Document aJjL6mXpJrnm7wkDKaMNQgy7y

TO: Wayne Hilgers iV'-r-H.c ftcib Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles June 9, 1986 "FOOD GRADE" ACID VISTA As we discussed, the Food & Drug Administration (FDA) has yet to finalize it's determination on the proposal to revoke GRAS status for by-product hydrochloric acid. That decision is not on the agency's priority list according to the current project manager at FDA. The proposed specifications for hydrochloric acid, including benzene levels, have been published by the Food Chemicals Codex in a second supplement to the third edition (attached). Based on the above, and the current manufacturing conditions at Baltimore, I recommend the following statement or portions of the statement be added to the Muriatic Acid technical data sheet or other marketing material. FOOD AMD FOOD PROCESSING APPLICATIONS Vista has available Muriatic Acid that meets or exceeds the specifications for hydrochloric acid set forth in the Food Chemicals Codex, Edition III, Second Supplement. Specifications can be provided to assist in establishing the suitability of this acid for use in food or food processing applications. Please let me know if you would like me to prepare a letter or presentation for the "acid marketers" to assure their understanding of the issues involved in the food grade certification question. Thomas G. Grumbles ajo/9 Attachment cc RAK, MJF, PCG, RRC, PTH, THH, OCK, BRBM, DTP vvv oooon017 SECOND SUPPLEMENT TO THE THIRD EDITION FOOD CHEMICALS CODEX COMMITTEE ON POOD CHEMICALS CODEX Food ond Nutrition Board Commission on Life Sciences National Research Council NATIONAL ACADEMY PRESS Washington, D-C 1986 VVV 000017013 Ub^UJ/' cb 15:11 RtD LST NO. 015 003 NATIONAL ACADEMY PRESS 2101 CONSTITUTION AVENUE, NW WASHINGTON, 20419 NOTICE The project that Is the subject of this report u approved fay the Oovemirtg Board of the Nstlonai Research Council, whose memben ere drawn from the Councils of the National Academy of Sciences, the National Aeademy of Enginesrinx, and the Institute of Medicine. The memben of the Committee reeponaible for the report were chosen for their special competences and with regard for appropriate balance. national research counol The National Research Council waa established by the National Academy of Sciences In 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and of advising the federal government. The Council operates in accordance with genera] policies determined by the Academy under the authority of its congressional charter of 1$63, which establishes the Academy as a private, nonprofit, self-governing membership corporation. The Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering In the conduct of their services to the government) the public, and the scientific and engineering communities It is administered jointly by both Academies and the Institute of Medicine. The National Academy of Engineering and the Institute of Medicine warn established in 1964 and 1970, respectively, under the charter of the National Academy of Sciences. rooo and nutrition board The Food and Nutrition Board was established in 1940. It is a division of the Commission on Life Sciences of the National Research Council. The Board serves as an advisory body in the field of food and nutrition. It promotes needed research and helps interpret nutritional science in the interests of public welfare. The Board acts in response to requests from public agencies and, at times, on its own initiative. The Board is active in areas of dietary guidelines, nutrition and health, food safety, food chemicals specifications, food resources, and international nutrition programs. It has established, among other important guides, recommended dietary allowances, principles and procedures for the evaluation of the safety of foods, specifications of identity and purity for food chemicals, guidelines for nutrient fortification of foods, and recommendations for maternal and infant nutrition. The Food and Nutrition Board draws upon the knowledge and expertise available from the combined resource of academia, government, and industry. Financial support for the work of the Board is primarily provided by government contracts and grants. In addition, uncommitted support is provided by private foundations and industrial organizations. Through memben of its liaison panels, technical input in aspects of nutrition, food safety, food technology, and food processing is provided. This study is supported by U.S. Food and Drug Administration Contract No. 223*78*2053 (formerly Grant No. FD 00213). compliance with