Document Z4wzrEG5RLYoM6pyJ1wqZ2Gm0

Vista Chemical Company 900 Threadneedle Houston, Texas 77079-2990 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224-9029 Fax (713) 588-3236 October 2, 1991 V1SHA TGG: *>--*k K:JdfRF Mr. J ohn Gwyrm Plant Engineer Pilot Laboratories 267 Homestead Avenue Avene1, NJ 07001 Dear John: 1 have reviewed the definition of "Petroleum" in the copy of the NJAC 7: IE-1.6 that you sent. It is my opinion that Vista Nalkylene 500 is not covered by this description. This opinion is based on the apparent intent of the definition to cover classical refinery streams. This is indicated by the use of the words "bituminous liquid", the processes described and the examples given. While the actual intent of the definition cannot be known without speaking to the state, the above is my opinion. Sincerely, Q/hA-s Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj cc: R. R. Cooley VVV 000007941