Document nmkeDezJkpBxY8X9mnqOXxj4m

Vista Chomtcai Company 15990 N. tartar's Landing Rd. Post Offica tax 19029 Houston,Txas 77224 Phorw (713) 531-3200 September 11, 1984 Mr, Gary Burling Asst. Purchasing Agent The Lubrizol Corporation 29400 Lakeland Blvd, Wickliffe, OH 44092 VISIA Dear Gary: Enclosed is a Material Safety Data Sheet for Vista Chemical's Diphenylalkane. In Section 5 of the MSDS we have listed the acute toxicity testing results which you requested. We have not done any long term testing to determine the mutagenic or carcinogenic properties of this product. Please feel free to contact me if you have further questions regarding this toxicity data. Sincerely, /) Thomas G. Grumbles, C.I.H. Director, Industrial Hygiene ajo Enclosure cc Dave Buell VVV 0000162^4 Interoffice Communication TO: Distribution XF: FROM: T. G, Grumbles DATE: September 11, 1984 SUBJ: VISTA COMMENTS TO THE FDA: GRAS REVOCATION OF BYPRODUCT MURIATIC ACID VISTA Enclosed is a draft of the comments we will send to FDA regarding the agency's proposal to revoke the GRAS status of all byproduct muriatic acid. Please review and return any comments or changes to me or Betsy Myer by September 19. We need to have the final comments in the mail by September 21, X, orrc'*---------------Thomas G. Grumbles ajo Enclosure cc Tom Huffman, Bob Klein, Mike Fortier, R. D. Gamblin Distribution: Jim Gibson, Kyle Resh, Carl Kerfoot, Betsy Myer Wayne Hilger, Nelson Borys, Bill McClain 0000162^ vvv September 11, 1984 DRAFT Dockets Management Branch (HFA-305) Food and Drug Administration Room 4-62 5600 Fishers Lane Rockville, MD 20857 Dear Sirs: Vista Chemical Company (formerly Conoco Chemicals Company) is a major producer of byproduct muriatic acid in the NALKYLENE Detergent Alkylate process at its plant in Baltimore, Maryland. Vista appreciates the opportunity to comment on the FDA proposal to revoke the GRAS status of byproduct hydrochloric acid, which appeared in the Thursday, April 26, 1984 Federal Register. The FDA stated that the reason for this action is the concern for undesirable contaminants in byproduct acid. The potential for specific organic contaminants in byproduct acid is highly variable, dependent on the process involved and the post treatment after production. To categorically revoke GRAS status for all byproduct acid regardless of general or specific contaminants levels in the final product, is not an appropriate manner to address the contaminant concern. It would seem more appropriate to develop performance standards based on process design or specific contaminant levels in finished product. VVV 0000X6296 The Agency stated that to evaluate a specific type of byproduct hydrochloric information was needed regarding the manufacturing Dockets Management Branch (HPA-305) Page 2 September 11, 1984 process and contaminant levels. The following is offered in order to supply that information on Vista Chemical's process. VISTA PROCESS DESCRIPTION VistaTs NALKYLENE process is a propritary process which reacts normal paraffins with chlorine to produce chloroparaffin and then alkylates the chloroparaffin with benzene in a Friedel-Crafts reaction catalyzed with aluminum chloride. Both the chlorination and alkylation reaction liberate HC1 gas which is absorbed in water to produce muriatic acid. The muriatic acid is then subjected to multiple purification steps before being sold. A more complete description of the HCl/muriatic acid production and purification process at the Vista plant is as follows: Chlorination Step The major feedstocks to the chlorination section of the Vista NALKYLENE process are normal paraffins in the Decane to Dodecane range and chlorine. Chlorine is fed into a chlorination reactor where it reacts with liquid paraffin to form chloroparaffin. The chlorination step liberates gaseous HC1 by the following reaction: ch3(ch2)qch3 + ci2 H ch3-c-(ch2)7-ch3 + HC1 C1 vvv 0000162^ Dockets Management Branch (HFA-305) Page 3 September 11, 1984 Off gas from the chlorination reactor is sent through a chlorine absorber where normal paraffin is used to react with any chlorine residual in the off gas. Chlorine free HC1 off gas flows from the chlorine absorber to the HC1 purification/absorption section