Document ypLQqdo9qkd7yOXo3q6rojaLr

TOC P&M Environmental Affairs (COMPANY) TO: FOR: FROM: RE: Tenneco Polymers Dan Carter R. D. Pruessner ENVIRONMENTAL REVIEW - PA INTEROFFICE COMMUNICATION DATE: 3anuary 2, 1985 Your approval is requested for scheduling the Environmental Review of the Pasadena Plant and affiliated wastewater treatment facilites on February 26 28, 1985. The proposed agenday 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: Charles Beresford Russell Bowers 3im Kachtick Emile LeRouge Ralph Maynard A1 Smith' Lloyd Stewart Roger Towe R. D. Pruessner r LTENftOA 8/84 TENNECO OIL P&M ENVIRONMENTAL REVIEW Name and address of facility; Tenneco Polymers Pasadena Plant 4403 La Porte Road P. O. B x 849 Pasadena, TX 77501-0849 February 26-28. 1985 Affiliated with: Tenneco Oil P&M Operations Manager: Daniel H. Carter (Name) Environmental Representative: 3(NimamKea) chtick Plant Manager (Title) Mgr.-Environmental Sciences (Title)--------- ------------------ Type of operation and/or principal products: Polyvinyl Chloride (713)479-3411 (Phone) (713) 479-3411 (Phone) Review Team: Name Title Phone Bob Pruessner______________ Roger Towe________________ Charles Beresford___________ Emile LeRouge_____________ Mgr.Environmental Affairs-TOC Sr.Environmental Eng.-TOC______ Attorney - TOC___________________ Environmental Supervisor-TOC (713) 757-3306 (713) 757-7685 (713) 757-8764 (504) 579-2274 1/2/85 TEN0 388 r AGENDA ENVIRONMENTAL REVIEW Tenneco Polymers - PASADENA PLANT February 26-28, 1985 TUESDAY - February 26 7:00 p.m. Supper for the Review Team and Polymer repre sentatives at Brady's Landing, 8505 Cypress, Houston, Texas. WEDNESDAY - February 27 8:00 a.m. Meet with Dan Carter to conform final plans for Environmental Review. 8:15 a.m. Meet with Jim Kachtick 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 Jim Kachtick for plant tour. 4:00 p.m. Adjourn THURSDAY - February 28 8:00 a.m. Visit with maintenance department representative to sight maintenance and calibration records for environmental equipment. 9:00 a.m. Visit environmental laboratory and sight required records on quality assurance, sample chain of cus tody, analytical procedures, etc. 11:00 a.m. Meet with Polymer representative to go over Dock portion of questionnaire. 11:30 a.m. LUNCH (Please bring in sandwiches.) 2:30 p.m. Meet with Dan Carter and staff to review proposed findings and complete the final report. Provide copies of completed report to Russell Bowers, Dan Carter Jim Kachtick, and Bob Pruessner. 12/27/84 TENO 389 r TENNECO OIL P&M FACILITIES ENVIRONMENTAL REVIEW TENNECO POLYMERS - PASADENA PLANT POLYVINYL CHLORIDE FACILITIES 12/20/84 TENO 390 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (1) 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 Russell Bowers__________ Title Vice President-Chemicals Name Title j Name ! Title 12/20/84 TENO 391 ( TENNECO OIL PAM ENVIRONMENTAL REYEEW TENNECO POLYMERS ENVIRONMENTAL STAFFING (2) Please list name 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 analyses, 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:____________________ 12/20/84 TENO 392 ( NPDES Permit No.: TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (1) 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 COD TSS 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: 12/20/S4 TENO 393 TENNECO OIL P*M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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? 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? How often?(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: 12/20/34 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (3) Permittee is using method of sample collection required by permit? If not, explain method used and the frequency of sampling: 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 bC 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 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (4) Are parameters other than tho*se required by the permit analyzed? Are the methods used stated on the laboratory report sheet? 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? 12/27/83 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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 Y ES, 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 WATER (6) What is the receiving stream? YES NO N/A Is there a formal Spill Control Plan (5PCC)? 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 TENO 398 I TENNBCO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS WATER (7) How is storm water treated? YES NO 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 399 ( TENNECO OIL P*M ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (1) Does this facility operate a ship or barge dock? What materials were transferred across the dock the last 12 months? YES NO N/A ____ Additional materials that may be transferred in the future. Does the spill control plan include the dock facilities? What is the volume of the spill containment for the transfer facility? What emergency spill containment equipment (booms, absorbent, etc.) are owned and available at the facility? 