Document 1Qya0zQrrRLqmobvxv5e3njYE

Interoffice Communication to J. C. Ledvina - HoustonChemicals From J. A. DeBernardi Date May 6, 1982 subject NEIC LaboratoryDeficiency Issue In response to your note of April 30 on the subject I would suggest we drop the situation right where it is. It is my opinion that both Conoco and EPA overreacted to the situation. I think this was made clear when we finally got the NEIC Inspection report (attached) and found that a difference was made by NEIC between required changes and recommended changes. The VCM Plant has already complied with the required changes and the majority of recommended changes. To continue a dialogue to prove who's right or wrong, essentially serves no purpose on such a trivial matter as this. The more contact we have either written or face to face on this matter only tends to alienate our EPA relationship. As I see it, alienation over this matter, at least at the VCM Plant, is not worth the effort. Please understand, I am not suggesting that we adopt all standard practices listed in the volumes of EPA published procedures and practices related to our laboratory. What I mean is, when an inspection uncovers a deficiency and a report requires a change we look to complying with the requirement set forth and that's all. I continue to believe that to justify their existence an inspection team must find something wrong, and will find something wrong no matter how much money or effort is put forth to reach perfection. As you know our plant takes a top priority interest in protecting the environ ment and being good neighbors in the community. The fact that the letter of the law is not met in every conceivable situation does not detract from the fact that the intent of the law is never lost sight of. The practicality of any situation normally leads to the proper path being followed. J. A. DeBernardi br attachment cc w/attachment RDG-JWW-RB-DLD -//zyes ' i/*B/8 2_ OCR 000067257 Analytical Laboratory NEIC found sample containers, preservation techniques, and holding times to be acceptable. Recordkeeping was satisfactory and met the require ments of the permit. No problems were seen in the laboratory portion of the inspection that should significantly impact the quality of NPDES results. A number of minor deviations from required laboratory practices were noted as follows: Required Chances Three 20 m portions of DI or distilled water must be used to prewash TSS filters. TSS filters must be reweighed until constant weight is achieved. The depletion rule for the BOD test, i.e., 2 mg/ D.O. with 1 mg/jl remaining must be observed where possible. Recommended Chanaes Glucose/glutamic acid standard should be used monthly to validate BOD test. Reverse osmosis water to make dilution water should be per iodically checked for TOC and metals. Chromic acid should not be used to clean BOD bottles. Analytical balance for TSS measurements should be calibrated daily and a log kept. Thermometers for TSS oven and BOD incubator should be cali brated and calibration records kept. Log of TSS oven temperature should be kept. Daily log of temperature of BOD incubator should be kept. CCR 000067258 42 Lab QC procedures should include use of spike samples on 10% frequency for chlorinated HC, COD, and NH3-N. Outside reference samples should be periodically analyzed as an independent check on the VCM laboratory. QA statement should be developed defining acceptable toler ances and identifying corrective action necessary when these tolerances are exceeded. MONITORING RECORDS AND NPDES VIOLATIONS, 1979-1980 In the first half of 1975, Conocc/VCM experienced a large nufiiber of NPDES violations. Most were h\gh TSS levels in the incinerator Aff1 uent (OutfVll 101). In May 1979, the incineration stream was taken/out of the VCM treatment works and divertedVto the adjoining Lake Charles Chemical Plant. \The NEIC team examined tna self-monitorinq recordsyfrom July 1979 to December 1980 to determine performance of the V.CM bioldgical treatment works and Assess discharges fallowing the changes, \stariing in July 1979, the number Vf violations decreased dramatically andXouxfall waste loads were considerably below pe/mitted levels. However, j(he frequency of raw waste bypasses ^around the' treatment wonks continues/t<ft be a problem. In creased waste equalization capacity or emergency o/flin\ storage is neces sary to correct th\ bypass situation. Monthly average''loads for the treatmenft/lant effluent (Outfall 201) were compared to average 30 day permit limi^svfor the 18 month period of July 1979 to December 1980. On an average/monthly basis, tjie treatment plant is achieving results\far better thary the NPsES limits. Parametej B0D5 / COD / TSS / NH4 a1 N Chlorinated HC Flow/(mgd) tange of Monthly ilues (yb/day) \3-S95 404-2,460 Wv278 a" 25 /106^915 / 0.49-0.81 Permit Limit (lp/day) \ \ \ \ \ &00 41x7 3ft l,50o\ \ CCR 000067259