Document a4xQVr8jvVYoprKvaXRjvpq9B

P TO: Lake Charles Biotoxicitv Team Members FROM: DATE: 3. -J. Hdqrnon, Ponca City July IS,"1989 SUBJECT: MINUTES OF BIOTOXICITY TEAM MEETING - E/29/83 The Lake Charles Biotoxicity Team with Dr. Ken Dickson in Charles on June 29, 1983. Attendees were: Lake L.CVCM - LCCP PED R&D - P. L. Fetzer, S. V. Corkran, E. R. Taylor, S. A. Rey, David B o o>t h D. A. Every T. W. Heller, W. S. Cal 1, Terry Gonza1es-Fo A. M. Nie 1 sen, S. J. Edgmon, G. L. Russell INTRODUCTION Paul Fetter began the meeting by effluent biomonitoring program at Biotoxi.city Study Team to date. giving a brief history of the LCCP and the actions of the the OVERVIEW OF PLANTS Sandra Corkran reviewed the VCM plant process and waste treatment. Ken Dickson was interested in the operation of and upsets in the ASU. He commented that the equalization basin is small (S hr retention time) possibly allowing shocks to reach the ASU. He also commented that the ASU is probably operating both biologically and as an air stripper. The ASU has a retention time of approximately one day. There is limestone neutralization at the process and caustic right before secondary treatment. Duane Every reviewed chem plant processes and waste treatment changes (related to the project) were also discussed. treatments. Planned waste minimization Sandra and Duane also discussed cooling tower blowdowns. Chem plant blowdown goes straight to the outfall, while VCM blowdown goes through their secondary treatment before going to outfall. Although all the cooling tower waters have approximately the same hardness levels, the VCM cooling tower water is much more toxic. VCM cooling tower water has higher additive levels. TOUR OF THE SECONDARY AND EPA SAMPLE POINTS The team (and Ken Dickson) toured the waste treatment facility and looked at EPA sample sites where it was possible. (Water levels were very high due to recent heavy rains.) CUM 000009979 REVIEW OF PAST DATA Allen Nielsen summarized past bionioni.toring data. Ken Dickson had familiarized himself with this data prior to the meeting. (Summary tables of bicmonitoring results and chemical data, along with other background information, had been sent to him .ir, advance.) As a result, the discussion moved quickly frorri review to comments and recommendations. 1. Differences between lab results (ENSR vs. Battelle) Ken Dickson recommended that we check the persistence of effluent toxicity (initial, 24-h and 48-h, for example.) In the Feb r89 testing, Battelle started the bioassay one day earlier than ENSR. This could account for the different results. Also, determining persistence of toxicity could give a clue as to the type of toxicant. 2. VCM cooling tower blowdown toxicity. Toxicity in this sample is very consistent. While zinc has been demonstrated to exhibit toxicity when added to well water, it may or may not be causing toxicity in the final effluent. The toxicity of metal ions is known to be affected by hardness level. Zinc toxicity vs hardness is well documented. Ken Dickson suggested that we compare toxicity values for zinc at well water hardness level and effluent hardness level. 3. High calcium level in effluent According to Ken Dickson, the calcium levels in 001 outfall samples caught his eye immediately. They are very high. Invertebrates (such as Daphnia and Mysidopsis) are more sensitive to high calcium levels than vertebrates (such as fathead or sheepshead minnows.) Ken Dickson gave the following approximate values: Species LC50 (mg/L) Freshwater: Marine: Daphnia Fathead minnow Mysidopsis Sheepsheadminnow 500 2100 500 4000 Ken Dickson also pointed out that the ratio of calcium ions to other ions is important. The more out of balance, the more toxic. He suggested monitoring total and soluble Ca, Na, K, Zn, and Ni along with salinity and hardness of the effluent. Compare cation/anion mass balance to literature values for sea water. He also suggested that we try a "quickie" test using EDTA or oxalic acid to tie up Ca ions and see if toxicity is removed or reduced. 4. Standard schedule for TRE's Ken Dickson suspects that after 2-3 months of chronic testing (assuming we will fail) that the EPA will cascade us into a TRE. Generally, have 60 days to submit a TRE plan after data shows chronic toxicity to be persistent. Then maybe a 2 year time frame to design a remedy before implementing. He considered it essential that we do toxicity studies along with the treatability studies that are going CUI-i 000009974 to be conducted as part of the waste ini nimi za t ion project, t hi e r e b y g a i n i n g v a 1 u a b 1 e i n t o r rn a t i o n f o r a T R If . ENVIRONMENTAL REVIEW AND EPA REPORT SUMMARY Ed Taylor discussed LCCC environmental status. He stated that implementation of Clean Water Act programs (permits, etc.) is delegated to the Louisiana DEQ subject to approval by EPA. Most plants in the area are under second round permits. The state is reviewing water quality standards. The EPA, acting independently under Section 304 of the Clean Water Act, asked DEQ to initiate some sampling along the Calcasieu. (Copies of the report entitled "Results of ToxicityTests Conducted on Effluents, Ambient Waters, and Sediments from the Lower Calcasieu River Estuary, Louisiana" were issued to team members.) The DEQ is waiting to issue state permits until they 1) have finalized water quality standards, 2) get more data from the EPA's 304 study, and 3) can develop a waste load allocation. The EPA study states that Bayou Verdine is more contaminated than Bayou D'Inde. PPG discharges into Bayou D'Inde. Vista and Conoco are the only dischargers into Bayou Verdine. Vista will probably not be issued a new state wastewater permit until after a few months of testing as required