Document 8gQK1mwnjNVgpgxYdGYjZ68B

Vista Chemical Company 900 Threodneeole Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston. Texas 77224 Fax (713) 588-3236 April 9, 1990 TGG: JCL: ERT. MJH: AJ0/RF :vkXF: li Mr. Michael J. Vint Process Development Manager Church & Dwight Company, Inc. 469 N. Harrison Street Princeton, NJ 08543 Dear Mr. Wint: Attached is Vista Chemical's response to Church St Dwight's Environmental Interaction Questionnaire. It is somewhat difficult to speak to predicted trends in the U. S. or Europe in a reasonably short answer but we have tried to indicate the highlights of what we see. Also, we will be forwarding answers to questions IV.A. and IV.B. in the near future. If you would like to discuss the questionnaire response further, please contact me at 713-588-3445 or Roscoe Cooley in our Saddlebrook office. Sincerely, ji----__ Thomas G. Grumbles, C.I.H. Environmental Quality Manager dlj Attachments cc: R. Cooley, M. Fortier-Saddlebrook - R. Swantkowski, B. E. A. Larsen, R. Bryan, M. Sweet WV 000012864 VISTA CHEMICAL COMPANY RESPONSE Information required from raw material supplier for review of laundry detergent environmental interaction: I. Corporate Information A. Corporate Environmental Statement What published statement has the corporation issued concerning environmental matters? Vista has established an environmental policy statement. A copy is attached. B. Performance What is the corporation's current environmental record (reputation) locally, regionally, and at the state and federal levels? How has the corporation reacted to any environmental transgressions (spills, etc.)? The company is in substantial compliance with all applicable environmental regulations. We believe that our reputation is good in the communities surrounding our plant, with the media, and with state and federal regulators. C. Commitment What has been done to improve environmental quality on a voluntary (above and beyond legislation) basis? Vista's corporate policy is to exceed governmental regulations where feasible. We have voluntarily reduced emissions at our plants over the years. Based on SARA 313 reported emissions, plant emissions have dropped significantly at all locations since 1987. A press release regarding these efforts at the Lake Charles facility, where ALFONIC alcohols and LAB are produced is attached. II. Key Trends A. Industry Are there any industry-wide trends that you are aware of which concern improvements to the environment or possible industry environmental liabilities? How will these trends affect the environmental reputation of the industry? Are there any pertinent international trends? In regards to trends, we believe responsible members of the industry have fully recognized their environmental responsibility and the need to develop communication with the public to assure that public opinion is considered when initiating and prioritizing environmental efforts. vvv 000012865 Evidence of this trend is CMA' s Responsible CARE program, a performance improvement initiative. Church & Dwight is also a CMA member committed to Responsible CARE, as is Vista, therefore, we've not provided details on this program. As to international trends, it appears that Europe may be behind the U. S. from a regulatory standpoint but probably is ahead of the U. S. in terms of the growing impact of the public opinion on business. This has been most evidenced in the "green" movements, specifically focused on chemical products and operations. The "eco-labeling" or environmental friendly labeling trend is one that is passing from Europe to Canada and the U. S. B. Corporate Has the corporation instituted programs that will, in the future, effect the environmental interaction and reputation of the corporation? Vista is working aggressively with communities and industries in the areas of our operations. The developing community outreach programs that involve information and education on the company's operations and emissions as well as community support programs such as "partners in education" and human services support. Vista is developing programs and doing projects in our manufacturing sites that should allow us to become more pro-active in meeting future environmental requirements. Articles from our internal newspaper "ChemNews" describing some of these activities are attached. III. Persuasion A. Industry What "pull", if any, does the industry as a whole have with government regulators and environmentalists? The chemical industry as a whole has had limited "pull" with government regulators and environmentalists in the last several years. Vista works with industry groups such as CMA, the Society of Plastics Industry, Vinyl Institute, and the SDA to address scientific and technical issues in environmental regulations. The EPA has been under severe Congressional pressure as well as public pressure, to promulgate more and more regulations in the environmental protection. The need to promulgate quickly has often resulted in poor quality regulations as well as unreasonable compliance deadlines despite industry efforts. B. Corporation Does the corporation have any "pull" or "leverage" with government regulators and environmentalists? ooooi^66 Vista actively participates in legislative and regulatory Issues at a state government level and has had some success In influencing governmental activities in Louisiana and Maryland. Specifically