Document 43byXJZRyBYrpDZvZOOZBRYQ

A MPA 000013286 L%b\ !f-Needed Statement LDEQ Settlement & Fine Lake Charles VCM Plant ' Date approved for use: 4/29/87 A m Vista Chemical Company has reached a settlement with the Louisiana Department of Environmental Quality (DEQ) on a number of small, inadvertent atmospheric releases of vinyl chloride monomer (VCM) which occurred between Oct. 26,1985 and March 16,1987 from the company's Lake Charles VCM Plant. The company agreed to pay a civil penalty of $12,000. Vista Chemical promptly reported all the releases to the DEQ as required. The DEQ was subsequently informed of all developments relating to the incidents, including extensive preventative measures which are being implemented to minimize additional releases. The civil penalty will be promptly paid. Due to the large amount of air dilution of the emissions following each of the incidents and the small amounts of VCM involved, Vista Chemical does not believe any of the inadvertent releases posed a threat to human health or the environment. In entering into the settlement, the company did not agree that the incidents were in violation of the applicable state regulations, but is taking this action to expedite resolution of the matter and to avoid prolonged litigation. Use the following material only in response to spedfic questions from the media: Q. How many incidents were there? A. There were 23 releases in all. Twenty were minor incinerator bypass incidents and three were relief valve discharges. Of the incinerator bypass incidents, 30 percent involved less than a pound of VCM each, 70 percent involved less than 10 pounds, and 95 percent involved less than 100 poundsof VCM. ^ The three inadvertent relief valve discharges involved volumes of 37 pounds (about 4 gallons), 97 pounds (about 11 gallons) and 2999 pounds (about 336 gallons), respectively, of VCM. A pound of VCM is roughly equivalentto about 3 cups liquid measure. #### Paqe 1 t'PA 00001328 If-Needed Statement Penalty Judgement for VCM Releases Aberdeen, Mississippi * Date approved for use: 4/3/87 Vista Polymers, a division of Vista Chemical Company, voluntarily agreed to pay a $2,000 civil penalty to the Bureau of Pollution Control of the Mississippi Department of Natural Resources as a result of two small, inadvertent vinyl chloride emissions at its Aberdeen PVC (polyvfnyl chloride) Plant in Aberdeen, Miss. The Commission maintained that the emissions, both of which occurred in 1986, had apparently not complied fully with requirements of the state's air pollution regulations. Vista Polymers does not agree that the incidents were in violation of the applicable state regulations, but is taking this action to expedite resolution of the matter and to avoid prolonged litigation. vpa 00001328 A * i \ i UFA 0000 1 'J'2br Hbl If-Needed Statement Chlorine Column Upset Lake Charles VCM Plant Date approved for use: 12/22/86 At 2:56 p.m. Thursday, November 13, 1986, Vista Chemical Company's Lake Charles VCM Plant experienced a process upset in the Direct Chlorination Unit, which affected downstream operations and led to an automatic bypass of the plant's Incinerator Unit. During an incinerator bypass, material that would normally be burned in the incinerator are emitted to the atmosphere. The bypass lasted about an hour and fifteen minutes. The chemicals involved were chlorine and vinyl chloride. Two Vista employees on duty at the time were exposed to chlorine gas during the release. They were taken to St. Patrick's Hospital in Lake Charles for medical observation and treatment. Both men were found to be in satisfactory condition and were released from the hospital at 10:00 a.m. Friday, Nov. 14. No long term health effects to the employees or to the general public are expected to result from this incident. Use the following material only in response to specific questions from the media; Q. Who are the two injured men? Their positions? How long have they been employed by Vista? A. Buddy Hoffpauir, 2nd Operator, a VCM employee since 6/17/74; and Bobby G. Wilburn, 2nd Operator, employed by VCM since 8/7/78. NOTE: Do not volunteer employees' names to the media. If the reporter already knows their identities, you may confirm job titles and employment dates, if asked. Q. What is the extent of their injuries? A. They were diagnosed as exhibiting minor symptoms of chlorine exposure. No residual problems are anticipated. Q. What are the symptoms of chlorine exposure? A. Inhalation of chlorine can cause sore throat, coughing and labored breathing. Eye irritation can also result from exposure to low concentrations. VPA 000013290 Page 1 -7 Q. What medical attention did they receive? A. The two employees received oxygen and other supportive treatment in the Emergency Room upon arrival at St. Patrick's and were held overnight for observation. While in the hospital, they underwent standard tests for symptoms of chlorine gas inhalation. Q. How much material.was released to the atmosphere? A. Approximately 106 pounds of chlorine and 2.4 pounds of vinyl chloride were released. Q. What were the weather conditions at the time of the release? A. Winds were from the northeast at about 5 to 7 mph. It was cloudy and the temperature was between 45 and 50 degrees. Q. What is chlorine? A. Chlorine is a heavy, greenish yellow gas, with a pungent, irritating odor. Vista uses it in the VCM Plant as a basic feedstock in the manufacture of vinyl chloride monomer, or VCM. Q. Is chlorine a hazardous chemical? A. Chlorine has been classified by the Environmental Protection Agency as one which could produce adverse health effects if accidentally released. Q. What are the health effects of chlorine? A. Chlorine has an irritating, pungent odor and is detectable at very low concentrations. Because it is intensely irritating, a person would not remain voluntarily in dangerous concentrations. High exposures can damage tissues in the respiratory system; severe exposures could prove fatal. Q. What is vinyl chloride? A. Vinyl chloride monomer is a highly volatile, colorless gas. Under adverse conditions, VCM vapors can form flammable mixures in air. VCM is produced at the VCM Plant and is a key feedstock for the manufacture of polyvinyl chloride, or PVC, a common plastic with hundreds of industrial and consumer uses. UFA 0 0 iJ 013291 Page 2 Q. Is vinyl chloride a hazardous chemical? A. Vinyl chloride has been classified as a volatile organic compound and is a regulated, hazardous air pollutant and a known carcinogen. Q. What