Document Eq40GBj24gw7DjYLyjR17wVXN

mnnm 1 Aj^UO^ --C0 Interoffice Communication To R. A. Frohreich, Aberdeen Chemical Plant From E. S. Wackerbarth, Legal, Houston Date September 20, 19 8 2 Subject REPLY TO MISSISSIPPI DNR REQUEST FOR INFORMAT I ON ABERDEEN PVC PLANT I have reviewed your draft response to the DNR and I that you, Joe Ledvina and I will need to discuss it in light of our recent experience in replying to EPA Region VI's 114 letter. I have attached a draft of a letter and a format for the reoly text that should be a good starting point for your next draft. I will call you in a week or to discuss a meeting at which we can ao over the draft in a thorough manner. In the meantime, please feel to call me if you have questions about the format I am suggesting for the reply. 4 SoXjXd- <&. UGojckaxW/dclLj Attorney sdw Attachment cc: J. Ledvina > DRAFT / September 20, 1982 CONFIDENTIAL ' 4i Mr. Jerry B. Banks, F.E. Mississippi Department of ** ** Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39204 Dear Mr. Banks: This letter and the attached reply text respond to your verbal request of (Date) for information about Conoco*s Polyvinyl Chloride Plant in Aberdeen, Mississippi. All of the pages in this letter and reply text which are stamped "Confidential" are claimed confidential in their entirety by Conoco pursuant to the provisions of _ As Conoco understands it, the Mississippi Department of Natural Resources will protect this information as confidential and will not divulge it to any other party. Please note that the reply text contains confidential information of a'business and technical nature. ^ I believe you will agree that the Aberdeen PVC Plant has taken all reasonable steps to prevent the potential for releases of vinyl chloride. Please do not hesitate to call me if I may provide additional information. R. A. Frohreich Chief Process Engineer t 1 ( I I l j i- r VAB.0001144355 I""TM* v CONFIDENTIAL REPLY TEXT TO MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES REQUEST % CONOCO ABERDEEN PVC PLANT ABERDEEN, MISSISSIPPI i VAB.0001144356 i fi- AN. 1. Give a concise description of the PVC manufacturing process, just to make sure Banks knows the process as it is carried out at our plant, and any terminology we use in the reply text. 2. Separate each incident with headings such as: February 2, 1979. 3. Describe events leading up to each release. Refer to figures, (if you've got them as parts of process descriptions) or to process descriptions so that you need not go into details of the process each time. 4. Tell how many ponds of vinyl were released rf Banks asked for that information. If he asked for--this information, you may want to use this phrase: "The relief valve sizing equations in the consolidated valve Catalog No. 1900B, page 47, (or other appropriate reference) indicates that approximately lbs of vinyl would have been released _." 5. Describe the corrective actions, including (a)~counseling of the operator if there was operator inattention or error involved/ (b) changes to 0/M procedures, (c) physical changes to plant, (d) training sessions held for employees, and (e) changes to written manuals or written directives to all employees, etc. Give dates of completion of measures. 6. Tell why the release COULD NOT HAVE BEEN prevented. This is important if we are to head off a possible i lawsuit. If there were other upsets, weather -i* " conditions, etc. that required attention at the time of the release, describe them and tell how they affected response to overpressure conditions leading * up to each release. 7. In general, use phrases like "event of (date)", or "incident of (date)", instead of "discharge of (date)". Say that the relief valve "lifted", instead of "discharged". v VAB.0001144357