federal Statutes The fact that an article appears in the Food Chemicals Codex or its supplements does not exempt it from compliance with requirements of sets of Congreat, with regulations and rulings issued by agencies of the United States Government under authority of these acts, or with requirements and regulations of governments in other countries that have adopted the Food Chemicals Coda. Revisions of the federal requirements that affect the Codes specifications will be Included io Codes supplements as promptly as practicable. LIBRARY OF CONGRESS CATALOG CARD NUMBER 81*38403 INTERNATIONAL STANDARD BOOK NUMBER 0-309-030900 Copyright lfgg by the National Academy Frees So fart ofthis book may be reproduced by any mechanical, photographic, or electronic process, or In theform ofa phonographic recording, nor may it be stored in a retrieval system, transmitted, or otherwise copied for public or private Use, without written permission from the publisher, except for the purposes ofofficial use by the United States Government Printed in the United States of America National Academy press The National Academy Press was tuvatud by the National Academy of Sciences to publish Ihe rppucls issued by the Academy and bv the National Academy of Knginucring. the Institute of Medicine, and the Natlonavesearrli Council, all operating under the charter granted to tiw National Academy ofScium-cs by the Congress of ih<? united States. VVV 000017019 Ui J 52 / fcc ui-second supplement / Monographs fraction, take care to include all saccharides in the standard composition calculation. Compute the dry-basis concentration (C)> in percent, of each individual component in the standard solution by the formula: C = (W'/lWt) X 100. in which Wt is the weight of the sugar of interest and 2 Wt is the sum of all sugar components. Standardize by injecting 10* 20 ill (about 1.0-2.0 mg solids) of the standard sugar solution. Integrate the peaks and normalize. Sum the individual DP4+ responses from the normalized printout to obtain the total DP*+ normalized response. Calculate the response factors as follows (see page 476, and page 73 of THIS SUPPLE MENT): _ __ known concentration, dry basis %, *' ~ measured concentration, normalized % ' In which R, Is the response factor for component L Compute the response factor for each component relative to glucose (A'.) using the following equation: R`, -- Rj/Rft, in which is the response factor for glucose. The R`, for DPlr should be programmed as a default value {if automated equipment is used) and used to compute the concentration of higher saccharides. Sample Analysis Determine the solids content (see below) of the sample and dilute to approximately 10% solids with water. Iryect a volume (10-50 jil) appropriate for the specific solids content. Calculation Calculate the concentration of each compo nent as follows: c, = (A, X Rt X looycs^A,), in which A, is the area recorded for that component and XAaR,, is the sum of the product of the areas (.4) and response factors (A) for all components detected. Arsenic A Sample Solution prepared as directed for organic compounds meets the requirements of the Arsenic Test, using 1 ml of Standard Arsenic Solution (1 ^ig of As). Color Apparatus Use a suitable variable-wavelength spectro photometer capable of measuring percent transmittance throughout the visible spectrum and designed to permit the use of sample and reference cells with pathlengths of 2-4 cm. The transmittance of all paired cells should agree within 0.5%. Standard Solution Dissolve 0.10 g of reagent grade potassium dichromate (K,CrjOT) in 1 L of water and mix thoroughly. Procedure With water in sample and reference cells of 2cm paihlengtb adjust the percent transmittance scale of the spectrophotometer to 100%. Leave the reference cell in place and replace the water in the sample cell with the Stundard Solution: determine the wavelength at which it exhibits exactly 54.5 percent transmittance. This wavelength is Uwfined ns X,, tho cormeied 45n.nm wavrlrriffhi Rcmt)ve lh? 2 .cm cells from the spectrophotometer and with wuter in the sample and reference cells of 4-cm pathlengih adjust the =2-3 percent transmittance scale to 100% with the spectrophotom eter set at X,. Leave the reference ceil In place and replace the water in the sample cell with the sample of high-fructose com syrup. Measure the percent transmittance (7*4M). Remove the sample cell, set the wavelength at 600 nm, replace the sample with water, and adjust the percent transmittance scale to 100%; then determine the percent transmittance at 600 nm (T'mo) with the