Document B874ky7avjEoRgEo83r5gMJYk

Vi$fa Chemical Company 900 Threadneedle Houston, Texas 77079-2990 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224-9029 Fax (713) 588-3236 June 18, 1991 Bhavana Shah Quality Assurance Petrolite Corporation 369 Corporation St. Louis, Missouri 63119 Dear Bhavana: This letter acknowledges that the Vista products listed below are on the USEPA TSCA inventory. Vista ALF0L*+ Alcohol Vista ALFOL810 Alcohol Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj VVV 000006487 TO: John Farrier XF: ^ RF Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles June 18, 1991 EX-PLANT CTIRP PLAN COMMENTS Below are comments on your proposed ex-plant CTIRP program. I believe we need a separate set of procedures for the ex-plant events similar to what you propose, but I'm not sure if we should fold it into the existing manual, or have a separate one. One approach would be to have one manual with distinct sections for each plan. I think we have to utilize outside contractors for ex-plant response based on the potential logistics issues. It seems we can analyze our current business and determine the areas of concentrated activities and/or highest risks to define how to utilize the contractors. I think we have to consider manufacturing responding to ex-plant events, but not as a primary source of response. If a plant can respond quicker than a contractor in a certain circumstance, then they should be asked. There are some issues to address here, but I think it's feasible. The "Shipment Scenarios" page is not clear to me. I need help understanding it. It may be a format problem but it confuses me. I think the manufacturing involvement issue needs to be discussed before the process flow can be finalized. At this point, I'm confused by the area I've circled on the attached chart. Hopefully, we can discuss this at a CTIRP Management Committee meeting or by conference call. T. G. Grumbles dlj Attachment VVV 000006488 INCIDENT IS REPORTED TO VISTA 0* 00