Document XzLEXjkNEx3z0RvbnO3o1QGLx

Vista Chemical Company 900 Threadneedle Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224 Fox (713) 588-3236 December 15, 1989 VISTAdH sav vm UH3 TOT *)91 Mr. B. I. Raffle Supervising Counsel Environmental & Engineering Group Conoco Legal Department P.O. Box 2197 Houston, TX 77252 Mr. H. J. Neeld Director, Environmental Programs Environmental Conservation Conoco Inc. P.O. Box 2197 Houston, TX 77252 Gentlemen: Vista is providing you with the attached information relative to recently discovered solid waste activities at the Lake Charles Chemical Plant. This discovery was discussed with Jack Neeld when initially found. The attached material describes the extent and regulatory status of the waste. The existence of this solid waste management unit will be disclosed in our ongoing RCRA permitting process. Sincerely, Environmental Quality Manager dlj cc: J. Friend, M. G. Hayes-LCCP Attachment r,EC--ll-!l89 MON 11:20 ID:LCCP "ISTh r. A r A' - "; TEL NO:319 4r^ 5172 ttsib P02 NOV 2 <519*8 to: Mike Hayes InMfofHn CCNlMnimkatlon From: Date: Subject M. L. Milanowski November 16, 1989 LCCP Office Revisions - soil Testing Results Introduction This report presents the results of the soil analysis for this project. A. black granular substance, determined to be coke fines, was found on September 5, 1985, while excavating for the chain wall foundation. Extensive analysis has determined this material to be a non-hazardous solid waste. The extent appears to be limited to the North third of the addition and to a depth of approximately ten (10) feet. Because this material provided unsatisfactory bearing support, It was removed from beneath the chain wall and replaced with fresh compacted clay. Four 30 cubic yard dumpsters of excavated material were disposed of at Chem Waste Management, Inc. on October 12 and 13, 1989. The foundation for the building is being constructed as designed. ChronologicAl Seouence of Results 09/05/89 "Coke Pines" found four samples taken and sent to Vista Laboratories 09/08/89 Two samples taken to Core Laboratories to run EP Toxicity Test 09/11/89 Samples taken on 9/5/89 were taken to Core Laboratories for Verification using the P Toxicity Test 09/11/89 Two water samples were analyzed for soluble Chromium at Vista's LCCP Laboratory 09/14/89 Samples taken at two levels in five feet increments around the perimeter of the building (See Sketch Page 4) 09/14/89 Sent thirty-two of the above samples to LCCP Laboratory for analysis 09/14/89 Four samples taken to Core Laboratories fur further verification VVV 000007343 * : 09/22/89 10/11-13/89 McClelland Engineering to take five soil borings to determine the extent of the material Removal and disposal of the Coke Material underneath the Chain Wall foundation VV,, 0000073** Extent of the_Hateria1 The extent of the coke material appears to be limited to the North third of the building. The material was placed in a trench approximately fifteen feet wide from the depth of four to ten feet deep. The material beneath the chain wall was removed disposed of, and replaced with fresh clay. The material beneath the slab was not removed. Even though the coke is limited to North third of the building, the total (soluble and insoluble) metal content of the soil around the perimeter of the building appears to be random. The concentration of chromium, lead, and zinc is not a function of whether or not coke is present. This is evident in the graphs shown on the following pages. The coke was Found in the location of sample numbers 9 and 17. It should be noted that the results were obtained at Vista's LCCP Laboratory using the digestive* procedure. The data comes from the thirty-two samples taken on 9/14/89. This procedure gives information on total metal content; not just the soluble metals as specified by the EPA. These results o no indicate hazardous levels. They were used to determine the extent of the metal content and to determine if a correlation existed between the metal concentration and the presence of coke. This correlation did not exist. VVV 000007345 /# * * -i ' S/r rs/** CHROMIUM CONCENTRATION (p p m ) sanos Nl "I3A31 wdd vvv 000007347 DATA FOR 4 '6 " DEPTH SAMPLE NUMBER + DATA FOR 3' DEPTH VVV G0G0073A8 3H1VA wdd DATA FOR 4 '6 M DEPTH SAMPLE NUMBER + DATA FOR 3# VVV 0 0 0 0 0 7 3 4 9 t ZINC CONCENTRATION (ppm) IN EXPANSION SITE SOLIDS U D >< E a a. D DATA FOR 4'6" DEPTH SAMPLE NUMBER DATA FOR y DEPTH . mc) i w ruu rnn) cHUa a L4 CO CUD fc. 'D CcnD DEC-11'-`89 MON 11:24 ID:LCCF5 uisTh 4 -. -' Summary of Results TEL. NO: 3i 494 51 72 a91b P09 Oate Taken Sample# Laboratory Test VOC 1Chromium Lead Zinc EM US ppm ppm ppm 09/05/89 n #4 n #3 Vista/ LCCP Vista/ LCCP Vista/ VCM Vista/' VCM Acid Digestion Acid Digestion GCMS GCMS -- 50 -- 48 4.01 Methylene Chloride 3,6 Methylene Chloride -- No No 8.8 No No 7 - * -- 09/08/89 m 09/11/89 09/14/89 NOTES: #1 n #3 #4 #1* #4* #4* #12* #16* #24* Core Core Core Core Core Core Core Core Core Core EPTOX EPTOX EPTOX EPTOX EPTOX EPTOX EPTOX EPTOX EPTOX EPTOX -- .45 -- -- -- -- <.0.01 -- -- -- -- <.0.01 -- -- -- <0.01 -- -- -- .39 .20 .29 -- -- .41 <.09 .08 -- -- <0.01 -- -- -- -- <0.01 -- -- -- -- <0.01 -- -- -- -- m <0.01 l* and 4* represent samples 1 and 4 taken on 9/5/89. ' Samples 4*, 1Z\ 16', 24* represent those samples taken while determining ttie extent. They correlate with samples 4, 12> 16, 24 shown on the sketch page. * The Vista LCCP Laboratory analyzed the samples using the acid digestion procedure. According to the EPA guidelines, however, the EP Toxicity test must be used to determine if the material is hazardous. When the EP Toxicity test was used, the levels were well Pbelow the 5 ppm limit. For more information, refer to the appendix. Each individual report is presented. vw 000007350 DE: 11 'S3 MON 11:24 ID:LCCP 'JISTA TEL NO:313 494 5172 831b P10 Conclusion In summary, an extensive analysis of the soil In the area of construction was performed* The material was determined to be a nonhazardous solid waste. No VOC's were present, and the metal concentration was well below hazardous levels. Using the EP Toxicity procedure the highest chromium level was .45 ppm, while the limit is 5 ppm. The extent of the material appears to be limited to the North third of the building, but the total metal content doesn't appear to be a function of coke. The depth of the coke is approximately 10' and was placed in a 15* wide trench going East-West across the building. Because of its pour bearing capability, the material was removed, disposed of, and replaced with fresh compacted clay. The foundation was constructed as designed. If you have any questions or need additional information call me at 491 5146. Mike Milanowski c: JF PDC CRD NER SWH JJ MfiM - LCCP WLN - Houston vw 000007351 DE'' -11-'89 MON 11: ID:LCCP NISTA TEL N0:31S 494 5172 fctSlb PH APPENDIX Ooooo7352 vvv