by the Administrative Order and after the state water quality standards are finalized. The Administrative Order mentioned above requires weekly monitoring of total and dissolved zinc and nickel from July 1, 1989 to October 1, 1989. It also chronic biomonitoring to be conducted monthly from August 1, 1989 to August 1, 1990. The team discussed the toxicity test dilutions that are required for this testing. (The dilutions range from 52% to 86%, with a 76% dilution being based on the low-flow effluent concentration.) Ken Dickson suggested that we contact the EPA and ask them to explain how they figured the low flow value. Also why were the other dilutions picked? Could we incorporate the 76% dilution into a test scheme using lower dilutions that would allow us to calculate a NOEL (no observable effect level)'? This would allow us to gain more information from these required tests, as we would expect the chronic LC50 well below 76%. NOTE: Ken Dickson pointed out that Mike Morton, the EPA permit writer who wrote the Administrative Order, is a graduate student under his (Ken Dickson's) direction. While this was not a problem for him, he felt that we should be made aware of this. CWH 000009975 ACTION STEPS David Booth Ken Bickson PLF: Contact ERA on G/30/S9 to inquire how `'- / calculated the low flow value- in Ad mi rust r a t i v e Order; also how the other dilutions were c hicser. Theri relay this info to PLF and Ken Dickson. Have prioritized 10. recommendations to PLF by July Distribute information received from David Booth and Ken Dickson to the team members. The team will meet via conference call the week of July 10 to be set later.) (date S. J. Edgmon R?<Dr Ponca City PLF DAE TWH AMN SVC ERT SAR, David Booth wsc, Terry Gonzales-Fox SJE GLR ~ LCVCM - LCCP ~ Houston - Ponca City "X+'js be&n cz pl-e^sure, Loorkt'^j y>7 0 a UJ CUH 000009976 TO: Biotoxicity Team Members Interoffice Communication FROM: DATE: SUBJECT: S. V. Corkran, LCVCM June 26, 1989 Minutes of Biotoxicity 6/22/89 Team Meeting VIS - The Biotoxicity Team met by conference call on 6-2289. The team members participating were: VCM LCCP R&D PED - PLF, DAE SJE, TWH, SVC AMN WSC The kickoff meeting with Ken Dickson, the selected biotoxicity consultant, has been scheduled for June 29, 1989 from 8:00 a.m. to 3:00 p.m. at the VCM Plant. PLF issued a history of the Vista Chemical 001 outfall biotoxicity study for the team to review. This summary will be sent to Dr. Dickson for his background information. TWH issued a bioassay table which summarizes all biotoxicity testing performed up to 6-2-89. Available analytical results will be added to this information. DAE and SVC reviewed process flows and materials/products information on the plants. material will be sent to Dickson before the meeting. raw This 6-29 The team compared ENSR and Battelle test methods and concluded the following: Battelle ENSR: Endpoint A: If appendages move but organism is immobile, it is dead. Endpoint B: If appendages move, it is alive. (Higher LC50 ' s than (Endpoint with "A") A is Battelle's normal definition) Normalmethod: If any movement of appendages seen under microscope then organism is alive. (Corresponds to Battelles Endpoint B) CWH 00000997 The team concluded that the small variation in LC50 results using the two definitions of death does not explain the larger variation in split samples sent to different laboratories in the past. ENSR ran the May effluent sample two days later than Battelle did. Salinity of effluent is different than in 1988 because muriatic acid is now being treated instead of sold. Battelle cannot run location (Columbus). east coast. higher salinity sample at same Sample would have to go to the SJE indicated future permits may determine test organisms based on salinity of receiving stream, not effluent. Next quarterly biomonitoring sample due in JulySeptember time frame. PLF and AMN lean towards ENSR for biotoxicity work but question their reliability of TRE data because they farm out GCMS work. The team reviewed the results of the EPA biotoxicity test on surrounding waterways and effluents. This may result in permit being reopened early. PLF estimate for budget $500M including TRE work. A preliminary agenda was prepared: 8:00- 8:30 8:30- 9:30 9:30- 9:40 9:40-10:40 10:40-12:00 12:00-12:45 12:45- 1:15 1:15- 3:00 Introduction Overview of plant (SVC, DAE) Break Tour of Secondaries and EPA points Review past date (Nielsen) Lunch Environmental review and EPA summary (MGH) Open to Dickson sample report Action Steps TWH - Compile available analytical results and fax to VCM on 6-23-89. PLF - Address comments on testing complete revisions on 6-23-89. history and WSC - Meet with Cindy Gross to discuss reducing CUIH 000009978 cooling tower zinc levels, eliminating zinc treatment, and requesting bioassay data from Nalco. SVC Send following information to Dickson no later than Monday. Plant process flows and materials information. PLF history of biotoxicity study. Data table of all biotoxicity testing results and analytical data. EPA Toxicity Study SVC/PLF Determine location of EPA sampling sites before 6-29-89 meeting. DAE - Check on MGH availability for 6-29 meeting. ALL - Consider items to be included in budget. The next meeting will be with the consultant on 6-2989 at the VCM Plant from 8:00 a.m. to 3:00 p.m. S. V. Corkran Process Engineer da (3) Biotoxicitv Team Members PLF, SVC VCM DAE - LCCP AMN, SJE, GLR - R&D TWH, WSC PED CUll-l 00000997? To: Bioassay Team Members Interoffice Communication From: Dale: Subject: T. W. Heller, Houston June 22, 1988 MINUTES OF TEAM MEETING - JUNE 17, 1988 VISTA The Lake Charles Chemical Complex Bioassay Team held its first meeting by way of a conference call at 10:00 A.M. on June 17, 1988. Meeting