Document OzBboj2VRk7NjwXgX6EEG0Q01

Shelt r Materials Group Vinyl Building Products Group CertainTeed Corp ration Governor Lane Blvd PO Box 290 Williamsport MD 21 795 301 223-7900 301 223-6249 (PAXi CertainTeed El via Federal Express September 1, 1992 Ms. Cindy Turkle, Manager Marion County Landfill c/o Marion Co. 1 Willett Drive * Rt. 5 Box 2 Knoxville, Iowa 50138 Engineer's Office RE: PVC Compound Waste, Wolverine Technologies - Grinnell, IA. Dear Ms. Turkle: As we discussed during our telephone conversation this date, CertainTeed Corporation is the parent of Wolverine Technologies (hereinafter collectively referred to as CertainTeed), which of course includes our facility located in Grinnell, Iowa. Please know that I did enjoy our talk, and in order to properly document that conversation, and to allow us to provide additional pertinent information, the following is offered. You advised during our conversation that several employees of the waste transfer station had concern and they had in fact relayed some symptoms which they attributed to dealing with our waste PVC compound material. It is further my understanding that these employees are dumping our waste materials on the floor of the transfer station and are thereby causing some airborne nuisance dust. It is also my understanding that our Mr. Mark Romano (Site Environmental Manager for the Grinnell facility) has provided you with a Material Safety Data Sheet for PVC Compound, and I today provided you, via FAX, with a copy of CertainTeed's MSDS for vinyl materials which CertainTeed makes or generates as a result of our process. Therein you will find much of the information we discussed and which you will need to make an accurate assessment of this material. I am also taking the liberty of enclosing with this letter a recent TCLP test analysis which will clearly document and substantiate our position that PVC Compound is NOT hazardous as defined by RCRA Subpart C, 40 CFR 261. I ask that you please observe from those MSDSs' which have been provided to you that the only real condition which can be presented by the waste at issue, and in the manner in which you are dealing with this material, is that of a nuisance dust. CTL031638 M*. C. Turtle October 1. 1992 Ptfe 2 CertainTeed El This dust is no more or less of a concern than are nuisanc -dusts of the same diameter and which can include soils, saw dust, etc. They possibly may, if your employees do not utilize customary safety precautions which I would suspect they would use in this type of operation; such as dust type respirators (simple filter masks) or adequate ventilation to keep concentration limits below that recommended by OSHA for nuisance dusts (eg: 10mg/m3) and safety glasses (with side shields) still only present (above those levels of concentration mentioned) the very minimal challenge of a temporary respiratory irritant with NO chronic health effects, and as a simple mechanical eye irritant; which again would be the exact same health concerns as breathing airborne dusts from soils. Should you be so inclined, I invite you to contact our Ms. Janis Reynolds, Director of Industrial Hygiene at our Corporate Health & Safety Department at 215-341-7000 should you have any specific questions relating to the the health issues of PVC as your employees relate to it. I advised you that CertainTeed's desire is that we respond proactively in this issue so as to maintain our good and credible working relationship with your agency, so long as this did not necessitate an undue burden on our operation, or result in anything unreasonable. Any requirement which might be levied over than we discussed and to which