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Vista Chemical Company
15990 N. Barker's Landing Rd. Post Office Box 19029
Houston,Texas 77224 Phone (713) 531-3200
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June 13, 1988
Mr. Steve Shoger BP Chemicals Inc. 200 Public Square (30D2753) Cleveland, OH 44114-2375
Dear Steve:
As we discussed, enclosed is a copy of the confirmatory sampling done in response to the EC Jordan report. Concerning the recommendations on Page 3 it should be noted that Item 1 will be a part of the actual closure plan for the lagoon. Item 2 is not related to the lagoon closure.
Also, I responded in writing to your concerns regarding the costs of the EC Jordan proposal in a May 25 letter to Richard Read. I would appreciate knowing if our response adequately addressed your concerns.
Sincerely,
Thomas G. Grumbles, C.I.H. Environmental Quality Manager
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cc Richard Read W. L. McClain (w/o enc.) D. A. Campanella "
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June 8 1988
Mr. David A. CampanelXa
Blane Plymers 751 North Main Street Mansfield, Massachusetts
02048
Re: 8833.1 Confirmatory Sampling
Dear Mr. Campanella:
Weston & Sampson Engineers, Inc. has completed the confirmatory samplings as discussed in our April 8, 1968, letter proposal. The sampling was intended to verify the results of sampling conducted by E. C. Jordan, a contractor to the Massachusetts Department of Environmental Quality Engineering (DEQE). The E. C. Jordan sampling was conducted on August 21, 1987, and reported to DEQE and the Region 1 Office of the United
States Environmental Protection Agency (EPA) under the title "Site Insection Report for Reidhold Chemical Inc.# Mansfield
Massachusetts# dated September 1987."
The E. C. Jordan sampling locations include two lagoon sites and one in the Rumsford River# Figure 1. Surface water and sediment samples where collected at each of these sites. Sample identifications are listed in Table 1.
Weston & Sampson's sampling program duplicated in part the E. C. Jordan work. Surface water and sediment samples were collected from sample location #1 and sample location #3, as illustrated in Figure #1, Samples were analyzed for volatile
organic compounds, EPA Methods 624 or 8240, priority pollutant metals and base neutral extractables# EPA Methods 625 or 8250. Analytical laboratory reports are located in the appendix and are summarized in Table 2. Samples were collected on April 28, 1988, and delivered the same day to the laboratory.
A summary of the results comparing the findings of E. C. Jordan with samples collected by Weston & Sampson is presented in Table 2 and provides the following insights.
No volatile organic compounds including carbon disulfide, were identified during the Weston & Sampson sampling program in either the surface water of the lagoon or the river.
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Woaton 4 Sampson
Mr. David A. Campanella
June 8, 1988 Page Two
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Base neutral extractable analysis identified 59 ug/1 of phthalates in SW-l-DUP of the lagoon surface water. This is attributed to sediment disturbance during sample collection and is not considered to be representative of dissolved constituents in the lagoon water.
Metals concentration in the river surface water were three to six times less in concentration than those identified by E. C. Jordan. This can be attributed to a dilution effect * The E. C. Jordan samples were collected in August during a period of low rainfall. Weston & Sampson's Program was conducted in April during a percipitation event resulting in the dilution or dissolved constituents.
During the present sampling, lead was the constituent which exceeded the safe drinking water standard. Cadium was equal to the standard.
No phthalates were detected in the river water sample contrary to E. C. Jordan's results
Lagoon sediment samples confirm the presence of metals
and phthalates detected by E.
C. Jordan. Higher
concentrations of copper# lead and phthalates were
detected in the most recent samples.
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River sediment analysis confirmed the presence of metals. Again# concentrations ofcopper and lead are higher than those previously detected by E. C. Jordan.
Phthalates were detected in the river sediments where they were not previously detected by E. C. Jordan.
Several differences are Identified between the E. C. Jordan and Weston & Sampson sample results. The lower metals concentrations in the lagoon and river water samples detected by Weston & Sampson may be attributed to sample handling. The Weston & Sampson samples were filtered by the laboratory prior to fixation to a pH of 2. Filtration would eliminate any contaminants which would be associated with suspended sediment. Lower concentrations can also be attributed to a dilution effect caused by spring river flow and a precipitation event at the time \ of sampling. E. C. Jordan samples were collected during the f month of August where Weston & Sampson's program was conducted in
April during a storm event. The detection of phthalates in river
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Mr. David A. Campanella
June 8, 1988 Page Three
water is likely to be the result of unfiltered sample; phthaltales are not very soluble and readily absorb to sediments. This round of samples identified the presence of phthalates in the stream sediments. The discrepancy between sample results can possibly be attributed to sampling methods and
the sediment strata collected. Phthalates tend to accumulate in organic sediments due to the absorptive nature of organic sediments.
Conclusion
The findings of the confirmatory sampling lead Weston & Sampson to conclude:
1. Ho volatile/purgeable organic compounds/ detected by EPA method 624 for water and 8240 for sediment, are present in
the lagoon or river surface water or sediment,
2. No phthalates are present in the lagoon water or river water.
3. Both lagoon and river sediments contain metals and phthalates. Some of constituents in the lagoon will be assumed by DEQE to be from Blane. River constituents could
be from an up-stream source.
The following recommendations are offered on the finding and conclusion of the confirmatory sampling:
1. Conduct one final EP toxicity analysis on a lagoon sediment
composite sample to determine if material gaefits RCRA waste
categories.
