Document xB69pX7QXKNKKGJKza0E0g3g

1 TOC P&M Environmental Affairs (COMPANY) INTEROFFICE COMMUNICATION TO: FOR: FROM: RE: Tenneco Polymers Dennis Hersh R. D. Pruessner ENVIRONMENTAL REVIEW DATE: February 23, 1984 Your approval is requested for scheduling the Environmental Review,, of the Flemington Plant and affiliated wastewater treatment facilities on April 24-27, 1984. le proposed agenda and Environmental Review forms are attached. It is requested the forms be filled in prior to the arrival of the review team. pm Enclosure cc: Pat Anderson Charles Beresford Guy Disch Walt Fogelsanger Jim Kachtick Fred Kanzler Jim Langford Ralph Maynard A1 Smith R. D. Pruessner RECEIVED FEB 23 1984 L UGAL-P& M TEN0 314 AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - FLEMINGTON PLANT April 24-27, 1984 TUESDAY, April 24 7:35 a.m Depart Houston Intercontinental on Eastern 560. 11:18 a.m. Arrive Philadelphia airport. Obtain large Avis rent car and drive to Flemington, New Jersey. About 4:00 p.m. Check in Bel Air Motel on Highway 202 in Flemington. 6:30 p.m. Supper for the Review Team and Polymer representatives at The Rustic Inn. Walt Fogelsanger will make reservations for 5 people from Houston and the plant staff. It is requested representatives of Tennece Polymers Research be invited to the supper. WEDNESDAY, April 25 8:00 a.m. Meet with Dennis Hersh to conform final plans for Environmental Review. 8:15 a-m. Meet with Walt Fogelsanger and staff to go over the information contained in completed Environmental Review forms. 11:30 a.m. LUNCH (Please bring in sandwiches.) 1:00 p.m. Meet with Walt Fogelsanger for plant tour. 3:00 p.m. Visit Raritan township wastewater treatment facility. 4:00 p.m. Adjourn 2/23/84 TEN0 315 (( AGENDA ENVIRONMENTAL REVIEW Termeco Polymers - FLEMINGTON PLANT April 24-27, 1984 THURSDAY. April 26 8:00 a.m. Review records, proposed N3DEP permit and Polymers proposed plans on groundwater monitoring and corrective actions, if any. 11:30 a.m* LUNCH (Please bring in sandwiches.) 1:30 p.m. Review records on wastewater discharges and selfreporting. 2:30 p.m. Review toxic volatile organic emissions compliance program. 3:30 p.m. Review Team prepare draft conclusion. FRIDAY, April 27 9:00 a.m. About 10:30 a.m. 12:30 p.m. 2:00 p.m. 4:53 p.m. 7:15 p.m. Meet with Dennis Hersh and staff to review proposed findings and complete the final report. Provide copies of completed report to Walt Fogelsanger, Jim Langford, Jim Kachtick, Guy Disch, and Bob Pruessner. Complete Environmental Review. Visit with Bob Miller for a tour of the Tenneco Polymers Research facilites. LUNCH (Please bring in sandwiches.) Depart for Philadelphia airport. Catch Eastern 551 for Houston. Arrive Houston. 2/23/84 -2- TEN0 316 ( T EN N ECO OIL P&M FACILITIES ENVIRONMENTAL REVIEW Tenneco Polymers - FLEMINGTON PLANT POLYVINYL CHLORIDE FACILITIES 2/22/84 ' TEN0 317 TENNECO OIL PAM ENVIRONMENTAL REVIEW Name and address of facility! Tenneco Polymers Flemington Plant P. O. Box 129 Flemington, New Jersey 08822 April 24-27, 1984 Affiliated with; Tenneco Oil P&M Operations Manager: Dennis Hersh_______________ (Name) __ Environmental Representative; Manager (Title) ______________________ Walt Fogelsanger___________ (Name) Plant Engineer____________________ (Title) " Type of operation and/or principle products; Polyvinyl Chloride (201) 782-4011 (Phone) (201) 782-4011 (Phone) Review Team: Name Bob Pruessner FredKanzler Charles Beresford Pat Anderson Jim Kachtick Title Mgr.Environmental Affairs-TOC Environmental Coordinator-TOC Attorney - TOC(713) Mgr.Environmental Audits-TEN Mgr-Environmental Sciences-TOC Phone (713) 757-3306 (609) 386-2213 757-8764 (713) 757-3604 (713) 479-3411 2/22/m TEN0 318 I( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT ENVIRONMENTAL STAFFING 0) Please show the reporting relationship between individuals directly responsible for environmental compliance and the senior manager associated with this facility. (Add blocks as necessary.) Name Jim Langford________ Title Director of Operations Name Title Name Title Name Title Name Title 2/28/83 TEN0 319 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT ENVIRONMENTAL STAFFING (2) Please list names and title of persons dedicating a significant portion of their time to environmental compliance. This should include those persons responsible for operating environmental control equipment, conducting laboratory environmental analysis, etc. NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:_____________________ Name TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:_____________________ NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:_____________________ NAME TITLE Approximate percentage (%) of work time dedicated to environmental: Brief description of environmental responsibility:__________________ --------------------------------------------------------------------------------------------------------------------TENO 320 12/8/82 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (1) NPDE5 Permit No.: Date Issued: Date Expires: Other Water Discharge Permits: Date Issued: Date Expires: Discharge permit requirements: Outfall Number(Add additional sheets as necessary.) Permitted Avg Max Typical Actual Avg Max No. of Self-Reporting Violations-Last 12 Mos. Flow BOD Oil & Grease Type of Waste Water Treatment System: Method by which sanitary waste water is treated: Who is treating sanitary waste? __ Sanitary Waste Water Permit No. Issuing Agency:Expiration Date: 12/8/82 TEN0 321 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (1A) RARITAN TOWNSHIP MUNICIPAL UTILITIES AUTHORITY NPDE5 Permit No.: Date Issued: Date Expires; Affluent (Flemington discharge to RTMUA) Permit Requirements; Permitted Avg Max Typical Actual Avg Max No. of Self-Reporting Violations-Last 12 Mos. Flow, MGD TOC. Lb./D COD, Lb./D BOD. Lb./D TSS, Lb./D O&G, Lb./D Cr, Lb./D EH________ Temp. F What percent of RTMUA's total influent does the flow from the Flemington Plant represent? Annual cost of using RTMUA 12/8/82 TENO 322 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMING TON PLANT WATER (IB) Effluent (RTMUA Discharge) Requirements: Permitted Avg Max Typical Actual Avg Max No. of Self-Reporting Violations-Last 12 Mos. Flow, MGD TOC, Lb./D COD, Lb./D BOD, Lb./D TSS, Lb./D O&G, Lb./D Cr, Lb./D Phenols, Lb./D EH Temp. F Total number of RTMUA's self-reporting effluent violations in last 12 months? 2/3/83 TENO 323 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (2) Date and significant findings of last regulatory inspection: Please attach copy of regulatory inspection report. Do any discharge permits contain a compliance schedule? YES NO N/A ____ ____________ Is the facility meeting the compliance schedule? FLOW AND pH In matters relating to flow, do procedures used conform to the "water measurement manual" (U.S. Dept, of Interior, Bureau of Reclamation) or other procedures approved by the E.P.A? Primary flow measuring device properly installed? Primary flow measuring device properly operated and maintained? Is primary flow measuring device calibrated? (Last calibration date: ) Secondary instruments (totalizers, recorders, etc.) properly operated and maintained? Are continuous pH recording instruments calibrated with pH buffer solutions? Frequency: _______ __________________ _ Are the date, time, and the name of the person who calibrated the continuous pH recording instrument recorded? In a book?___ On the chart?___ Are calibration and maintenance records kept for 3 years on pH and flow measurement equipment? Are pH and flow measurement data kept for the required threeyear period? SAMPLE COLLECTION AND PRESERVATION Permittee sampling meets requirements and intent of permit? Details: ____ 2/3/S3 TENO 324 ( TENNECO OIL P*M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMING TON PLANT WATER (3) Permittee is using method of sample collection required by permit? If not, explain method used and the frequency of sampling: _____________________________ YES NO Sampling locations adequate for representative samples? Parameters and sampling frequency agree with permit? Flow proportioned samples obtained where required by permit? Are composite samples refrigerated at ^C during collection? Are grab samples refrigerated as soon as possible after collection? Are samples labeled as to location, composite or grab, date and time of collection, and sampler? Are samples collected in the authorized containers for each parameter? Are approved preservatives used for each parameter, when needed? When samples must be preserved, are they preserved at the time of collection? Are samples analyzed within required holding times? Is the laboratory refrigerator for sample storage kept at 4C? When samples are not to be analyzed immediately in the lab, are they refrigerated at 4C? Are approved cleaning procedures followed in the laboratory for sample containers that are to be reused? LABORATORY METHODS Are EPA approved analytical testing procedures used?(40CFR 136.3) If a different procedure is used, has written approval been received from the necessary regulatory agencies to use this alternate procedure? If part of an approved procedure is changed by you, has written approval been received from the necessary regulatory agencies for this change? Are monitoring and analyses being performed more frequently than required by permit? If YES, are results reported in permittee's self-monitoring report? 