo 685 Bag House PVC Silo 686 Bag House PVC Silo 687 Bag House PVC Silo 688 Bag House PVC Silo 689 Bag House PVC Silo 690 Bag House PVC Silo 691 Bag House PVC Debox System Bag House Bagger Silo Bag House ABD00315286 Operating Permit Revision Application Page 6 D. COMPOUND PRODUCTION AREA Reference Number 004-1 004-2 004-3 004-4 004-5 004-6 004-7 004-8 004-9 004-10 004-11 004-12 004-13 004-14 004-15 004-16 004-17 004-18 004-19 004-20 004-21 004-22 004-23 Area and Item Compound Silo 410 Cyclone Separator Compound Silo 411 Cyclone Separator Compound Silo 415 Cyclone Separator Compound Silo 416 Cyclone Separator Compound Silo 418 Cyclone Separator Compound Silo 420 Cyclone Separator Compound Silo 421 Cyclone Separator Compound Silo 422 Cyclone Separator Compound Silo 423 Cyclone Separator Fines and Streamer Removal Bag House Line I Resin Use Bin Bag House Line I Plasticizer Weigh Tank Line I Plasticizer Heat-up Tank Line III Resin Weigh Bin Bag House Line III Plasticizer Weigh Tank Line III Plasticizer Heat-up Tank Line V Resin Use Bin Bag House Line V Clay Use Bin Bag House Line V Filler Use Bin Bag House Line V Plasticizer Make-up Tank Line V Plasticizer Weigh Tank Line V Resin Weigh Hopper Vent Sock Line V Filler Weigh Hopper Vent Sock ABD00315287 Operating Permit Revision Application Page 7 D. COMPOUND PRODUCTION AREA - Continued Reference Number Area and Item 004-24 Line V Clay Use Bin Vent sock 004-25 Line V Filler Use Bin Vent Sock 004-26 Line V Intensive Mixer Vent Sock 004-27 Line V Intensive Cooler Vent Sock 004-28 Line V Fluid Bed Cooler Vent Filter 004-29 Line V Fluid Bed Cooler Cyclone Vent Filter 004-30 Line I Bagging Silo Cyclone Separator 004-31 Line I Boxing Silo Cyclone Separator 004-32 Line III Bagging Silo Cyclone Separator 004-33 Line III Boxing Silo Cyclone Separator 004-34 Line V Bagging Silo Cyclone Separator 004-35 Line V Boxing Silo Cyclone Separator 004-36 Compound Line Ventilation System 004-37 Building Ventilation System Bag House ABD00315288 Operating Permit Revision Application Page 8 E. DRY BLEND PRODUCTION AREA Reference Number 005-1 005-2 005-3 005-4 005-5 005-6 005-7 005-8 005-9 005-10 005-11 005-12 005-13 005-14 005-15 005-16 005-17 005-18 005-19 005-20 005-21 Area and Item Dry Blend Silo 412 Bag House Dry Blend Silo 413 Bag House Dry Blend Silo 414 Bag House Dry Blend Silo 417 Bag House Ti07 Silo 477 Bag House Resin Use Bin Bag House Resin Use Bin Bag House Filler Use Bin Bag House Master Batch Use Bin Bag House Master Batch Use Bin Bag House Velex #1 Vent Sock Welex #2 Vent Sock Intensive Cooler Vent Sock Cooler #1 Vent Sock Cooler #2 Vent Sock Cooler #3 Vent Sock Cooler #4 Vent Sock Dry Blend Boxing Silo Bag House #1 Dry Blend Boxing Silo Bag House #2 Vacuum Cleanup System Bag House Master Batch Resin Bin Bag House ABD00315289 A Operating Permit Revision Application Page 9 F. PLASTICIZER PRODUCTION AREA Reference Number Area and Item 006-1 Plasticizer Reactor No. 1 006-2 Plasticizer Reactor No. 2 006-3 Plasticizer Reactor No. 3 006-4 Plasticizer Reactor No. 4 006-5 006-6 Phthalic Anhydride Storage Tank T-797 Phthalic Anhydride Storage Tank T-798 006-7 Phthalic Anhydride Vent Scrubber 006-8 Phthalic Anhydride Use Tank F-400 006-9 Caustic Storage Tank T-101 006-10 Alcohol Storage Tank T-102 006-11 Alcohol Storage Tank T-103 006-12 Alcohol Storage Tank T-104 006-13 Alcohol Storage Tank T-105 006-14 Alcohol Storage Tank T-106 006-15 Alcohol Storage Tank T-107 006-16 Alcohol Storage Tank T-108 006-17 Alcohol Storage Tank T-109 006-18 Alcohol Storage Tank T-110 006-19 Alcohol Storage Tank T-lll 006-20 Alcohol Storage Tank T-112 006-21 Plasticizer Storage Tank. T-181 006-22 Plasticizer Storage Tank T-182 006-23 Plasticizer Storage Tank T-183 ABD00315290 A Operating Permit Revision Application Page 10 F. PLASTICI2ER PRODUCTION AREA - Continued Reference Number Area and Item 006-24 Plasticizer Storage Tank T-184 006-25 Plasticizer Storage Tank T-185 006-26 Plasticizer Storage Tank T-186 006-27 Plasticizer Storage Tank T-187 006-28 Plasticizer Storage Tank T-188 006-29 Plasticizer Storage Tank T-189 006-30 Plasticizer Storage Tank T-190 006-31 Plasticizer Storage Tank T-191 006-32 Plasticizer Storage Tank T-192 006-33 Plasticizer Storage Tank T-193 006-34 Process Collect Tank T-450 006-35 Heat Treatment Tank T-460 006-36 Recovered Oil Tank 006-37 Waste Oil Tank 006-38 Plasticizer Reactor Relief Knockout Tank 006-39 Plasticizer Reactor Steam Jet #1 006-40 Plasticizer Reactor Steam Jet #2 006-41 Plasticizer Reactor Steam Jet #3 006-42 Plasticizer Reactor Steam Jet #4 006-43 Recovered Alcohol Tank T-451 006-44 Plasticizer Tank T-452 006-45 Plasticizer Tank T-453 006-46 Plasticizer Tank T-454 ABD00315291 Operating Permit Revision Application Page 11 F. PLASTICIZER PRODUCTION AREA - Continued Reference Number Area and Item 006-47 Plasticizer Tank T-455 006-48 Plasticizer Tank T-456 ABD00315292 Operating Permit Revision Application Page 12 Reference Number 007-1 007-2 Area and Item Vinyl Chloride Monomer Incinerator #1 Vinyl Chloride Monomer Incinerator #2 ABD00315293 * OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS A. VINYL CHLORIDE EMISSIONS 1988 - OOI The EPA VCM collection system is used to collect, contain, recover and reuse vinyl chloride from the equipment in vinyl chloride service. The inerts collected and a small amount of vinyl chloride are ducted to the vinyl chloride incinerators where the vinyl chloride is incinerated prior to discharge to the atmosphere. Vinyl chloride emissions from permitted NESHAPS sources for 1988 are as follows: lb/vr Rinse Water16' 7,742 Railcar Unloading (u 110 Slurry RVCM and Reactor Opening Loss121 65,520 Batch Water Strippers0' 181 VCM Incinerators0' 2 Other Fugitive Emissions15' 3.008 76,563 (1) Based on number of cars unloaded in the year. (2) Based on average residual vinyl chloride in slurry and average reactor opening loss for the year. (3) Based on number of batches of water stripped in the year. (4) Based on hours incinerator in high fire for the year. (5) Based on measurements taken on specific components and EPA fugitive emission factors. (6) Based on sample measurements. ABD00315294 OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS B. PARTICULATE EMISSION 1988 PVC DRYING AREA - 002 Dryer Number 002-1 Hours1" Qpeyated 2219 Particulate Emissions #/hr 7.O'3' Particulate Emissions ton/vr 7.8 002-2 0 0 0 002-3 6419 7.O'21 22.5 002-4 8077 7.0<2> 28.3 002-5 002-6 6994 8219 7.0<2> 7.0(I* 24.5 28.8 002-7 002-8 7778 7699 7.0'3' 0.9'" 27.2 3.5 002-9 0 0 0 Total Particulate Emission from Dryers - 142.6 ton/year. A (1) From production records. (2) Average emissions from previous particulate testing on the rotary dryers. (3) Average emissions from previous particulate testing on the fluid bed dryer. ABD00315295 A OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS C. PARTICULATE EMISSIONS 1990 (ESTIMATED1! PVC DRYING AREA - 002 Dryer Number Estimated Hours Ooeration Particulate Emissions #/hr Estimated Particulate Emissions ton/vr 002-1 2520 7.0`21 8.8 002-2 00 0 002-3 8322 1.5(n 6.2 002-4 8322 1.5l" 6.2 002-5 8322 1.5'" 6.2 002-6 8322 1.5lu 6.2 002-7 8322 1.5(n 6.2 002-8 8322 0.5`" 2.1 002-9 00 0 Total Estimated Particulate Emission from Dryers - 41.9 ton/year. (1) Based on particulate s ampling completed during October and November 1989. (2) Average emissions from previous particulate testing on the rotary dryers. ABD00315296 OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS D. PARTICULATE EMISSIONS LIMITATIONS PVC DRYING AREA - 002 Dryer Number Particulate Emissions Limit lbs /hr Particulate Emissions Limit tons/vr Hours Ooerated Baghouse Emissions Testing lbs /vr1,1 002-1 8.0 12.3 3066 002-2 0 00 002-3 3.0 13.1<2t 8760 002-4 3.0 13.1' 8760 002-5 3.0 13.1(JJ 8760 002-6 3.0 13.1'3' 8760 1.95 002-7 3.0 13.1'2' 8760 0.87 002-8 1.5 6.6 8760 0.55 002-9 0 00 TOTAL 84.4 Notes: (1) Emissions monitoring done in October and November of 1989. (2) New baghouses were installed on these dryers. A ABD00315297 A OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS E. PARTICULATE EMISSIONS 1988 P?C STORAGE AND HANDLING AREA - 003 Particulate emissions from dust collectors are based upon vendor guarantee that dusting from the collectors will not exceed 0.03 grains per cubic foot of air flow for a properly sized and maintained bag house. Transfer system flow rates, hours of operation in 1988 and 0.03 grains per cubic foot of air flow were used in the calculation of the particulate emissions from the storage silos. Emissions from the transfer of resin to the various silos from the various transfer systems and from aeration air supplied to the silos is as follows: Ton/Year Rotary Dryer Transfer Systems 1.85 Fluid Bed Dryer Transfer Systems 2.86 Transfer to Compound Raw Material Silos 0.09 Transfer to Dry Blend Raw Material Silos 0.74 TOTAL 5.54 ABD00315298 h OPERATING PERMIT REVISION APPLICATION II. CALCULATION F. PARTICULATE EMISSIONS 1988 COMPOUND PRODUCTION AREA- 004 Particulate emissions from the process area dust collectors are based upon vendor guarantee that dusting from the collectors will not exceed 0.03 grains per'cubic foot of air flow for a properly sized and maintained bag house. Air flow rates, hours of operation in 1988, and 0.03 grains per cubic foot of air flow were used in the calculation of particulate emissions from the compound process area. Calculations for the Building Ventilation System are based on an estimated 99% recovery for the bag house. This is based on the 6:1 air to cloth ratio for the bags. Material collected in the system in 1988 is estimated to be 100,000 pounds. Particulate emissions from the compound area are as follows: Ton/Year In-Process Resin Transfer 0.27 Building Ventilation System 0.5 TOTAL 0.77 ABD00315299 h OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS G. PARTICULATE EMISSIONS 1988 DRY BLEND AREA - 005 Particulate emissions from the dust collectors are based upon vendor guarantee that dusting from the collectors will not exceed 0.03 grains per cubic foot of air flow for a properly sized and maintained bag house. Air flow rates, hours of operation in 1988, and 0.03 grains per cubic foot of air flow were used in the calculation of particulate emissions from the dry blend area. Particulate emissions from the dry blend are as follows: Ton/Year In-Process Resin Transfer 0.12 In-Process Filler, TiO, and Master 0.11 Batch Transfer Dry Blend Product to Silos 1.05 Vacuum Cleanup System 0.73 TOTAL 2.01 ABD00315300 OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS H. INCINERATOR EMISSIONS 1988 - 007 Rated Process Capacity Per Incinerator Lb /Hr Ton/Year Process 163 714 Quench Steam 303 1,327 Air 1,095 4,796 Quench Water 24.809 108.663 26,370 115,500 Normal operation is to have one incinerator on standby and the use. The one in use is in high fire an average of eight hours Actual Operating Conditions Standby on Low Fire Process Quench Steam Fuel Gas Air Quench Water Normal High Fire Process Quench Steam Fuel Gas Air Quench Water Lb/Hr 0 0 16 382 24.809 25,207 Lb/Hr 56 0 33 1,095 24.809 25,993 Ton/Year 0 0 70 1,673 108.663 110,406 Ton/Year 245 0 144 4,796 108.663 113,848 ABD00315301 Pi VCM Incinerators - Continued Average Feed Input: 25,207 # Hr + 0.33 X 25,207 + 0.67 X 25,993 50,940 #/hr 223,117 ton/year. At maximum venting conditions, the volume of the exhaust stack gases is 17,000 SCFH. Using the vendors guaranteed performance limits, the maximum process emissions are calculated as follows: Maximum Concentration Limits PPM (Bv.Volume) Cl3 25 CO 30 HC1 50 NO, 200 Maximum Emissions Cl CO HC1 NO, Lb/Hr . 0.084 0.040 0.086 0.436 --Ton/Year 0.368 0.175 0.377 1.910 ABD00315302 S OPERATING PERMIT REVISION APPLICATION II. CALCULATIONS I. REFUSE DISPOSAL CALCULATION 1988 Refuse is transported by: Waste Management of North Mississippi - Tupelo P. 0. Box 1373 Tupelo, Mississippi 38802 The refuse includes: Paper, cardboard, plastic, garbage, wood, PVC resin and compound. The refuse is disposed in the Monroe County Landfill. The refuse is collected in a forty cubic yard roll-off container and then transported to the landfill. In 1986, there were 324 container loads taken to the landfill. The weight of the refuse per load is estimated to be 15,000 pounds. 180__containers X 12.356 avg. lbs, refuse - 2,224,080 #/yr year container 1,112 ton/year * ABD00315303 OPERATING PERMIT REVISION APPLICATION PROPOSED PARTICULATE EMISSION LIMITATIONS Sourr.p. Emission Limit lb/hr 002-1 8.0 002-2 0 002-3 002-4 3.0 3.0 002-5 3.0 002-6 3.0 002-7 3.0 002-8 1.5 002-9 003,1-34 0 1.3 004,1-37 0.2 005,1-21 0.5 006 0 007 0 Boiler No. 1 0.3 Boiler No. 2 0.3 Boiler No. 3 0.4 Emission Limit tons/vr 12.3 0 13.1 13.1 13.1 13.1 13.1 6.6 0 5.7 0.9 2.2 0 0 1.3 1.3 1.8 Hours of Ooeration 3,066 0 8,760 8,760 8,760 8,760 8,760 8,760 0 8,760 8,760 8,760 8,760 8,760 8,760 8,760 8,760 TOTAL 97.6 ABD00315304 OPERATING PERMIT REVISION APPLICATION IV. SULFUR DIOXIDE A. PROPOSED SULFUR DIOXIDE LIMITATIONS Source Boiler No. 1 Sulfur Dioxide Emissions lbs/hr 4.6 Sulfur Dioxide Emissions tons /vr 20 Boiler No. 2 4.6 20 Boiler No. 3 6.8 30 Hours of ODeration 8,760 8,760 8,760 & ABD00315305 OPERATING PERMIT REVISION APPLICATION * IV. SULFUR DIOXIDE B. BOTT.ER EMISSION CALCULATIONS - 1986 Federal EPA publication AP-42 gives the following compilation of air pollutant emission factors for boilers in Table 1.4 - 1, Natural Gas Combustion, Rating B. Emission #/MM ft3 Gas Burned Particulate 18 SO, 0.6 CO 17 CH, 3 NOx 120 Boilers #1 and #2 130MM ft2 Yr. A. 18 lb. MM ft3 Ton 2000 lb. 1.17 Ton Particulate Year 130MM ft3 Yr. A 0.6 lb. MM ft3 Ton 2000 lb. 0.04 Ton SO, Year 13GMM ft3 Yr. X 17 lb. MM ft3 -X Ton 2000 lb. 1.11 Ton CO Year 130MM ft3 Yr. X 3 lb. MM ft3 X Ton 2000 lb. 0.20 Ton CH. Year 130MM ft3 Yr. 120 lb. MM ft3 A Ton 2000 lb. 7.80 Ton NO.. Year Boiler #2 194MM ft3 Yr. 18 lb. MM ft3 A Ton 2000 lb. 1.75 TonParticulate Year 1.94MM ft3 Yr. 0.6 lb. MM ft3 Ton 2000 lb. 0.06 Ton SO, Year 194MM ft3 Yr. 194MM ft3 Yr. X 17 lb. MM ft3 3 lb. MM ft3 Ton 2000 lb. Ton 2000 lb. 1.65 0.29 Ton CO Year Ton CH. Year 194MM ft3 Yr. 120 lb. MM ft3 Ton 2000 lb. 11.64 Ton NO.. Year Vista Poiymen A Division of Vista Chemical Company ABD00315306 Highway 25 Post Office Box 91 Aberdeen, Mississippi 39730 Phone (601) 369-8111 A November 22, 1989 VISTA Mr. Danny Jackson North Air Emissions Section Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39209 Dear Mr. Jackson: Vista Polymers is requesting approval for a project which will add a new vinyl chloride emission point. This project will enable our facility to increase the amount of high performance PVC resin we produce. By modifying our existing support systems for our reactors, we can produce the high performance PVC resin. The high performance PVC resin will displace current production of commodity - type PVC resin. Therefore, the Vinyl Chloride Monomer (VCM) emissions at our facility will not increase. Although VCM emissions will not increase from our facility, one new emission point will result from this project. In addition, an extra relief valve will be installed on one of our reactors. Per Bobby Whitaker's letter dated August 14, 1989, no NESHAP approval will be necessary for this project. However, Bobby did state that a construction permit will be required. The part of the permit affected by this new emission source is Part III (Other Requirements). This section authorizes the emission of air contaminants from equipment and processes in accordance with the NESHAP's regulations. We will be adding one additional emission point and it will comply with the NESHAP's regulations. The additional emission point we will be adding is a blend tank. We currently have eighteen blend tanks operating at our plant. There are no emissions control equipment on the blend tank. All emissions control is completed in our reactors before the material is sent to the blend tanks. ABD00315307 ft 2 The new blend tank is necessary to produce the high performance PVC resin. However, overall plant production will not increase. The emissions from all of the blend tanks including the new one will be the same as before. The new blend tank will displace some of the volume that went to the existing blend tanks. I would be happy to discuss this project with you further either on the phone or in person. My phone number is 601-369-3637. Sincerely, F. G. Jeanson Senior Environmental Coordinator /tjs cc: RWS, DCS, RBN, JEL, PJK ABD00315308 To: Distribution Interoffice Communication From: Date: Subject: F. G. Jeanson August 8, 1989 LOW MOLECULAR NESHAP AUTHORIZATION VISTA Attached is a letter received Molecular Weight Resin Project. emission source (blend tank) emissions. from the EPA regarding the Low This project added an additional but did not increase overall We submitted a letter asking for NESHAP approval. According to this letter we do not need NESHAP approval for an additional emission source. Frank G. Jeanson Senior Environmental Coordinator tjs cc: RWS, RBN, PJK, SCH, CJMc, KWB Houston: JCL, TGG, WLM, DLG ABD00315309 `d ! : tM 88/^0/80 J.N03 nod ana sw woad AUG 2 1989 4APT-AC UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 349 COUNT LAN O STRICT ATLANTA. GEORGIA 30M9 Mr. Bobby V. Whitaker, P.E. Air Quality Division Bureau of Pollution Control Department of Natural Resources P. 0. Box 10385 Jackson, Mississippi 39209 Subject: NESHAP Permitting Guidance Regarding New Blend Tank Instruction at Vista Polymers Located in Aberdeen, Mississippi Dear Mr. Whitaker: As requested in your letter of June 22, 1989, we have reviewed Vista's May 4, 1989, submittal providing you with information on the referenced changes, and are supplying guidance on how permitting for the blend tank addition should be handled. Based upon our review of the information supplied by vista, we have determined that Vista will not be required to obtain NESHAP approval prior to installing the blend tank. Therefore, Vista will only have to ccmply with applicable Bureau of Pollution Control permitting requirements* The basis for our determination that NESHAP approval will not be required prior to installation of the blend tank is that the installation will not constitute modification or new source construction as defined in the NESHAP General Provisions. If the installation did constitute modification or new source construction, 40 CRF 61*05 would have required Vista to obtain written approval prior to commencing construction of the blend tank. Installation of the blend tank is not considered to be new source construc tion because the affected facility defined in Subpart F is the entire vinyl chloride production plant. Since the affected facility is the entire plant, adding one piece of new equipment {the blend tank) to the plant would not constitute construction of a new source. While the addition of the blend tank does not constitute new source construc tion, it also has to be evaluated fran the standpoint of modification which is defined in 40 CFR 61.15 as "...any physical or operational change to a stationary source which results in an increase in the rate of emission to the atmosphere of a hazardous pollutant to which a standard applies." Based upon our review of the information in Vista's suimittal to the BPC, we have deter mined that the blend tank addition should not cause an increase in air emissions and therefore, does not constitute a modification as defined in the NESHAP~ The blend tank addition should not cause an increase in anissions because its installation will increase Vista's high performance PVC resin production capacity but will leave the plant's total PVC resin production capacity unchanged. The blend tank addition will not increase Vista's resin production because no new reactor capacity will be added and because the increased amount of high performance resin produced at the plant will displace an equal amount of cawnodity-type resin production. *d nyioi 0 AgDOOgJ^^-lp 68/10/80 inod nod ana sw woad Although Vista will not be required to obtain NESHAP approval prior to instal lation of the new blend tank, the tank and associated equipment will become subject to all applicable 40 CFR 61, Subpart F anission standards once the equipment begins operating in vinyl chloride service since the entire facility is already subject to 40 CFR 61, Subpart F, If you have any additional questions or require any clarification oi the information contained in this letter, please contact Mr. David McNeal of my staff at 404/347-2904, vrun-c R A_ __________ Air, Pesticides and Toxics Management Division cct Mr. Dwight Wylie, P.E., Chief Air Quality Division Bureau of Pollution Control Department of Natural Resources P. 0. Box 10385 Jackson, Mississippi 39209 i5 s3 S_ n i a ce *5. I <3~ * 1 r- <?b r- * t-"C ^9 \ S Li_ ABD00315312 Operating Permit Renewal Application Page 3 PVC DRYER AREA Reference Number 002-1 002-2 002-3 002-4 002-5 002-6 002-7 002-8 002-9 Area and Item PVC Dryer No. 1 PVC Dryer No. 2 PVC Dryer No. 4 PVC Dryer No. 5 PVC Dryer No. 6 PVC Dryer No. 7 PVC Dryer No. 8 PVC Dryer No. 9 PVC Resin Reclaim Dryer A ABD00315313 Operating Permit Renewal Application Page 4 PVC STORAGE AND HANDLING-.... Reference Number 003-1 003-2 003-3 003-4 003-5 003-6 003-7 003-8 003-9 003-10 003-11 003-12 003-13 003-14 003-15 003-16 003-17 003-18 003-19 003-20 003-21 003-22 003-23 003-24 003-25 Area and Item PVC Silo 281 Bag House No. 1 PVC Silo 281 Bag House No. 2 PVC Silo 282 Bag House No. 1 PVC Silo 282 Bag House No. 2 PVC Silo 475 Bag House PVC Silo 476 Bag House PVC Silo 478 Bag House PVC Silo 479 Bag House PVC Silo 490 and 491 Bag House PVC Silo 492 Bag House PVC Silo 493 Bag House PVC Silo 575 Bag House PVC Silo 576 Bag House PVC Silo 577 Bag House PVC Silo 578 Bag House PVC Silo 675 Bag House PVC Silo 676 Bag House PVC Silo 677 Bag House PVC Silo 678 Bag House PVC Silo 679 Bag House PVC Silo 680 Bag House PVC Silo 681 Bag House PVC Silo 682 Bag House PVC Silo 683 Bag House PVC Silo 684 Bag House ABD00315314 Operating Permit Renewal Application Page 5 PVC STORAGE AND HANDLING - Continued Reference Humber Area and Item 003-26 PVC Silo 685 Bag House 003-27 PVC Silo 686 Bag House 003-28 PVC Silo 687 Bag House 003-29 PVC Silo 688 Bag House 003-30 PVC Silo 689 Bag House 003-31 PVC Silo 690 Bag House 003-32 PVC Silo 691 Bag House 003-33 PVC Debox System Bag House 003-34 Bagger Silo Bag House ABD00315315 Operating Permit Renewal Application Page 6 COMPOUND PRODUCTION AREA Reference Number 004-1 004-2 004-3 004-4 004-5 004-6 004-7 004-8 004-9 004-10 004-11 004-12 004-13 004-14 004-15 004-16 004-17 004-18 004-19 004-20 004-21 004-22 004-23 004-24 004-25 004-26 Area and Item Compound Silo 410 Cyclone Separator Compound Silo 411 Cyclone Separator Compound Silo 415 Cyclone Separator Compound Silo 416 Cyclone Separator Compound Silo 418 Cyclone Separator Compound Silo 420 Cyclone Separator Compound Silo 421 Cyclone Separator Compound Silo 422 Cyclone Separator Compound Silo 423 Cyclone Separator Fines and Streamer Removal Bag Houaa Line I Resin Use Bln Bag House Line I Plasticizer Weigh Tank Line I Plasticizer Heat-up Tank Line III Resin Weigh Bln Bag House Line III Plasticizer Weigh Tank Line III Plasticizer Heac-up Tank Line V Resin Use Bln Bag House Line V Clay Use Bln Bag House Line V Filler Use Bln Bag House Line V Plasticizer Make-up Tank Line V Plasticizer Weigh Tank Line V Resin Weigh Hopper Vent Sock Line V Filler Weigh Hopper Vent Sock Line V Clay Use Bln Vent Sock Line V Filler Use Bin Vent Sock Line V Intensive Mixer Vent Sock ABD00315316 Operating Permit Renewal Application Page 7 COMPOUND PRODUCTION AREA - Continued Reference Number Area and Item 004-27 Line V Intensive Cooler Vent Sock 004-28 Line V Fluid Bed Cooler Tent Filter 004-29 Line V Fluid Bed Cooler Cyclone Vent Filter 004-30 Line I Bagging Silo Cyclone Separator 004-31 Line I Boxing Silo Cyclone Separator 004-32 Line III Bagging Silo Cyclone Separator 004-33 Line III Boxing Silo Cyclone Separator 004-34 Line V Bagging Silo Cyclone Separator 004-35 Line V Boxing Silo Cyclone Separator 004-36 Compound Line Ventilation System 004-37 Building Ventilation System Bag House ABD00315317 Operating Permit Renewal Application Page 8 DRY BLEND PRODUCTION AREA Reference Number 005-1 005-2 005-3 005-4 005-5 005-6 005-7 005-8 005-9 005-10 005-11 005-12 005-13 005-14 005-15 005-16 005-17 005-18 005-19 005-20 005-21 Area and Item Dry Blend Silo 412 Bag House Dry Blend Silo 413 Bag House Dry Blend Silo 414 Bag House Dry Blend Silo 417 Bag House TIO^ Silo 477 Bag House Resin Use Bln Bag House Resin Use Bln Bag House Filler Use Bln Bag House Master Batch Use Bln Bag House Master Batch Use Bln Bag House Welex #1 Vent Socle Welex 02 Vent Sock Intensive Cooler Vent Sock Cooler 01 Vent Sock Cooler 02 Vent Sock Cooler 03 Vent Sock Cooler #4 Vent Sock Dry Blend Boxing Silo Bag House 01 Dry Blend Boxing Silo Bag House 02 Vacuum Cleanup System Bag House Master Batch Resin Bln Bag House ABD00315318 air permit ABD00315319 PERMITS A. Operating Permit No. 1840-00014 for Air Emissions Equipment An application for a construction permit needs to be submitted for any significant modification to the process or facility which alters the rate or composition of air pollutant emissions. A new permit application must be submitted 180 days prior to March 1, 1991, in order to renew this permit. This permit gives emissions limitations on our three boilers, nine PVC dryers, particulate matter on 35 baghouses combined, particulate matter from the Compound Production area, particulate matter from the Dryblend area, air contaminants from the Plasticizer Production area, emissions from the VCM incinerators, and emissions covered under NESHAPS. 