Document N2yMLKz8NjOdkDaa1BdJBpKXp

Mary Ann Fisher Cconoco) To /l.A. DeBernardi Plant Manager Lake Charles VCM Plant Date 7/25/79 John Burns Vice President, Chemicals Suite 1904, Houston Berry St. John Liskow& Lewis One Shell Square, 50th Floor New Orleans, Louisiana 70139 t Attached is a copy of the PEDCo report that I received from EPA on Monday. -* j lh or- ~ ecu 00001903Z Q\(^](&](^\(^ VSR/ VMR/ ^|JR/ \W|R ^\/^\/S\/S\/S p/v^m/\qv/V^n> PEDCO ENVIRONMENTAL, INC. P.O. BOX 20337 DALLAS.TEXAS 75220 (214) 259-3577 TELEX (214) 254-4021 INVESTIGATION AND ANALYSIS OF CIRCUMSTANCES ASSOCIATED WITH THE DELAYED COMPLIANCE OF FOUR VINYL CHLORIDE SOURCES IN REGION VI CONTINUING AFTER THE STATUTORY DEADLINE OF OCTOBER 21, 1978 (CONOCO REPORT) Prepared by PEDCo Environmental, Inc. P.O. Box 20337 Dallas, Texas 75220 Contract No. 68-01-4147 Task No. 84 John R. Busik, Project Officer Martin E. Brittain, Task Manager Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY DIVISION OF STATIONARY SOURCE ENFORCEMENT WASHINGTON, D.C. 20460 July 1979 CHESTER TOWERS CORPORATE OFFICE 1 1 499 CHESTER ROAD CINCINNATI. OHIO 45246 (513)782-4700 CCR 000019034 DISCLAIMER This report was furnished to the U.S. Environmental Protec tion Agency by PEDCo Environmental, Inc., in fulfillment of Contract No. 68-01-4147. The contents of the report are re produced herein as received from the contractor. The opinions, findings, and conclusions expressed are those of the author and not necessarily those of the U.S. Environmental Protection Agency. 11 OCR 000019035 CONFIDENTIALITY CLAIMS Some of the information in this report have been labeled as "confidential" as claimed by Conoco Chemical Company and should be treated accordingly per secrecy agreement dated January 26, 1979. 111 CCR 000019036 ACKNOWLEDGMENTS This report was prepared under the direction of Mr. Thomas C. Ponder, Jr., of PEDCo Environmental, Inc. Coauthors were Dr. Herbert J. Belknap and Mr. Dilip H. Mehta. Task Manager for the U.S. Environmental Protection Agency was Mr. Martin E. Brittain. CCR 000019031 iv SUMMARY On October 21, 1976, under the authority of Section 112 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) promulgated regulations for the control of the hazardous air pollutant vinyl chloride. The regulations are designed to limit vinyl chloride emissions from ethylene dichloride (EDC), vinyl chloride, and polyvinyl chloride manufacturing plants. In accord ance with Section 112(2)(1)(B)(ii) of the Act, sources covered by the vinyl chloride regulations were required to achieve com pliance within 90 days of the effective date of the regulations unless a waiver of compliance, to extend no later than October 21, 1978, was granted by the Administrator (authority delegated to the Regions). On July 5, 1977, EPA granted Conoco Chemicals Company (Conoco) a waiver of compliance until October 21, 1978, for the completion of five compliance schedules at their EDC and vinyl chloride monomer (VCM) plants. Conoco did not meet the compli ance date of October 21, 1978, for two schedules, partly because of delays caused by strikes and rainy weather. Conoco began the VCM emission control project in 1975, long t4*$**^' before the National Emission Standards for Hazardous Air Pollu- ` f tants (NESHAPS) regulations for vinyl chloride were promulgated. Incinerator manufacturers were contacted in January 1976 to aid in the design, which was finalized in 1977. The incinerator was ordered from the John Zink Company in March 1977 for delivery on January 10, 1978. Construction schedules developed in Conoco's Engineering Department in 1976 allowed 6 months, from January 1 to July 1, 1978, for installation of the incinerator and associated piping. Because CCR 000019038 r P . L t_ the project was 2 months behind the original schedule by March 1, 1978, the construction conractor, H.E. Wiese, Inc., Baton Rouge, Louisiana, prepared a new schedule with a completion date of September 1, 1978. As a result of a Teamsters' strike, the construction project was delayed another 50 calendar days, and Wiese prepared a revised schedule with a completion date of October 18, 1978. Wiese offered to move up the completion date and increase project manpower if Conoco awarded them the contract for a second incinerator that was planned. When Conoco agreed, Wiese made a new schedule showing an increase in manpower up to a maximum of 104 workers and a completion date of September 23, 1978. The number of workers on the No. 1 Incinerator project was in creased. Wiese continually expressed confidence that they would complete the incinerator installation before October 1, 1978. The Teamsters' strike lasted from May 1 to June 14, 1978, and work resumed on June 20, 1978. Because this strike was against the Associated General Contractors, Conoco could not avoid the delay it caused. Conoco acted during and immediately after the strike to try to make up for the delay. During the strike Conoco continued delivery of construction materials to Lake Charles, a town near the construction site, and stored part of them in rented warehouses offsite. Meanwhile Conoco had piping fabrication work continue in an outside shop. As soon as the strike ended, Conoco bargained to obtain more workers for the No. 1 Incinerator project by awarding the contract for the second incinerator to the same contractor. 00001903 Despite these actions, Conoco was unable to get the incin erator installed before the compliance date of October 21, 1978. It would have been possible for Conoco to finish installing the incinerator after the strike if they had taken stronger action. This action was not taken because (1) Conoco had a fixed price contract with the construction contractor, and any changes or requests would have cost Conoco additional money, and (2) the contractor expressed confidence that his installation completion date of September 23, 1978, would be met. 1 'JoJ&X 'WUXf' After reviewing the information in the EPA files and the documents supplied by Conoco PEDCo believes that Conoco expected to complete the incinerator project before October 21, 1978. The capital expenditures for equipment and materials were made before October 21, 1978, and detailed plans were made for startup. Because operators were trained and paid in advance, Conoco did not save an appreciable amount of operating and maintenance costs from the delays; only supply and utility costs were saved. These savings were offset to some extent, however, by the cost of the Conoco engineers working on the project after the October 21 compliance date. After the strikes were over, Conoco requested an extension of the compliance date for a number of days equal to the length of the strikes. Conoco wrote letters to the EPA on June 21, June 28, and July 7, 1978, requesting the extension of the final compliance date to December 15, 1978. EPA reported that no written response to these letters was sent to Conoco. In other EPA regions, 9 companies subject to the VCM compli- ance deadline were issued 30-day compliance notices after 4' ***b October 21, 1978, which presented them the opportunity to make an all out effort to gain compliance (or shutdown), and in all cases , reviewed compliance was accomplished. /AfAtA- PEDCo made the following findings regarding Conoco1s options and subsequent actions to achieve compliance: 1. During the concrete haulers' strike, the following methods were available to reduce construction delays and Conoco took the actions shown: a. Obtain concrete from H & H Concrete Company. Conoco obtained concrete for 7 days from H & H Concrete Company during the strike. Conoco agreed to pay overtime rates to H & H Concrete Company and the Vincent Construction Company. Approximate cost in overtime for concrete and underground work was $9355. vii CCR 000019040 b. Obtain concrete in Orange, Texas. Conoco contacted a number of concrete suppliers in Orange, Texas. These concrete suppliers re fused to furnish concrete in the Lake Charles area, indicating that they could not deliver concrete to a point as far away as Lake Charles. c. Erect a concrete batch plant at construction site. Conoco examined in detail the possibility of erecting a concrete batch plant at the construc tion site. The strike ended, however, before Conoco could implement this plan. d. Utilize spot overtime. Conoco had contractors work overtime to compen- j) sate for delays caused by the concrete haulers1 strike. Conoco spent $9355 for overtime work^ on the concrete and underground* phase of the No. 1 Incinerator project. if , Ajrlix* .2 During the Teamsters' strike, the following methods were available to reduce construction delays: a. Continue work by the piping contractor. Conoco decided against the offer of H. E. Wiese to work under a national contract, because of a long history of labor turmoil in the Lake Charles area. Moreover, because Wiese was the only con tractor having a national contract, other con tractors' workers may have refused to cross the picket lines, further limiting construction acti vities. Of the contractors only Wiese had a national contract. b. Continue material deliveries. To continue deliveries of materials during the strike, Conoco had shipments delivered to the Lake Charles area and held at the local carriers' terminals. Arrangements were then made for carrier supervisors (who were able to cross the picket lines) to deliver the materials at the job site. In some cases warehouse space was leased where the materials could be stored until the strike ended. viii CCR 000019041 c. Continue piping fabrication Much piping fabrication, which otherwise would have been performed in the field proceeded in outside shops during the strike. The Millwrights' strike did not last long enough for Conoco to consider or implement any corrective actions to reduce the construction delays it caused. During the rainy weather, the following methods were available to reduce construction delays: a. Place shell on muddy roads and around the con struction site to improve vehicle traction. Roads and parking lots around the construction site were made accessible by placing shell on them. The approximate cost of this action was $27,000. b. Provide temporary shelters over work areas c. Continue shop work whenever possible. PEDCo was unable to determine whether the latter two methods were used by Conoco to reduce delays caused by rain. Before October 21, 1978, 7 temporary control measures were considered by Conoco to reduce vinyl chloride emissions. PEDCo reviewed these control measures and determined that it was not feasible for Conoco to implement any of them in given time period (see Section 5.5.1). No additional temporary control measures were identi fied by PEDCo, that were available to be implemented by Conoco. After October 21, 1978, the following additional temporary control measures were available to reduce vinyl chloride emissions: a. Reduce the plant production rate. VCM plant,production was reduced from about 8.85 x 10 kg/day (1.95 x 10 lb/day) to between 7,71 x 10 and 8.16 x 10J kg/day (1.7 x 10 - 1.8 x 10 lb/day) because of a problem with the pressure drop in the oxychlorination system. IX CCR 000019042 I I b. Vent dip sticks to holding vessels during loading. c. Remove from service tank cars containing oxygen in concentrations greater than 1,000 ppm; r rather than purging them with nitrogen. Conoco conducted a modeling study to determine the potential reduction in ground level concen trations of VCM if these measures were imple mented. The analysis of the modeling effort revealed that the potential reduction amounted to only 0.3 ppb. As a result of this analysis Conoco decided not to implement these temporary control measures as their impact was inconse- (ULtjrJLJUu. quential. PEDCo did not have enough information) ^ j to support this claim. 7. PEDCo analyzed the schedules supplied by Conoco and concluded that it was possible for Conoco to complete the installation of the VCM incinerator before October 21, 1978 (see Section 5.3). How^ever, schedules One and Four were out of compliance on October 21, 1978. The construction work was com- * pleted for these schedules within an additional period equal to the number of strike days (see Table 3, Section 5.3). The compliance testing, however, was delayed for these schedules beyond the number of strike days (see Table 4, Section 5.3). The construction schedules prepared after October 21, 1978, were not available to PEDCo. Although Conoco did not work two shifts per day, it appears that construction work was completed in an expeditious manner. After October 21, 1978, Conoco assigned one of their own engineers to work directly with Wiese. Conoco's direct participation helped facilitate completion of desired systems, but Conoco was still dissatisfied with the overall efficiency of construction activities. Conoco deleted certain tasks from Wiese's contract, and avoided assigning any further work. These jobs were accomplished by another contractor after Wiese finished (see Appendix X). , 8. The savings gained by Conoco from not meeting the J compliance date were mainly in deferred capital ssCtr&dtt expenditures. Savings in the operating and main- f tenance costs were made only on supplies and cO? Ooqj 9043 L utilities and not on labor costs, since the operators were trained and paid before the com pliance date. Moreover, these savings were offset, to some extent, by the expense of Conoco engi neers working on the project after the compliance date (see Section 6). xi CCR 00001904-4 CONTENTS ! Acknowledgments Page iv f Confidentiality Claims Sumary I Figures Tables iii V xvi xvii I 1. Introduction 2. Plant Description I 2.1 Introduction 2.2 Emission sources 2.3 Control practices 1 2 2 2 4 2.3.1 Thermal incineration system 4 2.3.2 Oxychlorination vent cleanup reactor 6 2.3.3 Process waste water stripper 6 2.3.4 Portable carbon adsorption system 7 '1 2.3.5 Installation of rupture discs under pressure relief valves 1 2.4 Compliance schedules 7 3. Causes of Delayed Compliance 12 3.1 Introduction l 3.2 Labor strikes 12 12 3.3 Inclement weather 14 4. Company Corrective Actions 15 4.1 Corrective actions to alleviate delayed compliance 15 4.1.1 Corrective actions to alleviate delayed compliance due to labor strikes 15 xii CC* .oooi45 CONTENTS (continued) 4.1.2 Corrective actions to alleviate delayed compliance due to inclement weather 4.1.3 Corrective actions to expedite equipment delivery 4.2 Temporary control measures 4.2.1 Temporary control measures considered by Conoco before October 21, 1978 4.2.2 Temporary control measures considered by Conoco after October 12, 1978 4.3 Process modification to reduce vinyl chloride emissions Delay Analyses 5.1 Analysis of procurement and purchase procedures for emission control equipment 5.2 Analysis of Conoco's corrective actions 5.2.1 Analysis of Conoco*s corrective actions during the labor strikes 5.2.2 Analysis of Conoco*s corrective actions to alleviate delays due to inclement weather 5.2.3 Analysis of Conoco's actions to expedite equipment delivery 5.3 Analysis of Conoco*s corrective actions after the Teamsters' strike 5.4 Analysis of the company corrective actions in other regional areas 5.4.1 Company corrective actions in Region II 5.4.2 Company corrective actions in Region III 5.4.3 Company corrective actions in Region IV 5.4.4 Company corrective actions in Region V 5.4.5 Company corrective actions in Region IX xiii Page 16 17 17 17 18 18 19 19 20 20 22 22 23 27 30 30 30 31 31 CCR 000019046 CONTENTS (continued) Page 5.5 Analysis of temporary control practices 31 5.5.1 Analysis of temporary control measures considered by Conoco before October 21, 1978 31 5.5.2 Analysis of temporary control measures considered by Conoco after October 21, 1978 33 6. Cost of Non-compliance 34 6.1 Total capital expenditure 34 6.2 Operating and maintenance costs 34 Appendices A. Approved waiver of compliance A-l B. Semiannual reports - VCM plant's compliance plan B-l C. Number of days lost due to inclement weather C-l D. Correspondence with Vincent Construction Company D-l E. Daily log - incinerator project E-l F. Overtime reserve - incinerator project F-l G. Correspondence with cement manufacturers G-l H. Proposal for an on-site concrete batch plant H-l I. History of labor turmoil in Lake Charles 1-1 J. Project review meeting - VCM incinerator J-l K. Work order cost control - shell purchase K-l L. Litwin's expediting reports L-l M. Communications with John Zink M-l N. Receipt for the delivery of fire brick N-l O. VCM emissions meeting - alternate control measures 0-1 P. Correspondence with incinerator manufacturers P-1 Q. Proposal invitation of engineering contract incinerator project Q-l R. Proposal evaluation - incinerator project R-l S. Engineering contract - incinerator project S-l T. List of Conoco personnel assigned to incinerator project T-l xiv CCR 000019047 CONTENTS (continued) U. V. W. X. Y. Z. AA. BB. CC* DD. Page Bid tabulation - piping and equipment installation U-l Progress report - incinerator project V-l Construction schedule - incinerator project W-l Performance of H. E. Wiese - Incinerator project X-l Manpower projections and construction schedule - incinerator project Y-l Instrumentation contractor - foremen's daily/weekly report Z-l Pipefitters and welders - high rate of turnover AA-1 PEDCo's correspondence with incinerator manufacturers BB-1 . Inventory summary CC-1 Cost data - incinerator project DD-1 xv CCR 000019048 FIGURES Number 1 VCM plant block flow diagramand vent identification. 2 Simplified process flow diagram of the VCM plant thermal incinerator. 3 Simplified process flow diagram of the VCM plant steam stripper. 4 Simplified process flow diagram of the dock recovery and carbon bed adsorption systems. Page 3 5 8 9 xvi CCR 000019049 TABLES Number 1 Conoco's Compliance Schedule 2 Manpower Projections and Construction Schedule for the No. 1 Incinerator 3 Number of Excessive Days Over Strike Days for Startup of Incinerator and Carbon Adsorption System 4 Number of Excessive Days Over Strike Days for Compliance Testing of Schedules 1 and 4 Page 10 24 28 29 xvii CCR 000019050 SECTION 1 INTRODUCTION On October 21, 1976, under the authority of Section 112 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) promulgated regulations for the control of the hazardous air pollutant vinyl chloride. The regulations are designed to limit vinyl chloride emissions from ethylene dichloride, vinyl chloride, and polyvinyl chloride manufacturing plants. In accordance with Section 112(2)(1)(B)(ii) of the Act, sources covered by the vinyl chloride regulations were required to achieve compliance within 90 days of the effective date of the regulations unless a waiver of compliance, to extend no later than October 21, 1978, was granted by the Administrator (authority delegated to the Regions). On July 5, 1977, EPA granted Conoco Chemicals Company (Conoco) a waiver of compliance until October 21, 1978, for the completion of five compliance schedules at their ethylene dichloride (EDC) and vinyl chloride monomer (VCM) plants. Conoco was unable to meet the compliance date of October 21, 1978 for two of the schedules partly, because of delays caused by strikes and rainy weather. The purpose of this task is to investigate and analyze the circumstances associated with the delayed compliance by Conoco. This report contains a brief description of the vinyl chloride plant, the control practices implemented to reduce vinyl chloride emissions at this plant along with the respective compliance schedules, causes of delayed compliance, and the corrective actions taken by the company. The last two sections of this report give PEDCo's analysis of the company's corrective actions and cost data. 1 CCR 000019051 SECTION 2 PLANT DESCRIPTION 2-1 INTRODUCTION Ethylene dichloride and vinyl chloride monomer are manufac tured in direct chlorination and oxychlorination processes. In these processes combined EDC stream is purified and thermally cracked in a gas-fired furnace to form VCM and anhydrous hydrogen chloride (HC1). The mixture is then distilled to separate the VCM from the HC1 and uncracked EDC. This VCM is neutralized, dried, and stored in pressure vessels. (Figure 1 shows a block flow diagram for the plant.). The normal VCM capacity of a plant is 2.95 x 10 kg/yr (3.25 x 10 tons/yr), and the maximum 85 capacity is 3.18 x 10 kg/yr (3.50 x 10 tons/yr). 2.2 EMISSION SOURCES There are six vinyl chloride emission point sources and four sources of fugitive vinyl chloride emissions at this plant. The point sources are: 1. C-500 vent stack. 2. EDC wash system vents. 3. Process wastewater. 4. EDC and light ends (L.E.) storage tanks. 5. VCM loading vent ^tack. 6. VCM dock vent stack. 2 CCR 000019052 ri Chlorine Ethylene OJ Ai r Ethylene o o 70 O oo o t-- 0 01 w Direct chlori nation Atmospheric vents(2) 1J EDC EDC * washing EDC ^cracking Oxychlorination EDC + Reaction water HC1 Distillation column vents C-500 vent stack (1) T-450 ,T-453 , and T-402.vents (4) EDC purification EDC and L. E. storage Pure EDC .> Water to effluent treatment^) Uncracked EDC Vinyl purifi cation VCM Rail car loading Ship loading Refrigeration system Dock vent stack(6) Loading ITvent stack (5) Figure 1. VCM plant block flow diagram and vent identification, (Numbers in parentheses indicate point sources.} The fugitive emission sources are: 7. 8. 9. 10. Pumps. Compressors. Relief valves. Vents (during manual venting)'. 2.3 CONTROL PRACTICES The following sections discuss the new control devices installed and revisions made to enable existing controls to reduce VCM in process wastewater to concentrations within the regulation limit of 10 ppm. 2.3.1 Thermal Incineration System Incineration is a combination of pyrolysis and oxidation. Pyrolysis occurs in seconds whereas oxidation takes only milli seconds. The temperatures and residence times necessary for complete destruction of different toxic substances vary widely, depending on the chemical and physical forms of the wastes to be incinerated. The relationship between temperature and residence time must be established before a given waste material can be effectively incinerated. If relationship are carefully observed, toxic air contaminant emissions from incineration can be minimized. Two thermal incinerators have been installed at this plant, eventhough one is probably adequate to achieve compliance. The second incinerator is a backup device used during malfunctions or required maintenance of the first. The incineration system includes two 14.07 MW (48 x 10^ Btu/h) units each designed to operate at 1316C (2400F) with a 1.5 second residence time. Each incinerator has a waste heat boiler to recover part of the heat of combustion, an HC1 absorp tion column to recover HC1, and a caustic scrubbing column to control residual HC1 and chlorine. Figure 2 is a simplified flow diagram of the VCM incineration system. The HC1 absorption ^ ^ ^ column was not in operation at the time of PEDCo's on-site , visit. 4 CCR 000019054 HC1 absorber Ln CCR 0 0 0 0 X 9 0 5 5 2.3.2 Oxychlorination Vent Cleanup Reactor This catalytic reactor was installed in July 1975 to control ethylene emissions in the oxychlorination vent. This reactor can control the VCM emission to the limit specified in the emission standard, namely 0.2 g per kg of EDC produced by the oxychlorina tion process. The efficiency or VCM removal depends greatly on the opera tion of the oxychlorination process and the chlorine feed. Small variations in the ethylene and VCM concentrations in the vented gas or in the chlorine flow to the reactor can cause large changes in the reactions and in reactor heat releases. Since the reactor contains more than 45,360 kg (100,000 lb) of catalyst and has no provision for cooling, a small change in the reaction and heat release can cause the reactor bed temperature to increase to the point that the reactor, the reactor catalyst, or downstream equipment can be damaged or destroyed. Modifications and optimi zation of this existing catalytic reactor were completed and tested prior to October 21, 1978. 2.3.3 Process Wastewater Stripper All process wastewater streams are stripped in a steam stripper to recover chlorinated hydrocarbons, including VCM, from the water before discharge to the effluent treatment system. The VCM content of the wastewater leaving the stripper is below the 10 ppm VCM concentration limit required by the standard. The VCM recovered is routed to the thermal incinerator through the two EDC wash system vents and the light ends distillation column and light ends product tank vents. A second spare steam stripper has been installed and instru-\ mented in a way to ensure that VCM is removed from the process wastewater at all times. A simplified flow diagram of the steam } stripper system is shown in Figure 3. J CCR 000019056 6 2.3.4 Portable Carbon Adsorption System A portable carbon-bed adsorption system has been installed to adsorb the VCM vented during sampling of the ship hold tanks and cleaning of the loading hoses as well as VCM vented from the hydroquinone injection system. The adsorption system uses four calgon vent-sorb adsorption beds in two parallel systems to recover the VCM in these vent streams. When saturated, the carbon-bed system is returned to the plant for regeneration. The VCM vapors from regeneration are routed to the thermal incinerator. The flow diagram of the dock recovery and carbon bed adsorption system is shown in Figure 4. 2.3.5 Installation of Rupture Discs under Pressure Relief Valves All the relief valves on equipment used in vinyl chloride production in the EDC and VCM plants have been equipped with rupture discs to minimize VCM emissions due to leakage. 2.4 COMPLIANCE SCHEDULES The compliance schedules proposed by Conoco in December 19.76, were approved by EPA on July 5, 1977 (see Appendix A) . The compliance schedules and the actual compliance dates are shown in Table 1. The actual compliance dates were obtained from the semiannual reports of March 15, 1979, and January 11, 1979, and the progress report of December 1, 1977 (see Appendix B). Schedule 1-- This schedule provided for the installation of an incinerator system and necessary manifold ducting. The sche dule required final compliance by October 21, 1978. Construction of the No. 1 Incinerator was completed by December 29, 1978, and the compliance tests were completed on January 12, 1979. Schedule 2-- This schedule provided for the modification and optimization of a catalytic reactor. The reactor was placed back on stream on September 25, 1978. The compliance tests on the vent streams from the oxychlorination reactor were completed 7 CCR 000019057 Light ends co to T-453 Figure 3. Simplified process flow diagram of the VCM plant steam stripper. CCR 0 0 0 0 1 9 0 5 8 CCR 0 0 0 0 1 Figure 4. Simplified process flow diagram of the dock recovery and carbon-bed adsorption systems. o o U1 r~ Schedule 1) Thermal incineration system 2) Oxychlorination vent cleanup reactor, R-305 3} Process waste water steam stripper revisions 4) Portable carbon adsorp tion system 5) Rupture disc installation TABLE 1. CONOCO COMPLIANCE SCHEDULES' Start Award contracts mechanical and/or design order equipment Start of Completion onsite of construction construction Regulatory compliance date 1 <_n I -j 5-1-77 1-1-78 10-1-78 10-21-78 2-15-77 4-1-77 7-1-77 2-1-78 10-21-78 6-1-77 10-1-77 4-1-78 8-1-78 10-21-78 2-15-78 4-1-78 6-1-78 8-1-78 10-21-78 2-15-77 4-1-77 8-1-77 2-1-78 2-1-78 Actual compliance dateb 1-12-79 10-19-78 < 2^,<M9',S barges : 1-20-79 4* ship: 2-21-79 12-1-77 fa aThese compliance schedules were approved by EPA on July 5, 1977 (see Appendix A), b The actual compliance dates were obtained from the semiannual reports of March 15, 1979, and January 11, 1979, and the December 1, 1977, progress report (see Appendix B). CCR o O O O oo o on October 19, 1978. The schedule required final compliance byOctober 21, 1978. Schedule 3-- This schedule provided for the reduction of VCM emissions from the process wastewater leaving the steam stripper. The compliance tests were completed on October 19, 1978. (Control of the vinyl chloride stripped from the wastewater is covered under compliance Schedule 1.). Schedule 4-- This schedule provided for the installation of a carbon-bed adsorption system to control VCM emissions from the following fugitive emission sources located in the EDC and VCM plants: 1) ship-loading lines and related hydroquinone injection system, 2) the compressor seals during inert purge, and 3) the ships' hold tanks during sampling. The construction work was completed on December 29, 1978. The compliance tests have been completed for the carbon adsorption system at the company's VCM ship and barge loading dock. A compliance test was conducted during the loading of two barges on January 20-21, 1979. Anothe compliance test was conducted during loading of a ship on February 21-22, 1979. Schedule 5-- This schedule provided for the installation of the rupture discs on the relief valves on the equipment in the EDC and VCM plants. The final compliance was met on December 1, 1977, well ahead of the regulatory compliance date of February 1, 1978. 11 SECTION 3 CAUSES OF DELAYED COMPLIANCE 3.1 INTRODUCTION The causes of delayed compliance at the Conoco plants were three labor strikes and inclement weather. These are discussed in detail in the following sections. 3.2 LABOR STRIKES Three labor strikes that occurred in the Lake Charles area from December 1977 to June 1978 caused subtantial delays in the installation of the No. 1 Incinerator. The first labor strike, involving concrete haulers, began on December 2, 1977 and lasted until January 9, 1978. H & H Concrete Company was the only concrete company in the Lake Charles area not affected. Although Conoco was able to obtain concrete on 7 days during the strike (through the Conoco-initial efforts ex plained in Section 4.1.1), 14 working days were lost as a result of the strike. The Teamsters' strike against the Associated General Contrac tors began on May 1, 1978. H. E. Wiese, the piping and equipment installation contractor, could have continued to work under a \ national contract despite the picket lines imposed by the localJ Teamsters. Conoco officials decided against taking advantage of this national contract, however, because of the risk of developing bad relations with the unions that might cause further delays later. Also it was believed that despite the national contract some workers would quit rather than cross the picket lines. 