Document gEgp3jDx6Gqye2qxROM81ZOEN

Vista Chemical Company September 12, 1989 900 Threadneedle Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 TGG: JCl W1''-- AJ0: RF XF; Ms. Lynn Bradley Chemistry Section/Registration Division Mail Code T5767 Office of Pesticide Programs EPA 401 M Street, S.W. Washington, D. C. 20460 Dear Ms. Bradley: This letter is to provide ultraviolet absorbance data for the LPA Solvents to verify those products which meet all the physical requirements of 21 CFR 172.884. The data requested is attached. It is my understanding that you will provide Vista a letter as requested to verify your agreement that our products do meet the definition in 21 CFR 172.884. Also we are requesting the establishment of a Pesticide Ingredient Inert Master File be established for these solvents, in case confidential business information is necessary in the future. Thank you for your attention to this matter. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager dlj Attachment VVV 000013936 SEP-GS-'O FRI 10:35 ID:UI STA R*D TEL NQ:512-331-^3bV Tom Grumble*, Environmental. Houston interoffice Communication From: Data: Subjoot W. L. Sorensen. R&D, Ponca City September 8, 1989 21CFR 172*844 Specs for LPA-140 and LPA VISTA LPA Solvents Attached is ASR-04*86-6814*20, which concludes that LPA-210 meets the UV requirements for 21CFR 178.3620 (c) - technical white mineral oil* The technical white mineral oil UV specifications are more restrictive than the 21CFR 172.884 odorless light petroleum hydrocarbons. Hence LPA-210 should pass the odorless light petroleum hydrocarbon UV specifications with no problems. LPA and LPA-140 should also pass the 21CFH 172.884 UV specifications because they contain less aromatics than LPA-210. Some GCfMS work (2-26-87) indicated LPA-210 had 0.6% aromatics, LPA-140 had 0.2% aromatics which means LPA would have ~0.3% aromatics. This assumes the UV test is basically a test for aromatic content Yvayne aorensen Chemicals Technology jms cci JTP, JFL, JCP, RLP, RBM VVV 0000139B7 SEP-08-'00 FRI 10:36 ID:UISTfi R&D TEL NO:512-331-2337 H233 P03 roffU* nwmmkcrtfon ASR No.: ASR-04-86-6814-20 TO: M. M. Goodreau, Environmental* Houston FROM; DATE: T. M. Latimer, Research and Development, Ponca City December 22, 1986 SUBJECT*, FDA REQUIREMENTS FOR MINERAL OILS (2ICFR 1783620(c)): LPA210 AND C1416 NORMAL PARAFFINS VIS1A QPJECT: To determine if LPA-210 and Cl416 normal paraffins meet the FDA requirements set forth in 21 CFR 1783620(c) for minerat oils used in rolling oil applications. KEYWORDSiFDA. LPA, Normal Paraffins CONCLUSIONS Sample 141610l (Cl4ie normal paraffins) and sample 7010-L611 (LPA-210) meet the FDA requirements for initial boiling point, color and ultraviolet absorbance. Tlie results are given in Table 1. SUMMARY The methods used in this work were ASTM D86 for the initial boiling point, ASTM D1500-82 for color and 21CFR 1783620(c) for the ultraviolet absorbance. The detailed procedure for the determination of the absorbance is attached to the end of this report The experimental section which follows is a brief summary of the absorption procedure. The resulting UV spectra are shown in Figure 1. The distillation data for the samples are given In Appendix 1. T. M- Latimer Research Chemist cc: DRW JTF WLS - Ponca City PQ JJU FRW - Houston KBY - LCCP JLN Oak Brook 00001^38 yVV SEP-08-'00 FRI 10:36 ID:VISTA Rjfl TEL NO:512-331-2387 *4233 P04 ASR No. ASR-G4*86*6814*20 December 22, 1986 Page 2 SUMMARY OF THE EXPERIMENTAL PROCEDURE FOR THE DETERMINATION OF THE ULTRAVIOLET ABSORBANCE All glassware was washed with chromic acid, rinsed thoroughly with deionized water and allowed to air dry. All reagents were tested and found to meet the specifications of the method. A list of the reagents used is attached jn Appendix 2. The instrument used to measure the ultraviolet absorbance was an IBM 9420 UV-Visible Spectrophotometer. A 20 gram sample of the oil was dissolved In Isooctane and extracted three times with a mixture of dimethyl sulfoxide and phosphoric acid (DMSO/H3PO4). The DMSO/H3PO4 solution was diluted 3:2 with water and back extracted twice with isooctane. The isooctane back extracts were washed three times with water, filtered through anhydrous sodium sulfate and combined in an Erlenmeyer flask. 1 ml of hexadecane was added and the isooctane was removed by evaporation on a steam bath under a stream of nitrogen to concentrate the extracted residue to a volume of 1 ml. The residue was transferred to a 200 mi volumetric flask and made to volume with isooctane. The absorbance was measured in 1 cm cells compared to isooctane as the reference. Both samples met the absorbance specifications at this point and It was not necessary to perform the chromatography portion of the procedure. VVV 000013939 TABLE 1 RESULTS OF THE FDA SPECIFICATION TEST 21 CFR 178.3620 (c) SAMPLE 1416-101 Cl416 Normal Paraffins 7010-L611 LPA-210 Reagent 8UWfTa) INITIAL BOILING POINT 476.6F 461.4F FDA Specification >450F COLOR <0.5 <0.5 < 5.5 MAXIMUM ULTRAVIOLET ABSORBANCE 280-289run 29Q-299nm 300-359im 360-~400na 0.273 0.188 0.111 0.006 0.009 0.002 < 0.7 0.007 0.002 < 0.6 0.005 0.001 < 0.4 0.001 0.001 < 0.09 (a) The Reagent BLANK is used only in the UV-absorbance test,