12/12/83 TENO 325 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (4) Are parameters other than those required by the permit analyzed? Are the methods used stated on the laboratory report sheet? YES NO N/A LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL Who is responsible for Laboratory Quality Assurance Program? Are duplicate (precision) samples analyzed with each set of analyses? Frequency: Are spiked (accuracy) samples analyzed with each set of analyses? Frequency: Are precision control charts prepared and used? Are accuracy control charts prepared and used? Are intralaboratory quality control standards used for each permit parameter? Frequency: Is satisfactory calibration and maintenance of laboratory in strument and equipment performed? Are laboratory equipment calibrations and maintenance records kept for the required three-year period? On analyses which require standards to be used in preparing calibration curves, are the curves prepared by using a blank and at least seven standards? On analyses which require calibration curves or internal in strument calibration with standards, are blanks and standards analyzed with each set of samples in order to verify the calibration curve? Are temperatures recorded on ovens(TSS) and incubators (BODs)? Frequency: ________________ Are laboratory analytical balances checked using NBS weights? Are glucose-glutamic acid standards analyzed with each set of samples analyzed for BODs? Is Class A volumetric glassware used for permit-required analyses? 12/27/S3 TENO 326 THNNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (5) LABORATORY DATA REPORTING AND STORAGE Are the following recorded on the laboratory report sheet: Sample location? Composite or grab? Date and time of collection? Sampler? Date and time analysis started? Analyst? Are sample results kept for the required three-year period? Are quality assurance and quality control records kept for the required three-year period? Commercial laboratory used? Commercial laboratory state certified? Weeds cut and vegetation growth in ponds removed? Banks and dikes maintained? (Erosion, etc.) Any reports of groundwater contamination from pond(s)? If YES, give details: Seepage reported? Adequate freeboard (2 feet) to prevent overflow? Effluent release is: Continuous Intermittent _____ Seasonal 12/12/83 TENNECO OIL P*M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (6) What is the receiving stream? Is there a formal Spill Control Plan (SPCC)? Has the SPCC been approved by management? Is the SPCC certified by a registered engineer? Has the SPCC been reviewed and updated within the last 3 years? Have there been any reported spills the prior 12 months? How many? Total amount of spill: If more than 2 reported spills within the last 12 months, has the SPCC been revised and certified by a registered engineer? Is a training program existing to instruct personnel in operation and maintenance of spill control equipment? Are briefings scheduled to insure adequate understanding of the SPCC plan by company personnel? 12/12/83 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT WATER (7) YES NO N/A How is storm water treated? What is the design basis for storm water treatment? Do existing discharge permits have storm water requirements? What are the requirements? 12/12/83 TENO ,329 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS(NESHAPS) (I) YES NO N/A What type(s) of PVC resin is produced: Dispersion resin Suspension resin Bulk resin Does this plant have a fixed vinyl chloride monitoring system in place to continuously monitor VCM emissions? Do exhaust gasses meet the less than lOppm VCM limit? What sort of control devices are used to reduce VCM exhaust gases to lOppm or less? How many relief valve discharges were reported in the last 12 months?___ Where did relief valve discharges go?