P.1 

Standard Oil 

Chemical Company 

Ft. Amanda Road 

P.O. Box 628 

Lima, Ohio 45802-9983 

;r/- $-</</ 

July s, 1986 STANDARD OIL 

CHEMICAL 

/o/Clo)F?R-±> -7 " 

National Response Center 

c/o U.S. Coast Guard 

2100 Second St., S.W. 

Room 2611 

Washington, D. C. 20593 

Attn: Duty Officer 

Henry L. Longest, Director 

Office of Emergency & Remedial Response 

United States Environmental Protection Agency 

401 M. Street, S.W. 

Washington, D.C. 20460 

Mr. Kenneth A. Schultz, Chief 

Emergency Response 

State of Ohio Environmental Protection Agency 

361 E. Broad Street 

Columbus, OH 43216-1049 

Re: Annual Notice of Continuous Releases 

Dear Sirs: 

This letter is written on behalf of Standard Oil Chemical Company, 

(formerly Sohio Chemical Company), a wholly owned subsidiary of The 

Standard Oil Company (an Ohio corporation). Standard Oil Chemical 

Company owns and operates a chemical manufacturing facility located 

in Lima, Ohio. The purpose of this letter is to provide annual 

notification of continuous releases of certain hazardous substances 

pursuant to the procedures under Section 103 (f) of the Comprehensive 

Environmental Response, Compensation and Liability Act ("CERCLA"). 

These substances are acrolein, acrylonitrile, ammonia, hydrogen 

cyanide, nitrogen oxides and RCRA wastes (K011 and K013). 

As explained in my letter of July 8, 1985, Standard Oil Chemical does 

not agree that EPA has discretion to interpret the "federally 

permitted release" exemption as narrowly as described in William N. 

Hedeman's June 12, 1985 letter to me. Nevertheless, we continue to 

report in accordance with that letter, in an effort to accommodate 

the Agency's concerns. This letter should not be construed as an 

admission by Standard Oil Chemical Company that reporting of the 

releases it describes is required by Sections 103 (a) and 103 (f) of 

CERCLA. 

A unit of the original Standard Oil Company 

founded in Cleveland, Ohio, in 1870. 
P.2 

-2-

Please note that, due to updated permits and new Ohio EPA regulations 

on Volatile Organic compounds, several additional sources qualify for 

the federally permitted release exemption, even under the narrow EPA 

reading of that exemption. These sources are footnoted in the 

attached table, and emissions from these sources are excluded from 

the continuous release totals. As updated permits are received for 

the remaining sources, we expect that many of these sources will 

qualify for EPA's view of the federally permitted release exemption. 

Since the 1985 notice, Standard Oil Chemical has undertaken a major 

effort to further quantify emissions to the atmosphere from all 

sources at our facility. In addition, continuing improvements in 

control devices and operating practices have reduced emissions. For 

example, floating roofs were installed in our acrylonitrile storage 

tanks and new startup and shutdown procedures have reduced acrylonitrile absorber emissions. Also, a continuous monitor was installed 

on the acrylonitrile absorber vent stack. The inventory of releases 

has been modified to reflect these changes. Although the quantity of 

releases is intended to be representative, in some cases it is based 

on best engineering estimates and calculations. 

Another source of change in the notice is the change in reportable 

quantities in 40CFR302 effective on July 3, 1985. As continuous 

emissions of acetonitrile and methanol are below the final reportable 

quantities, they have been excluded from this year's notice. 

The range of releases reported for each hazardous substance was 

developed based on our operating conditions over the last year and is 

expected to be representative of normal operating conditions over the 

next year. Therefore, Standard Oil Chemical believes that this 

notice satisfies the requirement in CERCLA Section 103 (f)(2)(B) that 

notice be given for a period sufficient to establish the continuity, 

quantity and regularity of these releases. 

Thank you for your attention to this matter. Please direct any 

questions to Jim Facer, (412) 226-1220. 