12 CCR 000019062 Pickets were removed from the site on June 14, 1978 and work resumed on June 20, 1978. Thirty-six working days (50 calendar days) were lost as a result of this strike. The Millwrights' strike against the Associated General Contractors began on June 26, 1978. Pickets were removed on June 29, 1978 and work resumed on June 30, 1978. Four working days were lost as a result of this strike. These strike dates have been verified by union and construction contractor officials as follows: 1. Mr. Jim Welch, General Manager, Associated General Contractors of Louisiana verified the dates of all three strikes: the concrete haulers' strike from December 2, 1977 through January 9, 1978, the Teamsters' strike from May 1, 1978 through June 14, 1978, and the Millwrights' strike from June 26 through June 29, 1978. He also said that labor unions in the Lake Charles area were strong and that violence had erupted in the past when another union hiring multicraft workers attempted to work in the area. For these reasons, the labor unions were believed to be potentially volatile. Welch also confirmed that there was no shortage of workers in the Lake Charles area in the July through October 1978 period, except for some spot shortages of pipefitters and welders in October, November, and December, 1978. .2 Mr. Hollis Midkiff, Business Agent, Millwrights' local No. 1476 verified the Millwrights' strike dates as June 26 through June 29, 1978 . He said that he was not \ aware of any labor shortages in the Lake Charles area jZhf'ML in the fall of 1978. ^/ 3. Mr. Herman Rousseau, Assistant Business Agent, Teamsters' local No. 969 verified in a telephone interview the Teamsters' strike dates as May 1 through June 14, 1978. 4. Mr. Donnie R. Lee, Assistant Business Agent, Local 102 of the American Federation of Unions, Lake Charles District, confirmed the strike dates and said that he was not aware of any labor shortages in that area in J rfufaL (pd&f' the fall of 1978. - Ja ( 13 CCR 000019063 3.3 INCLEMENT WEATHER Conoco maintained that during the period October 11, 1977, through October 21, 1978, 26 days were lost because of rainy weather (see Appendix C). Of these, 19 working days were lost between October 1977 and March 5, 1978, and 7 working days during the critical period between April 1, 1978, and October 21, 1978. When contacted by telephone, the U.S. Weather Bureau at Lake Charles verified that there had been rain in the area on the days that Conoco said were lost (see Appendix C). 14 CCR 000019064 SECTION 4 COMPANY CORRECTIVE ACTIONS 4.1 CORRECTIVE ACTIONS TO ALLEVIATE DELAYED COMPLIANCE This section identifies the corrective actions Conoco con\ sidered and/or implemented to avoid delays in compliance due labor strikes and bad weather, (A third potential cause of A* delays, slow equipment delivery, was avoided through deliberate company action.). 4.1.1. Corrective Actions to Alleviate Delayed Compliance Due to Labor Strikes Conoco considered a number of measures to avoid delays resulting from strikes. Some of these measures were implemented. The concrete haulers' strike affected all concrete suppliers in the Lake Charles area except one, H & H Concrete Company. Conoco contacted the H & H Concrete Company and agreed to take available concrete on a spot basis (see Appendix D). Conoco was able to obtain concrete on 7 days during the strike period by agreeing to pay overtime rates to both H & H Concrete Company and Vincent Construction Company (see Appendices E and F). Mr. Dan Kidd of Conoco called a number of concrete suppliers in Orange, Texas (see Appendix G). The notes reflect that these suppliers refused to furnish concrete in the Lake Charles area because it was too far away. Conoco examined in detail the possibility of erecting a concrete batch plant at the construction site (see Appendix H). The strike ended, however, before this plan could be implemented. . 15 000019065 OCR In addition, Conoco had contractor employees work overtime to compensate for the delays caused by the concrete haulers' strike (see Appendix E). Conoco spent $9355 in overtime for the concrete and underground phase of the No. 1 Incinerator project (see Appendix F). During the Teamsters' strike of May 1, 1978, H.E. Wiese ' advised Conoco that Wiese could continue to work under a national contract despite the picket lines imposed by local Teamsters. / Conoco carefully considered this available option and decided against it because of the history of labor problems in the Lake Charles area (see Appendix I). During the Teamsters' strike, the delivery of materials to the site became difficult. Conoco decided to continue having materials shipped to the area and, to overcome these strike- related delivery problems, made special arrangements for delivery When materials reached Lake Charles, several measures were em ployed. In some cases the shipments were held at the local carriers' terminals until carriers' supervisory personnel (who were able to cross the picket lines) could deliver the materials to the job site. In other cases warehouse space was leased where the materials could be stored until the strike ended. During the Teamsters' strike, piping fabrication proceeded in outside shops at Conoco's insistence. This made possible more rapid installation when field work was resumed (see Appendix J). During the Millwrights' strike, Conoco was unable to take any corrective actions because the strike lasted only 4 working days. 4.1.2 Corrective Actions to Alleviate Delayed Compliance Due to Inclement Weather From November 1977 through March 1978, Conoco spent more than $27,000 to place shell on muddy roads and parking areas in and around the construction site (see Appendix K). In addition, Conoco used overtime labor to partially over come the effects of weather delays (see Appendix E). 16 CC 000019066 4.1.3 Corrective Actions to Expedite Equipment Delivery Two of the primary responsibilities of the engineering contractor, Litwin Corporation, were to procure the materials necessary for the project and to expedite delivery of those items (see Appendix L). Because Litwin performed well, Conoco did not cite equipment delivery as a cause of delay. In addition, in March 1978, Conoco learned that the fabrica tor of the boiler (J. Zink) had completed the fabrication. Because there were only six railcars capable of transporting this unit available in the United States, a delay of 6 weeks or more was anticipated while awaiting a railcar. Conoco took extra measures to expedite delivery. A railcar of the proper type was quickly obtained and furnished to Zink. Conoco personnel followed the unit on its trip from the Zink plant to Westlake. These efforts expedited the unit's arrival by several weeks (see Appendix M). On one occasion, arrangements were made to freight by air the fire brick for the incinerator to insure that no delays occurred (see Appendix N). 4.2 TEMPORARY CONTROL MEASURES This section discusses in two parts the temporary control measures considered by Conoco before and after October 21, 1978. 4.2.1 Temporary Control Measures Considered by Conoco Before October 21, 1978 Conoco considered the following temporary control measures in response to the EPA inquiry. 1. Routing of VCM vents to a flare stack. 2. Routing of VCM vents to a boiler or cracking furnace. 3. Securing a portable incinerator. 4. Routing of plant vents to a controlled incinerator at another plant. 5. Routing of VCM vents through the existing oxy system vent control device. 17 CCR 000019067 .6 Installing regenerable carbon-bed systems. 7. Storing VCM vapor from vents in a large pressure tank and shipping by tank car or tank truck to a controlled location. 4.2.2 Temporary Control Measures Considered by Conoco After October 21, 1978 After October 21, 1978, Conoco considered the following additional temporary control measures: 1. Reducing the plant production rate. 2. Venting dip sticks to holding vessels during loading. 3. Removing from service tank cars that contained oxygen in concentrations greater than 1000 ppm rather than purging them with nitrogen. 4.3 PROCESS MODIFICATION TO REDUCE VINYL CHLORIDE EMISSIONS Conoco considered the following process changes to reduce VCM emissions but maintains that these process changes would have been impractical to implement. 1. Converting the oxy process from an air-based to an oxygen-based system. It is estimated that this would have taken 2 to 3 years to complete. 2. Taking EDC overhead in the vinyl product from the vinyl tower. This would reduce VCM in recycled EDC that vents in T-101, but the VCM would not be salable with EDC in it. 3. Eliminating caustic usage in the VCM neutralization system. This would eliminate the majority of VCM in the wash system and steam stripper vent, but the VCM would not be salable with HCl in it. 18 CCR OOOOlRO60 SECTION 5 DELAY ANALYSES 5.1 ANALYSIS OF PROCUREMENT AND PURCHASE PROCEDURES FOR EMISSION CONTROL EQUIPMENT This section presents an analysis of Conoco's procurement and purchase procedures to show why no construction delays were attributed to slow equipment deliveries. PEDCo has reviewed and analyzed the relevant documents furnished by Conoco to determine whether proper procedures were made and priorities established. 'rw < ---T' T -- -----y-i 1. Conoco placed a fairly high priority on installation of vinyl chloride emission control system. This is shown by the following: a. Conoco1s research staff began preliminary design work on a vinyl chloride destruction system early in 1975 (see Appendix 0). They chose thermal incineration as the best method, after considering both catalytic oxidation and carbon adsorption. Engineer ing design work was begun in early 1976, when the John Zink Company and the Trane-Thermal Company were contacted concerning preliminary designs (see Appendix P). b. The awarding of an engineering contract to Litwin for the procurement and delivery of the majority of the equipment and materials for the project (see Appendices Q, R, S). Through the efforts of Litwin and Conoco, all equipment an' when needed. c. Conoco assigned what appears to have been an adequate number of highly qualified and experienced construction engineers to this project (see Appendix T). 2. Conoco solicited bids for all major equipment and contracts in this project (see Appendices R, U). 19 CCR 000019069 An approved bidders list was compiled first for each procurement or contract and bid specifications were developed and sent to the qualified bidders. The bids for each phase were tabulated and compared, and awards were made on the basis of standard selection criteria. The work was divided into three parts, each of which was bid on separately. Ten bids were recieved for the engineering contract, five for the piping and equipment installation contract, and one for the incinerator. In the opinion of Conoco, only the John Zink Company was qualified to build the incinerator to Conoco1s design and reliability specifications. Trane-Thermal was rejected as a potential incinerator supplier because they wanted to utilize a higher temperature and a shorter residence time than specified by the Conoco design. 3. The selection criteria used by Conoco were standard criteria utilized by most companies receiving compe titive bids. The following selection criteria were considered by Conoco (see Appendices R, U): a. Cost. (Because all bidders were qualified for the job, some preference was given to the lowest bidder.) b. Ability to bring about timely completion of the construction or delivery schedule. c. Expected quality or reliability of the equipment or completed work. An important criterion for the engineering contract was the ability to provide qualified manpower to work on the project when needed (see Appendix S). The bidder selected was carefully investigated before being awarded the contract. Conoco had previously investigated the H. E. Wiese Company and determined their qualification for the job. PEDCo reached the overall conclusion that the procure ment procedures used by Conoco were in accordance with standard company procedures and good engineering practice and are consistent with those used by other companies. 5.2 ANALYSIS OF CONOCO'S CORRECTIVE ACTIONS 5.2.1 Analysis of Conoco1s Corrective Actions During the Labor Strikes During the concrete haulers' strike Conoco took the following- corrective actions: 20 CCR 000019070 1. Conoco obtained concrete for 7 days from H & H Concrete Company during the strike. Conoco agreed to pay overtime rates to H & H Concrete Company and the Vincent Construction Company. 2. Conoco contacted a number of concrete suppliers in Orange, Texas. These concrete suppliers refused to furnish concrete in the Lake Charles area, indicating that it was too far away. 3. Conoco examined in detail the possibility of erecting a concrete batch plant at the construction site. The strike ended, however, before Conoco could implement this plan. 4. Conoco had contractor employees work overtime to compensate for time lost to the concrete haulers' strike. Conoco spent $9355 in overtime for the concrete and underground phase of the No. 1 Incinerator project. During the Teamsters' strike Conoco carefully considered taking advantage of Wiese's national contract but decided not to because of the following two incidents that occurred in the Lake Charles area. 1. In January 1975, the OCAW had a strike against Conoco's Westlake Refinery and Chemical Plant. Conoco states that its Gillis Gas Plant was deliberately sabotaged, causing big gas flares, the evacuation of 300 persons, and the interruption of natural gas supplies to several industrial users in southwest Louisiana. In this incident, chains holding valves open on the 24" inch pipeline were cut and the valves closed. The re sulting pressure buildup caused the safety valve at the plant to pop open, which in turn caused big gas flares. 2. On January 15, 1976, in the Lake Charles area, work at the Jupiter Chemical Company ammonia plant construc tion site was halted after a flareup of labor violence. This incident left one person dead, four others injured, and 16 cars and trucks and two mobile offices damaged. The attack was believed to be the result of the labor dispute over the use of "multicraft" union workers belonging to Local 102 of the American Federation of Unions, a group not affiliated with the AFL-CIO. The Local 102 workers were employed by Payne and Keller of Baton Rouge, Louisiana. This attack occurred one week after a similar attack on a Payne and Keller project near Houston employing the multicraft workers. 21 CCR 000019071 These two incidents explain Conoco1s2 apprehension and deci sion not to take advantange of Wiese's national contract. During the Teamsters' strike, delivery of materials was continued and materials were stored in Lake Charles warehouses. Also, considerable piping fabrication was done in outside shops. These measures allowed high productivity when field work on the. construction project was resumed. -------^ During the Millwrights' strike, which lasted only 4 days, Conoco did not have enough time to take any corrective actions. PEDCo concludes that Conoco took all the possible corrective actions to alleviate the delay caused by the concrete haulers' and the Teamsters' strikes. 5.2.2 Analysis of Conoco's Corrective Actions Taken to Alleviate Delays Due to Inclement Weather 1. Conoco spent $27,000 to place shell on muddy roads and parking areas in and around the construction site. 2. Conoco paid overtime to expedite concrete and under ground work. From the above mentioned measures, it can be seen that Conoco took some corrective actions required to alleviate the delay caused by the inclement weather. Other corrective actions that could have been taken by Conoco were: (1) build temporary shelters over work areas, and (2) continue shop work whenever rain made field work impossible. Thus Conoco did not use all the \ corrective actions available to alleviate delays due to inclement / weather. 5.2.3 Analysis of Conoco's Actions to Expedite Equipment Delivery Litwin and Conoco made special efforts to expedite the equipment deliveries. 1. Litwin procured the necessary materials for the project and expedited delivery of those items. 2. Conoco furnished a railcar of the proper size to Zink for the timely delivery of the incinerator and waste heat boiler. 22 OCR 000019072 3. On one occasion, arrangements were made to freight by air the fire brick for the incinerator* As a result of the above measures no delays resulted from equipment deliveries. 5.3 ANALYSIS OF CONOCO'S CORRECTIVE ACTIONS AFTER THE TEAMSTERS' STRIKE The construction contractor, H. E. Wiese, Inc., moved to the jobsite on March 13, 1978. Wiese's construction schedule showed a completion date of September 1, 1978, 24 weeks after start) using a maximum of 40 workers and requiring 32,560 man-hours. Wiese's schedule was evaluated by Joe Alix of Conoco on March 27, 1978 (see Appendix V). The schedule and manpower projections appeared to be realizable. After the 50-day Teamsters' strike was over, the construction was 50-days behind schedule. A revised schedule prepared by Conoco's Central Engineering Department on July 7, 1978, showed a completion date for the mechanical portion of the work of October 14, 1978 (see Appendix W). A revised schedule issued by Wiese showed a completion date of October 14, 1978 (see Appendix X). At this time, Conoco was preparing to award the construction contract for the installation of the second incinerator. Wiese proposed that if they were awarded the contract for the second incinerator, they would increase the manpower working on the first incinerator immediately and shorten the schedule. Wiese revised their schedule on June 19, 1978, showing a projected increase in workers up to 104 for the first incinerator and a completion date of September 23, 1978 (see Appendix Y). Although Wiese was not the low bidder for the second incinerator, Conoco awarded the contract to them as a means of obtaining the most workers for the first incinerator in the shortest time (see Appendices X, Y). Table 2 shows the construction schedule and manpower projections for the No. 1 Incinerator and piping contract. After the award of the second incinerator contract, Wiese ex pressed confidence in their revised construction schedule, which showed a completion date of September 23, 1978. 23 CCR 000019073 Week ending TABLE 2. MANPOWER PROJECTIONS AND CONSTRUCTION SCHEDULE FOR THE NO. 1 INCINERATOR PIPING AND INSTALLATION PROJECT Wiese schedule Men Cumulative employed man-hours Actual (projected)3 Men Weekly Cumulative employed Days man-hours man-hours Actual (pro- jected) % comp. 6-24-78 7-1-78 7-8-78 7-15-78 7-22-78 7-29-78 8-5-78 8-12-78 8-19-78 8-26-78 9-2-78 9-9-78 9-16-78 9-23-78 28 52 78 102 104 93 86 80 68 50 32 27 8 1,360 3,440 6,560 10,640 14,800 18,520 21,960 25,160 27,880 29,880 31,160 32,240 32,560 35 30 39.4 58.4 63.8 77 77.6 (80) (95) (95) (95) (80) (27) (8) 5 1,400 1 240 5 1,576 5 2,336 5 2,522 4 2,464 4.5 2,796 (3,200) (3,800) (3,800) (3,800) (3,200) (1,076) (320) 1,400 1 ,640 3,216 5,552 8,104 10,568 13,364 (16,564) (20,364) (24,164) (27,964) (31,164) (32,240) (32,560) 35.5 43.4 48.0 (59.2) (65.3) (78.3) (88.1) (96.3) (99.1) (100.0) a This table was made up after week ending August 5, 1978, showing actual men and days worked through week ending August 5, 1978. Entries after August 5, 1978, are projections and are shown in parentheses. This table was retyped from the table shown on p. Y-18. 24 CCR OOOOI9074 Chronology of interactions between Wiese and Conoco from July to September 1978 (see Appendix Y): 7/15/78 7/29/78 8/5/78 8/9/78 8/12/78 8/15/78 8/23/78 8/28/78 9/6/78 9/20/78 Conoco data showed Wiese was ahead of schedule. Conoco data showed Wiese was behind schedule. Conoco data showed Wiese was behind schedule. Conoco met with Wiese. Wiese expressed confidence in achieving their 9/16/78 completion schedule. Conoco data showed Wiese was still behind schedule, but improving. Conoco met with Wiese. They agreed to provide additional supervision. An additional Wiese supervisor began work. Conoco data showed Wiese's progress was poor. Mr. L. B. McCormick of Conoco1s Maintenance Engineering Department began evaluation of Wiese's schedule (CPM). A critical path analysis was developed. Conoco met with Wiese and presented Conoco require ments for phased completion by 10/9/78. Wiese management was committed to that schedule. During August and September 1978, Wiese expressed confidence that the project would be completed on schedule. Conoco took some actions to speed up progress in the first \ week of October 1978, but earlier they preferred not to interfere] with the contractor because of the fixed price contract. Wiese Vt had a fixed price, turnkey contract, and any interference by Conoco would have added to the cost of the project. Conoco did inform Wiese, however, that their productivity level was low, and they were lacking sufficient supervision. Conoco maintained an overtime reserve for this project. The overall allocation was $175,000, of which $78 ,.761 was allocated toj^.^y. the piping and equipment installation project (see Appendix F). j&bf'<*J As of October 31, 1978, $24,130 had been committed, but only s $8,749 had been expended. Conoco had authorized and encouraged, Wiese to use spot overtime labor whenever Wiese thought it feasi ble. Scheduled overtime labor was not used, however, because, in Conoco's opinion, in the Lake Charles labor market scheduled 25 CCR 000019075 overtime labor was not productive. Jim Welch, Business Manager, Associated General Contractors, supports this statement. Conoco arranged to have the instrumentation contractor perform work in parallel with the piping and electrical work to expedite installation. (Generally, instrumentation contractor work follows behind the piping work.). To do this Conoco arranged for the instrumentation contractor to supply additional workers. Because the addition of these workers necessitated the use of a "nonworking" supervisor, Conoco agreed to pay for the time of that supervisor (see Appendix 2). An analysis of the Wiese construction schedules and manpower projections shows that Wiese contracted to construct the facility in 24 weeks using an average of 34 workers per week and a total of 32,560 man-hours. After the strike, on July 1, 1978, there were 12 weeks before September 22, 1978 (the last date that would allow compliance demonstration by October 21, 1978). Projected manpower loadings were up to a maximum of 104 workers with an average of 66 workers each week and a total of 32,040 man-hours after the strike. This projected manpower appears to have been entirely sufficient to complete this project on time. Conoco recognized the poor productivity of the Wiese workers as early as July 1978. They said the major cause was the lack of Wiese supervision. Wiese said they had the normal amount of supervision on the job, that is, one supervisor for 40 to 80 workers in addition to the working foremen and general foremen required by the union. Wiese stated that the following factors contributed to the low productivity: 1. Conoco's strict welding inspection requirements. 2. High rate of worker turnover (see Appendix AA). 3. Frequent rainouts. 4. The difficulty in working the furan pipe. 5. The strong union shop in the area. 26 000019076 OCR One major impact of the Teamsters' strike was to prevent Conoco from recognizing Wiese's low productivity and generally poor performance until late in the project. If Conoco had been able to recognize these earlier, they might have taken over from] Wiese in time to complete the installation by October 21, 1978. From the above schedules and analyses, PEDCo concludes that I it was possible for Conoco to complete the installation of the / VCM incinerator before October 21, 1978. Schedules One and Four were out of compliance on October 21, 1978. The construction work was completed for these schedules within an additional period equal to the length of strike (see Table 3); however, compliance testing was delayed for these schedules beyond the number of strike days (see Table 4). The construction schedules prepared after October 21, 1978, were not available to PEDCo. It appears that the construction work was completed in an expeditious manner for one shift opera-y tion. (Conoco was led to believe that a two-shift schedule would not have been significantly faster.). After October 21, 1978, Conoco assigned an engineer to work directly with Wiese to: 1. List for Wiese the work required to complete a system. 2. Plan the procedure for hydrostatic testing. 3. Witness the testing. This direct participation by Conoco resulted in completion of desired systems. Conoco was still dissatisfied, however, with the efficiency of construction activity. Conoco deleted certain tasks from Wiese's contract, and avoided assigning any further work. These items were accomplished by another contractor after Wiese left the project (see Appendix X). 5.4 ANALYSIS OF THE COMPANY CORRECTIVE ACTIONS IN OTHER REGIONAL AREAS Company corrective actions implemented in Regions II, III, IV, V, and IX are discussed in detail in the following sections. There are no vinyl chloride sources in Regions I, VII, VIII, and X. 27 CCR 000019077 TABLE 3. NUMBER OF EXCESSIVE DAYS OVER STRIKE DAYS FOR STARTUP OF INCINERATOR AND CARBON ADSORPTION SYSTEM Schedules Regulatory Actual compliance startup date date Number of days past compliance date Number of days lost due to strikes Concrete Team Mi 11 - haulers' sters 1 wrights1 Total number of days lost due to strikes Number of days unaccounted for 1 (incinerator) 4 (barges) 4 (ship) tO CO 10-21-78 10-21-78 10-21-78 12-29-78 12-29-78 12-29-78 69 69 69 18 50 4 18 50 4 18 50 4 72 72 72 ---- TABLE 4. NUMBER OF EXCESSIVE DAYS OVER STRIKE DAYS FOR COMPLIANCE TESTING OF SCHEDULES 1 AND 4 Schedules 1 (incinerator) 4 (barges) 4 (ship) Regulatory compliance date 10-21-78 10-21-78 10-21-78 Compliance test date 1-12-79 1-20-79 2-21-79 Number of days past compliance date 83 91 123 Total Number of days lost due to strikes number of days lost Concrete Team Mi 11 - due to haulers' sters ' wrights1 ^ strikes 18 50 4 18 50 4 18 50 4 72 72 72 Number of days unaccounted 1for n 1! J CCR 0 0 0 0 1 9 0 7 9 I /yd^ot7^ L/i /* ^ - 5.4.1 Company Corrective Actions in Region II Three vinyl chloride sources in this region--a Hooker Chemicals plant and two Tenneco plants--did not meet the statutory deadline. These sources were issued 30 day notices to comply 1 with the VCM emission standard. Marcus Kantz, EPA Region II reported, that Hooker Chemicals had spent $500,000 in overtime to meet the November 21, 1978, deadline. The remaining two vinyl chloride sources also met the November 21, 1978, deadline. The Panasote Company in Puerto Rico would have been out of compliance on October 21, 1978. To meet standards, however, they used a temporary control measure to comply with the VCM emission standard by transporting VCM in a pressurized tank car to the PPG incinerator. 5.4.2 Company Corrective Actions in Region III Six vinyl chloride sources in this region did not meet the statutory deadline. These sources were issued 30-day notices postponing the compliance deadline for the VCM emission standard by November 20, 1978. Peter Schaul, EPA Region III, reported that Stauffer Chemical I Company had experienced labor problems during the construction period. The corrective action taken by the company was to work until midnight for 1 month to meet the November 20, 1978, deadline. -< Diamond Shamrock also had experienced labor problems during the construction period. The company's corrective action taken was to work two shifts for 1 month to meet the November 20, 1978, deadline. Also, Diamond Shamrock had experienced labor problems during the construction period. The corrective action taken was to work two shifts for one month to meet the November 20, 1978, deadline. All six vinyl chloride sources in this region met the November 20, 1978, deadline. 5.4.3 Company Corrective Actions in Region IV Air Products was the only vinyl chloride source in this region that did not meet the statutory deadline. To comply with 30 CCR 000019080 standards, Air Products was replacing the existing plant with a new one. The company was fined for operating the old plant past the October 21, 1978, deadline because of delays, they had been unable to start up the new unit. 5.4.4 Company Corrective Actions in Region V All vinyl chloride sources in this region met the statutory deadline of October 21, 1978. 5.4.5. Company Corrective Actions in Region IX All vinyl chloride sources in this region met the statutory deadline of October 21, 1978. 5.5 ANALYSIS OF TEMPORARY CONTROL PRACTICES 5.5.1 Analysis of Temporary Control Measures Considered by Conoco Before October 21, 1978 A number of temporary measures were considered by Conoco before October 21, 1978. PEDCo has evaluated all of these measures to determine whether it was feasible for the company to implement them in the given time period. 1, Route VCM vents to flare stack. No flares existed at the plant prior to October 1978. Design, purchase, and installation would have been required, including rerouting of the vent system piping. Equipment design, procurement, and installation would have taken 6 to 9 months. 2. Route VCM vents to boiler or cracking furnace. This VCM plant does not have fired boilers. Extensive design modifications to the plant vent systems would have been required to route vents to cracking furnaces. Because the furnaces are induced draft type, changes would ^ave been re quired to assure sufficient oxygen for vent combus tion. The time required for delivery of the air blowers and combustion control was estimated to be 3 to 4 months. The hydrogen chloride formed on combustion would have gone uncontrolled to the atmoshpere. 