___ Flare ___ Atmosphere Other Were they reported within the required time (10 days)? _____ FUGITIVE EMISSIONS FROM EQUIPMENT IN VCM SERVICE Are loading and unloading lines in VCM service degassed thru a control system before opening? _____ Are slip gauges used in the VCM loading/unloading operation? _____ Are slip gauge emissions reduced via a control system? _____ If controlled--what is the control mechanism? Are all pumps either sealless, have double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? Are all compressors equipped with double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? Are all agitators equipped with double seals or equivalent? a. Positive pressure maintained between seals? b. Double seal interspace vented to a control system? c. Other____ ____ 12/27/83 TENO 330 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NE5HAPS) (2) Are relief valves connected to a process line, recovery system, or equivalent? If not, are they equipped with rupture discs? YES NO N/A _____ ___________ _________________ When sampling, are sample containers purged into a closed process system? Are unused portions of samples (10% or more VCM by weight) returned to the process? _________________ _________________ Is the VCM content of equipment reduced as required before opening to atmosphere? _____ ____ ____ Does this plant have a formal leak detection and elimination program? _____ ____ ____ a. Has the program been approved by the EPA Administrator? _________________ b. What is the plant definition of a "leak"? Is the VCM content of "in process wastewater" reduced as required? _____ ____ ____ Does this plant have Standard Operating Procedures incorporating the VCM fugitive emission requirements? _____ ____ ____ Are emissions data reported in Semiannual Report as required? _____ ____ ____ How many reported exceedances were there the last 12 months for: a. Residual VCM content of stripped PVC slurry? What percent is this of total reported values? b. Reactor opening emissions? What percent is this of total reported values? c. Incinerator VCM emissions greater than lOppm? What percent of incinerator operating hours? Is record keeping performed as required? a. Are records kept two years? b. Are they destroyed after two years? _____ ____ ____ _____ ____ ____ _____ ____ ____ 10/27/82 TEN0 331 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT AIR (1) List air construction permits or permit exemptions obtained in the last 12 months: Description of Permitting Permit Unit Agency Control Allowed Device Emissions Date Issued 1. __________________________________________________________________________ 2. 3. _____________________________ ____________________________________________ 4. 5. - --------------------------------------------------------------------------------------------------------------------------- 7. List air operating permits presently in force: Description of Date Expiration Allowed Monitoring Reporting Permit Unit Issued Date Emission Requirements Requirements 1. 2. _____ 3. 4. 5. _ 6. _________________________________ _ 7. 8. 9. 12/8/82 TENO 332 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMING TON PLANT AIR (2) When was the last air regulatory inspection? ______ Please provide a copy of last inspection report (Date). . Describe any noted deficiencies and the corrective action taken: DEFICIENCY CORRECTIVE ACTION 1. ___ 2. __________________________________ 3. ___________________________________________________________ 5. _________________________________________ 6* _____________ ___ 12/8/82 TENO 333 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT AIR (3) When was the last air emissions inventory? List reported emissions rates: 1. Hydrocarbons 2. Sulfur Dioxide______________________ 3. Nitrogen Oxides 4. Carbon Monoxide___________________ 5. Particulate_________________________ 6. Vinyl Chloride______________________ 7. ___________________________________ 8. ______ DATE Tons/Year What procedure is followed to report emission excursions to regulatory agencies? Please attach a copy of existing written procedure. Is this facility monitoring ambient air quality? Is a quality assurance program used? (Please provide quality assurance records.) 12/8/82 YES NO N7A" YES NO n7a* TENO 334 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT AIR (4) What parameters are monitored? Has air monitoring data shown exceedances of air standards? ____ ___ YES NO "N7A Is this facility in compliance with or on a schedule of compliance with all applicable emission limitations and standards under the Clean Air Act? Discussion if required: "yes "no "n7a Does this facility have procedures to insure leaded gasoline is not used in company vehicles designed for unleaded gasoline? ____ ___ YES NO "n/A If this facility dispenses more than 200,000 gallons of gasoline per year, does it have Stage 1 vapor control system installed? ____ ___ ____ YES NO N/A Who is responsible for gasoline health effects warnings? Is gasoline health effects information posted in vehicle refueling areas? 