same sample of high-fructose com syrup in the sample cell. Calculate the Color (C) of the sample with the following formula: C (log iTuyi -- log 4, in which Tw is the percent transmittance at 600 nm and ia the percent transmittance at 450 nm. Heavy Metals Prepare and test a 2-g sample aa directed in Method II under the Heavy Metals Test, page 5)2, using 20 fig of lead ion (Pb) in the control (Solution A) and 500" aa the ignition temperature. Lead Transfer 10 g of the sample to an evaporating dish, add 5 ml of sulfuric acid solution (1 in 4), mixing it thoroughly with the sample, and evaporate most of the water on a steam bath. Char and dehydrate (he sample by heating on a hot plate, while heating at the same time with an infrared lamp from above, and then heat in a muffle furnace at 500* until the residue is free from carbon. Remove the dish from the furnace, cool, and cautiously wash down the inside of the dish with warer. Add 1 ml of 1 A hydrochloric acid, evaporate to dryness on a steam bath, then add 2 ml of 1 ,V hydrochloric acid, and heat briefly, while stirring, on a steam bath. Quantitatively transfer the solution into a separator with the aid of small quantities of water, and neutralize with 1 N ammonium hydroxide. This Sample Solution meets the requirements of the Lead Limit Test, using 10 g of lead ton (Pb) in the control. Residue on Ignition Ignite 5 g as directed under Residue on Ignition, page 533. Solids Determine the percent solids from the refractive index (see page 533) as directed under High-Fructose Corn Syrup Solids, page 84 of THIS SUPPLEMENT. Sulfur Dioxide Proceed as directed under Sulfur Dioxide, page 546, using a 100 g sample. Packaging and Storage Store in tight containers, Functional Use ia Foods Nutritive sweetener. Hydrochloric Acid, page 144 Replace the Description and Requirements with the following: DESCRIPTION A water solution of hydrogen chloride of varied concentrations. It is clear, colorless or slightly yellowish, corrosive liquid having a pungent odor. It is miscible with water and with alcohol. Conccmrations of hydrochloric acid commercially VVV 000017020 06/ U-_j ir'6 15: 10 N'&D [<ts | i *j. uio uuj FCC JIl*5ECOND SUPPLEMENT / MOttOgrophs / S3 available are usually expressed in Baume degrees (Be*) from h percentages of hydrochloric acid and specific gravities w readily be derived (see Hydrochloric Acid Table, page 514). The usually available concentrations are 18*. 20*. 22*, and 23* Be. Concentrations above 13* Be (19.6%) fume in moist air, lose hydrogen chloride, and create a corrosive atmosphere. Because of these characteristics, suitable precautions must be observed during sampling and analysis to prevent losses. Note: Hydrochloric acid is produced by various methods that might impart trace amounts of organic compounds as impurities. The manufacturer, vendor, or user is response ble for identifying the specific organic compounds which are present and for meeting the Requirements for Extracta ble Organic Compounds. Methods are provided for their determination, in applying the procedures any uwcwu) standards should be used to quantitate the organic com* pounds present in each specific product. The variety of organic impurities that might conceivably be found in hydrochloric acid is such that it is impossible to provide a comprehensive and accurate list here. Therefore, the manufacturer, vendor, or user is responsible for establishing the suitability of such hydrochloric add for its intended application in foods or food processing in accor dance with the provision on Trace Impurities, page 3. REQUIREMENTS * `entifleatioo .gives positive tests for Chloride. page 516- Assay Within the range of Baum6 degrees specified or implied by the vendor. Arsenic (as As) Not more than 1 mg/kg. Color Passes test. Concentration of HC1 Within the range specified or Implied by the vendor. Extractable Organic Compounds Total Organic Compounds (tfon-Fluorine-Contalnlng) Not more than 3 mg/kg, including: Benzene Not more than 0.03 mg/kg. Vinyl Chloride Not more than 0.05 mgAg. Fluoridated Organic Compounds (total) Not more than 25 mg/kg. Heavy Metals (as Pb) Not more than 5 mg/kg. Iron Not more than 5 mg/kg. Nonvolatile Residue Not more than 0.5% Oxidizing Substances (as Ch) Not more than 0,003%. Reducing Substances (as SO.t) Not more than 0.007%. Specific Gravity Within the range specified or implied by the vendor. Sulfate Noi more than 0.5%. TESTS Extractable Organic Compounds Proceed as directed under Extractable Organic Compounds (in Hydrochloric Acid), page 80 of THIS SUPPLEMENT. Insert the following