are the health effects of vinyl chloride? A. High levels of exposure to VCM over long periods of time can cause cancer in humans. VCM rapidly disperses in the atmosphere to low concentrations, however, and it is unlikely that hazardous concentrations would be encountered beyond the immediate area of release. Q. When was the release reported, and to whom? A. The incident was reported to the appropriate state and federal authorities within a few hours of the release, as required by law. Q. What caused the problem? A. That is currently under investigation. Q. What measures are being taken to avoid a recurrence of this event? A. Remedial measures are being investigated. Q. Is this a lost time accident? A. No. The two men were released from observation the morning following the incident, and could report to work at their regular shift times. #### A gpA unOQO13292 Page 3 To: Distribution 4 Interoffice Communication From: Date: Jim Rutledge June 10, 1986 Subject: OSHA Hazard Communication Program If-Needed Statements Site-specific if-needed statements on the OSHA Hazard Communication Program have been approved for the following Vista plants: Aberdeen (previously issued) Lake Charles LAB Lake Charles VCM Hammond Oklahoma City This memo transmits "official11 copies of the appropriate statement(s) for your files. Final if-needed statements for the remaining plants will be forwarded when they have been approved. DISTRIBUTION: RWS, RAC, JDM, JBM, HDG cc: RTF, TGG, WLM, MSR, DAK U 000013293 If-Needed Statement OSHA's Worker Hazard Communication Standard Lake Charles LAB Plant Date approved for use: June 4,1986 Sunday, May 25, was the deadline for full compliance with the new Hazard Com munication Program promulgated by the U.S. Occupational Safety and Health Ad ministration (OSHA). This standard requires ail manufacturers, transporters and users of a wide range of listed chemicals to develop procedures for evaluating the workplace hazards of those chemicals pertinantto their operations, following spe cific OSHA guidelines, and to produce or obtain a material safety data sheet (MSDS) for each. In addition, all workplace containers with hazardous chemicals must meet expanded labeling requirements. Finally, all employees handling or working with hazardous chemicals must receive training in the specific hazards associated with those materials. Vista Chemical fully supports the purpose of the new standard, which is to provide effective communication of potential hazards to workers, customers and others handling hazardous chemicals. Although Vista had to implement certain administrative measures to fully comply with the final regulations-such as posting additional signs in our plants for specific chemical hazards and obtaining updated or expanded MSDSs from our suppliers-the company has long been a leader in com plying with the goal of the regulations. For example, even prior to Vista's forma tion in 1 984, when it purchased the assets of Conoco Chemicals from Du Pont, the company had taken the lead in preparing MSDSs for its products. The company's regular safety training programs for employees and others working in our plants have for many years provided information on specific chemical hazards at each location. The new measures only add to Vista's existing workplace hazard com munication efforts. All plants operated by Vista Chemical Company are in full compliance with OSHA's new Worker Hazard Communication Standard. * Use the following material only in response to specific questions from the media: Q #1. What hazardous chemicals do you have in your plant? A #1. Although none of the finished products leaving the LAB Plant-linear alkylbenzenes (or detergent intermediates)-are considered hazardous by OSHA stan- Page 1 dards, we do use large volumes of certain hazardous chemicals in our plant, such as hydrofluoric acid and benzene. In addition, we have smaller quantities of chlorine and sulfuric acid for cooling water treatment and potassium hydroxide for acid neutralization. Q #2. How has the new standard been implemented in your plant? A #2. We have evaluated the hazardous properties of each of the chemicals used in our plant, prepared or obtained the required MSDSs from our suppliers and taken steps to label all containers holding these chemicals or to post all areas of the plant where they are present. Plans are already underway to update our existing em ployee training programs to include information on additional chemical hazards. We at Vista are proud of our long record as a leader in the chemical industry for maintaining a safe and hazard-free workplace for all our employees and the local community. We welcome and support measures such as the new OSH A standards, whose purpose is to increase the safety of all who manufacture, transport or use hazardous chemicals through more effective communication about their potential hazards. #### f age 2 UhA GOOuiiZVS If-Needed Statement OSHA's Worker Hazard Communication Standard Lake Charles VCM Plant Date approved for use: June 4,1986 Sunday, May 25, was the deadline for full compliance with the new Hazard Com munication Program promulgated by the U.S. Occupational Safety and Health Ad ministration (OSHA). This standard requires all manufacturers, transporters and users of a wide range of listed chemicals to develop procedures for evaluating the workplace hazards of those chemicals pertinant to their operations, following spe cific OSHA guidelines, and to produce or obtain a material safety data sheet (MSDS) for each. In addition, all workplace containers with hazardous chemicals must meet expanded labeling requirements. Finally, all employees handling or working with hazardous chemicals must receive training in the specific hazards associated with those materials. Vista Chemical fully supports the purpose of the new standard, which is to provide effective communication of potential hazards to workers, customers and others handling hazardous chemicals. Although Vista had to implement certain administrative measures to fully comply with the final regulations-such as posting additional signs in our plants for specific chemical hazards and obtaining updated orexpanded MSDSsfrom oursuppliers-the company has long been a leader in com plying with the goal of the regulations. For example, even prior to Vista's forma tion in 1984, when it purchased the assets of Conoco Chemicals from Du Pont, the company had taken the lead in preparing MSDSs for its products. The company's regular safety training programs