Document mpgDbgMxg9ZMawZ1MJneO810Z

Vista Chemical Company 900 Threadneedie Houston, Texas 77079 {713} 588-3000 P.O. Box 19029 Houston, Texas 77224 Fox (713) 588-3236 T-G6: ^lT XF: i pp August 7, 1989 Mr. John Braddy Manager - Marketing Department Petroferm, Incorporated 5400 First Coast Highway Fernandina Beach, FL 32034 VIS1A Dear John: Below is an attempt at addressing your questions resulting from our meeting on August 1. You asked me to provide information regarding how you could respond to the following three questions. 1. Can you put LPA-210 in a sewer that goes to a POTW? There is a very general regulatory restriction regarding this that may mean the answer is no. 40CFR 403.5(a)(1) states a user of P0TW may not introduce into a POTW any pollutant which causes "pass-through1' or interference. Interference means disrupt the operation of the POTW. As stated, this is a very general definition and prohibition. Obviously concentration, volumes, etc. would be important to determine an absolute answer. There are two more specific prohibitions that may apply, once again, depending on specific use conditions. 40CFR 403.5(b)(1) prohibits introducing pollutants to the POTW that create a fire or explosion hazard in the POTW. Based on the physical properties of LPA-210 this probably wouldn't be a problem. 40 CFR 403.5 (c) and (d) allow the P0TU to set specific oil and grease limits to allow the POTW to meet it's discharge limits. This may apply to specific users of any particular POTW. VVV 000009478 2. Can you put: LPA-210 in a septic tank? We know of no specific regulatory prohibition, however in significant amounts the solvent may interfere with the operation of the septic, i.e. kill the bogs, and allow pass through of the solvent. If this occurs, ground water contamination is a potential concern. 3. Can you pour it on the ground? I believe the answer to this is no. If you do this the LPA210, like all relatively non-volatile hydrocarbons can contaminate surface waters nearby or leak to groundwaters. I have enclosed a copy of the last proposal for the Toxicity Characteristic (TC), or TCLP, definition rule changes for identifying hazard waste. I have also enclosed a pre-Federal Register draft of the final rule. As you can see these are lengthy, but I don't know how to adequately summarize them for you without possibly leaving something of interest out. I have also enclosed a copy of our drum and bulk container labels for LPA-210. As to the comparative regulatory issues for LPA-210 vs. 150 Flash Solvent. I've listed the regulatory issues I believe to impact 150 solvent that don't impact LPA-210. This is probably not a complete listing, but these items are my thoughts based on my knowledge of this type of product. 1. DOT Classification: hazardous (combustible liquid) in containers greater than 110 gallons in volume, there for requires placarding, labeling, BOL's, etc. 2. OSHA Hazard communication (1910, 1200): physical and health hazard (combustible, irritant)which requires labeling, etc. The solvent may contain aromatics or PNA's which cause it to be classed as a carcinogen. Probably has a lower exposure limit. 3. EPA Regulations: Based on physical properties may be a V0C by federal or specific state regulations. Aromatic content, such as benzene, toluene, or xylene, may cause it to "flunk" TCLP criteria and become a hazardous waste for disposal purposes. The aromatic content may cause SARA 311, 312, or 313 reporting and record keeping. 4. Other: aromatic content may trigger California Proposition 65 labeling and warnings. VVV 000009479 I think I've answered your specific questions at this time. Please call me at (713) 588-3445, if you have questions on the information above. It was a pleasure to meet you after our many phone conversations. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager tmp Enclosures Vvv 000009480