participants by location were: Lake Charles - Paul Fetzer, George Hopkins, Duane Every, Mike Kane o Ponca City - Allen Nielsen, Sheila Edgeman o Houston - Wendy Call, Tom Heller Mike Kane, serving as facilitator, began the meeting with a review of the mechanics of a team meeting. Paul Fetzer then led the group in a discussion of the team objective. The group settled on the following formal statement of objective: The prompt evaluation of biomonitoring data and use of the problem solving model to develop recommendations to reduce possible causes of biotoxicity and to reduce the level and variability of biotoxicity in the Lake Charles Chemical Complex effluent as defined by EPA test method EPA 600/4-85/013. Paul Fetzer explained some of the background of the toxicity problem which has brought us to this point. The effluent wastewater permit issued to the Lake Charles VCM plant in November of 1986 included a requirement that the VCM plant begin performing quarterly toxicity tests on the effluent water. The permit re quires a 24 hour screening test using 100% effluent water. If survival of the test organism (daphnia) is less than 80%, the plant must perform additional tests to determine the LC-50 of the effluent. The quarterly tests were performed only on VCM plant effluent until the VCM plant and LCCP effluent streams were combined into one outfall and one permit in April 1987. Since that time the testing has been performed on the combined effluent stream. Vista has been sending the effluent samples to outside labs to have the tests done. The Vista effluent has failed every one of the screening tests performed on the VCM effluent or combined VCM/LCCP effluent. 018/PED44/1 CtJH O0099S0 Three different labs have been used. Tests performed on a split sample by more than one lab gave highly varying results. This variability raises additional concerns about the reliability and repeatability of the test. Gulf South Research Institute (GSRI) labs are currently studying the effects of hardness of the source water on the test results. That information will be made available to team members when GSRI completes their work. Another test was performed where an effluent sample was spiked with EDC. This sample gave better results (showed less toxicity) than a similar, unspiked sample. All the existing data on LCCC effluent toxicity has been issued to team members. Action items resulting from this meeting were: o PLF will issue all new information to team members as it becomes available. o PLF will put bioassay data on a computer disc to share with other team members. o TWH is to issue these meeting notes. o AMN will contact Don Grothe of Monsanto to discuss biotoxicity and to determine Mr. Grothe's willingness to act as a consul tant to Vista. o PLF will issue a meeting agenda one week before the next team meeting. The next meeting is scheduled for Friday, July 8, 1988, at 10:00 A.M. The meeting will be held by conference call. A main agenda item for next meeting is brainstorming causes of toxicity. I have attached two pages from the LCCC NPDES permit which show the bioassay requirement. An AT&T operator can put together a conference call that generally has better sound quality and less disconnects than calls we make ourselves. The operator can be reached at 1-800-225-0233. TTut^aj I'ldUb Thomas W. Heller PED - Houston /cek Distribution: Biotoxicity team members: cc: CRD TGG - Houston MGH JCS - LCCP RAC WPS - LCVCM OCK - R&D File: A-7 PLF GEH MRK - LCVCM BED DAE - LCCP AMN SJE - Ponca WSC TWH - Houston 018/PED44/2 t'UH 0000099S1 Permit No. LA0003336 Page 1 erf PART III PART III OTHER CONDITIONS 1. pH EFFLUENT LIMITATIONS UNDER CONTINUOUS MONITORING Where a permittee continuously measures the pH of wastewater pursuant to a requirement or option in a National Pollutant Discharge Elimina tion System (NPDES) permit issued pursuant to Section 402 of the Clean Water Act, the permittee shall maintain the pH of such wastewater within the range set forth in the permit, except excursions from the range are permitted, provided: (a) The total time during which the pH values are outside the required range of pH values shall not exceed 446 minutes in any calendar month; and, (b) No individual excursion from the range of pH values shall exceed 60 minutes. For purposes of this section, an "excursion" is an unintentional and temporary incident in which the pH value of discharge wastewater ex ceeds the range set forth in the permit. Both the number of individual excursions exceeding 60 minutes and the total accumulated excursion time in minutes occurring in any calendar month shall be reported in accordance with Part II.C.5 of this permit. 2. BIOMONITORING REQUIREMENTS The provisions of this section are applicable to Outfall 001. (a) The permittee shall determine if eighty (BO) percent or greater of the culture of test organisms will survive by use of the "Range-Finding Screening Test" set out in "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms", EPA 600/4-85/013 (Third Edition, March 1985). Organisms for this test shall be Daphnia sp. if the effluent is less than five (5) parts per thousand salinity or MysTdopsis sp. if the effluent is equal to or greater than five (5) parts per thousand salinity. This screening test will be conducted within sixty (60) days of effectiveness of the biomonitoring requirements. Tests will be conducted once each quarter for a duration of two years utilizing a static method for 24 hours and following this dilution scheme only: Effluent sample(*)- 100 percent by volume Dilution water - 0 percent by volume (*) 24-Hr. Composite; refrigerated immediately upon collection of each aliquot CWH 000009982 / / Permit No. LA0003336 Page 2 of PART lII (b) If art any time during the