31 CCR 000019081 3. Secure a portable incinerator. After contacting various incinerator manufacturers PEDCo was informed that portable incinerators can not be rented or purchased on short notice but must be designed specifically for the job for which they are to be used. It would have taken incinerator manufacturers approximately 6 to 9 months to deliver a pallet-mounted portable incine rator (see Appendix BB). 4. Route plant vents to an existing controlled incinerator at another plant. Incinerators were available at the PPG plant, 3 miles from the Conoco plant. The installa tion of pipelines and a compressor system would have been required to route plant vents to PPG incinerators. Conoco maintains that even if installing of pipelines and a compressor were feasible, they did not believe PPG would have had any spare incinerator capacity, because PPG was installing an additional incinerator at the plant to meet their own needs. PEDCo did not have enough information to support this conclusion 5. Route VCM vents through the vent control device for the oxy system. Significant vent piping modifications would have been required to route vents to the oxy system. In addition, compressors would have been needed to vent emissions into the oxy system, because it operates at higher pressure than any of the other venting process equipment. 6. Install regenerable carbon-bed systems. Design, procurement, and installation of regener able carbon bed systems were not feasible in the given time period. Furthermore, regeneration would have been impossible without a control device such as a flare or incinerator. 7. Store VCM vapors from vents in a large pressure tank and ship by tank car or tank truck to a disposal site. Equipment such as compressors, a refrigeration system, piping, and loading facilities would have been required to store VCM vents in a pressure tank and then ship to an incinerator. Design, procurement, and installation of the system would have taken approximately 6 to 9 months. 32 CCR 000019082 An overall conclusion was reached that Conoco did not have enough time to implement any of these temporary control measures before October 21, 1978. 5.5.2 Analysis of Temporary Control Measures Considered by Conoco After October 21, 1978 Conoco considered the following additional temporary control measures after October 21, 1978. 1. Reduce the plant production rate. 2. Vent dip sticks to holding vessels during loading. 3. Remove from service tank cars that contained oxygen in concentrations greater than 1,000 ppm, rather than purging them with nitrogen. Conoco conducted a modeling study to determine the potential reduction in ground level concentrations of VCM if these measures were implemented. The modeling effort revealed that the potential reduction amounted to only 0.3 ppb. As a result of this analysis Conoco concluded that implementation of these measures would be worthwhile. PEDCo did not have enough information to supp this conclusion. 5 Plant production of VCM was reduced from about 8.85 x 10 kg/day (1.95 X 10^ lb/day) to between 7.71 x 10"* and 8.16 x 10^ kg/day (1.7 x 106 to 1.8 x 106 lb/day), because of a problem with the pressure drop of the oxychlorination system (see Appendix CC) . OCR 000019083 33 SECTION 6 COST OF NON-COMPLIANCE 6.1 TOTAL CAPITAL EXPENDITURE Conoco has estimated total capital expenditure for the No. 1 Incinerator project from the project report (see Appendix DD). It is divided into expenditures made through October 1978, and those made after October 31, 1978. Expenditures through 10/31/78 Expenditures after 10/31/78 $5,523,124 356,876 Total capital expenditures $5,880,000 The capital expenditures for equipment and materials were made before October 21, 1978. The deferred capital expenditure was mainly for labor used in the delayed construction. ; sCtrttdh- 6.2 OPERATING AND MAINTENANCE (O&M) COSTS O&M costs are based on budget projections because Conoco did not have operating experience when they submitted these O&M costs. Operating costs include operating payroll, processing supplies and paying for utilities. Payroll cost was incurred for the operator training and prestartup before the control equipment was liop in operation. Costs for supplies and utilities however, were deferred. Maintenance costs include maintenance payroll and materials and contract costs. Money was spent before startup on precommis sioning activities. Conoco estimates that the cost of these CCR 000019084 34 activities about equalled the cost budgeted for maintenance. Therefore, no maintenance cost savings were realized from delays of project completion. Conoco estimates deferred operating and maintenance costs at $349/day (see Appendix DD). Total savings from deferred operating and maintenance costV^ -Jfor 83 days (for the period from October 21, 1978, through Janu ary 12, 1979) is $28,967. These savings, representing supplies and utilities, however, were offset to some extent by the Conoco personnel working on the project after the compliance date. ' 35 CCR 000019085 ww JUT J5gR/ Vi/ Vfro/ Votr/ VOTS^ OTR/ VSiR, ^gg>. vVy PEDCo ENVIRONMENTAL ,^gp*/ v<M|py, x<py '.pr OCR 000019086 APPENDIX A APPROVED WAIVER OF COMPLIANCE 0000V* CCft -frD-( - \(\*T, ) / JUL 0 5 1277 I i.r. J. A. Deilornardi PI tint manager Conti nor. till uil Company P, 0. Cox 605 liestlnhn, Louisiana 70C69 Hear i,r. tobernurai: Ycur letter dated December 21, 1076, supplemented by information on l-iarcii td, 19/7 recounting a waiver of corny! iauce frem certain re.'uiroisonts of the r;:cior.a] hcisarcsus omission ntancarh fer vinyl chlorice (AO CFR bore 01, 0si;port F) for your Cbd and v'Cii facilities lccar.au in liestlckc, Louisiana has been received and revion-ad. require: vows or no u-u rare oi, incjuaitv) nui^.'-.-re r, imst uc comwii with In all respects curing the period of October 21, 1970 to i.ou tensination case of ilia waiver unless specifically discussea in the enclosure to this letter. J The enforcement Division Director, Region VI, environmental Protection Agency, 1ZC1 Eki Street, Dallas, Texas 7S270, trust be notified no later than 10 cays after each increment of progress has been achieved. Prior to the* termination date or the waiver, you are required to test er.vir.si'.'ne, using an aoproveo test method, from the sources listed in the enclosure to cc.rcr.r.trr.te compliance with the vinyl chlcrice standard. This office waist be notifies at lease jj days prior to such omission test so that we i.ay have an opportunity to observe the test. The c...issicn test shall te conducted and reported as required by oO CFR Fart Cl. For live res dining subject sources and vents which require testing, Chat are not collocated in the enclosure, i.c., these sources and vents which you consicer to bo in cemol lance with the S'carmarc, you are also required to conduct appropriate emission tests. The schedule for ccniiuctinj these tests will be arranged fnrcu.jii cur .Surveillance aim analysis Division. For ehis purpose, please notify lh\ Philip fchwindt of the Survuilkr.ee and .r.alysis division within 10 days of the receipt oi this lettrnr so that a msu (.ate ar.l I're-conrcivnor.1, if necessary, can be ~arran ;uu. !.r. C'cnwinr.f. ;..ay be conLccteU hy telepiiune at (nlA) 7*1 w` *71 IfG. A-2 000019089 CCR L ; / is-- -2- Please bo advised that, unless stated otherwise in the enclosed waiver, you are requires to report, on a sc;liuunual basis, all the irtl:ori:.ntion contained in Section 01.70, semiannual report. Your first report will bo duo on Septa: be r IS, 1977, Any deviation froei the conditions of this \/a1 vur, unless previously i approved by the birector of tho bnforcowant division, shall be nrounds fortho irsv.c-ciato tenaination of this waiver. In addition, a situation of iis.hnent en-janpersiont way warrant the insediaio intervention of the llnvironr.oiital Protection A-jsncy. Other requests yen i.:av have subi.rittc-d. such as equipwont and test method equivalencies, will he addressed under separate cover. Additionally, we intend to discuss end oval us to your lord: detection prc:era;:i uurinj an on site inspection, to be soiieau lea In the* near future. Should you have any questions concerni; r.j the substance of this waiver, you r.;oy contact hr. Cary A. b math of lay staff by letter to this office or by. telephone at (bKi) 749-7675. .Sincerely, ORIGINAL SIGNED BY Howard C>. Do reran Director, bnforcer.ant Division Enclosure cc: Louisiana Air Control Corsmssion F. 0, box 6CGS0 .`lew Orleans, Louisiana 701 GO bee: Surveillance &'Analysis Division (6ASA) Rich Bioncii, DSSE Susan Wyatt, USED r^s . -s/O A-3 CCR 000019089 jI jAoplicable Regulation 161.62(a) 1 SSI.65(b)(9)(ii) I61 '.65(b) (3) (i) 51165(b)(3)(iv) 561.65(b)(5) 6V.65(b)(6)(ii) > ,fc- 151.65(b)(7) |!cj.65(b)(l)(ii) Is).65(b)(2) Continental Oil Company Westlake, Louisiana EDC-VCM Plants Emission Point :i i : EDC-VCM Plants ; EDC-VCM Plants i ! EDC-VCM Plants i EDC-VCM Plants ; EDC-VCM Plants EDC-VCM Plants I EDC-VCM Plants EDC-VCM Plants EDC-VCM Plants Descriotion As described in Continental's submittal of March 23, 1977 CCR 0 0 0 0 1 9 0 9 0 Compliance Schedule Humber 1 1. Date by which equipment will be ordered 2, Date of commencement of on site construction Date of completion of on site construction \'t Date of final compliance and date on which this waiver terminates i Hay 1, 1977 January 1, 1973 October 1, 1973 October 21, 1978 1--; r Applicable Regulation 161.62(b) I -2- Emission Point EDC Plant "nation description ---------- - a .--------------- I?~zm-~ <1 :! - *-1 i-- for oxychlori- reaction vent emissions. Compliance Schedule Number 2: 1. Date by which equipment will be ordered 2. Oate of commencement of on site construction 3. Date cf completion of on site construction 4. Date or final compliance and date on which this waiver terminates .April 1, 1977 July 1/1977 February 1, 1973 Octcbe/21, 1973 AddIicable Regulation 61.65(b)(9) Cl)..- \ -3- Emission Point EDC-VCM Plants Dsscriotion Uastcwater stream leaving existing j)_rncess waste watcr( 11 ---* ^ s "i rr r ''"TITT Compliance Schedule Number 3: 1. Date by which equipment will be ordered 2. Date of commencement of on site construction 3. Date of completion of on site construction 4. Date of final compliance and date on which this waiver terminates October 1, 1977 April 1, 1973 August 1 , 1973 October 21, 1S73 CCR 0 0 0 0 1 9 0 9 2 Aoolicable Requlation hl.65(b)(l)(ii) 61.65(b)(3)(iii) 61.65(b)(7) -4- Emission Point EDC-VCM Plants Des cription_____________ Deck vent stack, VS-6C0, containing vent gas emiss ions as identified! in Continental *s submittal of March 23, 1977 T Compliance Schedule Number 4: -o 1. Date by v/hich equipment will be ordered 2. Dote of commencement of on site construction 3. Dote of completion of on site construction 4. Date of final compliance and date on which this waiver terminates on 50 o o o Q >Q O 'O OJ April 1, 1 June 1, 19 August 1, October 21, 1973 vf> CO --J -5- Applicable Regulation- 51.65(b)(4)-1 j i - i ________ Emission Point-______ EDC-VCM Plant Description 45 relief valves on equipment in VC service, as identified in Continents' letter dated March 23, 1977. Compliance Schedule Number 5: > i 00 1. Date by which equipment will be ordered 2'. Date of commencement of on site construction 3. Date of completion of on site construction 4. Date of final compliance and date on which this v/aiver terminates April 1, 1977 Aunusjt 1, .1977 February V, 1573 February 1, 1973 CCR 0 0 0 0 1 9 0 9 4 I r f I APPENDIX B i SEMIANNUAL REPORTS - VCM PLANT'S COMPLIANCE PLAN 1 CC* OQ0l 9095 VCM Plant CERTIFIED MAIL #315633 RETURN RECEIPT REQUESTED \'JI IUUW / Conoco Chemicals Continental Oil Company P.0 Bo* 605 Westlake. Louisiana 70669 (318) 491 -5211 March 13, 1979 Diana Dutton Director, Enforcement Division Environmental Protection Agency, Region VI First International Building 1201 Elm Street Dallas, TX 75270 Dear Ms. Dutton: The following is the March 15, 1979 semiannual report of non-compliance information as required by Section 61.70 of the Vinyl Chloride Emission Standard for the CONOCO VCM Plant at Westlake, Louisiana. As was reported in our previous semiannual reports, all vent sources at the CONOCO VCM Planthad been included in a Waiver of Compliance granted on July 5, 1977. With this waiver, no initial compliance tests had been conducted nor continuous emission monitoring begun until October 19, 1973. Therefore, we have no information to report as required by Section 61.70 prior to that October date. Initial compliance tests were conducted and successfully completed on the vent streams from the oxychlorination reactor and steam stripper on October 19, 1978. The initial compliance test on the effluent from the spent caustic collection drum, S-10S, was successfully completed on November 3, 1978. The results and details from these tests were included in the emission test report sent to your office on November 15, 1978. ` The initial compliance test on the vent stream from the plant's new Thermal Incineration System v/as successfully completed on January 12, 1979. The results and details from this test were included in the emission test report sent to your office on January 15, 1979. In addition, initial compliance tests were successfully completed for the Carbon Adsorption System at the company's VCM ship and barge loading dock. An emission test was conducted during the loading of two barges on January 20-21, 1979. An emission test was also conducted during the loading of a ship on February 21-22, 1979. Results and details from these tests were submitted to .your office in emission test reports dated February 8, 1979 and February 23, 1979, respec tively. The following is a record of vinyl standard emission non-compliance at the Westlake plant as required by Section 61.70 of the standard. The report covers each area in the plant from the time of initial testing through March 15, 1979. For clarity purposes, each area has been listed separately. B-2 CCR 000019096 ^P / Diana Dutton Page 2 March 13, 1979 1) Oxychlorination Reactors (Initial compliance test completed October 19, 1978) The vinyl chloride emissions from the oxychlorination reactors ex ceeded the limit of 0.2 grams/kilogram of EDC produced, as prescribed in paragraph 61.62(b) of the vinyl standard, during the hours listed below: Date Hour Vinyl Emissions (G/KG EDC) November 7, 1976 1700 0.2165 (Hourly average for the entire day was 0.0883 G/KG EDC) November 8, 1978 0100 0300 0400 0500 0600 0700 0.2174 0.3673 0.3297 0.2942 0.2481 0.2123 (Hourly average for the entire day was 0,1196 G/KG EDC) December 13, 1978 0500 0.2055 (Hourly average for the entire day was 0.0761 G/KG EDC) January 2, 1979 2200 2300 0.2140 0.4311 (Hourly average for the entire day was 0.0943 G/KG EDC) January 3, 1979 0100 0200 0300 0600 0700 0800 0900 2100 0.3264 0.2918 0.2589 0.6044 0.2305 0.2227 0.2417 0.2069 (Hourly average for the entire day was 0.1799 G/KG EDC) January 5, 1979 1500 1700 1800 0.3037 0.2186 0.2066 (Hourly average for the entire day was 0.1291 G/KG EDC) B-3 CCR 000019097 Diana Dutton Page 3 March 13, 1979 January 6, 1979 0100 .0500 (Hourly average for the en ire day was 0.0749 G/KG EDC) January 9, 1979 0100 0200 0300 0400 (Hourly average for the en ire day was 0.1521 G/KG EDC) February 1, 1979 1500 (Hourly average for the en ire day was 0.0598 G/KG EDC) February 23, 1979 1500 1600 1900 2000 2100 2200 2300 (Hourly average for the entire day was 0.3230 G/KG EDC) February 24, 1979 0000 0100 0200 0300 0400 0500 0600 0700 1400 1500 1600 1700 1900 2000 2100 2200 2300 (Hourly average for the entire day was 0.3057 G/KG EDC) B-4 0.2127 0.2087 0.2731 0.2643 0.2012 0.2628 0.3342 0.8678 0.3423 0.2974 0.2301 0.3119 0.3400 0.3170 0.2462 0.2486 0.2490 0.2369 0.2420 0.2307 0.2492 0.2067 0.4126 0.5442 0.4591 0.6664 0.2543 0.5832 0.4974 0.7237 0.5795 CCR 000019093 1 1 b Diana Dutton 1 Page 4 i March 13, 1979 r February 25, 1979 I l 0000 .0100 0200 0300 0400 0600 0700 0800 i (Hourly average for the entire day was 0.1660 G/KG EDC) February 26, 1979 1 I a w * . 0500 0600 0700 0800 1000 1100 1300 1400 1500 1600 2000 2100 2200 2300 (Hourly average for the entire day v/as 0.2328 G/KG EDC) February 27, 1979 0000 0100 0200 0300 0700 0800 1100 1500 1600 i (Hourly average for the entire day was 0.1768 G/KG EDC) i February 28, 1979 0600 (Hourly average for the entire day v/as 0.1244 G/KG EDC) 9 March 1, 1979 1000 1500 1600 1800 L (Hourly average for the entire day was 0.1156 G/KG EDC) 0.5620 0.3484 0.3660 0.3705 0.2767 0.5980 0.5979 0.5420 0.3175 0.3169 0.2623 0.6071 0.2559 0.2161 0.3306 0.3190 0.2914 0.4126 0.3646 0.4166 0.2912 0.4489 0.5310 0.3692 0.3712 0.2031 0.3429 0.2901 0.2131 0.3389 0..2452 0.2127 CCR 000019099 0.2397 0.2737 0.2298 0.2063 * D.iana Dutton Page 5 March 13, 1979 2) Steam Stripper (Initial compliance test completed October 19, 1978) The vinyl chloride concentration in process wastewater discharged to the atmosphere exceeded the limit of 10 ppm, as prescribed in paragraph 61.65 (9) of the Vinyl Standard, during the hours listed below: Date Hour Concentration January 15, 1979 2100 14.2 ppm January 16, 1979 0100 12.6 ppm 3) S-108 Slops Caustic (Initial compliance test completed November 3, 1978) No violations occurred during this period. 4) Thermal Incinerator (Initial compliance test completed January 12, 1979) All major vent streams at the Westlake plant, with the exception of the oxychlorination vent, are piped to the new thermal incineration unit to reduce the vinyl chloride content to less than 10 ppm. The incinerator is fed by two main headers, the wet vent header and the direct chlorina tion vent header. Exhaust gases from the EDC purification section and the vinyl chloride formation and purification sections are discharged to both the wet and direct chlorination vent headers. Vent gases from the tank farm are piped into the wet vent header, and the exhaust gases from the ship and railcar loading vent recovery system are discharged to the direct chlorination vent header. No violations occurred at the incinerator stack during this period; however, the thermal incinerator was down or various feed gases were by-passing the control unit during the time listed below: January 13, 1979 - The direct chlorination vent by-passed the incinerator from 0655 to 0700 and from 1355 to 1505 January 14, 1979 - The direct chlorination vent by-passed the incinerator from 1130 to 1300 and from 1455 to 1555. B-6 CCR 000019100 Diana Dutton Page 6 March 13, 1979 January 15, 1979 The direct chlorination vent by-passed the incinerator from 0530 to 0605, from 0640 to 0650, from 1215 to 1220 and from 1455 to 2030. January 16, 1979 The direct chlorination vent by-passed the incinerator from 0500 to 0600 " and for a number of very brief periods between 0700 to 2345. January 17, 1979 The direct chlorination vent by-passed the incinerator from 0635 to 0730 and from 0920 to 1315. The wet vent by-passed the incinerator from 1230 to 1330. January 19, 1979 The wet vent by-passed the incinerator from 1330 to 1400. January 20, 1979 The direct chlorination vent by-passed the incinerator from 0032 to 0104. January 24, 1979 The direct chlorination vent by-passed the incinerator from 0140 to 0142. Incinerator shutdown due to low combustion air from 1140 to 1215. January 26, 1979 The direct chlorination and wet vents by-passed the incinerator from 0725 to 0845. January 30, 1979 The direct chlorination vent by-passed the incinerator from 1215 to 1220. February 1, 1979 The direct chlorination vent by-passed the incinerator from 1633 to 1647. The wet vent by-passed the incinerator from 1645 to 1755. February 2, 1979 The incinerator was shut down due to flame failure from 0615 to 0830 and from 2245 to 2310. The direct chlorination and wet vent by-passed the incinerator from 1432 to 1522. B-7 ooooi^01 CCfc Diana Dutton Page 7 March 13, 1979 February 4, 1979 The wet vent header by-passed the incinerator from 0704 to 0715. February 12, 1979 The incinerator was shut down at 0300 for a scheduled natural gas outage, as outlined in our letter to your office dated February 1, 1979. .. The unit was totally on stream again by 1800 on February 13, 1979. The outage occurred during the February plant turnaround period. During this 18-day period the entire VCM and EDC processing unit was shut down and cleared of all VCM and EDC thereby assuring no VCM emissions to the atmosphere from the processing area. All tank car and ship loading operations were secured during the period of incinerator downtime to assure no venting of VCM to the atmosphere as a result of loading operations. Storage tanks in EDC service were either empty or stagnant, and thus due to the cool February weather, no tank breathing occurred during the incinerator outage. Finally, the light ends tank was temporarily emptied into tank cars to prevent any VCM emissions. February 22, 1979 The direct chlorination vent by-passed the incinerator from 0520 to 0538. March 2, 1979 The wet vent by-passed the incinerator from 0800 to 1040. March 6, 1979 The tank farm vent system was shut down from 0445 to 1230. March 9, 1979 The direct chlorination and wet vent headers by-passed the incinerator from 0903 to 0920. 5) Carbon Adsorption System at the VCM Loading Dock (Initial compliance tests completed January 20-21, 1979 and February 21^22, 1979) No violations occurred during this period. Please let us know if you have any questions concerning this report or require any additional information. Sincerely, CCR OOOOl9102 J. A. DeBernardi Plant Manager CC: J. F. Coerver, LACC B-8 V-.Vi Plant Conoco Chnmiculs Contin<:iu il Oii Company P.O. Hox C05 Westlaku. Louisiana 70669 1318) 491-521) January 11, 1979 Mr. James F. Coerver Technical Secretary Louisiana Air Control Commission P. 0. Box 60630 New Orleans, LA 70160 jDear Mr. Coerver: vEPhis is the semiannual report on the VCM Plant's Compliance Plan for the ^period July 1, 1978 to December 31, 1978. Item I - R-305 Catalytic Reactor on Qxychlorination Vent R-305 continues to effectively reduce ethylene, VCM, and chlorine concen trations in the oxychlorination vent and has been on stream continuously since September 25, 1978. From April 21, 1978 to May 10, 1978 the VCM Plant was down for a scheduled plant turnaround. Although the remainder of the plant was started up on May 10, R-305 start up was delayed to allow steam tracing and nozzle repairs as well as catalyst recharge. A strike ;by Teamsters' Local #969 against the Associated General Contractors, lasting from May 1 until June 19, delayed the R-305 repair work. Another labor dispute between Millwright Local #1476 and the Associated General Contractors from June 26 until June 29 further delayed repair work. During these labor disputes it was impossible for contractors to complete the scaffolding an'd insulation removal work necessary to allow nozzle and steam tracing repairs. With the resolution of the disputes, repair work was finally completed in midSeptember. The reactor was recharged and then placed back on stream on September 25, 1978. Item II - Dock Vent Return Pipeline and Vapor Recovery System All ship, barge, and railcar vents were processed through this system with the exception of those loaded during the first week of November when the vent recovery compressor, Bl-410, was down for repairs. Both the return pipe line and the vapor recovery system continue to operate satisfactorily. Item III - VCM Incinerator Vent CCR 000019103 Construction has been completed on the thermal incineration system. In addition to the incineration unit, construction is also complete on the associated vent collecting systems and the neutralization system for the HC1 produced by the vent combustion. Incinerator warm-up was begun on December 14, B-9 James F. Coerver Page 2 January 11, 1979 1978 and the plant continued in the process of starting up and checking out the complete systems throughout the end of December. Please contact the plant should further information on this semiannual report be required. J. A. DeBernardi Plant Manager is CC: Director of EPA Enforcement Division EPA, Region VI Permits Branch (6AEP) 1201 Elm Street Dallas, TX 75270 B-10 CCR 000019104 I ;i m:vi:moi!i:.vr iu::r.Vi n:i: Ovvl.-nd 11/7-'.) 1*0 jh` ^ f 0 . ri:v::cr;::"i, A cr.irnnrArm:i nuiper of t Uc facility, on location at the plant site, in on fol low?:: * F j/tf-rs a. riof.po i I'l /\:!! :: COiiiiii -V 7j::;'a;;y .'<r .1 )*ct:L address/ J`. 0, I -..o, parish, Zip code: l\ 0. MIX b!f. \w\ t* 14> V* code/ to 1 ophone ho. : 'jiK/f'Ui-ux.i *i to contact of the altc of the facility ah out air pollution control, if nt from the above: X' r. telephone )!o./ extension: . Gary i.. rnsnrr Cllii I- 3 ib/'djl -iiv'o2 i;.`i'f;fi t.La company1 r, air pollution control correspondence and document,'; arc prepared r.rhju .-.risers office, at a different site, fiive the inforr.atfon on the person to ; ted &edow: . '' ... H. J. Neeld -----------DirrrcTTiirorTirrn^'n'iTarT^iTTfoi: j^g-'pzr.'.y; or parent company: J^Rreet address/ 1*. 0. Do::; .tate. Sip cod*: a area code; telephone No. : p. o. im _______ _W(iSTI./'.i'i:. !A_7fHGR non vho prepared this report: (if prepared by a consultant) (If prepared in**house) nndress/ P. 0. J3o:;: state, oip cede: oj , tele phene v, extension: (7(j one o'l "the. above, juu-t check appAcpiMite btcch:) .O A. G. DC. KCK'llfTli G. ilr.lffO * ______ pkou.'.ss coai );:h;:Yai:i;Ti. "ct-MPAiiY U'"i"0X Viio L/i / TlTiTiYi-aO/ir '..TiuIPiwJ.C.uAT.wIO.sh'.. jj c.cvfU-cs-if{i\ifj, aunncd!ecsac txh:iiec ptovmitious in lI.cotttu.ityilannna and UUnndiatetedd SSttaaAtci p'iovi-lc cJLuninal pe.iuu',ii.c-i {,o:i ^cClc l-iaicntniA, .that Hi it to:,iti>iioonn, Q:icj<?ic>r.:;aC'ir., inctiuli:,;# a AC attachr.e.ntA thdcio, contain-i in^o^rraattciovn U -tA'ic. and co'oicc.t to the bcii oft /a^1::;aisf.cdf>_e^,,y.::<u1 beCti.iCeJn.. _ // y/T> rtdi...................................................................................... C^re ut i<:aiu:j*,ar, or other company n;;cnt) ____ fojY-S h.' Ot-Mrrn uvlY, ' 'ninFj'dn-ir<~r..... ......... (printed or i:y`,vd A title o! person above) /Z/2./7? ________ (dale Sip,lied) / r B-ll CCR 000019105 VCM Plant (conoco) Conoco Chemicals Continental Oil Company P 0. Box 605 Westlake. Louisiana 70669 (318)491-5211 December 1, 1977 Mr, Howard G. Bergman Director, Enforcement Division Environmental Protection Agency, Region VI First International Building 1201 Elm Street Dallas, TX 75270 Dear Mr. Bergman: Increments of progress are hereby submitted on the completion schedule for two of the emission points at the CONOCO VCM Plant, Westlake, Louisiana. The increments of progress for the subject sources are as outlined in CONOCO's letter of December 21, 1976. Compliance Schedule Number 2--0xy Vent Heater, H-312, for Oxychlorination Reaction Vent Emissions. On site construction of the Oxy-Vent Heater revisions has been completed. Scheduled completion date for this increment of progress was February 1, 1978. Compliance Schedule Number 5 - Rupture Discs for Relief Valves in VCM Service. Installation of rupture discs under-relief valves in vinyl service has been completed. The scheduled completion date for this increment of progress was February 1, 1978. Future reports will be issued as per the compliance schedule requirements. Sincerely, J. A. DeBernardi Plant Manager is CC: James F. Coerver - LACC OCR 000019106 APPENDIX C NUMBER OF DAYS LOST DUE TO INCLEMENT WEATHER oooW'10'1 ccfc /. / 'r.' r i :, ______ I ' i' > < ) / A --t v /i t.---->jt i !''////> ? "A' /? 7 /.A ? u/w <y /"> v /v ' /l `t I -t. /A *7 //'<*/"> 2 / t' t% As ///> A 4 // {/>. A /.A *> hi J /p-.,,. t/' / ./ 30 0 t/i-rh/t j/io /v 3 r/s'/?8 t(?% 7. /y A '/i *t I ;1I // :i i j 1A/7^ i c,.//?//7 X/ v< ( f / o w / i/ h?r *y //<;./?? A :: . ;i t, ` ; ti * 1 ; `* : .1! 7 / t ^ l-i 8 -4-,/ ( //Utn ri-||' ,/ - . ' !| i /it hs * a '4. fc./' 7 A/A? y . vt 7'.'.,;. .. * /*$/> fj/`Z ?\'Av rA/A? /4 0 -?////? p* 7/V/A //.A/7** / ft/f. *s-', A //Ay/A? /y. A//?,7 !(y hr C-2 // (l-.-..: i ii !I i * | ii CCCCRR 000019108 PEDCo ENVIRONMENTAL, INC. MEMORANDUM TO! Project File SUBJECT: Communication With U.S. Weather Bureau, Lake Charles, Louisiana FILE: PN 3470-1-H DATE: March 13, 1979 FROM: Herb Belknap cc: A call was made to verify the amount of rainfall recorded by the U.S. Weather Bureau at the Lake Charles airport on the days listed by Conoco as rainout days. Days listed by Conoco as lost due to rainy weather 10/11/77 11/21/77 11/25/77 11/29/77 11/30/77 12/28/77(h day) 12/29/77 1/16/78(5* day) 1/18/78 1/19/78 1/20/78 1/23/78 1/24/78 1/25/78 1/30/78 1/31/78 2/1/78 2/7/78(5* day) Official rainfall ( 1.46 1.10 0.03 3.14 0.09 0.64 0.70 0.90 0.23 0.45 Trace 0.40 2.10 0.35 0.17 0.35 0.44 0.32 C-3 CCR 000019109 (continued) Days listed by Conoco as lost due to rainy weather 2/9/78 2/17/78(^4 day) 3/5/78 4/11/78 4/12/78 7/24/78(^5 day) 7/27/78(4 day) 7/31/78(4 day) 8/15/78(14 day) 8/28/78 9/8/78 9/11/78 9/15/78(4 day) 11/6/78 . 11/27/78 12/4/78 12/8/78 Official rainfall ( 0.26 0.36 None 0.08 0.37 Trace 1.92 0.02 0.15 5.88 0.13 0.02a 0.01 0.77 0.57 0.05 0.51 a Rainfall for 9/9/78 (Saturday) and 9/10/78 (Sunday) was 2.2 in. and 1.5 in. respectively. C-4 CCR 000019110 i I F | APPENDIX D CORRESPONDENCE WITH VINCENT I CONSTRUCTION COMPANY b* OCR 0000191H L L Tf:! C| 'Iv.'iU? 882-l;>76 ' rt !As Ce( ii6{'tuc{toil l\ o. Iin.< 26/ Sulphur, I:ikj 70662, January 6, .1077 vV'U Cm ' Conocn Cli'Miii ca 1 r; 1?.0. I5o:: 7 2 7 Wenl..l al.c , I-ouir.iana Attention: Fit. D. I:. Kidd Re: Conoco - veil Incinerator Con L met Ho. VCM-102 Our Job Ho. 77020 Foundations Gent.'l cm on: 7^t your rogues t we hero by submit to you a credit for all conreto purchased l:y Conoco and delivered to the jobsite, oi y77.60 nor cubic yard of 3000 ps.i, mi;-:. '7 /. (;' Rased on your furnishing 300 cubic yards of concrete we will credit, you with $.l-l;-7-30- 00 . /7v,k A,0O ..//;/ Edward I. Lu.ni.or, P.F, Vice-Prosibent F.IL/sd D-3 CCR 000019113 t. v-auk on a rue; < i c/.i: ft,amt .........V..................i i ,'V""77y.......... T<7u on.i Vnr.CDJ CHANGE omum no. f.r.E* on cmr.cn r.')_____ _ bioo-in-.io;* COJ .'TRACT 170. VCM-IOO DATE ,'fn m a rv 10 , l'17f! |f0D T.T I'LL' f: LOGATIOIJ r''"';'V|' f' / _ ' * 1: '7 )A n v n-( rmd K1 iwOi; i o;D for vcn_Vf,~ol. J no-! n. EQUEIpTA'D CHARGE i: RBAO0)J _ jv''ioi-o ";riO cn'.oo y.'M'u;.; of ['(in-i-rQ'- rmn orldn.'il __ b.i 0 >n\i r:o. Or.no'-.o i r. bnyj r,rf 000 rn!i i < wm'i.o i ren 11 t< I! . Yi'ir: nni !; j:i nf i'l'G n< i'V:jv !-o l ]r:i: j .