Document omorDBaGX86bm5g70kK9axj9r

Vista Chemical Company 15990 N. Barter's Landing Rd. Post Office Bo* 19029 Houston,Texas 77224 Phone (713) 531-3200 November 17, 1986 Mr. B.I. Raffle Supervising Counsel Environmental & Engineering Group Conoco Legal Department P.0. Box 2197 Houston, TX 77252 Certified - Return Receipt Requested VIS17 Mr. H.J. Neeld Director, Environmental Programs Environmental Conservation Conoco Inc. P.0. Box 2197 Houston, TX 77252 Certified - Return Receipt Requested Re: U.S. v. Conoco (Case No. 83-2518) Gentlemen: Pursuant to the Asset Purchase Agreement dated as of July 20, 1984, among E.I. Du Pont de Nemours and Company, Conoco Inc., and Vista Chemical Company, and the Consent Decree entered in the above action, we hereby provide notice of recently-discovered information which may lead to the filing of an Environmental Claim. On November 14, 1986, the Vista LC-VCM Plant experienced a by-pass which potentially resulted in VC emissions. The release was reported to the LADEQ as an incinerator by-pass exceeding one hour. During the by-pass chlorine was released in unknown quantities and a Superfund Report was made to the NRC. A tran script of the NRC Report is attached. Please contact me if you have any questions regarding this matter. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager /are cc(w/attach): W.L. McClain R.A. Conrad M.G. Hayes ) I UNITED SEflTES ___________ OFFICIAL SENDER l______________ Printyour name, sddrese, end ZIP Cod* in the space below. * 9?-wPi*t*ftaw* 3, snd 4 on the reverse. ' SSSBBr",,,t ease m, ftRLV E nHR/STM PENALTY FOR PRIVATE USC 1300 RETURN TO T.G. Grumbles Vista Chemical Com^^riy^ (Name of Senear) P.O. Box 19029 (No. end Street, Apt., Suite, P.O. Bom or R.D. No.) Houston, TX 77224 (City, State,and ZIP Code) JiniHiiiiiiiiliilililnilui!! \ united sots postal service OFFICIAL BU6INESS_______ PENALTY FOR PRIVATE use *3oo . gasM~iW'^-,-r adtocent to number. RETURN TO - T.G. Grumbles v-tai-a Chemical Company --' (Name Of Sender) P.O. Box 19029 ' (No. end Street, Apt. Suite. P.O. Box or r.u. r.J Houston, TX 77224 -- -- (city, Stete, end ZIP code) ,, VVV 000023246 DOMESTIC RETURN RECEIPT PS Form 3811, July 1983 447*845 ^SENDER: Complete items 1, 2,3 and 4. Put your address in the "RETURN TO" space on the reverse side. Failure to do this will prevent this card from being returned to you. The return receipt fee wiH provide you the name of the person delivered to and the date of delivery. For additional fees the following services are available. Consult postmaster for fees end check box(et) for service(s) requested. 1. 53 Show to whom, date end address of delivery. 2. O Restricted Delivery. - Director, Env. P, Environmental Conservation Conoco Inc. - P.0. Box 2197 Houston, TX 77252 4. Typeof Service: Article Number GQ Registered O Insured Certified COD P 653 813 871 Express Mail Always obtain signature of addressee or aoent and DATE DELIVERED. S. Signature -- Addressee X 8. Addressee's Address (ONLYifrequestedamfeepm) PS Form 3811, July 1983 447*845 ^ SENDER: Complete items 1,2,3*and 4. Put your eddress In the "RETURN TO" space on the reverse side. Failure to do this will prevent this card from being returned to you. The return receipt fee will provide you the name of the person delivered to and the date of delivery. For additional fees the following services are available. Consult postmaster for fees and check box(es) for sarvice(s) requested. 1. C?Show to whom, date and address of delivery. 2, Restricted Delivery. 3'Mrr.tlC,5f!<Irt^al^le - Supervising Co Env. & Engr. Group - CONOCO INC. P.0. Box 2197 Houston, TX 77252 4. Type of Service: Articla Number Registered Insured U Certified COD P 653 813 868 Express Mail Always obtain signature of addressee or aoent and PATE DELIVERED. 6. Signature -- Addressee . 6. Signature - Agent X 7. Oete of Delivery 9.30***- 8. Addressee's Mdrtu (ONLY ifrequestedandfee paid) DOMESTIC RETURN RECEIPT m o<v o >> ' The following is a recording of a telephone conversation by George , Hopkins with the National Response Center on November 13 at approximately 10;05 pm to report a possible release of Chlorine to the atmosphere* NRC: National Response Center. GSH: Hello, this is George Hopkins with Vista Chemical Co. I'm calling to notify you of a release. NRC: Ok, stand by. NRC; What's your material? GEH; chlorine* NRC; chlorine or Fluorine? GEH: Chlorine - C-H-L-O-R-I-N-E. NRC: Ok, you said you are George Hopkins? Yes. I'd like to record our conversation if that is OK? GEH: NRC: Ok. Your company? ) GEH; Vista Chemical Company. NRC: Vista with a V? GEH; Yes. NRC: Your title? GEH: Chief Process Engineer. NRC: Mailing address? GEH: P O Box 605, Westlake, LA. 70669 NRC: Area code and phone number? GEH: (318) 494-5062. NRC: Is your company the spiller? GEH: Yes. NRC: What town did the spill occur in? GEH: Westlake. I 000023**8 2 *d 0S .