for employees and others working in our plants have for many years provided information on specific chemical hazards at each location. The new measures only add to Vista's existing workplace hazard com munication efforts. All plants operated by Vista Chemical Company are in full compliance with OSHA's new Worker Hazard Communication Standard. Use the following material only in response to specific questions from the media: Q #1. What hazardous chemicals do you have in your plant? A #1. The VCM Plant uses and produces several chemicals which are considered hazardous by OSHA standards. We handle large volumes of vinyl chloride monomer * Page 1 VPA 000013296 * (VCM), ethylene dichloride, hydrogen chloride and ethylene. Two by-products, heavy ends and light ends, are present in smaller quantities. In addition, we use rel atively small quantities of many other chemicals, such as water treatment chemicals, acids and sodium hydroxide, which are considered hazardous by OSHA. All of the chemicals used in the VCM Plant are handled in accordance with estab lished safety procedures, developed to assure continuous safe plant operation. Q #2. How has the new standard been implemented in your plant? A #2. We have evaluated the hazardous properties of each of the chemicals used in our plant, prepared or obtained the required MSDSs from our suppliers and taken steps to label all containers holding these chemicals or to post all areas of the plant where they are present. Plans are already underway to update our existing em ployee training programs to include information on additional chemical hazards. We at Vista are proud of our long record as a leader in the chemical industry for maintaining a safe and hazard-free workplace for all our employees and the local community. We welcome and support measures such as the new OSHA standards, whose purpose is to increase the safety of all who manufacture, transport or use hazardous chemicals through more effective communication about their potential hazards. #### 'vVA 00001329? Page 2 A If-Needed Statement OSHA's Worker Hazard Communication Standard Hammond Plant Date approved for use: June 4,1986 Sunday, May 25, was the deadline for full compliance with the new Hazard Com munication Program promulgated by the U.S, Occupational Safety and Health Ad ministration (OSHA). This standard requires all manufacturers, transporters and users of a wide range of listed chemicals to develop procedures for evaluating the workplace hazards of those chemicals pertinant to their operations, following spe cific OSHA guidelines, and to produce or obtain a material safety data sheet (MSDS) for each. In addition, all workplace containers with hazardous chemicals must meet expanded labeling requirements. Finally, all employees handling or working with hazardous chemicals must receive training in the specific hazards associated with those materials. Vista Chemical fully supports the purpose of the new standard, which is to provide effective communication of potential hazards to workers, customers and others handling hazardous chemicals. Although Vista had to implement certain administrative measures to fully comply with the final regulations-such as posting additional signs in our plants for specific chemical hazards and obtaining updated or expanded MSDSs from our suppliers-the company has long been a leader in com plying with the goal of the regulations. For example, even prior to Vista's forma tion in 1984, when it purchased the assets of Conoco Chemicals from Du Pont, the company had taken the lead in preparing MSDSs for its products. The company's regular safety training programs for employees and others working in our plants have for many years provided information on specific chemical hazards at each location. The new measures only add to Vista's existing workplace hazard com munication efforts. All plants operated by Vista Chemical Company are in full compliance with OSHA's new Worker Hazard Communication Standard. Use the following material only in response to specific questions from the media: Q #1. What hazardous chemicals do you have in your plant? A #1. Two of the products shipped from the Hammond Plant, namely sulfonic acid and slurry (neutralized sulfonic acid), are considered mildly hazardous by OSHA Page 1 MPA. GOOD 132'?8 * standards. Two raw materials, sulfur trioxide and sodium hydroxide, used in pro cessing and stored in moderate amounts in the plant, are also considered hazardous by OSHA standards. Q #2. How has the new standard been implemented in your plant? A #2. We have evaluated the hazardous properties of each of the chemicals used in our plant, prepared or obtained the required MSDSs from our suppliers and taken steps to label all containers holding these chemicals or to post all areas of the plant where they are present. Plans are already underway to update our existing em ployee training programs to include information on additional chemical hazards. We at Vista are proud of our long record as a leader in the chemical industry for maintaining a safe and hazard-free workplace for all our employees and the local community. We welcome and support measures such as the new OSHA standards, whose purpose is to increase the safety of all who manufacture, transport or use hazardous chemicals through more effective communication about their potential : hazards. #### Page 2 VPA 0000132??- A If-Needed Statement OSHA's Worker Hazard Communication Standard Oklahoma City Plant Date approved for use: June 4,1986 Sunday, May 25, was the deadline for full compliance with the new Hazard Com munication Program promulgated by the U.S. Occupational Safety and Health Ad ministration (OSHA). This standard requires all manufacturers, transporters and users of a wide range of listed chemicals to develop procedures for evaluating the workplace hazards of those chemicals pertinant to their operations, following spe cific OSHA guidelines, and to produce or obtain a material safety data sheet (MSDS) for each. In addition, all workplace containers with hazardous chemicals must meet expanded labeling requirements. Finally, all employees handling or working with hazardous chemicals must receive training in the specific hazards associated with those materials. Vista Chemical fully supports the purpose of the new standard, which is to provide effective communication of potential hazards to workers, customers and others handling hazardous chemicals. Although Vista had to implement certain administrative measures to fully comply