12/6/82 TENO 400 TENNECO OIL WtM ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (2) Have arrangements with other organizations been made for emergency spill cleanup support? Who? ____ Do any of the materials transferred or anticipated to be transferred meet the Coast Guard definition of "oil," i.e., oil of any kind or in any form, including but not limited to petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil"? If the transferred materials fall within the Coast Guard definition of "oil," an operations manual meeting the requirements of Coast Guard Regulation (CFR 33 Part 154--Oil Pollution Regulations for [Marine Oil Transfer Facilities) is required. Has an operations manual been prepared meeting these requirements? (Please provide a copy of the manual.) (1) If an operations manual has been prepared, has it been sub mitted to the Coast Guard "Captain of the Port" (required no later than March 3, 1983)? (2) Has the Captain of the Port issued a "letter of adequacy"? (3) Have amendments to the dock operations manual been made since the issuance of the Coast Guard "letter of adequacy"? (4) Are copies of the dock operations manual available to dock operations personnel? (5) Has this facility designated "persons in charge of facility oil transfer operations" and advised the Captain of the Port of this designation in writing? (6) Are current (annual) hose pressure tests and inspection records available at this facility? If the transferred materials do not fall within the Coast Guard definition of "oil" but do fall within the requirements of 33CFR126 --Handling of Explosives or Other Dangerous Cargoes Within or Contiguous to Waterfront Facilities--has a dock operations manual been prepared for this facility? 12/6/82 ( TENNECO OIL PdtM ENVIRONMENTAL REVIEW TENNECO POLYMERS DOCK OPERATIONS (3) (1) If an operations manual has been prepared, are copies available to dock operations personnel? (2) Does the operations manual contain the following: A. Documentation that the dock operator is a qualified operator? B. Dates and results of the most recent cargo hose and piping hydrostatic tests? C. Cargo information cards listing the following: a. Cargo identification characteristics (appearance, odor, etc.)? b. Emergency procedures? c. Fire fighting procedures? YES NO N/A ____ 12/6/82 TENO 402 TENNECO OIL McM ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) (1) 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 403 ( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) (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 lQppm?__________ 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? When was last NESHAPS inspection? (Please provide copy of report,) 12/12/83 TENO 404 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR 0) 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. 6. 7. List air operating permits presently in force: Description of Date Expiration Allowed Monitoring Permit Unit Issued Date Emission Requirements 1. 2. 3. 4. 5. 6. 7. 8. 9. Reporting Requirements 12/8/82 TENO 405 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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. 4. 3. 6. 12/8/82 TENO 406 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS AIR (3) When was the last air emissions inventory? ___________ DATE List reported emissions rates: Tons/Year 1. Hydrocarbons__________________________ 2. Sulfur Dioxide 3. Nitrogen Oxides 4. Carbon Monoxide_____ 5. Particulate 6. Vinyl Chloride 7. 8. 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 N/A ____ ___ ___ YES NO n7A' TEN0 407 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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 N/A 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 "n7A Who is responsible for gasoline health effects warnings? Is gasoline health effects information posted in vehicle refueling areas? YES NO N/A 12/27/83 TEN0 408 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (1) Is this facility registered under the Resource Conservation and Recovery Act (RCRA)? What is the registration number? Generator Storer T reater Disposer Transporter YES NO N/A _____ __________ _________________ _________________ _________________ _________________ _________________ 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. Is any hazardous waste disposed of in a landfill as free liquid? If so, have arrangements been made for another type disposal of this waste after May 1985, since this practice will then be prohibited? Does this facility produce, distribute, or burn any fuel derived from hazardous waste? Discuss: YES NO N/A If this facility is a treater, storer, or disposer (TSD facility), does it have a final RCRA permit? 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 <Jc 270? 12/27/84 TENO 409 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SOLID WASTE DISPOSAL (2) If this is a TSD facility which does not yet have a final RCRA permit, is it in compliance with the interim standards? 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? YES NO N/A Are uniform manifests used with each off-site load of hazardous waste? Are all hazardous waste manifests accounted for? Starting 9/1/85, generators must certify on their manifests that they have a program in place to reduce the volume and/or quantity and toxicity of their hazardous waste. Does this facility have such a program? 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? Has 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 12/27/84 TEN0 410 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS Solid Waste Disposal (3) How are empty drums disposed of? Are any empty drums given (sold) to employees or neighbors? YES NO N/A _____ Are drums emptied of purchased materials returned to the vendor as part of the agreement to purchase the material? _____ 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? Does this facility have an ongoing groundwater monitoring program? If facility has a final RCRA permit, what phase of GW monitoring exists at present? Detection___ Compliance___ Corrective Action If facility is still in interim status, is GW monitoring program in compliance with the interim status requirements? 