*; Iv* j nn do] ol''d ? r, , 30 j-fy puBm.: v;-rd. t V. ClLhVGK REOUKSTED MTi ,/ *7 * t/ y >} ___________________ p.EP'.'V K.icJd .Con|-r\ rlf)nj._pf. `fO CORABACTOR : V` ncc-"(: 0<`iv"" iyuo!i on Co, /HE ABOVE CHARGE KILT, BE: 0 3 2 700.00 *^ihf OBITER: CREDIT) 'itAi F REQITOTBD WORK JO /APPROVED, ADJUETI^KT OF TBJ^COir^rJiCT PRICE SHAW.. BE Tine nu vnnn i.tpc't* nrr.T.'rcn >.xwnnv //v.'Tjr.v'orr.M fj ; :onthactor*c signature: WCS//'. //. //// ,V7 ;''` dAumdjrtf r,Wucx / 'UJ PROVED : A; 7 sJ.L i;:\.' APPROVED ///./ 7 A- IP ROVED : V7''....... 1 * - ...................... // tl ,i\, l,i': ;ii'i j.t I\ X DATE: Mate*.. DATE : DATE t JiUMlL JAUV.J 00 7 .EJi, .'I n, c-r.j D-4 CCR 0019114 APPENDIX E DAILY LOG OF INCINERATOR PROJECT CCR 0000191X5 fa# '/? <> h\l 1 5/ *i l~? `<5' 3/i.> (?& .// />? W-3As V/2c.' /?ff w /*, & w /1 ? F W' As :. s^//?jr iA-*'-*- * * -- ^ fv^\ U <;J, .,! ,, V' U*_j3, A >T A V* (i K V- J " tA ?-A-... o-r U.Ac*.^____<' 5 -<7c>/ . c.,,./v( I^6/ '^ J* u- t J y A'-*' / * 0- ?.o/ C' "7--dvvvv''--'^--'^~r r7`-^-lty -Ai ,`J Q. . l^-> / F'm-J) 7 .//' / rry.*,-t--ki. / 5/ S w* / P--A S S^'f7 .^<A /- .,/ f-S/,* -A . //i..7.o--;---i ~ <1.*--/L--e-"---*'* < U /W A*' <*( Oftc/yx <//? As ^ /SAa / *> 5 fc/ T.f ji <* /soh# j* sh ht f/sh'* \ S I &hfiz . * i j!i jy//? - I -a* ?Ih 17 f (?*7. J J i, ; i ^cl ^2 ^ C*C //rt'-e~v 1' '^ Ac i .{ A-?*/73 1f> Ajt '/ / ^-t,^*'Wf- <--ip- _-.' ^-furK-A' . i-d^i UJuA-I^t v--*'- &-tJ^ . , SiCe-OO 'v* ^ P^Cy^u^rO ^ ( P"<-A / "*-V-'we> P'V( tOOnAr/ Aa V, .vrfWwt 2 /^?.Cj/ l^/* fiVwi/ 7) * .< /sr*.*A, ? 2 2 ) : ljW-'w.Olk'--(> "'"/^'^^,,,'VV' . ^C-(--~-(j fiL/'\/ it C-<> ?'-)/ e^/s&r t. ---- J-p*3Lr4f*y/^ f_ I. ;i & '} ^'/'7& filed--:--. S* A*. o/ Jj ) ^^-*^-J/l---^'.l' /,,yJ> .. , 0 -tt'/'P' . <=*) n-^C ^.0-^fT /* ,- r * '*j i*/v./?>r 7'fy^- f~> - |A rfa'infr 6-0 Hv'i d l*^ip{X ^<D liJ./.j^ZA .(/> i A-ii.-( .-- -^-v ^ J.s<'jC-7 o '<'.', - ^-C-- `v"u/' OOOOl^117 CCR E-3 APPENDIX F OVERTIME RESERVE FOR THE INCINERATOR PROJECT CCR 000019119 1T* (' "A Vi S' * /* * .; `* l> A NiwA.^'H U ' . ' V', *V .\f // ( 4 4.. l.Ht'UJIrf'' ) ( < I':. '. <Vi V( , c`. O r Interoffice Communication To Difj tr ibu t i on r rrooi j. j. Brooks v r Date llovombor 29, 1070 Subject Vont; Gns Incinerator Projects Coot Report:.; r The attached report reflects the status of the Vont Gas Incinerator Projects as of October 31, 1078. r ^ /'WcrS.' Ulo it 3m J. Brooks JJB/sn Dis tribution: J. A. DeBernardi K. G. McLeod J. II. Brunson R. D. Gamblin R. G. Gantz i tzer l /f. 33. Kidd' TPr-AT^Tie gene r |m* R. D. Beck C. T. Wyatt J. C. Counter i, R. E. Lehmkuhl B. D. Ratliff J. R. Holcomb L J. E. VanZant J. D. Stone P-2 CCR 000019120 APPENDIX G CORRESPONDENCE WITH CEMENT MANUFACTURERS CCR 000019122 I* 1 f i' <; --/) /'A.-, t I'.if' ,/ 7-# -*// < /' *A / }>U 7(0 / iJtLl. * - yir # *. C\r; c 'h /' C'cf.i/tinl I 'v r>`C> ('r /t t.'U >'iJ V C/c;i 5.. ^ */ ">',l `t 'f* 1-hiS'r', 1I tz/ss/'f'? - /V/X l-'^n c s 'S/. i: y " /Tv 'T *1 I} A^auJ ~}i'H ^ ; | '"i-Tki {/lie: Cc'WlliWf,'r i'Jhi, JJC cr.-i.-a-.-i-o ! r/o-r /-< oj -Tit. /0 F Mtr -"Vv ih/(\ . ft I T- 1 i11 !I *** * Z >^s . tQ O^TCH T^(,*uv ,> t1 " i IT1 :i? t: . --- - 1i t - .. !i Ji"J'i .... ... 1 i* ...j .... i! I.* . .. i Swj ... .... i i i . !i - 1 It r1 i . b/t*T* <- ; .i /lA .... | -j C!rs.-.i c-oj\ !i ..... ... ... i i 1 - | C< c?v> i.J... L-!.. ....!i I'' ' ! -1 r 1' " I -I1 1 .1- 1 i ! ' i-ieuutt . Ni'o^ V-.1 *4 it La 1 : i I!--i !- l " j -!- ** "" 2x0^5 OCL-< . CA,1 , ^ww|l i . :i.. ! t i i, ! rr iii Vh ' * ......' . J.tA<.t..vnc * , ij . i..! ;1 !i 1 1i i ;! CJ uaux*! i M. 'i ' ' \ C.owit aoc, 1I. ! iOantn 1 I" fi-iTtinc. i 0<^- v/HJ :* i* (CoOr ? : i i ; TO1 Afc'fu. Oc.c.i.oUC'W - ! iI iI ii r I l I i.. I M i *li, V!; * * <, i . !iG-- 2 ` tr ;i /. i i. ; ;. ; T CCR 000019123 dftu {.\r- -rc_ VS 9a/ r C~ ``a*: r - 9oil. S> - Pc* "C r $ 9C't( T- *? 5":* i 5 - V/7- r fY.. *Wu. (' . - V/IL ^ rr <y * v/z. P ,.4 { P- <vo'./ A {'& T5'- ?D p- ^0^/3 yfe/VT &/ Snr',r/d C-Vst 'Q<*-oe>/ ZC'VC'I. C7- "?/0 j i P"S ti *? 2,<s6? -L2-5" P5 3oPS -30-7 p; n'c. TP 30*1 PS -*si~ z.'5r L PP l'tu> /C5 r'- /A <l*,>,f j '* Atmf St f V. * * ` 6 /.v5J c:. i 3 u** y -'v i-/ a-. .* *;* d-. C>.^. o.z. i-f iC dJLr\*J r- <vt /Ao < c-L/ r//.'c: 75 v ii-f- V" . 5' y 3y '3 `> o.S. i : .I. i i ii 3 > 6.r^ ': i i( ...... .. cp 6" ^ tr 0.*b. . . . : . ! i i-- i ; i: , ` I; 1 i !i i i! 1 i i ! ........ i i : i ; -! ...: ' j - ! ! - j *UrC. .! ---y :i i, l !i; i 12 C, ffy l . : . :. - ! i .......... i j. i. .! ty Z-'ly. :'V /, S' y 3> '> (c7 i ..!. :. ..i . j ?* ryfl77$ ; . .. 1; ij. . i*. }^ * 1! f ! ' 1 | :: . < ! : ! :! ! ! !j : j ' T "\ i' ' ! :> - :1 ;; : ! ;*i : I I- !I iy `1 > "9 > / 14 . ' ; G-3. . ../ CCR 000019124 * r r r ^/'i`.-<.1./r->17 "TiiM/i zj/-( - /-//? >4. Cl, To ,-v/ "Tc'i.C" r~vi <2 i-lrit/L, V>!f.: U u) ~h'i>cr cj~ /4,lyr.frAt. , !/[;- (V^ U-r,|,/ai; (f" ` 0,T/. \J7 j OU"r vWv-Tic/S, o - rc\'(i r <iocS~ t': /A? /Awr> .T rtf t ^ //or t-/-/*- T'.'/C r-Vj/? cV^y r ; j //A?. 0i'u/7u\^ th/vf4ttTr jj CfjuiHT /VU ,'/V'V:c.'.vr;7 ifrf-VL' Ct/Otiy '0y.it. l'$ - J'jT X?mol7b <>) 7Jc> >"vV 7/> 4/f.K`tL V'-hifcp. //or s!c*(C<jc;q^ 'upp). t '/3-- </3 y/ ^/y,r .*<<'u*. &rifrtli /t'ftfTeCi&L'}? ' dtf&TiS Surf,/ J lg,At< iVVtiKT, I I / / 0C4<<> <-' j TV : ?/3" i) Lp^a_ uims . .i i 2-) f/l^Y ^ri "to /-A*//1 ^A-5 , ^tt-'TSkAcji s ?>) '^0 7> CVv.-x'juisj 7>c.iVf //or -7> /4f<r7I Tu r}. {? L I I i J.. ! ii !!I !! It .. I iI. iI ii ! :. I. I. G-4 CCR 000019125 . '* l <' 1** rI,./, iW /.r - ( j A,As..` \ " 7-7/ Vt / i' S' / / / /' ,, \ . f>. *. I t'' -"M * * <<:'. V 77j--(; /.A / f-' 1 -- f V O^*- **' '^': /7-' , '"' 1 )/"] /2|M. K'{'V.<*i *''*l t''> r; --K<<'/ i" 'A'*-'- -/ f^O o''/ A--1--V ,. "0 i/ /K-S,? / c6/ L-o *f v'( ^ P^'11" fi. >*' ..*!' -j (/ 1 AA'c~Jy/1',^^' >A/wwvy/ O-o--^- <7 ^f-^ <^r- ^ ....;.:. ..# v' ' ' . */ A\ S; f (' ^ V.'. ' O' A-i if * , <-/ /r>.' l4> / ."V- --v - 7V7 r t -> - . yJ :?.< '<-; />j- --. /y'* *. -:. <pC?tf ir*Y "7 #4* "'23 -iT/ er 00001^126 CCR ta G-5 . /"K,// , * 0rtl , -> J . </? $c'i- V t o-It <.?*, ,"i>' ('>t*-c'-' ^ . O* ,/? jiA. -C c ) t <. a ' ~W- ?jw ) srS ,' ^rV/ +-- """ ' i* cca 0000191Z7 G-6 V r A-ituu. { F;> r r i?t-.-lV:. OT U.it'C. >b i 1& Yfs /*W4 C` > <>-r4 :/*//? i. - t i I*' ^a.<c.v~ >/.- i-.J/ "* StfJVoCii. *tj Z*Z. <?is.*r W'Ay: /*^ Oa<4*{(i 0, Tk- . !'i,.: .i ? i! CA-aT ^//".V t>u' POOT//-<S i i /Jo (*,4-l.u .! Acu \ ' 2!) *f) *Su PRt fctc'V) &. Ql --> lS>g\4l/ vAoM. r <./ >, AI D vOt'vT ri^3- Hi,a.e. . i! i ( ' i /O^-iiV-^'-^OS ? Cowco AeeS/tt- / fewf-MF ti ! '1 I . t ! :. .'. I ! iiI !1 i j > I, OCR 000019128 APPENDIX H PROPOSAL FOR AN ON SITE CONCRETE BATCH PLANT CCR 000019129 4 r r r r ! Ft \ I ' l l*s / iJ * r t *, \ z (if *. * IK li, KA XiHteCiV'J '3. - " l?:;c;/zc(. -tail T;i;n Klioj.-o o coco Vj Jicrv.yi C; Co. rp*'' ,/.:: v.*. i.'O i ' v>\' c'.o.Yi i.julri.i c. '...2 iio-i V ^ | \i ;li|, ^ kj /..i.'if'iiii . > .tkiUU.k J v-.'jiAi**'# "* iVc.riaX r.\ ;'iiH Fioltl S'-i-jin-iffi* C*>iir.iV.l iter.vrtr&nt ncsysw CO v;/i:jri'.'Jc:iui-e ooD, oiiiJ, Ci:-:, CiW |w. CCR 000019130 C H-2 Of d'vxii/A Cni'-s((.((''((oil, <(fnc. r GO2d 5/6 Conoco Chomi cals I'.O. I.'oy. 7.77 V.T:stla);c, l.ouisinna P. a. Hex 26/ Si dpi ht, I 'juii iono 70663 January '1, .19/7 , /fV feed 9 Jw L 7vttc.nl. ion *. 0. ]:. Kidd Uo: Conoco VCM Incinerator V?as I Into, J.ouis.iann Contract fvc:;-:i 02 Our do).) !! 7 7 - 0ii Foundation:; .. * Con tlcJiir:JJ: t V?o propose to furnish concrete for components per your spoeif.ica tions biiyiiirf ready-mixed concrete from 'a $22.OU/eubic yard. the subject, job, by mixing on t!ie jobsite instead c.f local vendor, for an additional The un.it cost is based on a job requirement of approximately 1300 to 1900 cubic: yards. Thin unit, also include:s all equipment and materials required to mix, transport and deposit the concrete. Inspection and mix control by an independent laboratory .is .included, A fixed cost of 030,000.00 is to be paid by the increased unit cost. If Conoco va.-u.ld not want, to pour all concrete at this price and ready-mix would become available, wo wonId charge Conoco 0is,000.00 plus $32.00/cubic yard of concrete poured, less. $20.00/cubi.c yard for each yard poured which would be credited against the $30,000.00 fixed cost. Therefore if 3500 cubic yards arc poured, the only added cost would bo $22.00/cubic yard. Example: 1. Initial Cost Concrete poured Lost, credit for 500 500 ey. cy. 022..00 02.0.00 $30,000.00 31,000.00 (30{000.00) $3.1 ,(100.00 l_ 4 E Average Cost ~ 31,000 -$G2.00/cy. 500' 'ey. 2. Ini! ini Cost; Concre1e 1 mured 1500 oy.02 2.00 boss credit lor .3 500 cy.<'2.0.00 $30,000.00 33,000.00 (30,000.00) '$33 /(jiloTuo Average Co'-t 33,00!) $7 2.00/i.y 3.500 ey. H-3 CCR 000019131 Tclc| 882-1 S/rt r r i Sulphur, l.cmirioiiu 70'6i The jTfjiii I::; for Uie job bnleh.inq ope [alien which v.'ou.lri J uni i ohetl )jy (:euooo ere: (.1) Vw.ili'i (?) .Kb el r i ca.l pw,nupply. (S) Opera Li mj )>er;:i.i l.f: hr on or 5'ccV- ra.l. aejoneief... P.leer.e eon LarI. u:; ;i f I'.herc arc any c ju":r.t i; )!iii conoorninq Lhin pr< ;n>r.u 1.. J.i nccro .1 y , JMw.irrt T.. Lanier, P.E. Vice-Prur.i deni. HlL/.sd L CCR 000019132 APPENDIX I HISTORY OF LABOR TURMOIL IN LAKE CHARLES AREA OCR 000019133 ! Ccmtrantal 02 Co. said !>' `day. Jar.. 2i. that 'evlii-arati sartta^" was br; io: :irvlre -,j o:r.;r area lr.-i !b t^lke"":: rlbr; ~ 0! ~ChVmi :11! ice Li ctrtala tha us_;si vsas rat H I b2 ts-acd 2: la' 1 b.tu. ts-das. Continental :-zii the' w :....::_r.y "has Inbstttru :h= ca tion ctfbirs that :h? ncttatialbn tr.tet.r.p pr-a-v.stasiy sukt-aubd bests sar.ssl:--. Che CCe.'.Y -.'.aa can :: .ur.iees the il- ,lzzzl amkrtmt: sat. vines. in-absir.: ts.e- 0:3.rue::da c: the .rtas.ts" c: cstr.nr.ny r.srscnr.qi ; 7:-; s:r.k-j 2:2-25: Can- 'nn.atali V. j-: Lake tvikttrv; ;:n: ;svmis_i plant brtem-a its try mar. apparent cub: on bn: p .V.:-: :v:.-z nr.i 2 ttm- O . [p;-:ry or:;: against *2 .Uns. slass m the ebauts an- /* t --: .; .?.i, 1 ; I* tfeXOOOO ! Cant-attunl's Lake Charles' :;t trimeter. Zi Lively, 522! {thems Lick,.-.: valve; cgtr. :r. it r.-.'s-Jz a. a. km: mere cut 222" viL'.rr ulast-d. catusin;; ares-; , ^ rare to amid up ii :k: Lx. j 1 V.'ker. prossura birrl: too hick,.! [Lively said, sutoty valves it tea: pism; activated and the :2s 52-' kamaticatiy ium-ad through : I: vas fir:: thi-i'hi me. e:-t- 'tlJilss had orcu-red and ahiat c'jO ptmstns v.-gra uvuauatai; brant area. The flarait? ca-| burred 2: 2:1} a.m. nr.d ccrr.-l 'pany otilubb said tha piscine! was bid-: 'a operattan smartly] but'ore 3 z.tz. " j Ton: Pev.o':!, abettor oi s;:e-| 2:2'. r.-c>::s for Cantina".'..:!.] said lie interruption in Service! a:L::'.c: Virement:. OIL-'., PPG, Gu.1 States Utilities and Ccr.: mental. Meanwhile. 3-lth Judicial Listricl Judea Ear Veror. sr.iJ he h2i ::-::c'.;u.-J a:v.il fat. ft a or inierfariny vv::a carry of emit' rrcat i;:a ri::s by Continaaial, ernalayar. j Cen::n:-:;ia! rr.playes vara; ordered la c.ive siovry thraujli; the Zy.it. V.'iula Veren's adian '.laainy* evrr.ir.p cnacclad cut a ached-- alia a.m. tour: hc-ariup tuaay: cn the sen; subject, it did net c::ec: another heorinp sehad- uli-ii lor n.nj. Thursday, Jon.j 31 That h:r.r:r:g canters around! a Confr.cniii .r.cfen filed Pri- dav nahiny Veren to hale the: CCA'.V in caruamnt oi aaurt lor* a'la-a-adly via'.rnnp Veres's] critical rastminias order. j t Shortly after 7 n.m. loaay,' Jan. 2S. ca!v 2 lew r.irkets were. on duty 3l Cc.-uiacntai's ra-i beery and e'crr.'-af 'hint ir.) U\s: I.aI.e. They ineiud.J sev eral vcm.ra, raarmr.^ ihe! Varan sr.'.J V.e sicnid iU or der ii:--T an in.usur.l even:.23 :as?:cn Monday ::i his ixnrc ir. .aLuuh ha n:a: v.L:h n::c:-nv>i tor Cun:;:::::::! u::J fra CC.'.\V. 'Varcn .-.'.La Loth slias uyre-.i ;o j:ha t.\:-a::.-.;a. ! Ti'.-a temporary erder war i:ruacl Jan. i7 by Vcrar far a 1Cday pc.-neJ. It prcaiabaa GC.-.Ur rr.arubirr from aicaVur.p era en trance to lire Co.v.iaan'.al plants sccad sfrairi.: day -ant wives ct strikiny emnbtyos have been cn the plakci hues. j . A sitr-haur stalemate ai tha! chemical a!.V't er.-ird shnr.ty' 'before 2 p.'-A- Mettcay v.T.an: -.four cars" carrying contract I reardr bit cites acuta perked. iir.ee about 2;Cd ami. P.uk-atsl lead hteckcc tha ears attar 2; ;iif:h guard v.hble akryediy .streak two pickets whlb at-; tempting :j enter tha pbr.L j The Calcasieu Parish Sharlifs Ciyartatea: said an :n:-m<v* irvisticat.cn into tea yiaclne inc:d;ai is enaervey. i ' Lively said the incident *:v.-is| 0 dcLb-trate act 0: saaam.re to )h= olrni and majar industr.-s: H supybes.'' However, he vcu'aj net sr.c-aulnia cn v.ac :vas- leaaar.-'.h'e. | Vie Hess, an attorney :crt CC.'.",', said the 'union ~i!I . ccevuraiu fully v.r.h 12 " enlrtcraant t a e r. c. e a in inva;::t,a::n5 :x":nc:a^nt. "ifs cLvicas sena=:h:n5 hayaentd an; that tne safety eat:: a man:, verhed nraneriv tc tube care ai ' the sraafcm,'' Pets rata. Ctrtaia the strihiny bar.:: rid_ "Vra u: .5 everythin;; to c.n.pty ...tn the re-,;rn..t.n^ c:crr .srued by Juuae Varan 1 r-.nd reck only a peaceful and. iur; sattioment c: the car.trac;. cis tufe." ; Perms n-arers. .nra.-.iaar.t of; CC"Local 7-a.l na.d warkLrs- at ihe Gi-ks plan: are memaers of that locai, which aba rfprc-sar.ts weritars at Civ.05- fbrvba Gi! Co., and ara r.at. invoked m the disaute b-f.veaa Car.tir.antal and Local -1 mim, i a. I win;! i) o. r.1,^0.. s. *15,000 ) JAN ?* 0 1975 <* Called 'Ih'l'dn'iate. Rahmana' Pi pidii ec Daiosuset h it 'Findii iBialte I'alik p LAKE CHAKLMS. l.a. <At'A)Li 'h. iw Fitfely valves nl -- Ooii(iiinil.il Oil Co. tnncell. dithe plant popped up nr:d the further m:;:uli.!tu os with .`.irik-it'aimd ;-ns nmumaiicaliy it:- fur; ufinery wot hers Tuesday jailed and Ilnieil.^ follmvia;: wlnt a .wokosmair `"I lino was m> explosion nucl tall. d "(iolibcrale sabotage m ai no plain cipiipment on lire," pipeline." Lively r.aid. Tv.o valves wore closed tin n The Calcasieu Parish Slier* 2-f-inrli pipeline early Tuesday, uf's office first reported an ex* cntisin,; u lempor.-.ry pas cm- irln-unv ami fire ai the plant, tr.iliucnl to seine local busi tui'ilm; it was cvacuMiiu' a few nesses. |families as a precaution. The company said it can*! 1'ivtlv "* C'trtiiivnlal work* celled a wnaliMinn session.fcl* rccUisttl the two mam will, (lie Oil. Chemical mid v;.1vcs and the. }wwr v.-as re-. /domic Workers Cuii.n selied-i at ' bf' led for this ali"iim:m, .fare snend mu,or m.uMrk-s in| "The nr AW irr.., "csl Calcosmu l'av.ih sim,died. taS'i'lf IStlTi,,':1 "SiS* '!'<" sir1 " "",*l ,,"i!i :lliin . n ,. oi, .^`rri'olace to llic plant and ina-` rlllh^ofCSmlly11 *"id; -W. ri'im-, 7i` ^oiiliii-tiiird Oil in Houston rc! Uic'coinpahy1 said! ** <W l I J ^dement. iici wns a rnivo niinmi Disl Jiid'X Karl Vrron had!,and' tliusa responsible crtlered strikers not to blnek| v jp he prosecuted'hi the ful, I' .nd L-ntrances morn than t e*:tc:tl of Ike law when appro ved; a::o. He extended Ins tcm-j|,,.ll(|f(|.* pr.rory order Monday r.iijhl un- Vick Hess. nu'OCAW allot*- lit I'cb. IS. n-**y, raid lik uniriii wi'l cooper Company spokesman Pul ate fidlv with law ciiforcemenp 'Lively said chains ami larks; an'im.-ilier. ir.veslipaliu': the in* werc cut from" two main vnlvi-sjcidcnt. lull said he was cerlaini cn a 21-inch line (mm tho r.iUisilhe union was not involv'd. 1 .flat processing vlar.l, nllmvinp, Do also raid Ikn union was' Hie valves t(i dwe and hv.ild upidr.ir.r; all II could lo comply .prisruru In the liiu. with Jwtae Veron's restrain or- j When (he pressure built too'drr. ___ . y.i CCR 000019135 * ' %** n Wll\7.SUi;!r TtXAS ( litv.s U. 13.003 ) l'* *sZV JAM P.9 1375 V Sabotage Claimed ;; O Im Conoco Fires LAKli CIIAItl.KS, In. <l.:!`l) J-- Uil Co. said | Tuerday its Willis pi,nit was S.ilolaivrf. .*,!USi||f> III;' pas -.-flares, the evacuation of 300 persons ai'.il iukrnipiiou of *' lialornl (pis. supplies lo several . indusli ini ii.iors in Southwest 1 '.Louisiana. i An aUhnicy for the strikinp, -Oil, Chemical. anil Atomic , Wot kci-s 1'iiion tOCAWT said lie is certain the union v,ns nut Involved. !;<] I ively, Continental's coor dinator. said chains hohimit .valves open on a 2-1-incli .Viilvi-line weir cut and the .Valves closed. Lively said this pres.-uie nclisnled n safely jialve and i'.as automatically , .liiiiilcd t!-(iui;h flares. The incident was fnsl tliout;ld to he an explosion and aoo perrons were evurualed at 3 a.in. Continental said pas Service was -interrupted to Firestone, Uulf Slate Ulililcs. Olin, and 1JI'(, and Continen tal. The Calcasieu Parish She riff f Department said invcsil- palioiis into the pi) eline valve opeiimp. are tindc-r way Lively said. "Its a debl-orale act of r.ntwiai'c lo the plant and main imlu-.trics it supplies". Continental said. "The com pany has informed (he union ofiiceis that the mcc-tin;' scheduled for 1.30 pin. Wcdn.'.'.d'iy has l.vro cuncelled. The tiCAU* '.as informed that no further meetings can he set unless iliep.id picketing nelivites are curtailed." f The stnho np.aiiir.t Conlinen- tal's West Lake lefiio'iy and rlicinn-al plant cnleicd its lOth day. Jud,{*' Karl Verun. 1-llh Judicial District Court, issued a tempo* i ary rcslrnininj! order Jan. 17 prohibit in:' union pickets from i-larkinp the entrance to the Continental plant. - i CCR 000019136 1-4 .% Hie: Southwest Uuildor - Thursday* January IS, 1976 o/I^ . _r/^ * vJ c^r LA KM CHAm.Kf., La. (IM'i) -- Ouo man was shot to death and five others were wounded today in hd:m* vinlcncn at a chealien! plant constiuctioii site. V.'ifiK'isos said more than Hi:) men attached workers at (lie Jupiter Chemical Co. rile in western Calcasieu Parish, shouting lilies, pistols and shotguns, overturning cars and damaging trailers. Vintnn, n plant guwd, suffered a 1 nee injury but was not shot. Authorities said the* attack started when an earth-moving machine, tore through the construction gale* and rammed a nearby frailer occupied by eight cr nine worker;. Gunmen on the machine ami in cars then opened fire on the work site. Edwards, who suffered The attack was wounds of the bach' and believed to ha the result thigh, said he heard of a labor dispute over Hooper shout from inside use of "multi-craft" a trailer, "They're uu i o n w o r 1: e r s shooting me! They're belonging to I.ocai 102 of shooting me!" Ihe Amoiicau rederation Hooper was dead on of Independent Unions, a arrival at a hospital. group not affiliated with The Local 10:'! workers the AFL:CIO. were employed by Payne A spokesmen for Local and Keller of Louisiana, a < 102 said his men had baton Kougo firm. The ! expected violence and attack occ.urcd one wecJ; had warned law enfor- after a similar attack on i cement officials about a Payne and Keller the possibility. project employing Hie The dead man was mulIi-craft workers near identified as Joe A. Houston. Hooper, 20, Lake Charles, The Calcasieu Paris!; who dic'd of a bullet sheriff's office and other wound. law enforcement Those wounded bv (lie a g c n c i o r, w e r e gunfire were Mike 1 oUmi:;, Latte (harli:,; Thomas Lee Eduards, Ft, Sulphur; Arthur hs-w, t;:,. Alexsndr a, raid Pr.ry Lrdn i, ;*.*; , 1 r i.O ( |l,|| |, in vc align ling tin*, incident, but no im mediate arrests were made. LiiUImt Lal'.ovc, r;i. S CCR 000019137 January 15, 1976 LAKE CHARLES AMERICAN PRESS v.-v I rM l : v,; v / u fi iv i I; I A ii v..^ I II *'*** I ::>.;{ ; .,'/> I V. , 1' * t: u !i U I; '| | ' it ii u i J ** n fK\ ! Ii (, !' .1 M ri \\\/fn ds;vk r-2 'u \j i W/ u W't! f* o v./w ,, Vi ptviible li::k l.:l '.im I..h ir -U'ldli-'if c iii ''Vv. (Mid a 6, ;*W l>aitacl: early Ir.-i.:*.. ,l,ir I5. mar I she Charles in a kit one iflead ar.J five :eimIms been .MUcd by bib'ir nbj-c r\ ci s. The larpel of I he atla-T. Inday at the Jupiter Chemical Co. she in We.t Oalon.-ieu P.';i-'t was Payne .ir.il Ki ller of Lem-u.-ma. Inc., and v. in hers In !>: lo Local l U of ti'.o Anniiiaii Federalimi of Independent Unions. Payne and Keller o? Texas. Inc., v. ll:e lnrp.fl of an eib'.rk 3liy .fi*u unitMi vml.iTs in lioii:.inn early Vudrrsday llml lestiltcd in million in damages and hi ought a re:lraii',i'i:j order from a stale il.:ti!vt judge. .Members of I /Oval Kb! who weic win kin*; on the .b.'piler t in nii.nl Co. job in West Calcasieu ore raid lo be "multierntr journeymen able lo perforin more than one skilled job, observers raid. Local 102 was farmed in E.V.011 Kongo aller tin: K'bOG? emu met ion bomn died down, obborveis said. Union woikt-rs wba bad been ' woi king on permits were refused mem ber bip in regular union locals and formed llieir own local. Observers said Uwnl 102 was relii.-i.il oflnlal lecoynilam by the ALL-CIO and later petitioned Die National Labor Itclations I'.Oiid br, official status as an in-.!'-pendent union. An official of Local 102 in lialon 11010,0 was ejuutett as saying Loral l-c members were working on the Houston jet) when the violence erupted Wednesday. Payne and Keller of Louisiana is .-aid lo bo com pletely union while Payne and Keller of Texes operates as open`bop. or non-union. Named a t neb ndams in the rrilralniiifi order ir.-ued in Texas proliinitinfj further picket it.;; oi ma,-.:*. v iolenec were (lie Hou.-biii (lull Coast Area Kuildmf. and Trades Council and 15 tmiuii local.-:. f U'H tx r"-` IS f r-tt /-a i S ii li cj b r i *VlI r :i v,n in I ;:ss i HO UN TON (AIM Protesters failed in appear today alter J.f'aO police ringed an oil ielmery where three days of labor rli.-putc violence had left an estimated t-l million in damaite. 0Deputy Pulice Chief It. . MrKc-chan said fm I her violence and dost nici ion was deterred ! by (he presence of the rn filers i and by a ro'irl order against ' violence mi l mass pick*-tin:;.* i Wnrl;im\ on oveitnne. the police l i'.in a. -eiiibbr.:' at the Ciiailer Jnlcinalioii.il oil Co. 3pi ml at a m Five b>>i!r:. l iter Kiev befl.m lit (It.-pel -.e but Mi-iicrhnii said a! mil v. rt-m.'.-iii.at the plant i'.miii,: the (lav. 1-6 CCR 000019138 January T5, 1S76 3 LAKE CHARLES AMERICAN RRESS Z- v "' ' l: ij " R--S i? ?8 y r> 3 t vr-- f* /^v- ' r j, ; j Sr. f; j.; ,; y *! r3 * tU !! sr *V! .' -J Wli J Tuv ; :r:`.cr Chemical Co. restaurant employe. `'On my Inside- the trailers, jumiturc cut the wdrdaw lo see a forklift co-T.vttT; s:te on Ft-ic way lo work, my car was run off was splintered and strewn wiki mm sacoting irem it and i'-.-.i locked like 2 the road just before I reached about. A ret:inert: cr irshte rue me:s behind it ceuiira through .tl-u cficr Kray's attack the parking lot. trailer was heavily denied and the: by ;> -a hies icf. ere mar. "i gave them a geei piece c; the cuar ripped ego::. Its ccn- "! went to ti:c Stack of the c.-...: -J:':ye ethers T.: rvu;e trailers liseti as cf .c.-c mangled musses cf s'--:.: after bring rnm- r::: r-y a p.rer fcrsvy mind. New that ! knew what ihappened. I'm surprised vuuu't t'hal." One trailer had at least 25 bullet hales :r. it. The arg'e of tents were scattered about except icr a few cans cf soft drinks which were left upright in thair place. The at.net: happened will) the trailer ard get cn the finer. When -hat group left, a passing car en.ue by and started shaataa; at the trailer. That's when 1 was kit in the log. Teday i --rut. A Mru"i`y muae-d's the holes indicated the shots suddenness of a perfectly was my first day on tire job." h. v ;v- gate was overtitmed. Cars and trucks. were bai- Irrvscarred with billet holes *'.m gunfire ccufd re heard by erriru-iae the Cajun Kit'chr?. i'crtnurast about th.pun r:ers oi a mile away f:;:r. the job site. -It v.-unded like cannons were pm.g off." said one came straight ahead frem the north and others at an angle were `rent the northeast. Thirteen ears and four tricksy sustained heavy damage from the attacking moo. Car and trad; windows *.vcre shattered with hear.- objects, fenders were ripped eff and one car had its head punctured with ana:;. executed ambush,' observers said. Luther LoSeve. a security guard who had only been working throe cays. said. "It happened so fast: can't believe anyone knows what hopnvnrl" Tr.c~ns Edwards, tee of the injured men. said "I had been here live minutes witt-n I leaked Law enforcement officers, hespiial cnyrinyvs. ami.uiar.ee drivers wore eatrsged and hewiidored about why the violence erup te d. "It's just erray." said cne restaurant employe. "It's r-citsuicss. what's the reason io.r it?'' a heap:;a! cm- r.l.y.p ;;.:d. 1 Arut::? hernial employ* where hm'-uud tefongs .tc a union dv pi trod th; act. `There's ju-t r..o reason far r> something like iriis," she said, o 30 "lucre's no naeti for it." f o o o o Ul o 0 .-.ej^ru 1,- :iwicio r** r Us ! n '~r-I i~p t ; *v- nr "v .m- i.--, Lh? i .* t j An all-out !r.ve>:::ati-.n into violence at a Calcasieu err-itrauar. site m which rue men w;- ard i;v; :rju-ed was pivnuy; j;;-.by Calcasieu Pur;.-a biwr.f; i'ear-- A. Fcni Jr. "Ti is NuterrlM*' thm.a. Tais is rnurJrr. ;:.J the .-herui's dfpnrtnu n;;; P una am; v. :i'. ao c- .r-huna m :!> p--'.er to .-.e that rtspenrihlv arc erupt. You can depend on that." stii-a licid. D;st. Atty. Frank Saiicr Jr. also wert cn record ta-u:y. pr ums-na aetton by h;s e t:::c. Jailer rma. *'Tr.? r.:a:- c-f this tr.orrnna arc rtp:rr.-:n.>:ve sr.uaf go.a: cm.-:purree :nc rrrp'e of ;h;> area. E' er;.' s*e? wfi! be tnkiii !o cis^wer the pr-rn; wim commuted these rrimes and auamarr-ion they -.viii be pr-veeu*-' j V.'e -.via r:-u stand lor vii.ftiiuc. E-.-.-ry type : vtolc-r.ee mu.-t L- tup- p:c.:s:d." January l!i, 197G LAKE CHARLES AMERICAN PRESS is ii * vi-' i. t " h '-1 ` k. 1 W> i' i: v..^' n if, Kty- C+i v. l!. Li 'i.-7 k-u!!<- ] r\\ j t.y>-tarp.arcz Li liOL iI ii CrO V'/l! il wuii I: w^WU^il <J ' OffirirJs n! the J/niiMjp.a l'.!::lsiiiiri and CMi- idructiou i r."(ic r. (.'oimril (Llaiifil s-l.*o:i!i:*rr .M a Wc .1 I'al- iCSsifii triKii.v.1 ;-i!o on . `jpwifoss/nn.-d Mrikt-brchl.t-is ' i pi3*c*l by t;.c company." \ tiifkinH made it dear they Mfrc- roirrri:;.'*. to Pay-J arid EsSirr of I mm-iain. inc. (ha company whose ov.ii woifc torcc . teas attacked early today in a Ttotfiil Incident which lift ena inr.i: dead and live oiiieiv hart. , Trades Council Business . Manager P.i:u!d I.ovtJl r.n;l at- ' lot coy Wilihm ISaardt ivi-.cle ' Hie curnnv. r.l.? In a suLmont shortly before uoon after a luiphy ruuferenco with law enforcement offieiais. ; "Wc know frotn pa.-,I c.\par- icnco that some companies bring in profi-Mdonal strike breakers in pmvoice violence, so that tl'.ey can pi into emu l and seek injunctions or re- Mraiivinj; orders apainrt the ! union on tiio f.rctind.s tlial vio lence has occurred.'* said ling- gelt. "We su-pcct thc.t such pro fessionals. employed liy the company, v.erv lr<\ jived in this morning's incident." Bnpyit added Hint Bayne and Kdlcr work dies report edly were Involved in ciimiar nets t f w/iVnc*: Wednesday in cies llial we will cooperate iir the IK mton. i v.\., riva. any way to a..sure that (lie A:,!:td atria! a possible dis p.ui!ty parties are apprehended pute with latmr poops, and cuavictcct. Ba;."/ it acVod: "We were picket in:1, that contractor "We arc sure that when this (l'iiyi:e a:'.'l I jailer) and have no incident is fully inverlimited, dispute v.i.ii any other labor the law 'iifonciviviit agviieios oi::aii!.\';l!u!i." will find that pio.'v.rtioi)al In a prepared shtciiienl, I ev strike In takers were used," en said i. i al labor kc.iers du 1/nvlt convlt.dvd. not condone violence, wore r.ot involved in lid; morning's inci dent i.nd j.io;ni' ?,| foil u-.pei> ti'm v. ;;h law enforcement agonties. "We. the labor leaders of Southwest l.oi'iriaiia, were Victims listed . tliwlcd end di.-moved by the violence that occurred this in plant violence morning at the Jupiter Chemi cal site. We do not condone vio lence in any form. Identification of ihc one man Mike U-Paiiv. V,, ?! t Louie "Vc.-jc. h'y. Jan. M, vc put a ' killed in hilK>r violi'iice and St., bullet wound in chest, stable pc'ca'i lul pici.i l line on I'ayuc IliOfO injured at a cun; 1 ruction condition. and I'h llvr In protest f.ui>stan.i..aJ wages and working amdiiui.'.s. We Instructed the pickets on huw to conduct a pcace/t;l picket lino. "they v.ere inslrtided to repot I to the union office any viiiicnce or lltrtai of violence. Wc are in no way connected with ti! incident that occurred Hits r.orrrng mid have adored f.i.? lo;-.:l law i u^acinmd agen site today were reported by local ho.- pita) so.i/ cos. Treated and released at Lake Charles Memorial Hospital Dead is Joe A. Hooper, 2C. lit. Uioxl3to, hake ( Italics. Hospitalized in St. Patrick Hospital were: Thonios Lee lidwards. 21. of Oeneral Delivery, Sulphur, pmshut wound:- in back and iiO|;lt, were: Arthur De-ar. f'i, of Alexan dria, cue gum hot wound m le;t. Cary Latiner, 2ii, of l-'oresl Villa;1,e Apartments, gunshot wound in leg. satisf.iilorv oDidjIion Hooper, Ldwards and 1-UleluT i.aHove, St. top Hor- La Hove were taken to Hat ridjjv St. Vli.m-.i. twiMf-d I uec.' ..hospital in i`o!'.d<l Memorial treated and wilt t.e iele;i:-cd. Chape! ambulances. CCR 000019140 1-8 Mm<: i' and ci iipl'-il jit .1 I\\ I ( .ill .1 It il l Oil pjirj-nniiii'io /\rni rtvi_jhm<j_ An Afl'HiLi^? iinaJ-AihHi siir MiUihmi Ci' ;il "iii V .1 in to (I,IV. J.ill I'.. I .i\r:". <'l!" l.l.'iil slii.l lo (!' :lii ,::iil Inf utl.i'pi lllll 1 ill i.".l V. Illii '.d do.-j'i ilml ;i, .i ' nil'll .n iinn " Jnc A Him,icr, 1'ii. in Mi'; -'. liluftwo.il i::-'.I. "II M.iilul so f.i.-l mil oily knows v!:;.l om: man /it ll.c .Iu;ii!.i fln*!!ii.'..l ('ll. (ii:i-'| Hi Ill'll MIC S.'.ld. I'asne alii loTicf of Ioili.i.'i; .l. Inc. a lt.iii'.i ii'.nic ci'ii.-lino- 1 io:i lirIf., i1- (iii.liaclur lor the M.iiifiia Hi.`ad V.Y-Inr-d.iy The line. : f.lf is u:i l!if lo'id 1>.I.'.'ell I ini.k l.'oih, pi i ndent of (lie Coliimhia Kiiiidifin Haul and litluir iT.imeil. deniid that the buljihur. . pickets came (rom his Mike I'inris, an nilomcy for r-rp.'iii/alioii. lie abi said he the cn:i I met ran comp'iny. .`-aid l:.:d r.a l.noulidj-f of any at- the (Vntr.d 'I'f.i.Vr. raid l,:l.ar tempi;; to put UY lerslr.imil's (V n::ril 11UI lip a pirl.fi line union mil of luisinc.-s. \Vf(!iif:;d.iy claiming sub- liiehaid IV It'*'.id, an in standard wages ami working vestigator for IP.I, An: invites coiKiilions. of llidon IJiiuje, a company new .`iimumim plant. (ice of l!u* n.ciiid men. Thomas l/o IM.i-.in!>:. s.m!. "l!r..i|'(T I'.hMitiiI f"iir nr ip.*.