4-2 ABD00315320 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau nf Pollution Control P. C Sox 10385 Jackson. Mississippi 39209 1601) 961-5171 February 24, 1988 * CERTIFIED MAIL NO. P-125 260 667 Mr. John Friend, Plant Manager Vista Polymers P. 0. Box 91 Aberdeen, Mississippi 39730 Dear Mr. Friend: Re: Operating Permit No. 1840-00014 Aberdeen, Mississippi Enclosed please find Operating Permit No. 1840-00014 issued for the operation of the air emissions equipment. Operation of the air emissions equipment at the facility shall be in accordance with the terms, conditions, and limitations of the permit. Any significant modification to this process or facility which will alter the rate or composition of air pollutant emissions will cause this permit to become invalid. Should you wish to make such a modification, it will be necessary to submit a new application for a construction permit. This permit expires on March 1, 1991. A new permit application must be submitted one hundred and eighty (180) days prior to this date in order to renew this permit. Any appeal of this permit action must be made within the 30 day period provided for in Section 49-17-29(4)(b) Mississippi Code of 1972. If you have any questions or if we can be of service, please let me know. Very truly yours, BVWseb Enclosure Bobby^. Whitaker North Air Emissions Section 4-3 ABD00315321 STATE OF MISSISSIPPI AIR POLLUTION CONTROL PERMIT TO OPERATE AIR EMISSIONS EQUIPMENT THIS CERTIFIES THAT Vista Polymers Hwy. 25 Aberdeen, Mississippi has been granted permission to operate air emissions equipment In accordance with emission limitations, monitoring requirements and conditions set forth herein. This permit Is Issued In accordance with the provisions of the Mississippi Air and Water Pollution Control Law (Section 49-17-1 et. seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder. Issued this 23rd. day of February. 1988 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Expires 1st day of March. 1991 Permit No. 1840-00014 4-4 ABD00315322 PART I Page 3 of 11 Penal t No. 1840-00014 b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to Inspect any monitoring equipment or monitoring method required In this permit; and to sample any air emission. 8. After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked In whole or In part during Its term for cause Including, but not limited to: a. Violation of any terms or conditions of this permit. b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or c. A change In any condition that required either a temporary or permanent reduction or elimination of authorized air emissions. 9. For renewal of this permit the applicant shall make application not less than one-hundred eighty (180) days prior to the expiration date of the permit substantiated with current emissions data, test results or reports or other data as deemed necessary by the Mississippi Department of Natural Resources Permit Board. 10. Except for data determined to be confidential under the Mississippi Air & Water Pollution Control Law, all reports prepared In accordance with the terms of this permit shall be available for public Inspection at the offices of the Mississippi Department of Natural Resources Bureau of Pollution Control. 11. The Issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does It authorize any Injury to private property or any Invasion of personal rights, nor any Infringement of Federal, State or local laws or regulations. 12. Nothing herein contained shall be construed as releasing the permittee from any liability for damage to persons or property by reason of the Installation, maintenance, or operation of the air cleaning facility, or from compliance with the applicable statutes of the State, or with local laws, regulations, or ordinances. 13. This permit Is non-transferable. 14. This permit Is for air pollution control purposes only. 4-5 ABD00315323 A PART II Page 4 of 11 Permit Ho. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the boiler, Emission Point 001. Boilers: 1. 2. 3. Springfield No. L680 - 39.9 x loji BTU/HR Springfield No. L694 - 39.9 x 10D BTU/HR Cleaver Brooks No. OL76 - 59.8 x 10 BTU/hr Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Boiler No. 1 Particulate Matter 19.01 lbs/hr Sulfur Dioxide 95.76 Ibs/hr Boiler No. 2 Particulate Matter 19.01 lbs/hr Sulfur Dioxide 95.76 Ibs/hr Boiler No. 3 Particulate Matter 26.64 lbs/hr Sulfur Dioxide 143.52 Ibs/hr Also Included with this Emission Point Is the Vinyl Chloride Reaction and Monomer Storage Area. (See PART III of this Permit.) 4-6 ABD00315324 PART II Page 5 of 11 Penalt Ho. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee is authorized to operate air emissions equipment and emit air contaminants from the PVC Dryers, Emission Point 002. PVC Dryers: 1. PVC Dryer #1 with Baghouse .2 PVC Dryer #2 with Baghouse 3. PVC Dryer #4 with Baghouse 4. PVC Dryer #5 with Baghouse 5. PVC Dryer #6 with Baghouse 6. PVC Dryer #7 with Baghouse 7. PVC Dryer #8 with Baghouse 8. Fluidized Bed PVC Dryer with Scrubber 9. Resin Reclaim Dryer with Baghouse Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Particulate Matter: 1. PVC Dryer #1 2. PVC Dryer #2 3. PVC Dryer #4 4. PVC Dryer #5 5. PVC Dryer #6 6. PVC Dryer #7 7. PVC Dryer #8 8. Fluidized Bed PVC Dryer 9. Resin Reclaim Dryer 19.1 Ibs/hr 19.1 lbs/hr 19.1 Ibs/hr 19.1 Ibs/hr 19.1 Ibs/hr 19.1 Ibs/hr 19.1 Ibs/hr 36.3 lbs/hr 5.9 lbs/hr 4-7 ABD00315325 PART II Page 6 of 11 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIRBENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the PVC Storage and Handling Process, Emission Point 003. Thirty-five (35) baghouses are Included with this Emission Point for control of particulate matter. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Particulate Matter 36.4 Ibs/hr - This represents the total mass limit for the entire Emission Point (all 35 baghouse combined). It is based on a process weight rate of 26.0 tons per hour. 4-8 ABD00315326 h PART II Page 7 of 11 Permit No. 1840-00014 PART II BUSSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Compound Production Area, Emission Point 004. This Includes all cyclones and baghouses associated with the process. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Particulate Matter 12.3 Ibs/hr - Based on a process weight of 5.1 tons per hour. 4-9 ABD00315327 fb PART II Page 8 of 11 Permit Mo. 1840-00014 PART II MISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Dry Blend Production Area, Emission Point 005. This Includes all particulate matter collection devices associated with the process. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Particulate Matter 10.9 lbs/hr - Based on a process weight of 4.3 tons per hour. 4-10 ABD00315328 PART II Page 9 of 11 Pewit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Plasticizer Production Area, Emission Point 006. Such air emissions equipment shall be operated as efficiently as possible to provide the maximum reduction of air contaminants. 4-11 ABD00315329 PART II Page 10 of 11 Penalt No. 1840*00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning February 23, 1988, and lasting until March 1, 1991, the permittee Is authorized to operate air emissions equipment and emit air contaminants from the Vinyl Chloride Monomer Incinerators, Emission Point 007. Such emissions shall be limited and monitored by the permittee as specified below: EMISSION LIMITATIONS Chlorine (Clg) 0.084 lbs/hr and 0.368 tons/year Hydrogen Chloride (HC1) 0.086 Ibs/hr and 0.377 tons/year % 4-12 ABD00315330 % PART III Page 11 of 11 Penalt No. 1840-00014 PART III OTHER REQUIREMENTS (1) The permittee Is authorized to emit air contaminants from equipment and processes In accordance with the terms and conditions of the National Emission Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR Part 61 Subpart A - General Provisions and Subpart F - Vinyl Chloride. SR-154 ABD00315331 CONSTRUCTION PERMIT ABD00315332 % IV. PERMITS B. Permit for Construction of Air Emissions Equipment Although we are presently not required to have a Prevention of Significant Deterioration ("PSD") permit, we could trigger that requirement if we have new construction of $1.2MM or modifications of the process. We are a major emitting facility because we emit or have the potential to emit 100 tons per year of particulates. The new baghouses for the rotary dryers should bring us under the 100 tpy trigger point. No new construction may be started on a major source or modification in any area where PSD requirements apply without preconstruction review of air quality impacts. Therefore, we submitted a request for construction permits to install new baghouses on our rotary dryers. A copy of that request and consent is attached. 4-14 Visfo Polvmers A Division of Vi$to Chemical Company ABD00315333 Highway 20 . Post Office Box 91 Aberdeen. Missjsjido* 39730 Phone ioQU 369*8111 s May 3, 1989 Mr. Bobby V. Whitaker North Air Emissions Section Mississippi Department of Natural Resources Bureau of Pollution Control P.0. Box 10385 Jackson, MS 39209 Dear Mr. Whitaker: Re: Construction Permit No. 1840-00014 Aberdeen, Mississippi As we discussed in a recent telephone conversation, the approved construction permit for a new baghouse on our dryers needs two modifications. The modifications requested are for limitations in fuel and production and volatile organic compounds. When we discussed the rate of natural gas to the dryers, I gave you an average usage not a maximum. Please change the limitation on natural gas to the dryers to a rate of 180,000 scf per day. During the production of Poly Vinyl Chloride , a certain amount of residual vinyl chloride is contained in the PVC particle. As the PVC particle is handled through our process the vinyl chloride in the particle is given off. When the PVC particles reach our dryers, there is some residual vinyl chloride contained in them. This vinyl chloride is released during the drying process and would be vented out the baghouse. The maximum amount of vinyl chloride released in the drying process would be 0.1 lbs/hr or 0.438 tons/yr. If you have any questions, please give me a call at 369-3637. Sincerely, Frank G. Jeanso Environmental Coordinator c: RWS, RBN ABD00315334 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control P.O. Box 10385 Jackson, Mississiopi 39289*0385 (601) 961-5171 April 13, 1539 * CERTIFIED MAIL .VO. ? 965 30** 005 Mr. Frank G. Jeansen Environmental Coordinator Vista Polymers P. 0. Box 91 Aberdeen, Mississippi 39T30 Dear Mr. Jeansen: He: Construction Permit No. 18LO-COOIU Aberdeen, Mississippi We have completed our reviev of the plans and specifications for the above referenced permit and approval is hereby indicated for air pollution control purposes only. Enclosed please find Construction Permit No. 1840-00014 for the construction of the air emissions equipment and air pollution control equipment. Prior to startup of the air emissions equipment at this facility, a Performance Evaluation Permit must be obtained from the Permit Board. In order to obtain the Performance Evaluation Permit, it will be necessary to submit certification by a professional engineer registered in the State of Mississippi that construction vas completed in accordance vith the approved plans and specifications and a written reauest for the rermit. Any appeal of this permit action must be made within the 30 day period provided for in Section 49-17-29(4)(b) Mississippi Code of 1972. If you have any questions or if we can be of any service, please let me know. Very* truly yours. BVW:eis Enclosure Bobby V. Whitaker North Air Emissions Section 4-16 ABD00315335 y y STATE OF MISSISSIPPI ni AIR POLLUTION CONTROL y PERMIT TO CONSTRUCT AIR EMISSIONS EQUIPMENT li n i y fi THIS CERTIFIES THAT j n Vista Polymers j Highway 25 Aberdeen, Mississippi has been granted permission to construct air emissions equipment to comply with emission limitations, monitoring requirements and other conditions set forth herein. This permit Is Issued In accordance with the provisions of the Mississippi Air and Water Pollution Control Law (Section 49-17-1 et. seg., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder. u 1 Issued this 11th day of Aprl1. 1989 ( li ip MISSISSIPPI NATURAL RESOURCES PERMIT BOARD i n i director; bureau of pollution control MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Permit No. 1840-00014 4-17 ,1 ABD00315336 \ PART X Page 2 of 9 Permit No. 1840-00014 PART I GENERAL CONDITIONS 1. The plans, specifications, schedules, dates and other data submitted to the Permit Board are filed with and considered as a part of this permit. 2. All air pollution control facilities shall be designed and constructed such as to allow proper operation and maintenance of this permit. 3. The necessary facilities shall be constructed so that solids removed In the course of control of air emissions may be disposed of in a manner such as to prevent the solids from becoming windborne and to prevent the materials from entering State waters. 4. The air pollution control facilities shall be constructed such that diversion from or bypass of collection and control facilities is not needed except (1) where unavoidable to prevent loss of life or severe property damage or (M) when approved by the Mississippi Natural Resources Permit Board. 5. The construction of facilities shall be performed In such a manner as to reduce both point source and fugitive dust emissions to a minimum. 6. The permittee shall allow the Mississippi Department of Natural Resources Bureau of Pollution Control and the Mississippi Natural Resources Permit Board and/or their representatives upon presentation of credentials: a. To enter upon the permittee's premises where an air emission source is located or in which any records are required to be kept under the terms and conditions of this permit; and b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to Inspect any monitoring equipment or monitoring method required in this permit; and to sample any air emission. 7. After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or In part during Its term for cause including, but not limited to: a. Violation of any terms or conditions of this permit; b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts, or c. A change in any condition that requires either a temporary or permanent reduction or elimination of authorized air emissions. 4-18 ABD00315337 h PART I Page 3 of 9 Permit No. 1840-00014 8. Except for data determined to be confidential under the Mississippi Air & Water Pollution Control Law, all reports prepared In accordance with the terms of this permit shall be available for public Inspection at the offices of the Mississippi Department of Natural Resources 8ureau of Pollution Control. 9. The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any Injury to private property or any Invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. 10. Nothing herein contained shall be construed as releasing the permittee from any liability for damage to persons or property by reason of the Installation, maintenance, or operation of the air cleaning facility, or from compliance with the applicable statutes of the State, or with local laws, regulations, or ordinances. 11. This permit Is non-transferable. 12. This permit Is for air pollution control purposes only. 13. Approval to construct will expire should construction not begin within one (1) year of the Issuance of this permit, or should construction be suspended for one (1) year or more. 14. This permit shall become void upon completion of construction. The permittee shall furnish the Bureau of Pollution Control written notification of construction completion within 15 days of such date. 15. Prior to startup of air emissions equipment at this source, a Performance Evaluation Permit must be obtained. The permittee shall submit certification by a professional engineer registered In the State of Mississippi that construction completed In accordance with the approved plans and specifications and a written request for the permit. 4-19 ABD00315338 & PART II Page 4 of 9 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989, the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 3 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A. PH10 Sulfur Dioxide 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and Q.Q18 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 lb/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 lbs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60. Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-20 ABD00315339 PART II Page 5 of 9 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989\ the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 4 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. BttSSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A. PM10 Sulfur Dioxide 2.4 Ibs/hr & 10.5 tons/year 0.004 lb/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are In effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse Is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-21 ABD00315340 b PART II Page 6 of 9 Permit No. 1340-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989', the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 5 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 toris/year, verifiable by Test Methods 1-5, 40 CFR 60, Appenoix A. PM10 Sulfur Oloxlde 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 Ib/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are In effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse Is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-22 ABD00315341 PART II Page 7 of 9 Permit No. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989; the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 6 in the PVC Drying Area, Emission Point 002. The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 Ibs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appendix A. 2.4 Ibs/hr & 10.5 tons/year Sulfur Dioxide 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. Carbon Monoxide 0.134 lb/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatlle Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse Is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. 4-23 ABD00315342 PART II Page 8 of 9 Permit Ho. 1840-00014 PART II EMISSION LIMITATIONS AND MONITORING REQUIREMENTS Beginning April 11, 1989, the permittee is authorized to construct air emissions equipment for the emission of air contaminants from Baghouse No. 7 in the PVC Drying Area, Emission Point 002, The air emissions equipment shall be constructed to comply with the emission limitations and monitoring requirements specified below. EMISSION LIMITATIONS Particulate Matter 2.4 lbs/hr and 10.5 tons/year, verifiable by Test Methods 1-5, 40 CFR 60, Appenaix A. PM 10 Sulfur Oioxide Carbon Monoxide 2.4 Ibs/hr & 10.5 tons/year 0.004 Ib/hr and 0.018 ton/year, verifiable by Test Method 6, 40 CFR 60, Appendix A. 0.134 Ib/hr and 0.587 ton/year, verifiable by Test Method 10, 40 CFR 60, Appendix A. Nitrogen Oxides 0.667 lb/hr and 2.92 tons/year, verifiable by Test Method 7, 40 CFR 60, Appendix A. Volatile Organic Compounds 0.054 Ibs/hr and 0.0234 ton/year, verifiable by Test Method 18, 40 CFR 60, Appendix A. Opacity 40% verifiable by Test Method 9, 40 CFR 60, Appendix A. All test methods specified above shall be those versions which are in effect April 11, 1989. FUEL & PRODUCTION LIMITATIONS The drier controlled by this baghouse is permitted to be heated only with natural gas at a rate not to exceed 160,000 scf per day. ABD00315343 PART III Page 9 of 9 Penait Ho. 1840-00014 PART III OTHER REQUIREMENTS The operator of the equipment covered by this permit shall operate and maintain this equipment to assure that the emission rates will not, at any time, exceed the rates allowed by the Mississippi Air Emission Regulations. SR--158 4-25 ABD00315344 WATER PERMIT ABD00315345 ft VI. PERMITS C. State of Mississippi Water Pollution Control Permit This NPDES Permit Number MS0001970 expires March 31, 1991, and application for renewal needs to be made 180 days prior to the expiration data. It gives effluent limitations and monitoring requirements for the following waste streams: 001 002 003 004 Process Water from Pond 6 Outfall South of Pit #2 New Module non-contact cooling water and storm water Pit #1 non-contact cooling water and storm water Once through breathing air pump seal water 4-26 ABD00315346 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control P. O. Box 10385 Jackson. Mississippi 39209 (601) 981*5171 June 23t 1986 CERTIFIED MAIL NO. P 285 765 578 Mr. John Friend Vista Polymers, Inc. P. 0. Box 91 Aberdeen, Mississippi 39730 Dear Mr. Friend: Re: NPDES Permit No. MS0001970 Enc. aed is National Pollutant Discharge Elimination System (NPDES) Permit Numr. ;r MS0001970, which is hereby issued to Vista Polymers, Inc. Please note the effluent limitations, schedule of compliance, monitoring requirements, and monitoring reporting dates in Part I of the permit. This permit is issued in accordance with the provisions of the Mississippi Air and Water Pollution Control Lav (Sections 49-17-1, et. seq., Mississippi Code of 1972), and the regulations and standards adopted promulgated thereunder, and under the authority granted to the Mississippi Natural Resources Permit Board pursuant to Section 402(b) of the Federal Water Pollution Control Act. If you desire that a Permit Board hearing be held regarding this permit, you must make written application to the Permit Board within thirty (30) days of receipt of this notice; otherwise, the terms, conditions and limitations of this permit become final. JEM:els Enclosure cc: Mr. Robert F. McGhee, EPA (w/enclosure) Mr. Warren Foster NRO (w/enclosure) 4-27 JUN2 6 ABD00315347 State of Mississippi Water Pollution Control PERMIT TO DISCHARGE WASTEWATER IN ACCORDANCE WITH THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM THIS CERTIFIES THAT VISTA POLYMERS, INC. Aberdeen, Mississippi has been granted permission to discharge wastewater into James Creek in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts L H, and IQ hereof. This permit is issued in accordance with the provisions of the Mississippi Water Pollution Control Law (Section 49-17-1 et seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder, and under authority granted pursuant to Section 402 (b) of the Federal Water Pollution Control Act. DIRECTOR, BUREAU OF POLLUTION CONTROL MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Issued: May 9, 1986 Expires: March 31, 1991 Permit No. MS0001970 4-28 ro-s O' o o o -- z oo H ABD00315348 --i O C25 a. a C. C. a. E o u 6h*0 y X y *oa o U N oc fat> v O' O' cn 12X y bCO X e s 60 e C "3 C n ys b y 44 y 2 cn vO w ao O' u -0 b Cl ON W r* gO 60 .S i*s C V) if fts"O 2 Oc 5UQ. >Cr 8 c <" Qo * jj x 0) CJ & M S3 E awu. u X X *3 uhACaJ a oS E co CO o ft> Xo 4) 2? xCc6j o X CJ 3 CO a S. E *2 4 $ z 3 a u a uz S o f- oz z ~ >s CO 3 CZoO $ p 5b < t 2 j w 2 S B za Jz a 12 b 3 m go EE EE s oO 0O0 3 0o b CJ u u CJ CJ CJ CJ CJ *3 Li bb bbb b ,. bb 0 XS XXXXX XXX u 11 1 1 ) y1 1 1 eft y < *y -31 tf b ST 4* <r b oft CM CM CM CM CM U CM CM CM CJ CO 5s 3s >. c 3 454s pH> 5s >* > 9s >s bMb OIVU C .yX -aX) y VU y y bb eft <0 &&&2 3 3 3 3o ft) ft) ft) ft) ft) cj "pHs 660 60 so ns o ' -5* m on Io m cn ii ii 60 60 BB o us CM VC cn cm lI ll ll l) ii ii /S /4 cm cn -- CM X O' O f- m o\ r-> O -T cm cm cn CN| | Loao* Wr*. w W a4 cn r*. w ( 1 00 cn sr us i x cn cn cn cm 44 cn p* a4 X <N 1 ti 1ii /S b -4 fb /*N lb 4Nb X 44 m cn in St CM rs cn i <r cn -- 44 X 1 M w w '--i w w i x cn O' X 44 X X US o vo us m X 1 1 o e <s Sc3 Q <n *a c B ft) o a 3) a CO a ea) -o y 60 3 >> C * f X g to bSS WCO ^ -4|<n| bft) bft) ay CC3QO by_ 434 cq z) b g y u s b H C S ") ft) ^ y jh o B h 3 co a 9 0 3 W ci 3cn u s O f* X O ft) U HH eft JXs eft y x Xu y i X o o>-t y fi* *bH X44 bta o54s iHo UI HyWy Xcj cm X O Xz CL | CO a > X44c0Bb0y4J Xy 44XCm44O *C3 wmH e3 S*4b<eyC33J0O oO' 4oesyt3n4 4byyu4 X4ey4 X4by0J X4(c0J 4byb6yyJ0 b0C 4wH4 eH 1sy044 4y4 X*4a>H4 bO c3 4o4 S4tbyCyoo3J o o 4I4Myo6CH440 X 44 X4cy4 4<<y40n Xy pVH aSyy Xyb60 o XTy6by0yH330 4cO4 p4H4 Xycn y X4H4 3 Xyy 0c Xy 44Xya44 Xo. XHy 9 oyyc ' xHbyy c0H0 3o pH b0 404 404 X4y4 4y4 cy SX6bynyHy30 4y4 4y4 y 434 X 4X40y443 yy 4o4 b X>yoy S3 bC0Hl X434 44yyacyH44n . 