Document 6RBngM4R285o7VbXrXvDaRnr1

Vista Chemical Company 900 Threodneedle Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 August 17, 1990 T A! . Mr. David Patti Executive Director Pennsylvania Chemical Industry Council 212 North Third Street, Suite 2 Harrisburg, Pennsylvania 17101 qp VISTA Dear David: As we discussed on the phone, Vista Chemical does not operate in the State of Pennsylvania. We certainly support state chemical organizations where we have plant operations and believe them to be an effective means to influence legislation. However, even though we do market products in Pennsylvania, we cannot support joining the Pennsylvania Chemical Industry Council at this time. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj cc: R. D. Gamblin VVV 000013478 TO: R. D. Gamblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 17, 1990 PROGRESS REPORT 1. EPA has removed the TSCA inventory description and CAS number we are currently using for C-550 Slurry from the TSCA inventory. The inventory status of our product is still intact based on our original 1978 inventory listing for this product and similar products from Hammond, however, we will need to make modifications in our technical literature regarding the chemical description of these products that is most appropriate for inventory purposes. 2. TGG participated in a meeting to review and determine our next step in development of a fetal protection policy for lead. 3. DOT has delayed the implementation of Docket HM-126C, Emergency Response Communication Standards, until January 1, 1991. It is expected that the docket will undergo extensive changes before it is implemented. 4. ERT participated in a meeting of the Environmental Engineering Guidelines Team. The proposed guidelines for equipment in Hazardous material service not in RCRA will be submitted to management for comments. 5. JCL attended the CMA Phthalate Esters Panel meeting to discuss regulatory activities impacting phthalate plasticizers. EPA has recently proposed drinking water standards for DEHP, butylbenzyl phthalate, di-butyl-, di-ethyl-, and di-methyl phthalates. No standards were proposed for 6-10P components. DEHP seems to be getting considerable regulatory attention due its high production volume and health effects. 6. Guidance was issued to LCCP on the impact of the Distillation New Source Performance Standard in EXAM and the Alcohol Plant. In both cases, the effect is minimal. 7. JCL advised Management of Conoco's proposal for splitting the cost of doing a remedial investigation of the Aberdeen Superfund site. It was agreed to split the cost 90/10 Conoco/Vista for this phase of the study. Conoco also agreed to pay the complete cost of removal and disposal of the drums buried on the site. 8. Briefed the Surfactants Steering Team on the effort to do a SARA 313 delisting petition for di-n-octyl phthalate. The plan is to have data accumulated to support the petition by the end of October. Held a conference call with Aristech on the same subject. \ o---------- T. G. Grumbles dlj VVV 000013479