new monograph to precede the monograph entitled Iron, Carbonyl, page 151: Invert Sugar Invert Sugar Syrup, Invert DESCRIPTION Invert sugar is a mixture of glucose and fructose that results from the hydrolysis of sucrose in accordance with good manufacturing practices. IicU sugar is marketed na a oompo* nent of invert sugar syrup that also contains sucrose In various amounts as represented by the manufacturer. Invert sugar syrup is a hygroscopic liquid that has a sweet taste, is very soluble in water, glycerin and glycols, and is very sparingly soluble in acetone and ethanol. REQUIREMENTS Identification Prepare a 10% solution in purified water and inject 7.5 pd into a high-performance liquid chromatographic system equipped with a cation exchange resin maintained at 85* and a differential refractometer detector; the liquid phase is purified water eluting at a flow rate of 0.7 ml per min. The chromatogram of the sample gives appropriate elution times for fructose, glucose, and sucrose when compared to a standard solution containing 1 g of each saccharide in 100 ml of purified water. Assay Sucrose and invert sugar content shall be as represented by the manufacturer. Arsenic (as As) Nat more than 3 mgAgHeavy Metals (as Pb) Not more than 7 mgAg. Lead Not more than S mgAg. pH Not less than 3 nor more than 5-3. Residue on Ignition Not more than 0.2%. Total Solids As represented by the vendor. Total Sugars Not less than 99.5% of the total solids content. TESTS Assay Apparatus Mount a ring support on a rmgstand 1-2 in- above a gas burner, and mount a second ring 6-7 in. above the Arst. Place a 6*in, open-wire gauze on the lower ring to support a 230-ml Erlcnmeyer flask, and place a 4-in. watch glass with a center hole on the upper ring to deflect heat. Attach a 30-ml buret to the ringstand so that the tip just passes through the watch glass centered above the flask. Alternatively, a buret with an offset lip may be used in place of a buret with a straight tip extending through the hole in the center of the watch gU*s. Place an indirectly lighted white surface behind the assembly for observing the end point. VW 00001^021 Ob---03- '86 15: 13 RS.D WEST NO.G15 006 80 / fcc m*SECOND supplement / Central Tesu and Apparatus must be between 0.95 end 1.00 for any single experiment nr from Accumulated data. Recalibrate the system after every ten determinations or two days; whichever occurs first. Sample Preparation Prepare as directed in the individual monograph. Procedure Inject the volume of Sample Preparation as desig nated m the monograph Onto the column. Determine the concentration of intermediates and side reaction products from the peak areas using the slope (m) and intercept (6) calculated under Calibration by the equation: At -- mCt -+- bt in which C, Is the concentration of the unknown in the Sample Preparation and A,iti corresponding peak area. VOLATILE MATTER Transfer 1.5-2.5 g of colorant, accurately weighed, to a tared crucible. Heat in a vacuum oven at 135* for 12-15 h. Lower the pressure in the oven to minus 125 mm Hg and continue heating for an additional two h. Cover the crucible, and allow to cool in a desiccator. Reweigh the crucible when cool. The loss of weight is defined as the volatile matter. WATER-INSOLUBLE MATTER Transfer about 1 g of colorant, accurately weighed, to a 250-ml beaker and add 200 ml of boiling water; stir to facilitate dissolution of the color. Tare a Gooch crucible equipped with a glass fiber filter (Reeve Angel. No, 5270, or equivalent). Filter the solution with the aid of suction when it has cooled to ambient temperature. Rinse the beaker three times pouring the rinse through the crucible, Wash the filter with water until the filtrate is colorless. Dry the crucible and filter in an oven at 135* for at least 3 h, cool them in a desiccator and reweigh to the nearest 0.1 mg. Calculate the percent water-insoluble matter (/) by: / - <WK/Wt) x 100, in which Wt is the difference in crucible weight and \Vf is the sample weight. the Vapor Partitioning Method for the determination of benzene gnd vinyl chloride. Vapor Partitioning Method This method is suitable for the determination of extractable organic compounds at 0.05*100 mg/kg, but is most appropriate for organic compounds with a vapor pressure greater than 10 mm Hg at 25*. Use a gas chromatograph equipped with a flame ionization detector and a 4*m x 2-imn (id) stainless steel column packed with 13% by weight methyl trifluoropropyl silicone (DCFS 1265. or QF-1. or OV-2JO, or SP-2401) stationary phase on 80/100 mesh Gas Chrom R or the equivalent. A newly packed