404 *4cyB44 4byy4 yc *bsbcyy3Hr >e4Hy4 44by44 4446ebO4440 eoB X4yJ X44 3 H4aB0yyycy4. cH X4eyy4 y ^4cOa44. ^X0yyyy0yH4 40byycy4 X4y4 4y4 PL0a-L* 4yy0b4 3 by>yy6eHH0 X4y4 X4H4 Hc0yQSyn. 4oeHJ byyoL 3 6e0 XsH i-y4 aey0 X6by0 y X4H4 3 HXy5ys 3 4VbOo4 cos Xy prXHy0H eyv "i"Ha. 6s0 o SO X4ey4 00y Xy 4cO4 t--i X0y 6yc0 9Xos -r>yo4 *o00Ho HXy Xy>0y cH <Syyyo04HH34. 4eoH4 iHyoy X4y4 4y4 .4eyyX4 con fbH4 <O. XX4b6O340 a* XaybyByy con Xzb>yByo XX46ob340 Xy5s oy 0y sUycyo44 cyo SIHy3 0H 0H 4by4 2cH ybs c3n -- 1|CM| A . EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS cm cn . us < 4-29 I* 2(b) . EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS fo llo w in g lo c a tlo n (s ): a t the nearest a cce ssib le p o in t a fte r fin a l treatm ent but p rio r to a c tu a l discharge o r m ixing w ith the re c e iv in g w aters. o rO' o o vr o x-- C/5 <44 0d 2 oo bC v Om Om Hcc ABD00315349 u so 3 X <sgJ 5 o 3 oc <30 .2 44 4a4 a> X 4 4kV4t - O' O' -- uSQ 4_i m-- C/5 X 3c O3 fc4 <0 u XV 44 CO X3 c 00 3c 00 H a2C F-t Oo0 cw w CO 44 c <I3 C xo CO O' oZ C" -o O' o >cq c*j s oo a~ ai "i a 33 Oc *3 *c u 35 M "<3 (M 3 O O " a 44 ou> Q. V) n w V o. V X >t -<au o eo S a cco 3a> 44 <0 4> f (9 X o .2 3 wLI 3 CO at UJ S jj z m < a. <t6!) *(S c tfl CO O u x a. x x x co co 6 <0 CO <0 C kt O kt 14 >- m o u o cj o X XXXXX oc co co co XXXX pvl fN CN -H -- --< oo ec oo oo <n 8 S S E 1 O' I O O O eM m niNCM-O p* 00 00 00 00 abse NOOlflN zo ---- oo till till 1 111 1111 3 3 H f4 * Q Obu o c/5 C3O 2S 3 r4 o 2o 0t CO 3 4o4 * H C0O1 > at at H fH 06 3 >- O. ^ 33 3 k 44 * 3 B o at ^ -5 3 u C/5 3 H H c H at **4 e -- kt > a3 o a 0 So BS au OX c p-4 H X U. H H u N u 3 01 3 H 0/ 0) CL i- oi 6 u oi co at x co ^ 44 IW CO 00 C *3 01 1H 0) X C 00 H k* f4 0*4 iJ X 1-t eu3 O 00 0 1-14-1 u c co at H tf 9 co e h <H *4 U ui at <4- at x at u a o at S 4J X 4J aut 4J o c at at at X i"X 3X 3 3 TO at o o c uat n u <o co at u a. CO *3 ecu i-t m 8 0(0) W0) 4J o 4J 0) X CO X u b *j c n oo 1*4 >> F0lt 3Cu fH O 3 C X *3 o ue *3 o at at x 44 3 3 rt e 44 B3 at f4 U X at *3 44 f4 e 3 p4 33 3 X 3 00 3 at e u at o f4 e 44 O Ft 3 H o u e c ot o o o f4 H B at X 44 X ot H at 44 3 X <44 3 0o3 44 fH e at 3 3 o c X at 14 H co 3 44 k*. 3 co O co 1> to V CBH pxU* V4J J4 >4 0t B 44 3 3 3 at 44 U 44 *3 c 3C at a e at B 44 X at at 3 44 fH 3 p-4 at ot pH U Xo o H a*- X 3 Ot O 0 4J H C o 6 at X fH 3 X CO *3 e 3 CO 44 i4 e 3 3 t4 3 3 C 3 44 3 o . O' c 3 X 44 uV 44 COu0O0t 0 e 3 44 H c 3 3 U 3 3 e 3 44 3 . O at F4 X a. B e3 33 X 44 X 3 3 kt 3 00 at fH 3 Ot X X 44 H o ex O 38 X 3 14 at Z CL a. at at o Xc Ho at X 3 44 X0c) c CO 3 0 B at 3X at o U3 CO X 44 CO e 0t 3 X >0 44 X CO M at X 301 44 0 c H a0)t a B CO 3 > O* at uu 0 00 3c 3 i4 Ft kt f4 o 0 44 3 l4 e 00 o Cs H 44 at 3X O 44 f4 <44 X 44 <44 03 at at 00 Oi |4 e 33 X ot f4 3 CL. s 3 o 0c 01 Xe at XX f-4 CO 3u X 3 (0 at at fH t4 a at B X H CQ C/5 <*> 4-30 l * 2(b) . EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1986 ce t r-* 9N o oo -<r wz z -9 -- u BO eC P3 cl. a4.) H02 co 1) ? o .S3 3 O' vNoco 3ea M uo 3 a. 4) X on ON <n _o xu "X3) M a ~ *4 3 3u oo eo ax <0 g) _ 0) ew 5 0 3 cu 3 c X oe on' za.oo 00 cS ^ 11 C/1 3 V 4> * i a. o 5 > x 2 o o E i a 2 o 2 0c "s5-*c3 4> M 5^ 00s 1c*23 QO a< ABD00315350 X 3 0 4) 3 C (0 44 X tn to cU wO XX 44 44 ce oo .z ac CH <N1 /--s irt J1 wo U-> *o 11 11 11 11 11 11 Qfe u1^w0 Z >3 u o 3 <^**44 4* 3 2u 3 5%1 A0B)* U* H T3 0) Ll O 44 H C Q S 3 X pH pH <0 X CQ CO 44 a c c3 (0 O s 00 <0 44 p< 01 Ca 3 <Q *o uM M 3c 3 3 eX (Q 44 u 00 Ll o 01 Xu ON o c ca X u u 3 u 3 0) U 00 M O c 00 4J e 3 3 l* CO *3 C 3 44 CO ou p-t X Q. a C3 3a X 44 X 3 a In 3 00 01 pH a a) x X 44 H 44 5 o ex u PH e pH O 3 X a in Hi sc a a 3 0) u Xc HO c H s 3 O <4H 0) X H a > U o (0 3 H 'pH 0 a oo c H 4-1 oa pH 41H <M 0 01 00 u 3 X o 3 ^4 *3 O a 3 X pH pH 3 X 3 3U 3 X H co c H 3 O pH pH 0 <4-1 IH 0 3 X3 44 00 U 44 3 3X U ea 3 iH X *3 3 4J pH 3 39 X 44 a pH 3 pH 3O X 44 a u 3O > *H OM xa 3 44 3 9 3X H 4M 44 H C a3 38 CL 44 33 3 3 H 44 44 e 3 pH S3 U3 e hH iH <44 9 3* M 33 U 44 <44 00 3 C H 44 ne 4O4 *oH H CL C O3 0 pH X 3 -H X3 44 3 3 X3 3 44 u >4 H 3 3 3 44 44 3 33 3 a3 C Li 33 H 3 pH 6 a 83 OX 3 44 C 44 00 e M > H 3 3 3 U hH 3 3 X C 44 3 XX 3 3 44 44 W p4 c3 3O 3 hH 00 epH 44 a 3 hH S 3 3 0 Xin 8C/2 pH 4 CM m 4-31 A I* 2(a) ABD00315351 PART I Page 5 of 14 Permit No. MS0001970 A B. SCHEDULE OF COMPLIANCE 1. The permittee shall achieve compliance with the effluent limitations specified for discharge in accordance with the following schedule: 2. No later than 10 calendar days following a date identified in the above schedule of com pliance, the permittee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncom pliance. In the latter case, the notice shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement. 4-32 ABD00315352 A PARTI Page 6 of 14 Permit No. MS000I970 B. MONITORING AND REPORTING 1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. 2. Reporting Monitoring results obtained during the month shall be summarized and reported on a Discharge Monitoring Report Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following the completed reporting month. The first report is due on July 28. 1986. Copies of these, and all other reports required herein, shall be signed in accor dance with Section 6 and 7 of the Mississippi Wastewater Permit Regulations, and shall be submitted to the Mississippi Natural Resources Permit Board at the following address: MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES* BUREAU OF POLLUTION CONTROL P. O. Box 10385 Jackson, Mississippi 39209 3. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304(h) of the Federal Water Pollution Control Act, as amended. 4. Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: a. The exact place, date, and time of sampling; b. The dates the analyses were performed; c. The penon(s) who performed the analyses; d. The analytical techniques or methods used; and e. The results of all required analyses. 5. Records Retention a. All records and information resulting from the monitoring activities required by this permit (including all records of: analyses performed; calibration and main tenance of instrumentation; and recording from continuous monitoring instru mentation) shall be retained for a minimum of three (3) yean, or longer if re quested by the Permit Board. 4-33 ABD00315353 A PARTI Page 7 of 14 Permit No. MS000I970 b. The permittee thill furnish to the Permit Board, upon request, copies of records required to be kept by this permit 6. Definitions a. The "monthly avenge** (applicable to municipal and domestic permits), other than for fecal cohform bacteria, is the arithmetic mean of all samples collected in a one-month period. The monthly average for fecal cohform bacteria is the geometric mean of ah samples collected in a one-month period. In computing the geometric mean, one (1) shall be substituted for sample results of zero. b. The "weekly avenge** (applicable to municipal permits), other than for fecal conform bacteria, is the arithmetic mean of all the samples collected during a one-week period. The weekly average for fecal cohform bacteria is the geomet ric mean of all samples collected during s one-week period. In computing the geometric mean, one (1) shall be substituted for sample results of zero. For self-monitoring purposes the value to be reported is the single highest weekly svetage computed during s one-month period. c. The "daily average** (applicable to industrial permits), other than for fecal con form bacteria, is the arithmetic mean of ah samples collected in a one-month period. The daily average for fecal cohform bacteria is the geometric mean of an samples collected in a one-month period. In computing the geometric the value one (1) shah be substituted for sample results of zero. d. The "daily maximum** (applicable to industrial and domestic permits), is the highest value recorded of any sample collected on any single day of the calendar month. 4-34 ABD00315354 A PART II Page 8 of 14 Permit No. MS000197 PART II A. MANAGEMENT REQUIREMENTS 1. Change in Discharge r^.._ All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute a violation of the per mit. Any anticipated facility expansions or treatment modifications which will re sult in new, different, or increased discharges of pollutants must be reported by sub mission of a new NPDES application. If such changes will not violate the effluent limitations specified in this permit, and upon written notice (in lieu of a new NPDES application) to the Mississippi Natural Resources Permit Board, the permit may be modified to specify and limit any pollutants not previously limited. 2. Noncompliance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any provision specified in this permit, the permittee shall notify the Mississippi Pollution Control Permit Board orally within 24 hours of becoming aware of such conditions. A written report shall also be provided within five (S) days of such time and shall contain the following information: a. A description of the discharge and cause of noncompliance; and b. The period of noncompliance, including exact dates and times; or if not cor rected, the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, eliminate and prevent recurrence of the noncomply ing discharge. 3. Facilities Operation The permittee shall at all times maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. 4. Adverse Impact The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment 5. Bypassing Any divenian from or bypass of wastewater collection and treatment facilities is prohibited, except (i) where unavoidable to prevent loss of life or severe property damage, or (ii) where excessive storm drainage or runoff would damage any facili ties necessary for compliance with the effluent limitations and prohibitions of this permit 4-35 wr>f i ABD00315355 PART II Page 9 of 14 Permit No. MS0001970 The permittee shill notify the Natural Resources Permit Board orally of each such diversion or bypass within 24 hours of the diversion or bypass, or if the need for the bypass is known in advance, it shall submit prior notice, if possible, at least ten (10) days before the date of the bypass. 6. Removed Substances Solids, sludges, filter backwash, or other residuals removed in the course of treatment or control of wastewaters shall be disposed ofin a manner such as to prevent such materials from entering State waters and in a manner consistent with the Missis sippi Solid Waste Disposal Act and the Federal Resource Conservation and Recovery Act 7. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either: a. In accordance with the Schedule of Compliance contained in Part I, provide an alternate power source sufficient to operate the wastewater collection and treat ment facilities, or, if such alternate power source is not in existence, and no date for its implementation appears in Pan I; b. Provide a method whereby the effluent limitations contained in Pan I shall be met upon the reduction, loss, or failure of the primary source of power to the wastewater collection and treatment facilities. B. RESPONSIBILITIES 1. Right of Entry The permittee shall allow the Mississippi Natural Resources Permit Board and the Regional Administrator of the U.S. Environmental Protection Agency and/or their authorized representatives, upon the presentation of credentials. a. To enter upon the permittee's premises where an effluent source is located or in which any records are required to be kept under the terms and conditions of this permit; and b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equip ment or monitoring method required in this permit; and to sample any discharge of pollutants. 2. Transfer of Ownership or Control This permit is not transferable to any person except after proper notice. In the event of any change in control or ownership of facilities from which the authorized discharges emanate, the permittee shall notify the Mississippi Natural Resources 4-36 ABD00315356 PART II Page 10 of 14 Permit No. MSO0OI97O Permit Board at least thirty (30) days in advance of the proposed transfer date. The notice should include a written agreement between the existing and new permittees containing a specific date for the transfer of permit responsibility, coverage, and lia bility. 3. Availability of Records Except for data determined to be confidential under the Missisrippi Water Pollution Control Law, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the office of the Mississippi Department of Natural Resources Bureau of Pollution Control. 4. Permit Modification a. The permittee shall furnish to the Permit Board within a reasonable any relevant information which the Permit Board may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. b. Upon sufficient cause this permit may be modified, revoked, reissued, or termi nated during its term. c. The filing of a request by the permittee for a permit modification, or a notifi cation of planned changes or anticipated noncompliance, does not stay any permit condition. 5. Toxic Pollutants The permittee shall comply with any toxic effluent standard or prohibition (in cluding any schedule of compliance specified in such effluent standard or prohi bition) established under Section 307(a) of the Federal Water Pollution Control Act 6. Civil and Criminal Liability a. Any person who violates a term, condition or schedule of compliance contained within this permit or the Mississippi Water Pollution Control Law is subject to the actions defined by law. b. Except as provided in permit conditions on "Bypassing" (Part II, A-5), nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. c. It shall not be the defense of the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. 7. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties 4-37 MDI-5 ABD00315357 A PART II Page 11 of 14 Permit No MS0001970 to which the permittee is or may be subject to under Section 311 of the Federal Water Pollution Control Act and applicable provisions of the Mississippi Water Pollu tion Control Law pertaining to spills of oil and hazardous materials. 8. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State, or local laws or regulations. 9. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstance, and the remainder of this permit, shall not be affected thereby. 10. Expiration of Permit The permittee shall not discharge after th6 expiration date of this permit unless he has submitted a completed application for reissuance no later than 180 days prior to the expiration date. The Executive Director may grant permission to submit an application later than this, but no later than the expiration date of the permit. ABD00315358 PART III PART III Page 12 of 14 l Permit No. MS0001970 A. REOPENER CLAUSE This permit shall be modified, or alternatively, revoked and reissued, to comply with any appllccble effluent standard or limitation issued or approved tinder Section 301(b) (2) (C), and (D), 304(b)(2), and 307(a)(2) of the Federal Water Pollution Control Act If the effluent standard or limitation so Issued or approved: 1. Contains different coudltlons or Is otherwise more stringent than any effluent limitation in the permit; or 2. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable. B. TOXIC POLLUTANTS NOTIFICATION REQUIREMENTS The permittee shall comply with the applicable provisions of 40 CFR 122.42. C. CLOSURE REQU1 arlUviJiNTS Should the permittee decide to permanently close and abandon the premises upon which it operates, it shall so notify the Permit Board no later than * 90 days prior to doing so. Accompanying this notification shall be a closure plan which describes how and when all manufactured products, by* products, raw materials, stored chemicals, and solid and liquid wastes will be removed from the premises such that they will present no potential environmental hazard to the area. Abandonment of the site without providing proper notification as required herein, or without completing all aspects of the closure plan, will constitute a violation of this permit and may result in penalties of up to $25,000. 4-39 ABD00315359 PART III ?age 13 of 14 Permit No. MS0001970 cA D. BIOSSAI REQUIREMENTS The Water Quality Standards of Mississippi require that all waters be free from substances in concentrations or combinations which are harmful to humans, animals, or aquatic life (State of Mississippi, Water Quality Criteria for intrastate. Interstate and Coastal Waters. Section II.4. Minimum Conditions Applicable to All Waters, page 3, adopted November 12, 1974). In accordance with such requirements, the permittee is authorised to discharge from outfall(s) 001 (process Wastewater) only in accordance with the following conditions: 1. The permittee shall submit any existing toxicity data for review by Mississippi Bureau of Pollution Control within 30 days of the effective date of this permit. .2 The permittee shall initiate the following series of tests within 60 days of the effective date of issuance of the permit to evaluate wastewater toxicity. The permittee shall conduct a 7-day Ceriodaphn-ta survival and reproduction test, and Plmephales promelas (fathead minnows') larval survival and growth teat (or use the embryo-larval survival and teratogenesls test) on different concentrations of effluent to determine if the discharge from outfall 001 is chronically toxic. Such testing will determine if the water affects the' survival and reproduction of the test * organisms. Such testing will be conducted using 24-hour composite samples of effluent collected daily. Chronic toxicity will be demonstrated if: l) there is a 20% or more difference in survival between test organisms exposed to appropriate control water and any serial dilution of the effluent; or 2) there is a statistically significant difference at the 35% confidence level in reproduction between Ceriodaphnia exposed to an appro priate control water and any serial dilution of the effluent. Dilution water should be taken from the receiving water at a point as close as possible to the outfall, but upstream from the sone influenced by the effluent. When the receiving stream has no flow, a substitute dilution water must have a total hardness, total alkalinity, and specific con ductance within 25 percent, and pH within 0.2 units, of the receiving water. 3 a. Such chronic toxicity tests shall be conducted once/quarter (with organism type being alternatively used) for a period of one year following the effective date of the permit. After the first year of testing, fre quency of monitoring will be reduced to 1 /6 months for the life of the permit. The first 6 month test will evaluate Ceriodaphnia according to the testing requirements in B. 2. The second 6 month test will evaluate Pimephalea promelas (fathead minnows) according to the testing require ments in B.2. These organisms will be alternatively tested every six 6 months. If any one test during this period indicates the presence of chronic toxicity, then another confirmatory chronic toxicity test will be conducted within 2 weeks* If this confirmatory test indicates the presence of chronic toxicity, then the provisions of Section 3(b) shall apply. If no chronic toxicity is indicated in this confirmatory test, then the pro visions of Section 3(b) will not apply. The results of each toxicity test shall be submitted to Mississippi Bureau of Pollution Control within 2 weeks of completion of testing. 4-40 ABD00315360 Page 14 of 14 Permit No. MS0001970 b. If the presence of chronic toxicity is confirmed, this will constitute a violation of Part I of this permit. The permittee will then be subject to the provisions of the Section 5. 4. All quality assurance criteria used shall be in accordance with short-term Methods for Estimating the Chronic Toxicity of Elluents to Freshwater Organisms, EPA-600/4-85. All test organisms and procedures used shall be in accordance with Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms, Section 12; Ceriodaphnla Survival and Reproduction Test Method 702.0. 5. In the event that after review of the above studies, the Mississippi Natural Resources Permit Board determines the waste stream is toxic to the receiving stream , the permittee shall: A. Provide plans and specifications to reduce the toxicity of the waste discharge to safe levels. (Safe levels will be determined by the Mississippi Natural Resources Permit Board). B. Develop a schedule for implementing this plan. 1 In large rivers, lakes and estuaries the permittee mist provide a schematic map showing isopletha of waste concentrations. 4-41 ABD00315361 VCM EMISSIONS ABD00315362 A IV. PERMITS D. Historical Emissions of VCM Attached is a history of VCM NESHAP's enforcement at the Aberdeen plant. The plant is no longer under a compliance plan and hasn't had a release of VCM since 1986. We are presently reviewing the need for Compliance Plan refresher training. The second attachment is a copy of the SARA 313 Emissions for all PVC plants in the United States. They are listed alphabetically, by stack emissions, by fugitive emissions and total emissions. The third attachment is a list of all the SARA 313 Emissions from the Aberdeen plant. 