* limes: llii.y'ie shnnnr.i! me. Ihey'ic S!mKi(.'i,;' me.1 " He i.iid there ttn.i pinnre m (nun of l!ie Irailer. Ti.:* first m-'iiji of m. :i left, ll; n a s.Yund iar pn.-.-ed Iiy and si ai led sli.winig at Hie trailer. An official of the union rfo'iv*. the couslnii lion work (or I 'oync and Keller sud l.e i-.niniid local authorities Wcilire.Ml.iy of the possibility of violence at Hie site, lull no action was taken. H. H. Wivl-'if Inndl. business agent for l.o. :il lad. Aiacruv.ii ri.deralion of Independent t nioiif, `.-.id ike attack on the con.itrurlion v.urkers was part of a continuin''1, i bv Hie AKL-CIO 'to run 'his c.rpiinicaiKiii out id the ..laic. failed by P.iyne ami I.YIIer Wednesday to lain* pirlmes of Hie picket in;;, raid h j contaetid li'.iilo Police on his fiii/ens Hand cmti rer.cy fuqueney -hi rnintiics k inre the violence tun!: place, hut he said police ignored ins request fur help, "'limy laid me mulling was Vidor 1Jus-iie. president of going lo happen," IK-.Mmil. the stale AFLCiO, said lie Phans mid ti lr-jilim;.: linos to I.T.c-w nothing of Hie Lake the site have Ij.nm cul. lb.;ld Charles iecKianl and denied made the emeri'cuev call after llii.t his mpaniialion has at- the mad v.as blocked in the templed to break the in at cos. dependent union. Spl. Raymond Hnffpauir of An iillorncy for Payne, & Troop D. State IM.'i. v, said they Chief Deputy All^it Manuel of the sheriffs department .s.iiil today that to hi know led ;e no one from local HU had io> laded his department yesterday. first reports wore that about Killer said that alter, a H- received the CU cv.il about a iii.n crew began wark at the toad bring blocked "Wo were Hie Wednesday. Hie Calcasieu sending a unit to cheek on it. Parish Central Tiades and Von never know who'!, poing lo Linar Council, a coalition of try to r-fir up violence out CB several AFLCIO foibliurlion radios. A unit drove Iiy and the worker.' unions, set up a picket toad was clear.1' 100 men rushed the plant behind a piece of heavy cailh i.iovjm; Cfimpnii fit and began h!;:-ti:ig away at a c.instriii'iina trailer containing about eight cr nine men. The heavy machine rammed two trailers and a pickup liuck. January 15, 1575 LAKE CIIARL1.S AMERICAN PRESS (Hass was broken on about a dawn cars in Hie parkinr, lot. including three cars thm tin I been ovorinined. A portable liuard house was also over- lunii'd. Ollier workers tor the com pany said tl ey came out of * :'.o Of the poiY.Viivr.! Ii;;:l(l:n, -. ai.d a "iii.-ib with twins'- ordered llu in luck ir.side A ininpan> ip-ike; man raid al> ill I! i.i'ii. mfiiiiui'v of a !.'*M pi MT lli'l.ill: liMi'll, l.i'.'.'l in.*, C-ii i' lo 11if :i!f on I Ylf CCR 000019141 1-9 Ii f* r* 11 l. v.,.; W -./ iJ i, ) ij r:"iV be.! v* ,, k,) U u '.v II 11 fVr'"v It -J Ai.\ r:i ) ! )J il.Hil TESTIMONYUy DON ILI,\VJK11Y Atrciicau lYcis.'mdl Mditor tlus Male as iiroKmilinij albiir.eys neared the end of (OllurMuiyciiri.v'a ir>) GHKT.VA - A man v.liii vent Ilifou;!ii the gate al lln- .ItipiitT Clivaiical Co. silo liding a forkiill and waving a-il-caliber Magnum spelled out detail ritc.r detail ui Ho t .Ian. li violence before tlaiing jurats he iv I'rid'v. Kenneth 1C. "](< Wee" IIorijii.T, e.-em led by a eonIon of r.rmi.'d deputies as be tillered the Mill Judicial DistiiiT Gmrlroam lieie to appear as a DETAILS ON PAGE 16 Testimony bv Kenneth 1C. "IVu Wee" Hooper in tile t.ralli of his second entMin. Joe J!.u per. on Jan. J.i at Die scene of Hie Jupiter violence is on Page lli ol today's Lake Charles Anicnenn I Te.\;. "We bad special deputies with nuns.in cur bunch,'' said Ilonper. Ihcir presmilalioii. Willi only two more stale miIih-M: is: lalcd to he lii.ard loday. July Ml. there were indications lliai liie ease might In' ILirne.l over in the jury as curly as Sunday ovening. Judge Alvin User, an Orleans Parish Criminal District Couil judge sill in;: t:s a s jv-eiitl judge for Ilia .Jupiter violence Inals which were moved line l:om Luke Charles, lias been conducting 12 and tl-liour daily state wilivss dm iug (lie seeoivi- I looper. test if\ inn tinder natli. sessions since the trial not> dcfii'eo murder Ii lal of Wilbur d. Mid the Jupiter vinlei.ee was undei way Wcd11c.sd.1y. 4 LcLeiK Jr., said the Jupiter planned during, earlier In other testimony Friday, violence was planned lil:e a meetings and ginis were witnesses mud the bullet ilia! commando nllm It. distiiiiulej to the group lie was killed Joe Hooper fell out of Ins "We Iward! iuce Urc. 1 about v. il!t al a pro-dawn meet ins* at a dollies when an orderly began 1/ical 10i movi:.1; ji;,'' paid restaurant in Lake Charles. inirjic r;iii;; the body in a SI. Hooper. "My iaii.ni'. didn't bi:o Hooper t- .slilicd that alter the Putrid; Hospital emergency it al all. `I hr y laid us v.c would vioient e ended, ho met with room after the body war. have lo slop (bem.'' several men - again al Hie brought inlroin lie: Jupiternte. Hooper sold a? many as "ml restaur,on; - and "we had The slate sent I ! wiliie.v-es to incii massed along' Prlo col fee anti talked about bow we the Maud in an ailcmpl to lie Mnnena Hoad ami::; bom Ibo shinned them:" (bat bullet to a a nun IJrov.oin:' jupiltl rile ab,ml fi; 15 ;un. 0,, Hooper testified Ilia! later in nuloiuulic pistol the statu 'J'liiir.diy, J.ni, 15. (lie day ho "drank' some gin" claims was fired'by LcLeux AsUerf v.liclber lie bad seen and cried in the presence of Lou. during Ihe Jupiter mind:. any law enforcement cllieeis in I'or.lennl. m.'inai'or of a Lake Kmpty !) min Midi eases; (lie area beieie the allael;. Charles renlal film and a Iricnd Lullels ie.,1 fired hum Hie pun. Hooper said liluntly. "There of ImiIIi Hooper and Ixl/uc testimony claiming tbe bullet was a Slate I'nliee ear parked "Yes. I cried fli;:! 1 ihoiidit I pellet 1 aled a jaeiat, shirt and pear the p,alo. He seen us with rnipjit have lulled my cousin.'* T-: bill 011 one side of Hooper's ouriauisandbeln.ikolf,'' said Hooper. body bill only ponelraled lli.' T- Asked whethcr any oilier law Ihll.'d will; a single htillrl in Miiil aller il rumeo'.ii the oilier rffieeis won,1 around. Hooper (lie Juniler vioieii-e was Joe A. side. 0/ Hie body, and ballistic said. "Yes. we hid special Hooper, a L'ii year old Lake lepoits v.erg: entered as deputies with us." . "Willi '.on '" a: l ed a Mailled < :' n* lja.sYm..,i\n.`vJ, h/o: `.,mss n inn,lineJ.' evid, nee lor lla1 stale. Alter Hie stale re. I.; its ease ddeii.eliishyTihne. t* J j \ < 7 , durum tne morniti 1 In-lav. tbe ) i \V \ d'.fen ,e v. ill begin pi escnttni'. its \ east'. iiucc/.Y, jn.v in, ii,! .1 r:..i av.mI.-* { 1-10 Si . . 1 , , *. . * OCR 0000191^2 r r' r r \ ) APPENDIX J PROJECT REVIEW MEETING - VCM INCINERATOR i* r L L CCR 000019143 '** hs "i* * fni uroii ;o::i jit imiinii rtiion To bi s tr i but ion r i oin J . I . A) i row M;jy 18 ,, >^^.1 r-f<o.ir.r.T ui:vi(,\: kitting - (n n i it; iiti-at or.s LAUC CH/.LLLS VCM fLAIIf - HAY 16, 1^/3 1 ' ;) i i lit , ( 1,1 Attendee..: G. L. J. A. J. K. G. S. A. 1). ` E. J. K. Urcutzer Lndiei narci i llo 1 c.t...ib ilcl.eod Meyone r Ki dd A1 ix Field wo11; on this p roj ec k ha: been shut de Teamsters* strike ayoir.si: 1` 1 iti conLi' actors . a sett ic'.if. ni before early June is unlikely. May 1, r;73, by SjM.:eU leV,. ion is ihift Des_i cur Mechanical disir;:i is complete except for tin* CondenSfiiL* S tor vu System, Construction drawings for the ?Oo Lys tan will issue in about one week. (l) Tin* IJ1 ant continues to Lie concerned about use of wafer values and instrument tees in Fur cm piping. They fear that the unsupported portions of the Furon fM.nycs will Is oveistressed and broken. G. L. Kreutzer will oiinnyu a demonstrat ion to show: a) that the flanges will hear ilia required bolting torque. h) how miioh ove.r-torque the flanges v/ill take before f; i 1 n re. (2) The "IIYC/.k" gaskets specified foi the Furen piping are .unsuitable for the service. G. I.. Kreutior wi 11 recoruVicrid a gasket Material which will resitt the chlorinated hydro carbons, etc. This needs to he resolved promptly to avoid further delays when Liiti Gli ike is over. CO A portion ui t.n-iei ground ui.m pip inn h.\:. ..) i.: .t 11 y k-een i lil- .yl 1e* I With ' `11Y l./.k`1 >;; K- l *.. . i`it., lion to ill I eel' this will he k: tel U. i ,,i-.i Intel . CCR 0000191^4 J-2 (>i M r i !>u! i: .) May 18, 1378 Page Two (fj) TIk1: basis for accommodating t ho mm.'; 1 expansion in the reran piping wis iev i ew..*d , It was concluded that. there is no problem with the c un un M des i yn. (!>) Valve support requi i omen ts for tin*. Furnn pi p i no hove been reviewe;!. Additional supports have been added ns necctssury. ((f) I'.. I). IcG< (: has furnithed comments on the I ncu1 ation Package, k. G. Me,I.rod will review the. Par.lo.iyei in detail and furnish r i; v i sod line specification to G. I,. Kroutrcr by dune 16, 1978 (#1 oud -HZ I no i no re tors) . G. L. Kreutzer will have the Insulation Bid Packages revised and re-issued. (7) G. I., i'ceut^er will prepare a P::sign Change Order to revise the safety shower water supply. (8) J. F. Alix will initiate a Change Order to cover the Condensate Storage System. Materials will not be purchased until the Change Order is approved. Pmcuri: m nj^ With Li twin P.O. |Wi 16-116, a 11 materials for the #1 Incinerator are on order. With Li twin P.O. 5^37-71, all materials (except, two valve positioners) arc on order for the !,2 I nc inerntoi . I.'o mef.cri.i1s have- been ordered for the Condensate Storage System, hut major equipment has been bid. * (1) The {!7. Incinerator war. te-heat-boi ler is being field up at the vendor's pending end of strike. (2) Tim main control panel is likewise ready for shipment, but is being held. Construct!on Based on the Contractor's estimated man-knurs and ''normal" manning, i.iec li.ui i c.i 1 comp i < 1 i on of the /') I nr i net a lor is projected at 7? weeks aftei end-of-M r i !.i.. There are several areas where improvements can proh.iMy be male, I.'. F. Kidd and S. A. Heycner will continuously exploie. a 11ei u.ii i ves , including: (|) Any wot k 'which ran be done off-site (?) Piioiity lists for piping work to advance electrical and i ns11 uisen f.i f i on CCR 000019145 J-3 * r r r i F > I. I, l>i ,i i i l "i i on M-iy lt', )'j/a I lime (3) I nt: reared manning {h) Mul 1 i | I 'Mi i i" ir. (i>) Overt inrj ilie object i *= to develop cost end sc hedu 1 c, effects of -ill fees i Lie: til rri a.at ivc;s , so a revised plan can bs assembled quickly ai the end of the '.trike. Pipin'.: fabrication is proceeding in outside shops. The-her I; log of spool pieces should allow high productivity when field work resumes. IncerrMne c.a t . r i a 1 r. shipments have been held up at the local carriers1 t f:i iii nr., i 5 . /w rnc.ieiren l.s will be made to receive material!; at live site to the e>:ten. that this can he done without incident end to the extent that Plant labor can be provided foi unloading heavy shipments. Ita 1 nr i n 1 s tire on hand for oil shop (ebrianted piping and electrical end i ruj frumen v. mate rials two in good shape. Areas requiring continuous attention and c e.pud i 1 i ny are* - Balance of: KrJnnkin Older - Monel value.:1. - Lined valves * Orifice f)or.cios ** Furon/I P.P piping Distribution: Attendees L C. T. l/yntt D. A. Lewi:; ft. 0. 0 a n v M. D. McMee L B. D. Hut 1 iff ft. L. Leh.Ml.uhl H. V. Mcl'lv 1 son D. A. Kulm/J. II. Ce*irley CCR 000019146 r.: r r r | APPENDIX K WORK ORDER COST CONTROL - SHELL PURCHASE 4 i u i; L CCR 000019147 (T3 i ii ; ,W~ t ieygics date r-.-.ss7D /AM-77! i //,T V /.:* j /?-*<-7? "1 * ' -V U i1 /- `"7 i . /. j.'_ 7? - >-- ?f ! . ' ! .--^.7' I,;--//- 7;- : ^r t -7?-^7- "7 ] j*/T. f'.u* ' 4 [ 7:' . f. l : ;7-/r- '? |jiS. J7-7.P i 'ts.-r. l i1 ; !! ' ! i E3 i`nOCESS S ?vir.i DXXS n-n-77 // /*% . - -+- ' V JUS- -Hr i * A* ! . a: ! !^-/s-vT C-M-'i -v_.ri " 1 J -E-/- "rf 1 ti ! i- i : ! i________________ :_________U__________! 1 FRID ? Ac 2 1 El?p 1 4Ai J -- / -- !<' ' tI * ^7/<!/<? /acR I! M / :-/r/A 1 A' /C-. , J-7 ' , '"?>/ / i ci\ i I i 1! !i ' 1 ! ti 17-;: j ;i _ ii !! 1! : --.i~ ??: i! 1! :. Ii !i !: i5;= j ii i1 11 ! ! 7- --- i : i I: :: - i::. i to _____ __ > i i i - \. ' - ; !i ii 1j t1 !i i! it :! !i ;1 t' ! i i i ! i\ 1 ! t > _... `^ v .-- !: n --s i III 1S t -'ll it! :! i ji 1 il i ill 11 v. j i 1 -- -- J "7 tI i.' i! n i! i1 !! ii t! 1! ,! II i! i !i ! ; 1~r-------- -- ii - 1; nn i .; i i ;: ': !i *i II it '. i * i ;: ; :J i i; j ii V *`- S * ; *' ST CCR 0 0 0 0 1 9 CD APPENDIX L LITWIN1 S EXPEDITING REPORTS CCR 0000191*9 s> JLl J i t> -5 CUIII'O-IA fU'M '' ......... po V t *' 11 A pag!: - |-- or.j. jTRIUUTlOH: t'ROJ, MGR___ j.f'ROi cr.-q-n. Il'iiis^Ul J tES'.GN OtPT. .giier. pett___1. lay lor A: Cl TELL) (JPO. flLf. Q-.'.i'!'0; I E [JlNS'-'i.ei FliL r*`;ooi{ J1!i C!'ii'_____________ AppijESS Oniu__________ i''l-1|','-l(-1 U'hKNgo 1 LITWIN: ORDER M). 1 (' ~ t C'1*'11 opor'M Atr: ____ item ______________ tar- IMid.i-.VF P-flUS-A/H VENDOR 9.\nl 1-150 (2) jo!jnl! *-*11 :co CM SHIr'I'ING t'ROM'SE C ' .'Ant____________ ^ f . J :___fj__'Ll.-lkC_1-0 , N f _ ~j ERVltlv.EC. PATE --S:-.22 II___ visit phone WAMMc_^4actai^L.JsZj:a.i^li,i-- ______________________SALES NAME _____________________ EJIGiNCEROJG 4-- ______________________ PURCHASING ` tfl.D GAVE ___ NAME___ NAME _ PRODUCTION INSPECTION SHIPPING r :Xtescript ion: Engineering: . .Material: Fabrication: Two (2) Union Carbide Model 4-CA-lU "Barbate" centrifugal [tumps complete with Talk spacer couplings, coupling guard, John Crane type 9 mechanical seal,- rtc'l fabri cated base plate and 40 III' motor driver with .'pace heater, Tag: P-904-A/3. Two (2) Union Carbide Model 5-CA-10 "Barbate" centrifugal pumps with Falk spacer couplings, coupling guards, John Crane"type 9 mechanical seal, steel fabricate! base plate and IS HP motor driver with space heater, Tag: P-905-A/E. Complete. The crane seals have slipped delivery to 9-2-77 from 6-15-77. Fabrication has started but is not. far enough 'advanced to warrent an inspection trip. : ' J j i Completion: The completion date has slipped to 9-9-77 due to the seal delivery; however, the original date of 10-7-77 will not be exceeded. Mr. Straight will notify writer in tine to arrange for an inspection trip for the hydro and run test G. L. Krcutzer .. J. R. Ilolcom}) . J. C. Counter J. 0. Gibson I ` B. D. Robertson J. G. Pogue L. Manns J. Friend M. French J. A. MeBernardi H. II. Butt .}. Khitt/B. Gctchell J. F. Alix R. Mat hi a received LITWIN EXPEDITING DEPT. AM A,JG?D>377 FM 78.P.ifl,n,i?(i,2,3i'l|5,6 S' l iI CCR 000019150 ,;'X> i." **> 'o {.'jii ;m: ii*iiih( '' t "!f I'AOC ...l--(. rSTRIUUT I0M: } nt0J. MGR._____________________ 1 rsei* rue.'!! t.. 1 lousc'i.in LITWIH: .repostuvmms ' -v 'OR0F.R NO. b 1 10 - 1 d - UUl______ taoER HAtr -1 -25-.dr f UtSKiit ULr I 1 cewFu nrPT --- --- ------ 1 1 1 or vnaneR Union CarbM- i:... i)pn fkrv I'-pni.A/i.- f. p-unS-A/1 ; J. .F-. Alix U. Mat l>ia Actress ... Cleveland. O|;io\- r !J<1 - Vlnocs UA511 '.uiH.:) J.1 h'hitt/B. U'tcheH pnprC - * 1 J,1*'** v- * ^-------- ao3 fie. -l:A5d.lln.'J! 21..... ^ JflELO ('M1p.O; FILE CXPEDIUR QinSPECT. ru L ; I SHi'TiNG PRCU'SE c= I 0- , "as r'Cvi 0.0-" ___"IfSEST' j(?-:u-r JTERVIEViED. DATE'I:-;-':'.--."-7------Vl$i r PHONE [3 TEL.O MftMF; Scott Strn igluy _,________________ sales nave___ r AVt_____________________ ENGINEERING NAVE ___________________________________ AME_____ ;PURCHASING NAVE __________________________________________________ , PROOUCTIO; .INSpCCTI0N SKIPPING t L - 1.. Ucscription: Engineering: Material: Fabrication: Shipping: n-.o (2) Union Carbide M.\!cI l-CA-K1 "Karbnte" centrifugal pump.' cor.pletc with Falk spacer coup 1 iups, coupling' guard, John Crane type ? recr.nnienl seal, steel fabricated base plate and JO (if motor driver with space heater. Tag: I'-SCU-A/B. I'uo (2) Union Carbide Model 5-CA-19 "Karbnte" centrifugal pumps with Falk spacer couplings, coupling guards, John Crane type 9 mechanical seal, steel fabricated base plate and 15 iiP motor driver with space, heater, Tag: R-905-A/B. Complete. Union Carbide's Mr. Scott Straight advised the writer that John Crane Co. has not given a firm delivery date on the seals. Litwin's Mr. Roger Mjthia has been advised of this problem. the Vendor has completed as r.uch fabrication as they can without the seals. Slipped to 10-20-77 due to the seal delivery. cc: G. h. Krcutzcr J. C. Counter B. U. Robertson J,. I in mis M. French II. II. Butt ,1. R. Holcomb .J. 0. Gib.;on J. G. Rogue J. Friend J. A. UeBernardi tO ' 1 l/11J ` 1 '1 1 I;f*> r-M c`'jLR.i1 'V '.v < .* .n *1 ! i *1 -iv'lG Vf Pli t "i : Q L-4 OCR 000019151 .'Air ! .'ly* * Tt ^Vnn ct v' ;< >m' *i a T i J f STRlfo UTIOH: 1 PKfll M'lil nir.il C. IliRisenan Hi I'l'i ` i! 11 EXPHHTHiG HEPOST 1 srurn n'TT. f. F.'Alix ! lay lot Frost ."Tiltitt/lC" fie rebel J J FIELD qp.O. FILE GM'sCITCR INSPECT. FILE vF.mrv?Anr.PFss. run.'ip . Union Carbide Cl eve Chie dl.'--Is4-2000 SHIPPING PROMISE o fi'siL l ' ptFv ..VTERV'E^.O. PAT r.mauw ; feat: straight .__ awe . ____________________-- AWE J____________________ ___ -VISIT PHONE .SALES ENGINEERING .PURCHASING TEL. O NAWc ___ NAVE ___ NAVE __ ; PAuL . m .. LITW1H: ORDER NO 11 o- 1 A-001 ORDER DATE, 77 irri.t I'U'.U'S tt.r. I'-'tll l-A/F bMl'-POa AM'. . . VENDOR -'V'U-'.aO 1.2) _ inn mo -'Aalllrd i 2) o * _1. , . isFsrST . PROO'JCTtOt .INSPECTION SHIPPING Descripttou: Two (2) Union Carbide Model 4-CA-in "Knrbare" centrifugal r DECEIVEDgtJWN EXPEDITING DEPT. pumps complete with Falk spacer couplings, coupling guard, Join Crane type P mechanic;! 1 seal, steel fabricated base plate and 40 HI* motor driver with space heater. Tag: P-P04-A/B. J* 8CT*3*1 1977 Hist- 7 PM %^|!0,!|,!?|1,2|3,4|D|6 4 q.ft! Two (2) Union Carbide Model .VCA-10 "barbate" centrifugal pumps with Fall; spacer couplings, coupling guards, .John Crane type 9 mechanical >eal, steel fabricated base plate and 15 IIP motor driver with space heater, Tag: P-9U3-A/3. t Engineering: Material: Complete. All material deliveries complete. John Crane seals delivered 10-15-77. Fabrication: Complete: The pumps are ready for final run and hydro tests. Scott Straight advised that November 4th would be earliest date possible for use of their test stand. !** Shipping: Slipped to 11-12-77. Late delivery of John Crane seals reason for delay. cc: G. L. Kreutzer J. C. Counter B. 14. Robertson - L. Ha tins M. French II. II. Butt J. R. Holcomb J. 0. Gibson J. G. Pogue J. Friend J. A. Delicmardi J. F. Alix R. Matliia CCR 000019152 Piirt-i;: V'.v r L-5 .. I 4 ii* L <i /** Pescr in: ran: Interviewed: G. L. Kreutzer J. 'c. Counter B. D. Robertson h. liarns >!. french 11. H. butt J. R. Holcomb J. 0. Gibson J. G. Popuc J. friend .1. A. IVI'.crnirri i J. ISuHer 7e (: 'hi ion. . rnide U a, * TV* ! * * j. ' !* ten t r ifaynl pimps c v~.pl at 1* 1.- i tli i'n i 1% .space r c,' i; f ** 11 *'! **T' f ,''v1 " pi in.; ;i:ard John Cr ;i:.c ty l 1 p ;;l-C nical s oa 1, steel fabri W* .i.t .*. V, vi1 base p1 a t v a r.J J{)' i iT .notor d river w i tii c \ ' Cl 0 0 ! \ ,,* Ci L tj r >. ;'a.e : J'_ 00-1A/ B. ta ! WO {..! Union i. irbidv M odel Lrs.*V ii ;'i "i; nrii.it t" VieSx*' ** i filial pomps w i; h l:a 11. sp see V jc apl in `.S , w oiplinp. rd s. loha C;ane t ; t'C H I..K *: baa: tea i seal, SloO 1 fahr;anted base plate and 15 HU ~ o t o r Jr ivor with sp ace h. cater. Taj: P-0 '.'5A/ H. !'.-.:;jy b a ley. k'u; .lit y Co ntro!. Maria .'! arator ' > P i'o due t iori Con t r.i! . Cn 11-10-77 a final inspectioa was held on the above mentioned items. The inspection was perfor-e,; uwi.u; "A" approved drawiny CP-S t-lt-RA (Iti.:*i T-A f, i'O and draain; CT-fiJIS-il (Item P-905 A/TO. All i teas were found to he in accordance with said drawings and Conoco*.; data sheets. The i tens were accepted by thy writer and released for shipment (Shipped ll-lt-77). Attached please find copies of the vendor's test records. . >, j *> a S->Zl f OCR 000019153 . .... . . _____ _ - J J- ' t-* I'.Ci j -v '! i*n > c t; >o a t i u h ih.pOl l (A(,c ,_..L_~or iniRinu noM: r'HCu. mow THOJ. ENO' I design oErr.. SCHFD rif.PT.. r. i.ivi.<t ',\hi; r ' :*. U'l < i11'! I r. Marl-, in FIELD P.0. FILE QLXPrC^TL.1-' GlNSPECT. Ri.E U* m * d \A l`-) p?n*?T %l *M fi M Vf*J t > kV J* C./ J X Vj.'itv'1?! , -H---a-v--e----1---(------;--i -----l-\-f--. r1--.! i*--:v > ucrfus; i.': !t < n , Me! ,K.i re r " c f-1:------1.v?-tv:--.viv lITWIfl: ORDER NO. _ v0 VIWCH ITEM ./ -X-- TAG____ / VENDC.T JD3N0 ___ :_____ I i(. I '-hr<* :* I ** f t'l Ii'.vll J S H. *'fG PRCV SE ct.jir.-Ai lP`2o-"'.' -sf , S rnt-sL-.' 1-1.--- ^ IN rCRVIEnEO, DA IT' ii - i lveGave , i i C ?i !'l t,"Q! NAM . Ai:7 PHDNE0 .SALES ENGINEERING .PURCHASING TEL-G NAME___ NAVE___ NAVE ___ .PRODUCTION .INSPECTION SHIPPING f [ __ { Description: One (1) r lav eg * 1 (\-;;,orite i.'! Ah.-;jrbcr `AA I.b. a 50'C incluviishield and s ! i eve. ha 11 trief'A-ss o; Absorber te be l5." thick haver. 1} pit..** V ;hic.k Ci 1 .s:"cT wound Epoxy a]ass. liiir', incori ug: Complete. Material: Cc'.-.p 1 etc. Fabrication: Six (6) shell section-, arc .u.u'.cc!. arc cor.;*lete. Nipples and r.mnhe; . r R^rr-ivco I -*;: Xr C?:T:4G DEPT, AM ' W ^ ' PM r batter. section- Three '5} rirr.-. hot to..: h-.w, rnd ;-t;i,'t arc fit up and polyp,las* lir.iit , liar- beer. pplied to t ho outside, being r.achiaeJ this date. Approx irately CC.CONlJllftC. Top ? oction- One tu r In Mil top heat! nr i: I'oly yla S3 1: r.'i r,,; is s chi d a 1 e 1J to u ;;; r*J icc'. t :.< we el; of 12- S- ^. ^/. A.I.p r rex i r.a l c- ly 5 Ci CC pic L .. Mid sect ion- ( WO (-1 : it: *s a c e :k esent 1> yv lll^ i u"lCli 1 NI'll for l i tup. i'itup to ho cc*.role to the weoi of 12-9-77. App vox ir-.atc l y 20; co:; pi e tc- The i'. riJ bar i j r L.he J-. ;;i s : it are appr-.'-- u.i'iti iy 7iih etc. Shipping: rc: G. L. Kruutzcc .1, G. r -1:,l. r li. !). !' ts-'Ti I.. !!/.:: M. I'rem b M. II. ii.it t I're.sen;. Jy holding fur rh ip;-vnt ol 1-lb V J. v4ov-4 Loo'cS LiCq~ ^/'(O ' |'Vi t,. '* .1. i*.. !:> I f i/ *-- > i ^-- .1. o. 'li'.i.Min 1. FI. i,rv).||,. I. rri.-til i. a. N. i.- i'ivi! i .1. I\ A! i ft; / //' ft CC 000019154 c L-7 l u , ti; /NUil -f r * .** STHIIHUJ lllOmIiIl:: I'lV j LITVMM: m, ! I'ljOJ ............. I! nioi f.Nfnr _ /)* . *>;u ;m 4mm * * F3!?n>i'?rVj 19 itl..' H L ii/J * - [H-PORT h k -a i U t .if- i i--ti; tl'tLislbiMr.-N.ri tl'LU' 'i..__ C . 41 "'HI ----------; '----_ j---------- ----1 I M l. Ah>.ot-.'or ; sculp inf*i . (ireeiMJl _i\. t :i_;n_____ i J \:.*''')./------------- . ---------------- {i-v; $v' 'v!:!/.-.1 '21!.*._______ ______ Wh' I , Will'Ll /iiMh'lvhvl 1_________ 1 M'VsV',-:- *__ _______________ j .`OS '.0 iv, \:.\ T '1 i-t.p ' o f u r. t-nr -i ' 1 1r <;'i ov:sr -..if i V i - I >- *,* rvie.m;' r`>'E .'i-vr <.. mit 0 phone 0 i>!u: 1 .`V iiar: m. _ :'j an i Jliiliaink _____Kt'n_ Sr-: "h, jm j_i.'*: ...._______ _____ ....r (Ilea nr. j:stoner ivj'vieo Tft. 0 NAr.'t____ have _____ nave _________________`'-.LJOFIC.'' _______ ... . 1 ciiOs Sm 'T:no 1'ro,stress .; ino, va s he 1,! at haven's 5'lant i:i v'i l:v.inc:on, L\> 1 aware on II-'-77 Points el t ra s a ion ,.is mellows; r;i:i:K i:: .* "in; i hut In;.; was eor.plvic, hc-.wor !! ivio, failed '.. 0 pick up the addition of Ms Injection beans ns per Rev i sion M Heusum.m the' ehanao on nr.nwin.e. 227hR2- i'.ro.i r o:' ii.veo. advises that li.i- ill not cause a del..v in fabrication. (Nott: Idrec . picks up conran*.:' on Lllvin's orivio. i! 2r.iVi:>os ALJ f'Liior cii.ir.AV'i r: :st in- ".^Jo .,-j : i,i : * s ii r :v i n^s . > 2. C. Brcv.-cr will ,'.aviso Li twin of Mo ad Ji L ion.i! cst for addin;; the (-ns Injection T.iis cost will vary fror. Job ?i3". 3. Litwin to chock their dravi:*.:s versus Have;;1 s to verify all. changes have boon :...uio. Have;; is to ,4lso double chock drawings. b. brewer stated that all r.atori'-.l is co.v.pleto opt for two (2) 'k' nances, which si..mi 1 rivoiveii ot(; rtl;-. : 'I CAT 1' 1. Fabrication was re 1 ease:! n 10-3-7 7. 2. C.. brewer stated tliat snail fiLtic.s;s fjiavej; 11 material; arc conplete. 3. 'Hie Siit* ] J Section is to be r.uldeJ . in * j (0) aertions. Section 1 was molded on 11 -- ? -- 77. Schedule fur the remain in;; sections for the win;;. I I 01"* I'tjH .(j L-9 .S' CCR 000019X56 . t> i 1-1 1 ! DISTRIBUTION: J ''' < ' : ci r,iiu! 'ii; h............. [J tn.su.ii t'l n ..... O knit' nr ft .. ....... I ["1 * ti r [ Ql'O. f.,r 0r> n'? I f.Avr.... r r.'Avr ,, NA7F.____ nv ".; it: ` 7: ru:pfi^T !-iH i.*M 8 i .*J <V..i ./ill j .! npv .; -wti ss , ! `1 ' I'WSE li.LVl , LiT win , ,>.*[ r \i. ; i! "7^ M[ ; , --!1 .... J ------------------------- ? . .. j ' *.0 . '. 11-01 / V S:lQ ______ fHCf.lQ ____SAlLS ENGINEERING -- rilRCMAS:1..' ILL NAVE____ NAVE . , , -__--------------------- - --___-- NAVE ,,-------- 22--------n_2 -- ----- --------------(f .. V',,i ; l Siiii'!1 iNC iAil Si k;:vakxS: ] . .t.u'.u ;ry 1 1117' v. ts '/..olot! ii ivi ;; ,'iIS L;:1 otit:; i.it j i 1 tor : 1 i pfiCtll . 1 \ L1 rt* t ! 1 l ry : 0 i rvvv t it is ,;.;i1 as r.t:> is 11 s ;vssii' 1 1 `t c `i it' ho.In 1 ts! v i a ra i ' . it 1ms ( tt - ONolusiv l' expo J i t o 2 el ivory 1to Oi'sp.o ^ C-yS* sv. % if- ^ i; - 0 i' 1 *, ra. \A la l . C. 'Lvov r is t Ci : ;,i 1 .in i:pti 1 ! t Enbrio a 1 i. r 1 s clu.L d* i to 1 - i t v;; n on ll-V-7 7 , . Have.: i: as pri 'iii'. t i, a I'.ooL i i;;: 4k> t. vi*ry .'ti! l! nf Lerrv' 'll . ;' rva r is to .'lil vise !.it win of tha rnirreni S t .1;as I'verv Tfinrs .lay. 3 . T'nis jo :ii>v r.i r r i.-. s ;; prior i t y ar li.-.vt Have;; f- 1 11 i. C* C) Ui.d ;.iii;; was 1 lit- i< i ?;!if st priority in titi'i r pi a i . ll.-IVO" V .'Tr.S tvo ' i si, if is v: illi approx i:.: t 0; v 250 - 2 00 si; -sp i 1 oy vs. Thr ri ec'isui sli 11 L it 1 retina l*L1 Sll lit. . i'lanr i ^ Lo !o - 10.*.is; : ;>r :io rr.*1 1 i 1'1 1 i * I ays only. - ( I II it 1 i f' 1- ,;ivin wi ; r isir...s > u . J . Y.'h i i. t to,a i,i v;.- 0 V.r. Cirra :> (ilerct 10 I1-1--7 7 0:. pro/tv .s of r.oot ir. cc: C. h. Kreutzcr J. C. Count er . V, KoiHtrtson 1.. 11 a rrt; M. l`r< il. II. i*'i t t J. V. AI i >1 .1. :l. Hnlcf.'r.i) j. t*. CLbson .1. C. J'ojpte .1. i'r i ontl .!. A. !)f!5erinri .1. Frost roM ruK-'^ti y'7 1 ' \i ' V7 L-10 CCR 000019157 .4.V I' ( , | tf I t" '1wA 51 1pt 1tt '.I .'.'I ; DISTRIBUTION: y*n * * ^ I LITWIN: l.Q iIpo.i r.u.f* ________,,._____ _ .,, . nu'j lug k___ . OtSIGM 1>F-F* r_____ C-I..-' io.VLl________ ! p sculp deft___ X--T'.u-'I.or------ K. i S li r - B i i (i i f tS I ; o`.ti >. so ..... j iio - li-..'17.... i on pi.r :).'f ._ i--'.'- J/...... ........ _, ,Tf V (it'l, .V's.'r';.'r____ _____ .1 M'O'?__,, V_^Ji < jLp'tl'VV.Lid ^J: ...TAG_____________ L'.tl'lU f F. A11 x___ G. Ci.ivnir.HM_____ WUIRCSS ,, --VxWiTAi f ;':Vw i'v *'>7 vxe!________ VL upon I'HPNE ---- ______________ u!wm' `'iA-21 Qnf.tO Qe'.ft PI TEfi rQep riuE i'lr-fti T ru.F. 'Ul.PPISG rROMISt INTERVIEWED- PATF . ,,],l" LIZ-----VISIT Q PHONE 0 TEL Q .... . r.s_....... ut- v-j fli'.'E____ MQ. J.l'LUKil 7:V*3_______________________SALES NAME ___ Ntyp ___!U.VJL.' t'M VW. - I'l.lsticLMy. . ENGINEERING NAVE . r?opi!CTiC' .INSPECTION NAVE____Hercules Corpor.it ionpurchasing nave S'l PPING Contacted Mr. Karmun in reference to the sIippp.ee of C-901 from 12 2-2.1-78 as reported by Mr. Glen Brewer of Haver. 77 to Mr. Karnan stated l he unit went: to nanufacturine on l"1-1,- 7. Completion ad shi pr.cn t are scheduled ter late December or early danuarv 1978. Arrangements were made for n progress nee tin.? between I.i twi n/Conoco and Haves for November 8, 1977 , at Haves's plant in Ni lnington, Pel aware. Karnan also slated that he would advise Mr. Dudley Barton (Haves'' to update the fabrication schedule dated 10-11-77. Following will be in attendance at ll-S-77 meet ini; J. White - hitwin C. Houseman - Litvin R. Mathia - I.itwin G. L. Kreutzer - Conoco Updated report forthcoming after meeting. |st cc:.. R. Mathia. J. Front J. Whilt/B. Getchell L G. L. Krcutzer L Poe* I'UV-OII l: V >N1 !. L-ll / ;/ OCR OOOOIRIS8 'JX-' J tti't'' -i wo -U v u '* *t` * t ia f Ih !! ISTRliBUTION: PRO f. ! # ro.) r.'K'. i;_____ 'DESICNOF.PT.. l- '*' " 'ri S:{?DlIii!6 ui?OXI i soisjo cept L'----_____ i! i; c! rhiT.f cu i !: i r-.rii: [lathi :i M. I i ^ i:. AM al'CRESS___ Pain Pc Injury | sfiitt.'R. (-Vtclu'll ______ _ held exhcter -I `NiCNE----- ,'ipj -yy.oo i ........- r PO. FILE (jiNSHU'T f ILF. Smf'r 'ia "Rr'.' SE c".-i ,. IUT PiJC`.oQ a- tel.G liv,i:___t-ion nrt?wo." | WE j----------------------------- _____________ SALES NAVr ____ ____________ENGINEERING NAVE ____ NAVE 2_:__ !________________ Pi-1- -OH AS Iff 0 NAVE ic.'4 ---- Of------- LI TWIN: ORDER NO. _ ONT-FR DATE.. i . > > "; ITEM ________ M' .-ii l l".T TAG_________ vendor ;on ao .. t.v'! a - ."Sr ?E NT ) -T" . PROOL'CTIO. . INSPECTION SHIPPING Dcscripr ior, * rng inocr in.;: Mater Lit 1.3 labr icaticn: Shipment: One : l!a\ee 41 Coi-.pos i r e :!PI. Absarhcr 9s ,v'>" !.P. X 56'n" including shield a:u! sleeve. ball thickness Absorbvr to be lV thick ! lav eg 41 plus V thick fi iai.c::i ;,o:ir..l F.pnxy g1as 5 . Coiap 1 t e. All major material deliveries as u e 1 I as ilavcg 41 complete. Scheduled to start Poccr.I'or 9, 1977, (Shell section) thru 12-15-77. Base scheduled to start m/0 12-19-77. Final inspection scheduled for February 1C, 3975. New scheduled for February 20, 1975. Late drawings is the reason given for fabrication start delay. at RECEIVED LITWIN EXPEDITING DEPT. L AM"OCT:jU977 PM L 7|8n,IO,ll,!2|l,2,3|'l|5|U JAP L cc: G. L. Kreutzer J. C. Counter Jl. P. Robert son b. I In mis M. French H. II. Butt J. R. llol corib J. 0. f.ibson .1. G. Pogue J. Friend .J. A., DoHcrnardi OCR 000019159 L"J 7.,< -/? ... L-12 ik'scrip* ion: ('ne !.! 1 ll.'Hvi.; >1! Composite MCI, Absorber ?>h 3/S" 1.1*. X 36'6" inc 1'.i 1 i* shield unJ sleeve. Wall thickness of Absorber to bo lT j" thick Havcg 11 p 1 vis V thick filament wound fpexy glass. Engineer i ng : RECEIVED UTV/ltJ EXPEDITING dept. am "--.!1377 7|S. i- <* _ FV, C. I.. I: rentier ^4. '< mu or H. I). ; in.TLscn 'uns ft;;* , it-nch 11* I i. ;'i i* ( 4. 