Document 0qz465ZRmbOgeNJVkRzXd3G7J

(conoco) ----------------------------------------------------------------------------------------- ------------------ -f0P^ Interoffice Communication To Chuck Putnik From Tom Crumbles Date August 4, 1983 subject TOXICOLOGY TESTING FOR MOLEX RAFFINATE Enclosed is a memo from Bill Broddle concerning the subject testing. Bill Broddle has determined from his review of existing data that representative statements can be made and no testing of Molex Raffinate will be recommended by the Toxicology Assessment Committee. Thomas G. Grumbles ajo Enclosure cc W. D. Broddle W. L. Groves 0. C. Kerfoot VVV 0000X3281 TO: Compound Management Team TGG: JCU ERT-. MJU Interoffice Communication FROM: DATE: StJBJ: T. G. Grumbles July 9, 1990 SARA 313 IMPACT ON 610-P The 610-P produced by Vista is considered a mixture containing a certain amount of di-n-octyl phthalate. Di-n-octyl phthalate is on the SARA 313 list and all 313 requirements would apply to 610-P use if threshold use quantities were exceeded. For "processors'1 of a chemical the threshold is 25,000 pounds. However, only the actual percentage of di-n-octyl would be used to calculate use quantities and emissions. The attached letter gives our current thinking on the actual percentages to be used for these calculations. The other 313 requirement is to notify customers of the presence of any 313 materials present in products sold to them. This is typically done with MSDS statements. Current MSDS's may have to be modified if 610-P were used in a compound for the first time. It should be noted that Blane and Aberdeen have reported di-n-octyl phthalate emissions the last two years. CT^ T. G. Grumbles dlj .118 Distribution: J. Stokes, F. Williams, T. Grula S. Saborsky-Premiere, C. Miller-Blane 00q013282 To: F rom: TGG JCL Date: March 24, 1990 Subject: Di--n-octyl Phthalate Content of 610P I talked to Morey Osborn concerning the expected yield of di- n--octyl phthalate made from Alfol 610. If Alfol 610 ADE or 610 AFC is used to manufacture the plasticizer, the expected di-n-octyl phthalate is approximately 12*/. or 18*/. respectively. The 610P and VRP MSDSs say that these mixtures contain up to 50V. di-n octyl phthalate and that it is a SARA 313 reportable substance. As a result, I would expect most people to use 50V. when reporting SARA 313 emissions. That seems to greatly overestimate actual di-n-octyl phthalate emissions. I recommend we change our MSDSs. The annual SARA 313 customer notifications should also be changed to reflect the lower di-n-octyl phthalate levels. Di-n--octyl phthalate discharges reported at Premiere, Blane and Aberdeen should also be reviewed to assure we are not overestimating SARA 313 reportables. Joe Ledvina cc: MJH, ERT, FGJ, GCL, MGJ VVV 000013283