4-42 ABD00315363 HISTORY OF VCM NESHAP'S ENFORCEMENT Oct. 20, 1976 Jan. 19, 1977 Feb. 2, 1979 Jan. 19, 1980 Apr. 3, 1980 Apr. 7, 1980 Sept. 16, 1981 Oct. 16, 1981 Nov. 5, 1981 Jan. 11, 1982 June 10, 1982 Jan. 13, 1983 Dec. 18, 1983 VCM Neshap's Promulgated VCM Neshap's Becomes Effective RVD 25,500 lbs. RVD 24 lbs. RVD 180 lbs. RVD 36 lbs. RVD 20 lbs. RVD 357 lbs. RVD 89 lbs. RVD 3-7 lbs. RVD 57 lbs. RVD Manual Vent 222 lbs. 229 lbs. D-300 D-400 D-9 D-9 Charge filter T-201 Charge filter Recovere m o no me condenser Recovere mo nome condenser D-745 ? Feb. 1, 1984 After July 20, 1984 Aug. 19, 1985 Sept. 16, 1985 Oct. 25, 1985 Nov. 14, 1985 Dec. 31, 1985 Conoco Sued by DOJ on behalf of EPA July voluntarily becomes a party to the suit. Vista & Conoco agree to settle out of court. $100,000 penalty Agree to submit a compliance plan. Compliance plan submitted to EPA. Suggest 3 projects plus administrative; asks for R0L equivalency EPA asks for more information Vista sends more information EPA tentatively approved plan; they do not approve ROL equivalencies. -1- 4-43 ABD00315364 Mar. 27, 1986 Apr. 1, 1986 Apr. 3, 1986 Dec. 23, 1986 July 27, 1986 Aug. 8, 1986 Mar. 11, 1987 Apr. 14, 1987 Aug. 6, 1987 Nov. 7, 1987 EPA approves ROL equivalency. AFE for projects submitted. $107,500 1. Reactor valve limit switches 2. Water Stripper T/P recorder 3. New module BD Tank level indicator Conoco EPA Appvoves compliance plan. Three projects complete. VCM release VCM release MS Bureau of Pollution Control issues complaint releases Vista settles with the State for $2,000. Termination filed on the consent decree. Case closed. 2- - 4-4 4 ABD00315365 X vcnmissions/* us. producti io FU6IIIVC STICK OTHER TOTIL SoipMion | f i i o A Total FUSITIVE STICK OHO TOTH vcbwsstONS as.> isi? eveWfccm, w us. 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Lot oo* ZD >z M5Oz1--cS 1 o p0XH0 PRODUCT INITIATED CONCLUDED 1/79 11/80 12/84 7/82 3/80 6/82 4/85 1 ^| | 10/78 10/78 11/79 3/80 PA 12/83 5/85 ) -- DECLINED BY EP VC 11/84 VC 3/82 I 10/83 PVC 8/89 ABD00315375 TOTAL 22 64 45 ABD0034S376 rH r*v ro CM (-V. rH CO o iH CM CM rH CM r- fL rH o- o- to LO orH CM 0ro0 ** Q H CM 31 h- O * * * CM H > pH CM CM at A STATE NESHAP PENJVlES ( in USA) O > o: >C LU 1-- >z O LU o> OC < Q h-- tO 1-- vO < 2 O Cu M to Hto LlJ cc CM CO CO rH LO rH CO to LlJ to o CM CM z c o X LU H b~ to CO __1 H __I CO a: to to LU LU rH at H to z Z CO ro rH r =r Qa LU O XX LU rH rH H- t-- to to < CO Lf) CM o pH _l CM rH CM c -J CO o r^i o Q Lf) Lf) oooooO o o o o oO rs. oo * in * ir> V r. iH r-s. rH CM in CO rH pH to to- to to- to to o o o o o o o o o o LO o o O o o o o o o o o o o CM o o o o o CJ> o o o o Lf) LO rH o if) o o Lf> CM Lf) to o rH CM to Lf) pH CO pH CM rH o CM co to Lf) to- to- to- to to to to to to to to to to to tO to Ml O o CO UJ cC o a. o to Lf) rH co to P-. CO \ 00 to r-. CO r*- to r*-. r- to CO 00 co 00 CO 1 CO i 1 i 1 rs. pH 00 co CO CO CO CO C0 CO CO CO CO CO CO CM co to CO CO CO 00 CO 00 CO > >o Q_ a. > o 5 >> > > CL O. CL > o_ CL r -J u. >- < < < to to X s h- X f-- r Q_ rH CM CO Lf> to r- CO a> H H pH LO o z I--E to Of t-M < * ABD00315377 AIR PERMITTING PROCESS ABD00315378 It , . U To: Environmental Coordinators A Interoffice Communication From: Dote: Subject: David Cohen May 20, 1988 AIR PERMITTING PROCESS Please note the following clarification of my May 11, 1988 memo concerning the air permitting process: Sources subject to National Emissions Standards for Equipment Leaks (NESEL), a subpart of the NESHAPs rules, need not also comply with NSPS requirements. (See 40 CFR 61.240(c)). In order to be subject to NESEL, a source must be intended for operation in volatile hazardous air pollutant (VHAP) service. Subject sources include pumps, compressors, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, flanges and other connectors, product accumulator vessels and control devices or systems. "Product accumulator vessel" is defined as any distillate receiver, bottoms receiver, surge control vessel, or product separator in VHAP service that is vented to the atmosphere. A product accumulator vessel is considered to be in VHAP service if the liquid or vapor in the vessel is at least 10% by weight VHAP. VHAPs include benzene and vinyl chloride. As a result of this rule, a valve regulated by a NESEL obviously must comply with the NESEL, but is exempt from any otherwise applicable NSPS. Thus, modification or reconstruction of such equipment may be accomplished without going through the NSPS procedure. Of course, any equipment not regulated by a NESEL is not eligible for this exemption. In addition, please be aware that EPA recently issued a policy memo stating that in reviewing PSD permit applications, the Agency will place the burden on the applicant to justify use of control technology which will not achieve LAER (lowest achievable emissions rate). The two allowable justifications for higher emissions rates than LAER will be technical feasibility and cost. Unless an applicant can justify to EPA such higher emissions rates, LAER will be required. \ ... j4r 4SO 1 IU WIICII y /bi V. 52.die 4-57 y/zfii ABD00315379 Environmental Coordinators Interoffice Communication From: Date: Subject: David Cohen May 11, 1988 AIR PERMITTING PROCESS: PSD AND NSPS OVERVIEW Introduction This memo discusses the basic elements of the PSD and NSPS programs. More specifically, it describes the process of obtaining a PSD permit, and indicates various things to consider when modifying or expanding plant operations. Please bear in mind that this memo describes federal programs. State programs may differ slightly. Also remember that the following is merely a summary of the PSD and NSPS programs. You must carefully read the actual regulations prior to taking any action that may be regulated under these programs. Pursuant to the Clean Air Act, the EPA has established National Ambient Air Quality Standards ("NAAQS") for each criteria pollutant. "Criteria pollutants'' include sulfur oxides, carbon monoxide, total suspended particulates, nitrogen dioxide, photochemical oxidants and lead. Each state is divided into air quality regions, and each region is placed in one of two categories -- attainment or non-attainment -- for each criteria pollutant. An "attainment" area for a particular pollutant is an area in which the ambient air quality meets the NAAQS for that pollutant. A "non-attainment area" for a particular pollutant is an area in which the ambient air quality does not meet the NAAQS for that pollutant. It is important to note that a region can be an attainment area for one pollutant and a non-attainment area for a different pollutant. In order to ensure that ambient air quality remains below NAAQS in attainment areas and meets NAAQS In non-attainment areas, the Clean Air Act ("the Act") requires that states promulgate State Implementation Plans ("SIPs"). The SIPs contain pre-construction review procedures for major new sources of air pollution. Additionally, EPA has adopted technology-based New Source Performance Standards ("NSPS"), which set emissions limits on certain new or modified facilities. PSD Issues Each SIP contains Prevention of Significant Deterioration ("PSD") requirements. These requirements apply in attainment areas, as well as in areas that are unclassifiable with respect to the NAAQS. They set maximum allowable increases in ambient air pollutant concentration levels ("increments") for certain 4-58 ABD00315380 A Environmental Coordinators May 11, 1988 Page 2 pollutants, and are designed to ensure that the air quality in attainment areas remains below the NAAQS for those areas. Thus, PSD permits allow facilities to increase the concentration of a specific pollutant, in an area that meets the NAAQS for that pollutant, by a set amount -- a portion of the area's increment. % The size of the increment for each area depends on the area's classification. The PSO regulations establish 3 separate classes for air pollution control regions. Class I areas include such things as large national parks and wildlife areas, and allow only minimal increases in pollutant concentration over baseline concentrations. Class II areas provide for larger maximum allowable increases, and Class III areas provide the largest maximum allowable increases. All Vista plants are located in class II areas for all pollutants they emit. PSO permit requirements apply only to major stationary sources and major modifications of stationary sources. "Major stationary sources" are defined as stationary sources, including chemical process plants, which emit, or have the potential to emit, 100 tons or more per year of any pollutant subject to regulation under the Act. Thus, unlike the NAAQS program, the PSD program does not make its category determinations on a pollutant- specific basis. In other words, if a plant is a major stationary source because of a single pollutant, it is a major stationary source under the PSD program. Fugitive emissions from chemical process plants must be included in determining whether a stationary source is major. 4|HBrthat any physical change that occurs at a non-major stationary source will not make the source major unless the change would by itself constitute a major source, i.e., emit, or have the potential to emit, 100 tons or more per year of a regulated pollutant. For example, a source that emits 90 tons per year of SOg is not major. If the source implemented a modification that increased SO2 emissions by 90 tons per year, the modification would not be major, modification " t&omp$ete and the vSource Mrits-iaQtons peryear, it wiVV be considered major for all,.jutufe^calculations. r A "major modification" is any physical change in, or change in the method of operation of, a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act. A "physical change or change in the method of operation" does noi mean routine maintenance, repair or replacement of equipment, various uses of new fuels as specified at 40 CFR 52.21(b)(2)(iii)(b)-(e), increased hours of operation, increased rate of production (unless such increase would be prohibited under a federally enforceable PSD permit) or changes in ownership. A "significant" emissions increase is defined as a rate of emissions equal to or greater than the following: 4-59 ABD00315381 A Environmental Coordinators May 11, 1988 Page 3 Pollutant and Emissions Rate Carbon Monoxide: 100 tons per year (tpy) Nitrogen oxides: 40 tpy Sulfur dioxide: 40 tpy Particulate matter: 25 tpy of particulate matter emissions; 15 tpy of PM10 emissions Ozone: 40 tpy of volatile organic compounds Lead: 0.6 tpy Asbestos: 0.007 tpy Beryllium: 0.0004 tpy Mercury: 0.1 tpy Vinyl chloride: 1 tpyf Fluorides: 3 tpy Sulfuric acid mist: 7 tpy Hydrogen sulfide (H2S): 10 tpy Total reduced sulfur (including H2S): 10 tpy Reduced sulfur compounds (including H2S): 10 tpy Several exemptions to the PSO rules exist for older facilities (see 40 CFR 52.21(i)(4) and (7)). The requirement of conducting impact and air quality analyses as they relate to any maximum allowable increase for a class II area does not apply to any major modification of a stationary source that was in existence on March 1, 1978, if the net Increase in allowable emissions of each pollutant subject to regulation under the Act from the modification after the application of best available control technology would be less than 50 tons per year. In addition, the Administrator may, at his discretion, exempt facilities that submit complete permit applications by June 1, 1988 from various pre-application air quality monitoring requirements. Also, the Administrator may exempt a stationary source or modification from pre-application air quality monitoring requirements for a specific pollutant if the emissions increase of the pollutant from the new source or the net emissions increase of the pollutant from the modification would cause in any area air quality impacts less than the following amounts: Carbon monoxide - 575 ug/m3, 8-hour average; Nitrogen dioxide - 14 ug/m3, annual average; Particulate matter: 10 ug/m3 of TSP, 24-hour average; 10 ug/m3 of PM10, 24-hour average; Sulfur dioxide - 13 ug/m3, 24-hour average; Ozone; Lead - 0.1 ug/m3, 3-month average; Mercury - 0.25 ug/m3, 24-hour average; Beryllium - 0.002 ug/m3, 24-hour average; Fluorides - 0.25 ug/m3, 24-hour average; 4-60 ABD00315382 A Environmental Coordinators May 11, 1988 Page 4 Vinyl chloride - 15 ug/m3, 24-hour average; Total reduced sulfur - 10 ug/m3, 1-hour average; Hydrogen sulfide - 0.2 ug/m3, 1-hour average; Reduced sulfur compounds - 10 ug/m3, 1-hour average; The administrator may also make such an exemption if the concentrations of the pollutant in the area that the source or modification would affect are less than these concentrations, or the pollutant is not listed on this list. The PSD permit regulations contain five major categories of requirements. Under the first category, "control technology review", major stationary sources and major modifications must meet all applicable emissions limitations under the SIP, as well as all performance standards required by NSPS or NESHAPS. In addition, each new major stationary source must apply the best available control technology ("BACT") for each pollutant subject to regulation under the Act that it would have the potential to emit in significant amounts. Similarly, major modifications must apply BACT for each pollutant subject to regulation under the Act for which the modification would result in a significant emissions increase at the source. Note that throughout the PSD rules, when calculating the total emissions from a source undergoing a major modification, facilities are allowed to "net out" their emissions, i.e., subtract the total decrease from thetotal increase. Recognize, also, that once the requirement to use BACT is triggered, it applies to each proposed "emissions unit" (any part of a stationary source with the potential to emit any pollutant regulated under the Act) at which a significant net emissions increase in the triggering pollutant would occur as a result of the modification. Be aware also that for phased construction projects BACT determinations must be periodically reviewed and, where appropriate, modified. The second major category of requirements under the PSD permit regulations is "source impact analysis." These regulations require the owner/operator of the proposed new source or modification to demonstrate that the proposed Increase in emissions will not cause or contribute to air pollution in violation of any NAAQS in any air quality control region or any applicable maximum allowable increase over the baseline concentration in any area. The third category is "air quality modeling." This section requires that all estimates of ambient air concentrations be based on the applicable air quality models, data bases and other requirements specified In EPA's modeling guidelines. These models may be modified, or other models may be substituted, only after notice and opportunity for comment by the public, and written approval by the Administrator. 4-61 ABD00315383 Environmental Coordinators May 11, 1988 Page 5 The fourth category Is "air quality analysis." PSD permit applications must contain an analysis of ambient air quality for each pollutant that a new source might emit in a significant amount or for which a modification would result in a significant net increase. In addition, the analyses must include at least a year of continuous pre-application monitoring for such pollutants. Post-construction monitoring as EPA or the state deems necessary may also be required. The last category is "source information." These regulations require the PSD permit applicant to submit, at a minimum, information on the nature, location, design capacity and typical operating schedule of the source or modification, a construction schedule and various technical information needed to determine which 8ACT is appropriate. The application must also include an analysis of impairment to visibility, soils and vegetation in the area that would result from the new source or modification. NSPS Issues Separate and apart from the PSD permitting process are the New Source Performance Standards ("NSPS"). NSPS are set out at 40 CFR Part 60, Subparts D through PPP, and specify which processes and types of equipment they cover (see Appendix). These standards are applicable to owners/operators of any stationary source that contains an affected facility, the construction or modification of which is commenced after the date of publication of any proposed NSPS applicable to that facility. Sources subject to National Emission Standards for Hazardous Air Pollutants ("NESHAPs") must also comply with any and all applicable NESHAPs. An "affected facility" is any apparatus to which a standard is applicable. "Modification" is defined as any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted. The following are ng considered modifications: 1. routine maintenance, repair and replacement; 2. increased production that can be accomplished without capital expenditure (Note: "capital expenditure" means an expenditure for a physical or operational change to an existing facility which exceeds the product of the applicable "annual asset guideline repair allowance percentage" specified in the latest addition of IRS publication 534 and the facility's existing basis, as 4-62 ABD00315384 Environmental Coordinators May 11, 1988 Page 6 defined in section 1012 of the Internal Revenue Code. The total expenditure for a physical or operational change to an existing facility may not be reduced for any "excluded additions1' as defined in IRS publication 534. For obvious reasons, I recommend that anybody who believes his plant might be eligible for this exemption work with the Tax, Environmental and Legal Departments to determine whether the exemption applies); 3. increased hours of operation; 4. certain changes in type of fuel or raw material used; 5. addition of a system or device whose primary function is to reduce air pollutants, unless the new device or system is less environmentally beneficial than the one it replaces; 6. relocation or change in ownership of an existing facility. Facilities must achieve compliance with all applicable standards within 180 days of the completion of any modification that requires compliance with such standards. In addition to the foregoing, existing facilities must comply with NSPS upon undergoing reconstruction, regardless of whether such reconstruction effects any change in emissions. "Reconstruction" is defined as the replacement of components of an existing facility to such an extent that the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, and it is technically and economically feasible to meet the applicable standards set forth under NSPS. "Fixed capital cost" is defined as the capital needed to replace all the depreciable components. An owner/operator planning to replace components, where the fixed capital costs of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility must notify the Administrator of the proposed replacements 60 days (or as soon as practicable) before construction of the replacements commences. The notification must include various items specified at 40 CFR 60.15(d). Upon receipt of the notification, the Administrator has 30 days to determine whether the proposed replacement constitutes reconstruction. 4-63 ABD00315385 Environmental Coordinators May 11, 1988 Page 7 Owners/operators of facilities subject to NSPS standards must,notify the Administrator of the following things: 1. the date construction or reconstruction of an affected facility is commenced, within 30 days of the date of commencement; 2. the anticipated start-up date of an affected facility, not more than 60 days nor less than 30 days prior to such date; 3. the actual date of initial start-up of an affected facility within 15 days after such date; 4. any non-exempt physical or operational change that may increase emissions of any air pollutant to which a standard applies, within 60 days or as soon as practicable before the change is commenced; 5. the date upon which continuous monitoring system performance commences, not less than 30 days prior to such date; 6. the anticipated date for conducting opacity observations, and the type of test to be used, not less than 30 days prior to such date; In addition, owners/operators of facilities subject to NSPS standards must maintain extensive records regarding operations and monitoring at the facility (see 40 CFR 60.7(b), (c) and (d)). NSPS regulations also require affected facilities to conduct performance tests, as specified in 40 CFR 60.8, opacity observations as described in 40 CFR 60.11, and continuous monitoring, as specified at 40 CFR 60.13. As you can see, the PSD and NSPS programs are extremely complex. Accordingly, 1 urge you to scrutinize the regulations and consult with the Legal and Environmental Departments in Houston whenever you consider modifying or expanding plant operations. V. David Cohen /bi 32.die.1 4-64 ABD00315386 APggflHx The following is a list of standards of performance for new stationary sources (NSPSs): Subpart 0 - Subpart Da - Subpart Db Subpart E Subpart F Subpart G Subpart H Subpart I Subpart J Subpart K - Subpart Ka - Subpart Kb - Subpart L Subpart M - Standards of Performance for Fossil-Fuel Fired Steam Generators for Which Construction is Commenced After August 17, 1971 Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978 Standards of Performance for Industrial Commercial-Institutional Steam Generating Units Standards of Performance for Incinerators Standards of Performance for Portland Cement Plants Standards of Performance for Nitric Acid Plants Standards of Performance for Sulfuric Acid Plants Standards of Performance for Asphalt Concrete Plants Standards of Performance for Petroleum Refineries Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction Reconstruction, or Modification Commenced after July 23, 1984 Standards of Performance for Secondary Lead Smelters Standards of Performance for Secondary Brass and Bronze Production Plants 4-65 ABD00315387 Subpart N - Standards of Performance for Primary Emissions from Basic Oxygen Process Furnaces for Which Construction is Commenced After June 11, 1973 Subpart Na - Standards of Performance for Secondary Emissions from Basic Oxygen Process Steelmaking Facilities for Which Construction is Commenced After January 20, 1983 Subpart 0 - Standards of Performance for Sewage Treatment Plants Subpart P - Standards of Performance for Primary Copper Smelters Subpart Q - Standards of Performance for Primary Zinc Smelters Subpart R - Standards of Performance for Primary Lead Smelters Subpart S - Standards of Performance for Primary Aluminum Reduction Plants Subpart T - Standards of Performance for the Phosphate Fertilizer Industry: Wet-Process Phosphoric Acid Plants Subpart U - Standards of Performance for the Phosphate Fertilizer Industry: Superphosphoric Acid Plants Subpart V - Standards of Performance for the Phosphate Fertilizer Industry: Diammonium Phosphate Plants Subpart W - Standards of Performance for the Phosphate Fertilizer Industry: Triple Superphosphate Plants Subpart X Subpart Y - Standards of Performance for the Phosphate Fertilizer Industry: Granular Triple Superphosphate Storage Facilities Standards of Performance for Coal Preparation Plants Subpart Z - Standards of Performance for Ferroalloy Production Facilities Subpart AA - Standards of Performance for Steel Plants: Electric Arc Furnaces Constructed After October 21, 1974 and on or Before August 17, 1983 Subpart AAa - Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 7, 1983 ABD00315388 Subpart BB - Subpart cc - Subpart DD Subpart EE Subpart FF Subpart GG Subpart HH Subpart KK Subpart LL Subpart MM Subpart NN Subpart PP Subpart QQ Subpart RR Subpart SS Subpart TT Subpart UU 90fepart VV ` Subpart ww - Standards of Performance for Kraft Pulp Mills Standards of Performance for Glass Manufacturing Plants Standards of Performance to Grain Elevators Standards of Performance for Surface Coating of Metal Furniture Reserved Standards of Performance for Stationary Gas Turbines Standards of Performance for Lime Manufacturing Plants Standards of Performance for Lead-Acid Battery Manufacturing Plants Standards of Performance for Metallic Mineral Processing Plants Standards of Performance for Automobile and LightDuty Truck Surface Coating Operations Standards of Performance for Phosphate Rock Plants Standards of Performance for Ammonium Sulfate Manufacture Standards of Performance for the Graphic Arts Industry: Publication Rotogravure Printing Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations Standards of Performance for Industrial Surface Coating: Large Appliances Standards of Performance for Metal Coil Surface Coating Standards of Performance for Asphalt Processing and Asphalt Roofing Manufacture Standards^of Performance for Equipment Leaks ef VOC In the Synthetic Organic Chemicalv Manufacturing Industry Standards of Performance for the Beverage Can Surface Coating Industry 4-67 ABD00315389 A Subpart XX - Standards of Performance for Bulk Gasoline Terminals Subparts AAA- EEE Reserved Subpart FFF Standards of Performance for Flexible Vinyl and Urethane Coating and Printing Subpart GGG Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries Subpart HHH Standards of Performance for Synthetic Fiber Production Facilities Subpart III Reserved Subpart JJJ Standards of Performance for Petroleum Ory Cleaners Subpart KKK Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants Subpart LLL Standards of Performance for Onshore Natural Gas Processing; S02 Emissions Subparts MMM NNN Reserved Subpart OOO Standards of Performance for Nonmetal lie Mineral Processing Plants Subpart PPP Standard of Performance for Wool Fiberglass Insulation Manufacturing Plants 37.DLC.1 4-68 ABD00315390 A TO: R.W. SEYMOUR FROM: V.E. MESSICK DATE:APRIL 4, 1988 SUBJECT:PERMITS FOR DEBOTTLENECKING PROJECTS BELOW IS MY UNDERSTANDING OF PERMITTING REQUIREMENTS FOR DEBOTTLENECKING PROJECTS. WE NEED TO WORRY ABOUT THREE TYPES OF PERMITS. 