1. Aliy 4. I\. i If Jj 4 N. f I 11, : 11|| 4. (, j'flj'ljM 4. I r 4. A. lu IVni;ir4i Milcri;i| : The drawing.; wore returned by Litvin to IIAVr'l and received -4-7-. liny were "A" approved as noted. iiAVf.G'* policy is that no fabrication starred or material purchased until drawings are received. Ca S-23-77 in a phone ccnversat ion with Glen Brewer of ILWI-G, he stated that they have the drawings corn 1 etc this dole and will hate a bill of material with delivery dates by 5-26-77. Writer notified Litwin's Scott Cathy on 8-23-77 of the drawing situation. The main problem at this time is that, after the return to I.itwin of the drawings plus three weeks for squad chocks the date will be approximately 9-9-77. IL-WEG lias a 13 week fabrication tine after receiving the drawings. The projected delivery date would be 12-10-77. Scott Cathy discussed this with the client and it is ac ceptable to them; however, no slippage past nid December is acceptable. Mr. Brewer of HAVtiG stated that they would still try to hold the 10-26-77 delivery and writer will criJenvor to maintain' the 10-26 77 with the foreknowledge that there will be some slippage. In this manner writer hopes to hold slippage to a ninimm. Now ordered but lliveg 41 is shop rnde. 1 I'*11*' i f:l inn J* Cnr-ji | i ttn; f*>t t*: I None starred. Cor pi ct ion i r. still stated 10-26-77. rit'T will rite e.'pediling phone call', for t h*' drawing ap.pi o-. 11 and j' I in <n i in pert i un and exp-, d 11 : n.; trip as ''ill a, the : h"l 1 i s laid up .ml j' > ly lor no. Me in> out. L-13 1 . / '. /./ . CCR 000019160 iri t-t-r * Hi**; Report -H-I5 i 1* 4 C * j {3 ifc'l mJt fl '*>3*1 II,V/Vi Chem i ca 1 feu i r-oti t ... r, ,!i)! ling ton, Delaware 5(13-4 Jb-jal'J L --- - - -- __ _ .. ' -- v-pscvse c s',l 10/?b.72___r*s.. :j "u0NcO c^le* :_L.i"rtr3i:;tERiN,G purchasing TEL.G K-WE ............ . nave _ .. name f'AGl' - -Or LITVIN: ORDER fiO.- . . -I'' lb - 1 1 -'J1 / CRDEf! DATI l,/`J- ' ,-c,, hCl Absorrar C-9J1 VLNCOR i -T3N0 r .1 "j " I ,, - ,, PUFSisr ij-Av tor f7 7 production inspection ... shipping I) '; y e g 41 Composite i:(L ".bs.i,'Ler 45 3/3" I.D. ; inciting shield -in.4 s 1 :. r.. V.'alV thickness ' Absorber toi be IV' thick baveg -1 plus V! thick 'i 1 wound Lpoxy class. A;; res c-c Drawings, were sent 7/11/77 so IV. B. Getichell of l.itwin. be:-is ter of Teflon and Hastel loy. internals and all other ,-iterial will be ordered on receipt of approved drawings. The Haveo 41 is node in the shop. rubrication v.ill start upon receipt of approved drawings. At the time of the drawing release the vendor requested a 13 week delivery from that date. In order to make the delivery date Haveg should receive che drawings by 7/26/77 *4*' 1 J. f J- * - v , ;`j:- : * * ; *., \ x ` , " ** V x ii ;iutr J. R. Holcomb J. 0. Gibson .'. r,. 1'op.no J. K riend I. A. PoBornnrdl J. Khitt/H. Get.c H. Bierce ' P-T> L-14 y Mil ; 4 1 <> f`U (?.P ' CCR 00001916X APPENDIX M COMMUNICATIONS WITH JOHN ZINK CCR 000019162 r i- r E. H. Kallemeyn tSI./3 . x!w Or^n-! (conocQj Date X- XL-7 / <Xu /J /cxT GLo^J 'sdac(. astvf?' <^Lo*AU oC-. - ^xiu, -rfJL^o^sJ Ip i'-VX y - 7<f vh'O 'Jl/Vk/,St^A|V/ TXm, M-2 OCR 000019X63 Ib^SW^^JOKN Z[MK^^=~-- - 'r N /As:r _____ _____________ __ ____________r .. 11(4;, li. FLtViSE REMIT 10 J0!!,:! i NK CO.'tPAjJy rt-an `HEAT KAXEI53* S. O. NUMPfa TO 085580 SOUTH PEORIA * DOX 7388. SOUTHSlDE STATION TULSA, OKLA^V<IMA Vq91'e)'.747^7! g ORDCB NUMBER 790061 DATE HAY26 Ti INVOICE NUMBER 19,84 3 T0F p CONTINENTAL OIL CO PURCHASE DEPT P 0 BOX 2197 HOUSTON TEXAS 77001 n REF JZi INV I 9,764T0 J FREIGHT CHARGES PREPAID f?Y US FOR YOUR ACCOUNT (PER ATTACHED PAID COPIES) MISSOURI PACIFIC F/B 389003 PURCH. JUN 5 1978 fviMWH | tj'jiiC " j. iiil COM |j I PUR 0*D NO 1 1 - -*-J -S1Al--tS ,TJAJB---- 1 JJJ. i V\fio&Mm i TAX R*t j J "z 3 DAT PASStO^ PRICE OK TAX tXLMIM oho nr --<M 1 1il.L> UlSIRII'UtlON 3.2 4 1.29 3,24 1.2 ` THIS INVOICE IS DUE ON RECEIPT m M-6 ' .......... CCR 000019167 M-7 CCR 000019168 M-8 S'/'/o DATE HOUR \ `L-I ' <J, TO------ CL/X'--- WHILE YOU WERE OUT !, J.1 j*/J i / y. -i ' "a -c /^ OF. PHONE. (S AREA CODE PHONE NUMHER TELEPHONED RETURNED CALL LEFT PACKAGE PLEASE CALL WAS IN PLEASE SEE ME WILL CALL AGAIN . WILL RETURN IMPORTANT MESSAGE .-x FdlfCjT // ytfo.. frr/t i HHWH l ^ l. _ > **11* 1--1 1 f/Af7? ' >/ Cf : -L i' ~) s.. /vr, WiTrF'* i---------------------- ]oco) SIGNED . Order No. 00301 Irom Stationers Inc. 627-1500 'V o S'o' C{ ) . 0. - Tc> o / <T V-- -*->'-- J Aw. *r- *7 7) ~/Y\ - *. o->--*--? o^" -p \ <5^0---------- - o_A/ ^O1-- -----------'-----------*u ~T^KJOA*v^'oJv\^ J , I J> ^ Q.O-U ( O-Xr' '"tLiv. --- ^ ^^o^^JUxjL^-\-rs-> <J\ "riXiUaJ, C VV\v Tlr-rw' -Vkts .S Cj)-S-0-At-*V*o (2> 7\ CCR 000019170 * M-10 # r" r ' "n / \ *r '* lsy_..Wo.'.^.vj //9 0 \Xi, CO-^-L.s^'TT.^.___l'., , c~) '` ' -V^~ ^ ^-o-v-x-.' iL^J^sJUk t <N _-<? Ar'O. V^W ^. A ' yC- AJ jXdL ' IW -inJO_,____/~ - . o __ U^i-^ gy^' i do ' ' (v^v .r~r \^o 5 r -oXU;__c^_J ju^JuAJk. JL^_ - ^__________________ Xr!^ -**- ^XsCvJO^--)I ^>V--><i- J g-N^ ^ /\ - -l-' ^ X <^X-A. liT~" o ,. . I I -*y'-^-'^`<^-Z I\ t 'b- ^~Cr -iL^Si O '--i~.v~r,-^'J (-,~N~0>-^ a--Mv.y^ Cw I vQ H `^A .-j I: cAr " 1-^ -~X'^yvjsC> vA _ h\ _ MtSv'1'. g... 'Os^ A- v|- *S\ ^jwV. " " V -o V ^.<XL`____V/mL^vaaoAw v/ Cvv.\_^ 7 ^ ir *> / n "W \ '%Cjm_____ VMj-.'--1 /'^vaJ "" JUy, ^ 9 . _VNs-v-'v^v l- TMD'... '" ________ \> <`~^*' ^~3nX \ , * r,....................................*"' A-v \^~~C.'*~>--^v>vO~J^L. - rrrrr (W -n^r*' g*yy7^ft*^g*yirnp< "! 1.nW'<UgBA*?. ffTwiwu\4'/' ^`"AT******* '. V.::V\y ,v, .;. '" , , /.'!.' f/J-. ; -* " * .`. . a . ** . " '.`\} '? - *V ' ,.!,,, * , '( rt, > < j A M-ll CCR 000019172 ---------- di JL 7RIAL SIZE y/sicht C^)r<?C. A 3C* oTc 7 J rp FROM /0 ~C^ - 3- oJ^ju J. I* Hailey - Corpus Christi, Texas. RAKGK Q^A.A.jtsl3 v QjlyuaAAA/'vcJ ^OiLW^X/ Estimated Weigh17*^ C f Turner Brothers - Edmund, Oklahoma Distance: ' B.* F. Walker Inc., - Casper, Wyoming Rate B. F. Walker Inc., - Odessa, Texas Lufkin Industries - Lufkin, Texas Send Prepaid/Collect __ American Kfgr,, Co., - Fort Y/orth, Texas 'it'vjr->t a vtno: vY'R: Jr.SSS: . ; A *7 . L 'TOLL: Latt;-: : Continental Oil Company T i C M O/ULKv\. 7H~71 .o\ XaZLc . "jJk~ b^A( mqj t , COMTIiiEMTAL OIL COMPACT VQq m. PQ*<XvJr q^Ll-1 ; lii TERMSDIAT3 COESIG35E i ;* .- caoi_g_/_r____<US'\'\J\KQ-^-oOsj t/(V-/ t>. -3Xa j L' *Vr,^' JTL JL-r**..<" w^ JT\ [^ Q cuo ^3.p\ O^V^JO ^^.yLr^J7 va*rL;.>< .* L*- 7 \ tv . rH. * TRAhvJFSR , M-12 CCR 000019173 -- PURCHASE ORDER HO. . J /) /'JL r/,/ S f '/3^> ______ ___ jLm-4?^.. _.. ____ ... ii i / /l / ......../...- /? s\ . r / C'-'/f 'r''___________ ^ " ........ ">?" `&luj. \ [--' ' v-J. --------------------- J I \AAt' 39Jff~s-/*PAXJ2Jj&M./6a#, r ?jr-^A if f / // jsdvr) ^ | y->s . i'V3i r l.-, f.._... | -- - - ts----- *v : tJs.rL-J'.l/L--.. ^i^O -... . ._... ! >_ o&l / j________ Ca-3&lA''kf/d...... .-x?........ ........ _._........._________________________ i Vd in ^_.A~ . .j.................. 111 y?.iC^S-vflt / t *y ^/ * 7/ ti&p yyyU ( ,7,. / _J,,- / -/ 5 :'.. iXjiiL. x` 4w> 'TsAc.slO-* Cls , :.,. .tf. -i-ii ..:v.'lr? vA/73'. .. Soy j i Z-& (j / / / / y>7 / /flc- v /fcly ff^r: Afyy/y/C'!*1C~- j yyS/72 J/>h c/ utcb//\/yAtr.u_, I ,.': -J> ~f..~*/ ! ' vV' < C';. /~ /'.* ! ; `rf h'(X '.'-' ` C c--i < 'y. , , ; -- v^-/ ,_> ^;.-y "- \ r?'^0 sZs* y'A. !7 J / (} * ^ fc Sf&v, .4- &-6/4:c f.?.$<>, Qc-. /# v./^..,v ^ - * . . . ......... ... CCR 00om74 vit ' X- A^wX\a. l\\;v dLv.) ^v. n -i*i gLi^Sa ^1-O-v^ O-N-iJ^AJi'S__ _ -.----- 4 ,,\ VWl-^tN iNli1# M-X3 r r r> | f * l* L 0 0 APPENDIX N RECEIPT FOR THE DELIVERY OF FIRE BRICK CCR 00001917s GE1T: ALLEU CriitTni mtih1m- r vxiisim. cnAimin suivier AIRCRAPIHUNTAL r REMIT ANl) DIRECT INGUIMIUS TO: P.O.nOX 7\7 SULPHUR, LOUISIANA 70U53 l.or.iitrfi ji (31 III G2!i-3CiI3 Uoeoifrt .'i cQuincy ln<l>i-.(ti.il Air I'ark r. no. :* '/1 , i** date / ?. j?/1, 19 /. i cu:k>mtr (* '/.' 7 // ,0/A /JV. JjlJLJ&AL Ap 9 r $010 nv fyj-tr/.J.r*', /-.J. 7/?/> 9 CA$H COO. CMAfct.il y <>U ACCT M0$t.rcU>. FAWCUt * * * cm tin ion PftK.1 AMOUNT T /rj_ Ni U i in ___ ! ;r^ .././? ;r* M"rsr)/ -- -- i. L __ 5 <> " T~ T ) 9 c, -72 s* L L * r**r *l Tax TOTAl JS 7.c V . ..p !>01 a*--' *t ,t.. ' j* ' va.liwJ1.: lw iJrMKfc L r\ . ,*; I*IATP f 'MOOIM PQllMIJNi:,. < N CCR 000019176 (d E N-2 ( I I | I If I- l: II * APPENDIX 0 VCM EMISSIONS MEETING - ALTERNATE CONTROL MEASURES i ' s L; I. L i CCR OOOOW^ G ii <t'-'-, i /-** -I ' !/../// a-'> /,' .>. - s /. si* ...t I i'l.t'T- i r. # . c 4 / > <: y ^oly^ynj AcJ-^,i^:d____Citify* A-i<y y-Jry^----------------------------------------- '...........--....- -------------------- r: r- ......... 'k--)/:V,' - et'f* ,, .. /J-xJ/C^veS '/J,'sri . 'X&' jic. \ <r^7 "v Avi /'VvJ ....s/'i.'-fer'C .. ^T.cu -A SO'Y'Ys , i- / ^ss-J-A'.' c /S f . cZ&sjj/dc/ jI`(? UCAs} . - Vvf <~Cc:-urj* * //!<: ;T// /-/' . <?/' Cycissy you., czl^rj. S/ '/> -*CJj/I VA.y i . C-} J J* C I C'Uq C_/.-------- . i'/c/r) /])x-y' /lt'/J I/O si '..... v<;?// j.v'/aiX.te<///) . oUi. C. os-ji/s .<A#/ <{so S1 . .. ... ^o/yuc //ua'/Ytfft Ssjoy J't-: / f'i.i) !/ ,'-V ;WU ../)/' -r/ . c.' <J e.........^.... ....... * s/rjj-^/^Ly .. u, /*$ 0 . J.'V c.<; h . ,. i 'ATf vwi* ''''// , ;' 'i /t'/7.*:v V' i i .c^"*' -1' J/cl* * ,V\.i V^ . << f' t '* _. , V////.../V / ."..vo .*.*.'vi.JtJ. t*y`7f/'/ ///} U`]/i'!Z,j*\Vy'y" // /Ascoy. _. ,V/// .../Vy^ .... <x/:a.' t-c. Cs' 1 \Jc/vn -'W '/////'/'cJ\*rsi .. /*."?.`''/ir/,, /Cci i'*"' *,y s /,: y-r, . vr-- ' * /) /' ' / (I.. LSJcJ, I," r' .-- ,n \ /s-:<s . % p./..V * * *. * // . c;y.<:- /cV '*V.?//ir J/'0L\J . / L /?> sC'u.' y'cJ / ...../i. >/: / . ^ v/ # /kt f , / * 1. " *-'* ^ 4, . * it * . t ' ' '> r1 ' '* <* / ^ .' V' / 'V * 4t /* . J. r s.// A^ ./*<' # ' . oooom79 CCR A/* ".: V/'.- -V> / , '' .i*^/ / -f /_T ^, / > '' X< /.. .;. /.v.'vn Jl.'r > t- k- .> / , / 4* v * # ' ^*'',*1'^/#* * /./: / 0-3 1 //; - r ** '1 _ . . . .... I /, -r'/o)' j /}n ///Va" Vc.ri / J /< U~~ ,* ."* -V. -'. -;. Vff',...-, / rt, f -/ ^7 //, 'J /.V" iACa i * .*-*'-7***/* if ' * ' Jt.'VJ' / ;A,; J w/,-. /' t .-A *m/v' ( \V / />,*//7/JV.V /] f ' V . '/// fcv`V rt:*V`/*// /iS.r ^t/, i. M (/ r<n i l.t'5 C<5 ' .*'/// t'Vc/Vi' ,h />["a `s"V-ivc / *.f* / C'O { / JJ A" J: t ck . /St 7 oJ:rt V |fM ;f / c?00"' / 6/ /JU 7^. <^/M -- &//?. L Cc* 0ooi9iao 0-4 E I cth a;a... *.*0 2-- I 'J ! ( > i1 i . c7/; C. .0-? . .... - /Jv- 0 - . y/c-i Z? "1 <V , 1 / W* //*--7';^ / (`(J# t/ .. J . f <1 luF ' AAv .. . tA C; . C- ..//cl//0 . *'PC~....Zcvvy^d, * $U &?/) cJt? CC/v.ypje. - Vo - />*!J d*t - dc Lcu > y 'JJ C ..... V ... /\C /___ t/l. . .ffreJ&s/te -.........................................................-...............--........................................................ __ //s * S^C/.. -r? ?/^iv'V V/// 'fUrfAc // /.......... ................................................................................................................. jw* jSthLJk<jL..............-- -- -......-...................................................... -............. - ... -------------------------------- q/s/SitS-&c A ... A?e?5..___<-^.(0......*3Xy i-yssZfjjfaAyJ/J.~. y-y dccjj (t'/js&J? . /i'.J'iy. . y,r,, y /J /d- /' f // y-j / . /J ..-CJ'c <-//<*;, /.. Jar- JJ'J-J"/ , ./5 rcv^-sy k'Cry_____ //y7.^v*-<j .. y >-<t ^ / Jd:j_A J 'Vt / t ''//iA i % U *|l /"''.J ,A ** ' '/ ,<r 0-5 /Vl` / J JJ C. Y'J'y <? f f'-r J ^ T~~ 'f //A { . /'W /jr 0000X9181 CCR .V'i!v ' f -A> */o ^-'71//^^ / .r J/Cfv? *i I <057- C5//Q a , ^cf y7AC*'i //* (-/ A<-r:ot.f'fy 7) ' vA -- c av J/o a ';'</ P<'{'ui-<*v v l~- | r / I# /?-V P M v*. .>/ y-rJJjJj/c 17//'y/ ./itVvv.j <? ^ -l!/7r.~/-?7V/./7 c-f 7- <Lu/ //^C* '/'<? C rsj^ /l':C C. u/Jsy wt// /,W,f W/'/Jy l&WJ'J- *+k <'. Jyj/ V/Ay/ -, ;G/' fv t'Ce' a .*&$}/'$)$'? j . ^vCV\y^% '^ciu/e>cJir J*reJ ,, r\7 5A*uJ 5>bv;.<'/>} ^ " '<y7/ 0 <1 /7- t3{^r' - 7/ p*" 7 /'/ o . ,ry. '/*'-//1'A /r/.-- ; V/ / V. . / <?/ /-<:~ s? s\ LiA / // 5' j-:, Ac A- fS/ ,} / `J/ , r-x.-v/ f' V efCiJjs /\ 0 J'/S) -- /<:' crX Jr<jc cJJ o. 7/* . /\ 7 ' , 7Vv/y t ,t) .0/kJuC- i . ,-v^J SJsy '7/a } 7* X^-v? /< f ..ysA , "-V{ ''.''trr.-L' rr >/soj^ 7 ''77r -7,,// 'c'^s >rf* CCR 000019182 0-6 I f l APPENDIX P I CORRESPONDENCE WITH INCINERATOR MANUFACTURERS \m L L CCR 000019183 C 1'roenM Empimming IJcpnt tnirnt Conlimmlul Oil Company P.0 Ho* 1V"W I'ofii'i' <-il\ /AGO I |A00) Mr. Jim Newburn John 7,ink Company 4 4 0.1. South Peoria Tulsa, Oklahoma 74105 Dear Jim: As we discussed on the telephone, we are involved in the process design of an incineration unit to control the emission from a vinyl, chloride plant and would like to discuss several process and materials questions with you. You have already given me preliminary recommendations on several of our questions, but I have included a complete listing so that you might review t^hese points based on a more complete definition of the feed. Table 1 shows the incinerator feed balances we have calculated for various operating conditions. Our design questions are as follows: 1. What combustion temperature is required to reduce the vinyl chloride concentration to less than 10 ppm? 2. What residence time is required at the above temperature? 3. How much excess air should be present in the combustion chamber? .1 4. Is supplemental fuel required to achieve your recommended operating temperature; if so how much? (Supplemental fuels available are liquids.) 5. What concentration of gases? will be present in the combustion We would also like some information on your burner selection for this application and your recommended mode of operation. In particular: 1. What is the design duty of the recommended burner? 2. what is the minimum firing level which should be maintained (what are the turn down capabilities of the burner)? / P-2 CCR 000019184 III. lit lit Hi'Wllli r M I'.igP 7 March !">, llT/fi 3. What: arc the* materials of construe Lion in the burner ami the combustion chamber? 4. Is it necessary- to control the combustion temperature at some upper level? If so, what medium should be used -- excess air, steam, or other? 5. Would air preheating normally be included in your design? If supplemental fuel must be continuously added to the burner, or added during low vent, conditions, several alternate sources are available. One of the sources would be a liquid by-product from the vinyl chloride plant. The composition of this mate rial is given in Table 2. Vie would also like your, opinion as to the suitability of this material as a supplemental fuel; either by itself or in combination with non-chlorinated fuels. Our final area of concern involves the quenching of the combus- tion gases before HCl scrubbing. We have elected not to include any heat recovery. We also decided to not recover an HCl product Thus, direct water quench would be used to lower the combustion gas temperature to a level suitable for entry into a. dilute acid absorption column. Our questions on this area of the process are 1. Is there a particular quench chamber design which you would recommend`for use with your combustion chamber? 2. Should the quench chamber separate from the combus tion chamber, or included in the same unit? 3. What is the rough size and configuration of the unit you would recommend for this service? 4. What materials of construction would you. recommend for the chamber and sprays? We look forward to hearing your comments and recommendations on these questions. Thank you very much for including this in your schedule. , Sincerely yours, James 0. Gibson rrocess,Png j neor Design Division Process Engineering Department CCR 000019185 P-3 Cnnliiiciitnl Oil Comp/iny l` O l'"< Wt;7 l'(tr.n City. Ok'.ilwitiii 7^tiO 1 HOI.) '/<>2 .'J'Vifi March 5, 19 7 6 Mr. Charles K. McCracken Trane Thermal Company Mrook Road Conshohocken, Pennsylvania 19420 . near Mr. McCracken: ,. * A"' we discussed on the telephone, we are involved in the process design of an incineration unit to control the emissions from vinyl chloride plant and would like to discuss several process ''.id materials questions with you. You have already given me preliminary recommendations on several of our questions, but r have included a complete listing so that you might review 'hose points based on a more complete definition of the feed, '"'hie 1 shows the incinerator feed balances we have calculated lf>r various operating conditions. OUr design questions are as follows: 1 . what combustion temperature is required to reduce the vinyl chloride concentration to less than 10 ppm? . "huh residence time is required at the above temperature? ;::jw much excess air should be present in the combustion chamber? ' in supplemental fuel required to achieve your recommended operating temperature; if so how much? (Supplemental fuels available arc liquids.) Wlml: concentration of Cl gases? will be present in' the combustion What is Liu: design duty of the recommended burner? P-4 toc:g 2- CCR 000019186 11 .1 l it* u'wvt Page 2 March !i, 1SJ 7f> 3.- What are the untoria.ls of construction in the burner and the combustion chamber? 4. Is .it necessary- to control the combustion temperature at some upper level? If so, what medium should be used -- excess air, steam, or other? 5. Would air preheating normally be included in your design? If supplemental fuel must bo continuously added to the burner, or added during .low vent conditions, several alternate sources arc available* One of the sources would be a liquid by-product from the vinyl chloride plant. The composition of this mate rial is given in Table 2. We would also like your opinion as to the suitability of this material as a supplemental fuel; either by itself or in combination with non-chlorinated fuels. Our final area of concern involves the quenching of the combus tion gases before MCI scrubbing. We have elected not to include any heat recovery. We also decided to not recover an HCl product Thus, direct water quench would be used to lower the combustion ' gas temperature to a level suitable for entry into a dilute acid absorption column. Our questions on this area of the process are 1. Is there a particular quench chamber design which you would recommend for use with your combustion chamber? .* 2. Should the quench chamber be separate from the combus tion chamber, or included in the same unit? 11 3. What is the rough sise and configuration of the unit you would recommend for this service? 4. What materials of construction would you recommend for the chamber and sprays? We look forward to hearing your comments and recommendations on these questions. _ Thank you very much for including this in your schedule. . Sincerely yours, Janies 0. Gibson Process Engineer Design Division Process Engineering Department mdn Encs P-5 CCR 000019187 TABLE 1 VENT GAS HALANCES r i Component . Minimum Continuous Operation MoIs/Hr Typical Operation Mols/IIr r C2I14C12 C2U3C1 0.31 2.21 0.44 3.16 i C2,!5Cl CHC13 5.92 0.13 8.46 0.18 - CC14 0.03 0.05 CII4 7.46 10.66 C2n4 11.79 16.84 C2H6 0.69 0.98 Il2 0.79 1.13 2 5.18 7.40 n2 39.89 56.98 CO 0.78 1.12 C2 7.52 10.74 HC1 2.90 4.15 Total 85.60 122.29 Design Maximum Mols/Hr 4.04 11.80 41.78 4.93 2.47 9.55 19.26 1.07 0.79 5.32 103.12 0.94 7.80 2.90 215.77 Temperature, F 40 40 60 Pressure ----- Essentially Atmospheric l I CCR 0019188 P-6 * < 'i*t TABLE 2 BY-PKODUCT LIQUID COMPOSITION Component C2lI4C12 c2h3ci C-2,H5rC.l chci3 CC14 CH. C2H4 C2"6 MQl % 9.88 8.48 58.70 14.27 5.68 0.23 2.58 0.18 100.00 CCR 000019189 P-7 APPENDIX Q PROPOSAL INVITATION OF ENGINEERING CONTRACT - INCINERATOR PROJECT CCR 000019190 V:-,1 of b PROPOSAL INVITATION vi:nr ('as incini-ratok VCM PLANT ,AKK nAKU:P. 1,0V I SI ANA ffK i - : i.No; to mnnr.RS ............ 'i I Company (COMPANY) is seeking proposals from qn.i 1 i -- ' t.lu' ricehnnic.n 1 dosi}-;n and icri.nl procurement of vent pas incinerator facilities for the VCM .. ;, Louisiana . i >: defined in Section TI. below. Tin; project work to Mows: CONTKACTOK will provide met linnic.il design i on,, nt services for the facility (oneIud ini; the I1 -r.it ini' drawings, specifications, and ether data : .nid detail to allow COMPANT to solicit competitive r field construction. II prepare a cost reimbursable contract proposal It include sufficient information to allow the COMPANY evaluation and, as a mini mum, shall include the r the CONTRACTOR'S reimbursable costs anti overlay. The ill provide a "check list" of reimbursable and nonch.irgcs and show what is chargeable as: r. imbursabl e at cost. * ' 1 : i < inbursable at cost plus overlay. i>- - n: i~!mrsnh 1 c items which are covered by overlay. > i",:.ilies a single overlay percentac*: applied to base 1 " 'I'ich cover;! all overheads, hut dons, and profit. s. i in; ..s by job classification such as dr.iitsn.in, engineer, "ct * ii, u-.er, etc. C* ',u ' 1 * *1 ',f I OR 5 reply to this .inquiry .hould: fJ) lnd ie.it e agreement with Section 111, TYPI CONTRACT and "`-',W\*y v TM Q-2 CCR 000019192 1)11-029-003 2 of 6 STANDARD CONTRACT DOCUMENTS. Included In Hi is Invitation, or state any exceptions so that any coiuraettir.il differences may be resolved prior to screening of CONTRACTORS. (2) A statement that lie is willing to sign a Secrecy Agreement. See EXHIBIT I (to be furnished later), d. Ter diem rate for field trip (food and lodging). e. Description of the organization which will bo used on this work with resumes of key people who will be assigned. The CONTRACTOR shall also state how the work will be carried out. Including the following activities: (1.) Planning and scheduling. (2) Project engineering. (3) Other home office activities and procedures. f. Background information and experience in design of similar facili ties. g. Description of the CONTRACTOR'S present workload (manpower curve) and indication of presently anticipated future workload, sufficient to illustrate to tho COMPANY that the CONTRACTOR has adequate man power for the project. 5. At any time by written notice, COMPANY shall have the right to termi nate CONTRACTOR'S work on the project. In. the event of contract termination, COMPANY shall have the right to unrestricted use, for any purpose it shall deem necessary, of any and all design documents furnished to it by the CONTRACTOR. COMPANY' shall remit charges for work performed. 6. Written proposals to perform the work shall be received in COMPANY'S Ponca City office no later than 4 p.m. on November 19, 1976. Three copies of the CONTRACTOR'S proposal shall be mailed to the following: W. E. Taber Coniinental Oil Company P. 0. Box 1267 Ponca City, Oklahoma 74601 7. The proposals arc to remain firm for a period of 30 days. 8. The .successful bidder will be furnished a Basis of Contract to govern his work on this project. The Basis of Contract will Include special Q-3 OOOOX^92 OCR DU-029-003 3 of 6 job conditions, applicable COMPANY engineering and design specifica tions. 9. Design shall be in accordance with relevant portions of any federal, Louisiana, or local laws, regulations, ordinances, or codes applicable at the job site. SECTION II - SCOPE OF WORK 1 GENERAL On December 24, 1975, the Environmental Protectioa Agency added vinyl chloride, to the list of hazardous air pollutants and proposed a standard for VCM emissions. Following a public comment period, a final standard was issued on October 21, 1976 (Federal Register, Vol. 41, No. 205, Pages 46560-46573). The purpose of the standard is to minimize vinyl chloride . emissions from all known process and fugitive emission sources in ethylene dichloride-vinyl chloride planes. The VCM control technology Conoco has selected is incineration. All process and fugitive vents, with the exception of the oxychlorination reaction vent, will be piped to a new incineration unit. By-product liquids will also frequently be burned for disposal or as a supplemental fuel. The combustion gases will be cooled in a waste heat boiler, and . then scrubbed with water and caustic. Most of the HC1 produced in the combustion process will be removed in the water scrubber, while the remainder of the HC1 and Cl^ will be removed by caustic scrubbing. The scope of the VCM incineration project is as follows: 2. VENT COLLECTION SYSTEM A project is currently in progress to collect all process vents into two vent headers. Dry vents will be collected in carbon steel headers, while furan piping will be utilized for the wet, HC1 containing vents. These headers will be extended to the new incineration- area, and a knockout pot added to the wet vent header. In addition, the vents from tankage in chlorinated hydrocarbon service and product loading will have to be piped to the incinerator feed system. Furan piping and a small blower will be required for the tankage vents. Product loading vents can bo carried in carbon steel piping and will not require any additional pressure. 3. _ INCINERATOR BATTERY LIMITS The main incineration system train will consist of the'Incinerator, a waste beat boiler with top-mounted steam drum, water scruhber, and caustic scrubber. The inclneratoi--waste heat boiler will be purchased from a single vendor hy COMPANY. Inconel.lubes and tube sheet will be . CCR 000019193 Q-4 DI1-029-0OJ 4 of 0 used in' the fire-tube boiler to minimize HC1 corrosion. A boiler feed winter system will bo installed in the incineration area to collect, treat, and pump condensate to the waste heat boiler. Steam will be returned to the main plant steam system, with tie-ins provided for a future HC1 recovery system. An inconel transition piece with expansion joint will carry hot gases from the waste heat boiler to the HC1 scrubber. The scrubber will be a multi-bed parked column (8 feet - 0 inches x 56 feet) constructed of Haveg 41. Two acid circulation and cooling systems with graphite pumps and exchangers will be required. Piping will be teflon and polypropelene lined steel. Expansion joints will be required at all process connec tions to the Haveg column. The scrubbed acid will be piped to a day tank, with future connections provided for an HC1 recovery system. The caustic scrubber will be a carbon steel-packed column (6 feet 0 inches x 28 feet) with a pump-around system. Caustic make-up to the .scrubber will be a slip-stream from the main plant caustic system. ; The caustic will be partially spent and returned to the main plant system. Vent gases from the caustic scrubber will be discharged to the atmosphere through a 75-foot tall 3 foot 0 inch-vent stack made of FRP. In addition to the major systems outlined above, a by-product liquid charge tank and pumps are also required. There will be two 10,000 SCFM combustion air blowers.. One will be driven by a steam turbine. A steam blowdown drum is also to be installed. The incineration system design should also allow for two future projects. The HC1 recovery project has already been mentioned. In addition, a second incinerator may be required in the future. Equipment and piping lay-out should allow' for symmetrical vapor flow and common sparing of non-critical items. 4. OFFSITES A new 11,000 GPM cooling cell and pump will be required to supply the incineration system. All other utilities systems will have to be expanded to the incineration area. A steam transfer line is also pre sently under consideration. This line would transfer the excess steam generated in the w^istc heat boiler to users in the adjacent chemical complex. Several thousand feet of piping would' be required for the complete transfer system, 5. CONTRACTOR shall furnish project management, and material procurement and such other home office services required to design the facilities in accordance with COMPANY'S design basis. 6. The COMPANY will furnish the following: 6.1 Specification and procurement of incinerator. 6.2 Soils Investigation Report 00001*19* OCR Q-5 D1I-029-00J 5 of (> 6.3 Topopraphie maps of area. 6.4 Process Design 6.5 Basis of Mechanical Design 6.6 Permits required to be in COMPANY'S name. 6.7 A COMPANY representative. 7. The approximate cost of this project is $5 million. Q-6 0000191^5 CCR M-029-Q03 6 of 6 | SECTION III - STANDARD CONTRACT DOCUMENTS [ TABLE Of CONTENTS - CEXKKAL CONTRACT DPClMENTS Letter Contract Certificate of Insurance Secrecy Agreement Typical attached Form 6-11-S Revised 8-1-67 Will be provided later * OCR 000019X96 0-7 r* L Typ lea] better Contract Gentlemen: Subject: Engineering Services Ye nr Proposal No.Dated This letter includes certain of our standard conditions and it, along with your Proposal No. dated, including Exhibits __ , ___, & ___, constitutes the contract for this project. |(Contractor), will, as an independent Contrac tor, furnish engineering, procurement, and drafting manpower and other services as requested and required by Continental Oil Company (Company) to design and prepare drawings and specifications and to purchase materials as instructed by Company for the _______________ ______________________________________ . Company will provide Contractor overall general instructions but Contractor shall have the sole right to determine the manner and means in which such general instructions are to be implemented on a day-to-day basis. Con tractor will provide construction drawings and specifications in a good workmanlike manner. The construction is not a part of this contract and Company is under no obligation to award the construction work to Contractor. OnLy full time regular Contractor employees will be assigned to this pro ject unless written approval is obtained from Company. The work is to be performed on the following basis: 1. Payroll Rates The Proposal shall govern charges hereunder. Rilling will be based on actual payroll within the salary ranges set forth in Exhibit ____ of the Proposal. 2. Items Covered in Overhead The overhead rate of ____% sot forth in the Proposal will be applied to direct salaries as stated Jn the Proposal, This charge is to cover all home office overhead and profit as typically specified In Exhibit All other charges will he at Contractor'.*: actual cost as covered in the Proposal. If this project requires other than Contractor's full time regular employees, such employees will be billed to Company at Contractor's actual Invoiced cost. Q-8 ecu 000019197 Page Z (l)aU') 3. Insurance Insurance to cover Workman's Component ion and Occupnt icon] Diseases and Ocncral Public Liability with bodilv injury limits of not loss than S300,300 for one accident ami a proportv damage limit of not loss than $100,000. All Insurance policies required to bo provided by Contractor under the terms of this contract shall be written on policy forms and by insurance companies approved hv the Company. Contractor agrees to furnish Company at Post Office Box 126", Ponca City, Oklahoma, 74601, certificates of insurance on forms approved by Company 11sting all such policies. Such certificates must provide for not less than ten days prior written notice to Company in the event of cancellation or material change affecting Company's interest. Contractor shall therefore furnish Company certificates as outlined above for insurance coverages. 