with the final regulations-such as posting additional signs in our plants for specific chemical hazards and obtaining updated or expanded MSDSs from our suppliers-the company has long been a leader in com plying with the goal of the regulations. For example, even prior to Vista's forma tion in 1984, when it purchased the assets of Conoco Chemicals from Du Pont, the company had taken the lead in preparing MSDSs for its products. The company's regular safety training programs for employees and others working in our plants have for many years provided information on specific chemical hazards at each location. The new measures only add to Vista's existing workplace hazard com munication efforts. All plants operated by Vista Chemical Company are in full compliance with OSHA's new Worker Hazard Communication Standard. Use the following material only in response to specific questions from the media: Q #1. What hazardous chemicals do you have in your plant? A #1. The OKC Plant manufactures a single grade of polyvinyl chloride (PVC) resin which is not considered hazardous by OSHA standards; however, we do handle UPA 0000,12300 Page 1 A large volumes of hazardous chemicals in the plant, principally vinyl chloride mon omer. In addition, we maintain relatively small quantities of many other chemicals which OSHA has listed as hazardous. Q #2. How has the new standard been implemented in your plant? A #2. We have evaluated the hazardous properties of each of the chemicals used in our plant, prepared or obtained the required MSDSs from our suppliers and taken steps to label all containers holding these chemicals or to post all areas of the plant where they are present. Our employee training programs have been expanded to comply with the new OSHA standard. We at Vista are proud of our long record as a leader in the chemical industry for maintaining a safe and hazard-free workplace for all our employees and the local community. We welcome and support measures such as the new OSHA standards, whose purpose is to increase the safety of all who manufacture, transport or use hazardous chemicals through more effective communication about their potential hazards. #### UPA GOODi3301 Page 2 to: Distribution A Interoffice Communication Prom: Date: Jim Rutledge June 2, 1986 subject: OSHA Hazard Communication If-Needed Statement The attached if-needed statement, prepared at the request of Aberdeen plant management, has been approved for use should that plant receive any media queries on the new OSHA Hazard Communication Program. Note that most of the material is applicable to any Vista plant; only the answer to Ql is spe cifically geared for Aberdeen. Ralph Ferrell asked me to work with the other plants on de veloping a comparable site-specific response for each Vista location. Could you review the statement, including the "Aberdeen" an swer, and help me prepare a similar response for your plant? Thanks for your reply by Thursday, June 5, or sooner. DISTRIBUTION: Plant Managers (except Aberdeen) cc: RTF, JF, JWW, TGG, WLM, MSR, DAK v'PA 00001330* /f-Needed Statement OSHA's Worker Hazard Communication Standard Aberdeen Plant Date approved for use: June 2,1986 Sunday, May 25, was the deadline for full compliance with the new Hazard Com munication Program promulgated by the U.S. Occupational Safety and Health Ad ministration (OSHA). This standard requires all manufacturers, transporters and users of a wide range of listed chemicals to develop procedures for evaluating the workplace hazards of those chemicals pertinantto their operations, following spe cific OSHA guidelines, and to produce or obtain a material safety data sheet (MSDS) for each. In addition, alt workplace containers with hazardous chemicals must meet expanded labeling requirements. Finally, all employees handling or working with hazardous chemicals must receive training in the specific hazards associated with those materials. Vista Chemical fully supports the purpose of the new standard, which is to provide effective communication of potential hazards to workers, customers and others handling hazardous chemicals. Although Vista had to implement certain administrative measures to fully comply with the final regulations-such as posting additional signs in ourplantsforspecific chemical hazards and obtaining updated or expanded MSDSs from our suppliers-the company has long been a leader in com plying with the goal of the regulations. For example, even prior to Vista's forma tion in 1984, when it purchased the assets of Conoco Chemicals from Du Pont, the company had taken the lead in preparing MSDSs for its products. The company's regular safety training programs for employees and others working in our plants have for many years provided information on specific chemical hazards at each location. The new measures only add to Vista's existing workplace hazard com munication efforts. All plants operated by Vista Chemical Company are in full compliance with OSHA's new Worker Hazard Communication Standard. Use the following material only in response to specific questions from the media: Q #1. What hazardous chemicals do you have in your plant? A #1. Although none of the products leaving the Aberdeen plant-various grades of polyvinyl chloride (PVC) resins, dryblends and compounds-are considered hazardous 000013 Qo Page 1 A by OSHA standards, we do handle large volumes of certain hazardous chemicals, such as vinyl chloride and some alcohols. In addition, we maintain relatively small quantities of many other chemicals, such as compounds of lead, antimony and acids, which OSHA has listed as hazardous. Q #2. How has the new standard been implemented in your plant? A #2. We have evaluated the hazardous properties of each of the chemicals used in our plant, prepared or obtained the required MSDSs from our suppliers and taken steps to label all containers holding these chemicals or to post all areasof the plant where they are present. Plans are already underway to update our existing em ployee training programs to include information on additional chemical hazards. We at Vista are proud of our long record as a leader in the chemical industry for maintaining a safe and hazard-free workplace for all our employees and the local community. We welcome and support measures such as the new OSHA standards, whose purpose is to increase the safety of all who manufacture, transport or use hazardous chemicals through more effective communication about their potential hazards. #### MPA 0000 1 3;-;Q4 Page 2 To: Distribution * 0 Interoffice Communication From: Date: Subject: Jim Rutledge March 13, 1985 If-Needed Statement for VCM Release The attached If-Needed Statement has been approved for use should we receive any media queries on the subject release. DISTRIBUTION: Timberway: TGG, WLM, RDG, REL, DAK, MSR, JCB, DLM Lake Chas: RTF, JDM, RAC -f * If-Needed Statement Title: VCM release Location: Lake Charles VCM plant Date approved for use: 3/12/86 At approximately 7:30 p.m. on Monday, March 10,1986, Vista Chemical Com pany's Lake Charles VCM (Vinyl Chloride Monomer) Plant experienced a release of vinyl chloride. The release is estimated to he approximately 1,023 lbs. The release was detected by the plant's fixed point monitoring system and the situation was corrected within 15 minutes. Plant personnel responding to the inci dent put on the proper protective gear, including respiratory protection equipment. No employees were injured during this release. Prior to donning their protective equipment, up to four employees may have received minimal VCM exposure. VCM is normally a gas, but is stored and handled as a pressurized liquid in the VCM Plant. Immediately upon release, the VCM vaporized and dissipated into the atmosphere. The exact cause of the release is under investigation, but is thought to be the failure of a sample connection nozzle. Corrective actions are under study. Theap- : propriate state and federal authorities were notified. Use the following material ONLY in response to specific questions from the media: Q. What were the weather conditions at the time of the release? A. Variable winds between 5 and 10 mph were blowing from the south-southeast, which provided adequate atmospheric conditions for prompt and complete disper sion of the vaporized VCM. Q. Isn't VCM a carcinogen? A. Studies indicate long-term exposure to high levels of vinyl chloride can increase incidence of angiosarcoma, a rare liver cancer, in humans. It is our policy to mini mize employee exposures, and to comply with all OSHA standards regarding VCM exposure. Q. How dangerous was the release? A. VCM concentrations resulting from this emission are not believed to be harmful to the environment, nor acutely toxic. Because it is a gas under normal atmospheric pressure and temperature, VCM dissipates quickly into the atmosphere, leaving little or no residual material in the surrounding area. Because of its low solubility in water, VCM would not be absorbed in appreciable amounts in natural water. #### Page 1 MPA 000013306 to: Plant managers, communication contacts A* Interoffice Communication From: Date: Jim Rutledge February 28, 1986 Subject: If-Needed document on Air Emissions The attached "If-Needed" document has been prepared for use in answering media inquiries on air emissions should the need arise. It contains specific reference information on the major chemicals made or used at Vista's plants, along with approved responses to questions that would likely be encountered during press interviews. This document updates and expands on the material included in our earlier 'if-Needed" Statement on Bhopal ("Recommend ed Response to Media Queries re Bhopal Disaster" from Peg Donahue, dated January 2, 1985). Please destroy all copies of that statement and replace them with the present docu ment. If you have any questions regarding the attached material or need assistance in responding to a media .inquiry, please let us know. Please also continue to keep us advised of all local press calls or contacts. Thanks for your help. cc: JDB, REL, RDG, TGG, WLM, DAK, MSR, JCB, DLM !-'Ph 000013307 A If-Needed Statement AIR EMISSIONS All Vista plant locations Date approved for use: 2/28/86 [Rev. 4/23/86] Use the following material only in response to specific questions from the media: Does Vista use or manufacture hazardous chemicals? Vista Chemical uses and manufactures a number of chemicals in volumes large enough to be of concern in the event of an emergency. However, these chemicals are strictly controlled and monitored. Our plants have been carefully designed and built to handle them safely. Our employees who work with these chemicals have received detailed special training. All of these precautions make an accident which could injure a member of the public extremely unlikely. Do you routinely release any of these chemicals to the atmosphere? Yes. Air emissions from our manufacturing processes are regulated by state and federal environmental agencies. These agencies have issued permits to Vista regulating our air emissions. Vista currently operates under 43 different environmental permits which specify allowable air emissions for chemicals ranging from sulfur dioxide and nitrogen oxide, which come from fuel burning processes such as steam generation, to hydrocarbon products. In addition, two compounds produced and used extensively by Vista-benzene and vinyl chloride monomer-are stringently regulated under the Clean Air Act as hazardous air pollutants. The amount of permitted emissions is generally determined by health effects data and by best available control technologies for our manufacturing processes. How can you justify releasing these hazardous chemicals, some which are known cancer-causers, into the atmosphere on a routine basis? Vista Chemical and the regulating agencies believe that the permitted quantities will not harm the employees who work in our plants or members of the public and the environment nearby. THIS PAGE REVISED 4/23/86 Page 1 MKr 00001330 Air Emissions The chemicals we use or manufacture are well understood, common chemicals which have been used for years throughout the industry and which have been studied at length. The effects of exposure to them are well known. Safety and health precautions for properly handling them have been developed, installed and regularly tested at our plants. Our plants' emissions are controlled so that the concentration of cancer-suspect chemicals in the air in the plants is as low as feasible, typically less than one part per million. With those concentrations in our plants, we know the concentrations in the air further away from our plants are even lower. Chemicals which have been shown to cause cancer have done so only at relatively high concentrations over long periods of time. Based on the large amount of scientific data available from studies done over the past two decades, low level or short term exposure to these chemicals does not create a hazard. We believe there is a more than adequate margin of safety for our