1. NESHAP THIS IS TRIGGERED BY THE AMOUNT OF MONEY SPENT. IF WE EXCEED 12.5% OF THE BOOK VALUE OF THE ASSETS, A PERMIT IS REQUIRED FOR AN EXPANSION. THIS WOULD BE ABOUT $1.25MM. THIS APPLICATION IS SUBMITTED THE STATE. THEY MAY CONSULT REGION IV, BUT WLM THINKS TIMEFRAME IS TOO SHORT FOR THEM TO SUMBIT TO REGION IV FOR REVIEW. REGION IV HAS TYPICALLY ASKED SOME DETAILED QUESTIONS ABOUT EXPANSIONS IN THE PAST. 2. STATE PERMIT WE ARE PERMITTED FOR 455MM POUNDS PER YEAR. EMISSIONS ON PRODUCTION ABOVE THIS AMOUNT ARE NOT PERMITTED. HOWEVER, EARLIER IN THE YEAR, RAF HAD A CONVERSATION WITH BOBBY WHITAKER, OUR REPRESENTATIVE IN THE STATE DNR. BOBBY INDICATED GOING TO 465MM POUNDS PER YEAR WOULD NOT BE A PROBLEM SINCE NO CAPITAL PROJECT HAS BEEN INSTALLED. THE STATE DEFINES A NEW FACILITY TO INCLUDE "ANY EXISTING FACILITY MODIFIED OR RECONSTRUCTED... THAT EMITS DUST, FUMES, MIST, SMOKE, OTHER PARTICULATE MATTER, VAPOR, GAS OR ANY COMBINATION THEREOF FROM THE SAME PROCESS OR RELATED OPERATION." A NEW FACILITY REQUIRES A PERMIT. THE PERMIT APPLICATION MUST BEAR SIGNITURE AND REGISTRATION NUMBER OF THE PROFESSIONAL ENGINEER(REGISTERED IN THE STATE OF MISSISSIPPI) RESPONSIBLE FOR THE DESIGN OR REVIEW OF THE NEW FACILITY. AN APPLICATION FOR A PERMIT TO CONSTRUCT MUST BE SUBMITTED AND APPROVED PRIOR TO THE START OF ACTUAL CONSTRUCION OR INSTALLATION. 3. PSD PERMIT THE MAJOR ISSUES FOR DETERMINING IF A PROJECT NEEDS A PSD PERMIT ARE: A W A. IS THE FACILITY A MAJOR SOURCE? A FACILITY IS A MAJOR SOURCE IF IT EMITS MORE THAT 100 TONS PER YEAR OF ANY ONE POLLUTANT. WE HAVE CHECKED TWO THINGS--PARTICULATES AND NOX EMISSIONS. RAF AVERAGED 44 ROTARY DRYER DATA POINTS FROM WHEN WE USED TO STACK SAMPLE IN 1978-1980. THESE AVERAGED 7 POUNDS PER HOUR. THE VARIABILITY WAS LARGE. USING THIS DATA AND EMISSION DATA FROM THE FLUID BED DRYER, RAF CALCULATED PARTICULATE EMISSIONS OF 123 TONS PER YEAR. WE WILL HAVE TO ADD SILO AND BOILER PARTICULATESTO GET THE TOTAL. OUR ACTUAL EMISSIONS MAY BE LOWER THAN 123 TONS PERYEAR. WE SHOULD PROBABLY HIRE A CONTRACTOR TO STACK SAMPLE TO DETERMINE ACTUAL EMISSIONS. WLM STILL SAYS WE HAVE A PROBLEM BECAUSE PAGE 1 4-69 ABD00315391 A WE CAN LEGALLY EXCEED THE 100 TON PER YEAR NUMBER. HE THINKS WE WOULD HAVE TO BE LEGALLY BOUND TO LESS THAN 100 TONS PER YEAR. OUR PARTICULATE PERMIT LIMIT IS ABOUT 770 TONS PER YEAR. NOX EMISSIONS ARE ABOUT 45 TONS PER YEAR WITH PERMITTED EMISSIONS ABOUT 85 TONS PER YEAR. JCL AND WLM SAY THAT OKLAHOMA CITY IS NOT A MAJOR SOURCE, SO THEY DO NOT NEED A PSD PERMIT. THEY SAY THAT OKLAHOMA CITY IS GETTING A NESHAP AND A STATE PERMIT FOR THEIR CONDENSER PROJECT. B. THE NEXT ISSUE IS THAT OF A MAJOR MODIFICATION. THIS IS DEFINED AS "ANY PHYSICAL CHANGE IN OR CHANGE IS METHOD OF OPERATION OF A MAJOR STATIONARY SOURCE THAT WOULD RESULT IN SIGNIFICANT NET EMISSIONS OF ANY POLLUTANT SUBJECT TO REGULATION UNDER THE ACT." THE REGUALTIONS ALSO STATE THAT "A PHYSICAL CHANGE OR CHANGE IN METHOD OF OPERATION SHALL NOT INCLUDE: (A) ROUTINE MAINTENANCE, REPAIR AND REPLACEMENT..." C. SIGNIFICANT FOR VINYL CHLORIDE MEANS EMISSIONS THAT EXCEED ONE TON PER YEAR. OUR SLURRY EMISSIONS IN 1987 AVERAGED 208 PPM. THIS MEANS THAT MODIFIDATIONS THAT EXCEED ABOUT 9.6MM POUNDS PER YEAR ADDITIONAL PRODUCTION REQUIRE A PSD PERMIT. D. IF OFFSETS ARE USED TO REDUCE EMISSIONS, A PSD PERMIT IS NOT REQUIRED. HOWEVER, THIS EFFECTIVELY LOWERS THE LEGAL LIMITS FOR EMISSIONS. E: ATTACHED IS A QUOTE THAT RAF RECIEVED ON PREPARATION OF THE PERMIT BY A CONTRACTOR. AN ISSUE UNDER THE BACT ANALYSIS WILL BE THAT OF CONTINUOUS STRIPPING. VELDON E. MESSICK C:RAF, WLM, JCL. FGJ, JEN, EJM PAGE 2 4-70 ABD00315392 Scott Environmental Technology Inc FLUMSTEADVILLE, PA 18949 PHONE: (215) 766-8861 TWX: 5KW65-9344 March 29, 1988 SET Proposal No. 0113-03-2888-79 ft Mr. Dick. Frohreich Environmental Manager Vista Polymers Highway 25 Aberdeen, MS 39730 Dear Mr. Frohreich: Presented herein is a summary of the services offered as assistance to Vista Polymers in the development of a Prevention of Significant Deteriora tion (PSD) permit for a planned plant expansion. Services are summarized by the major PSD permit areas and an estimated ceiling cost is presented for each area. BACT Analysis Scott will conduct an evaluation to determine what the Best Available Control Technology (BACT) will be for reduction of emissions from the subject facility. This will involve evaluation of several control options including analysis of costs, environmental residuals, and energy impacts of each option. A very Important consideration will be coordination with the design engineers who are designing the plant expansion. In a report which will become part of the PSD permit application, Scott will summarize all of the options which were studied and present the rationale for selection of one option as BACT for this application. Cost - Not To Exceed $12,000 Air Quality Analysis Scott will search and evaluate all available ambient vinyl chloride and PM-10 monitoring data in order to establish baseline pollutant concen trations in the area of the source. Five years, of meteorological moni toring data will also be obtained. Additional to this, Scott will obtain land use and population Information for an area within 3000 meters of the source. In order to address the requirement of an emission Inventory within the region of the source, Scott will obtain Mississippi Emission Data System (MEDS) information for the area. All sources in the area will be reviewed and summarized in a report along with the air quality and meteorological data. Cost - Not To Exceed $8,000 4-71 TROY, MICHIGAN / SAN BERNARDINO, CALIFORNIA / HOUSTON, TEXAS / WHEELING. ILLINOIS SOUTH PLAINFIELO, NEW JERSEY / FREMONT, CALIFORNIA / WAKEFIELD, MASSACHUSETTS I LONGMONT. COLORADO Mr. Dick Frohrelch Vista Polymers ABD00315393 2- - Marcn 29, 1988 011*3-03-2888-79 Air Quality Modeling Scott will conduct dispersion modeling of predicted source vinyl chloride and PH-10 emissions by the 1SCST model in order to determine the Impact of the source on the ambient air quality of the area. The results of the modeling will be compared to the available increment for each pollu tant. The results will also be added to the background concentrations to evaluate potential violation of primary and secondary ambient air quality standards. Modeling will be conducted by tvo procedures. The first proce dure will Include a screening analysis using the EPA worst case meteorolog ical conditions. Modeling will also be conducted using the five years of meteorological data obtained during the Air Quality Analysis. All modeling will be conducted in strict accordance with EPA modeling guidelines. Cost - Not To Exceed $6,000 Secondary Impact Assessment Scott will perform an analysis of the impact of the proposed source on the visibility, soils, and vegetation of the area. There are no firm EPA guidelines on this section of the permit application therefore the analysis will be conducted and presented according to the general guide lines of an environmental Impact statement. Cost - Not To Exceed $4,000 This completes the summary of the services offered by Scott for this project. We appreciate this opportunity to be of service to Vista Polymers and we pledge our very best efforts toward the successful completion of the PSD permit application. If you have any questions or need any further information, please do not hesitate to contact me or Mr. Arthur Nunn. RPN:tae Robert P. Newman, P.E. ^ Marketing Manager Environmental Services Group 4-72 ABD00315394 manifests ABD00315395 A V. MANIFESTS Storage, shipment and disposal of hazardous wastes are regulated under RCRA. Shipment and delivery of hazardous wastes can only be made by authorized transporters and management facilities using the manifest procedures. The following is a list of wastes that we ship using the manifest system: WASTE STATE MANIFEST USED Waste Oil API Separator Louisiana Parts Cleaner Solvent Mississippi Lead Contaminated Bags Alabama Plasticizer Filter Cake Alabama Floor Sweeps* Alabama API Sludge Alabama P.A. Spill* Alabama Asbestos Alabama Stabilizer Spill* Alabama WHO SUPPLIES THE MANIFEST Vista/LA State form Safety Kleen/MS State form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form Vista/CWM form The following is a copy of each of the types of manifest used in the above list. * Temporarily shipped to Louisiana due to Alabama ban on hazardous materials. Additional form, LA state form 5-1 ABD00315396 STATE OF LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY HAZARDOUS WASTE DIVISION P.O. BOX 44307 BATON ROUGE. LOUISIANA 70804 i" ___________________________ -iOUut' -___________ i T 20.Faalitv Owner or Operator Certification oi race! of hazardous matenats covered by this manifest exeeot as noted in item 19. Prtnted/Typed N3n Signaon C;A\-------- T--\ ~A.\ tk.v.J ___________ A 6PA Form b700-22 k(Rav. 9/86) Previous soition is oosoistt. 5-2 Month Oay Y( \r&\T\& DEQ FORM HW-3 (R< ^6-0 9 4-01 ABD00315397 ease onnt or type. (Form designed tor use on ate 02-pttch) typewriter.) UNIFORM HAZARDOUS 1. Generator's US EPA ID No WASTE MANIFEST HSDO07031230 Form Approved. OMB No. 20500039. Expire* 9-30-91 Manifest Document No. Generator's Name and Mailing Address VISTA POLYMERS HUY 25 PO BOX 91 ABERDEEN MS m r T in e c o o n APFFR rD D F OF FFDEBAl REGULATIONS. 40, PART 262.20. U S. E n v ir o n ^ ^ 'refection Agency, 401 M Street, SW, Washington, DC 20460; and to the Ottice ot In J ^ ^ 'io n and Keyuiaioiy Aiimm. u m w m uuim hiui ......._...... ^ reviewing insujtf '`is , gathering data, and completing ano reviewing me n<uu. .. 15. Special Handting instructions and Additional information 8920 _0_6__0__9__1__8__9_ _6 IFUNDELIVERABLE* RETURN-TO GENERATOR* FOR RECYCLE 36X365 6-094-01-6134. _0_2 16. GENERATOR'S CERTIFICATION: t hersoy declare that the contents of this consignment are rutty and accurately duondad above oy proper ehlppicp name and are ''--'** pacxed. mimed, and labeled, and are in ail respects in proper condition tor transport Oy highway according to appticaMs intemeponas-ewd nanonet. government regraannns. if t am a taiga quantity generator. I certify that I have a program in place ta reduce the volume and toxicity of waste generated to the degree t have determined to be economically practicable and that i have selected the pracocaPie method ot treatment, storage, or disposal currendy evattapia to ma which mtntmtze* the present and future thraet to human health and tha environment: OR. it I am a small Quantity generator. I have made e good faith < effort to minimize my waste generation and select the oast waste managamem method that la available to me and that l can afford. Oats Prtnted/Typed Name . (Signature fO 'JAtnes M. ifAuMgrvr Jo.___ M. CeLnA/idsk . 17. Transporter 1 Adtnowfedgement of Receipt ot Materials__________ /* _ PrlntedfTyped NNamjme j_ 18. Transporters *- >. "A /. Signature,, Printed/Typedi Naammee SlgnatWe .I iy Month * Day Ybjt \fW6\3 \Oats Month-Day .Year L 12,4.137 Date .Month-Oaf- Yaar 19. Discrepancy indication Space x-.-j-i-oMja. ^ . I ,* T" - A"---- . V'*-. -**-1.... - 1 20,, Facility Owner or Operator Certfffcatlon of receipt of hazardous materials covered by this manifest except as noted in Item 19. Printed/Typed Name C ne.r r rt_ (junrve-LS_______ 7 LfvlC.KXJC EPA Form 6700-22 (Rev. 9-68) previout editions odsoiete -- _ Motffh Day Year i -ft i n SAFETY-KIEEN CORP. 90290. 6 ORIGINAL - RETURN TO GENERATOR 5-3 ABD00315398 HA *4 v a ; (As Required By The Alabama Department of Environmental Management) l'Form dostgnodfor uto on otitm 112-piteht typewriter.,* I UNIFfiRWAZAftbous' 1. Gammor i US EPA ID No. '\f Manifest WASTE MANIFEST MiSiQ.tOf<a7rqi,3|,7i^B'0 T""5enerator a Nam^Tn^^SS^^XSSnST Vi ^rcs- ~~ Fofm OMB Mv2DGMn Eanea-aoae J 0 fcx ? / 4. Generator's Phone ( 1`d.i ) b. iranspo^^T^ujmpeny Nyne t-OfSlTg /. Transporter 4 Mmpsny Name -- r"jiI T US EPA 10 Number \n\z\b\ i is r7i3iSTai3gQ. 8. US EPA tO Number 3. Designated facility Name and Site Address CHEMICAL WASTE MANAGEMENT. INC. Emelle Facility Alabama High way 17 at Mile Marker 163 Emeile. Alabama 35459______________________ " US EPA ID Number | A, L] D| 0[ 0, 0, 6,2 | 2 11. US DOTDoocnovonOnekjdinffProporS/yppatQAfanm Hazard Class. and iD Humbarf ' C.rejr- /NJOfX _ H-Ci-^iXT-tioiA b` H&Xdl^^OvTi AiiO-r^Z-J CWM Profile Number/nAK-73 J Sol-cX iVi. O-S t OftM'-E ^^CWM PpJfil^mber fa c- a;itOL A*** Afov T. Xi i CWM Profile Number MSH-/736S" "CWM Profile Number <T.A- <a. WIMI i -A; _l^5ct^.cjlI per- 'fKe. ii Gjb^lVrcsJ- 16 GENERATOR'S CERTIFICATION: I hereby declare mat the contents ot this consignment are tuiiy and accurately descrioeo above by prooer shipping name and are classified, packed, marked, and labeled, and ara m all respects in proper condition lor transport by highway according to applicable international and national government regulations. _ r if I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I htare^Msaans^ieba economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which mmwmaatbapiueni and future threatto human health and the environment: OR. if I am a smallouantitygenerator. I have msdoegoodlaitheflort to minimize my wattegeneration and aalaci mu hast waste management method that is availabla to me and that I can alford. Printed/Typed Naina Signature on' y--r V LTr*^t- \ -SO (9 ^ IM 17.Transpcrter 1 Acknowledgement ot Receipt of Matanata , tJh-LFi aadu tS.Tranaporter g Acknowledgement of Racepa of Matariala Primad/Typed Nam* Signature * 19.Discrepancy Indicatii So*711K - AKcuicS Vac: >LH-^.WVj'l5'oi y 0-.- 4-\_ H - 3-1 . 'hr D- r L. i asaig Momm Oar-^Yaar miii W^kZj / * 7- / <-<w 20.Facilitv Owner or Operator Certification of receipt of hazardous materials covered by this manifest except as noted in Item-"19. Printed/Typed Name ' -/ J> />' /A j-L Signature/y- / - /- 7. y- ^ ........ Sw 5-4 Month Day Peer ABD00315399 A SHIPPING PAPERS INTRODUCTION Biggest Source of Violation Activity and Shipment Delay It has been this author's personal experience that the vast majority ofviolation activityand shipmentdelay is caused by Shipping Papers not prepared in accordance with 49 CFR (or other applicable regulations). Any Inspector, State Trooper, Enforcement Person, or Carrier Accep tance Person, worth their salt will start their inspection with the ShippingPaper. Obviously ifeveryone looks at it and it is not correct problems will result. We at GSI recommend as strongly as we can that emphasis be placed on insuring that the Shipping Papers are correct This will help Emergency Response Personnel respond effectively to accidents or incidents involving the shipment elimi nate potential enforcement activity, and limit potential customer problems that result when a shipment is de layed. Use By Emergency Response Personnel Once theshipment leaves the Shipper's facilityand enters the transportation system it is subject to those "condi tions normallyincident to transportation'*as well as those thatare not "normally incident'* to transportation such as vehicleaccidents, punctureddrums,etc. In theevent ofan accident or intident involving the shipment Emergency "U.S. DOT vs ``Normal" Shipping Paper" The term "Shipping Paper" as normally used within the transportation system means the piece of paper or docu mentation used for piece count, billing, accountability tation of Hazardous as well as non hazardous materials. As used in 49 CFR the term "Shipping Paper" means documentation containing the specific Hazardous Mate rials information required by 49 CFR. Except for shipments of Hazardous Wastes (172^05) 49 CFR does not require the use of any specific form. The system is flexible enough to permit the use of ANY form so long as the required49 CFR information is on theform (171.8). As a practical matter by Highway it is very com mon to see the normal "Straight Bill of Lading" used for shipments of both hazardous and non hazardous goods. On the other hand, although not required by 49 CFR, the air industry requires the use of a particular Document called the SHIPPER'S DECLARATION FOR DAN GEROUS GOODS. GSI CR: Hazardous Waste Manifest, BS GSI CR: SHIPPER'S DECLARATION, C33 Response Personnel will have to make IMMEDIATE decisions as to how to handle it The Shipping Paper provides VITAL INFORMATION needed to make these decisions such as but not limited to the Proper Shipping Name, Hazard Cass, the Identification (ID) Numberand the amount of material involved. Definition of "DOT 49 CFR* Shipping Paper Tobein compiiancewith49CFR whatever"form" is used as the Shipping Paper MUST contain the information REQUIRED by: 172J02 containing the Basic Description requirements consisting of: 1. Proper Shipping Name (172.202(a)(1)). 2. Hazard Class (172^02(a)(2)). The ID (UN/NA) Number from Column #3A of the HMT-I72.101 is a required entry on the Shipping Paper. It is keyed to the "Emergency Response Guidebook". This Guidebook gives Emergency Response personnel information relative to the Hazards associated with the material, recommended responses, and other actions such as evacuation etc. Obviously if the ID Number is not on the Shipping Paper or otherwise visible Emergency Re sponders will not have the benefit of this quick cross reference. Lives could hang in the balance. 3. ID (UN/NA) Number (172.202(a)(3)). 4.1-3 above in sequence (172302(b)). 5. Quantity ofMaterial (172302(a)(4)). 172303 containing Additional Description requirements which MAY apply to a particular Basic Description. 172.204 containing the Certification and Signature re quirements. A39 (08fW) 5-5 ABD00315400 A General Applicability Multiple Page Shipping Papers As a general rule if a Hazardous Material is offered for transportation the person offering it MUST describe the material on a Shipping Paper in the manner required by 49 CFR (172.200(a)). A Shipping Paper may consist of more than one page PROVIDED each page is numbered consecutively AND the First Page bears a notation specifying the total num ber of pages included in the Shipping Paper as follows: Exceptions Page l of 3 `Normal" (Commercial) Shipping Papers are generally required to transport most materials. Hazardous as well as non hazardous. Except for Hazardous Wastesand Sub stances, "DOT Shipping Papers" ARE NOT normally required for shipments of materials: 1. Identified by the letter "A" or "W" in Column #1 of the HMT-172.101 except when offered or in tended for transportation by the mode indicated, "A* for Air and/or "W for Water. Z That are ORM D's except when offered or intneded for transportation by air. (172.200(b)) GSI CR: "A'V'W" "AW", A15 Hazardous Materials and NON Hazardous Materials On The Same Shipping Paper When a Hazardous Material is shown on the same shinpingpaperswitha non hazardous material the description of the HAZARDOUS MATERIAL must: 1. Be shown first (172^01(a)(l)(i)). OR 2. Entered in an ink of a contrasting color, (172.201(a)(l)(ii)). In this case the description can be located anywhere on the shipping paper and/or intermixed with the non hazardous to. Of Um HM ATVpe Straight Bill DESCRIPTION AND CLASSIFICATION (Proper Shipping Name. Hazard Class. UN/NA Number) 1 Bex Grandmas Kltea 9 Drums X Acetone, Flammable liquid, UNI 090 IDntms X Flammable liquid.n.o.s. (Acetone,Xylene) Flammable liquid, UNI 993 TootOuMoqr (Wl/Vol) 100 lbs 4320 lbs 960 lbs FIGURE SP-1 General Shipping Paper Description Requirements material entries. OR All required shipping descriptions must: 1. Be printed (manually or mechanically), in english. and legible (172^01(a)(2)). 2. Contain no codes or abbreviations except as au thorized or required (172.201(a)(3)). i.e. Abbre viations for the quantity (net or Gross) of the Hazardous Material being described (172^02(c)(l)); RQ for "Reportable Quantity" (172.203(c)(2)); Ltd Qty for "Limited Quantity" (172.203(b)). 