Document 15kn09Zk6qBy5yq2BpqQ50N3a

TO: Distribution OMQ-. r% r-* it- Interoffice Communication FROM: DATE: SUBJ: Tom Grumbles September 16, 1985 STIPULATED PENALITIES AGREEMENT Enclosed is the final Stipulated Penalities Agreement outlining payment policy and procedures we will follow in obtaining reimbursement costs for capital projects related to the VCM Consent Decrees. To date we have reached basic agreement on capital projects to be included in the compliance plans. Thomas G. Grumbles ajo/7 Enclosure Distribution: R. A. Conrad J. Friend R. D. Gamblin H. D. Garrison D. Hansen H. Kramer D. A. Kuhn R. E. Lehmkuhl J. Stoner VVV 000016647 Vista Chemicoi Company 15990 N. Barker's lording Rd. Post Office Box 19029 Houston,Texas 77224 Phone (713) 531-3200 TGG: fSSS'Sk nF September 13, 1985 Mr. Gary Garber Offshore Mud Movers P.0. Drawer 53508 Laffayette, LA 70505 Dear Gary: This letter is to verify the proper transportation classification for Vista ODC Drilling Fluid Base Oil. As you are aware, ODC has a minimum flash point of 144F. It exhibits no other DOT defined hazards. As such, the DOT hazard class for ODC is combustible liquid. The proper shipping name for ODC is Petroleum Oil, N.O.S. with a DOT I.D. number of NA1270. As we discussed, if a material has a flash point above 141F and exhibits no other hazards it would not be regulated for international shipments, and therefore, not have a UN number or IM0 hazard class for transportation purposes. This is the situation for ODC. Unfortunately, in this case, there is a UN127Q designation for petroleum oils as well. This number would be for petroleum oils with a flash point below 141F. If the 1270 number is seen without the appropriate prefix one would properly assume the material to be a hazardous substance for international and IMO shipments. Also for air shipments of ODC drums, the product is considered an unrestricted (non-regulated) article. I trust the information above will help resolve the confusion over the classification of Vista ODC Drilling Fluid Base Oil. Please call me at 713-531-3445 if you have questions on the above. Sincerely, Thomas G. Grumbles, CIH Environmental Quality Manager ajo/7 cc Tom Randolph Bill McClain Garland Smith VVV 000016648