employees and the public. The amounts of these chemicals routinely released have been greatly reduced over ; the years, because it makes good business sense and because of more rigorous governmental regulations. We've spent more than $3.2 million in the past five years just to protect the air around ail our plants. A Why is it necessary to release these chemicals to the atmosphere? Why don't you just make your plants leak-proof? It's not possible to make a chemical plant 100 percent leakproof. We employ the best available technology and operating procedures to keep emissions at very low levels which are safe for employees and the neighbors of our plants. Besides the routine releases to the atmosphere, do you have accidental releases? Very infrequently. We must immediately report these releases in accordance with the appropriate state or federal regulations. No accidental release of a chemical from a Vista Chemical plant has ever caused a death or serious injury to a member of the public. We've studied the causes of these releases and have made engineering or operational changes to prevent their recurrence. 00t33Q9 Page 2 Air Emissions Why haven't you reported these releases to people in the communities surrounding your plants? Because the releases have not been of a quantity which would cause injury to the public, and an evacuation of the community has never been required as a result of the releases. K Could such an accidental release lead to a Bhopal-type accident at one of your plants? Because the chemicals we handle are not as toxic as methyl isocynate (MIC), and because of the strict controls and procedures we use in our manufacturing processes, we believe that that the possibility of an incident similar to that which happened in Bhopal is very remote. Our plants are well-designed and are maintained, inspected and operated by well-trained, experienced personnel. In the event of a large gas release, a catastrophic loss of life (such as occurred in Bhopal) is highly unlikely because we do not have any materials as toxic as methyl isocynate. In addition, we have emergency procedures for dealing with gas leaks if one were to occur and we are working with local authorities to improve procedures for protecting the public in the event of an emergency. Have you made any changes as a result of Bhopal? Due to the extent of the tragedy at Bhopal, we instituted a formal program to reassess our existing safety systems and emergency procedures. This assessment included a study of materials present in the plant, our handling, processing and storage of those materials, employee training and emergency response procedures. We wanted to be certain that we are operating our plants in a manner that is safe and which will prevent any tragedy from occurring in our plant communities. We've also broadened our studies to include the surrounding communities. Our work at our Lake Charles plants is a good example. We have joined together with other local industry members as well as medical, governmental, police and fire agencies in a committee to improve our communication and understanding. That committee is examining such topics as availability of emergency medical care, a direct public warning system and evacuation routes which might be needed in the unlikely event of a major catastrophe. vJPA 0000 13310 Page 3 Air Emissions * What sort of warning system or evacuation procedure do you have for the public? Current procedures call for alerting and providing assistance to local authorities who have the authority to handle evacuation in the event of a disaster. At our Lake Charles complex, we are connected by special phones with other major plants and governmental agencies in the area, so that we can warn or be warned of emergencies. More direct methods of notifying people in the surround communities are being studied. Which chemicals listed by the EPA, or otherwise classified as acutely toxic, does Vista Chemical use or manufacture? 1. Chlorine is used as a feedstock at our Lake Charles VCM Plant and the Baltimore, Maryland, LAB (linear alkylbenzene) Plant. 2. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant 3. Hydrogen fluoride is used as a catalyst at our Lake Charles LAB Plant 4. Sulfur trioxide is used as a feedstock at our Hammond, Indiana, Premium Sulfonation Plant. 5. Hydrogen chloride is used as a feedstock at our Lake Charles Chemical Plant and at our Lake Charles VCM (vinyl chloride monomer) Plant. Muriatic acid, its liquid form, is manufactured at our Baltimore, Maryland, LAB (linear alkylben zene) Plant; a small amount is also produced in our VCM Plant incinerator unit. In addition, we use or manufacture much smaller quantities of: 1. Sulfur dioxide 2. Nitric acid 3. Sulfuric acid 4. Isopropanol (Isopropyl alcohol) 5. Methanol (methyl alcohol) [See reference section for more detail.] Which of the chemicals you use or manufacture are volatile organic compounds? 1. Ethylene dichloride (EDC) and THIS PAGE REVISED 4/23/86 YPA 000013311 Page 4 Air Emissions * 2. Vinyl chloride monomer (VCM) are made at our Lake Charles VCM Plant. VCM is also used as a feedstock at our Aberdeen, Mississippi, and Oklahoma City, Oklahoma, PVC plants. 3. Benzene is a feedstock at our Baltimore, Maryland, and Lake Charles LAB (linear alkylbenzene) plants, and a byproduct containing benzene is manufactured at our Lake Charles Chemical Plant. 4. Methyl chloride is manufactured at our Lake Charles Chemical Plant. 5. Ethylene oxide is used as a feedstock at our Lake Charles Chemical Plant. 6. Ethylene is manufactured at our Lake Charles Chemical Plant and is used as a feedstock at that plant and at the Lake Charles VCM Plant. 7. Butadiene is manufactured as a byproduct at our Lake Charles Chemical Plant. 8. Propylene is manufactured as a byproduct at our Lake Charles Chemical Plant. 