3. Be identified by the entry of an "X" placed BE FORE the Proper Shipping Name in a Column captioned "HM" (172.201(a)(l)(iii)). If this op tion is used the Hazardous Materials may be placed anywhere on the Shipping Paper as illus trated in Figure SP-1. "Grandma's Kites", the firstentryon theShipping Paper, is not a Hazard ous Material; is listed first on theShipping Paper, and the Hazardous Materials are not entered in an ink of a contrasting color so the "X** must be placed in the "HM Column for each of the Haz ardous Material entries. A40 (0888) 5-6 ABD00315401 GSI COMPLIANCE PRACTICE- Use the "HM" Coluran Option. Put an "X" in the "HM Column" as a stan dard practice when entering Hazardous Materials on the Shipping Paper EVEN IF the Shipping Paper only has Hazardous Materials on iL This avoids having to select an Option and the decision as to whetheror not theselection of one of the Options is necessary for a particular ship ment. Technical Name Exception 49 CFR currently (08/87) permits the "technical" or group names of a material to be entered (in parentheses) between the Proper Shipping Name and Hazard Class (172.202(d)). The Flammable liquid, n.o.s. (Acetone, Xylene) entry in Figure SP-1 illustrates this entry for a Flammable liquid mixture containing "Acetone" and "Xylene". THE ABCs OF THE BASIC DESCRIPTION (172.202) To insure compliance with 49 CFR all Shipping Papers, including Hazardous Waste Manifests, must contain a Basic Description containing the following information in sequence: A. Proper Shipping Name The FIRST Item in the sequence is the Proper Shipping Name listed in Column #2 of the Hazardous Material Table 172.101 for the Hazardous Material (172202(a)(1)). The entries Acetone and Flammable liquid, iuxs. in Fig ure SP-1 show this entry. GSI CR: Proper Shipping Name, A3; Marking, Proper Shipping Name, A27 GSI RECOMMENDATION- Include the "Technical" or chemical names in parenthesis for most ProperShip pingNames endingwith the letters "n.o.s." as required by applicable UN regulations (ICAO by air and the 1MDC Code forwater). As a practical matter most Proper Shipping Names end ing with the letters "n.o.s." being offered for transporta tion by air or water under the appropriate International Regulations will require the addition of one or more chemical names in parenthesis immediately after the the letters n.o.s. in the listed Proper Shipping Name. Pending rule changes to 49 CFR (HM-126C and HM181) will require basically the same type of entry for domestic shipments within the next few years. GSI CR; Air, C N.O.S. Name Rule C13 B. Hazard Gass The SECOND Item in the sequence should be the HAZARD CLASS listed in Column #3ofthe Hazardous Material Table.101 for the Hazardous Material (172.202(a)(2)). The entries Flammable liquid after the Proper Shipping Names in Figure SP-1 illustrate the Hazard Cass entry. GSI COMPLIANCE PRACTICE- Although there are some exceptions to this requirement we at GSI recom mend that the HAZARD CLASS be used at all times. GSI CR: Classification, A10; Placarding, AS1 C. Identification fUN/NA) Number The THIRD Item in the sequence is the Identification Number including the "UN"'or "NA" prefix listed in Column #3(A) of the Hazardous Material Table 172.101 for the entry (172.202(a)(3)). This is illustrated by the entries UN1090 and UN1993 in Figure SP-1. GSI CR; CoL #3A A14; UN/NA No. Marking A27 E. Quantity of Material Except for empty packagings, compressed gas cylinders, and packagings havinga capacityofmore than 110 gallons such as Cargo Tanks the "Total Quantity" of thematerial covered by the Basic Description, including the units of measurement, must be entered on the Shipping Paper (172.202(a)(4)). The TOTAL QUANTITY entry may: 1. Be given weight OR volume or as otherwise appropriate. 2. Appear either before OR after OR both before and after the Proper Shipping Name, Hazard Class and Identification Number information on the Shipping Paper and may be abbreviated (172.202(c)). 3. Be either the "net amount" of the material in the package or the "Cross Weight", the weight of the material in the package plus the packaging, as appropriate. Generally the "net" figure is used for air or Hazardous Waste shipments and the "Gross Weight" for Highway Shipments. n. Required Sequence of Basic Description The ProperShipping Name, Hazard Class,and Identifica tion Number MUST BE IN SEQUENCE with nothing between them. AH the entries in Figure SP-1 are in this this sequence (172.202(b)). The entries in the "TOTAL QUANTITY" Column of Figures SP-1 through SP-4 illustrate these entries. GSICompliance Procedure- Always include the Quantity of the Material even ifan Exception applies. As a practical A41 (0888) 5-7 ABD00315402 A matter the "Gross Weight" is going to be included for most, non Cargo Tank, highwayshipments and will be the Figure most often used. GSI CR: Air- P. C38 elsewhere the Additional Description information should be entered AFTER the Basic Description information on the Shipping Paper as shown by the Ltd Qty and RQ entries in Figure SP-2 Prohibited Entries Additional Description Entries A material not meeting the definition of a Hazardous Material may not be described on a Shipping Paper using either a DOTHarardCJassora UN/NA Number (172202(e)). A packageof "Paint" having a Flash Point of250>F may not be described on a Shipping Paper by any of the following descriptions: Paint, Flammable liquid, UN1263 Paint, Flammable liquid Paint, UN1263 It should be described simply as Paint A. DOT Exemptions If the Basic Description describes a Hazardous Material being shipped under a DOT Exemption the notation "DOT-E" followed by the "Exemption Number" as signed must be entered in association with the Basic Description (172203(a)). A shipment being shipped under "DOT Exemption # 1234" must have the entry DOT-E 1234 entered on the Shipping Paper after the Basic Description as shown for the Aldrin entry in Figure SP-2 GSI CR: Air-Auth.Column, W.C41 THE ABCs OF ADDITIONAL DESCRIPTION REQUIRE MENTS (172.203) In any case where a Shipping Paper is required it will, at a minimum, contain a Basic Description, in addition, one OR more of the Additional Description requirements contained in Section 172203 MAY or MAY NOT apply to a given Basic Description. Each paragraph in 172203 rep resents a potential Additional Description Item thatcould be required. If one or more of the Additional Description Items specified in 172203 applies to the the Hazardous Material described in the Basic Description the appropri ate entries must be made. If none apply to the particular Basic Description hen no Additional Description informa tion has to be entered. GSI COMPLIANCE PROCEDURE- As a general rule EXCEPT where specifically required to be placed B. Limited Quantity If a material is offered for shipment as a "limited quan tity** the words Limited Quantity or Ltd Qty must be entered on the Shipping Paper after the Basic Descrip tion (172203(b)). This entty is illustrated by the entry Ltd Qty after the Butane entry in Figure SP-2 GSI CR: Limited Quantities, A19 C. Hazardous Substances At a minimum the letters RQ must be entered on the Shipping Papereither before or after the BasicDescrip tion IF the material covered by the Basic Description is regulated as a Hazardous Substance as shown in the Aldrin entry in Figure SP-2 (172203(c)(2)). In addition, except for Hazardous Wastes. IF the name(s) of the constituents) causing it to be regulated as a Hazardous Substance, as listed in the Appendix to 172101, Straight Bill N&OfUm* 11M DESCRIPTION AND CLASSIFICATION * Type (Proper Shipping Name, Hazard Clasa. UN/NA Number) 2 Ba X Aldrin, Poison B, NA2761, DOT-E1234, RQ 25 bis X lBx X IBx X Butane, Flammable gas, UNI 075, Ltd Qty Hazardous substance, liquid, n.o.s., ORM-E NA9188 (n-Butyl phthalate) RQ Magnesium metal, Flammable Solid, UNI 869 Dangerous When Wet FIGURE SP-2 A42 5-8 TouiQuMMy (wi/von 30 lbs 250 lbs 150 lbs 60 lbs ABD00315403 is not partoftheProperShippingNameitmustbe entered in parenthesis in association with the Basic Description as illustratedin the Hazardous substance liquid, n.o.s. entry in Figure SP-2 (172.203(c)(1)). it is part of the Basic Description or has been added in accordance with 172.203(k)(2). GSI CR: Air, USG-34, C43 GSI CR: Haz. Substances, Bl; Air, USG-01, C42; Hazardous Wastes, A44 D. Dangerous When Wet If the package is required to be labeled with a"DANGEROUS WHEN WET* label the entryDanger ous When Wet MUST be entered on the Shipping Paper in association with the Basic Description (172.2030). This entry is shown in the Magnesium metal entry in Figure Sp-2. GSI CR: Labeling. A35; Air, USG-12, C42 E. Poisons-Inhnlation Hazard Name- If the Proper Shipping Name does not contain the the name of the compound or primary constituent causing it to meet the definition of a a "Poison", as defined in 49 CFR, the name of the compound or principal constituent causing it to meet the definition of a "Poison" must also be listed in association with (after) the Basic Description for the materiaL The name used may be either the ffghnimi name of the material or any name for the material that is listed in the NIOSH Registry (National Institute for Occupational Safety and Health) (172.203(k)(l)). Poison* IF the material meets the definition of a Poison under 49 CFR and the fact that it is a "poison" is not disclosed by either the Proper Shipping Name, or the Hazard Class the word "Poison" must be entered on the SHIPPING PAPER in association with the Basic Descrip tion as shown in the Waste Ally! alcohol entry in Figure SP-3 (17Z203(k)(2)). GSI CR: Air, USG-U, C43 F. Hazardous Wastes Shipments of Hazardous Wastes must be described on a specific form, the Uniform Hazardous Waste Manifest (EPA 8700-22), prepared in accordance with 40 CFR 262^0 (172.205(a)). The instructions for preparing this form for Blocksother than 11. aresuffidentlyexplained in the Appendix to 40 CFR Part 262 and will not be ex plained in this text. Except as noted below, the description of a Hazardous UNIFORM HAZARDOUS WASTE MANIFEST IGmncan US EPA ID N& VUotfw OoeuaaaNa 1. faf* t f 1L US DOTDwcnpuow (Including Proper.Shipping Hum* Q id ID No.) 11 Comn No. U.Tou4 NUnk Quad? Wl/Vd WmNa a. Waste AHyl alcohol. Flammable liquid, UN109S, RQ Poison- Inhalation Hazard 10 DM 1500 jj P b. Hazardous waste solid, n.nA, ORM-E, NA9189 RQ (EPA EP toxicity) 10 DM 4400 FIGURE SP-3 fiigf P Wmm. Poison-Inhalation Hazard- If the Basic Description covers a material meeting the inhalation toxicity criteria of 173.3a(b)(2) packaged in primary containment units of more than one (1) liter capacity the words "Poison-Inhalation Hazard" must be entered in association with the Basic Description (172.203(k)(4)). The Waste AHyl alcohol entry in Figure SP-3 illustrates this point. The word "Poison" in this entry is not required if Waste on the Manifest is the same as for any other Hazardous Material: 1. The word Waste must be added preceding the Proper Shipping Name If It is not part of the Proper Shipping Name appearing in Column #2 of the HMT-172.101 as illustrated by the Waste AHyl Alcohol entry in Figure SP-3. If the word Waste is nan of the Proper Shipping Name appearing in Column #2 of the HMT172.101 leave it where it is as illustrated by the A43 5-9 ABD00315404 Hazardous waste solid, n.o.s. entrv in Figure SP-3(172.101(c)(10)). Except for the requirement that the Quantity of Material covered by the Description be in Items 13 and 14 and that the Unit of Measurement be entered in hem 14 be as specified in the Appen dix to Part 262 of 40 CFR all the Basic and Addi tional Description Items required by49 CFR will be entered in Block 11 ofthe Uniform Hazardous WasteManifestas illustrated in FiguresSP-3 and SP-4 below. Container Number and Tvne: Item 12 requires an entry for the "Number1' (No.) and `Type*' of containers being used to transport the Haz ardous Waste. The entry for the "TVpe" of container must beas specified in the Instruc- For Characteristic Waste the words: EPA Ignitabiltty; EPA corrosivity; EPA reactivity; EPA EP toxicity, as appropriate or The appropriate D Number. The letters RQ must also be added to the Basic Description of a Hazardous Waste that is regulated as a Hazardous Substance in the same manner as required for any other Hazardous Substance (177.203(c)(2)). GSICR: Hazardous Substances. C.A42 UNIFORM HAZARDOUS WASTE MANIFEST LGcnenun US EPA ID No. Manrfot Document No. l L US DOT Docnpoon ((ndudioi Proper Sfaepof Nm Hajart data, ami 10 No.) of 11 CcMMMI O. Total No. Typ* Quantity KUmt i Wt/Vot WaMrfta. a. Waste Flammable liquid. n <^*- Flammable liquid, UN1993 (Acetone/Xyiene) or (F003) RQ FIGURE SP-4 tions for Item 12 in the Appendix to Part 262 of 40 CFR. These entries are illustrated in Figures SP-3 and SP-4. 3. Ifthe Hazardous Waste is also regulated asa Hazardous Substance and the Proper Shipping Name docs not con tain the nameof the Hazardous Substance as listed in the Appendix to 172.101 one ofthe following must be entered in (parenthesis) as an Additional Description Item in Item 11 of the Uniform Hazardous Waste Manifest as illustrated in Figures SP-3 and SP-4 (172.202(c)(1)): The Name of the Hazardous Substance as listed in the Appendix to 172.101 or The Waste Stream Number if a Waste Stream is involved or 1 TT 4000 G wmm. A44 5-10 Pages A45-A48 Reserved. ABD00315405 A CERTIFICATION addition to the manual signature of that person. The Certification must be on the Shipping Paper con taining the Basic Description. The person who signs the Certification is saying on, BEHALF OF THE COM PANY, that everything has been properly described, packaged, marked, labeled etc. GSI CR: Air-Cert., AA.-CC., Page C41 No Certification Required Certification for Highway & Rail Transportation If highway and/or rail is the mode of transportation the Certification in 172.204(a)(1) should be used. This Certification is commonly preprinted on Bills of Lading used for Highwayand Rail transportation ofHazardous Materials. Certification for Water Shipments If water is involved in the transportation of the Hazard ous Material the Certification in 172.204(a)(2) should be used because it is also in compliance with the provisions of IMO (Section 9. paragraph 9.4 of the General Introduction). Useofthis Certification will also cover the highway portion of the transportation by inserting the words ' 'highway and water" where the '**" appears in the body of the Certification (172.204(a)(2)). Except for Hazardous Wastes no Certification is re quired for Hazardous Materials offered for transporta tion by motor vehicle AND transported in a cargo tank supplied by the carrier OR by the shipper as a private carrier unless the Hazardous Material is to be re shipped or transferred to another carrier (172.204(bXl)). Nocertification is required forthe shipment ofan empty tank car by rail (172.204(b)(2)). Certification bv Air If air is involved in the transportation of the Hazardous Material the Certification in 172.204(c)(1) AND 172^04(0(3), with the appropriate entry deleted should be used. As a practical matter this information is preprinted on a red bordered (hatched) form known as the ' 'SHIPPER'S DECLARATION" which is used by most air carriers in the world. This Certification also covers the highway portion ofthetransportation to and from the airport. GSICR: Air- Transport Details Box, C36: Certifica tion, C41 SIGNATURE The required Certification must be LEGIBLY signed by a principal, officer, partner, or empioyeeof the shipper or their agent (172.204(d)(1)). Except for Hazardous Waste Manifests and Air Shipmentsthe signature may be manual, by type writer.or by other mechanical means (172.204(d)(2)). Hazardous Waste Manifests and Air Shipments Hazardous Waste Manifests will have the name of the person signing the certification typed or printed along with a manual signature in Item 16 of the Uniform Hazardous Waste Manifest. For Air Shipments the SHIPPER'S DECLARATION FOR DANGEROUS GOODS will have the name and position of the person signing it printed or typed in the Signature Box in A49 (08/871 5-11 ABD00315406 ENVIRONMENTAL OFFICE^MAP ABD00315407 6-1 ABD00315408 r REPORTING AND SPILL CHECKLISTS VII. ABD00315409 REPORTING AND SPILL CHECKLISTS The following table lists all environmental reports due during the year and the due date. DATE REPORT DUE Jan. 28 and the 28th day of every month NPDES, Discharge Monitoring Report form (EPA No. 3320-1) to MDNR for preceding months water discharge data. March NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall March 1 (even no. yrs) RCRA Hazardous Waste Shipments Activities Reporc March 1 SARA 312, Emergency and Hazardous Chemical Inventory forms to State ERC, Local EPC, and Local Fire Department March 15 NESHAP, RVCM report for December, January, and February March 31 NESHAP 1st quarter Bleeder Valve Survey June NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall June 15 NESHAP, RVCM report for March, April, and May June 30 NESHAP 2nd quarter Bleeder Valve Survey June 30 NPDES, Bioassy of outfall using ceriodaphnia June 30 SPCC Plan Survey July 1 SARA 313, Toxic Chemical Release Reporting to EPA and State Officials July 1 TSCA, Annual report for PCBs in service or projected for disposal for previous calendar year September NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall September 15 NESHAP, RVCM report for June, July, and August September 30 NESHAP 3rd quarter Bleeder Valve Survey October 31 SARA 311, updated MSDS sheets to State ERC, Local EPC and Fire Department December NPDES, Quarterly BIS(2EH) phthalate, Di-n-octyl phthalate and VCM concentrations in outfall December 15 NESHAP, RVCM report for September, October, November December 31 NESHAP, 200 VCM Service Valve Survey and Bleeder Valve Survey 4th quarter December 31 NESHAP Annual VCM Flange and Valve Survey December 31 NPDES, Bioassay of outfall using pimephales promelas December 31 SPCC Plan Survey 7-1 4 ABD00315410 To: Distribution nteroffice Communication From: Date: F. G, Jeanson January 4, 1989 Subject: RELEASE AND SPILL REPORTING One of the requirements of the Emergency Planning and Community Right-to-Know Act of 1986, commonly referred to as SARA, is the reporting of releases of certain substances to the environment (Section 304). The report is to be made to the emergency coordinator of the local emergency planning committee and to the Mississippi Emergency Response Commission. This reporting requirement is in addition to the Superfund or CERCLA section 302(a) reporting to the National Response Center which we have been doing for some time. Naturally, the substances and conditions requiring notification are not the same for each of the reports. Table I lists the substances used in the plant that require SARA release reporting. Table II lists the substances used in the plant that require CERCLA section 302(a) release reporting. The tables also show the reportable quantity for each of the substances. The regulations concerning when reporting Is required are complex; therefore, the Environmental Coordinator should be contacted Immediately in case of a spill or release to help determine if it requires reporting. In general, a spill or release of any substances in excess of the reportable quantity except for federally permitted discharges (most vinyl chloride emissions are federally permitted) must be reported. Any non-permitted release of a gaseous material in excess of the reportable quantity will require reporting for both SARA and CERCLA 302(a). If greater than the reportable quantity of a liquid or solid is spilled on concrete and totally contained before it reaches any soil, the spill does not need to be reported by either SARA or CERCLA 302(a). If greater than a reportable quantity of a liquid or solid is spilled on the ground but the spill does not leave the plant boundary, It needs to be reported to CERCLA 302(a) only. If greater than the reportable quantity leaves the plant boundary, the spill will also need to be reported under SARA. Attached is a form listing the questions usually asked when a release is reported to the National Response Center [CERCLA 302(a) list]. This form should be filled out by the operating personnel in the area where the release occurs prior to the phone call. Also attached fs the Mississippi Emergency Management Agency Hazardous Material Release Report form. When notifying the emergency coordinator of the local emergency planning committee and the Mississippi Emergency Response Commission of a SARA release, the information in boxes 1 through 9 must be provided. 7-2 A ABD00315411 Distribution 1/04/89 Release and Spill Reporting Rage 2 In addition to the verbal report of a SARA release, a written followup emergency notice is also required setting forth and updating the information required to be reported in the verbal report and to include additional information with respect to: 1. Actions taken to respond to and contain the release. 2. Any known or anticipated acute or chronic health risks associated with the release, and 3. Where appropriate, advice regarding medical attention necessary for exposed individuals. This written report is to be sent to the emergency coordinator of the local emergency planning committee and to W. E. Austin, Special Projects Officer, SARA Title III, Mississippi Emergency Response Commission, F. 0. Box 4501, Fondron Station, Jackson, MS 39216-0501. The written report is to be submitted as soon as practicable after the release. The written report should be submitted within ten days as a maximum. F. G. Jeanson Environmental Coordinator rah attachment 7-3 ABD00315412 TABLE I SARA REPORTING MATERIALS Report to: Jerome Huskey Emergency Coordinator, Local Planning Committee Work Phone: 601-369-6439 Home Phone: 601-369-6439 Mississippi Emergency Response Commission 1-800-222-6362 In State (24-Hour Number) 1-601-352-9100 Out of State (24-Hour Number) 1-960-9000 Regular Hours (Bill Austin) Material Ammonia Chlorine Di-n-octyl Phthalate Hydrazine Hydroquinone Sulfuric Acid CAS Number 7664-41-7 7782-50-5 117-84-0 302-01-2 123-31-9 7664-95-9 Reportable Quantity Pounds 100 10 5000 1 1 1000 7-4 ABD00315413 TABLE II CERCLA 302 fa) MATERIALS Report to: National Response Center 1-800-424-8802 Material Ammonia Antimony Trioxide Asbestos (Friable forms only) Chlorine Di-n-octyl Phthalate Hydrazine Lead Stearate Lead Sulfate Mercury Methanol Phthalic Anhydride PCB1s Sodium Hydroxide Sulfuric Acid Vinyl Chloride Unlisted Hazardous Wastes: Characteristic of Corrosivity Characteristics of EP Toxicity Arsenic D004 Rarium D005 Cadmium D006 Lead D008 Characteristic ofIgnitability Characteristic of Reactivity 7-5 A Reportable Quantity Pounds 100 1000 1 10 5000 1 5000 100 1 5000 5000 10 1000 1000 1 100 1 1000 1 1 100 100 ABD00315414 NATIONAL RESPONSE CENTER TYPICAL QUESTIONS 800-424-8802 A 1. Naas of person reporting the spill and/or release: 2. Company represented: Vista Polymers Inc. 3. Mailing address and phone number: P. 0. Box 91, Aberdeen, Mississippi 39730(601) 369-8111 4. Plant location: Highway 25 South 5. County: Monroe 6. Site of spill: 7. Material spilled: 8. Time and date of spill: 9. Vlnd direction* wind speed, barometric pressure: 10. Did spill enter a waterway: 11, Water body affected: [ ] Yes [ ] No 12. Source of spill: 13. Cause of spill: 7-6 ABD00315415 NATIONAL RESPONSE CENTER TYPICAL QUESTIONS Page 2 14. Was equipment in operation at the time: 15. Size of spill: [ ] Yes [ ] No A 16. Was there any property damage from the spill: [ ] Yes [ ;| No 17. Corrective action taken to stop spill: 18. Did company personnel conduct' cleanup: [ ] Yes [ ] Ho 19. Has the affected equipment been repaired: [ ] Yes [ ] Ho 20. Was anyone hurt: [ ] Yes [ ] No 4a - 21. Was any evacuation needed: [ ] Yes [ ] No 22. Have any other agencies been notified of the spill: [ 1 Yes [ 1 No 23. Do ve have any plans to notify any other agency: [ ] Yes [ ] No 1. Time and date incident reported to National Response Center: 2. Name of person accepting report: 3. Other Information requested: 4. Signed: 7-7 ABD00315416 SPILL/RELEASE REPORT TO BE FILLED OUT BY SHIFT SUPERVISOR TIME PERSON REPORTING SUPERVISOR LOCATION NAME NAME DATE DATE DEPT TYPE OF MATERIAL. ESTIMATED AMOUNT. DURATION___________ CAUS E_______________ WIND DIRECTION, SPEED, BAROMETRIC PRESSURE. DID MATERIAL ENTER GROUND_______________________ DID MATERIAL ENTER STORM SEWER. DID MATERIAL LEAVE THE PLANT__ IS MATERIAL ON SARA__________ OR CERCLA. .LIST. (SEE ATTACHED TABLES) IF SO, DID THE SPILL/RELEASE EXCEED THE REPORTABLE QUANTITY. WHAT ACTION WAS TAKEN TO STOP SPILL________________________________ WHAT ACTION WAS TAKEN TO CLEAN-UP SPILL. A DISTRIBUTION: RWS, DCS, FGJ, TFL, RBN, OPERATIONS SUPERINTENDENT, OPERATIONS ENGINEER, DEPARTMENT SUPERVISOR 7-8 ABD00315417 SPILL/RELEASE PREVENTION REPORT TO BE FILLED OUT BY DEPARTMENT SUPERVISOR SPILL/RELEASE THAT OCCURRED___________________________________________ RECOMMENDATIONS OR ACTION TAKEN TO PREVENT RECURRENCE A DEPARTMENT SUPERVISOR ENVIRONMENTAL COORDINATOR OPERATIONS SUPERINTENDENT PLANT SUPERINTENDENT PLANT MANAGER DATE DATE DATE DATE DATE 7-9 ABD00315418 MISSISSIPPI EMERGENCY NANAGBKW AGENCT HAZARDOUS MATERIAL RELEASE REPORT 1 Release Location nt ra 5. Contact for further information N I Tl t I : 4. Coapany Ni City: State: n p> 6. Bel Information