4. `Premium Time Premium time is established in the Proposal. Company approval shall be obtained before any premium overtime work is authorized. 5. Method of Pavnent a Advance Fund Material During, the life of this agreement, the Company shall advance funds that will permit the Contractor meeting substantially all Its costs in connection with the job. Funds are to be advanced based on the Contractor's estimate of costs for the ensuing month for material. Early in the project, the Contractor shall prepare a schedule showing the monthly estimated rate of expenditures covered by the Advance Fund over the life of the job. Thu Contractor shall submit four copies of the request for advance, in the form of an invoice, prior to the last day of the month. The Company shall have ten days in which to check the request, approve,- and pay. The Contractor shall present Progress Invoices monthly, and upon approval by the Company, the amount of each Progress Invoice will be credited against die Advance Fond. b. Invoices for Engineertng Invoices .shall he submitted monthly for salaries and supported with a list by name of the individual:; who have worked on the project, their classification, payroll costs and the number of CCR 000019198 Q-9 Pape 3 (Date) hours worked. The applicable overhead percentages will be shown separately in arriving at the total invoiced cost. Upon approval, the Company will pay percent of each invoice. Invoices are to be addressed to the attention of . 6. Guarantees Guarantees for specific items of equipment competitively purchased from vendors on the basis of an individual specification, including but not limited to pumps, compressors, heaters, exchangers, and similar items. Contractor agrees to use its best efforts to obtain supplier's guarantee of both mechanical condition and operating per formance for a period of twelve months from the date of initial operation or eighteen months from date of shipment and pass on such guarantee to Company. In cases where suppliers refuse to extend their guarantee to Company for this period, Contractor agrees to notify Company prior to purchasing. 7. Travel and Living Expenses Travel and living expenses will he in accordance with the Proposal. Commercial air travel will be economy class. 8. All Contractor expenditures and charges are subject to audit and approval by Company, and Company shall have full and free access to the Contractor's records regarding this work. 9. The Contractor shall indemnify and hold Company harmless and shall defend Company at the Contractor's expense from any and all claims, causes or action for damage or loss to property and persons, including Contractor's employees, arising out of the work to be performed under this contract. 10. The Contractor shall not permit his employees, vendors, visitors, labor representatives, deliverymen, salesmen, agents or subcontractors to enter any area of the Company's plant other than the work areas designated from time to time by the Company for the purpose of this contract. The Contractor shall (notwithstanding the provisions of Item 9 above) indemnify and hold the Company harmless as to any claim, cause of action, liability, obligation or expense whatsoever which may result from any injury to or death of persons or loss of or damage to property arising out of or as a result of any breach of this para graph except to the extent that such injury, death, loss or damage be the result of any gross negligence or willful act by the Company or any of its employees. 11. except as Company shall deprive Contractor of freedom of choice or Company shall independently eject , 'Contractor agrees hereby to Indemnify and save Company harmless from all claims for all alleged patent 1 nfrinr.ement asset ted against Company and growing out of the performance of work by Contractor voider this contract, and as may arise from the 0-10 CCR 000019199 Page 4 (Date) operation by Company of the facilities ns designed under this contract, and Contractor shall defend, at Contractor's sole expense, any suit involving Company alleging patent Infringement hy reason of the fore going causations or any thereof and shall hold Company harmless from any judgement entered in any such action. 12. Contractor shall comply with all federal, state and local laws, ordin ances, rules and regulations affecting the work to be performed here under. 13. Contractor shall use care in the use of Company premises and observe local and plant safety rules. 14. The originals of ail drawings, calculations, etc., used or developed hereunder are the sole property of Company and may be used for any purpose Company chooses. The Contractor shall give these items to Company upon termination of this contract. 15.. Company shall have the right to terminate this contract at any time by notifying Contractor and making payment to Contractor for all costs incurred to the date of termination. 16. To complete the contract documents, the following are enclosed: 1. Certificate of Insurance, Form 6-11-S, three copies. Please have your insurance carrier complete this form certifying that your insurance coverage is as required by this contract. Return two executed copies to me. 2. Appendix L, Certification of Nonsegregated Facilities, two copies. Please return one executed copy to me. 3. Appendix M, F.qual Employment Opportunity. This for your infor mation and file. If the above meets with your approval, please so indicate and return two (2) signed copies of this contract for our files. Yours very truly, Accepted this __ _ day of, 1976. By: Attest: 0-11 00001920 OCR * APPENDIX R PROPOSAL EVALUATION - INCINERATOR PROJECT CC* O000I92Q1 /V ,f.v. \ ` \fc,i i V} T . v 0 ") / J > :V) l w "<1 </ \ x a( :) i : '* j.V.V K- IQ! 7\ J1 ; r * :\ I ,25 I !-* i > f- / 7 7 ` I S/Sif w~ /-,, / . // - .'70 /oo fZl ,, l !Si*' I 7C | *^> f /Si .*/;;. <?* f'''V* v x, %*> i` 1o o * */ ^ * *j / i^ O-' I , r#r I if ^ ; 3^ z 5? I @>'-A/V< tr < - ', /i../, /r. i >0 S& /t -7- J7 4< / // #7-`' ,/ [ (pli /tZ'' J), rcopSENTIAL-:'D 1 / 5", i" i i /^* / d? j / /^* / "T2-Z. /- /o /. ^ '' <J*s1*>1 1 / -T J7 1 \ .-'Xll.6x i I1 / TT" . ii\I # /!C to ! /< 7 & 'z 7 ,^ 7 = $ 7' : >-r. M . !/J ; IS- ;'* , , /t* /2F ys ^ . 1 \ z>aS> . (! * . iT ; 1- ' ^t- <- -s"-* ! wjj/<'//*- -- 1 ,-p .' " AO /e>P II ! 70 ; // ! i i / "2. /-2. i< }i ( *1 i^t ' * ss> i / ',; o / o>> /i ////.(.!,, : JSO zoo '-' zso SC !0 ! 7 >" ' is t 1 , ! zo :ii /^ i i 90 : /SO '. I (io t 72 V4 ^'":; 1 70 1 ;. - 7'd> i r > * Srt * '. v ,-- f*. f/?*y* *' *'"* *' ** i ./ .* /v/ / <:* 1 I | #' * -1 !^V? T *..,.< f. / ^ ;..*'* I ' ^ f U j V. - . ,. .. ..* lr- 1--** I , .ci;-*: y i f*-\ j' | j / /: tr'/ i * *. ' * ti CCR 000019202 i APPENDIX S ENGINEERING CONTRACT - INCINERATOR PROJECT CCR 0000X9203 J H llumblolon, Jr. rMf|<nn*fiM'j Uci*jiMnu*ni s A - - - w* * ContirtpnffH OH Cowpimy 9* U Hot 1 *'* ' O* t\tu i*is M**01 <40!l 7(j? 3-UH. r April IS, 1977 r The Litvin Corporation P. 0. Pox 1281 r Houston, Texas 77001 Attention Mr. F. J. Trotter i Gentlemen: Subject: Engineering Services, YCM Incinerator Project i Continental Oil Company, Lake Chariok__VCM_j' 1 an_t This jetter constitutes the contract for the above project, ami cancels n and supercedes the letter of intent dated December 21. 1,976. 1. It is hereby agreed between CONTINENTAL OTL CPMFANT, a Pol aware Corporation (herein called "Company"), and the LITVIN CORPORATION of Houston, Texas (herein called "Contractor"), that Contractor will, as an independent contractor, furnish engineering, design, material procurement, expediting, and inspection services for a VCM Plant Incinerator - Waste Heat Boiler System for Company's VCM Plant, Lake Charles, Louisiana, as defined in EXHIBIT C, Scope of Work. 2. TERM Said work is to be commenced not later than .January j, 1977. and Contractor shall use its best efforts to complete the work not later . than August 15, 1977. 3.. epKN^SArrn'; 3.1 Contractor will be compensated on the following basis: 3.1.1 Contractor will be reimbursed for all reimbursable items as defined by EXHIBIT A. Charges for wages and salaries will be in the ranees defined by EXHIBIT B. The rate ranges in EXHIBIT 11 nay, however, he rhanged at any time provided the Cnmnanv is riven a new schedule of rate ranges a minimum of two weeks prinr to the effective date of the new s.t.edule. Charges for use of Contractor's in-house facilities will be is folios: a. Data Link Usage - $1 per connected minute plus $6 per nasbour for keypunch operators. Cc 000019204 S-2 C r APPENDIX T LIST OF CONOCO PERSONNEL ASSIGNED TO I INCINERATOR PROJECT t CCR 0000i92 CoaJCCO iri li-TlOAi Kl fy c rs A4 'Ttj \ZcV4 l/fr-cr ^ r? 5 j5w cimj&p >-rc'C_ St*I (/&<\ '><&. Kic tMai) Cfei.1 tstslil ST!Si_ ; ,/Kct-^f /2cc/f ; t'lT>5 c/ W ; 5c/ `r? H< if/ ' fArfLCOCA/ f^lcMu'l T 'JciiC.vf *aW CM Bo3 Art*i i^/iaJI ; CliJiJet/Q ;4cu.'c,2.TI# fWlSr FCS/UCH iilMt -^o^*a<,ojy. ; J.FAu,y a/jv 1^77 to (j'.*>//\'& rto*-( -4,1^1 Te- <2c*->p/-nc'( ^Z- v'^JT /`fJ'fl TCi Cor`*tf>i&'T't?'*J "AetU-l 11>3 r0 ,iu<f /9>s aAw (<??5 tCj ^c/<^ / J'7r Ai-(fy 19 7$ vc- C?qwP t-rio*.f 1V>6 -ft (,prfliT*'irtifi'^ ^>s- -ro Cd/^c^r,CA( ^sPr <9?s to- <?c->iu',as--ru;tj "SfiPr > 5 tcl. Cf-. n<5.;1s.fic.l^ 9((z. \/(j "??i6 7b Coaa/,Jo..t.Ca; \Z((t -Scrsr <T7jr -ro, C<j.-wt>h't*cw **ri \I(\T dvn t'Jis r^i a/ecu. CofWjicer/CA/ A.v/^;n to <t*j? ai Pu&Tt o Pi Git o r/i tst&o T^isPUC.'Tic^ /wfep X.^spfrr*o*l a/co X-r 3/><?or<o<J a//?? Z^/SPCtc-j Sc^tDMt/i/^ l/i3-ce tw &<jt; -Xm St a a wickt' Cl&D XVv*Ui\m.F*iT CiiECs XM-srttdci ur-tbjTr Riico &MC imsefe. P)C.O0 Z-7~ M <-^ T-2 CCR 00oi^06 r f i APPENDIX U i BID TABULATION PIPING AND EQUIPMENT INSTALLATION cCr 00i 9^07 L L BID TABULATION 1- I C it: N,'-i ' *- C,`- i LO CAT 10 N) t.ake chari.es. Louisiana DATEy February 6, 1978 J"PROJECT, VCM VENT GAS INCINERATOR / * 3.G.0. TITLE PIPING f< EQUIPMENT INSTALLATION B.O.D. # PB-029-033-3| CED 0.O.B. EST $q80,ooq.** ARE AMOUNT $729,837.* AFE #8196 U-2 APPENDIX V PROGRESS REPORT - INCINERATOR PROJECT CCR 000019209 \{itctofIice Commun i cation To 0. 0, Kail iff J. r. Alix March 27, 1978 Subject VENT GAS I NCI HERAT I Oil PROGRESS REPORT (AFE'S 1-3^-8196, 8217, 8257, 832/) With improvement in the weather, construction progress has been good. Prospects for startup of the H\ Incinerator in September and for com pliance with the EPA schedule remain good. A potential obstacle is expiration of a number of construction labor contracts on April 30, 19/8. Wo arc monitoring this situation, but it does not appear that we can significantly influence the course of events. Cost -reports as of February 28, 1978, forecast expenditures for all AFE's to be within Budget. Although there ore a few known problems remaining to be resolved, none of .these arc likely to cause overruns. U\ INCINERATOR - AFE 8196 I. Construction All Field Contracts except Painting and Insulation have been awarded. The Piping and Equipment Contractor started work March 13, 1978. Although muddy conditions persisted in early February, weather conditions and work progress have otherwise been good. I I . Schcdu1e The schedule was re-evaluated in mid-March, using the contractors' proposed manpower loadings and calendar-day estimates. This projected a mechanical completion date of October 6, 1978. (Exhibit I). The "critical path" centers about Instrumentation. To improve the October 6 projection, the. basic plan is: a) Apply "spot" overtime-to complete critical areas of concrete work, to allow the Piping and Equipment contractor to proceed. b) The Piping r. Equipment contractor is willing to increase hir. maximum crew size if the work areas can be made avaiIabIe to him. V Cu^L V-2 CCR 000019210 B. D. Ratliff March 27, ly/8 Page Two c) Start the Instrument Contractor as soon as the major pipe runs and equipment are in place. The Instrument Contractor has sub-contracted the electrical portion of his job to the Electrical Contractor. That portion of the Instrument package will start by May 1, instead of June I. d) A revised schedule will be developed with the Instrument Contractor for the balance of his work. The target date for mechanical completion remains September 1, 1978. III. Design and Procurement All engineering packages are complete. Work remaining is mainly Ipspection and expediting of purchased materials. Current delivery dates do not conflict with the plan outlined above. IV. Cost Accounting Summary sheets for the February 28, 1978, cost report are attached (Exhibit II). These project an under-run of $160,935 for AFE 8196. This reflects: a) Material purchases 95% complete b) Ouside engineering 100% complete c) All field contracts bid, except Painting Insulation (98%) Uncommitted allocations for contingency and overtime total $352,894. Close control is being exercised in these areas. HZ INCINERATOR AFE 8217 I. Construction Except for certain work included in the #1 Incinerator packages, , construction has not started. The Concrete Underground package has been awarded. II. Schedule Meehanica completion is scheduled for late in November 1978. V-3 OCR 000019211 n. o. Ratliff March 27, 19/8 Page Three III. Design and Procurement All packages have been issued to CONOCO except for Piping & Equipment Erection. Engineering is proceeding on a revised Condensate Storage System. Equipment will not be ordered until the Definitive Estimate is completed in Mid-April. Scope changes for a Sulfur Dioxide Injection System and a Direct Chlorination Knock-Out Drum have been approved. A change order to add a Cownuri icat ion System is not yet approved. IV. Cost Accounting A'net under-run of $136,360 is projected. This represents: a) Purchased materials 80?, complete b) Outside engineering 73% complete c) Field contracts about 19$ bid. An additional $81,*63 of contingency funds Is unallocated at this point. NEUTRALIZATION SYSTEM - AFE 8257 I.- Construction A contract has been let to re-locate the guy wires for the wooden vent stack during turnaround. This is required to clear the area for the acid pits. The Concrete and Underground package is out for bids. There is a potential conflict with a United Gas 6-inch natural gas pipeline. We will cross it with several sewer lines. A meeting is being set up with United Gas to determine action required. II." Schedule The current schedule prepared by CED-Design shews final mechanical completion on October 1, 1978. All required equipment for initial Incinerator start-up is to be in place by September I, 1970. Ml. Design and P-rocm ement , Mechanical design is substantially complete. Purchasing is complete except for structural steel and above-ground FRP piping. V-4 CCR 000019212 f. R. (). Roll iff March 27, 1970 Page Four IV, Cost Accountinci I We are projecting an under-run of $122,905, mainly due to outside engineering being below budget. CONCENTRATION SYSTEM - AFE 8327 The Muriatic Acid sales contract Was finalized on March 16, 1978. The hold on cash commitments has therefore been released. The Concentration Unit (absorber and tail column) has been ordered. Other major equipment will be ready to order after a review on April 6, 19/8. A' Project Schedule will be issued during April. f (7$ t l_ cc: JDB, LNV, REL, DAK, JEC, RJA, RWMc, JJL, BRJ, ' J. F. Petersen D. M. Lewi s J. E. Van Zant G. L. Kreutzcr R. E. Hanna S. Burnam - J. 6 C. T. Wya 11 D. II. Sanders . 8. G. Gantz ft. 0. McGee E. J. McGuire J. A. DcBernardi K. G. McLeod (DEK-SAU-JJU) R. D. Gninbl i n V-5 CCR 000019213 w Pa'' /'/cf CCWCP'STT q y/j viC^Sf^o'jAjti * /"Myi f^C 1^Cia^/2&TD>-(4#^ ff'l^-fc- J_ r "5 X" f 'A .J v_ -OtJ i fZ-oi. <><JI pt f'.sJZ i>J)P li^CA~\ QPJ f U= C77u CAL rAOLin'TS jfj SVfL'jM ** 1 A>57'/T\.'-/tT10AJ < i Cft -5 /! ^ 1/vjTlA^y- Jt_/VT) 0Aj Oxziizii ^TTTf^ ^^ -V---^v^^T>V>':X;-'pVyX>^rpTA VO v J/W Fee, Mr)rt\/iPrz !.;, -r-i >jv jou O > -- ' {r F 1 y~ I CCR 000019214 _ Sm -^T^yC -jaQ r~f:'" Z2 -->V;;h !3 l/">' 213 - f&Jpoiffc /ZeVlSiOV ,^4.9-!>c Jc^) '.A ' nCT-j^i_ StWJT L "i '>-'CTr^; c/i f-o }T: JK) of /^S DC'jA\-C*j T PV?C L/i -J\T yta Cc 'io^jC ir S^-'e'c'W i~*x~ Co^iyi^-f^K l SV8$*v APPENDIX W CONSTRUCTION SCHEDULE - INCINERATOR PROJECT CCR 000019215 rr^? err u:<Cr :i*L; O-n ESTI! .*! G- iO CCMPLITiOK iCHEO'JLi POii P.\C>: -Oat : /U s .-t/ftih .'..i. * ' I v r. ii- fl to i0000192 6 GT3 s i I u> X) sj 00001922 y APPENDIX X PERFORMANCE OF H. E. WIESE - INCINERATOR PROJECT OCR 000019218 ADDENDUM RESPECTING PERFORMANCE OF H. E. WIESE, INC. Near the end of the Teamsters' strike in June, 1978, H. E. Wiese, Inc. prepared a schedule showing the normal completion of piping work on the Number 1 Incinerator at October 14, 1978. Allowing 'one week for instrumentation completion and three weeks for startup, this would have delayed Compliance until mid-November. At the same time, Conoco Chemicals was bidding the Number 2 Incinerator. Wiese proposed that, if they were awarded the Number 2 contract, they would complete the Number 1 Incinerator by September 16, 1978. They would accomplish this by increasing their peak manpower from about 40 to 104 workmen. They would also put more equipment on the job. This alternative was the most attractive of any considered, and offered a good chance of achieving timely compliance. Plans were made to assure that the other facets of the job would be consistent with the Wiese schedule. X-2 CCR 000019219 With the resumption of work, Conoco Chemicals monitored Wiese's progress on a weekly basis. By late July it was apparent that Wiese was not achieving their schedule. Based on their performance, Conoco was projecting piping completion at mid-October. Conoco met with Wiese management on August 9, 1978 and reviewed the problem with them. They assured Conoco that they would still be close to the September 16 completion. They would add more people and supervision. Additionally, they committed to provide weekly work schedules. When their progress did not sufficiently improve, and,.the promised schedules were not provided, Conoco again met with Wiese management in Baton Rouge on August 15, Although Wiese did not yet agree that their productivity was poor, they committed to assigning a planner/scheduler to the job. Conoco agreed to provide Wiese with a priority list, excluding some systems not required for startup. Arrangements were made for joint monitoring of progress on a weekly basis. On August 28 Wiese' presented a revised schedule, showing completion of the high priority work by September 18. X-3 CCR 000019220 Conoco's monitoring continued to show that Wiese was not meeting the schedule. (See Doc. 64). Conoco presented Wiese with their requirements for a phased turnover, requiring completion of the last system by October 9. Conoco also had the remaining work analyzed by L. B. McCormick, MED, who concluded that such a schedule was feasible, Wiese committed to meet the schedule, and on September 20, 1978 Wiese management was still i predicting completion by October 9. In all these activities and efforts to improve job progress, Conoco continuously considered several options: 1) Overtime Work. . Conoco authorized overtime work on several Saturdays and evenings. This was not generally effective. It seemed that the limiting factor was Wiese's capability of planning and directing the work. 2) Replace the Wiese Superintendent. This would undoubtedly have introduced confusion and delay. Even if per formance could be improved by this X-4 CCR 000019221 move, the judgment was that time would be lost. 3) Cancel the Contract. The judgment was that, even with the, expectation of improving work progress by obtaining another contractor, this approach would have been counter productive . 4) More Direct Supervision by Conoco. This alternative was discussed extensively. It was a step that substantially increases Conoco's liability and exposure to added cost claims. On October 4, in a weekly meeting with Wiese management, Wiese told Conoco they were, projecting a labor over-run of over 20,000 man-hours. They also presented a list of grievances and problems, and asked for Conoco's help. A major problem stated by Wiese was that they felt the inspection requirements were unrealistically strict. In fact, it was obvious that the real problem was Wiese's inability to determine what is to be done and to assign their forces to get it done. X-5 CCR 000019222 In addition to going to any extreme to resolve Wiese's stated problems, Conoco assigned an engineer to work directly with the Wiese forces to: 1) List for them the work required to complete a system. 2) Plan the procedure for hydrostatic testing. 3) Witness the testing. Wiese expressed a willingness to proceed this way, and to assign the appropriate crews to this work. The mpre direct Conoco participation resulted in achieving completion of desired systems for the first time, although overall efficiency was still below normal. Conoco deleted certain work from Wiese's contract, and avoided assigning any further work. These items were accomplished with another contractor after Wiese moved out. X-6 CCR 00001 APPENDIX Y MANPOWER PROJECTIONS AND CONSTRUCTION SCHEDULE - INCINERATOR PROJECT CCR 0000Z9224 Co / r' Pr?< > C*jftr~>'<T /J^iOcrfr Sc'-'iCWca' f-^K 9s& c-^/u-pou !!i ! , (sjiC*>Z? MO'^ri) k> TT.'.'A'H s rt:>- spLit^r <ry-/;wCD i. - ' f' *)''.' 4 ipfS # *v . * f nn^ih^v^' \V We-'Un ^ /Wiv/iv/C <v1Ct- lAj C- ^ vm f: j ;i . j; i j! . . !j ; tt/H-16~fjT? ;!Ii i p/c. i..<zr*> n io-A. <2. i l :. j ;:I' *So^oc. <> I nj j s/hc^^D <^>e~3<r ! 1 ! ( ! j (3cyt)'V]> ,! I fiU- , 1 *< : 1\ If 'I <-0 m-f- ujittG 7*77A1?`r tMib Tw&*r us3*i Co^Vi^^-"9-/6 1 I^ ' 1 , Tyr]'& $ H"Um^<TD --fc i t 6* ? 7? Gx/r ' ova/*- I /tT-rv u; ??* ^<G3t --TT Vtt p-^-A'riG'P JX> faovibe /H'Dl SXjfiU . /0 M'L uvjiOir-' S't.Jf'V ' -------J/)<3 '' C-oo c-o {Wiv4 : 6*7 Pnozit^^i? fa}**- caji cT'-b (Z~ f /?c r> ?1D fu\*j f=oK. i-h /`W/1?/*-f/rcua* - j, /V* Co ;? a^u C-Kl CiM &'> ? ^'^y^OA-' Jif--/^ * ** * * C : of' | |( S^xy^UxfiP- C^/v\') . 1 1 i 1\ * . ; 1 1 ! i ; ; i . M&'T li/i 77-/ uj i ^cT - Pr-x^sc^yy^P O u>-t i: .! /'fesnrr d?;< ..; j fttJ-fec-O ^\'j$4j . fi*'?' ^C- Tj ^ ; C&w* '^~r tr-t> ~t o '7>HT' ; !! --n/`^V' S/f,}\ ntfr^-oo^n 46" rpCX'-' <? o J ... ' '! :' C^r/v'Mw/t"/) T))/fT~ Conoco ^uuj) )'f; ->> .> j/, /; ci 7 y J CCR 000019225 ";^.'..//-v ~rc`'f nts. ' c.v 1 * ^"!T *5 * nv^, n . ., /,',t'iO/l'.`i ;i/.-i) J, < J / W)/,'>/,'^` Y-2 # jL \/JC\NC PiflAJCr 4 6Ft$uiVm^1 i;! !1; n IjI; fc<XunVi C/JT i IMST4LL, fA6 Cl"* <-&*) Stil\j <= T srf^ T7</Kc "7H-o u. Tv'Cs'b&Y <n-`2.U'lt 1 "7-0 7>H e^T. m u. 5940 <.yvj>s~9 xw US') ifZ iI .1 7. I loZq 7<? 2.3.S? ?<T j;41 : .70 ; C? i . o ; ^h To Go IjB" J 0/4. * 42.1 491 ..... _S*'-7'. pi -22.-71^ ,,.m.. i. .L.. L.;. i i I -~'*,rr s-hfc. 3"+- ! '.. Sin. s i*oP *A-6 lit*-" 31 q4 ii- * ! !.. ! ./fc/Z\ iI .. !. !: ! i . S'Lo z ! . :T9 4<T9</ .1.. At y/s" joo 1! j 1 * 'J* - -t o I --H-If- -4- ... I *i ' !-- . <ZL97L -- (...... ^<T:........................ ! I!- -- I_ | . ^ -- ti T .... i` I :. .... -- ........ , i fc ` r i , * J / D O (P . - I- j... u.?.L.i. -- .J1 .-- - f... -j-' L: - *.. 4 * ... \ !........ ............ . ., "T L i1 . i. . H-* *X--L. I *i I iTM' ~->i.... i Vi . J/4ti A ;P ' 1 tvi ! /ij?i :T/jii" a ,.. '. 1 .1 u CCR 000019226 Y-3 ;.V /'/^CiAJcrrl <0 TOn P)p<u& :r crc <J) T1M*> Ti/d-S ; <?-/9-7 T r | -c\0 i f,A 6"tJT Pi Pli\>'0~ IW* I 'AnfrTIOV j pliuchno^ Cj h-S u?x) S7?^<=tw>l. J : STM TX/j-CS' ' "37 f?' TOTrVL C^T'/W JV 3940 /40^ O ^irOo" /^37 IX-L XZi]) bM^/verD /M 3<W/. ^70*5 pi / oc? M3 1 <7 rf; ^___ ^9 6,9 >*) c? - -I 92. t ,/V1 to t> C3-A&-J? *4 S 70 7- 5-0 r r-Z33(- j.; 3ft*f i ; *S*M ^+ )xt4^ ^717 3/*4"! . !^>d>2i 3/^4^ -36-vs / >"? i ! ; ' M ; 1 i I I i ! //'>" ,O 1 Gqs) i Hi :V tb r t,U' ^;\ 5 7 v ( i-H 'l ^~JLO^ ? CCR 000019227 yV TO/' 4 <5Q.'JU {usiasej) 77>/2vJ 'ivCs TV)V "7 S' (TaWMEVr (,)b/p!,vV` l^CT/)ii. .......... S'"I'7" ^ T ST>'\ T^/j-qr ToT/ru H 39<^T -2^ 2.g'2 "Sv!3.'ro'1.'/ru F/f-ub ' 22.-?i`i SW A/) 6 3"+SiVV2" 5*70 3'4-<? . T!>TA"I. I I: -sTr? <T * &ftylNeb /'A W Z7 A /a 3 013 - &0^-l --/ ear o' 5"7 ----- 5~7 o >'1 ,' t r&o?..- .3 1 ul l! 2:2C, 33 ---- 2 2i 0 'J ^/ i i r 9'^ /oo \m 9i/n ,\ ; ^7^.4? (,U> 0:1> tr C1 } i/'i Y-5 J/yl fp^h?y OOOOX^Z^8 CCR / /m:: /a/ . r.7 /"* ., . ... ( Tth'Zv /'/cnvir-j Sr-/ *"" > *>0 t: CQO'FAAtj/Jr 1) fWk F-T' mw1 npA/ STOuciv^/i-u ^rM. "pt/l Co7 S\;^ior/iv. eUj TVT/)i OzT. /Vi H 3cmo /a oSo T-tor /fr3<? *2 221/9 1 A?.//C/l/?j*sC-i) 2f\lL b~ni : ` i 'xTOT- o 't 120 <4*1 S. 7C, . 4V ' *rr . f?7 . ~S3% I c 7C^"' rl1"- ^ 7 ^SHby5 F/3/3 ?? : (ii r imm* ' 3't- l\42J ' { } a/0 TdtAv .j -- T. * 1 * i t l.. ^: -M-rt i : ' j . - -- ! 'I ' ! son ;s~i3 i . 9 SZ jco3/v-n . . . 3 /u^i . 1! ' 0 2 o&tq! . 3/rrr'.,' !z to C.3 | * ! ` _i * 1 I 1 > ,! ! .jj; 1 1 ; " " **"' ii ** j *** *" J ' - * i..; ..!.. i ... ...! : J... i i- ; -*.....i - 1 ' f - i- * ; ! S -- I! i[ i. ;;;.,,. .:... . -t1j ..!.. i j... Ij .| ... 1 !, ; * - wsr, d&a-ll. .............. ;......1 ! j ! 1 * 1 } ! !. \ .r*.. .. iJN PLJ\CS 1 L . ; . .4 'Cus'&LJ& ova" . . !i nr-sr . ilvq :...;. J. 3q$0 62?_ ; 32x13 7/rw : l.; ^ . i ....; i '*. 1 ; "' It '-1 - l .i i < i ! J . li .Hosv . , i '! : T H ! ! ! * j i. j i! 1 ,, i i * r - ` 1 * ; 1 i! ,c>3m \ \iil;l. ; * 'i , i -l 1- ii- * * i i :; ! ' I i! i ! >62 j- .' !| j ; 1 ;1 i . i ! ! ; : ! 'r , : :. :! ; i. I .> ii !I Y-6 CCR 000019229 "luUJ '-J /10 i 1 u ............. ... __5G T. 1 *I |S`n;w. Sfr.'a iei 0 r Z*f ........ ;________ %... <Z^ "6y "______.___ ._ _* B . "IT* H__ ________ . . __ ________-.......; "M m "T* 66 V e,si (Pi'tvt "__________ ______ o______ Hi&o, v'S,___________________ ______S3...V? Tol/U. 1\?S _. Gz-S"! i. ;* <. \' Jo.TM-O0^ h- i i JTN\_________ ___ --Vocfo. Y-8 ............... j CCR 000019231 Y-9 CCR 000019232 t Ji^s ~bo ' !I ` .*';*I j 2- i '*~d. (yi^-^. i nr. 0tL. /oJLLJt AC**''*'-- 'Co ~ 2-3 -- '?&' [ S?-q -i Y-16 CCR 000019238 \ to* WMH &/ , - S&/C ..-.-J 6' A?ptat.3 2j {& i UJC&K. (?r-)biK/C- iC-irq*. ' L*J/&5<?~ ^-S .- t ' f r.&r-\ (A > 9 C^v SO //?To<* aw* J7.`* `,wu J 7 -- I. 4; 5 1* f c j G-Ay ...... 9- 1 _ ,:.7V..; , ! /34o 1:0. J , ! 3&<to -t /-&0 i-j k-o _: 2Y..i - ! /j4o l\u\UL-\./i<to.. U -u: .L-- : A- 9 1 j li ; 4 1^ 7-2 .............. :,7^...:. :. ; 6<?o *;; tl: ..J 3<f<f0 1!..;lU =i 3iik qT-Tj; ;.... 7-i$*________ . 7oi....-. . /ot(f> _, llr-l b&O .;.;.. :.:J. ..: s~tTi : 'T.T !j 7 -11 . /09 /tfipo .! lot . ._. /ot'^D :: A?-\~ : *,0% - 7-24 ______ .43.., .. /Kip . ,.J /OtL.i J: /aJ7o :-i~:a>^V _j I :. 34-4 jLj JLJ433.i_:j -<r j.i. -9 S-JL . rk 41 .. cj..i :: /r<w .: f 771, .rj3u?)i! I i ' . :^r.i ^ 54. FT...... .. ,?o .. . .2 S7to. .,; % . A C/ot> aCvo i 6'4i^r.i :;7Z? : i: :0'Z-; 1: :io.. . : . i ^ .*.* _ ..-2-A. b %------- .21^...... . ?o..: : 27Mo. ... ( 3o).\__CV>b1%.'.. | ... ^(7 i. i 4.7;..... .Tt .11.. <s-iv > q-1 .40. ... . 24?so ,.: 63-; 27?57>. isv), riiM.n'f'):j ., <??T! .. 44 32 i .3/ /o. ,.j . 57)..: _._. 24?*7> .CnUPl.; I . : : .Z:zfi-L: h.U-1 . . 7 o 4-4________ ,,21___.. J2240 .! 32.: ...: 3J/4o. :: fe. V4,C)J . 'LL. ; . : 9 S 4-A 4-2 3 _. O - izsT&c! ..: Zll- ^,522^0 ! ______ J. .4. J _ i .l 11i ._ 992.; /j.-Zri .:J .2J\: . ,9r T-2_i_4.. /*> - - . 777 ^-30 _ ! Vr . i ; ' i 1 - \ -- 7 - -! "'.' 55*. J" .. .. ,7'j , ' 2|r . / <* _ . 1 v. -re .* ' ... n: s" * ^ Z-- ; _7 * f .. . . 1 2- . .. '7 1. .:..?' /y i n' _L. A? S*, . ~p 7"i - i rt ..J . tvi : 7< M T '! j --i ( A --J - 5r-v-...... n *71" ~7I ! >i;:l , i , t .i n o jo o o o o -- IM * o APPENDIX Z FOREMAN' S DAILY/WEEKLY REPORT CCR 000019241 i /. / \ ,J // V / #*,/*# .; i f ,s/. )iw / it i (./ i / it i, i' i i>l l:i \ \ \ ",t u .s'' *1 lrorrn!mi*;; Heporl Dai r I CtlAtt'.l wo. r n r jot: i .o, IJ/.MM wn. NAWr 3. Davic^ _t CllAf T NT roilKI ton . sur;:!!i;iut'PriiT T. onvuzs S 1. O. 1. rot..i 1 lourly l;uu? lour* tOUl* Malo Amount i i - & EQUIP.1'.;: Tt I.DIIJG MACmurGAS , WCI.PHIG MACHINC. II.LCTQIC pickup truck c.m im'AiifvJ to-/ n t :> r rowir'tKur firr ih'tT Af)inr, I'Ai.'irin*' nrr'WAjt ic* cp-vur. ------------------------------------- ------- ....... -- -- -- -- Z-2 -- -- -- -- -- -- -- -- ---------------- TOTAL CCR 0000X9242 / ( A'/:WY>r/n` //V/,: r.nr^trt 1/ jv-m.i \ n nn\ '-rttnn 1 ; f t t;o( tMM IW \j t'Mrt, *, Hit, nt\ f'ofcm:in,ii Itoily/V/p'-My Import I OAlti '" CMAHGP NO............. * ' l r NT JOIt llo. ItAliGK NO. NAMf 1 CHAIT T. T>/)Vic.s Nr i oiim ion sure mm rtiDft 1 r 1 i J. >AYJ S Mourrn. 1(lVoinT*, 11loOuMr*l Hourly Amount [ ` a - eouii`>'(-:ht WFLOIMC W/.OIINT, GAS welding maci 11 ni;. r:i.r ctiiic riCKlie Tllllf K cAi.itil.'k.h iKAuri! t. rrnnniniT nrr liiiif /.''me. a .'Chii;'. H Vl)li auUC fi;/.nr. Z-3 L _______ TO 1 AT. CC# 000019243 * I r f i r i i * i A ' / // t: />r r.ni H.i 'I l\ : I I "I \ 1 I //r>`. s' I . / li; / :if.' ) i.i.t d, im m>\ i.fi , /, i oi'r.n.VA ,tuj /'!>/ f#.T / Forciwwi's P.iil; / VV-1'! '(Hi surcMmrniDCNT OMf. CHAIKW; llf. .'T .IOt' t DAPf'G uo. 3\ -- NAUr -\ * 00 \ v> ^8 1- r> V 00 r-- \, Do r- \ Vo vj> r-- \ CMAIT o-- T' o- o- <r-- - Nr roiiM ion O, T. I lH.il 1 lorn? Monts 1Inti* ly M.ilo Amoiiiv FQUiri'tliT WF.LDIKG MACHINE, fjAS wrtmriG machine, ci.cci me PICKUP TRUCK CAl.llUT/TIC'N TR/.II 1 if f rCIUIPMFNT rirr Turr aiunc wACinijr, imU'M.'l IC. CriANL ! Z-4 * TOT Al. CCR 000019244 r A'/v//>'m /a//:. /if-{/ A - /I'M/ l\` <l. MIIMV ( l * I \ ir.t S' / \? / M.s Mi I W / / l ' 1 /,V,riU". < ./-// ".Vv>.7 r r \ t L 7* L L L c nt ronM mu anwrj I (f f ... APPENDIX AA PIPEFITTERS AND WELDERS - HIGH RATE OF TURNOVER i ti 1: - l CCft 000019247 /' / VI U <-*- U( 1* . > j' --r /3-C&S /fS> j / *< __ 3-/6- 7P ^ *S- 5- 7$ . J-7P 3-^7'-?^ y ' 7-`7p $>^J '7<P ^S? -7&PiS3S7?a/*' Xsc+_ ........ ^//- 7^ J-Jor?& $'Z}--?B /-/'?$ r 7^' _____3'?'7? gy'/^ gpth^i. ___ ______ . jr*-^ iy- yj* _7r^-7P <?"2/7p' if r 19?^ J<Z^-&r+tSL* ^ff J~?-7d'\ 2'i.S~7$ tf'Z/'-7Y r-?.-?9 fy'S-P? X'2,3'77 . I7i' { ------- i----------I, ` w.y. ^ As&&n&^. ... .. .:7-/f:??. . t^SSS^ta^t'____ .. .. -- J ' -* v ~~ * K. . T'/r f r ......... .. .. V'/s-py.............. tf'jb-ys> ---- 71 6 ^7--/7 rp <y'i/t'7?, /'<?/- ?<y Try sX/faTr-ltsm s&~urt& ... _ #'i/~7ir }' 7!,,t^ yf^7Z/*^ 1 7$* < U ........... ...... 7-Z#'?9 ____ f'X'77___ ___ _______ ... <? '/S-77___ 2--51 J7 ? :zJr.?y___ $'LS"7 7 . urix-w <y" //- *7 p /hJ-'iS _*2t ZS-7^ __ .?