column should be conditioned et 120* and 30 ml/min helium flow for at least 2 h (preferably overnight) before it is attached to the detector. For analysis the column is maintained isothermally at 105*; the injection port and detector are maintained at 23P; the carrier gas flow rate is set at U ml/min; fuel gaa flows should be Optimised for the gas chromatograph and detector In use. The experimental conditions may be changed as necessary for optimal resolution and sensitivity. The signal to noise ratio should be at least 10:1. Preparation of Standard Solutions Prepare a standard solu tion of the organic compounds to be quantitated in hydrochlo ric acid (known to be free of interfering impurities) at approximate concentrations of 5 mg/kg, or within 50% of the concentrations in the samples to be analyzed. Place a stirring bar in a 1-L volumetric flask equipped with a ground glass stopper and tare the combination. Fill the flask with reagent-grade hydrochloric acid so that no air space is present when the flask is stoppered and determine the weight of the hydrochloric acid. Calculate the volume (V) in of each organic component to be added from the formula*. V = <C X W)/(D X 1000), in which C is the desired concentration in mg/kg, W is weight of the hydrochloric acid in g, and D is density of the organic compound in mg/p.1, and 1000 is a conversion factor with the units g/kg. Add the calculated amount of each component to the hydrochloric acid with a syringe (assure that the syringe tip is under the solution surface), stopper the flask and stir the solution for at least 2 h using a magnetic stirrer. Calibration Treat the standard in the same way as described for the sample under Procedure (below). Determine a blank for each lot of reagent-grade hydrochloric acid and calculate a response factor (A) by dividing the concentration (C) in mg/kg for each component by the peak area (A) for that component (subtract any area obtained from the blank sample): R = C/(A -- area of blank). Extractable Organic Compounds (in Hydrochloric Acid) Extractable Organic Compounds Analyses arc to be carried out by gas chromatography employing Vapor Parittianin% or Solvent Extraction, depending upon the characteristics of the compound being determined It is necessary, however, to use Gaseous compounds present special problems in the prepara tion of standards. Therefore, to determine response factors for gaseous compounds use the following method, which will be referred to as the Method of Multiple Extractions. Dilute a sample of hydrochloric acid known lo contain the gaseous compound of interest with an equal volume of water. Draw 20 ml of this solution into a 50-ntl glu*s syringe; then draw 20 mi of air into the syringe, cap with a rubber septum, and pluce the syringe on a shaker for 5 min. Withdraw l ml of the vapor through the septum and Inject it Into the chromatograph. Expel the vapor phase from the 50-ml syringe, draw in unother 20 ml VVV 000017022 <- Ub.'03.'S6 15: l RZ.D WEST NO. Ulb iJiJV fcc m SECOND SUPPLEMENT / GiH<hl! Ttiih and Appurvtut / 81 of air, repeat the extraction, and inject another I-mi vapor 'ample into the chromatograph. Carry out the extraction and JC analysis on the same sample of acid a total of six times. For each impurity plot the area (A determined for extraction n against the difference between A,, and the area determined for extraction (n + 1); that is* plot An against + ,]. The slope of this line is the extraction efficiency (} for that impurity into the air. Inject into the chromatograph 1 ml of a 0.1% (by volume) standard gas sample of each impurity in air and determine the absolute factor (Fe) in g per peak area (A) by the following formula: Ft = (M X 4.0816 X lO-'J/X, In which M is the molecular weight of the compound. The concentration (C) in mg/kg of the component in the original sample l calculated by the formula: C (A X Ft X 1.6949 X 10*)/JE in which A is the peak area corresponding to the compound (as above). Ft is the absolute factor, and is extraction efficiency. The response factor is then calculated as: R * CM. Procedure Dilute a 10-ml sample of hydrochloric acid to be analyzed with an equal volume of water. Draw this solution into a 50*ml glass syringe. Then draw 20 ml of air into the syringe, cap with a rubber septum, and place the syringe on a shaker for 5 min. Draw 1 ml of the vapor through the septum and inject it into the gas chromatograph. Approximate elution imes in min for some specific organic compounds are as follows: Methane and acetylene Methyl chloride Vinyl chloride 1.1,1-Trtchlorofluoromethane