plant personnel are very active in the Louisiana Chemical Association and the Maryland Chemical Council. Our Baltimore plant manager was recently elected Vice President of the Maryland CIC. Environmental Impact of the Material A. Primary Degradation What is the biodegradation characteristics and environmental fate of the material which we purchase? How was this information generated? If generated as internal reports, could we obtain copies? B. Secondary Concerns Are there any byproducts or coproducts generated in the operations which produce our material? Do you know of any environmental problems caused by these by-or coproducts? What raw materials are needed by you to supply our material? Do these materials cause environmental concern? C. Releases or Exposures Are there any records concerning environmental consequences of releases, spills, or other exposure to the material we buy from you, or it's by- and coproducts, or it's raw materials? Vista has had no significant events, spills, releases, etc., that have resulted in records or problems concerning ALFONIC ethoxylates or LAS. We are not aware of other companies having such records or any such information in the public literature. Trends Concerning Material A. Direct Effects Are you aware of any trends in industry or government which will effect the availability, regulatory status, environmental reputation, or general usability of the material we purchase from you? Any possibilities of technological changes that will render your material obsolete for use in a laundry detergent? Vista believes LAB/LAS will continue to be the premiere, highest quality detergent intermediate available to the industry. To further establish this position, Vista has formed the Council for LAB/LAS Environmental Research (CLER) with Monsanto. CLER's goal is to provide communication and do research projects that will further establish the environmental acceptability and safety of LAB/LAS as a detergent material. In fact, CLER will be contacting your company in the near future to discuss CLER's activities. VVV 000012867 The Green movement in Europe has attempted to attack these materials based on a natural vs. synthetic comparison and CLER's work will assist in refuting non-scientifically based claims if the need arises. CLER is coordinating activities with the European soap and detergent industry. Indirect Effects Are there any trends that you expect will impact on the environmental, regulatory status, or usability of the byor coproducts or raw materials that are associated with the material we purchase? Vista sees no future trend that could impact the environmental or regulatory status of the by or coproducts produced in the manufacture of ALFONIC ethoxylates or LAB/LAS. Raw materials used in the manufacture of these products, such as benzene and ethylene oxide have come under increasing regulatory scrutiny and control, but Vista believes we can manage these issues with prudent and pro active environmental programs. 000012863 VM V Vista Chemical Company ENVIRONMENTAL POLICY Vista Chemical Company produces and transports chemical products that can potentially impact the environment in the communities in which we conduct business. Vista believes that compliance with all laws and regulations related to environmental quality and public health protection is a minimum standard of acceptable practice. Vista Chemical Company is committed to improving Vista's environmental protection efforts to achieve performance levels exceeding those required by law. Vista recognizes the responsibility we have to our employees, the surrounding communities, customers, carriers, contractors and government agencies to conduct our business activities according to the following environmental principles: Vista will inform and educate employees, surrounding communities, customers, carriers, contractors and government agencies of the health and environmental hazards of the chemicals we make, use and sell. These activities will involve recognizing and responding to community concerns regarding environmental issues. Vista will continually reduce the risk to employees and neighboring communities posed by chemical substances used, produced and transported within our communities. Vista will continue to take steps to reduce emergencies involving chemical releases that would impact the environment and surrounding communities. Vista will foster and maintain an awareness of and sensitivity to environmental responsibility among our employees through an ongoing internal communication program. Vista will maintain an environmental quality assurance program to ensure that operations are in full compliance with Company policies and procedures, governmental permit limitations and regulatory requirements. Vista will determine how each new or existing product can be made, used, handled and disposed of while protecting employee safety, public health and the environment. Vista will make safety, health, environmental control and waste minimization essential and integral parts of process and facility design, construction and operation. Vista will reduce waste generation in the air, water and soil through employee involvement ard the pursuit of source-control technology. Vista will work with the government and other parties in developing responsible laws, regulations and standards to protect employees, surrounding communities and the