Document OJ17GaQgoQD5dOY4Y016GO3Xp
Vista Chemical Company
15990 North Barker's Landing Road Post Office Box 19029
Houston, Texas 77224 Phone (713) 531-3200
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June 8, 1988
Mr. Robert Smith Document Control Office Chemical Inventory Section, TS-790 U. S. Environmental Protection Agency Office of Toxic Substances 401 M Street, NW Washington, DC 20460
VISTA
Dear Robert:
As we have discussed, and as was outlined in the August 5, 1981 letter (attached with August 12 corrections) to Mark Scoville, Vista Chemical is proposing the following descriptions for our alkylate and specialty alkylate products. These descriptions are consistent with your sections desire to achieve consistency of inventory description methods for these products. These actions are based on agreements reached in our meeting of July 22 and outlined in the above referenced letter.
The basic process flows for Vista's three alkylate products are
attached.
The descriptions below are added to those diagrams to
clarify the applicability of the descriptions.
Process Feedstock - As referenced In the August 5 letter we will consider our paraffin feedstock to be covered by the following description:
Sorption Extracted Normal Paraffins C5-20 (CAS # 64771-72-8)
Premium Alkylate Product - The premium detergent alkylate produced will be described as follows:
Benzene, CIO-15-Alkyl
A form C will be filed to obtain a corrected inventory status for this material and a CAS number obtained.
Specialty Alkylate Products - All derivative products from the process will be described as follows:
Benzene, C10-15-Alkyl Derivatives
A Form C will be filed to obtain a corrected inventory status for these products and a CAS number obtained.
00001^8
Hr. Robert Smith Page 2 June 8, 1988
Vista believes the above descriptions to be consistent with the Agency's guidance on describing complex mixtures or "process streams" for inventory purposes. Please contact me by mail or at 713/531-3445 to discuss our next step.
Sincerely,
Thomas G. Grumbles, C.I.H. Environmental Quality Manager
ajo cc W. L. McClain, J. P. Warner, D. L. Mahler, M. G. Hayes
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DETERGENT ALKYLATT RODUCT N-500 TYPICAL DISTR!bu>ION, WT.%
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CBENZENE, N-DECYL
C:, BENZENE, N-UNDECYL
cj*
BENZENE, N-DODECYL
Cl*
BENZENE, N-TRIDECYL
BENZENE, TETRADECYL
0.6 19.8 33.6 35.4
9.1
1.5
PROPOSED - REVISE WITH BENZENE, C1Q_15 ALKYL (CAS# TO BE OBTAINED)
ALKYL DERIVATIVES
RM C
PROPOSED - REVISE WITH FORM C BENZENE, C1Q_15 ALKYL DERIVATIVES (CAS# TO BE OBTAINED)
DERIVATIVES
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DETERGENT ALKYLATE PF___ XiCT N-550L TYPICAL DISTRIBl ON. WT.%
<C10
C10 c11 c12 c13 >c14 -15
BENZENE, BENZENE, BENZENE, BENZENE, BENZENE, BENZENE,
N-DECYL N-UNDECYL N-DODECYL N-TRIDECYL N-TETRADECYL N-PENTADECYL
0.3 13.4 30.4 29.0 24.0
3.0 0.2
PROPOSED - REVISE WITH FORK BENZENE, C10-15 ALKYL (CAS# TO BE OBTAINED)
ALKYL DERIVATIVES
TYPICAL DISTRIBUTION. WT.%
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Ci CT* C:^ Cf^ >Cj^
DECANE
UNDECANE DODECANE TRIDECANE TETRADECANE PENTADECANE
0.3 13.4 30.4 29.0 24.0
3.0 0.2
PROPOSED - WILL BE CONSIDERED SORPTION EXTRACTED NORMAL PARAFFINS (CAS# 64771-72-8)
PROPOSED - REVISE WITH FORM C BENZENE, C1Q_15 ALKYL DERIVATIVES (CAS# TO BE OBTAINED)
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DETERGENT ALKYLATE ODUCT N-600L TYPICAL DISTRIBUTION. WT.%
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BENZENE,
BENZENE, BENZENE, BENZENE, BENZENE, BENZENE,
TRACE
N-DECYL
0.3
N-UNDECYL
1. 5
N-DODECANE
19. 2
N-TRIDECYL 48.0
N-TETRADECYL 28.0
N-PENTADECYL 3-0
PROPOSED ~ REVISE WITH BENZENE, C1Q_15 ALKYL (CAS# TO BE OBTAINED)
ALKYL DERIVATIVES
>RM C
NORMAL PARAFFIN FEED TYPICAL DISTRIBUTION, WT.%
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C c
10 10
c c
11 12
c
13 14
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15
TRACE
DECANE
0.3
UNDECANE
1.5
DODECANE
19.2
TRIDECANE
48.0
TETRADECANE 28.0
PENTADECANE 3.0
PROPOSED - WILL BE CONSIDERED SORPTION EXTRACTED NORMAL PARAFFINS C CAS # 64771-72-8)
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PROPOSED - REVISE WITH FORM C BENZENE, C1Q_15 ALKYL DERIVATIVES (CAS# TO BE OBTAINED)
DERIVATIVES