9. Various light alcohols, such as butanol, are manufactured at our Lake Charles Chemical Plant. In addition, we use or manufacture much smaller quantities of: 1. Methanol (methyl alcohol) 2. Toluene 3. Xylene 4. Chloroform 5. Isopropanol (Isopropyl alcohol) [See reference section for more detail.1 What do you do about tiny leaks, ones that are so small that even people working in the plant would not notice? We have a system of fixed point monitors in our plants to detect quantities of the of the most hazardous VOCs in the air as small as one part per million, or less. When these chemicals are detected, an operator is notified. Then, employees using portable detection equipment can pinpoint the leak and repair it. MPA 0 000 1 3312 Page 5 Air Emissions Reference Section Key: VOC = Volatile Organic Compounds EPA 402 = Chemicals listed by the EPA as "acutely toxic." * Chemicals which Vista uses or makes in large quantities Chlorine Chlorine is a major feedstock at our Lake Charles VCM (vinyl chloride monomer) Plant, arriving by pipeline or rail tank car. We use it to make vinyl chloride monomer, the major ingredient in polyvinyl chloride (PVC), a plastic with hundreds of uses from vinyl siding and food packaging to plastic pipe and record albums. Chlorine is also used as a feedstock at our Baltimore, Maryland, LAB (linear alkylbenzene) Plant to make a major ingredient in industiral and household cleaning products, such as detergents. Its most common usage is in water treatment plants. Chlorine is a heavy, greenish-yellow gas at normal temperatures and has a pungent, irritating odor which is detectable at very low levels. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high concentrations can damage tissues in the respiratory system resulting in breathing difficulties. Severe exposures could be fatal. Chlorine is also present at most of our other plants in cylinder quantities for water treatment purposes. EPA 402 Hydrogen fluoride (HF) Hydrogen fluoride is used as a catalyst at our Lake Charles LAB (linear alkylbenzene) Plant. It arrives at the plant by truck. We use it to make the chief active ingredient in such products as laundry detergents and dishwashing liquids. It is a colorless fuming liquid which rapidly vaporizes in the atmosphere to a gas, which reacts with moisture in the air to form a visible cloud. HF is very irritating to the skin, eyes and respiratory tract at low concentrations. Exposure to high concentration in air can burn the skin and damage lung tissue. Lung damage resulting from severe exposures could be fatal. EPA 402 ypA 000013313 Page 6 Air Emissions A Sulfur trioxide (SO3) It is a major feedstock at our Hammond, Indiana, Premium Sulfonation Plant. We use it to make the active ingredients in such products as laundry detergents and dishwashing liquids. It comes to our plant through a pipeline from the Stauffer Chemical plant adjacent to our property. Sulfur trioxide is a colorless, fuming liquid that reacts with moisture in the air to form a visible sulfuric acid mist. This mist is odorless, but is very irritating at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. E PA 402 Ethylene Oxide (EO) Ethylene oxide is a feedstock in the ethoxylation unit at the Lake Charles Chemical: Plant. We use it to make ingredients which have a multitude of uses, including cleaning and personal care products. It is shipped to our plant by rail tank car. Ethylene oxide is a highly flammable and reactive gas at room temperature. We handle it under pressure in a liquid form. At high concentrations, it has an ether like pungent odor and is irritating to the eyes, nose and throat. Exposure to extremely high concentrations may result in lung injury and accumulation of fluid in the lungs and death. It is regulated as a cancer-causing agent. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. EPA402, VOC Vinyl chloride monomer (VCM) Vinyl chloride monomer is produced at our Lake Charles VCM Plant, and is a key feedstock at our Aberdeen, Mississippi and Oklahoma City PVC plants. VCM is shipped from Lake Charles and arrives at Aberdeen and Oklahoma City by rail tank car. We use it to make polyvinyl chloride (PVC), a plastic with hundreds of uses from vinyl siding and food packaging to plastic pipe and record albums. Vinyl chloride monomer (VCM) is a colorless gas and a liquid under pressure. Vapors can form flammable mixtures in air. Burning VCM generates hydrogen chloride (HC1), a Page 7 UFA 000013314 Air Emissions strongly irritating gas which, in high concentrations, can damage tissues in the respiratory system. High levels of exposure to VCMover long periods of time can cause cancer in humans. VCM is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC A Benzene Benzene is a key feedstock at our Baltimore, Maryland, and Lake Charles LAB (linear alkylbenzene) plants. We use it to make LAB, the active ingredient in many household and industrial detergents and other cleaning products. It arrives at Baltimore by barge and tank truck, and at Lake Charles by rail tank car and tank truck. In addition, we manufacture a relatively small quantity of benzene in our ethylene unit at the Lake Charles Chemical Plant. Benzene is a clear, colorless liquid with a aromatic odor. It can form explosive and flammable mixtures with air. Overexposure can cause dizziness, nausea, vomiting, unconsciousness. Severe exposure for 15 to 30 minutes may be fatal. High levels of exposure over long periods of time are believed to cause cancer in humans. VOC Methyl chloride Methyl chloride is made at our Lake Charles Chemical Plant. It is used by our customers to make products such as synthetic rubber, silicones and refrigerants. It is shipped from our plant by rail tank car. It is a colorless liquid or gas with a faint, ether-like odor and sweet taste. Severe exposures may result in narcotic effects, such as dizziness, and affect other body systems, such as the kidneys, liver and blood. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC Ethylene dichloride (EDC) Ethylene dichloride (EDC) is manufactured at our Lake Charles VCM (vinyl chloride monomer) plant. We then use it to make VCM, the key ingredient in a common plastic, PVC (polyvinyl chloride). We use it all on site and do not routinely ship any outside the plant. After it is made, it is held in tanks until it is needed in Page 8 UFA 000013315 Air Emissions A the VCM manufacturing process. It is a colorless, oily liquid with a chloroform-like odor. High exposure can cause intoxication, nausea, vomiting and depression of the central nervous system. Severe exposures may affect other body systems such as the kidneys and liver. The National Institute for Occupational Safety and Health has recommended that it be handled in the workplace as if it were a carcinogen in man. voc Hydrogen chloride (HCI) [muriatic acid] Hydrogen chloride (HCI) is used at our Lake Charles Chemical Plant to manufacture methyl chloride, an ingredient in such products as synthetic rubber, silicones and re frigerants. Mixed with water, it forms muriatic acid. The Lake Charles VCM Plant uses HCI in the production of vinyl chloride monomer (VCM), and also produces med ium strength (15-22%) muriatic acid in its