two year testing period a test shows a survival of less than eighty (30) percent of the test organisms, the permittee shall within twenty-four (24) hours conduct a replacement static 48-hour median lethal concentration (LC50) test on the originally collected sample. Replacement of effluent samples shall be once per 24 hours. Organisms for this test shall be Daphnia sp. if the effluent is less than five (5) parts per thousand salinity and reconstituted fresh water (ERA 600/4-85/013, Section 6) shall be used for dilution. If the effluent is equal to or greater than five (5) parts per thousand salinity, Mysidopsis sp. shall be used as the test organism, and reconstituted seawater will be used as dilution water (EPA 600/4-85/013, Section 6). The remaining LC50 methodology is available in EPA 600/4-85/013. (c) The permittee has the option to forego the 24-hour screening test and proceed directly with the complete 48-hour test as described above. (d) All screening and LC50 test results shall be reported with the Discharge Monitoring Reports. The test results should include the chemical and physical data as specified in Section 10 of EPA 600/4-85/013. 3. The term "24-hour composite sample" except for volatile organics means a sample consisting of a minimum of 4 grab samples of effluents collected at regular intervals during the actual hours of discharge over a 24-hour period and combined proportional to flow, or a sample continuously collected proportional to flow occurring during the actual hours of discharge over a 24-hour period. 4. VOLATILE ORGANIC SAMPLING For the "24-hour composite" sampling of volatile organics using EPA Methods 601, 602, 603, 624, or 1624 [40 CFR Part 136, 49 FR 43250, 10/26/84], the permittee shall manually collect four (4) aliquots at regular intervals during the actual hours of discharge during the 24-hour sampling period using sample collection, preservation, and handling techniques specified in the appropriate test method. These grab samples must be combined in the laboratory immediately before analysis. To composite these grab samples, see the instructions for the test method selected in Method 601 (Section 10.4), Method 602 (Section 10.4), Method 603 (Section 10.4), Method 624 (Section 11.4), or Method 1624 (Section 10.3). Each sample is poured into a syringe. The plunger is added, and the volume is adjusted to 1-1/4 ml. Each sample (1-1/4 ml) is injected into the GC (total 5 ml). After four (4) injections, the sample is purged. Only one analysis or run is required since the aliquots are combined prior to analysis. The daily determination of mass (lb/day) shall be the product of the daily concentration (ug/1) determined above times 0.001 times the density correction factor {8.34 lb/gal) times the daily flow (MG0) occurring during the 24-hour sampling period. 000009983 CUH TO: Biotoxicity Team Members FROM: DATE: W. S. Call, Houston June 15, 1989 Interoffice Communication SUBJECT: MINUTES OF BIOTOXICITY TEAM MEETING y i6/12/89 The Biotoxicity Team met by conference call on June 12, 1989. Those team members present were: VCM - PLF SVC LCCP - DAE R&D - SJE Houston - TWH WSC TWH reviewed comments on the contract. He will make some minor changes and send the contract to Ken Dickson by June 13. PLF will call Ken Dickson today and arrange a meeting with Dickson for June 27, 28, or 29. TWH contacted Cindy Gross, Vista's materials and corrosion engineer, about removing zinc from the cooling towers. Cindy said that zinc removal would involve a lot of discussion. SJE suggested chelating out the metals at EPA 001 and testing again to see if the effluent is still toxic after zinc removal. TWH and WSC will get more information from Cindy regarding lower zinc levels and zinc replacement and will ask Cindy to request bioassay data from Nalco. TWH and WSC will also tell Cindy that Jon Cole (VCM plant) asked Nalco for a new proposal with minimum zinc levels. DAE talked to Tom Rutz (Ale CT operations), Eddie Guillory (Ethylene CT operations), and the Nalco sales rep for the ethylene CT about the zinc level in the cooling towers. All three said that we are at the lowest zinc level to prevent > 1 mm/year corrosion in the cooling towers. DAE said the flow diagrams are ready. PLF said that ENSR will test the special CT samples the week of June 19. The samples will be 10% of the zinc level (0.5 ppm) and 40% of the zinc level (2 ppm) . ENSR will test a series of dilutions of these samples to determine the toxic level of zinc. PLF sent ENSR and Battelle a split sample on 001 on 6/1/89. Each lab was going to use both their own method for counting dead organisms and the other lab's method. PLF has heard nothing from either lab on the results. He will call the labs about the results. 00000 998-4 CUH The team discussed the consultant meeting. The proposal is to have it in Lake Charles beginning at 8:00 in the morning. A proposed agenda would be: 1) Introduce everyone 2) Discuss problem definition/background 3) Look at plant drawings 4) Plant tour 5) Discuss past data 6) Discuss action steps Before the meeting, Dickson should be sent: 1) raw materials and products list, 2) plant drawings, and 3) past test results. ACTION STEPS TWH - Send out contract June 13. PLF - Contact Dickson about a meeting June 27, 28, 29. Get ideas from Dickson for agenda of the meeting. TWH - Make table of results of bioassays to date. Distribute copies to the team. TWH/WSC - Meet with Cindy Gross about zinc removal, zinc level reduction, and Nalco bioassays. Tell Cindy about Jon Cole's request to Nalco. PLF Get ENSR and Battelle to tell us results of the split sample. Send special CT samples to ENSR. DAE Compile list of raw materials and products and drawings for LCCP. Distribute copies to the team. SVC