12/27/83 TEN0 41] TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS Solid Waste Disposal (4) How many monitoring wells are used?_______ How many wells are upgradient? How many wells are downgradient? How deep are the monitoring wells? What are the wells monitored for? (40 CFR 265.92) 1. Set 1 Parameters: _________ 2. Set 2 Parameters: _________ ______________________________________________ 3. Set 3 Parameters: _________________________________ _ 4. Other: _ Have initial background concentrations been established for ail of the parameters analyzed? YE5 NO N/A _____ ____ ____ Does this background information indicate any groundwater contamination? _____ ___ _ ____ If so, has a groundwater quality assessment program been established as per the interim status regulations? _____ ___ _ ____ What has been the total cost of the groundwater monitoring program? What were the costs for the last 12 months? Are monitoring-well results reported to state? _____ ____ ____ What is the depth of the shallowest aquifer currently used? 12/12/83 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS Solid Waste Disposal (5) 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. 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.) 12/12/83 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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 y.ou 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? 12/12/83 TEN0 414 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS UNDERGROUND STORAGE (1) Does this facility have underground storage tanks? YES NO WA 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. 3. 9. 10. How often is stored product inventory reconciled? _________________ What program is followed to insure early detection of potential leaks? 12/12/33 TEN0 415 TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS POLYCHLORINATED BIPHENYLS (PCB) (1) YES NO N/A As of July 2, 1978, did this facility contain in service, stored for future use, or stored for disposal: 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? 12/20/84 TEN0 416 ( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (1) Name of pipeline; When was pipeline constructed? ____________ _________________________ _____ What is pipe diameter?___ Length of pipeline? What products are transported?_____ Normal operating rate and pressure: Maximum operating rate and pressure;_____ Date of latest hydrostatic test: Do current DOT regulations require additional pressure testing? YES NO N/A How often are pipeline rights-of-way inspected? Who conducts these inspections? __________________________________ _ (Provide a copy of a typical inspection.) How often are navigable waterway crossings inspected? Are all line markers provided as required? Do the markers contain the proper wording as required as well as emergency phone numbers?__ How many pump stations are on this pipeline? What is the source of power? Electric Yes___ No___ N/A Gas Yes___ No___ N/A Diesel Yes___ No___ N/A What provisions are made to shut down pumps in event of pipeline leak? 12/8/82 TEN0 417 (( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS HIGHLY VOLATILE LIQUID PIPELINE (2) Are herbicides used to control right-of-way vegetation growth? If herbicides are used--what kind is used? YES NO N/A How applied? Aerial_____ Ground Are licensed applicators used to apply herbicide? _______________ YES NO N/A Have adjacent land owners complained about herbicide problems? YES NO N/A If so, give brief description. Is cathodic protection provided for the pipeline? _______________ YES NO N/A What type?_______ How often is cathodic protection current measured? How often is cathodic protection pipeline to ground potential measured ? (Please provide representative records of cathodic protection maintenance.) How is the "Public Education" provision of 195.440 administered? What material, if any, is discharged from the pipeline during testing or cleaning?__________________________________ __ How often?______________________________________________ Where?__________________________________________________ What is final disposition of material?______________________ 12/8/82 TEN0 418 /( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS 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? Has the Emergency Contingency Plan been updated in the last 12 months? (Please make available a copy of the Emergency Contingency Plan for the Review Team.) YES NO "N7A TB NO Wa 12/12/83 TEN0 419 (( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS 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 420 f( TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS 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 421 TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (2} 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 422 8/16/83 (( TENNECO OIL PAM ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (3) Unresolved questions raised as a result of the Environmental Review. Question It Responsible party: Date for answer: Answer: Date answered: 12/8/82 TENO 423 <f TENNECO OIL P&M ENVIRONMENTAL REVIEW TENNECO POLYMERS SUMMARY (4) COMMENTS 12/8/82 TENO 424