Ethyl chloride Vfnyllden* chloride Methylene chloride Chloroform 1, l-Dichloroethane Carbon tetrachloride 1,l, 1-TrichtorOcthane Benzene Trichloroethylene Ethylene dichloride Propylene dichloride Perchloroethylene 1.70 2.21 2.29 2.62 2.90 3.20 3.64 4.49 4.53 4.86 5.50 6.00 6.22 6.61 8.41 9.73 Alternate columns may be required to resolve some combina tions of components- Methyl chloride and vinyl chloride are resolved by a 3.7-m x 3-mm (id) squalane column at 45* and A helium flow of 10 ml/min. Chloroform and l.l-dichloroethane are resolved by a 4-m x 3*mm (Id) DC 350R column at 110* and a helium How of 12 ml/min. Calculation Calculate the concentration (C) in mg/kg of each compound by multiplying its corresponding peak area (A) by the appropriate response factor (A) determined in the Calibra tion protocol. C ~ R X A. Precision The relative standard deviation at S mg/kg should not exceed 15% for five analyses. Solvent extraction Method The solvent extraction technique la suitable for the determination of extractable organic com* pounds at 0.3-100 mg/kg, but is most appropriate for organic compounds with vapor pressures less than 10 mm Hg at 25*. The conditions for the ga chromatograph are the same as for the Vapor Partitioning method, except that the column tempera* turn i$ 120* and the carrier-gas flow is 21 mi/min. Preparation of Standards Prepare the Standard Solution u described under Vapor Partitioning. Calibration Extract a sample of the Standard Solution as directed under Procedure (below) and inject it into the gas Chromatograph. Determine a blank for each lot of reagent* trade hydrochloric acid and nerchloroethvlena by extracting the hydrochloric add in the same way as the standard. Calculate a response factor (A) by dividing the concentration (Q in mg/kg for each component by the peak area (A) for that component (subtract any area obtained from the blank sample): R = C/(A -- area of blank). Procedure Accurately transfer 90 ml of the hydrochloric add sample and 10 ml of perchloroethylene (free of interfering impurities) into a narrow-mouth 4-oz bottle Place the bottle in a mechanical shaker for 30 min. Separate the two phases (perchloroethylene on the bottom) and inject 3 pi of the perchloroethylene extract into the gas chromatograph- Approx imate elution times in min for some chlorinated organic compounds are as follows: Vinylidene chloride Methylene chloride Chloroform Carbon tetrachloride 1.1,1 -Trichlomethane Trichloroethylene Ethylene dichloride Propylene dichloride Perchloroethylene 1,1,1,2-Tetrachloroelhaoe 1,1,2.2-Tetnchlororthane Pentachloroethane 2.94 3.2? 3.83 4.07 4.50 4.97 5.26 6 36 6 95 10.12 13-70 16.19 To determine perchloroeihylene and higher-boiling impuri ties, substitute methylene chloride (free of interfering impuri ties) for perchloroethylene in the extraction step- For higherboiling impurities such as monochlorobenzene and the three dichlarobenzenes use a 2.74-m X 2.1-mm (id) stainless-steel column packed with 10% carbowax 20M/2% KOH on 80/100 mesh chromasorb W (acid washed) at 150* and a nitrogen flow of 35 ml/ min. Calculation Calculate the concentration (Q in mg/kg of each compound by multiplying (he corresponding peak area (^) (subtract any area obtained from a blank sample) by the appropriate response factor (A) determined in the Calibration protocol: C = R x {A -- area of blank). Precision The relative standard deviation at S mg/kg should not exceed 15% for five analyses. vvv 00001^02* Vista Chemkol Company 15990 N. Barker's Landing Rd. Post Office Box 19029 Hot;slon,Texas 77224 Phone {713) 531-3200 KF June 4, 1986 Mr. B. I. Raffle Supervising Counsel Environmental & Engineering Group Conoco Legal Department P.0. Box 2197 Houston, TX 77252 Certified Mail Return Receipt Requested VK1A Mr. H. J. Neeld Director, Environmental Programs Environmental Conservation Conoco Inc. P.0. Box 2197 Houston, TX 77252 Certified Mail Return Receipt Requested RE: U.S. v. Conoco (Case No. 83-2518) Gentlemen: Pursuant to the Asset Purchase Agreement dated as of July 20, 1984, among E.I. Du Pont de Nemours and Company, Conoco Inc., and Vista Chemical Company, and the Consent Decree entered in the above action, we hereby provide notice of recently-discovered information which may lead to the filing of an Environmental Claim. On June 3, 1986, the Vista Lake Charles Vinyl Chloride plant experienced a RVD which resulted in VC emissions. Please contact me if you have any questions regarding this matter. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo/9 cc W. L. McClain Dick Conrad Ralph Ferrell VVV 000017024