Compile list of raw materials and products and drawings for VCM. Distribute copies to the team. PLF Write history of the project for the consultant. Distribute copies to the team. The next team meeting will be by conference call on June 22 at 3 PM. W. S. Call Process Engineer Process Engineering Dept. CUH 000009985 Distribution: Biotoxicity Team Members cc: GEH TGG FGJ JCS Houston Aberdeen LCCP PLF SVC - VCM DAE -KCP AMN SJE GLR - R&D TWH WSC -reD CUH 000009986 TO: Bioassay Team Members FROM: DATE: T. W. Heller, Houston, Texas June 7, 1989 Interoffice Communication SUBJECT: MINUTES OF BIOASSAY TEAM MEETING - MAY 24 The bioassay team met by conference call on May 24, 1989. Team members present were: P. L. Fetzer D. A. Every A. M. Nielsen W. S. Call T. W. Heller LCVCM LCCP R&D PED PED The meeting began at 1 PM with a review of last weeks action steps. Mike Hayes returned comments on the list of questions our team proposes to ask the EPA about our future wastewater permit. Mike feels all the questions are appropriate. He added no question of his own. T. W. Heller reviewed his phone call with Jim Pendergast (Chief, Toxics Control Section, Region VI, EPA). The reason for the past eight calendar quarters of biomonitoring was to take part in a national study on the ability of Best Available Technology (BAT) limits to reduce toxicity to acceptable levels. Vista is at the tail end of the permitting process. Our Round 2 permit issued in 1986 resembles the permits most Region VI facilities got in 1981. Our permit was delayed by the Waste Load Allocation issue concerning the Bayou Verdine. Vista's third round permit is to be issued in 1991. That permit, like all third round permits, is concerned with the in-stream effects of our effluent on the bayou at the 10 year low flow condition (0.9 mgd for Bayou Verdine - a very low flow). The required biomonitoring tests will be chronic, rather than the acute tests required to date. EPA has done some testing to date of the bayou downstream of the Vista discharge point, and have shared those test results with the Louisiana DEQ. EPA tests have shown Bayou Verdine to be chronically toxic downstream of the Vista facilities at a 5% dilution (5% bayou water in 95% dilution water). CUH 000009987 Vista will be asked to do more testing via an "information order" that we can expect to receive in 1990. This order will ask us to do one year of monthly or quarterly chronic bioassays and report the results to EPA. At the end of that period, they will write our new permit, including biotoxicity limits if the prior year's testing indicated Vista's effluent was toxic. Mr. Pendergast said we should look closely at sources of zinc as possible causes of toxicity, especially in the cooling tower blowdown. He recalled that we have about 1 ppm zinc in our final effluent. Zinc is chronically toxic at 100 ppb and acutely toxic at 800 ppb, he said. He also told us to expect a numeric state standard for zinc of approximately 100 ppb. If Vista's effluent was chronically toxic, we would be given a new permit with "deferred" toxicity limits to give us time to do a TIRE. The length of the deferral is negotiable, with one to two years being likely. When asked for a list of good labs or consultants we could hire, he said EPA has no such list. When I mentioned Ken Dickson and Jim Rogers, he had not heard of Rogers, but knew of Dickson. He said Dickson was knowledgeable and did serve as a consultant to municipalities and industry. EPA themselves have gotten information from Dickson in the past. The results of the simulated cooling tower blowdown tests were presented and discussed. They are included here as Table 1. Zinc chloride appears to be a significant source of toxicity and will be studied further. A. M. Nielsen related notes from S. J. Edgmon about Ken Dickson. He has worked two years with Exxon doing fractionations on refinery effluents. He has also done work for Shell. He is now working with the city of Dallas. His availability is spotty in June, but good in July and beyond. Dickson would take two to three days to review existing data following a plant visit. Then he would meet with us, followed by two to three days to draft a study proposal for us to follow. His costs are outlined in Table 2, which is attached. group selected Dickson as our consultant. The Mid-July is budget submittal time for the VCM plant. P. L. Fetzer will include a budget item to get money for FY1990 bioassay tests. The team will meet with Dickson prior to submitting the budget request so that we can have a better idea of how many tests we may do. CUM 000009988 Acute and chronic testing to further identify the cooling tower blowdown toxicity, and solutions to that toxicity, will certainly be part of our future testing. ACTTON STEPS 1. T. W. Heller will draw up a contract proposal for Dickson and show it to the team for review. We hope to meet with him the week of June 19, 1989. 