12/8/82 ____ ___ YES NO "N7A TEN0 335 r TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (1) Is this facility registered under the Resource Conservation and Recovery Act (RCRA)? Generator Storer Treater Disposer Transporter YES NO N/A What is the registration number? List any hazardous waste and the amount being generated and show if it is disposed of on or off-site. ON OFF List any solid waste and the amount being generated and show if it is disposed of on or off-site. If this facility is a treater, storer, or disposer (TSD facility), does it have a final RCRA permit? YES NO N/A _________________ Has this facility received its RCRA Part B application? If yes, when is Part B application due? Is Part B application being completed as per 40 CFR 264 <Sc 270? 12/27/83 TENO 336 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SOLID WASTE DISPOSAL (2) If this facility is a storer, treater or disposer, is it in compliance with the interim standards? YES NO N/A Are the following prepared? Written Waste Analysis Plan? Is the site secure to prevent unknowing entry or are "Danger-Unauthorized Personnel Keep Out" signs installed? Written inspection schedule on: (a) Monitoring equipment? (b) Security devices? (c) Operating and structural devices? Personnel training? "No Smoking" signs for ignitable or reactive waste? Preparedness and prevention? Contingency Plan? Arrangements with local authorities? Are manifests used with each off-site load of hazardous waste? Are all hazardous waste manifests accounted for? Is manifest record system properly maintained? Is an annual hazardous waste summary provided to the State? (Provide a copy.) Is hazardous waste held over 90 days? Have any drummed waste been held over 90 days? What is the present inventory of drummed waste? Number of drums Is each drum dated when hazardous wastes are placed in the drum? What is the present inventory of empty drums? Number of drums 12/8/82 TENO 337 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SOLID WASTE DISPOSAL (3) How are empty drums disposed of? Are any empty drums given (sold) to employees or neighbors? Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material? YES ____ ____ NO N/A What types of hazardous waste treatment are accomplished on site? Solar Evaporation ____ Processing for Detoxification ____ Incineration ____ Neutralization ____ Landfarming ____ Fixation prior to burial ____ Recycling ____ Biological ____ Other___ ____ Has TOC provided closure costs of on-site treatment and storage facilities? ____ What is estimated cost?Who estimated cost? Are ponds used in hazardous waste treatment? Are ponds in natural clay? Are ponds lined with clay? How thick?________________ What freeboard is maintained in ponds?________________ What is expected 24-hour rainfall in a five-year period? Are monitoring wells used? How many wells are upgradient?______________________ How many wells are downgradient?___________________ How deep are the wells?______________________________ How often are they monitored? 12/8/82 TENO 338 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SOLID WASTE DISPOSAL (4) What are the wells monitored for? 1. 2. _____________________________ _ 3. ________________________________________________ 5. ____________________________________________ Are monitoring-well results reported to state? YES NO N/A _____ ____ ____ Have reported (last 12 months) monitoring results indicated underground contamination potentially related to this facility's activity? What is the depth of the shallowest aquifer currently used? _____ ____ ____ Does this facility operate water wells? _____ ___ ____ What depth?__________ How many? List private drinking water wells near this facility. Owner Depth 1. 2. 3. 4. List industrial/commercial water wells near this facility. Owner Depth Water Use 1. 2. 3. 4. List municipal or public water wells near this facility. Owner Depth Water Use 1. 2. _ 3. __ 4. _____________________________________________ _ 12/8/82 TEN0 339 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMING TON PLANT SOLID WASTE DISPOSAL (5) YES NO N/A Do you receive hazardous waste from off-site? What types of hazardous waste disposal are accomplished on site? Sanitary Landfill Chemical Landfill Solar Evaporation Landfarming Deep Well NPDE5 Discharge after treatment Other What is the estimated useful life of on-site disposal? Has TOC provided for expected future closure costs of on-site disposal facilities? What is the estimated cost? Who estimated the cost?___________________________ How has TOC provided for the expected cost? Has this facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note?__________________ Have these discrepancies been corrected? (Provide a copy of last regulatory inspection.) 