Document KNXBYzQBRyg2rRROVmqMZnQQ

Vista Chemical Compony April 3, 1986 15990 N. Border's Landing Rd. Post Office Box 19029 Houston.Texas 77224 Phone {713)531-3200 - ^O ............... Mr. Jack Neeld Environmental Conservation Conoco Inc. Marland Building P.0. Box 2197 Houston, TX 77252 Dear Jack: Conoco was formally notified on December 6, 1985 of a Compliance Order received from the Louisiana DEQ regarding T-405 and T-452 in the Lake Charles Vinyl Chloride Plant. Subsequently, you were sent our response to the compliance order which consisted of a proposed plan to meet the requirements of the order. Attached is the final order approving our proposed plan. This is a hard copy of the plan faxed to you earlier today. Sincerely, 'V, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/8 cc W. L. McClain B. Raffle - Conoco vvv 000022779 STATE OF LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY IN THE MATTER OF: * VISTA CHEMICAL COMPANY ATTENTION: R.A. CONRAD POST OFFICE BOX 605 WESTLAKE, LOUISIANA 70669 * * * COMPLIANCE ORDER PROCEEDINGS UNDER THE LOUISIANA ENVIRONMENTAL QUALITY ACT LA. R.S. 30:1051 ET SEQ. * * This COMPLIANCE ORDER is issued to VISTA CHEMICAL COMPANY (hereinafter referred to as "the Respondent") by the Secretary, Louisiana Department of Environmental Quality (hereinafter referred to as "the Department"), under authority granted by the Louisiana Environmental Quality Act (La. R.S, 30:1051 et seq., hereinafter referred to as "the Act") and particularly by Section 1073 C of the Act. FINDINGS OF FACT I. The Respondent owns and operates a petrochemcial plant near Lake Charles, in Calcasieu Parish, Louisiana. U. On December 2, L9S5 an ORDER was issued requiring the Respondent to cease use of a leaking storage tank and to submit a remedial action plan to address the contamination. Ul. On January 6, 19S6 a remedial action plan for the heavy ends reuse storage tanks T-^05 and T-452 was submitted to the Department by the Respondent. Subsequent to vvv 000227so *d MM! 33/0/t>0 bism iNtnd ion wodd submittal, inspection of tank T-405 by the Respondent revealed numerous holes in the tank's base, in violation of Section 23.13 of the Louisiana Hazardous Waste Regulations. IV. During the month of January 1936, three spill events occurred from the Ethylene Dichioride product storage tank, T-450, adjacent to the reuse tanks. Extent of the spill is unknown, however, the free liquid portion of the spilled EDC was recovered, tank T-450 was emptied, and contaminated soil around the tank was removed. V. An inspection by Department personnel on January 30, 1936 confirmed the information in item IV. Additionally, the inspection revealed the probability of groundwater contamination due to a history of spills in this area. Groundwater monitoring wells adjacent to the area indicate contamination in the twenty-five (25) foot and eighty (30) foot sands. All of the above are in violation of Section 1147 of the Act as well as regulations cited. COMPLIANCE ORDER Based on the foregoing FINDINGS OF FACT, Respondent is hereby ORDERED: I. To begin, immediately upon receipt of this ORDER, implementation of the following schedule of construction and remediation: A. Remove tank T-405 from its base. 4 weeks. B. Excavate the base beneath tank T-405 plus one (1) foot, assuming no free liquids are observed. Further excavation will be performed until free VVV 000022781 P `d 2!:i! SB/ZO/PO dism iNtnd won wodd liquids are no longer .found, plus one (1) foot. Completion of this phase must be observed and approved by a Department representative. 4 weeks. C. Construct new base for T-405 which meets all applicable standards of the Louisiana Hazardous Waste Regulations. 15 weeks. D. Repair or replace T-405, as required, and install a new base. 7 weeks. E. Place T-405 in service. 3 weeks. F. Remove tank T-452 from service. 1 week. G. Clean T-452 and prepare for entry. 8 weeks. H. Inspect T-452 for leaks or structural damage. 2 weeks. I. Remove T-452 from its base. Excavate the base as described in item B. 7 weeks. 3. Construct a new base for T-452 as described in item C. 15 weeks. K. Repair or replace T-452, as required, and install on new base- 7 weeks. L. Place T-452 in service. 3 weeks. IL. To submit progress reports to the Department every month or upon completion of each major phase of plan. III. To be hereby notified that issuance of this COMPLIANCE ORDER does not preclude subsequent imposition of civil penalties in an amount not to exceed $25,000 per day for each violation described herein. IV. To be hereby notified that its refusal to compiy with this COMPLIANCE ORDER, and the provisions herein, will subject Respondent to possible enforcement procedures under Section 1073 ot the Act which could result in the assessment of a civil penalty in an amount not to exceed $50,000 for each day of continued non- compliance. VVV 00022782 9 `d 0 T : r r 93/0/f0 yisin iNyid won wod Done at Baton Rouge, Louisiana, this __ / v day of fiL/PUt This COMPLIANCE ORDER is effective on date of receipt* 19S6. A/U&Jt