2. P. L. Fetzer will call the other potential consultants and tell them they will not be used. The next meeting will be at 1 PM on June 1, 1989. T. W. Heller Senior Process Engineer Process Engineering Department /jw Distribution: Bioassay Team Members cc: Houston Aberdeen LCCP GEH TGG FGJ JCS PLF SVC DAE AMN SJE WSC TWH VCM LCCP R&D PED CUI-I 00000998? TABLE 1 Daphnia pulex Acute Test Results Simulated Cooling Tower Blowdown Lake Charles VCM Plant Sample Description LC-50 Simulated Cooling tower Water ABC D 13.7% Simulated Cooling tower Water BCD 12.1% Blended Cooling Tower Water AC D 11.0% Blended Cooling Tower Water ABC 9.2% Blended Cooling Tower Water ABD >100% All components blended at suggested control levels, (in proportion to their use in the actual VCM cooling towers). Where A) is B) is C) is D) is N-1336 N--7348 N--7384 N--83 00 Sure-Cool Inhibitor Aqueous solution of sodium Tolytriazole Biodispersant - Polyglycol Corrosion Inhibitor Aqueous solution of Zinc Chloride Dispersant Acrylate Polyglycols ENSR testing labs. CUH 000009990  --I 1 KENNETH L. DICKSON, Ph.D. P.O. BOX 13077 NT STATION DENTON, TEXAS 76203 817/565-2694 R. 01 May 25, 1989 Mr. Tom Hel1er Vista Chemical Co. Houston, Texas Dear Mr. Hel1er Per instructions from Mr. Paul Fetzer, I have outlined below my consulting rates. As you will note, I have a graduated rate schedule depending on whether or not I have to travel and related to the type of activity. Hourly rate for work at home office - $S2.50/hr Hourly rate for work away from office but not in hearing or court *75.00/hr Hourly rate for working with attorneys, participating in hearings and or court -- *100.00/hr These fees do not include expenses such as travel , lodging and meals etc. If you have any questions do not hesitate to give me a cal 1. Regards Kenneth L. Dickson CUH 000009991 Interoffice Communication To: VCM Biotoxicity Team From: Data; A. M. Nielsen, R&D, Ponca City June 5, 1989 Subject: Minutes of Team Meeting Held June 1, 1989 Conference Call Those participating were: VCM Plant - P. Fetzer D. Every S. Corkran Houston - T. Heller Ponca - S. J. Edgmon A. M. Nielsen Item 1 Reviewed Wording of Contract with K. L. Dickson Action Items: Tom Heller will compose section on consultant duties and FAX to other team members by 6/2/89. Other team members are to respond immediately to P. Fetzer since Tom will be out of town 6/5 - 6/9. Item 2 P. Fetzer informed other possible consultants that we selected Dickson. Had good response from two of them. Item 3 Discussed cooling tower biomonitoring data and decided to carry out another test to determine the "safe" level of zinc chloride. y Action items: Paul Fetzer will submit a sample to Enser with 10% of current zinc chloride and 100% of all other additives and ask them to do an LC50 with that sample. D. Every will contact LCCP about acceptable levels of zinc chloride for corrosion control. Tom Heller will contact GED about possible replacements for zinc chloride and acceptable levels. Paul Fetzer will contact Nalco about Chronic Data on zinc chloride additives. Duane Every will provide plant flow diagrams to consultant. j CWH 000009992 CM Plant Biotoxicity Team Minutes - June 1, 1989 Meeting Page 2 Tom Heller will provide Paul Fetzer by June 7, 1989, a summary of all the plant toxicity data gathered by the team to date. Item 4 It was proposed that a meeting in Lake Charles be held with Dickson some time the week of June 19-23. Item 5 Next conference call is scheduled for Monday, June 12, 1989. A. M. Nielsen dist: Houston/Heller and Call VCM Plant/Fetzer, Every and Corkran Ponca/Edgmon and Russell CUH 000009993 To: Biotoxicity Team Members Interoffice Communication From-. Date: p. l. Fetzer May 24, 1989 Subject: Minutes of Biotoxicity Team Meeting - May 17, VISTA 1989 The Biotoxicity Team met May 17, via a conference call. those present were: Lake Charles - Paul Fetzer, Sandra Corkran; Houston - Tom Heller, Wendy Call? Ponca City Sheila Edgmon, Allen Nelson. Action Step Review: 1. A copy of the questions to be asked of the EPA have been sent to M. Hayes and E. R. Taylor for review. Response was requested by May 26. 2. A set of simulated water samples, designed to identify the toxic component, was sent to ENSR for testing. 3. Split effluent samples are to be sent to ENSR and Battelle to ascertain if the difference between laboratories on earlier LC50 results are explainable by the definition of death used at each laboratory. Both labs have agreed to determine the LC50 value using each laboratories definition of death. It is the team understanding that Battelle defines death as the lack of movement by the daphnia while ENSR says that movement of any appendage means the daphnia is alive. Selection of Consultants The following is a list of consultant remaining for consideration: Individual Company Name Cost Availability Ken Dickson North TX St. $600/day Travel $500/day office & in Mid June-major project in Dallas John Rogers North Texas St. $400/day & Travel 300 to 400 office in Now CUH 000009994 Moe Jones ENSR $960/day & Expense Now Bill Isom Aware Estimated to be $1000/day & expense May be other people doing the way Mike DeGreave Ballette $1000 & Exp. Questionable Krzys. Jop Springborn $1000 & Exp. Appears to be available Bill Rue EA Engineering $560/day & Exp. Available Concern was expressed that consultants from the testing laboratories may be biased and would want to do additional and all future biotoxicity testing. Availability and service by the consultant was seen as a very important criteria. It was pointed out that either Dickson or Rogers would likely have the most unbiased opinion, after looking at past data, in providing guidance for future biotoxicity studies. Familiarity with Region V regulations was also an important parameter. Based on all the information considered, Rogers and Dickenson were selected as the top two consultants candidates. Consultant Responsibility Responsibility for the consultant would include: 1. Review of past data drawing conclusion based on information from similar plant. 2. Guidance on where we need to go based on regulatory guidelines. 