t) Kill o b) HA/OH! CASI -C) I t 71 d ) Data 0 f I 0 I 0 a S 0 : ) Tl () Strut oi of lit mm: I) lit mm iceirrid lata Air water a I) Sabstiict is utrtiti r linrditi YCS (par list is 40 era sss) NO 7 Rec nded precautions 8* Anticipated Health Bisks 9. Person reportInc release: Min: Tl t I : Addriis: City: Statii zip: rboia: MEMA-III-1 [0CT87] 10. Notified: Pollution coitrol ltd! o I o f I e il hmI t b Naas: Data: Tlafrf 11. Emergency Action Required: Naaa a Stats local 12. Person report: 7-10 ABD00315419 ATTACHMENT A Superfund Reporting Checklist Report? I. Below RQ No II, Above RQ 1,0 Air A. NESHAPS 1. VCM a). In VCM service 0 Process Vent 1. Less than lOppm VCM for 3 hr. TWA 2. Exceeds lOppm std by less than RQ 3. . Exceeds lOppm std by more than RQ ID RV/RD release 111) RV/RD leak iv) Other leaks No No Yes No No No Not in VCM service 1) Process Vent 11) RV/RD release Hi) RV/RD leak iv) Other leaks Yes Yes Yes No Massive Release Yes 2. BENZENE a). In benzene service 1) Process vent 1. In compliance with standard 2. Above standard by less than RQ 3. Above standard by more than RQ 11) RV/RD release Hi) RV/RD leak iv) Other leak No No Yes Yes No No 7-11 ABD00315420 Not in benzene service i) Process vent it) RV/RD release iii) RV/RD leak iv) Leak Massive release SIP 1. Release from specifically regulated point a). In compliance with regulation b). Above regulatory limit by less than RQ c). Above regulatory limit by more than RQ 2. Fugitive leak if SIP has fugitive control requirements C. OTHER 1. Continuous or routine releases 2. Significant increase in continuous or routine release 2.0 Water A. NPOES regulated discharge 1. Permit exceedance caused by spill of hazardous substance 2. No permit exceedance 3. Permit application identifies substance and amount (concentration) 4. Stormwater outfall B. Spills 1. Ground a). Inside Plant i) Volatile ii) Nonvolatile, nonporous surface iii) Nonvolatile, porous surface iv) Sewer (See NPOES) Yes Yes Yes No Yes No No Yes No No Yes Yes No No Yes Yes No Yes -27-12 ABD00315421 b). Outside Plant 3.0 Seepaqe to the Ground A. From impoundment - episodic B. From sewer lines - episodic C. From underground pipeline - episodic D. Initial detection of continuous release E. Subsequent continuous releases 4.0 Di scharqes to POTW's A. Pretreatment standard exists exceed standard by RQ amount B. No Pretreatment Standard - Spill RQ amount Yes Yes Yes Yes Yes No Yes Yes WLM07/089 ABD00315422 To: Distribution j7r>cr A Interoffice Communication From: Date: Subject: F. G. Jeanson February 3, 1989 PLANT ENTRY OF GOVERNMENTAL AGENCY PERSONNEL VISTA Each person from a Governmental Agency is to complete and sign the attached Request for Entry form before being allowed into the plant. If the person will not sign the form, ask what the problem is. He will likely have an objection because of Item 6, the indemnification section. Then ask him if he would sign the form if Item 6 is crossed out. If he says yes, cross out Item 6. Both the Agency person and the Plant representative are to initial the cross out. If the person will not sign the form under any circumstances, contact the Manager. He will then determine whether to allow the person entry into the plant. A supply of the Request for Entry forms will be kept by Terry Sullivan. Contact me if you have any questions about using the form. F. G. Jeanson Environmental Coordinator tjs RWS, DCS, JEN, JEL, DWH, PJK, JEB, HGC, TFL, GAM, BLT, SCH, VLT, RUN, REP, RAH, TJS, ENGINEERS 7-14 ABD00315423 RZQUEST "OR ENTRY 1. My name is ____________ ______________ . I represene ____ _ , which is escaoilstu (agency or bureau) by che lava of ehe (United States) (Scace of ). My official title or posielon is . My business address Is '* _____________________________ . 2. In my official capacity, I am requesting adatsslon to (plant or facility) for che purpose of: ( ) a. gathering scientific research information ar.d/or studying technology development, under (statute or popular name of act) ( ) b. making a regularly scheduled Inspection of the facilities, under (statute or popular name of accl ( ) c. caking samples of water, air, or _______ type of air monitoring equipment ___________ type of water or soil sampling equipment __ water chemical analyses (tests and methods) soil chemical analyses (tests and methods) location(s) for sampling _______________________ (circle) ( ) d. making a special iospeeclon of the facilities for the following purposes: under (statute or popular name of aec) ( ) e. gathering evidence for pending or potential criminal or civil proceedings, under (statute or popular name of ace) ( ) . V * * ochar; specifically under 11-11 T (statute or popular name of act) 3. X specifically wish to see che following units or activities: 7-15 ABD00315424 A I agree to provide spile samples or all samples ut vhaeever nature obtained, and to furnish you all analytical results from all tests conducted. I understand that I will be furnished a guide and such other assistance as 1 may require for Information or safety. I agree to comply with all safety regulations and instructions, whether written or oral, while on the premises. 6. I agree to Indemnify and hold you harmless from and against any loss, costs, expense or liability arising out of any loss, claim, or eause of action for loss of or damage to my property or equipment, or chat of my employees or agents, and Injuries to or death of persons caused by, resulting from or Incidental to the entry authorized hereby; provided, however, that exnape for losa of or damage to my property or equipment, or chat of ay employees or agenes, such Indemnification and hold harmless shall not apply to claims for loss, damage. Injury or death if caused by your sole negligence. 7. I, and my employees and agents, agree to treat and maintain as confidential property of the Agency, and, except as is necessary to perform the wort envisioned hereunder, shall not use or disclose to others, either during the eerm of this entry or thereafter, any Information (including any technical information, experience, or field data) regarding products, plans, programs, plants, processes, costa, equipment, operations, or customers which may be disclosed to or coma within my knowledge, or that of my employees or agents, during Che entry aucharlted hereby. The provisions of this paragraph shall noe apply to any information referred to herein which 1 can establish (1) has been published and has become pare of the public domain, other than by my or ay employees or agenes acts or omissions, (11) has been furnished or made known co me by third parties (othsr chan chose acting dlrecely or Indirectly for or on behalf of you) as a matter of legal right and without restriction on disclosure, or (ill) is required by law to be disclosed. (Date) (Visitor) (Time) Visit authorized by: (Title) _______________ (Agency or Bureau) (Plant or Facility) 7-16 ABD00315425 appendix ABD00315426 acronyms ABD00315427 A ACRONYMS 1. CAA - Clean Air Act 2. CERC1A - Comprehensive Environmental Response, Compensation, and Liability Act 3. CFR - Code of Federal Regulations 4. CWA - Clean Water Act 5. BDAT - Best Demonstrated Available Technology 6. EP Toxicity - Extraction Procedure Toxicity 7. EPA - Environmental Protection Agency 8. FR - Federal Register 9. HSWA - Hazardous and Solid Waste Act of 1984 10. LEPC - Local Emergency Planning Committee 11. MDEQ - Mississippi Department of Environmental Quality 12. MDNR - Mississippi Department of Natural Resources, now MDEQ 13. MERC - Mississippi Emergency Response Center 14. NAAQS - Nation Ambient Air Quality Standard 15. NESHAP - National Emission Standard for Hazardous Air Pollutants 16. NPDES - National Pollutant Discharge Elimination System 17. NSPS - New Source Performance Standard 18. OCPSF - Organic Chemicals, Plastics, and Synthetic Fibers 19. OSHA - Occupational Safety and Health Administration 20. PDS - Prevention of Significant Deterioration 21. RCRA - Resource Conservation and Recovery Act 22. RIM or RIL - Regulatory Interpretative Memorandum or Letter 23. ROL - Reactor Opening Loss 24. SARA - Superfund Amendment and Reauthorization Act 8-1 ABD00315428 ACRONYMS - (Continued) 25. SDWA - Safe Drinking Water Act 26. SMU - Solid Waste Management Unit 27. SPCC - Spill Prevention, Control and Countermeasure 28. TC - Toxicity Characteristic 29. TCLP - Toxicity Characterstic Leaching Procedure 30. TSCA - Toxic Substances Control Act 31. TSDF - Treatment, Storage or Disposal Facility 32. UST - Underground Storage Tank A 8-2 ABD00315429 RESOURCES: Environmental Department Legal Department Engineering R 6c D Tom Grumbles Joe Ledvina Bill McClain Dave Cohen Tom Heller Allen Nielsen Houston Houston Hous ton Houston Houston Houston X3445 X3446 X3278 X3548 X6886 X3308 REFERENCES: AP-42 SW-846 40 CFR FR Newsletter White Books Compilation of Air Emission Factors Test Methods for Evaluating Solid Wastes Code of Federal Regulations - Vol. 40 (10 books) Federal Register Daily "Inside EPA" "Environmental Policy Alert" "Environmental Reporter" Bureau of National Affairs TRADE ASSOCIATIONS: VI - Vinyl Institute SPI - Society of Plastics Industries CMA - Chemical Manufacturers Association SDA - Soap and Detergent Association CSMA - Chemical Specialty Manufacturers Association MMA - Mississippi Manufacturers Association LCA - Louisiana Chemical Association TCC - Texas Chemical Council MCIC - Maryland Chemical Industry Council AIM - Associated Industries of Mississippi VCSA - Vinyl Chloride Safety Association 8-3 A ABD00315430 A VIII. APPENDIX Example Environmental Situations The following pages have seven environmental situations which could happen at this plant. The steps necessary to control and report the situations follow each situation. For any environmental situation which occurs there are five steps to complete. Step one and two should be completed at the same time so that any aid needed in controlling the situation can be given. The five steps are: 1. CONTROL THE SITUATION 2. NOTIFY THE ENVIRONMENTAL COORDINATOR AND/OR THE CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OFMATERIAL RELEASED 4. DETERMINE UHAT AGENCIES TONOTIFY 5. REPORTING 8-4 ABD00315431 A 1. Rupture Disk Failure SITUATION A rupture disk on D-700 reactor prematurely fails. lift. What actions should be taken? The relief valve doesn't ACTION STEPS 1. CONTROL THE SITUATION a. Kill batch b. Recover reactor c. As soon as time permits, replace rupture disk and give blown rupture disk to Environmental Coordinator or Chief Process Engineer; in the mean time, continue with list 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. See example of next page 4. DETERMINE WHICH AGENCIES TO NOTIFY a. Because the relief valve did not lift, this incident is not a release. It is a leak which should be included in the yearly SARA 313 Emissions Report (Fugitive). 5. REPORTING a. Since this incident is not a release, there are no immediate reporting requirements. Do not forget to include pounds leaked as part of the fugitive emissions in the SARA 313 Emissions Report. 8-5 ABD00315432 A 2. Reactor Leaks to Sewer SITUATION An operator charging a reactor shuts off the high pressure service water and opens the catalyst bomb drain without shutting the automatic valve to the reactor. The reactor contents leak to the sewer. What do wo do now? ACTION STEPS 1. CONTROL THE SITUATION a. Prevent further release 1. Close automatic valve 2. Close backup manual valve is necessary b. Flush sewer with water to prevent VCM vapor cloud 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. In this situation VCM is released. A good estimate of the quantity can be obtained by the following formula: (ppm of VCM in water) x (gallons of water) x (8.34 gal/lb) 1,000,000 parts - pounds of VCM released 4. DETERMINE WHICH AGENCIES TO NOTIFY a. If pounds of VCM released is over 1 pound, the release is reportable under CERCLA 302(a) materials. b. If pounds of VCM release is under 1 pound, stop after completing 5 (a). 5. REPORTING a. Supervisor or Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 of this manual for copy of report b. Report needs to be filled out as soon as situation is under control b. Environmental Coordinator or Chief Process Engineer 1. Call the National Response Center a. 1-800-424-8802 b. Notified immediately c. Typical questions asked are located in Section 7, Page 9 of this manual d. Questions need to be answered before calling e. No written report is needed 8-6 ABD00315433 A 2. Reactor Leaks to Sewer (Continued) 5. REPORTING 2. Mississippi Department of Environmental Quality, Bureau of Pollution Control a. See Section 3, Page 2 for address, phone number and Administrator b. Send copy of report sent to EPA, Section IV 3. EPA, Region IV - send report a. Report per Regulation 61.64 (a)(3) which reads: Within 10 days of any discharge to the atmosphere from any manual vent valve, the owner or operator of the source from which the discharge occurs shall submit to the Administrator a report in writing containing information on source, nature and cause of the discharge, the date and time of the discharge, the approximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loss (the calculation of the vinyl chloride loss), the action that was taken to prevent the discharge, the measured adopted to prevent future discharges. b. This example violates Regulation 61.65 (b)(5) manual venting of gases which reads: Manual Venting of Gases. Except as provided in 61,64 (a)(3), all gases which are manually vented from equipment in vinyl chloride service are to be ducted through a control system from which the concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm (average for 3-hour period)] or equivalent as provided in 61.66. c. See Section 3, Page 2 for address and phone number and Administrator 4. Spill Prevention Report a. See Section 7, Page 9 of this manual for copy of this report b. Report must be completed before reporting to EPA 8-7 ABD00315434 3. VCM Relief Valve Lifts SITUATION A D-745 relief valve lifts caused by over pressure. VCM is emitted to the air. What now? ACTION STEPS 1. CONTROL THE SITUATION a. Kill reactor and split batch to open reactor if available b. Recover reactor that relief valve lifted on first c. Monitor VCM levels throughout the unit. Use judgement to determine if evacuation alarm is necessary d. Determine wind direction e. If release is considered to be big enough, tell people in the neighborhood via plant emergency speaker f. If levels are high evacuation of the neighborhood should be considered. This decision should be made in consultation with as many members of Plant Management as possible g. If situation is determined as emergency 1. See Emergency Plant for further actions 2. Contact LEPC or Police Department 3. Notify Mississippi Emergency Response Commission 1-800-222-6362 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. Estimate time relief valve was open using reactor pressure indication, eye witness accounts, and any other information available b. Use orifice, pressure, and time release data to estimate pounds of VCM released 4. DETERMINE WHICH AGENCIES TO NOTIFY a. If pounds of VCM released is over 1 pound, the release is reportable under CERCLA 302(a) materials. b. If pounds of VCM released is under 1 pound, stop after completing 5 (a). 5. REPORTING a. Supervisor of Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 this manual for copy of report b. Report needs to be filled out as soon as situation is under control 8-8 A ABD00315435 3. VCH Relief Valve Lifts (Continued) 5. REPORTING b. Environmental Coordinator or Chief Process Engineer 1. EPA, Region IV a. See Section 3, Page 2 for address and phone number and Administrator b. Report per Regulation 61.65 (a) which reads: Raliaf Valve Discharge: Except for an emergency relief discharge, there is to be no discharge to atmosphere from any relief valve on any equipment in vinyl chloride service. An emergency relief discharge "" a discharge which could not have been avoided by taking measures to prevent the discharge, th* owner or operator of source from which the relief valve discharges occurs shall submit to the Administrator a report in writing containing information on the source, nature and cause of the discharge, the date and time of the discharge, the approximate total vinyl chloride loss during the discharge, the method used for determining the vinyl chloride loss (the calculation of the vinyl chloride loss), the action that was taken to prevent -> discharge, and measures adopted to prevent future discharges. 2. Mississippi Department of Environmental Quality, Bureau of Pollution Control a. See Section 3, Page 32 for address, phone number, and Administrator b. Send copy of report sent to EPA, Section IV 3. Spill Prevention Report a. See Section 7, Page 9 of this manual for copy of the report b. Report must be completed before reporting to EPA A 8-9 ABD00315436 A 4. Oil on Outfall SITUATION A drum of Lube oil falls from a fork truck crossing the railroad tracks north of the 600 series silos. The barrel bursts open and oil goes into a sewer. You are in charge, what do you do? ACTION STEPS 1. CONTROL THE SITUATION a. Prevent further spill b. Prevent oil from entering sewers by use of dikes, absorbent booms or clay, or other methods available c. Determine type of sewer 1. Process a. Go to Step 2 (Notify Environmental Coordinator and stop 2. Storm a. Go to next step d. Check place where water leaves plant for oil. Even if oil is not observed, place absorbent boom in the stream e. Check Storm Water Pit to which sewer drains for oil f. If oil is present, use the following as needed: 1. Absorbent booms on outfall 2. Pump Storm Water Pit to process sewer 3. Vacuum Truck (See SPCCP Section 2, Page 25 of this manual) 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. Each situation is different. Use your best judgement. 4. DETERMINE WHICH AGENCIES TO NOTIFY a. Any oil sheen leaving the plant boundary and entering a water stream must be reported per the Clean Water Act and the Aberdeen Plant Spill Prevention Control and Countermeasures Plan; Section 2, page 16 of this manual. 5. REPORTING a. Supervisor of Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 of this manual for copy of report b. Report needs to be filled out as soon as situation is under control 8-10 ABD00315437 A 4. Oil on Outfall (Continued) 5. REPORTING b. Environmental Coordinator or Chief Process Engineer 1. National Response Center - If oil leaves the plant property. a. 1-800-424-8802 b. Notify immediately c. Typical questions asked are located in Section 7, Page 6 of this manual d. Questions need to be answered before calling e. No written report isneeded 2. Mississippi Department of Environmental Quality, Bureau of Pollution Control a. See Section 3, Page 2 for address, phone number, and Administrator b. Notify within 24 hours of incident 3. Spill Prevention Report a. See Section 7, Page 9 of this manual for copy of report 8-11 ABD00315438 A 5. Blend Tank Overflov SITUATION A blend tank overfills and slurry flows into a storm sewer. What actions are required? ACTION STEPS Any waste water that discharges outside of the plant boundary that normally goes to a process sewer is considered a bypass. 1. CONTROL THE SITUATION a. Prevent additional material from entering Storm Sewer by use of dikes, valving, or any other manner possible 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. Estimate quantity of waste water in pounds and gallons b. Estimate quantity of VCM 4. DETERMINE WHICH AGENCIES TO NOTIFY a. Under the Clean Water Act any Waste Water Bypass must be reported to the Mississippi Department of Environmental Quality (MEDQ) b. Under CERCLA 302 (a) if more than 1 pounds of VCM is released, the incident is reportable as explained in this manual under the situation REACTOR LEAKS TO SEWER 5. REPORTING a. Environmental Coordinator or Chief Process Engineer 1. Mississippi Department of Environmental Quality, Bureau of Pollution Control a. See Section 3, Page 2 for address, phone number, and Administrator b. Notify within 24 hours of incident 8-12 ABD00315439 A. 6. Acid Spill on Slag SITUATION A H2S04 truck entering the plant hits the weighscale building and breaks off a valve. The acid spills onto the concrete and slag. What would you do? ACTION STEPS 1. CONTROL THE SITUATION a. Isolate and rope off area. b. Any personnel in the area must wear protective equipment including breathing apparatus. c. Prevent further spill if possible d. Contain spill by use of dikes, damming drains and ditches, etc. e. Notify the Safety Director and Environmental Coordinator as soon as possible f. Neutralization of liquid inside containment dike 1. Dilute liquid with water to raise pH 2. Add Soda Ash (only if dilution does not work) until pH is above 6.0 3. Pump liquid in dike to Process Sewer g. Neutralization of soil/slag 1. Test pH of soil a. The soil needs to be tested to determine if it is contaminated. If the pH is greater than 5 and less than 10, no treatement is necessary. b. If the soil pH is less than 5 or greater than 10, neutralization of the soil should be done. See Environmental Coordinator for proper neutralization techniques. 2. NOTIFY ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. Estimate quantity of H2S04 that left plant boundary without being treated. Consult Environmental Coordinator for help 4. DETERMINE WHICH AGENCIES TO NOTIFY a. If greater than 1000 pounds of Sulfuric Acid is spilled on concrete and totally contained before it reaches the soil, the spill does not need to be reported to any Agency. b. If greater than 1000 pounds of Sulfuric Acid is spilled on the ground but the spill does not leave the plant boundary, it needs to be reported under CERCLA 302 (a) only. c. If greater than 1000 of Sulfuric Acid leaves the plant boundary, the spill also needs to be reported under SARA. 8-13 ABD00315440 A 6. Acid Spill on Slag (Continued) 5. REPORTING a. Supervisor of Area in which release occurred 1. Spill/Release Report a. See Section 7, Page 8 of this manual for copy of report b. Peport needs to be filled out as soon as situation is under control b. Environmental Coordinator or Chief Process Engineer 1. In-Plant Spill PreventionReport a. See Section 7, Page 9 of this manual for copy of report CERCLA 302 1. (a) National Response Center a. 1-800-424-8802 b. Notify immediately c. Typical questions asked are located in Section 7, 6 of this manual d. Questions needs to be answered before calling e. No written report is needed Page SARA 1. Emergency Coordinator, Local Planning Committee a. Immediate notification Jerome Husky (601) 369-6439 b. Written notification A written follow up emergency notice is also required setting forth and updating the information required to be reported in the verbal report and to include additional information with respect to: 1. Action taken to respond to and contain therelease. 2. Any known or anticipated acute or chronic health risks associated with the release, and 3. Where appropriate, advice regarding medical attention necessary for exposed individuals. This written report is to sent to Emergency Coordinator of the Local Emergency Planning Committee and to W. E. Austin, Special Projects Office, SARA Title III, Mississippi Emergency Response Commission, P. 0. Box 4501, Fondron Station, Jackson, Mississippi 39216-0501. The written report should be submitted within ten days as a maximum. 