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Brent Hanson Environmental Manager

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• Louisiana Tech 1974 BS Chemical Engineering

• Worked 13 years for PPG (Lake Charles), Boise Cascade (DeRidder)

• Plant Production, Reliability, Project Management

• PPG Reduction in Force 1985

• Looking for a job in the Environmental Field

• LCP Chemicals (Brunswick, GA) in 1987

• Doubts about LCP, but decided Pros outweighed the Cons

• Not knowing I would become one

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• Learned Environmental Regulations under retiring Technical Manager

• LCP site history: 1919 Atlantic Refining(ARCO); GA Power & Dixie-O’Brien Paints thru 1955; Allied Chem (Hg Cell chloralkali 1956) became LCP 1979

• USEPA multi-media site wide investigation in late 1987

• Concurrent with EPA report, GAEPD issued RCRA consent order (CO)

• Remediation began, WWT plant constructed under RCRA CO 1989-90

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• LCP declared bankruptcy in July 1991

• LCP discontinued meeting RCRA CO and Air Quality CO requirements

• LCP NPDES permit violations began in May 1992 and were reported as required(daily calls, written follow ups, monthly DMRs). This continued through 1992 and 1993.

• GAEPD made an internal decision to revoke permit in December 1992.

• Public revocation issued in June 1993, but stayed by local court.

• LCP continued to operate with Allied funding and managing through end of 1993 into 1994.

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• New job at Gilman Paper 11/93, escaping stress of LCP and allowing family to stay on St. Simons.

• LCP shut down February 1994. GAEPD/Allied could not agree on remediation scope.

• USEPA begins criminal investigation October 1994.

• I met with USEPA Criminal investigators 3 times and testified before a grand jury WITHOUT legal counsel

• Naively, I felt this was not worth sharing with my wife. All would be OK. • I shared LCP history and MY Personal Mistakes as honestly as possible

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• 6 Indicted: CEO, CFO, Plant Manager, Environmental Manager, Product Supervisor & Assistant Product Supervisor 4/98

• Gilman did NOT fire me as Environmental Manager in 1998

• Hired lawyer, offered 5 year conspiracy plea deal. REJECTED

• New lawyer, offered 3 year CWA violation plea deal. REJECTED

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• Final deal: 3 year CERCLA violation plus 1 year ESA (wood stork habitat) 12/98

• Probation?? 100 letters(including GAEPD) advocating leniency 3/99

• NO!!! Jekyll/Hyde sentenced to 18 months in Federal Prison Camp 5/24/99

• Faith tested, but returned to Gilman as Environmental Manager in 10 months 3/23/2000

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Do NOT be naïve Get legal advice early

Document everything

Do NOT assume that your situation will be understood

by the government regulators and/or the legal system

Lessons Learned

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