Document ba9KB3GwRBm9Z3XmMYbvqXQxo

Vista Chemical Company 15990 N. Barker's Landing Rd Post Office Box 19029 Hou$tonrTexas 77224 Phone {713)531-3200 o April 3, 1986 Mr. Jack Neeld Environmental Conservation Conoco Inc. Marland Building P.0. Box 2197 Houston, TX 77252 .....-...... VIS1A Dear Jack: Conoco was formally notified on December 6, 1985 of a Compliance Order received from the Louisiana DEQ regarding T-405 and T-452 in the Lake Charles Vinyl Chloride Plant. Subsequently, you were sent our response to the compliance order which consisted of a proposed plan to meet the requirements of the order. Attached is the final order approving our proposed plan. This is a hard copy of the plan faxed to you earlier today. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/8 cc W. L. McClain B. Raffle - Conoco VVV 000017151 STATE OF LOUISIANA department of environmental quality IN THE MATTER OF: VISTA CHEMICAL COMPANY ATTENTION: R.A. CONRAD POST OFFICE BOX 605 WESTLAKE, LOUISIANA 70669 * * * * COMPLIANCE ORDER PROCEEDINGS UNDER THE LOUISIANA ENVIRONMENTAL QUALITY ACT LA- R-S. 30:1051 ET SEQ. * * * This COMPLIANCE ORDER is issued to YISTA CHEMICAL COMPANY (hereinafter referred to as "the Respondent'*) by the Secretary, Louisiana Department of Environmental Quality (hereinafter referred to as "the Department"), under authority granted by the Louisiana Environmental Quality Act (La. R.S, 30:1051 et seq., hereinafter referred to as "the Act**) and particularly by Section 1073 C of the Act. FINDINGS OF FACT L The Respondent owns and operates a petrochemcial plant near Lake Charles, in Calcasieu Parish, Louisiana. II. On December 2, L9S5 an ORDER was issued requiring the Respondent to cease use of a leaking storage tank and to submit a remedial action plan to address the contamination. 1U. On January 6, 1986 a remedial action plan for the heavy ends reuse storage tanks T-405 and T-452 was submitted to the Department by the Respondent. Subsequent to e *d U : n 93/20/^0 WV 00001715,2 dsm iNtnd won woad submittal, inspection of tank T-405 by the Respondent revealed numerous holes in the tank's base, in violation of Section 23.13 of the Louisiana Hazardous Waste Regulations. IV. During the month of January 1986, three spill events occurred from the Ethylene Dichloride product storage tank, T-45G, adjacent to the reuse tanks. Extent of the spill is unknown, however, the free liquid portion of the spilled EDC was recovered, tank T-450 was emptied, and contaminated soil around the tank was removed. V. An Inspection by Department personnel on January 30, 1986 confirmed the Information in item IV. Additionally, the inspection revealed the probability of groundwater contamination due to a history of spills in this area. Groundwater monitoring wells adjacent to the area indicate contamination in the twenty-five (25) foot and eighty (SO) foot sands- All of the above are in violation of Section 1147 of the Act as well as regulations cited. COMPLIANCE ORDER Based on the foregoing FINDINGS OF FACT, Respondent is hereby ORDERED: I. To begin, immediately upon receipt of this ORDER, implementation of the following schedule of construction and remediation: A. Remove tank T-405 from its base. 4 weeks. B. Excavate the base beneath tank T-405 plus one (1) foot, assuming no free liquids are observed. Further excavation will be performed until free VVV GQG01T153 P 'd 2 l s I 1 93/S0/t?0 uisin iNtnd won wodd liquids are no longer .found, plus one (1) foot. Completion of this phase must be observed and approved by a Department representative. 4 weeks. C. Construct new base for T-405 which meets all applicable standards of the Louisiana Hazardous Waste Regulations. 15 weeks. D. Repair or replace T-405, as required, and install a new base. 7 weeks. E. Place T-405 in service. 3 weeks. F. Remove tank T-452 from service. 1 week. G. Clean T-432 and prepare for entry. 8 weeks. H. Inspect T-452 for leaks or structural damage. 2 weeks. I. Remove T-452 from its base. Excavate the base as described in item B. 7 weeks. 3. Construct a new base for T-452 as described in item C. 15 weeks. K. Repair or replace T-452, as required, and install on new base. 7 weeks. L. Place T-452 in service. 3 weeks. n. To submit progress reports to the Department every month or upon completion of each major phase of plan. HI. To be hereby notified that issuance of this COMPLIANCE ORDER does not preclude subsequent imposition of civil penalties in an amount not to exceed $25,000 per day for each violation described herein. IV. To be hereby notified that its refusal to comply with this COMPLIANCE ORDER, and the provisions herein, will subject Respondent to possible enforcement procedures under Section 1073 of the Act which could result in the assessment of a civil penalty in an amount not to exceed $50,000 for each day of continued non- compliance. vvv 0000m54 d e I : t I 93/0/f0 bisin iNtnd won woad Done at Baton Rouge, Louisiana, this __ / J day oi _ This COMPLIANCE ORDER is effective on date of receipt. _____ , 19S6- PATRICIA L. NORTON, Secretary Department of Environmental Quality All correspondence should be addressed to; Department of Environmental Quality Hazardous Waste Division Post Office Box 44307 Baton Rouge, Louisiana 70S04-4307 cc: Mr. Richard Goudeau Acadiana Regional Office 100 Eppler Road Lafayette, Louisiana 70505 Please serve the Respondent through Its Registered Agent for Service of Process; C.T. Corporation Systems 400 Poydras Street New Orleans, Louisiana 70130 cc: Vista Chemical Company Mr. R.A. Conrad Post Office Box 603 Westlake, Louisiana 70669 9 *d mil 9Q/C0/P0 yisin !Nb"ld WO A WOdd