Sincerely, 

STANDARD OIL CHEMICAL COMPANY 

By: UJWctttfC&te} 

•> c __ . 

W. Hougland / 

Manager, Lima Chemicals 

JWH:je 

EG128 

Attach. 
P.3 

Table I 

Standard Oil Chemical Company 

Lima Chemicals Facility 

Continuous Releases 

Pollutant 

Acrolein 

Acrylonitrile 

Ammonia 

Hydrogen Cyanide 

K011 (RCRA waste) 

KOI3 (RCRA waste) 

Nitrogen Oxides 

Continous Releases, lbs/day 

70 to 75 

170 to 980 

4,680 to 34,300 

110 to 750 

1+ 

1+ 

11,040 to 11,420 

TABLET/TXTSAB 
P.4 

'• 

Pollutant 

Acrolein 

Acrylonitrile 

. 

-

Standard 

Lima 

Table II 

Oil Chemical Company 

Chemicals Facility 

Continuous Release Sources 

Permit 

Application 

Number 

P014 

P035 

U002 

N001,2 

N004 

P003 

P005 

P009 

P010 

P011 

P014 

P035 

P043* 

P050* 

P051* 

T001 

T006 

TO 19 

T020 

T023* 

T024* 

T025* 

T026* 

T027* 

T028* 

T029* 

T030* 

T031* 

T032* 

T033* 

. U002 

U011 

U012 

Source Description 

Rec/Strip/Prod Col 

Reactor/Quench/Abs. 

Deepwell & Burn Pnd 

North & South T.O. 

Barex T.O. 

Elastomer Charging 

Latex Paste Line 

Elastomer Reactor 

Resin Reactor 

Resin Strd. Dryer 

Rec/Strip/Prod Col 

Reactor/Quench/Abs. 

Resin Fines Dryer 

Truck/Rail Loading 

AN/ACN Drum Loading 

AN Storage Tank 

RCM Surge Tank 

RCM Tank T-8 

RCM Tank T-19 

#1 Product Tank 

#2 Product Tank 

#2A Crude Tank 

#3 Prod Rundown TK 

#3A Prod Rundown TK 

#4 Prod Rundown TK 

#5 Offtest Prod TK 

#6 Crude Nit. Tank 

#7 Resin Surge TK 

#51 Tank 

#52 Tank 

Deepwell & Burn Pnd 

Waste Treatment 

Building Exhaust 

• - • . ' « 

Unit 

#2 AN 

#2 AN 

#2 AN 

Barex 

Barex 

Barex 

Barex 

Barex 

Barex 

#2 AN 

#2 AN 

Barex . 

#2 AN 

AN Off 

Barex 

Barex 

Barex 

Barex 

AN 

AN 

AN 

AN 

AN 

AN 

AN 

AN 

AN 

AN 

AN 

Barex 

Barex • 

• - • 

_

 -
P.5 

• 

— 

-. 

Pollutant 

Ammonia 

~~ 

"~ 

Permit 

Application 

Number 

P002 

P020 

P021 

P022 

P023 

P024 

P025 

P026 

P027 

P028 

P029 

P031 

P035 

P046* 

P047* 

PXX1 

PXX2 

PXX3 

PXX4 

PXX5 

T017 

T018 

TX17 

TX18 

TX19 

TX20 

TX21 

TX22 

TX23 

TX24 

TX25 

TX26 

TX27 

TX28 

TX29 

TX30 

TX31 

TX32 

TX33 

TX34 

TX35 

TX36 

TX37 

-

-2-

Source Description 

Prill Tower 

Reforming Section 

Purification Sect. 