3. Interact with the EPA on our behalf onregulatory guesting/guidelines. Further discussion on consultant responsibilities will be conducted at the next session. Action Steps 1. P. L. Fetzer to call Sheila Edgmon in Denton, Texas concerning questions to ask John Rogers and Ken Dickson for information to aid in the selection process. Questions topic are shown below: 1. Availability 2. Apparent cooperation 3. Industrial experience 4. EPA interaction experience CUN 000009995 2. T. Heller will contact EPA personnel to determine, if possible the status/working relationship that specific consultants may have had in past dealings with the EPA. Next Meeting Wednesday May 24 at 1:00 p.m. via conference. Paul L. Fetzer Chief Chemist LCVCM Plant dra TO: Biotoxicity Team Members Interoffice Communication FROM: OATE: subject: D. A. Every June 1, 1989 Minutes of the Biotoxicity Team Meeting* May 9, 1989 The Biotoxicity Team met May 9, 1989 via conference call. Team members at the meeting were: R&D Houston LCVCM LCCP - SJE TWH, WSC PLF, SVC DAE The agenda included the status of the: Battel 1e/ENSR meeting EPA meeting Summary of the team's work and test results Last biomonitoring results on the cooling tower water Proposed toxicity testing Consultant selection Tom said that Mick DeGraves was ready to meet with Mo Jones and the group on the 23rd or 24th of May. However, he suggested sending one more split sample to the labs before the meeting. This may allow us to determine if the definition of death for the test species is part of the difference in the test results. Each lab sites a different definition of death in the EPA manual. If both 1 abs are made to follow one definition of death and there is no difference in test results, the meeting can be cancelled. Sheila said this request would not require much more work from each lab. The group then agreed to make both labs comply with one definition for death of the test species and wait to see if the Battel 1e/ENSR meeting is necessary after the test results are examined. Tom told the group about his discussion with Ken Huffman (EPA). Huffman said that depending on our chronic results, we may or may not be required to do a TRE in our next permit. The LCCC's permit expires September, 1991, and after that point we will have one year to do chronic testing. At the end of September, 1992, a TRE will be required. Huffman suggested that the team contact Jim Pendergast (DEQ) about questions on a TRE and Craig Weeks (DEQ) about how the regulations apply to our plant. To summarize, Tom said that the state seems to require less than the federal government and additional conversation with the EPA may be possible over the phone. Next, the group discussed whether or not to keep using Battelle since Mick was moving to the Michigan lab. Paul is reluctant to accept Battelle since they do not have saline testing facilities at the 000009997 Biotoxicity Team Members June 1, 1989 Page 2 Columbus, Ohio, site. He also added that Battelle is not very customer oriented. On the other hand, Sheila stated that Battelle has very good research abilities and an impressive history (first lab to do extensive TRE work). Paul discussed the results of the cooling tower water samples. He and Sandra added four additives to well water (all of the regular additives except chlorine). Zinc levels were lower than the original cooling tower samples. Samples of well water, the actual VCM cooling tower blowdown, and simulated cooling tower water were sent to ENSR. The results were: Sample Well water Simulated cooling tower Water Actual cooling tower water LC-5Q >100% 8.27% 9.5% Paul told the group that a West Lake Polymers representative said that they were being required by the EPA to do a TRE. They had been doing chronic testing. Paul said that he will work on the summary of the team status memo later. Tom will put a table of data together. The group will talk about selection of consultants at the next team meeting. Action Steps Reso. Date - Contact Battelle to see if samples can be analyzed by May 25th. PLF 9/16 - Have each lab use NaCl as the standard reference toxicant. PLF Have both labs use the same definition of death for the test species. PLF - Talk to Craig Weeks and Jim Pendergast about how the regulations will apply to the LCCC. TWH 9/16 - Call Mick DeGraves to cancel the meeting. TWH 9/16 CWH 000009798 Biotoxicity Team Members June 1, 1989 Page 3 Action SteDs Send out another VCM cooling tower sample. Send Paul consultant resumes. Work on team summary. ResD. PLF/SVC Date 9/16 All PLF/TWH 9/16 M/D Duane Every js Distribution: TWH WSC - Houston SJE AMN - Ponca City PLF SVC - LCVCM JCS JRA - LCCP CUH 00000999? TD: Lake Charles Bioto'/icity Team Members FROM: DATE: S. J. Edgmon, Ponca City'1 May 3 ? 133b1 SUBJECT: MINUTES OF BIOTOXICITY TEAM MEETING - 4/24/89 The? Lake 3, 1983. Charles Biotoxicity Team met Attendees were: P. L. Fetzer, S. V. Corkran D. A. Every W. S. Call, T- W. Heller S. J. Edgmon via conference call on IV1 ay - LCVCM - LCCP - PED, Houston - R&D>, Ponca City The meeting began at 1:00 p.m. We decided to rotate secretary by alphabetical with today's meeting. (You're next, Duane!) order beginning ENSR/Battella Joint Meeting Status TWH reported that the ENSR/Battelle meeting could be week of May 1. PL.F and SVC will be unable to attend; attend. Cost for Mick DeGraeve is $1000 plus travel, cost is $90/hr. Pl.F already has approval for this. he1d the DAE will Mo Jones TWH said Mo Jones feels strongly that different definitions of mortality could be the reason for different lab results. Mick DeGraeve said this could be the reason. TWH talked to someone at the EPA and they stuck by thcair definition but didn't think it was very likely that this alone could make such a big difference in results. (6% to >100%). Cooling Tower Testing PLF had not yet received word on results; of the cooling tower water, simulated cooling tower water and well water bioassays. GC/MS ResuIts PLF reviewed results of GC/MS analyses done at Lake Charles on 3- 14-89 sample. V0C: 21 ppb chloroform, 65 ppb 1,2-dich1oroethans ( d e t e c t i. on 1 i m it is 1.0 6 p p b > , a n d 0.37 p p b 1,1,2 -1 r i c h 1 o r o e t hi a n e (detection limit is 0.19 