8-14 ABD00315441 A 7. Waste Water Permit Violation SITUATION The test results from EnviroLab returns with a BOD of 45 ppm at Outfall 001 (Pond 6 effluent). What should we do? ACTION STEPS 1. CONTROL THE SITUATION a. At this point there is not much that can be done since the BOD test is a five day test (results are 5 days old when they are reported to us). b. Make sure all the aerators are on and check for any visible oil. c. Investigate why the BOD is high. Were there any spills? d. The daily max values are not as important to the EPA and MDEQ as the monthly average. To decrease the monthly average, take extra (more than one a week) samples while the BOD level is below the monthly permit level. 2. NOTIFY THE ENVIRONMENTAL COORDINATOR AND/OR CHIEF PROCESS ENGINEER 3. DETERMINE QUANTITY OF MATERIAL RELEASED a. The ppm of BOD in the Outfall 001 is reported by EnviroLab, 1-3237744, our contact is Bob Schubert. The co-op process engineer receives results every Monday. 24 hours composites are samples from Tuesday morning to Wednesday. b. The pounds/day of BOD in the stream 001 is calculated by: pounds/day - ppm x GPM x 0.012017 The GPM of the Outfall 001 can be obtained from the totalizer located at the outfall and Che coop keeps a record of these results. 4. DETERMINE WHICH AGENCIES TO NOTIFY a. Since 45 ppm is above the permit limit of Outfall 001 (see p. 4-29), it is necessary to contact the State of Mississippi Byreau of Pollution Control, Industrial Water Section. Be sure to check the BOD pounds/day and COD pounds/day for compliance before reporting. 5. REPORTING a. Environmental Coordinator 1. NPDES Monthly Report 8-15 ABD00315442 A TECHNICAL INFORMATION COMMUNITY HEALTH EFFECTS 0P VINYL CHLORIDE Prepared Byt The Vinyl Institute Health, Safety, & Environment Cnaaittee Issuedt August I, 1986 8-16 The Vinvi Institute. A Division ol Tht* Sriniorv nt P'pefr? imiustrv inr ABD00315443 I. SUMMARY This document reviews the toxicity and human health effects of ambient exposure to vinyl chloride (VC), the raw material used in the production of polyvinyl chloride (PVC). It summarises the extensive and rigorous federal regulation of the VC/PVC industry, and compares quantitative risk assessments with actual health observations of Individuals in non-occupatlonal settings* A review of the world scientific literature shows no community health Impacts associated with exposure to VC emissions from VC/PVC manufacturing facllltlss* II. INTRODUCTION Vinyl chloride la the basic building block for producing the most versatile plastic yet developed -- polyvinyl chloride and lea copolymers with other monomers. Most of the seven billion pounds of VC produced annually In the United State* la converted Into PVC used In thousands of products in the home and in Industry ** products such ss wallcoverings, upholstery, flooring, house siding, wscer pipes, sewer pipes, luggage, clothing, automotive parts, medics! devices, food wrap, windows, doors, wire insulation, garden hoaee, and phonograph records. PVC Is a polymer produced from VC through a chemical reaction called polymerisation. VC is converted into PVC by suspension, emulsion, bulk or solution polymerisation methods. PVC resins can be extruded, molded or calendered into diverse shapes, sires, and colors* Mechanical characteristics can be controlled to produce forms that sre rigid, flexible, or in a liquid fora such as latexes, pastes, and adhesives. Vinyl chloride became of Industrial Importance approximately fifty years ago when Semon (1933) discovered that the polymer could be converted into ueeful articles by plasticization with phthalaee esters. Commercial development began first In Europe and then in the United States in the late 1930's. It was not until the early 1950's that widespread consumer applications developed. PVC is now a mature product, and its grovth ret* falls in stap with the Gross National Product. III. HEALTH HISTORY Acuta Toxicity Vinyl chloride it a strong anesthetic at 8*12% in animals and humans* Daeth follows rapidly after unconsciousness sets in if exposure is not rnduemd quickly (Patty et al, 1930). No major histological changes ware reported after 100 days at exposures of 50,000 ppm (Kuebler, 1964). Reversible liver effects at 100-500 ppm lad to a recommendation of a 50 ppm TWA exposure limit (Torkelson, Oyen, end Rove, 1961), buc the American Conference of Governmental Industrial Hygeniata adopted instead a recommendation by Yala scientist* of 500 ppm* This ie the value later accepted by 08HA and it served until 1974. Lehman and Plury (1943) termed vinyl chloride to be "one of the least dangerous of the chlorinated hydrocarbons". 8-17 ABD00315444 CooRunlty Health Effects of Vinyl Chloride P|a Tiro There ere no other known Acute human physiological effects from vinyl chloride exposure. The odor threshold la about 1,000 ppm. The high heat of vaporisation causes a substantial part of a large spill to liquify and presents the danger of frostbite. Vinyl chloride is flameble over Che range of 3.6-33T in air, and extreme care must be taken to avoid spills and leaka for that reaaon. Host measurement and warning systems were deslgnad to hold plant ataoapherea below the flammable limits. Retrospective estimates of typical Clme~velghted average personal exposures for polymerisation workers In England have been estimated (Barnes, 1980) as follovat 1945 to 1955 1955 to 1960 I960 to 1970 Mid 1973 1975 1,000 ppm (or above) 400 to 500 300 to 400 150 5 In soma jobs, particularly the cleaning of polymerisation reactors, exposures in the thousands of ppm range were experienced for short periods. (See Purchase, et al, 1985 and Barr, 1986 for reviews of Che toxicity of VC). Chronic Health Effect! The first clear Indication of chronic health problems assoclatsd with VC came In the 1960's in men who entered VC polymerization reactors co remove build-up of polymer from the walls. Some of these men developed aero-osteolysis, a disease resulting in softening of bones in the fingers (Suciu, et al, 19631 Harris and Adams, 1967 * Cook, et al, 1981). Modification of working practlcaa has led to the elimination of this disease in workers In PVC plants. In tha late 1960's, Professor P.L. Viola of the 8olvay Company tried to reproduce acro-osteolysia in rats by exposing thsm to high concentrations of VC for long periods. He failed to produce acro-ostsolyfIs, but hs reported an increase in incidence of a variety of tumors at virions sites. For the first time, it had been suggested that VC was an animal carcinogen. (Viola, 1969, 1970; Viola, Blgotti and Caputo, 1971). As a direct result of tha Viola work, four West European VC/PVC menufeetaring companies in Italy, France, Belgium, and England supported a comprehensive study of the animal toxicology of VC by Professor C. Hal tool, Director of the Institute of Oncology at Bologna. Maltoni's work which extended over eight years has proved to be the moat comprehensive study of VC toxicology (Meltool et el, 1984). By the end of 1972, Maltoni had found a rare tumor, angiosarcoma of the liver (ASL)., in some of tha exposed rats and confirmed that VC Is Indeed an animal carclnogan. These early findings ware reported at an international symposium in 1973 (Maltoni, 1977). Maltoni recommended epidemiological investigations and medical controls of exposed workers and early in 1974, a U.S. company announced that they had found three ASL cases in employees at one of their PVC polymerization plants. This finding lad to tha conclusion chat VC was a human carcinogen bocauaa it gava rise to a rare tumor whose only other known etiological agents in man were thorium dioxide, arsenic and possibly anabolic steroids. 8-18 ABD00315445 - * _-wC' ~oti rue. Coaosunity Health Effects of vinyl Chloride Page Three ASL l* a very rare tumor. Less chan 20 caaea per year from all these cauaaa occur in this councry. A review (Popper, at al, 1978) of all case* reported In the United States for the period 1964-197A revealed 167 case*, of which 19 were ascribed at that tine to occupational VC exposure, 26 to thorium dioxide given medically, and 9 to arsenic in Fowler's solution, also used medically. Tha remainder were of unknown etiology, with no connection to VC. The high level of lntereat In chla specific tumor is such that any^ subsequent caaea associated with environmental exposure to VC would moat certainly have bean reported, and none have. For a doe, NIOSH published a sunaary of VC-related cates (Falk, ec al, 1981), but this task was taken over first by John Stafford of 1C1, England (Foreman, et al, 1985) and later by Brian Bennett also of IC1. The 1986 update of VC-related ASL cases shove a total of 38 cases In the United States and 120 worldwide. All of these caaea Involve high occupational exposures to VC. The average ASX. latency period (years from first exposure to diagnosis) In the United States has been 25 years, but with a median of about 22 years. The latency period In Europe, particularly in Cermany, has been somewhat shorter, approximately 19 years. All the U.S. occupational caaea, and almost all such caaea in the rest of the world are cloaely associated with tha job of reactor cleaning, which was once done manually at the end of tha polymerization cyeie. There la clustering of caaea in relatively few plants and the majority of plants have had no caaea. Differing work programs and Job progressions may have had some effect on reducing rates at various plants. An Industry-sponsored epidemiological survey of workers In the VC/PVC Industry covered 6,384 men with at least one year of exposure before 1973 (Tabarshaw and Ctffey, 1974). The expectedexceaa of ASL was found. There vera also suggestions of an exceaa of cancers at other sites. This study was expanded to 10,173 workers (Cooper, 1981), where suggested excess of brain and respiratory' cancers continued to be seen without, however, an association between the brain cancer and exposure. In addition, moat of the lung cancer caaea come from ehe same facility, with many plants having no caaaa* A follow-up study of this expanded cohort to determine the status of tha workers as of the end of 1980 la underway. Several studlaa have been made of the general population using ASL as tha marker disease In an effort to detect an association with poaeibla environmantal exposure to VC. There was no association with living near a plant manufacturing or using VC in the general U.S. survey conducted by the Center For Disease Control (Popper et al, 1978i Falk, et al, 1981). Brady et al, (1977) surveyed 26 ASL deaths in Hew York Stata between 1970 and 197S, and found five who lived nearer plants handling VC than did their matched controls, but could not establish a direct connection with the dleeeee to exposure. Ten cases of ASL In Wisconsin were examined for poeelble connection with VC exposure, and none was found (Fiechtner et al, 1976). Baxter ec al, (1977) found no relationship between distance of residence from VC emitters and the 47 cases of ASL in the general population of Greet Britain reported in 1963-1973. A later update (Baxter et al, 1960) found one case where the person had lived the last six years of his Ufa near a PVC plant and three caaea where the men had worked in the plasties fabricating industry but for whom thara were no records to indicate exposure to VC. 8-19 ABD00315446 Cornualt> Health Effect* of Vinyl Chloride Pege Four The leek of reletlonehlp between residence neer vinyl chloride operation.! end cases of unknown etiology was confirmed. Serlc et el, (1976) studied the death* during the years 1968*1971 in an area surrounding a PVC plant that: had been in operation since 1949 and in which ehrae workers had died of ASL. No relationship was found for liver or for lung or bronchial cancer and place of residence for the general population. A similar study for communities neer a Swedish plane that had operated since 1945 end had found^ four ASL cases showed (Blinder and Pershagen, 1978) no unexpected elevation of fetal mortality, deaths from all cancers, or cancer of the liver or lunge during the years 1961-1974. Pancreatic cancer In males was elevated in the age group over 60. All ASL cases in Holland since 1950 (27 esses) vara studied, and none had any traceable contact with VC (Dalderup et al, 1976). Iturra (1976) observed sn excess of cancer deaths In s city in Canada with a PVC plant compared to a similar nearby city. This differanca vaa principally found In males aged 20 to 64, which is not indicative of a general pollution effect. The author drew no conclusion as to why the condition existed. Representatives of the Environmental Protection Agency have stated that It hat bean unable to establish a link between living near VC manufacturing and using plants and ASL. There are about 20 caacs of ASL per year In the United States that cannot be ascribed to one of the known causes of the disease. There are alao about 5 In Europe each year. Accordingly, there will be one case of ASL among the 5 million - 5 mile neighbors of VC/PVC facilities about every two yaara by chance alone. Thla has been seen in the studies in New York by Brady, et al, (1970), and in Connecticut (Heath and Landrlgan, 1974). Thaao states have cancer registries, which are of great value. In one case, s Jury award vaa made to the estate of sn individual who died of ASL, and who had lived the last four years of his life near a PVC plant. Inasmuch as that person alao had occupational exposure to VC and exposure to oehor ASL causative agents, It cannot be concluded that ambient VC exposure caused hla ASL (In re Crasso, Civil Action No. 78-1562, D.N.J.). A thorough study (Chlasse, et si, (1977), Chlaaae, (I960)) of more than 15,000 employees of PVC fabricators found no evidence of VC-related health effects in that group, which was estimated to have been exposued to at least 15 ppm VC for many years. The disease ASL la often difficult to diagnose (Block, 197.4| Heath, Flak and Creech, 1975), Is almost invariably fatal within a abort time, and presents a variety of symptoms, including portal flbrosla and hyparcanalon with splenomegaly and varices, proliferation of the sinusoidal lining, megalocytosle, and thrombocytopenia (Thomas and Popper, 1975) Cedigk et al, 1975). Hetastasls is frequently Involved. These symptoms art very similar to those seen In the mouse (Sehaffner, 1976) and rat (Paron and Kreea, 1979)and the pathology also la similar (Cordon et al, 1975). No raally adequate early warning testa have been devised (Whelan et al, 19761 Langbein et al, 1983t Tamburro and Creenbsrg, 1981), although the gammaglutamyl transpepaidasa test is promising, togethtr with ICO clearance and SCOT. Radiographic livsr scans and tomography and sonography (Koitchvltf at al, 1981) art said to be useful confirmatory casts. 8-20 ABD00315447 Community Health Effects of Vinyl Chloride Page Five In sussaary, VC is a classical procarcinogen, and Is clearly e human carcinogen, causing ASL In c small percentage of highly exposed workers. There la suggestive evidence that it may be a weak general carcinogen at high concentratlona, perhaps through an immunosuppreaaive mtchsnlsa, but store data are required to confirm this suspicion. Several studies of large populations have not shown p connection between general ambient exposore and an Increasad incidence of cancer. ^ IV. FEDERAL REGULATION OF VC/PVC INDUSTRY The primary federal agencies regulating the VC/PVC industry are the Occupational Safety and Health Administration (OSHA), which is part of tha U.S. Department of Labor, the U.S. Environmental Protection Agency (SPA), and tha Food and Drug Administration (FDA). OSHA regulation focuaas on worker health while EPA addresses the control of chemicals outslda tha workplace. FDA oversees uses of PVC that Involve foods, drugs, cosmetics, and medical devices. A. The Occupational Safety and Health Administration The allowable occupational exposure for vinyl chloride of 1 ppm on an 8-hour time weighted average (TVA) la set by the OSHA workplace standards at 29 C.F.R. 1910.1017. This was adopted In 1974, after extensive public heeringe, and became effective in April 1975. OSHA first set an emergency temporary standard of 50 ppm and proposed a permanent limit of nondsteeteble exposure by a test sensitive to 1 ppm. OSHA then promulgeted a final standard of an 8-hour TWA of 1 ppm, and a 15-mlnuta celling of 5 ppm. In brief, the regulation sates 1. A level of 0.5 ppa VC below which no action Is required. This generally exempts moat PVC fabrication planet and laboratories and many monomar plants. 2. A regulated ares where exposures are above 0.5 ppm which restricts entry to authorised persons. 3. Medical examination requirements and exposure record retention for specified employees. 4. A list of acceptable respirators. 5. Monitoring and alarm systems for the workplace, and tontine measurement of worker exposure. 6. Labeling and signsfor regulated areas and containers of vinyl chloride and PVC. 7. Work procedures for hasardous operations. 8. Training programs for employass. 8-21 ABD00315448 A Coooonicy Health Effects of Vinyl Chloride ?! 8lx 08HA Also has A HASArd Communication Standard (HC3), 29 C.F.R. 1910.1200, which provide* labeling requirement* complementAry to the OSHA Vinyl Chloride Standard. Articles mads from PVC are exempt from labeling requirements under che standard. B. Environmental Protection Agency 4 EPA regulates the release of vinyl chloride under several statutes, including the Clean Air Act, Clean Water Act, Safe Drinking Water Act, Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund), and the Toxic Substances Control Act (TSCA). 1. Air Standard (40 CFR 61.60) The EPA standard established in 1976 specified the following conditionsi a. Fugitive emissions controls by leak patrols and design standards for pump and compressor seals, agitators, and loading devices. b. Work practice# for vestal openings and sampling. e. Stripping requirements for residual monomer in realms and wastewater. d. Abatement of specified point source emissions to 10 ppm. e. Prohibition of relief valve discharges, except for emergencies, f. Extensive monitoring, reporting and recordkeeping requirements, g. Specific analytical procedures. EPA estimated that this standard would result In a 95% reduetlon of VC emissions to the atmosphere from VC/PVC manufacturing plants and reduce the 5 mils annual average VC ambient air concentration from 17 parts per billion (ppb) to less than 1 ppb. 2. Water Raeulationa Vinyl chloride is listed as a priority pollutant under Section 307(a) of the Clean Water Act, and a Water Quality Criteria Document hae been prepared. This subjects VC and PVC manufacturing plants to special considerations whan waste water discharge permits are leaned pursuant to EPA regulations. As part of its regulation of carcinogcna in drinking water, EPA hae published a final Rteomended Maximum Contaminant Laval (KMCL - a non-binding guideline) for VC in drinking water of taro (see 50FR 46860, Nov. 13, 1985 for this amendment to 40 CFR 141,50.) 8-22 ABD00315449 Community Health Effaces of Vinyl Chloride Plf.t Seven However, EPA Indicated that a "Justifiable" way to determine Che absence of vinyl chloride would be by setting a defined* tete-of-the-art detection limit sensitive to approximately l ppb. (49FR 24,330, 24,347 - June 12, 1984). EPA hae also proposed a maximum contaminant level of 1 ppb for vinyl chloride In drinking water. (See SO FR 46,902 - Nov. 13, 1985). 3. Waste and Spill Regulation 0 The EPA laaued a rule under which certain VC manufacturing distillation residues are listed as hatardoua wastes when disposed (49 7R 5306). This rule requires chat all auch wastes are to be disposed of only by RCRA-approved procedures. When disposed of, commercial grade VC la claealfled as a hatardoua watte under Che Resource Conservation and Recovery Act (RCRA), because of its toxic and lgnltable characteristics. Any disposal is subject to regulation under RCRA. EPA has proposed additional RCRA regulations (51 FR 21646, June 13, 1966) which apply to all wastes containing VC. These proposed regulations define waates as hssardous when the VC level in the extract by a specified teat method exceeds 50 ppb. Congrooi has specified an Interim 1 pound reportable quantity for vinyl chloride. Releasee to the environment in excess of 1 pound are regulated under CERCLA. 4. New Product Manufacture The EPA also administers the Toxic Substances Control Act (TSCA) which establishes health end environmental regulations for boch new and existing substances. No one may msnufscture or use s substance which is not on the Agency's official inventory, unleaa the Prssanufacturlng Notice procedure# are followed. C. Food and Drug Administration PVC is widely used for food contact applications. In early 1988* the Pood and Drug Administration (FDA) confirmed the safety of PVC for ail food-contact applications and withdrew an outstanding proposal to limit Its uao In food packaging. (See 51 FR 4173 - February 3, 1986). An accompanying new proposal would set various rssldual vinyl chloride levels for different food contact materials. Among other things* FDA found chat "vastly Improved production technology (since 1975) has made It possible for manufacturers to succeed in reducing the level of residual vinyl chloride monomer in vinyl chloride polymer." The comment period on the February 3, 1986 FDA proposal closed on June 5* 1986 without any advene comments on the health or safety of PVC. This PDA proceeding lends further supporc to the Inherent safety of human exposure to PVC. FDA regulates the use of PVC In medical davicss and drug packaging on s case-by-caae basis. 8-23 ABD00315450 rA Community Health Effects of Vinyl Chloride Peg* Eight V. COMMUHITT HEALTH CONCBAN8 As wss discussed In Section IV, VC is very atrictiy regulated substance* The EPA estimated that the 1976 standard would reduce the annuel average exposure of the persons living within 5 miles of VC/PVC facilities by 951 (from 17 ppb to about 0.85 ppb<) An EPA report (1985) states that currant* industry performance has resulted In actual emissions that are significantly lees then that predicted amount. Many authors have attempted to develop quantitative risk asseeanenta for lov level exposures to VC. (See Barr* 1982 and Purchase* 1985 for review). Some have incorporated human data (Cehring, et al, 1979, Anderson, at el, I960, Purchase, et al, 1985) and only these predict results vhleh era compatible with the absence of any observed effects on humans from ambient exposures. The remaining estimates all used variations of the EPA upper limit model (Anderson, 1983) and overstate the probability of risk by several orders of magnitude. There la no confirmed case on record in which a member of the general population has been harmed by exposure to vinyl chloride. That feet sate the upper limit of lifetime risk at leas than 0.3 predicted cesea of cancer per l million for expoaure to 1 ppm of VC. Because the data show that Industry ealaslona have been reduced by 99.99% (rather then the 95X eatimated by EFA), the actual risk la leee than 0.1 case of cancer In tha name 70 yeara among tha 5 million presumed to be exposed to VC from living within 5 alias of a VC/PVC facility. Dr. Richard Wilson of Harvard (1979) has attempted to help people understand this method of stating the rlska of every day occurrences. Each of tha following activities for example, Is predicted to result in one death par million peoplei smoking 1.4 cigarettes (due to cancer, heert diacaae)| drinking % liter of vine (due to cirrhosis of the liver)t traveling 6 minutes by canoe, 10 miles by blcyle, 300 miles by car, or 1,000 miles by Jet (dun to an accident)i and having one cheat X-ray taken in a good hoapltal (due to cancer caused by radiation). We conclude, therefore, chat chare is no basis for concern by persona living near VC-uaing or producing facilities for any health effects from exposure to ambient concentrations of VC now being experienced. 8-24