Document NEzXyqnqp73MV2gxM50J0KBaV

TO: Distribution FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles April 7, 1986 NOTIFICATION TO CONOCO OF VCM INCIDENTS VISTA For the events described in my letter of April 1 to Jack Neeld, please be sure that Jack Neeld, Garvin Fryar, and Brad Raffle are on the distribution for final copies of those written reports. Thomas G. Grumbles ajo/8 Distribution: R. A. Conrad S. H. Christiansen R. F. Ferrell J. Friend R. A. Frohreich H. D. Garrison M. G. Hayes M. Manion W. L. McClain J. H. McCulley OOOOI7138 o<J S BACKGROUND VISTA VISION has meant innovative and aggressive marketing of current products resulting in new customers and customers using our products for the first time. VISTA VISION has resulted in the development of truly new products through process modifications and new product development through by-product upgrading. Both of these developments have resulted in an increasing effort in the area of customer service and technical assistance. The new surfactants capability brochure has the following statement - ASK A MEMBER OF OUR FIELD MARKETING ORGANIZATION TO ARRANGE FOR A CONSULTATION. In other words we are the experts, let us help you. These activities create greater market shares, more sales, and ultimately greater profits. However, with this increased customer consultation or technical assistance comes increased risks from a liability standpoint. GOALS What we want to accomplish today is a broadening of your VISTA VISION. VVV 000017139 Broadening your vision in the following ways: Understand liability impact of Vista activities in new marketing areas. Learn to recognize potential areas of liability. Recognize when a waiver may be necessary. Understand how to service w/o waiver in a defensible matter. EXAMPLES I have listed some general subject areas that should cause you to think about liability concerns when responding. These areas are based on my experience in working with you and fielding customer calls. A. Regulatory Issues B. Hazardous Properties C. Labeling Specifics D. Exposure Potential E. Waste Disposal F. Exposure Controls 1. Ventilation 2. Respirators VVV 000017140 G. Process Conditions H. Operating Parameters Some specific examples in these areas: I. Does this regulation apply to this product and my workplace? A. I don't know B. I doubt it - Let me send you the regs. C. Vista's interpretation is .... In answering this kind of question, keep in mind we may have a source available, such as technical data sheet, that addresses the question. (Eto, FDA). These types of sources certainly can be used without a waiver. 2. Is this material hazardous and how do I dispose of it? A. I don't know. B. You can eat this stuff, throw it in the dumpster. C. I'll have our experts call you. Once again by utilizing option "c" you can appropriately respond without a waiver. VVV 00001714L I've never handled this chemical before. Can you please send me information on how to build my tanks, unload the railcars, any applicable emission or exposure regulations, respirators I need, etc. A. We'll get back to you. This is a situation where a waiver should be considered and most likely used, based on the scope of the assistance and the potential areas of risk. VVV 000017142 TO: D. A. Kuhn I Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles April 4, 1986 PROGRESS REPORT FOR THE WEEK ENDING APRIL 4, 1986 VISTA 1. A meeting was held with Conoco to discuss and finalize a cost allocation agreement for certain groundwater assessment and remediation costs at the LCCC. The specifics of the agreement, except for cost percentage allocation appear to be resolved. 2. A final compliance order for T-405 clean-up at the LCVCM plant I has been received from the State. It is substantially similar to the proposed clean-up plan submitted in January. 3. Planning for the April 10 Management Briefing is well underway. Plant personnel involved will be in Houston the afternoon of the 9th for a "dry-run" session. 4. Assistance was given to the Aberdeen plant in implementing the plant's medical certification program for respirator users. 5. We received an extensive information request from EPA concerning ethylene oxide emissions from the Ethoxylation Unit. LCCP is developing a response which is due April 30. The information will be used by EPA to write an EO emissions regulation. 6. Baltimore received an information request from EPA regarding releases from solid waste disposal units on the property. EPA says the information will be used to decide if corrective action is necessary. DuPont was formally notified of a potential environmental claim. The response will be coordinated with DuPont. The response is due to EPA on April 14. 7. Aberdeen's vinyl chloride compliance plan was approved by EPA and entered into the Mississippi Federal District court on 4/4. EPA granted Aberdeen a waiver of testing for reactor opening loss, equipment opening, and approved an alternate test method for residual vinyl chloride. All three VCM lawsuits have been settled. 8. Meetings were held with LCVCM and LCCP to initiate activity on \ a wastewater permit negotiation plan. EPA is proposing extremely low levels of EDC, benzene, toluene, and zinc in the wastewater discharges from those plants. 9. A memo was issued to the plants reminding them of the May 8, 1986 deadline for notifying their state agencies of the existence of their underground storage tanks. 00<n 10. Tabulated plant air emission data for possible inclusion in the Mif-asked" statement prepared on toxic air pollutants. 11. Changes to the hazardous materials descriptions for Hammond products have been completed. New placards have been received and are in use. 12. Updated State and Federal regulation source books for the plants. 13. Updated the table of Superfund reportable quantities for releases of Vista products for the Transportation Department Operations and Safety Manual Thomas G. Grumbles ajo/8 VVV 000017144