of the process. Alkylation Step The chloroparaffin from the chlorination section of the Vista NALKYLENE process flows to the alkylation section and is reacted with benzene by means of a Friedel-Crafts reaction using anhydrous aluminum chloride catalyst. The alkylation section also liberated HC1 gas by the following reaction: H ch3-c-(ch2)7-ch3 + Cl H ch3-c-(ch2)7-ch3 + HC1 The HC1 gas from the alkylation reaction is separated from the crude alkylation reaction liquid under a slight vacuum in order to remove as much HC1 as possible. The HC1 off-gas is compressed and fed to the HC1 purification/absorption section of the Vista process. vvv 000016298 Dockets Management Branch (HFA-305) Page 4 September 11, 1984 HC1 Purification/Absorption Since the alkylation reaction is carried out in the presence of excess benzene the off-gas from the alkylation section contains benzene as well as HC1. There is also a limited quantity of benzene in the chlorination section off-gas. In the initial step in the HC1 purification/absorption process the benzene concentration in the HC1 off-gas streams is reduced by contacting the combined chlorination/alkylation off-gas streams with chloroparaffin in an absorption tower. The chloroparaffin absorbs benzene. The HC1 gas is then sent to a second absorption process where fresh water is used to absorb the HC1 gas to form muriatic acid. The chloroparaf fin stream is sent to the alkylation reaction section. Fresh water is used in a two stage falling film absorption process to convert the HC1 gas into muriatic acid. Final scrubbers remove any residual HC1 from the inert gases which were present in the off-gas HC1 prior to their venting to the atmosphere. The crude muriatic acid product is sent to the acid purification section. Muriatic Acid Purification The crude muriatic acid from the acid absorption process contains about 1000 ppm of organic contaminants - primarily benzene. VVV 000016299 Dockets Management Branch (HFA-305) Page 5 September 11, 1984 Therefore, additional purification is required to produce a final muriatic acid product. Purification is accomplished in two steps by first contacting the muriatic acid with pure paraffin feedstock in a two stage contact/separation step and then final filtration \ with activated carbon. A pure paraffin stream is contacted with the muriatic acid and then separated from the acid in a coalescing filter/separation vessel. Two vessels are used in a series to get the optimum contact and separation. The pure paraffin stream absorbs benzene and other contaminants from the muriatic acid. It is however, almost completely insoluble in acid itself. Therefore, the total organic content of the muriatic acid is reduced to about 10 ppm after this step. The final carbon filtration step reduces the total organic concentration to less than 0.1 ppm (by hexane extraction analysis) and the benzene concentration to less than 50 ppb (by photo ionization detector chromatograph). To summarize the byproduct acid produced by the process described above will contain less than 0.1 ppm of total extractable organics and less than 0.05 ppm benzene. The agency also requested data on the food catagories to which the acid, and organic contaminants remaining in the food. Much of this information is not available to Vista as a producer. This data would best be obtained from the users of hydrochloric acid. yVV 000016300 Dockets Management Branch (HFA-305) Page 6 September 11, 1984 In addition to the above key items, we believe you should also be aware of the following potential financial impacts. A ban of by-product muriatic acid from food-grade non food-grade acid among the by-product producers. This will likely cause a decrease in the non food-grade acid price and will result in the destruction (neutralization) of much of the excess acid. Muriatic acid neutralization is costly and poses the potential environmental problem of HC1 vapor release. Further more, there will quite likely be regional supply shortages of on-purpose muriatic acid resulting in increased transportation costs to the food-grade consumers. We realize that on paper there will be no more acid being produced and things may appear to balance out. However, in reality muriatic acid inventory capabilities are small and timing is critical. We believe a disruption of this size to the market would take years to stabilize and would result in a price difference between by-product and on-purpose muriatic acid significantly larger than FDA has estimated. VVV 000016301 Thomas G. Grumbles (conoco) To C^V\oC\<. a\ lAette. cxrv a.fi> vVi o <\a,) sVetr fce, VVe_ (2e.