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2. Sample for metals and phthalates up stream and down stream of sample location 3.
3. Start discussion with DEQE on requirements for lagoon closure.
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Motion *4 Sampson
Mr. David A. Campanella June 8, 1988 Page Four
Weston & Sampson is prepared to meet with Blane to discuss our conclusions and recommendations* If you have any question or require additional information, please do not hesitate to call.
Very truly yours
WESTON & SAMPSON ENGINEERS, INC
PGStdjl Attachments (2) (B-233)
Paul G. Sutton Project Manager
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Waaton Sampmon
Sample ID
SW-1 SW-2 SW-3 SED-1 SED-2 SED-3 SW-1 SW-2 SS-l SS-2
TABLE 1 SAMPLE IDENTIFICATION LAGOON & RIVER SAMPLES
BLANE POLYMER MANSFIELD, MASSACHUSETTS
Sample Matrix
Surface Water Surface Water Surface Water Sediment Sediment Sediment Surface Water Surface Water Sediment Sediment
Sample Location
Lagoon Lagoon Rumford River Lagoon Lagoon Rumford River Lagoon Rumford River Lagoon Rumford River
Sampler
E.C. Jordan E.C. Jordan E.C. Jordan E.C. Jordan E.C. Jordan E.C. Jordan Weston & Sampson Weston & Sampson Weston & Sampson Weston & Sampson
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TABLE Z RESULTS OF CONFIRMATORY SAMPLING FROM
LAGOON AMO RIVER BUME POLYM-RS MASSACHUSETTS
C<mq>ouftds Oetected Beta!s
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Antimony Arsenic Cadmium Chromium Copper Mercury Nickel Lead Zinc Selenium Thallium Base/Neutral Extractables
01-N-Butyl ph thal ate Butyl benzyl phthalate. B1 s(2-thyl hexyl) phthalate 01 -N-Octyl phthal ate
Surface Water (ag/1)
....... Lagoon
River .
Sfcl
Sfcl
SW-1
SW-2
E.C.J' WASI2,
OUP
ECJ
WAS
0.15
0.07 0.03 0.22
D.l
0.13
0.39 0.34 0.28
593 4
157 11
Sediment (mg/kilogram)
Lagoon
River
SW-2
Sill
WAS
ECJ WAS
SS-1 DUP WAS
0.01 0.02
0.09 0.10
15.13 77.47
7.35 12.79 122.16
14.99 56.15 58.8 52.33 32.34
6.6 7.0 47 350 2.0 15 210 180
. SEP-3
56.45 60.78 13.97 82.76 91.58 2.28 17.2 302.3B 21.78 29.99 36.75
28 i
196 300 470
150 110
SEP-3 DUP
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WAS
22.81 63.33 1.59 7.69 74.66 .38 10.37 25.01 27.31 42.46 NO
5.2 IB 38 100 0.48 12 400 180
4.3 18 370 ! 10
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I, E.C.J. E.C. Jordan sample results from 8-2147 sampling
Z. WAS - Weston 4 Sampson Sampling results from 4-20-68 sampling
3, 59 ug/1 found In duplicate not detected in primary sample 4. Concentrations for SED-3 are average of primary sample and duplice
analysis.
TO:
R. D, Gamblin
FROM: DATE:
interoffice Communication
SUBJ:
T. G. Grumbles June 10, 1988
PROGRESS REPORT
VISTA
1. EPA has finalized a rule charging a fee of from 700 - 184,000 for pesticide registration and registration amendment actions. Unless registration requirements for Tobacco Sucker alcohols change, there should be no impact on Vista.
2. FDA has indicated it may be taking final action on it's proposal
of four years ago to revoke the Generally Recognized as Safe
(GRAS) status of "by-product" muriatic acid.
We are
participating with an ad-hoc acid group organized by the
International Food Additives Council (IFAC) to address the
recent activity with the FDA.
Preliminary indications are that the agency may specifically affirm by-product acid from some processes. Detergent alkylate processes may be included in the approved list.
3. OSHA has proposed to revise approximately 200 Permissible Exposure Limits by revising the Permissible Exposure Limit tables. We have not seen the proposal yet but will reviewing the revisions, when available, to determine the impact on Vista.
4. Completed SDA questionnaires regarding alcohol ethoxylate exposures and Proposition 65 activities and needs.
5. The CLER Communications Committee met with Procter and Gamble to discuss CLER's Communications program. Meetings are scheduled with Lever, Colgate, SDA, and Dial to discuss the same topics.
6. JCL attended the CLER Technical Committee meeting on 6/9.
7. EPA's proposal on the Toxicity Characteristic was reviewed and a memo issued advising of the impact on Vista. EPA is proposing a methodology to calculate regulatory levels that would reduce the impact on industry over the previous proposal.
8. A plan was developed to begin addressing environment careers and workload. Formation of teams to identify options will occur in July.
9. The Premanufacture Notification (PMN) for the product V-2000 or V-170B was sent to EPA on June 6, 1988.
10.
An MSDS for tin-stabilized rigid PVC compound produced at Premiere was completed.
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R, D, Gamblin
Page 2
June 10, 1988
11.
MMG attended a meeting between Vista and Ferro to discuss the PMN filing for the stabilizer BP-3235.
12.
A sample of Novel 10-44 Alcohol Ethoxylate and Novel 10-44 Ether Sulfate was sent to Stillmeadow for toxicity testing.
T. G. Grumbles ajo
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