we agreed would be arbitrary and capricious, and it would significantly hinder our ability to continue doing business. CertainTeed would in such an instance pursue appropriate legal recourses which are available to us. I trust however that we will be able to reach a mutually acceptable practice which will address your concerns. To that end, I did commit to you that we would agree to a brief period where we would take powered PVC waste, place it in degradable containers, so as to prevent airborne releases, and take it separately to the landfill to thereby afford you an adequate period of time to evaluate this situation. I did however mention that we would not be receptive to both of these steps on more than a temporary basis as these activities are unnecessarily redundant, and the potentials simply do not warrant this undue burden beyond that of a brief time. I suggested that one or the other steps may be, in and of itself, reasonable to address all of the concerns of your employees. You should know that CertainTeed Corporation operates several PVC manufacturing plants in many different jurisdictions. CTL031639 M*. C. Turtle October 1, 1992 Pate 3 CertainTeedH In each of these states we have and continue to landfill PVG waste in the manner which we have at your facility for many years. While I realize that you must examine this issue and all associated particulars, I hope that this knowledge will make you a bit more comfortable with our operation as it relates to your landfill site. I remain available for any questions you might have and I look forward to hearing from you in this matter. Sincerely./ Manager, Safety & Environmental Affairs Vinyl Building Products Group, & Shelter Materials Group cc: J. Oleson M. Romano (w/ attachments) M. Colitti S. Carr, Esq. J. Reynolds S. Greurich - Iowa DNR, Waste Management Division D. Elliott - Poweshiek County Landfill (w/ attachments) attachments CTL03l640 ANALYSIS REPORT CertainT eed Corporation Ken Everhart P.0. Box 2BQ Williamsport, MD 21795 AATS Sample #: UJW 39650 Date Submitted: 12/23/91 Dat e Report ed: 01/15/92 PO# Recelpt #: HA--19059 Sample Identification: PVC Compound Coll ect ed on at by ANALYSIS RESULT AS RECEIVED LIMIT OF QUANTITATION Mercury < 0. 005i mg/1 0. 005 The analysis for mercury was performed by KR on 01/03/92. 'he method used was EPA SW-896 , Method 7970. Arsenic < 0. 5 mg/ 1 0. 5 Se1eniurn < 0. 5 mg/ 1 0. 5 Barium < 2. mg/ 1 2. Cadmlurn < 0. 05 mg/ 1 0. 05 Chromlum \ 0. 5 mg / 1 0. 5 Lead ( 0. 5 mg/ 1 0. 5 Sl1ver < 0. 1 mg/ 1 0. 1 Tne extraction was perrortea oy DR on 12/26/91. The reported results for metals were corrected for the matrix spike recovery as specified in June 29,1990 Federal Register, p. 26993. The metal analyses were performed on a non-volatlie leachate prepared according to the procedure specified m the June 29, 1990 Federal Register. A sample is considered to have failed the Toxicity Characteristic (TC) test and is considered a hazardous waste if any of cne metal concentrations (mg/1) m the leachate exceed the following naxima >.100 times the Primary Drinking Water standards; : Arsenic 5.0 Barium 100.0 Cadmium 1.0 Chromium 5.0 Lead Mercury 5.0 0.2 Selenium 1.0 Silver 5.0 'he limits are pudlished in March 29,1990 Federal Reg i ster,pp. 11S45-6. 