*91 I yisin iNtnd woo wodd NRC: What county? GEH: Calcasieu Parish. NRC: Do you have an address or a position of where this happened? GEH: You mean a street address? NRC: Street. GEH: VCM Plant Road. NRC: What date did this occur? GEH: Today - November 13. NRC: The time? GEH: It began at approximately 2:56 pm. To the best of our knowledge it would have been completed by 4:15 pm. NRC: So it lasted a little over 2 hours and 15 minutes. GEH: No, 1 hour and 19 minutes. 2:56 pm until 4:15 pm. NRC: Give me the first number again. GEH: 2:56 pm. NRC: Second figure? GEH: 4:15 pm. NRC: Ok, a little bit over 1 hour and 15 minutes. GEH: Yes. GEH: Now the release . . . NRC: Hold on sir, let me ask the questions. GEH: Ok. NRC: Is this an air release? GEH: Yes. NRC: ok, what did this chlorine come out of? GEH: It came out of a stack. VVV 0000232*9 NRC: what kind of stack? GEH: What do you mean what kind of stack? NRC: A venting stack? GEHs Yes. NRC: What is the cause of the release? GEH: We have a vent gas incinerator that is a control device for Vinyl Chloride. NRC: Is this a normal operation? GEH; The Vent Gas Incinerator is a normal operation. We had an upset in our Direct Chlorination Unit which caused the Incinerator to shut down. After the Incinerator shut down that caused the vent gases that normally go through the Incinerator to bypass the Incinerator and go out the stack. NRC i What was the upset? What caused the upset and what was it? GEH; We are not totally sure at this time. NRC: What was the quantity? GEH; We are not sure of the quantity of than . . . chlorine, it may be greater You don't have to speak so slowly like that you can go ahead and speed up. GEH: Ok, It may have been greater than the reportable quantity of 10 lbs# We are not sure whether it is or not. We do not expect that even if it is greater than 10 lbs. that it is very significantly greater than 10 lbs. NRC: Was there any evacuations? GEH: No evacuations. NRC: Anybody injured or affected? GEH: There were two personnel in the operating unit. NRC: Two employees? GEH: Yes. Two employees that were exposed to Chlorine . . . NRC: Hospitalized? GEH: And hospitalized. They are in observation at this time. appear to be doing fine. They VVV 0000232.50 NRC: Ok. what did Vista Chemical do about this release? What kind of methods or actions did they take afterwards? GEH: We reduced the rates on the Direct chlorination Unit quickly and cut them back and then shut down the Direct Chlorination. Unit. We were able to get the Incinerator brought back up and that eliminated the bypass condition and therefore stopped the release. NRC: How come this lasted for an hour and 15 minutes? GEH: The standby unit. . . We have two Vent Gas Incinerators and the standby unit was down for maintenance and we had some problems trying to restart the unit that was automatically shut down by the upset condition. NRC: Did you notify any other agencies? GEH: We notified the State DEQ of the Incinerator bypass under LESHAP regulations. We will be calling them again to notify them of the potential chlorine release. NRC: Was it a small pinhole leak or was it larger than that? GEH: It is not a leak. It is a bypass. In other words where we had to vent. NRC: Bypass vent? GEH: Yes. Normally, we vent to the Incinerator which combusts all the material in the vent but the upset caused the Incinerator to shut down. NRC: Ok, does this affect any outside people, any neighbors or people living by? GEH: No. NRC: Any other complications? GEH; NO. NRC: Anything else you want to add? GEH: Just that. . . oh yes, you also asked if we had notified anyone besides - we also notified an Alert on our red phone system which notifies the other plants and police and Hwy. Patrol. NRC: How about Fire Dept.? GEH: I believe that is included in there. NRC: Ok, anything else you want to add? WV 000023251 S `d 9S 3 I 99/tM/I I yisin ind*1 d won wodd GEH: Just that we are not sure that we really released 10 lbs. We will be trying to quantify that to find out. It may have actually been less than 10 lbs. But we are reporting it just because it could be possible that it may have been that much. NRC: Alright. GEH: We don't believe that this release poses a environment but we are reporting in accordance regulations. hazard to the with Superfund NRC: you've got to report it then regardless. NRC: Ok, I'll report this on to the EPA. I'll let them know as soon as we hang up. GEH: Who am I talking to? NRC: The last name is Matheson. M-A-T-H-E-S-O-N. GEH: Ok. NRC* Alright. GEH: Thank you. NRC: Thank you - goodbye. VVV 000023252 9 'd 95'9 l 38/M/I l disifi iNtnd wdo uoaj