3/1/83 TENO 340 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SOLID WASTE DISPOSAL (6) OFF-SITE DISPOSAL If off-site hazardous waste disposal is used: What is the name of the facility? Name Permit Number 1. 2. 3. Do you have a copy of their current RCRA permit? Do you have a copy of their current state permit(s)? Have you visited this facility in the last 12 months? Did the evaluation confirm this site is satisfactory for disposal of your facility's hazardous waste? (If a written evaluation report was made, please attach.) Are DOT approved containers and labeling used for off-site delivery of hazardous waste? Estimated annual cost of off-site disposal? Has this off-site facility been inspected by a regulatory agency in the last 12 months regarding solid waste disposal? What discrepancies did they note? YES NO N/A _____ ____ _____ _____ ____ _____ __________________ _____ ____ _____ _____ ____ Have these discrepancies been corrected? 3/1/83 TEN0 341 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT UNDERGROUND STORAGE (1) Does this facility have underground storage tanks? YES NO N7A Please tabulate information on underground storage including fuel tanks. Tank Identification Tank Volume Material of Construction Tank Age Material Stored 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. How often is stored product inventory reconciled? __________________ What program is followed to insure early detection of potential leaks? 3/1/83 TENO 342 (( TENNECO OIL PflcM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT POLYCHLORINATED BIPHENYLS (PCB) (1) As of July 2, 1978, did this facility contain in service, stored for future use, or stored for disposal: YES NO N/A A. 50 or more large high or low voltage PCB capacitors? B. One (1) or more PCB transformers? C* 45kgs (99.4 lbs) or more PCB chemical substances or PCB mixtures? Does the facility contain other PCBs, PCB equipment (e.g., electromagnets, electric motors, hydraulic systems, heat transfer systems, compressors), or containers of PCBs or PCB mixtures? 9/24/82 TENO 343 { TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT COMMUNITY RELATIONS (1) How many complaints were received from neighbors or other interested parties the last 12 months? Is this a decrease compared to the previous 12 months? ______ _______ What percent of the neighborhood complaints received relate to: Air Water Noise Spills Solid Waste Disposal Other TOTAL _______ _______ _______ _______ _______ _______ 100% What percent of the complaints investigated relate to this facility? Describe briefly how complaints are handled and name individual(s) responsible for handling complaints. If written procedures exist, please attach a copy. When is the senior line manager responsible for local operations informed of citizen complaints? Who is responsible for reporting complaint information to the senior line manager? Does this facility have an Emergency Contingency Plan? YES NO ~n7a Has the Emergency Contingency Plan been updated in the last 12 months? "yes no ~n7a (Please make available a copy of the Emergency Contingency Plan for the Review Team.) 12/12/83 TENO 344 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT COMMUNITY RELATIONS (2) What individual is responsible to make timely reports of the occurrence of emergencies to TOC P&M Environmental Affairs Department (Houston)?__________ ____________________ Briefly describe activities this facility has participated in the last 12 months to enhance community relations. Typical activities are providing speakers for civic clubs and other local organizations, participating in county (parish) fairs, supporting youth groups such as Little League, Scouting, etc., providing information to newspapers, radio or television. 12/8/82 TENO 345 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SUMMARY (1) The following items represent commendable performance or innovative solutions to environmental regulatory requirements that may have applications in other TOC Facilities. 12/8/82 TENO 346 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SUMMARY --m-- THE FOLLOWING ITEMS REQUIRE LOCAL OPERATIONS MANAGEMENT ATTENTION: DOES LOCAL INDIVIDUAL RESPONSIBLE MGMT FOR COMPLETION OF ITEM DESCRIPTION SPECIFIC IMPROVEMENT NEEDED AGREE CORRECTIVE ACTION DATE FOR COMPLETION OF IMPROVEMENTS TENO 347 8/16/83 I TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SUMMARY (3) Unresolved questions raised as a result of the Environmental Review. Question // Responsible party: Date for answer: Answer: Date answered: 12/8/82 TENO 348 f TENNECO OIL WtM ENVIRONMENTAL REVIEW TENNECO POLYMERS - FLEMINGTON PLANT SUMMARY (4) COMMENTS 12/8/82 TENO 349