incenerator unit. Muriatic acid is manu factured at our Baltimore, Maryland, LAB (linear alkylbenzene plant). We ship it from the plant in rubber-lined tank cars. Muriatic acid is used in processing metals and gelatin and making pharmaceuticals and chemicals to develop photographs. Hydrogen chloride is a colorless gas, but reacts with moisture in the air to form a vis ible cloud. It has an irritating, pungent odor and is detectable at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High exposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal. Ethylene Ethylene is manufactured at our Lake Charles Chemical Plant and is used as a feedstock at that plant to make industrial alcohols and at the Lake Charles VCM (vinyl chloride monomer) Plant to make VCM, the major ingredient in a common plastic, PVC (polyvinyl chloride. We transfer it by pipeline and do not routinely ship it out of the Lake Charles complex. It is a colorless flammable gas with a sweet odor at high concentrations. It is a simple asphyxiant, meaning that it displaces oxygen in the air. Severe exposure may result in narcotic effects, such as dizzyness, progressing to unconsciousness due to lack of oxygen. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC THIS PAGE REVISED 4/23/86 ........... Page 9 Air Emissions A Alcohols, light Light alcohols, including butanol, ethanol and hexanol are manufactured at our Lake Charles Chemical Plant. We ship them by tank cars, tank trucks and in drums They are used to make various industrial and consumer products including plasticizers (chemicals which make plastics flexible). These are colorless flammable liquids with a sweet pungent odor. Exposure to high vapor concentrations may cause irritation to the eyes, nose and throat. Severe exposures will result in narcotic effects, such as dizziness, leading to unconsciousness. VOC Propylene Propylene is manufactured at our Lake Charles Chemical Plant. We ship it by railcar to other chemical manufacturers who use it to make a variety of products, including plastics. It is a colorless flammable gas with a sweet odor at high ; concentrations. It is a simple asphyxiant, meaning that it displaces oxygen in the air. Severe exposure may result in narcotic effects, such as dizzyness, progressing to unconsciousness due to lack of oxygen. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC Butadiene Butadiene is manufactured at our Lake Charles Chemical Plant. We ship it by railcar to other chemical manufacturers who make a variety of products, including synthetic rubber. It is a colorless flammable gas with an aromatic odor. Inhalation of high concentrations is irritating to the eyes, nose and throat. Severe exposures may result in narcotic effects, such as dizziness, leading to unconsciousness. These effects could potentially be fatal. Exposure to high concentrations over long periods of time has been shown to cause tumors in laboratory animals. This chemical is highly volatile and disperses rapidly in the atmosphere to low concentrations. Therefore, it is unlikely that hazardous concentrations would be encountered outside the plant boundaries. VOC UpA 00001331? Page 10 Air Emissions Other chemicals Vista uses or makes, but in relatively small quantities A Sulfur dioxide Sulfur dioxide (S02) is a byproduct produced at our Hammond, Indiana, Premium Sulfonation Plant, where we make the active ingredients in such products as laundry detergents and dishwashing liquids. We send the sulfur dioxide through a pipeline to the Stauffer Chemical plant adjacent to our property. It is a colorless, nonflammable gas with a strong suffocating odor. It dissolves in water to form weak but corrosive sulfurous acid. This mist is odorless, but is very irritating at low concentrations. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. Exposure to high levels can damage tissues in the respiratory system. Lung damage resulting from severe exposures could be fatal. EPA 402 Methanol (methyl alcohol) We use methanol as a feedstock at the Lake Charles Chemical Plant to make methyl chloride, an ingredient in synthetic rubber, gasoline octane improvers, silicones and refrigerants. It is brought to our plant by barge. It is a clear colorless flammable liquid with an alcohol odor. Overexposure can result in dizziness, visual impairment, nausea, and irritation of the eyes nose and throat. Severe exposures could result in unconsciousness and respiratory failure. EPA 402, VOC Nitric acid It is used in small quantities in laboratories or as a process additive at several ofour plants. It is a fuming colorless or yellow corrosive liquid. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High exposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal. E PA 402 Sulfuric acid It is used in small quantities i n laboratories or as a process additive or processing aid at several of our plants. It is a dense, oily, colorless, odorless liquid that is strongly Page 11 MPA 000013318 Air Emissions * corrosive and nonflammable. Because it is intensely irritating, you would not remain voluntarily in dangerous concentrations. High exposure can damage tissues in the respiratory system and cause breathing difficulties. With severe exposures, these effects may be fatal, E PA 402 Toluene Xylene Toluene and xylene are used as feedstocks at our Baltimore LAB (linear alkylbenzene) plant to make ingredients for industrial and household detergents. They are clear colorless flammable liquids with an aromatic odor. Exposure to high concentrations can cause irritation of the eyes, nose and throat. Severe exposures may result in unconsciousness and could be fatal. These chemicals are volatile and disperse quickly in the environment to low concentrations. VOC Chloroform It is used manufactured in small quantities as a byproduct at our Lake Charles VCM (vinyl chloride monomer) Plant and is used in small quantities as a laboratory solvent in several of our plants. It is a colorless, clear, nonflammable sweet smelling liquid. High exposures to chloroform may cause headache, dizziness and unconsciousness. Severe, exposures may result in kidney and liver damage. E PA 402 Isopropanol (Isopropyl alcohol) It is used in laboratory quantities at several of our plants. A clear colorless flammable liquid with an alcohol odor. Exposure to high vapor concentrations may cause irritation to the eyes, nose and throat. Severe exposures will result in narcotic effects, such as dizziness, leading to unconsciousness. E PA 402, VOC Page 12 i.jpp, 000013319