environment. oooovza69 VIS1A ENVIRONMENTAL RESPONSIBILITY VISTA GOES ABOVE AND BEYOND ENVIRONMENTAL COMPLIANCE Clean air, clean water, and a healthy en vironment--we all treasure these aspects of a healthy world for ourselves, our children, and for future generations. "At Vista, we are proud of our record on safety, health and the environment, and of our good relations with the com munities we call home," said John D. Bums, chairman, president and chief ex ecutive officer. But do we see ourselves and our in dustry as the public sees us? Can we af ford to rest easy with our own record, while the public becomes more and more concerned with the impact of our indus try on the environment we share? "In examining these questions, Vista management chose to strengthen the company's environmental efforts with the adoption of an Environmental Policy," Bums stated. A sampling of articles about Vista's environmental efforts that appeared in hemNews, a monthly employee publication. "We believe this statement embodies our philosophy and principles for envi ronmental compliance, control practices and public health protection," Bums con tinued. "The principles of our Environmental Policy will be the basis for our environmental decisions through the 1990's and beyond." In addition to Vista's Environmental Policy, the company also supports a new chemical industry initiative called Re sponsible Care, sponsored by the Chemi cal Manufacturers Association (CMA). In essence. Responsible Care is a perfor mance-improvement program that focus es on health, safety and environmental quality. The CMA board approved the initiative and participation in Responsi ble Care is now an obligation of mem bership in the association. "Implementation of the principles of our Environmental Policy is a long-term effort," said Tom Grumbles, environ mental quality manager. "This policy and resultant programs of work will be a continuous effort to improve our perfor mance. It's not just words on paper. It's action." He added, "Responsible Care is the beginning of a way of life for Vista, the chemical industry and the CMA. Most of the proactive concepts, ideas and pro grams that Vista haabeen developing and putting in place will find a home un der the Responsible Care umbrella." The Responsible Care program has the following major components: Codes of Management Practices: Each code will identify the elements of good management practices in health, safety and environmental areas, and de fine performance objectives. Initially, these codes will be considered for emer gency response, transportation, release reduction and management, and plant op erations. vvv 000012370 Public advisory panels: A national advisory panel composed of environmen tal, health and safety leaders will critique (cont'don page 2) GOING ABOVE AND BEYOND oru'dfrom page 1) management practice codes and identify areas they believe require industry ac tion. Community-level advisory panels will be encouraged. Company self-evaluations of manage ment practices: Each company will use performance objectives to measure per formance and improvement This data will be useful in identifying areas in which individual companies need assis tance in improving performance and in measuring collective industry improve ment Executive leadership groups: Com posed of member company executives, sse groups will meet regularly to share ...periences, review practice codes, dis cuss progress and identify areas where companies may offer or receive assis tance in reaching progress milestones. Bums stated, "No matter what role you play in Vista's success, our Environ mental Policy and Responsible Care ap ply to you. These principles are more than an attitude expressed by manage ment They must guide the way you and I do business. We will continue to go above and beyond compliance to im prove our health and safety performance record." 2 VISTA VCM PLANT RECEIVES ENVIRONMENTAL AWARD "In today's world, environmental com pliance and performance are top priority issues," observed Dick Conrad, plant manager at Vista's Lake Charles, La., VCM Plant (LCVCM). "To achieve suc cess in this area requires the same dedi cation that we've always applied to our safety programs." LCVCM's employees were recently recognized for the outstanding results they achieved in environmental compliance during 1988. The plant was awarded one of two environmental achievement awards in the vinyl chloride monomer (VCM) category by the Vinyl Institute. The award measures a plant's ability to control and minimize VCM emissions and is given to the top two performers in the category. This year's award recognizes performance in the following areas: relief valve discharges, rupture disc releases, oxychlorinadon reactor loss exceedances, manual vents, and; incinerator bypasses. "VCM's employees are working hard to maintain and improve the current level of performance," concluded Conrad. "I'm proud to be a part of their effort." P58 RIANT RECEIVES FIRST PLACE IN 'S> ENVIRONMENTAL ACHIEVEMENT In May, employees at Vista Chemical's Aberdeen, Miss., PVC Plant received the Vinyl Institute's (VI) first place award in environmental achievement. The award is the second consecutive award for the PVC plant in the three years the awards have been given. "This achievement is certainly a quality performance every day by Aberdeen's employees," said Bob Seymour, Aberdeen's plant manager. "It's