\uSior% - V\ec*ie a<D<D 4_b ~VV\.e_ ( VVV 000016302 MATERIAL SAFETY DATA SHEET conoco Conoco Chemicals 5 Greenway Plaza East P.O. Box 2197 Houston, Texas 77001 FIRST AID EYES: Wash with copious amounts of water for 15 minutes. Seek physician's aid. Wash with copious amounts of water for 15 minutes. Seek physician's aid. Remove to fresh air; Eliminate any airway obstruction. Administer INHALATION: artificial respiration or oxygen if breathing has stopped and cardio-pulmonary resuscitation if indicated. Seek physician's aid. INGESTION: r\o^ Ck^l>ca,'lc. NATURE OF HAZARD ,, tYE5. No effects from high concentrations in gaseous form. When compressed to a liquid form, it can cause burns._______________ No effects from high concentrations in gaseous forms. When compressed to liquid form, it can cause burns. INHALATION' Excessive exposure may cause nervous system depression and ' asphyxiation. INGESTION: Propylene is a gas at room temperature and should not be a significant hazard via ingestion. EFFECTS OF OVEREXPOSURE: ACUTE OVEREXPOSURE' Simple asphyxiant; Anesthesia, unconsciousness. CHRONIC OVEREXPOSURE: Unknown. THRESHOLD LIMIT VALUE (TLV) None established. TOXICITY DATA SKIN CONTACT'specific data available. EYE CONTACT: INHALATION: No specific data available. ?(topy|ertQ i^o EGuinea pigs exposed to 55,000 pra*for 1-2 hours showed tremors and nervous system depression ut no fatalities or tissue damage occurred. INGESTION: No specific data available. vvv 00001630^ SPECIAL PRECAUTIONS: VI REACTIVITY DATA CONDITIONS CONTRIBUTING TO INSTABILITY High temperature and pressure. Presence of strong oxidizing materials. INCOMPATIBILITY Strong oxidizers. HAZARDOUS DECOMPOSITION PRODUCTS n e>r\_ CONDITIONS CONTRIBUTING TO HAZARDOUS POLYMERIZATION VII SPILL OR LEAK PROCEDURES STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED Remove all sources of ignition. Dissipate vapor with water spray. NEUTRALIZING CHEMICALS WASTE DISPOSAL METHOD Incineration ^ an p-p up a. o , an< iaToA5 in aecoftO^ce VENTILATION REQUIREMENTS SPECIAL PROTECTION INFORMATION Mechanical ventilation should be used in confined spaces. SPECIFIC PERSONAL PROTECTIVE EQUIPMENT RESPIRATORY (SPECIFY IN DETAIL): Air supplied equipment. EYE: Chemical safety goggles should be worn if there is any possibility of liquid coming in contact with eyes. GLOVES: Rubber gloves should be worn if there is any possibility of liquid coming in contact with the skin. OTHER CLOTHING AND EQUIPMENT: i\4 Vo 'pOAvent vvv 000016305 IX IMCO HAZAHO CLASS AND NUMBER 2.1 UN NUMBER \Ol$ SPECIAL PRECAUTIONS HAZARD CLASSIFICATION INFORMATION US DOT CLASSIFICATION Flammable Gas EEC DANGEROUS SUBSTANCE CLASSIFICATION | -AflR CLASS NDMEETT EEC SPECIAL HISKS AND SAFETY ADVICE CAS NUMBER 115-07-1 USUAL SHIPPING CONTAINERS STORAGE TRANSPORT TEMPERATURE itoT TRANSPORTATION AND STORAGE ELECTROSTATIC ACCUMULATION HAZARD Yes - Ground All Equipment STORAGE/TRANSPORT PRESSURE <> T^ivyDeirc^'f'-dte-. * LOADING UNLOADING TEMPERATUHE T a ft ) . iV\ VISCOSITY AT LOADING/UNLOADING TEMPERATURE HANDLING AND STORAGE MATERIALS AND COATINGS SUITABLE UNSUITABLE Carbon Steel The above data is based on tests and experience which Conoco believes reliable and are supplied for informational purposes only. Conoco disclaims any liability for damage or injury which results from the use of the above data and nothing contained therein shall constitute a guar antee. WARRANTY OF MERCHANTABILITY, or representation (including freedom from patent liability) by Conoco with respect to the data, the product described, or their use for any specific purpose, even if that purpose is known to Conoco. Conoco assumes no responsibility for injury to Buyer or third persons proximately caused by the product if reasonable safety measures are not adhered to as stipulated in the data sheet. 1/20/81 yyy 000016306