ppb). PLF was unhappy with lab that EMSR had subcontracted work to. (Save reportable limits <10 ppb, etc.) ENSR had to subcontract because they were putting in new instrumentation and say they will have capability in future. M. Hayes Input D AE got MJrI7 s i n p u t Ci n p 1 a ns T r q e 11 i. n q c o ns u ]. t a n t.. Iv! j H s uq no? s ted t h a t w f? q Ci a 1 i eari a n d i. a 1 k to EPA soon i. b 1" Ci r 0 q e t tn q c onso..Litant) . H e did n't fee 1 t hi a t EPA wou. 1 d f cor c e u s i r) t o a n y t i i i r i q II n r ec! s o n a. b 1 e. 1 hi e n w o r q u. 1 d 1; e 1 1 a cons u .11 an t moro about the t i m e .. ..j V. I ... . ... h avs to w<::.r k w i. th . H e al so requested that we .issue a s urn me ry of wh a t the Bi-:- A.. v. j. c ity i- earn has done to date. CWH 000010000 HJH said tie would be willing to go with us to the ERA. He has had some experience in dealing with them. The team agreed that our first meeting with EPA should be for information-gathering and setting up a line of communication. SJE questioned whether we should"talk to DEQ or ERA Reqion VI. Consuit ant Phone Intev views SVC talked to John Rodgers. He gave Phil Dorn (Shel 1 -Houston) as a reference. He has negotiated with ERA and DEQ; said they were often more political than scientific. He would be gone through first week of May, but rest of summer is pretty much open. He could do work at the University of North Texas or at Trac Labs, but actually would prefer that we use other lab, freeing him to concentrate on results, consulting, etc. He has a Ph.D. in aquatic toxicology; also some course work in civil engineering, treatment design, and chemical engineering. Past students of his are now working in Region VI and other companies. No problem with travelling C$400/day + expenses!. $300-$400/day in his office depending on work load. He is sending resume. FLF asked about Ken Dickson's educational background. Unknown. DAE talked to Ron Bretler (Springborne Biono/ni cs) . He is Director of P r ogram Development. Basically brings business in to lab, writes proposals, etc. Has a Ph.D. in aquatic t o x i c o 1 o q y. Springborne mainly does testing but would be open to consulting. He was busy. Suggested Krzys Jop as a 11ernate. (See attachments.) Krzys is Dept. Manaqer in charge of doing TREs HE has worked at NTSUC?), Trac Labs, Battelle, a. n d did TREs on a c o u pie ci f outfalls for Shell in Louisiana. Sounded like he had time available. Springborne has a lot of industrial e perience and regu1 atory experience (particu1 ar1y the states of Mass., Conn., 111.). Costs: $ 1OOO/day/person + travel expenses. Mis ce11aneous work (a couple of hours in o 1" i i i r u. x am pi j. $ 100/hour. TWH related WSC's comments on Bill Rue (EA Engineering Science & Technology, Sparks, MD). He would want to familiarize himself with project by reviewing past data, and permit. Then work with our team to put together study plan. He co-authored EPA?s industrial TRE protocol document. Has been involved .in 25 TREs, many for chemical industry. Now doing TRE for a chemical comp)any in Dallas. Feels that permit negotiation is one of EA-'s strengths. Knows Jim Pender gr af t ('?) of Region VI. Consulting fee is $70/hr/person. Would be getting a whole team from EA. Inter disciplinary team nee dead for this type of work. He-? made some rough estimates of overall cost: Data collection - $5000; discussion and assembly of study plan - $2000. Would want to do TI/RE in-house, but has no problem with using outside lab for r ci u t i n e testing. A vail a h 1 e a s e a r 1 y a s M a y. H a B. S. and M. S. i n bio 1oqy. Co-ant hored paper s wit h Don Grot he, Mic k DeGr aeva, PLT- raised question of whether or b e d e s i r a Is 1 e. not an engineering firm would CUH 000010001 Based on the information we had been able to gather, narrowed down the list of consultants as follows: the te-?.fii NAME Bill Rue Mick D e G r a e v e hen Dickson John Rodqers Bud Burks Don Mount Perry L a n q f o r d Bob Winner Tom Wa11er Bob Foster Ron Bret 1er Krsys Jop -.'iX-'-- Bill Isom j Mo Jones Bill Goodfellow Wayne McCulloch DROP X X X X X X X X X KEEP VS'. x X x X X X AVAILABILITY H- HH- PLF stated that the Battelle-ENSR meeting will give us a better feel for Mo Jones as a consultant. After our meeting with the ERA we will select one consultant. ACTION ITEMS TWH PLF DAE TUJH PLF SJE TUJH ALL Set up ENSR/Battelle joint meeting and inquire through Daryl Hanson about how to handle charges for this. Contractor work order'? Provide charge number to TUJH for ENS R/E-a 11 e 1 1 e meeting. Check back with MJH about whether we want to set up meeting with DEG or EPA. Set up EPA meeting (with Mike Baskin of the Region VI Enforcement branch; PLF thinks this is who has responsibi1ity for LCCC permit.) Draft outline for executive summary of Biotoxicity team status. Send historical data worksheet (diskette) to Tl/JH. Update historical data;; break into summary tables. Copy resumes or other background info on possible c *o n s u 1 t a n t s t o PLF. NOTE: The day after this meeting, plf received preliminary results from the cooling tower water loic-assays: W e 11 w a t e r : cle a n , n co o b s e r v e d t o x i c i. t y VCM cooling tower water: cal c u 1 a 11 O' n s n o t d o n e yet) LCc. j'J 10-30% (exact Simulated VCM coo 1 inq tower water : LCcr) - 10 --30(ex a c t a 1 c u 1 a t i o n s n o t d O' n e y e -I;) CUM 000010002 The simulated cooling tower water had no chlorine in i t. Simulated cooling tower water - 4 ppm Zn Actual cooling tower water - ppm Zn ME XT MEETING - Monday, May 8r at 1 100 p.m via c o n 'fere n ce c a 1 1 . s.q. ctt o- J. Ed qmon RS'.D, Ponca City DISTs RLE DAE WSC 5 JE SVC TWH AMN - LCVCM - LCCP - Houston - Ponca City CUH 000010003