'ne analyses for arsenic, selenium,barium,cadmium, chromium, lead and Oliver were performed by DRS on 01/09/92. THe method used was EPA SWBk-b.netnoa 9010. subcontracted Page 1 of 3 CTL031641 5424 Buchanan Trail Ea$t,YY' Branch Office: 149 East Qu an St, Cha CO J" CertainTeed Corporation Ken Evernart P.Q. Box 88 Williamsport, MD 1795 _^sfegj^rs>-as:-`. *- ?r*ervf*iV^tK^\t *'' ANALYSIS REPORT -f - jv*~ '''a* -- AATS Date Date POM Sample #: WW 39650 Submitted : 12/23/91 Reported: 01/15/92 Receipt#: HA-19054 Sample Identification: PVC Compound Collected on at oy ANALYSIS RESULT AS RECEIVED LIMIT OF QUANTITATION TCLP Acid Base/Neutrals pyridine 1,4-dichlorobenzene 2-Methy1pheno1 3 and 4-Methy1pheno1 hexach1oroethane nit robenz ene n e xacn1 orobut adien e 2,4,6-trichlorophenol 2,4,5-trich1oropheno1 2, 4-dimtrotoluene hexachlorobenzene pent achlorophenol The semivolatile analyses characteristic leachate prepared according to the < 0. 040 mg/ 1 < 0. 026 rag/ 1 < 0. 027 mg/ 1 < 0. 030 mg/ 1 < 0. 028 mg/ I < 0. 024 mg/ 1 < 0. 028 mg / 1 < 0. 026 mg/ 1 < 0. 024 mg/ 1 < 0. 021 mg/ 1 < 0. 021 mg/ 1 < 0. 10 mg/ 1 were performed on a of the submitted procedure specified 0. 040 0. 026 0. 027 0. 030 0. 028 0. 024 o. 028 0. 026 0.024 0. 021 0. 021 0. 10 non --vo1 at11e toxicity waste. The leachate was in the March 29 and the June 29,1990 Federal Registers. A sample is considered to have failed the Toxicity lest ana is znerefore considered a hazarcous waste :f any of volatile concentrations (mg/ 1 ) in the leachate exceed the iTC) the semifollowing maxima: Total Cresol 1, 4-Dlcn1 orobenzene 2,^-Dinitrotoluene Hexachloropenzene Hexachlorobutadiene -e x ach.croethane 200. O 7. 5 0. 13 0. 13 0. 5 2. ') Nitroben z'e n e 2.0 Pent ach 1 or o pheno 1 100.0- Pyr i dine 5.0 2, 4, 5-Trich 1 oropheno 1 400.0 2, 4, 6-Tnchi oropheno 1 2.0 The limits are puDlished in March 29, 1990 Federal The analysis for TCLP semivo1 at11es was performed ~ne method usea was SUI-946, method 8270 subcontracted Register, pp. 11845--6. by TSW on 01/06/92. ANALYSIS REPORT CertainTeed Corporation Ken Everhart P.O. Box 288 Williamsport, MD 21795 AATS Date Date PO# Sample #: WW 39650 Submitted: 12/23/91 Reported: 01/15/92 Receipt#: HP-19054 Sample Identification: PVC Compound Collected on at by ANALYSIS RESULT AS RECEIVED LIMIT OF QUANTITATION TCLP Zero Headspace Extraction The extraction was performed by BH The reported results for regulated matrix spike recovery as specified p. 26993. Vinyl Chloride < 0.061 1,1-Diehloroethene < 0.028 Ch1 oroform < 0.025 1,2-Dichloroethane < 0.025 2-Butanone < 0.50 Carbon Tetrach1 oride ( 0. 025 Tnchloroethene ( 0.026 Benzene < 0. 025 T etrach1oroethene < 0.026 Chlorobenzene < 0. 025 on 12/26/91. volatiles were corrected for th in June 29,1990 Federal Register, mg/ 1 mg/ 1 mg/ 1 mg/1 mg/ 1 mg/ 1 mg/ 1 mg/ 1 mg/ 1 mg/ 1 0. 061 0. 028 0. 025 0.025 0. 50 0. 025 0. 026 0. 025 0. 026 0. 025 The volatile organic analyses were perforued on a zero headspace toxicity characteristlc leachate of the submitted waste. The 1 achate was preparea according to the procedure specified in tne March and the June 29,1990 Federal Registers. A sample is considered to have failed the Toxicity Characteristic (TC> test and is therefore considered a hazardous waste if any of the volatile concentrations (mg/1) in the leachate exceed the following maxlma: Benzene Carbon Tetrach1 oride Chlorobenzene Ch1oroform 1,2-Dichloroethane 0. 5 0. 5 100. 0 o. 0 0. 5 1,1-Dich1oroethene Methyl Ethyl Ketone T etrach1oroethene Trlch1oroethene Vinyl Chloride (2-Butanone) 0. 7 200. 0 0. 7 0. 5 0. 