Document jBgwBge0B3NV1kMKVM16MG3M5

Vista Chomical Company 900 TtmadiMsdls Houston, Texas 77079 (713)588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 November 1, 1990 Ms. Kathleen Kunzer Baker & Hostetler Washington Square, Suite 1100 1050 Connecticut Avenue N.W. Washington, D. C. 20036 Dear Katie: Below are Vista's comments on the draft "Glycol Ethers" survey. I believe the cover letter may not be persuasive enough for those companies that have not been involved in this arduous process. Despite the multiple SDA alerts, many may not have heard of this issue, understand it's Impact, or in fact, ever calculated emissions for 313 reporting. Based on these concerns, I think we need to have some more verbiage in the cover letter requesting participation. Specific comments on the survey form: 1. We need to specify a time-frame for the emissions, i.e. CY 89. This should be consistent with a 313 repotting year. 2. The "site identifier" element is confusing and I'm not sure it will be useful without some guidance or pre-numbered forms. 3. If companies utilize the SDA inventory nomenclature for ethoxylated alcohols, the hydrophope name will likely be the same for multiple products. In this case, grouping of emission numbers should be allowed. 4. Ethoxylate is misspelled in Item 4. 5. For purposes of the chart, it is not clear if the total of the 1, 2, and mole ethoxylates should be "lumped" or if individual sheets should be completed for each. 6. Item 6 and 7 ask for annual production. I'm sure most people have variable production rates. These questions should indicate "average" production for a defined period, i.e. 3 years. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj VEV-307553