Document mqkRe9Zdk3REDZQdD54Lk3q0k

Vista Chemical Company 900 Threadneedle Houston, Texas 77079-2990 (713) 588-3000 P.O. Box 1 9029 Houston, Texas 77224-9029 Fax (713) 588-3236 February 5, 1991 Mr. Jack White Vinylume 4021 Mahoney Avenue Youngstown, Ohio 44515 VISTA Dear Jack: As we discussed on the phone, 1 believe simply providing an MSDS for the compound we sell to you would be an inaccurate representation of the health and environmental hazards of the finished products you produce from the compound. We provided you with a SARA 313 notification based on the content of our compound. However, your product probably has little potential to result in an environmental release of any 313 listed materials, specifically metals. Therefore, you may be exempt from any SARA 313 notifications. I have attached information on the 313 customer reporting requirements for your review. Also, the waste classification of the product, or scrap from working the product is determined by a water leaching test, the "TCLP". Wastes with smaller particle size are more likely to allow hazardous constituents to leach into solution during the Toxicity Characteristic Leaching Procedure (TCLP). The TCLP is used to determine whether a waste is hazardous according to the Toxicity Characteristic (TC). Vista has no quantitative data demonstrating PVC compound to be hazardsou. We have anecdotal information regarding PVC compound pellets containing lead. The pellets do not fail TC. However, a wire recycling facility reports that the finely chopped fluff generated at their facility does sometime fail TC. This fluff is a much smaller particle size than the pellets. I would recommend you have some TCLP tests run on representative scrap from working your product to assure that the material would not be classed as hazardous according to the TCLP test. We can get you information on testing facilities in your area if you need. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj Attachment cc: Bob Schettek-Saddlebrook VVV 000011754 Vista Chemical Company 900 Threadneedle Houston, Texos 77079-2990 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224-9029 Fax (713) 588-3236 February 5, 1991 VIS1A Mrs. J. Abbott Department of Energy 1 Palace Street London SWIE 5HE Dear Mrs. Abbott: In response to your letter of 14 December 1990 regarding what base oils Vista Chemical Company supplies, please be advised Vista supplies 0DC and ODC 210. I have attached copies of the acceptance letters for both oils. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj Attachment VVV 000011755 Department of Energy PETROLEUM ENGINEERING DIVISION Thames House South Millbank London SW1P 4QJ Telegrams Energy London SW1 Telephone Direct Line 01 -211 6 10 6 Switchboard 01-211 3000 Vista Chemical Co Industrial Hygiene Product Safety PO Box 19029 HOUSTON Texas 77224 USA and Your reference Our reference ^^34), Date 26 January 1988 S<> BASE OILS 0DC 210 may now be added to the Department of Energy's list of oils accepted for use on the UKCS. They will be added to the list at the next revision. PHIL CAWSE FEB0l'88 Routs: Copy: vvv 000011^56 Department of Energy Petroleum Engineering Division Thames House South Millbank London SW1P4QJ Telegrams Energy London SW1 Telephone Direct Line 01*211 5669 Switchboard 01-211 3000 Mr T G Grumbles Director, Industrial Hygiene & Product Safety Vista Chemical Co PO Box )9029 Houston TX 77224 USA Your reference Our reference 80/729/12 2D* cf* june 1985 Dear Mr Grumbles We have now received the toxicity test report on VISTA ODC base oil and will raise no objection to its use in the formulation of oil-based muds for use on the UK Continental Shelf. Yours sincerely D R Bedborough ,j VVV 000011757