2 'he analysis for TCLP was The method used was SW846 subcontracted performed by method 8240. AJS on 01/04/92. Respectfully Submitted American Analytical Testing Services, Inc. Review d and Approv d by: Howard E. Holzman President CTL031643 * MaterialSafety Datasheet DATE PREPARE): MARCH23.1992 CertainTeedEI CertairiJeed Corporation P.O.Box 860 Valley Forge, PA USA 19482-0101 (215)341-7000 EMERGENCY TELEPHONE: CHEMTREC (800) 424-9300 PRODUCT IDmiFICATION All types & grades of extruded & injection molded Vinyl Siding and Vinyl Siding Accessories; Vinyl Window Lineals and Vinyl Window Accesories; and Regrind Chemical Name: CAS No.: Common Name: NFPA Rating: HMIS Rating: None None None Health Fire Reactivity 01 0 00 0 (See Section 8 for acronyms/definitions.) Degree of Hazard 0 - Minimal (Insignificant) 1 - Slight 2- Moderate 3 - Serious (High) 4 - Severe (Extreme) * - Chronic Health Effects) Description: For Regrind, CertainTeed Vinyl Siding and Vinyl Window Lineals have been ground into chips. 0 1. INGREDIENT nFORMATION All ingredients arc chemically or physically bound during the manufacturing process. Sawing siding and lineals or handling regrind may produce nuisance dust. Chemical Name: CAS No: Common Name: None None Nuisance Dust Exposure Limits: QSHA PEL Total Dust: 15 mg/m1 Respirable Dust 5 mg/m5 ACGIH TLV Total Dust: 10 mg/m3 OTHER None Percent in Product: N/A LD*: Not Available LCj*: Not Available This chemical is listed on: EPA SARA Title III, Section 313 , 302 , California Proposition 65 , Not Listed)g(, 2. PHYSICAL DATA Boiling Point (*F): None Vapor Density (Air=l): N/A Melting Point (F): Unknown Specific Gravity: Unknown Odor: None % Volatile by Volume: N/A % Solubility (H20): Insoluble Vapor Pressure: N/A Appearance: Various colored chips. vinyl siding or vinyl window lineals. Page 1 of 3 cTL031644 01-08-0040(3/91) 3. FIRE JUID EXPLOSION HAZARD DATA Flash Point CP) and Method: Not applicable to solid products. Flammable Limits: LEL: N/A UEL: N/A Autoignition Temperature: N/A Extinguishing Media: Water spray, carbon dioxide, dry chemical. Special Fire Fighting Procedures: Fire fighters should wear NIOSH/MSHA approved self-contained breathing apparatus. Unusual Fire and Explosion Hazard: Toxic or irritating vapors, including hydrogen chloride, carbon dioxide and carbon monoxide, may be generated when the product is subject to heating or combustion. 4. PHYSICAL HAZARDS Stability: Chemically Stable Corrosivity: Not Corrosive Reactivity: Stable. Hazardous polymerization will not occur. Incompatible Substances: None Reactivity with Water: None 5. HEALTH HAZARD DATA Primary Routes of Entry: Inhalation, skin and eye contact Acute Effects: Inhalation: Inhalation of dust may cause temporary respiratory discomfort Skin: None Eyes: Mishandling these products may result in traumatic eye injuries. Ingestion: No known effects. Medical Conditions Which May Be Aggravated: Bronchial asthma or other chronic obstructive respiratory diseases may be aggravated by exposure to products of thermal decomposition. Chronic: Skin: None Inhalation: None Page2 of 3 TLO31645 8. EMERGENCY AND FIRST AID PROCEDURES Eye Contact: Rush eye(s) immediately with water, including under eyelids for at least IS minutes. Contact a physician for further evaluation. SkinContact: No known effect. Ingestion: Unlikely. Consult a physician if ingestion occurs. Explosion: Does not support combustion. Fires: Remove to fresh air, administer oxygen, get medical help. 7. SPECIAL PROTECTION INFORMATION Personal Protective Equipment: Respiratory System: Provide ventilation to control nuisance dust levels to worker exposure limits. Eyes: Safety goggles or safety glasses with side shields. Skin: Protective gloves when handling hot material. Other Protection: Eye wash and safety shower. Storage: To maintain product quality, store in a cool, dry, well-ventilated area. Waste Disposal Information: Scrap material should be swept or scooped into a sealed, labeled container for recovery or disposal. Dispose in accordance with applicable federal, state and local government regulations. Extruded CertainTeed Vinyl Materials are not presently listed as a hazardous substance by RCRA, Subpart C, 40 CFR261. 