-/?:?_.......... 9-X'7P j^ -scr 1 1l 1 t is y^z^Tt^xrf-r \rs f7/ Lr>: ^ c ite*s>s ........ ___________________ ... *f'/7~7Y 3~' S >5 '7<T .... ?-z4:.7Y 7'7-7P J-'Jr /J*-- 7*- 27- 7^ 2-Z?-7?~ X'z%'7Y cn^y-ZuHA. siZl6C <n+/ '/U-u^ g'/7'7? ^5^ AA_2 CCR 00001*248 APPENDIX BB PEDCo'S CORRESPONDENCE WITH INCINERATOR MANUFACTURERS CCR 000019250 BRULE INCINERATORS 13020 South Western Avenue., Blue Island, Illinois G0406 DIVISION OF BRULE C. E. & E.. INC. Pedco Environmental, P. O. BOX 20337 Dallas, Texas 75220 Attn: Mr. Herbert J. Inc. Belknap Dear Mr. Belknap, Telephono: 388-7900 Area Code 312 Cable Addreit; 8RUINC1N Telex 25-3287 March 12, 1979 RE: In response to your letter of February 27, 1979 we offer ho following comments. 1} Brule' did not have one or more portable incinerators available for use on a temporary basis for incinerating vinyl chloride. 2) The original delivery schedule was approximately 13 weeks after receipt of approved drawings. Shipment of equipment was made on August 25, 1978. A copy of the bill of lading is attached for reference. 3) The delivery of the equipment was extended due to design improvements, for added corrosion protection, and equipment life. It should be noted that the equipment proposed and ordered by was designed to meet the 10 ppm vinyl chloride emission limit. 4) On July 6, 1978, Brule' advised by letter that shipment was scheduled for approximately August 1, 1979. As noted previously, Brule' made shipment on August 25, 1979. We trust the above answers your questions concerning this program. Yours truly. BRULE* ("BRU-LAY") INCINERATORS BRULE* Cy-E. & E., INC. . LJMrlsh Enclosures BB-2 L./J. Moore CCR 000019251 PEDCo ENVIRONMENTAL, INC. MEMORANDUM TO= Project File SUBJECT; Communication With Incinerator Manufacturers FILE* PN 3470-1-H DATE1 March 13, 1979 FROM: Dilip Mehta cc: On March 9, 1979, Dennis Carson, John Zink Pollution Research Division, Tulsa, Oklahoma was contacted to determine the availability of the portable incinerator on a temporary basis. It was learned that a portable incinerator must be designed specifically for the job and it would take John Zink approxi mately six to nine months to deliver a skid mounted portable incinerator. On March 9, 1979, Product Manager, Trane Thermal Company, Conshocken, Pennsylvania was contacted to determine the availa bility of portable incinerator. It would take Trane Thermal approximately nine months to deliver a portable incinerator. BB-3 CCR 000019252 APPENDIX CC INVENTORY SUMMARY I rA L OCR 000019253 i; j : ?:S'l'Y-a-a1 i ;o 'o o( 1 r |>jU 1 -;*31 -4-j2i p433 |460 Or R v JOh DR 1 CifUDI; PORT * SALT :> lOC In: 1 CRUUL 3 LOP ) l-iVTilTORY 1 1 33P.2o. 8068 9t>3. 1 03. 14997/0. 37643. --lilK; -- i-ui.i. i8. 13 83. 1 0.0 34.7 11.3 r 1 -413 Sul5 TOTAL 1 1330 309. DUCL LINT DOCA TAiLa 109242. 3 83 0 892. 39.4 LOADHU CAR3 0. r PHlKfJiSS I S'.JB TOT/1,!.. jRVHNTORY * 1 /802'i'j4 . 1303300. ___________ : ' TOTAL U.'C I8o03744. -BY PRODUCTS-- i * t^i IDUC l-] Oil PTRIOD 8346628. MUMTIl TO OATH 9121 2932 . YliAli TCI DATl: 1099 3332 7-1. t <? c1. i A IJLlA * "T7V7 7" ,\N;<; X-402 r-403 r SliRvlCH L1 (Ji IT UNDO 'STUNT'D TOTAL I MV . JA It STOi.'L-D TOTAL lllv. lMVHUTUliY .243438. 0 24 34 38. .342903. 0 342903. % TULL 36.0 84.2 --TABS PRODUCTION -- i")A 11. Y CU'.UJLATI Vi.-. 9022'1. I 137 1-12. T-40;l A -/IOil L --10:1 C J -411 A ir-A 1115 -A 11 c: i -4 1 11.) VINYL CIILORIDT -- IN VI: i ll OK Y 79377, 312488. 132094. < I 772 7 ! . 64706O9. 6036331. 3300736. SUB TOTAL 2293/170. f/v* TULL 1 1 ,4 77.0 22.3 91 ; 6 93.7 90.0 34.9 >> METIIR 5,001,200 51,204 ,600 PRODUCT JOIN- .PTRint) 3 /yi 7,176,L 7,77 tfUIiTII TO IMTH 34 137,04 1 . ill 5,236,763 53,043,473 Yi;AR TO L3ATL: 662 309814. VINYL LI Mi: 30 1 142. t Cl:N J'A J N i'L-t'i) 139079. LUADTU CAR'S ' 0. ---------*--- - SuB -J \U AL 23'>3739/ . 1 ;;v'!:.'-iJ`0.iY 1 9-VO 70. TOTAL 9l.lv!. 2303400/. ' CAR si/:i: 20 2c> 30 38 TOTAL 1 .I.IADDJ CARS 0. CARS 0!-i Rl-AOY VO TOTAL SIM-C SHIP STURAOi: 0 0 () 00 0 00 0 00 0 OCR 00001925* .l/-,i),iIt)i i, H I1'., I'M , Mi l T r SUPTKV1 ODIv'S ' r*r* o r.KO -490 1 vi 9 :l | 467 -4*j3 rr4ot) SERVICE Din' CRUDE PURi; CALLS LUC WET CRUDE SLOP ' I N VHNTOifY 70:>3(>42. 0409911. 1 Ob. 2230493. , 30013. SUU TOTAL I 0 7<19704 . [ DOCK LI Mi 109242. '41b DUCK TANK 13000669. i LOADED CALS 0. SUM TOTAL 24667079, [ iUCI-SS INJ'll;IV KiOXiOO. TOTAL iliOC 2W7II7R. % HULL 34 . | 6U.0 0,0 91.4 1 1 .6 94.0 production PERIOD 3031704. MONTI I TO DATE 87092934. Yf'A!? TO DATE I 0031 boil7 I . Pc>/6. <2-- lT/L / ^ /.NrC SERVICE J 102 LIG.IT HI IDS STORED TOTAL INV. |lOb . TAR' W STORED ! 1: TOTAL INV. - '.Ni< 1 10 li A fc*!Oli B 40IC ;i ia 11 111 "4 1 IjC 1r4 I I D SUB TUTAL -8Y PRODUCTS-- INVENTORY % HULL '* 293936, 37.8 0. 9 293936. 4 my 49. 79.2 --TARS PRODUCTION-- 0. DAILY Cl 408749, 18713. I 073329. VINYL CHLORIDE INVENTORY 02003, 194749. 406977. 1 43.724. 2092 003. 2O909/9. 390! 1 9. 6 770961 . % HULL 11.0 22.9 74, 1 1 .9 42.0 39.2 3.0 METER 1 ,063 000 PRODUCTJ ON PERIOD 1692337. MONT)! 'ID DATE bO,532,000 92990724. YEAR TtJ DATE 6081 73.771 . PROGRAM n 1,875,177 5?, 363,GUP ; vinyl line* 96 1 1 4.7 , CERTAlNTEED 139079. LOADED CALLS 0. L SUM TOTAL 7 4 7/1 02. iOGLSS MvHNTORY L 1 <:ot> /(), ......... ....... .. /'/ 3092, CAR S 1/1: .20 26 30 30 TOTAL LOAD! if.) CAL'S CARS UHH READY SPEC SHIP 00 00 00 00 TUTA I. STORAGE 0 0 0 0 L I'Ll LSMIH' supervisor:; CC-3 CCR 000019255  1 Ii.,::! / J 1 .A; ; J`l)' CO'JOi: i.) i . - i,i I >3 >0 1 rL.i.` |H 1 OLD A Hi iC J A .!:i i'l iY '< .Vi :.)l / . ii 7,'-. . 1 (;.> . 1 07 VO. 3 043 1 . X. i--.Jl.l_ o. / Oo, 0 o.O 3 ! . 7 11.7 riii ii k11: j' J. i, I I l;li I i t<; oaooooo. mu;;j ,i to uaii; I UOu'joOOo . r 6U0 YOTaI. 10 Im /MJy. ( 1J L9 u l\ 1 - J ! iZ 1 OVA4A, < 1 iJn.'.A 1a;.'.. 13 1 -Vi 000. |.,1 j/1,! Jt'.lJ 0. | 0J0 i 0 i A J. 3 3'A; | OS 1 1 i ,* `v.f.l; J 1 Jil l 1 30 33 00. 1 | ..JUlAI. uijO 33 704 0:0 . 03.7 YI;AW ltJ DATA 7303640 16. l ( O 2&(*3 . ? / -f ?, XxX I | --bY HI4.'ii)U( k)3 W oii'.'Y 1 Cl LKI/Ii' i:3;.J:> Oi'iii.'i-u ' i'Ol'Al. lih'.. 4 Oil ; TAR I ! o'l'Uii!:'!.) { . i'UJ'Alf J.3v, Jlh'lolTi.lKY 333 733, 0. 334730Si0333 0. :/l 033 3, % i:ULL 40.6 00.0 'JAMS FJ.'JOUCJ'I i.)A1LY Cu/.'Oi.AT J V I.: <3130 i 0. 1 >441 , 807. I ' ,1\ ii > 1 A: 1 I-1 L/IC : 11A 1 II/, 1. IC i 1 10; --V'lrl YL CiiLl. J. I'WhjIVuAY b17o4. 04073.. 410733. 0001133, 4 79 3 1 7o ,, i {>4 9 4 07, 6! >7 1 73, 0 H'Jl.L II . 7 13.1 03.9 70. / 7:j . o 37.3 . 0.7 MET HR 1 ,690,000 04,467,700 ; Oul; 'jui'aI, 1 4 On: >9 VO- V 1,; Y1. 1. J i i;; `3" II 43 , AlA'H/iJC lYiul! 3I;H .1 13/ i 730o;jO. . MUMTii TlJ DaTE bVWjUOuV. PROOKAi i n 1,779,467 58,110,906 Y 1:7,!.' TO I/ATI.: .b'jlt I 04040. ^ - : I A)1\:J 1 Oil 4 i / A3i. .................. ...... OuO jMjAI. 1 O'.Ki'i.' 0. . 1. i A i 11 , i . 1 , `i 1 a'i i i i / l J , : j.jia.'. i .ii i , n OAif : / iI Vi.Jl'nf. I.UAuillJ caw:; 0. CAIA3 lii l- m:/\i;Y TlJ OiVt,' on J r wo 0 i) i) u o0 J1117-.I. o j > i a A* ;i. u o 0 o ... CC-4 1 1i. 3.1 , i m , Oi 1 )' ." .X .. OCR 000019256 ` t I u|, I .'U*. | I {,* ] ( : - i'. 11 ' I A, I.-'. (mi;; `.luij .............. - -1. i -11. -- list .m\ ` i// < 1 lev' J. Ci: met couPi-, 1 1 ;PU ll!',OiJ r.i.!1' r\)3 rti: J CWUOi: .8!.UP ii-ivLiH HWY 4 3P 66. i P/OuJ 4 V . 1 ( "J . t O_ i. * O t * /i ov 8U6 JMIaL 992 4 1 On . 0. ! 66. I o.o u.3 (JUCi- UP:: 16 UuCA l jiPa 10 92-'i2. i l /. 1 L.UWLO U:\iui 0. 79.0 L 8 6,8 TU7-L 2 i `.it oo'Aj ^ i`v 111V r. i M * fi \ i ! 3003 00. ,1'lU /vL i:P0 *' 22. 860 l 96 . -ljv I'K'Jijuers-- I'ifi lOi-U'j'] UiJ 1'l.iltJ! IP 69 40220. MMI.* I'd J/U PAl'i: I o-.wjTm r<>2. YilhU TiJ IJATI: 61 /33 764 l. \ Sliiiv' I Cl: 02- LI GUT Li JOG 8)'Ul<l:U 1 TOTAL I H7. 36 ! TAW 6TU4LI.) ! ALM AS. .Ti`V . IMVhiiTOWY 281 60 3. 0. 2Lit o3. 606 1 36. f 0. -303136. 42.4 dO.4 TAW-3 I'iKJ'jUCTI'Jl'l -- IMJL.Y CuMul. AT IV L 48762. 2. 1 6 A. --vinyl ciii.Piuui:-- xL.-%\** 401 A ,4013 :j i o 1 1A 4 1 1 li 1 1C 1 IU I ITVli w'AliAV 02220. 2O00I9. 469631 . 1934100. 6 136913. 63 l 3.0 01 . 196303. % LULL 11.6 39. o To.9 2 6.6 93,3 96.0 1.1 MILT HR 3,515,000 56,025 >100 SUlJ I'UI'aL U4 12610. ` wwoouenoN 1> Gill UIJ 3640634, MONTH TO UAT Li 66342629'. PROGRAM 2 3,766,679 57,585 ,170 YlrlAii TU 0AT1 49704 3369. . V ill VI. IJXL `JO .11 A.?., * 1AI 4: l! C,V66 0. l U.t.i;! 1;! 6 i'.li: S * t * 11.'U ! h ji t: * J 1 i 2 !' i i. U t * * --* --*-- 00 , iul,,3. 169739 \}<i * (ICiN'ii 1. .6 1 { i i v'f'f to. ...... HAS . V 1 . i ( 1. i<U PK> , > JUTAL r.HAi 4:0 CAW 6 - l'l.iiAAli: (.uGUlT ilO.i CKI-I) l.UU'Jrr .iu.i 0,1 ( 14) CAW CAW6 IJ}-1~ WL/iDY 3 0 8 14 6 Ol'LC 6111 P 2U 0 0 00 U0 33 0 0 i-- l 'l !' > , .! A * I . ' , i r! i . 11 i i i il: ` i.!v t: u ! : CC-5 TOTAL S'J'GWA'Oi: 0 0 0 o CCR 0000192S7 v. v.i !i ;i-i:; i),/ I' i. K J11!) l.in : | i/J ' >' -~-v (If,(Jf) ' *05/0 I / / ft t SHHvlCL '0 ,!JBY CiAJO;: P BUHL \? 5aU:o HOC `j3 ; i.ti J CUUI/H r ;0!.Ur' I i\ V 1:1) j'l lii Y i A >. Co 1 o30''>. 106. icoocio. A 1 C i /. SOB jfJJ'Al.. 1 0 1 A3 Aon . j UiJCr; L.1 i'l- i | 6 IAJCi\ J AiiK UiV'/.A?., 0 i Ooly'iC), | jLiJtJi-1J CABS 0, --1:1 )>.; -- % I'Ul.L (>.? U3.0 0.0 CO. 1 13.0 3o , o , Suiv TOTAL I 6309663< f CHS3. Il.'VL'.l'l'OiiY 1 3033CO. ; TULAL HOC I. 0602003 1 I'hli] i M JH3 I / i 3. l 969 I (Hi 39. ' Yl. :AH TO OAT 71 once I ;:o. I nd 1 ol'\'ViI' ? lu , 1-5 , A- '6>1) i t SHKv I CH ,03 TIO.-iT HBOS T i Ai? - BY PWOOCCTb' -- Il!\M.:NTOi V 2 33'iVfAo / 1 63 % i-Ol.L 3 b. A 13. / -- TARS PRODUCT JO.'I DAILY CUMULATIVE S<--' nl 1\ U'* I 'l \1 ^ 33/1A ft i,2695n5 aV'V'-; ! t 01 A 1 i> 1 -1 c MIA 1 Hi /| 1C i 1 ID i Ilh'H.N TuR /Old' 133016 A 69 333 7 161/ I7937/9 - 1/17 1363 190A36 SUB 1'iJi`AL '1 1 6 7!.. 9A % Hi.HI. Ii.I I I // Vo. 3 0.0 Co. ti 3I . V 1.0 METER 1 ,856,000 53,976,700 poooucnu:! H HIM. 00 171176:;,.. aprogram 1 ,903,357 MUITlI TO I ``ATI-; 6/MIM'l. 56 ,501 ,78/l YI-AW TO DAT.1: A 3b 700630. vliiil 1.) ,IL 6o !,! !i l.il/all.iJ CABS 0 .[ # L. SOD j i j; ah 6 1 i * v1 i u J t >: f f J DJ'a! . VJ ,1 11. *i /) c / 1 Oo'C/O 1 A * ; i > ,01>'6 .iii!-, ri.; , (.. i\i i o CO /> . i- .13 IDTAI. UjAUI-j) cabs CAir- oho i,Vai;y OfV'C I) 61 111' 0 i.) 0 00 00 =- 0. io J`l i 17.1. STlWAOi: 0 0 o o CC-6 000 019258 cc* APPENDIX DD COST DATA - INCINERATOR PROJECT CCR 000019259 conoco Conoco Chcmtcut Company A Division ut CuiVmonial 0*1 Company 5 Gioonv/dv Fl&id tost December 4, L978 Hr. Howard C. Bergman, Director Enforcement Division U.S. Environmental Protection Agency First International Building 1201 Elm Street Dallas, Texas 75720 Dear Hr, Bergman: t- ^ f-- r'- rr-->i * : i.. t--^ i i, CD rj S rn C3 -- O c3 <*--* to ji 3 to The Information In this letter responds to your request' sent in a Telex to Hr. Jim DeBornardi, cur VC plant manager, on 11/28/78. Please understand that the answers to uour questions can vanj many irays, depending upon inter pretation. As we /lave discussed with you and your staff by phone. It is our intent to provide answers using assumptions consistent with what we believe to he the Final use oF this information. Specifically, we understand the answers will provide a basis to assess a penalty for noncompliance using the FPA formula and we believe that It attempts" to match the penalty to the money saved by the company during the period of their noncompliance. We there fore attempted tc quantify the money not spent because the omission control systen was not in operation. Only capital expenditures and OHM costs that are associated with equipment necessary to comply with the standard are given. Please keep us advised of questions that arise in using this information so no misunderstandings about, our case aviso before the penalty panel. TOTAL CAPITAL EXPFNDITU88 Total capital expenditure was estimated from the rest recent project report (dated 11/29/75), It Is divided into expenditures actually made through October, 1978 and tha projected amount left tv be spent until completion of the project. Those arc set out below. ( \ 7'otal spent through 10/31/78 $ 5,523,124 Expenditures projected after 10/31/78 358,870 Total capital expenditure 5,880,000 orF.Pj\Ti::c, and HArwriJAOCt: costs OUi costs must bo based on budget projections because we have no operating experience with the control system. This budgets wore prepared from design calculations and factors norm-lily used in estimating economics of capital projects. DD-2 CCR 000019260 Mr. Howard G. Bergman rage 2 December 4, 197S 17 Operating cost includes operating payroll, processing supplies and utilities. Payroll cost is already being incurred for operator training and prestart-up oven though the control equipment is not in operation. Costs can bo de ferred, however, for suppLies and utilities. These era estimated to be as follows: Deferred Operating and Maintenance Cost $349/Day Tho annual deferred OSH cost requested is not given because an operation change will occur during tho year. At first, wo will burn natural gas to sustain incineration of the process vents. Later we plan to utilize light ends and/or bottoms to conserve the natural gas. Estimate the annual cost by multiplying the daily cost by 105. Maintenance costs include maintenance payroll, materials and contract costs. Even though the control system is not operating-, money is being spent here prior to start-up on prcconmxissionlng activities. ft is estimated that the cost of these activities about equals tho cost budgeted for maintenance and will continue to do so throughout tho prestart-up period so oven though the equipment io not operating, no maintenance cost savings are being realized. ESTIMATED ADDITIONAL COSTS DUE TO DELAYED START-UP Because it is recognized that EPA's penalty policy attempts to penalize the company for noney "saved" by delayed compliance, the EPA should therefore be interested in estimated additional costs we have Incurred because of the strike delay. Examples of some, but not all, of theso are: Office rental Toilet rental Office equipment rental Temporary personnel Total $ 876.00 519.00 1,102.00 6,414.00 $8,911.00 Director of P> lamed leal and En vi ronmen ta 1 A ffai rs /vm DD-3 CCR 000019261 Jim DeBernardi To *^0 /Z&-d~e^er- (conoco) S. A-t-c<UAs-z*$ _ cv ?V / Oy\# 000019262 OCR Lakeside Industrial Relations and Services 816-818 North Lakeshore Drive JAMES R. WELCH General Manager March 12, 1979 Telephone: (318)436-1576 P. O. Box 836 Lake Charles, Louisiana 70602 Continental Oil Company Attn: Mr. Ed Lively 9001 Lakeshore Drive, Suite 1004 Lake Charles, LA 70601 Dear Ed: Enclosed are copies of the calling cards presented to me by representatives of Pedco Environmental, Inc. on March 1st and the written questions they presented me. I did not give written responses to the questions. I did re spond orally and they wrote their own answers. They seemed to be interested in the availability of pipefitters after the strike. Listed below are the figures I gave them for pipefitters as being employed and emphasized that they did not include all industrial projects in the area. Pipefitters Employed: April May June July August September October November December 1978 1978 1978 1978 1978 1978 1978 1978 1978 Strike-partial reports Strike not settled until 6/14/79 partial reports Report reflects 764 96 449 707 834 773 841 867 870 I told Pedco that there is a total membership of construction journeymen pipefitters in Local 106 of 800-900. They wanted to know the possibility of working scheduled overtime after the strike and I explained the impracticality due to loss in pro ductivity cost overruns and effects upon other jobs in the area. CCR 000019263 Page -2Pedco did not ask any specific question about any particular job or industrial owner. All of the questions concerned the area in general. During the discussion they volunteered that they were also investigating PPG Industries and Certain-Teed Corporation. On March 8th during discussions with W. E. Vincent, Secretary to the Building Trades Council, he stated they had called him and stated they were investigating Olin. He said he was unsure as to who they were and that if they wanted to talk about Olin that maybe Olin's people should participate in the discussion. He has not heard anything further from them and has since contacted Herring at Olin. ^James R. Welch Manager CC 000l9i64 7?am PEDCO ENVIRONMENTAL. INC. p.o. BOX 20337 DALLAS, TEXAS 75220 &SZ-&30 _____ (214) 259-3577 Herbert j. Belknap. Ph.d. PEDCO ENVIRONMENTAL. INC. P.O. BOX 20337 DALLAS. TEXAS 76220 214/259-3577 Dilip Mehta PEDCO ENVIRONMENTAL. INC. P.O. BOX 20337 DALLAS, TEXAS 75220 (214) 259-3577 4, m CCR 000019265 Interview Guide-Labor Officials Copy of union contract and rules. What is your assessment of the labor market in May 1978? What was the work load and the labor supply in May 1978? Did the labor force migrate out of the area during the strike?___________________________________________ _____________________________________ Is there a seasonal labor force migration in and out of the area? Explain._______________________________________________ Was there any way that the companies could have kept the construction workers on the job during the strike? Could the strike have been avoided? Explain. How long in advance did the companies or the unions know that a strike was likely to occur? That a strike was inevitable CCR 000019266 What was the work load and the labor supply after the strike Ju 1 v __________________ Aug u s t_____________________________________________ September________________________________________________________ October____________________________________________________________________________________ After the strike, was the possibility of working day and night shifts practical?...................................................................................................... Considering local conditions, was the use of scheduled overtime to reduce construction time practical? Explain. CCR 000019267 United States Environmental Protection Agency ssEPA Region 6 1201 Elm Street Dallas TX 75270 Arkansas, Louisiana, Oklahoma, Texas, New Mexico FEB 2 7 1979 Mr. Berry St. John Lisgow and Lewis One Shell Square* 54th Floor New Orleans, Louisiana 70139 Re: National Emission Standards for Hazardous Air Pollutants Standards for Vinyl Chloride, 40 CFR Part 61, Subpart F Dear Mr. St. John: As agreed at our meeting on Thursday, February 15, 1979, with your client, Conoco Chemicals Company, and EPA's contractor, PEDCO Environmental, Inc., transmitted herewith is a signed copy of the Task Request which outlines the scope of work for which PEDCO has been contracted. This is to also affirm our agreement to provide to you a copy of PEDCO's Final Task Report on Conoco Chemicals Company's vinyl chloride plant at Westlake, Louisiana when the subject report has been completed and received by this office. Sincerely, Martin E. Brittain, P.E. Chemical Engineer Air Compliance Branch (6AEAE) Enclosure cc: Ms. Nancy Long w/enclosure U. S. Department of Justice Ms, Frances 0. Allen w/enclosure Assistant U, S. Attorney Ms. Diana Dutton, Director Enforcement Division (6AE) EPA Region 6 cc* 000016B TASK REQUEST CONTRACT ft 68-01-4147 'ENVI RO't-lENTAL PROTECTION AGENCY CONTRACTOR PEDCO 00 Division of Stationary Source Enforcement TASK ________TECHNICAL SERVICE AREA 1 TASK i ~ The contractor shall furnish facilities, materials, and the necessary professional, technical, and supporting personnel for performance of the work required by this task. Investigation and analysis of circumstances associated witn tne delayed TITLE compliance of four vinyl chloride sources in Region 6 continuing after the statutory deadline of October 21, 1978. MANHOURS 1000 . MONTHS CONTRACT OFFICER 4 months Address Mr. Edward McLean (FM-214-C) . Environmental Protection Agency Contract Operations, Crystal Mall 2 401 m Street, S.W. Washington, D.C. 20460 Phone (703) 557-7432 PROJECT OFFICER Signature Address Mr. John R. Busik (EN-341) Environmental Protection Agency 401 M Street, S.W. V7ashington, D. C. 20460 Date - Work Plan Approval Phone (202) 755-2560 TASK MANAGER REQUESTOR Signature Address Martin Brittain Air Ccrtpliance Branch Enforcement Division US EPA Region 6 1201 Elm Street Dallas, TX 75270 Address Steve Hitte (EN-341) It*) SO? 401 M. Street S.W. W.D.C. 20460 fa-fa^Y Date - Effective Phone ; (FES 729-2755) Phone 1 '' (202) 755-7927 SECTION CHIEF BRANCH CHIEF SIGNATURE APPROVALS ej. /(Mcfio/id^ -A ^7o/>n DATE /1-/2-7& BRANCH CHIEF DIVISION DIRECTOR CCR 000019269 t I. Title Investigation and analysis of circumstances associated with the delayed compliance of four vinyl chloride sources in Region 6 con tinuing after the statutory deadline of October 21, 1978. II. Task Manager Martin Brittain Air Compliance Branch Enforcement Division, Region 6 1201 Elm Street Dallas, Texas 75270 (214) 767-2755 FTS-729-2755 . III. level Of Effort Manhours: 1000 hours Duration (from effective date): 4 months IV. Background ' On October 21, 1976, EPA under the authority of Section 112 of the Clean Air Act, promulgated NESHAPS Standards for the control of vinyl chloride emissions from certain sources. These standards are de lineated in 40 CFR Part 61, Subparts A and F. Sources subject to these standards were allowed to request a Waiver of Compliance for a period of up to two years after the promulgation date. Thus, at the latest, final compliance with the NESHAPS Standards was required by October 21, 1978. ' i Four vinyl chloride sources located in Louisiana did not com plete their compliance program by October 21, 1978, and are therefore in violation of Section 112, of the Clean Air Act. These four sources are the following: 1. PPG - Lake Charles, Louisiana 2. CONOCO - Westlake, Louisiana (Lake Charles Area) Area) 3. Certain-Teed - Sulphur, Louisiana (Lake Charles 4. Vulcan Materials - Geismar, Louisiana Three of the sources (PPG, CONOCO and Vulcan Materials) indi cated that unavoidable strikes were the cause of their delay, while Certain-Teed has cited a number of excuses including a strike, equip ment delay, and bad weather. CCR 000019270 2 Region 6's general strategy regarding these four sources is to proceed into federal court immediately with a temporary injunction in order to obtain a court ordered compliance schedule. The question of possible penalties will be left for a later decision pending the outcome of the investigation under this task order. Hopefully, this will avoid possible slippage of the compliance schedule because of ex tended litigation on the penalty question. Simultaneously, data will be obtained under this task order to assist in the determination of the amount of penalty to be assessed in each case, if any. Specifically this task order will require the contractor to review records, conduct interviews and consult the literature and equip ment vendors to determine the control measures that could have been imr . plemented by the companies during and after the strike (equipment delay) that would have resulted in avoiding or reducing the delay of the com pliance schedule. In addition,.in their defense the companies have made certain statements as to what they were able to do and what they were not able to do to avoid part or all of the delay. The contractor will need to obtain independent information so as to substantiate or refute these company statements. V. Scope of Work The contractor will perform a detailed investigation and analyls of circumstances associated with the delayed compliance of the four vinyl chloride sources mentioned above. Specifically, the ap proach for this study will include the following: 1. Review EPA files on the four companies to obtain basic information such as plant and process data, specific waivers of compliance, and relevant company correspondence. / 2. Review NESHAPS regulations, 40 CFR Part 61, Sub parts A and F. 3. Conduct an investigation, including on site-visits as required, of the four companies to obtain relevant information to be used in the analysis. Specific objectives of the investigation will be to: a. Identify methods which were available during all delayed construction periods and particularly between May 1, 1973, and October 21, 1978, to avoid or reduce construction delays caused by strikes (or equipment delays). been used. b. Determine whether the methods in a. could have CCR 000019271 i 3 methods In a. c. Determine any adverse effects of the use of in a. d. Determine the approximate cost of the methods e. Determine the extent that the methods in a. could have prevented emissions of vinyl chloride in excess of the stand ard after October 21, 1978. In conducting the investigation the contractor shall employ a methodol ogy that shall include, but not be limited to, the following: a* Obtaining sworn statements from company officials; b. Obtaining sworn statements from union officials and workers; c. Evaluation of union contracts and rules, including obtaining relevant copies; d. Identifying work practices in the Lake Charles and Geismar areas; - e. Identifying worker migration patterns. 4. Conduct on-site investigations at the four compan ies to obtain the following: a. Identify methods which were available during all delayed construction periods and particularly between May 1, 1978, and October 21, 1978, to reduce vinyl chloride emissions by October 21, 1978, even using temporary methods. b. Determine whether such methods in a. could have been used to reduce emissions of vinyl chloride to 10 ppm at some or all of the violating emission points. c. Determine any adverse effects of the use of such methods in a., including delaying completion of the permanent con trol equipment and interferring with other plant operations. in a. d. Determine the approximate cost of such methods In addition to the on-site Investigation the contractor shall review relevant literature and consult with vendors. OCR 000019272 4 5. Review each of the proposed construction schedules and determine if it is the most expeditious for each of the four sub ject companies. 6. Provide data from which can be determined the cap- Ital cost and the operating and maintenance cost saved by each of the companies because of the delay in completion of the respective construc tion schedules, including the following: a. A detailed listing of the nature (capital or operating and maintenance or other as specified), purpose, dates, and amounts of the cash flows, for the period of time from the first re ported delay in the respective construction schedule, which each com pany 1. should have experienced in order to meet the October 21, 1978, deadline, 2. planned to experience to meet the October 21, 1978, deadline, and 3. did or will experience in order to comply fully with the vinyl chloride standard. b. A comparison of the cash flows listed in subparagraph a above with a determination of which were delayed and for what reason. YI. Phases of Investigation l 1. Preparation - This phase pertains to steps 1 and 2 in the scope of work. tions. a. Outline of Task: Review EPA files and NESHAPS regula b. Allotted length for completion: Two weeks. c. Output at the end of the allotted length for prepara. tion: Outline on course of action for investigation phase, including methodology. 2. Investigation - This phase pertains to steps 3 to 6 in the scope of work. data. a. Outline of Task: Field investigation and collection of CCR 000019273 l l' 5 b. Allotted length for completion: Two months. c. Output at the end of the allotted length for investiga tion: Report relating to this phase of the study. 3. Analysis of Results a. Outline of Task: Analysis of data obtained, conclusions developed. b. Allotted length for completion: One month. c. Output at the end of the allotted length for analysis of results: Final report. / / CCR 000019274 . VI. REPORT It.'C REQUIREMENTS Within fifteen (15) days from the effective date of this task, the Contrac tor shall prepare a work plan with estimated cost for accomplishing this task and submit one (1) copy of each to the Contract Negotiator, Project Officer, Task Mati.iger and Requestor. The work plan shall include an introduction, project .approach, schedule of work and staffing. The estimated cost shall include direct labor, overhead, special testing, special equipment, travel, consultants and subcontractors, other direct cost, administrative fee and profit. The cost estimate cay be submitted using the Contract Pricing Proposal Form DD 633-4 or Option Form 60. .. . Within fifteen (15) calendar days after receipt of the work plan submitted by the Contractor, the Contracting Officer shall issue to the Contractor written approval or disapproval of the work plan. If EPA disapproves this work plan, the Contractor shall immediately stop work on the task for which the disapproved work plan was submitted pending resolution of the problem. The Contractor shall submit monthly progress reports which summarize the data obtained and identify the manhours and cost expended during the previous calendar month. Each report shall be submitted on the fifteenth (15th) day of the calendar month which is the subject of the report. A copy of this report shall be sent to the Contract Negotiator, Project Officer, Task Manager and. Requestor. During the period of performance of this task, the Contractor shall immediately .inform the Task Manager by telephone of any problems that may Impede performance along with any corrective actions needed by the contractor or EPA to solve the problem. . .... The Contractor shall submit a. Final Task Report summarizing the work completed under the task to the Contract Negotiator, Project Officer, Task Manager and Requestor at the end of the work period for the task. The Contractor shall maintain a file on all work documentation including raw data, calculations, assumptions, interpretations of regulations and source of information. The Contractor may also be required to present expert testimony at administrative and/or legal proceedings on the results of his task for EPA, and State and local air'pollution control agencies which EPA may designate. The Contractor shall notify the Contract Negotiator, Project Officer, Task Manager and Requestor when 85% of all allocated manhours are expended in this task. The Contractor shall not exceed 110% of the manhours approved by the Contracting Officer for this task without written approval from the Contracting Officer. CCR 0000192T5