l ------ ---------------- PATRICIA L. NORTON, Secretary Department of Environmental Quality All correspondence should be addressed to: Department of Environmental Quality Hazardous Waste Division Post Office Box 44307 Baton Rouge, Louisiana 70S04-4307 cc: Mr. Richard Goudeau Acadiana Regional Office 100 Eppler Road Lafayette, Louisiana 7050.5 Please serve the Respondent through its Registered Agent for Service of Process: C.T. Corporation Systems 400 Poydras Street New Orleans, Louisiana 70130 cc: Vista Chemical Company Mr. R.A. Conrad Post Office Box 605 Westlake, Louisiana 70669 VVV 000022783 9 *d P I : I I S8/C0/F0 dism iNbijd j42n kuoa April 1, 1986 Interoffice Communication Mr, Jack Neeld Environmental Conservation Conoco Inc. 600 N. Dairy Ashford Houston, TX 77079 VIST/ Dear Jack: As you are aware, Garvin Fryar has written to the OKC, Aberdeen, and LCVCM plants asking that Conoco be notified as soon as practical following any contacts with state or federal agencies regarding VCM releases, incinerator bypasses* etc. Garvin asks that he or Walt Finch be contacted. In order to assure that notification is given promptly and consistently to Conoco, the following is proposed for those occurrences relating to VCM incident reporting during the compliance period. Notification of Incident Conoco will be formally notified as soon as practical of an incident in which VCM reporting is involved via facsimile from Vista's Corporate Environmental Office, (Formal notification to H. J. Neeld.) Incident Reports to Governmental Agencies Conoco will receive a copy of the final draft of the incident report to be sent to state or federal agencies in which VCM reporting is involved via facsimile as soon as available. (Copies to H. J. Neeld, G. J. Fryar.) Agency Requests for Further Information Conoco will receive a copy of any agency request for further information pertaining to VCM reporting via facsimile immediately upon receipt to VCM reporting via facsimile immediately upon receipt of such requests. (Copies to H. J. Neeld, G. J. Fryar.) Vista Response to Agency Requests for Further Information Conoco will receive a copy of the final draft of the response to any state or federal agency's request for further information in which VCM reporting is involved via facsimile as soon as available. (Copies to H. J. Neeld, G. J. Fryar.) VVV 000022784 H. J. Neeld Page 2 April 1, 1986 Note: In the event an incident report or subsequent correspondence involved the Conoco Dock facility, opportunity to review content of the report or correspondence prior to submittal. We feel the above process will satisfy Conoco*s independently analyze the implications of reportable Conoco and allows for appropriate joint Conoco-Vista activities. needs to events to compliance Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/8 cc R. A. Conrad S. H. Christiansen R. T. Ferrell J. Friend R. A. Frohreich H. D. Garrison M. G. Hayes M. Manion W. L. McClain J. H. McCulley Garvin Fryar - Conoco VVV 000022785 1 TO: Steve Ashby FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles March 31, 1986 REVIEW OF VCM PLANT HAZARD COMMUNICATION PROGRAM VIST/ I have reviewed the draft program. With the exceptions listed below, it appears complete and comprehensive. 1. To be complete, Section I.B.5. should also include the labeling requirements for containers leaving the plant. For example, add the following: All containers of hazardous materials leaving the plant shall be labeled as above and have the company name and address included. 2. Paragraph (e)(ii) of the Hazard Communication Standard requires that the written program describe the methods used to inform employees of the hazards of non-routine tasks and hazards associated with unlabeled pipes, etc. The program as written does not specifically address this requirement. I believe this is done by the work permit system. A section describing this procedure should be added. 3. a. Under Section IV, Hazard Determination, you should add a section specific to the hazard determination for plant (VISTA) products. This could be another appendix or included in the body of the procedure. b. The need for Appendix I is not clear to me. In particular the third page, entitled VCM Plant Non-Hazardous Chemicals List seems redundant. To avoid confusion I would recommend that you only include the third page of Appendix I, Appendix II, and Appendix V as your chemical lists. This would cause some changes in the text. 4. You should add a statement regarding the distribution of MSDSs for company products. I recommend you change the title of Section V-I to MMSDS for Product and Sample Shipments'* and add the following statement there: MSDSs for Vista products will be sent to customers as required by the standard from the corporate headquarters office. Please call if you have questions on the above. 65T>~----- --------------Thomas G. Grumbles ajo/8 VVV 0022786 Thomas G. Grumbles --12^=-- To K s VQ tb Ve\ie 1 VIS1A Oat* q V\^c*\ dl^a^ eA VWe looi eACio5t_^ ru/o^^ to - td PT\G>\4 ^TF VVV 000022787