Document k60ZxjdDwJ0Zy4NmLR9xxq3O

Vista Chemical Company 15990 North Barker's landing Road Post Office Box 19029 Houston, Texas 77224 Phone (713) 531-3200 February 9, 1988 Mr. B. I. Raffle Supervising Counsel Environmental & Engineering Group Conoco Legal Department P.O. Box 2197 Houston, TX 77252 VISTACertified Mail Return Receipt Requested P25 8136198 Mr. H. J. Neeld Director, Environmental Programs Environmental Conservation Conoco Inc. P.O. Box 2197 Houston, TX 77252 Certified Mail Return Receipt Requested P25 8136199 RE: U.S. v. Conoco Gentlemen: i 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 February 5, the Vista VCM plant experienced an incinerator by-pass which resulted in VC emissions above the reportable quantity. The appropriate state and federal agencies were notified. Details were given to Jack Neeld by phone. Please contact me if you have any further questions regarding this matter. Sincerely, Thomas G. Grumbles, C.X.H. Environmental Quality Manager aj o .302 cc W. L. McClain M. G. Hayes R. A. Conrad vvv 000000320 r vw 000000321 . P25 8136199 T.. Grumbles RECEIPT FOR CERTIFIED MAIL NO INSURANCE COVERAGE PROVIDED-- NOT FOR INTERNATIONAL MAIL SENT TO H. J. Neeld, Conoco STREET ANO NO. P.O. 2197 P.O.. STATE AND ZIP CODE ,,_ _ Houston, TX 77252 POSTAGE $ CERTIFIED FEE `Vsu) SPECIAL DELIVERY c RESTRICTED OELIVERY a s o u</> lu SHOW T0 WHOM AND DATE DELIVERED <s (A ae CO o 3 CXO CoL o ee SHOWTOWHOM. DATE. ANDAOOHESS OF DELIVERY SHOW TO WHOM AND DATE DELiVf REOWTH RESTRICTED DELIVER*^.--- u c ' sStfro whU^c/iofano ` c c t t * ^ SENDER: Complete items 1 and 2 when additional services are desired, and complete items 3 and 4 Put your address in the "RETURN TO" space on the reverse side. Failure to do this will prevent this card from being returned to vou. The return receipt fee wilt provide vou the name of the person delivered to ana^hadate of delivery. For additional fees the following services era available. Consult postmaster for iraand check box(es) for additional service(s) requested. 1. 0 Show to whom delivered, date, and addressee's address. __ 2. D Restricted Delivery. 3. Article Addressed to> Mr. H. J. Neeld 4. Article Number P25 8136199 'Director, Environmental Programs Type of Service: Environmental Conservation Conoco Inc. P.O. Box 2197 Houston, TX 77252* 5. Signature -- Addressee X Q Registered Certified Express Mail B Insured COD Always obtain signature of addressee or agent and DATE DELIVERED. 8. Addressee's Address (ONLY if requested andfee paid) PS Form 3811, Feb. 1986 QOMgRTir peyjjpM ^SENDER: Complete items l^nd Q when additional services are desired, and complete Items 3 and 4. Put your address in the "RETURN TO" space on the reverse side. Failure to do this will prevent this card from being Returned to vou. The return receipt fee will provide vou the name of the person delivered to and the date of delivery. For additional fees the following services ere available. Consult postmaster for fees ana check boxies) for additional service(s) requested. 1. [SI Show to whom delivered/date, and addressee's address. 2. D Restricted Delivery. 3. Article AddressetTto: i r- - i Mr. B, 1. Raffle* 1 -N Supervising Counsel/!^ ? i, Environmental & Engineering Group Conoco Legal Department P.O. Box 2197 rS> 4. Article Number P25 8136198 Type of Service: Registered Certified Express Mall a Insured COD Always obtain signature of addressee or Houston, TX 11252'________________________ agent and PATE DELIVERED. 5. Signature -- Addressee Xy /y/*,*> \* *-1 ~j -J- 8. Addressee's Address (ONL Y if requestedandfee paid) pSFnrm ftail Fph IQftA. FEB 1 2 1988 - > TO: Distribution ' CS^-tT.O FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles February 3, 1988 OSHA ETO SHORT-TERM EXPOSURE LIMIT RULEMAKING VISTA On January 21, OSHA promulgated the long expected short-term exposure limit for EtO. The limit is 5.0 ppm as a 15-minute time-weighted average. The standard basically revises the 1.0 ppm 8-hour rulemaking of 1984 to include a 5.0 ppm short-term limit. Several nuances to the standard. The most obvious is OSHA calls the new limit an "Excursion Limit". This is a new term for OSHA. Their rationale for this is explained in the standard. Another concern is the applicability of the 5 ppm limit to product exemptions. The 1984 standards addressed EtO residuals in products by allowing exemptions where objective data demonstrated that EtO could not be released to the environment in levels tnat would create exposures above the action level of 0.5 ppm for an 8-hour TWA. The new rulemaking applies the 5.0 ppm limit to this exemption. In other words objective data must also demonstrate that EtO could not be released to the atmosphere and create 15-minute exposures of 5.0 ppm. We need to evaluate our ethoxylates according to this criteria to be prepared for customer inquiries. The comment period ends on February 22, with a hearing scheduled for March 3. The standard will probably be final sometime this Summer. The EOIC will be making lengthy comments regarding the technical content of the standard but not specifically opposing the 5.0 ppm limit. Please let me know if you think Vista should comment. ^--------------- T. G. Grumbles aj o .308 Attachment cc B. McClain D, Cohen C. Matson J. Friend DIST: S. Pitts R. Martin 000000323