one that benefits both our employees and the Aberdeen community.'' Vista is one of six VI member companies that received the award this year. The award was developed to recognize member companies who receive a perfect score from the VI for having no: relief valve discharges, rupture disc releases, residual VCM exceedances on slurry, reactor opening loss exceedances, manual vents, and; incinerator bypasses. "This is an award that every employee at Aberdeen can be proud of whether they are involved in preventing VCM releases or operating and maintaining equipment to ensure minimum emissions," concluded Seymour. ^ 000012871 'ADMIUM-FREE PVC: PROTECTING THE ENVIRONMENT WITH NEW RECIPES An environmental issue faced by the chemical industry in Europe, and now in the United States, is the presence of cad mium and other heavy metals in land fills. The industry is faced with taking ac tion on two fronts: "Eliminating cadmium from plastics and pigments that are dis posed of in municipal waste landfills. -Reducing disposal costs for ash from inciner ated waste that may have h concentrations of cadmium and other hazardous materials. Currently, this ash must be disposed of in costly landfills targeted especially for hazardous waste. American vinyl producers are taking the initiative to remove cadmium, a heat stabilizer, from their recipes. Along with other member companies'of The Vinyl Institute, Vista has pledged to remove cadmium from its PVC compounds, ac cording to Joe Ledvina. director of environmental activities. HHDING NEW FORMULATIONS. Vista's re search and development group in Austin, IX, is working with several outside sup pliers to develop alternatives to the cad mium stabilizers used in some of these recipes. "We're looking for alterna tives to cadmium that perform as well under process condi tions," explained Steve Hookansen, manager, applications and development. Concurrent testing of non-cadmium stabilizers is being conducted in Vista la boratories in Austin and at Blane Poly mers to speed the process of finding al ternatives and get them to market. Hookansen's group has tested noncadmium stabilizer systems in several customer applications in the field. "The non-cadmium stabilizer systems performed very well under normal pro duction conditions," noted Hookansen. REDUCED EMISSIONS IN LAKE CHARLES Vista's Lake Charles, La., Chemical Complex reduced SARA-repoatable emissions in 1988 by 57%, or 2.1 million pounds over 1987. Most of the reduction involved a dramatic decrease in reported air emissions. Several factors contributed to the de crease. More than 25% of the reduction was the result of equipment modifica tions and process improvements. Urn The remainder was due to updated cal culation methods and the discovery that emissions of alumina should not have been included in 1987 calculations. "We've continued to make significant changes at the three Lake Charles plants to make sure the chemicals we use and make are not discharged to the environ ment," said John Friend, plant manager at the i-akft Charles Chemical Plant. vVV 0000128''2 VISA 3 SPREADING THE WORD ABOUT ENVIRONMENTAL CONCERNS \ Quick Grbcich, a ^ process engineer in ' Houston, finds him- ' seif face-to-face with environmental regulations every day. Grbcich is part of the team working on the biochemical oxygen demand (BOD) project at Vista's Aberdeen, Ms., PVC Plant. A new regulation calls for further reduction of vinyl chloride and other or ganic compounds that are released to the plant's wastewater ponds. "I need to be familiar with environ mental trends and regulations so that 1 n apply them to my work," Grbcich "Because of their far-reaching effects, environmental concerns and regulations are something everyone at Vista needs to be aware of," said Ed Taylor, senior en vironmental specialist. "Environmental issues impact virtually every aspect--manufacturing, supply and transportaiiortrengineering, market ing--of our business." Armed with a checklist and trained by a member of Vista s environmental group. Lane Clayboum, ex-plant analyst, audits product transfer terminals and toll processors. The audit checklist measures the quality, environmental, safety and health performance of these ex-plant operations. "During an audit," he said, "I need to know what to look for to ensure die ter minal's compliance with current laws." "So many employees need a basic awareness of environmental issues to do their jobs effectively," added Joe Ledvina, director of environmental activ ities. "We found, through company-wide surveys, that environmental training was a major need among new-hires and vete ran employees alike." To spread the word about environmen tal concerns and the laws affecting the chemical industry, Taylor, Ledvina, Bill Taylor: "Environmental issues impact virtually every aspect of our business." McClain, senior counsel, and David Cohen, counsel, hold basic environmen tal awareness seminars that cover air, soil, water and groundwater regulations. The program also addresses permitting processes and solid and hazardous waste management. The first seminars were held for mem bers of the supply and transportation and process engineering departments in Houston. After attending an environmental seminar, Brett Earl and Doug Dolan, pro cess engineers, feel more comfortable with environmental issues. "All the language I heard during the presentations was new to me, but I feel better prepared to recognize potential en vironmental impacts on my work," com mented EarL "Emission regulations, to varying de grees, are a constant factor in my work," added Dolan. "A good working knowl edge of environmental laws helps me do my designing work right the first time." "We want employees to be aware that the corporate environmental and legal groups are a resource for answering any environmental questions they may en counter," concluded Taylor. He can be reached in Houston at 713/588-3492. 