Document XOk26wyaxxdKyO7LMb76yen6w

Tom Grumbles CowiiwiIuHIuii Subject: R..B. Martin December 20, 1991 HAZARDOUS CHEMICAL REPORTING IN TEXAS VISTA Reporting by RAD on SARA QI has been limited to pilot plant operations. This required only one chemical while in Oklahoma. The first year in Texas there were no reportables in the pilot plant area but in 1990 the usage ofSOz resulted in a reportable level. That material will be reported on current tier 2 forms to the Texas Health Department and the Local Emergency Planning Committee. Early this year 1 received a booklet that covered the Texas Hazard Communications Act. This act requires any business in select SIC codes to report any hazardous chemicals at 55 gal. or 500 lbs. The SIC code that has been used by RAD in the past would exempt RAD however the latest (2809-2) code defined by Houston legal puts RAD in the same classification as all manufacturingplants. The Texas Hazard Communication Act has an exemption for all RAD labs but diseusdon with the Texas Health Department yielded a waiver of the exemption for labs with manufacturing SIC codes. My contact at the Health Dept, was not very conclusive on this problem. I called Texaco Chemical and they report under both SARA and the Texas Hazard Communication Act. A contact was also made with 3M's laboratory and they also report. My intent in writing this letter is to aura concerning this reporting as all of the information is public knowledge. There will be about eight chemicals from the lab in addition to the S02 reporting in the pilot plant. I have a dated letter requesting this information by early January. Robert Martin Dist: J.P. Kirkpatrick, R.L. Poe, JR. Roheim, V.W. Weiss, Houston: L. Zimmerman Z/fi'd VSM 82678 USa blS IA l4b90:0T 26, 0 100