Document 8RD97zdrv05ropG67pX1288vd

TO: Mike Nathan ?i/c (sJ/rfrr' FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles March 23, 1988 REACTOR CULL SALES VIST/ Attached is the previous correspondence regarding the sale of PVC reactor culls. The shipping regulation mentioned in the 5/13/87 letter has become effective. The only significant change since May of 1987 is the label content for PVC containers. Current labels for all PVC containers contain a VCM warning. We would want to reemphasize the potential for VCM exposure by way of transmittal letter for the MSDS or with an attachment to a sales contract. Also, the attached MSDS has a 1000 ppm RVCM number listed. This may need to be revised. What do we know about the RVCM ranges? There are product liability concerns with the end-use of this material. We should try to get information regarding what products this off-grade material is put into. \<7N------------------T. G. Grumbles aj o .301 Attachments w. L. McClain R. R. Smith V. E. Messick R. A. Frohreich A. A. Sal ah vvv 000022704 v\prv_^ Thomas G. Grumbles VISTA T E-f\\\O.Oi\ Ccoo-Omo-toas 3 jrzDote Lo^ novu V^cx-m^. 4-V\t- (VrS r^)fZXJr il es* - Toxico\o^ca| Lec<o \jcvA r\\c\c<aA ,_ C-V\l <{<> e.-A e_ \ V fY\ tj VlvSOUU t (- you ujo-->i(D \\Vl-L <Lc<rS>'- ar\L^ 0^- -VWo$. ybu Ca^>ie-i V- a\e.extQ^. 144- VVV 000022705 TO: Distribution v^lc FROM: DATE: Interoffice Communication SURJ: T. G. Grumbles March 21, 1988 ANALYTICAL WORK FOR REGULATORY REQUIREMENTS Based on a review of the list Jim Yates prepared, it is clear that benzene and the PNA's are the chemicals with the potential to appear most often in our products. Therefore, initial efforts should be prioritized towards the analytical work for those two chemicals. From a Proposition 65 standpoint warnings are required now for benzene and will be required beginning in July for the PNA's. If analytical method development is required for the PNA analysis, this should be high priority. Second in priority, based on regulatory deadlines and product volume in commerce, would be EtO and dioxane. We already know a lot about these levels and additional work may only include data gathering, reviewing sampling frequency, and determining if current sampling frequency allows us to generate representative data. Third in priority would be the various chlorinated compounds on the Prop 65 list. These are BCME, CCL4, chloroform, epichlorohydrin, ) PCB's and vinyl chloride. These chemicals have the potential to be present in less volume for commercial purposes, but the warnings will be required in October of this year, except for BCME which is required now. The remaining analytical needs are for DEHP, nickel catalyst fines, lead acetate and arsenic. Arsenic warnings are required now. Attached is a suggested "project" organization based on the priorities described. Also, I've listed several general issues that should be considered. It should be noted that some PCB analysis and benzene in LAB work has been done in response to other regulations in the last two years. In several cases, collection of existing data will be our first step. Please review the enclosed then we'll schedule a conference call to discuss details of the project. \ CT^------------------" T. G. Grumbles aj o .310 Enclosure DISTRIBUTION: Jim Yates I Ron Poe Charlie Starks Wv 000022706 GENERAL ISSUES How do we represent the data? Ranges, accuracy statements, not to exceed ... How do we collect samples and/or how many analysis do we do to assure representative data? How do we validate non-referenced methods? be an issue.) (This may or may not Pro/cons of doing the work or all of the work at an "outside" contract laboratory. Analytical method applicability to different products (i.e., is benzene in LAB method same as benzene in HCL?) Significant data currently exists for dioxane, EtO, and VCM residual levies. Some data exists for benzene and PCB's. VVV 000022707 PROPOSITION 65 CHKMTCAT.S (EFFECTIVE DATE) AND PRODUCTS TO BE ANALYZED - PRIORITY GROUPINGS BENZENE (3/1/88) LAB Hydrotropes Specialty Alkylates AICI3 Liquor Muriatic Acid Sulfonic Acids Na Salt Slurries N-Paraffins Solvents (LPA, MR) HAD LAC Plasticizers ETHYLENE OXIDE (7/1/88) Ether Sulfates ALFONICS PNA's (7/1/88) LAB Hydrotropes Specialty Alkylates AICI3 Liquor Sulfonic Acids Na Salt Slurries N-Paraffins Solvents (LPA, MR) HAD LAC ALFOLS (mp greater than 70F) Plasticizers 1.4 DIOXANE (1/1/89) Ether Sulfates ALFONICS Epichlorohvdrin BCME (10/1/87) (3/1/88) CCL/t Chloroform PCB' s VCM (10/1/88) (10/1/88) (1/1/89) (3/1/88) EDC VCM MECL VCM EDC MECL VCM EDC MECL VCM EDC EDC VCM PVC LAB's MECL EDC PVC LEAD ACETATE (1/1/89) Hydrotopes AICI3 Liquor HCL Sulfonic Acids Ether Sulfates Na Salt Slurries MECL Alumina PVC ARSENIC (3/1/88) Hydrotopes AICI3 HCL Sulfonic Acids Ether Sulfates Na Salt Slurries Ether Sulfates NICKEL CATALYST FINES (10/1/88) ALFOLS ALFONICS Solvents Wv 000022708 C o lle c t d a ta : C orrespond w ith p la n ts In /o u t d e c is io n : d e c is io n on w hether to use o u ts id e c o n tra c t la b o ra to ry The end p ro d u c t w o u ld be a fo rm o r s ta n d a rd response le t t e r LO M H 2 a > P* 3 CD O C8 m T3 03 >H* m rt CP O X in CD 7? 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