4 VISIA 000012873 vW mine sure plant chemicals sta y where they belong oROUNDWATER TESTING BEGINS IN MOSSYILLE Visa and Conoco have started ajoint drilling project within the Mossville sub* division to testfor thepresence ofethy lene dichloride (EDC). Mossville is located on the western boundary of Visa's Late Charles,La., VCM Plant. Previous testing ofprivate water wells found no chemicals in the wa ter able under Mossville. "This drilling project is pan of Visa's continuing efforts to make sure the chemi cals we use and make at our plant say in side the plant property," said Dick Con rad, plant manager. A large truck--a test lab on wheels-- been parked at various locations on Mossville streets. Technicians oo the track have drilled two-inch holes and in serted measuring devices to depths of an to seventy feet to test forEDC. In the past. Visa detected traces of EDC directly underneath the VCM plant andnear the plant's boundary next to Mossville. To recover the EDC, Visa be gan an ongoing groundwaterremediation program, which means the company pumps the groundwaterout, treats it to re move contaminants and replaces it. PKEVEHTION ISTHE BESTCURL Pastpractices (hiring the plant's early years ofoperation contributed to the presence ofEDC in the groundwater. According to Conrad, precautions against this happening in the future have been taken. "We've investigated potential sources ofleaks," he said, "and in stalled new and better equipment, such as storage tank bottoms with special protection to prevent corro sion, a major cause of leaking in the past" EDC is used to make vinyl chlo ride monomer (VCM). VCM is used at other Vista locations to make polyvinyl chloride (PVC). NEW GUIDELINES TO UINIMIZE DELAY, WASTED EFFORT DESIGNING WITH OUR ENVIRONMENTAL FUTURE IN MIND Hazardous waste produced in this coun try is a growing concern to the American public and to government and industry. But whose responsibility is it? "Vista recognizes its environmental re sponsibility to employees, surrounding communities and government agencies," said Tom Grumbles, environmental qual ity manager. InJuly 1989, Vista's Environmental ^Micy was formally adopted. One of the ific actions outlined by the policy is to continue "to make safety, health, envi ronmental control and waste minimiza tion essential and integral parts ofprocess and facility design, construction and operation." That's where Vista's Engineering gfc _ Environmental Guide lines team fits in. According to Ed Taylor, senior envi ronmental specialist, guidelines devel oped by the team will minimize project delays and wasted effort by allowing for consistent decision-making while focus ing on future environmental compliance and protection. Team members are Taylor; David Cohen, counsel; Tom Heller, senior pro cess engineer, Neil Rasmussen, chief mechanical engineer, LCCP; Jerry Stone, chief engineer, maintenance and techni cal services; and Curt Watson, project manager, engineering. Ccorn'd on page 6) 00 l VtSHA 5 VASTEWATER PROJECT UNDERWAY IN LAKE CHARLES A new level of envi ronmental compliance is on the horizon for Vista's three-plant chemical complex in Lake Charles, La. (LCCC). To meet future environmental obliga tions, employees at the Lake Charles Chemical, VCM and LAB plants are tak ing a hard look at theirrespective wastewater systems. Two upcoming environmental require ments represent the trend toward stricter environmental compliance. The first, expected to go into effect be fore the end of this year expands the list of hazardous mated- reduces the allowable concentrations for these materials, including benzene and ethylene dichloride (EDC), and will cause all in-ground facilities that handle hazardous materials to be classi fied as hazardous waste treatment facili ties. "As our systems currently exist in Lake Charles, the ponds and lagoons that handle benzene and EDC would auto matically become hazardous facilities," 6 VISIA said Curt Watson, project manager. This means high administrative and construction costs for Vista to upgrade and maintain the ponds and lagoons as harardoug fariliHp.q, The second, expected to become effec tive at the aid of 1992, calls for a sub stantial reduction in the total amount of contaminants in wastewater released to local waterways. A project team has been formed to de termine what steps are necessary to com ply with these and future environmental requirements. The philosophy behind the LCCC wastewater project, according to Watson, is to spend environmental dollars on waste minimization rather than on build ing bigger and bigger waste treatment facilities. "We want to build a treatment system that, with slight modifications, can meet future regulations," he said. Team members are Watson; David Cohen, counsel; Sandra Coikran, process engineer, LCVCM; Tom Heller, senior process engineer, Joe Ledvina, director. environmental activities; Mike