8. ADDITIONAL COMMENTS Acronyms/definitions used in this MSDS: ACGIH: American Conference of Governmental Industrial Hygenists CAS No: Chemical Abstracts Service Number EPA: Environmental Protection Agency HMIS: Hazardous Material Identification System LC50: The air concentration of a substance, when administered over a specified time period in an animal assay, is expected to cause the death of 50% of a defined animal population. LDjo1 The single dose of a substance that, when administered by a defined route in an animal assay, is expected to cause the death of 50% of a defined animal population. LEL: Lower Explosive Limit mg/m3: Milligrams per cubic meter N/A: Not Applicable NFPA: National Fire Protection Association OSHA: Occupational Safety and Health Administration PEL: Permissable Exposure Limit RCRA: Resource Conservation and Recovery Act SARA: Superfund Amendments and Reauthorization Act Title III: Emergency Planning and Community Right to Know Act Section 302 - Extremely Hazardous Substances Section 313 - Toxic Chemicals TLV: Threshold Limit Value UEL: Upper Explosive Limit CTL031646 Page3of3 CTL031647 Vinyl Building Products Group CertainTeed Corporation Governor Lane Blvd PO Box 290 WilliamsDort. MD 21795 301 223-7900 CertainTeed El October 1, 1992 Ms. Marcellina Gurley Air Toxics and New Source Permits Division Air Management Administration Maryland Department of the Environment 2500 Broening Highway Baltimore, Maryland 21224 RE: Paint Spray Booth Permit Application Dear Ms. Gurley: Some weeks ago, I received a call from another individual from your department who requested additional information in support of our application for a permit to operate our paint spray booth. I apologize, but I have not been able to recall this individual's name to respond directly to him. I trust that you will please be so kind as to provide this correspondence to the official who is presently handling this permit review. As mentioned, we were contacted by your office, and we w re advised that our application was not complete as we had not provided all of the MSDSs which corresponded to the raw materials used in the paint booth. Because of this, we have contacted ach supplying vendor and we have in fact received a few new MSDSs in response. We are however still awaiting several more sheets, which will provide to you all together. I wanted to pass this information along to impress upon you that we are not in any whatsoever delaying our response to this most important issue; our response to the information requested is dependent however on the responsiveness of our vendors, which has been slower than we would have liked. We will immediately forward those materials which you require to complete your review as soon as we receive them. the interim, should you have any questions, please do not hesitate to contact the writer. Sincerely, CTL03l648 In Kenneth L. Everhart, Jr. Manager, Safety & Environmental Affairs Number of pages to follow this cover- FACSIMILE TRANSMITTAL TRANSMITTED FROM: Kenneth L. Everhart. Jr. CERTKINTEE1) CORPORATION P. O. Box 290 * Gov. Lane Blvd. Williamsport, Md 21795 Telephone: (301) 223-7900 Ext. 12 Telex: (301) 223-7950 FAX: (301) 223-6249 TRANSMIT TO: COMPANY NAME: /fe/AV & MAIL STOP: TELEPHONE:_ FAX NUMBER: b ") 6 ?*)??>'/? CertainTeedH Kenneth L. Everhart. Jr. ' 'anaaer S3tetv & Environmental Affairs CertatnTeed Corooration ^vi Buiiaina P'ocucts Greuo & Shelter Materials Grouo DC Box 290 u2ne0ivC .Viii.amsDort MO 21795 :01 223-7900 voice Man 800 359-7298 Box 2722 -ax 301 223-6249 CertainTeedH CTL031649