Synthesis Section 

Cond Purif Section 

Prill Dryer Cyclone 

Mother Liquor TK 

Synthesis Section 

Lump Dissolving Tks 

Chrystallizer 

Surge/Conc/Run Tks 

NH4N03 Neutralizer 

Reactor/Quench/Abs 

Granulator Unit 

Evaporator Unit 

Kill Kettle 

Brine Stripper 

NH4N03 Evaporator 

Reactor Feed Sect 

UTI Hbtwell 

NH4NQ3 Surge Tank 

Ammonia T-5, T-6 

Urea Truck Loading 

2800 Sol. D-1,2,3, 

2800 Sol. T-20, 23 

Anhydrous NH3 D-4,5 

NH4N03 Trk Loading 

Aqua T-26,27,28,29 

NH3 Truck Loading 

NH3 Rail Loading 

Urea Recovery T-61 

NH4N03 T-ll, 12,13 

NH3 S-l, S-2, S-3, S-4 

Slop Rec T-60 

Surge Tanks T-8, T-0 

Aqua Truck Loading 

Urea Tank #10 

Urea Solutin T-55 

Aqua Loading T-7 

Fert Sol Loading 

NH4N03 T-8, T-9 

Urea, T-51, 52,53,54 

NH4N03 T-21, T-22 

-

- _ - — 

Unit 

Urea 

NH3 

NH3 

NH3 

NH3 

Urea 

Urea 

Urea 

Urea 

Urea 

Urea 

Acid 

#2 AN 

Urea 

Urea 

Aceto 

Aceto 

BSS 

Urea 

Urea 

Acid 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

BSS 

_ - • • 

• 

- •' 7' 
P.6 

-3-

Pollutant 

Ammonia - Cont'd. 

Hydrogen Cyanide 

K011 

K013 

Nitrogen Oxides 

Permit 

Application 

Number 

TX38 

TX39 

TX41 

TX43 

TX44 

U003 

U004 

N001,2 

P012* 

P014 

P015 

P019 

P035 

P037 

T052* 

T025* 

T029* 

T030* 

T034* 

T035* 

U002 

U002 

B001* 

B002* 

B003* 

B004 

BXX1 

BXX2 

N001,2 

N004 

P018 

P019 

P030 

P031 

P032 

P039* 

U008 

U009 

U010 

Source Description 

Aqua Ammonia T-41 

NH4N03 T-11,12,13 

Acid Tank T-36 

Nitric Acid Loading 

Nitric Acid T-7 

Carb _ NH3 Pmps V-l 

Bldg Exhause Fans 

North & South T.O. 

Product Column 

Rec/Strip/Prod Col 

Batch Still 

HCN Column 

Reactor/Quench/Abs. 

Heads Column 

HCN Loading Rack 

#2A Crude Tank 

#5 Offtest Prod TK 

#6 Crude Nit. Tank 

HCN Storage Tanks 

HCN Storage Tanks 

Deepwell & Burn Pnd 

Deepwell & Burn Pnd 

#1 Boiler 

#2 Boiler 

Primary Reformer 

S/U Heater 

Ammonia Load Heater 

Gas Turbine 

North & South T.O. 

Barex T.O. 

#2 Calciner 

HCN Column 

Turbine Expander 

NH4N03 Neutralizer 

Blend & Storage Tks 

#1 Calciner 

T-35 

Platinum Filter 

Waste Heat Boiler 

Unit 

BSS 

BSS 

Acid 

BSS 

BSS 

Urea 

Urea 

#2 AN 

Aceto 

#2 AN 

Aceto 

HCN 

#2 AN 

#2 AN 

AN Off 

AN 

AN 

AN 

HCN 

HCN 

HN3 

NH3 

NH3 

NH3 

NH3 

NH3 

#2 AN 

Barex 

Catalyst 

HCN 

Acid 

Acid 

Acid 

Catalyst 

Acid 

Acid 

Acid 

* Indicates sources that qualify for EPA's view of the federally 

permitted release exemption. Releases from these sources have been 

omitted from Table I. 

AAAAAAHV/$OUMAIL 

7/7/86