McHugh, process engineer, LCLAB; Ralph Raines, senior project engineer; Jim Shamburger, senior process engineer, LCCP; and Mark Whitman, process engineer, LCCP. NEW GUIDELINES {cont'dfrom page 5) "By developing engineering environmen tal guidelines, we are addressing ele ments of Vista's Environmental Policy and can reduce potential environmental risks," said Taylor. The team is currently working with Vista's three-plant Lake Charles, La., Chemical Complex (LCCC). Facing two new environmental requirements, LCCC has an immediate need to revamp its wastewater treatment systems. VVV 000012S75 For additional information about the articles in this publication or Vista's other environmental activities, please call or write: Tom Grumbles Manager, Biomedical and Environmental Affairs Vista Chemical Company 900 Threadneedle Houston, TX 77079 713/588-3445 sta Cnemicai Ccmoany rOO Threaaneeaie HousTon "exas 7^779 :hone 1713j 588-3000 Release Post Office Box i 9029 Houston. Texas 7~12-ax (7131 588-3226 89-34 FOR IMMEDIATE RELEASE CONTACT: John Friend (318) 494-5341 or Mike Hayes (318) 494-5437 Vista Chemical reduced emissions in 1988, expects continuing reductions through early ' 90s LAKE CHARLES, La. (Sept. 21, 1989) -- Vista Chemical Company today announced it has reduced by 57%, or 2.1 million pounds, the reported amount of certain chemicals it released from its Lake Charles Chemical Complex to the environment in 1987. The company reported to the Environmental Protection Agency (EPA) a total release of 1.6 million pounds in 1988, down from the 3.7 million pounds reported in 1987. Most of the 57% reported reduction involved a dramatic decrease in reported air emissions. Vista's Lake Charles Chemical Complex reported a reduction of 53%, or 1.6 million pounds, in air emissions--from 3 million pounds in 1987 to 1.4 million pounds in 1988. Several factors contributed to the company's 57% decrease in reported emissions. More than 25% of the reported reduction was the result of equipment modifications and process improvements-- which means the company released fewer chemicals to the environment during 1988. (continued) VVV 000012876 For mare information on Vista Chemical Ccmoany see tne reverse or this sneet. r VISTA ENVIRONMENTAL Continued The remainder of Vista's total reported reduction was the result of other factors--the updated calculation methods the company used to determine its emissions, which provided a more accurate emissions total, and the discovery that emissions of one inert substance, uncalcined alumina, should not have been included in 1987 calculations. "We've continued to make significant changes at our three Lake Charles plants to make sure the chemicals we use and make are contained within the plants and not discharged to the environment," said John Friend, plant manager, Vista's Lake Charles Chemical Plant. "We're pleased with the progress we've made so far. "Process modifications in the plant led to a decrease of 560,000 pounds per year of ethylene discharged to the atmosphere during 1988. In addition to the reduction in air emissions, we made other process improvements to give plant personnel greater control over the plant's wastewater system. This resulted in a 10,000-pound reduction in chemicals released in the plant's wastewater^ discharge. " Vista submitted its 1988 "Toxic Chemical Release Inventory" to the EPA as required under the Superfund Amendments and Reauthorization Act (SARA), passed by Congress in 1986. Under SARA, companies that manufacture, import, process or otherwise use any of over 400 chemicals must file an annual report containing amounts of each chemical released into the air, water and land. "Vista was hard at work reducing its emissions long before the SARA legislation came about, and we're pleased with the success of all of our environmental improvement programs," said Friend. (continued) 000012877 tfVV Reported Emissions at Vista Chemical's Lake Charles Chemical Complex VIS1A -4 CO 9Z10000 TO: R. D. Gamblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles April 12, 1990 PROGRESS REPORT VISTA 1. TGG participated in Toxic Substances Control Act (TSCA) training in R&D. The training included an overview of the act and regulations and specific R&D compliance procedures. 2. TGG participated in a meeting with R&D personnel to begin to define the process needed to assure Premanufacture Notifications will be filed in a timely manner to assure commercialization. The EPA is beginning to require more and more data on PMN submittals which results in longer lead times to prepare PMN's and significant expenditures to obtain the data. 3. Senior Management has approved a headquarters recycling plan for paper and aluminum cans. MJH is working with the VHEA and Public Relations to implement the program. An official announcement of the recycling program is forthcoming. 4. ERT participated with S&T in the Quality Vendor Audit at Shaft Warehouse located in Houston. S&T will issue the final audit report. 5. The DOT training and assessment committee held its first meeting. It was decided that DOT audits of company locations would resume by late June, 1990 and DOT training would begin by September, 1990. We are planning to hold a seminar with Transportation Contacts sometime in June. 6. 16 COEDS ordered USDS's were sent out and one new label was entered in the system. T. G. Grumbles dlj VVV 000012079