Document rBjz7KoBwzOx56xqK2z5nvYZa

Lake Charles VCM Plant CERTIFIED MAIL # 809^931 RETURN RECEIPT REQUESTED May 11, 1981 .i * a -w .1 . **.' '.ts *' --' -*y Conoco Chemicals Company A Division of Conoco Inc. P O. Box 605 Westlake. Louisiana 70669 1318) 491-521 1 A received MAY 1 4 1981 Mr. William Librizzi Director Surveillance and Ana ysis Division U.S. Environmental P otection Agency Region VI First International fuilding 1201 Elm Street Dallas, TX 75270 Dear Mr. Librizzi Re: Reconnaissance Inspection Report, Conoco Chemicals VCM Plant (LA 0003479), aid La DRN Inspection 3/23/81 The following is to rovide correction to the above-named NPDES Compliance Inspection report, s jbmitted to you under cover dated April 1, 1981. 1) Section K - Self -Monitoring Program, Part 3 - Laboratory "Permittee Laboratory Proce iures Meet the Requirements and Intent of the Permit - No, The only respons s marked "No" which, we assume, resulted in the unsatisfactory result n imed above, are: (c) Parameters Analyzed Other Than Those Required, and (g) Spiked Samples are Used. Obviously, Part (c) is not sufficient to rep ult in the unsatsifactory rating. For Part (g). Spiked Samples, we are lot required by permit to perform spikes, and are unaware of any EPA regul ation or requirements to institute a spike sample analysis program. We wer 2 informed at the time of the NEIC inspection that a program of this lature was a recommendation and not a requirement. We have no plans to submit a program for spike sample analysis. On this basis, Part 3 sh Duld be corrected to indicate the Laboratory Procedures do meet the requnirements and intent of the permit. 2) Page 1 of 2, Referencing Section K, Part (g) An internal prog|r am for quality assurance for each analyst has been developed. This is an internal program and will not be submitted for inspection or apb roval. Results will be a part of normal laboratory recordkeeping pr Dcedures, but are not subject to submittal or separate agency scrutiny. Again, this is not a program to run spike samples, Certain suggesti ons made by EPA during the NEIC Inspection, for calibrations and other improvements in procedures have been implemented; however, these changes a rs also not required for submittal. VVC 000013435