Document rxoB7Zk7NbXbO92gVXapoeRyv

Interoffice Communication TO: FROM: DATE: SUBJ: Distribution TGG: JCL ERT: MJH: AJO: RF XF: T. G. Grumbles April 20, 1990 TSCA INVENTORY CORRECTIONS ALKYLATE STREAMS FOR ALKYLATE AND VISTA SPECIALTY Attached is our final (hopefully) correspondence with EPA regarding the TSCA inventory descriptions for our Baltimore and Lake Charles products. Once I get some indication they have been added to the inventory I'll proceed to review them with the Business Area, R&D and Manufacturing in terms of new product development and product modifications. T. G. Grumbles dlj .131 Distribution: D. L. Mahler, P. Warner-Balt, T. Salah-LCLAB, M. G. Hayes-LCCP W. L. McClain cc: without forms R. Bryan J. Ware-LCLAB, J. Friend-LCCP, R. Bauer-Balt, 0. C. KerfootAustin vvv 0OOO12915 Vista Chemical Company 900 Threodneedle Houston, Texas 77079 (713) 588-3000 P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236 CERTIFIED MAIL RETURN RECEIPT REQUESTED April 19, 1990 OTS Document Control Officer (TS-790) U. S. Environmental Protection AgencyOffice of Toxic Substances 401 M Street, S. W. Washington, D. C. 20460 VISTA Attention: Chemical Inventory Section Re: INVENTORY CORRESPONDENCE NUMBER IC-2557 Dear Sirs: As instructed in the attached letter from Henry P. Lau, Vista Chemical Company is submitting the attached inventory corrections for our process feedstocks, distillates, alkylates and specialty alkylate products. Please contact the undersigned at 713-588-3445 if you have questions on the attached Form C's. It is our understanding, based on the attached letter, that these descriptions will be added to the unpublished, non-confidential TSCA Inventory. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager dlf wv 000012916 tlOUMv UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, O.C. 20460 office of PESTICIDES AND TOXIC SUBSTANCES Thomas G. Grumbles, C.I.H. Environmental Quality Manager Vista Chemical Company 15990 North Barker*s Landing Road Post Office Box 19029 Houston, Texas 77224 Dear Mr. Grumbles: RE: IC-2557 This is in response to your letters of June 8, 1988, January 23, 1989, May 2, 1989 and EPA*s meeting with you arid Mr. Warner of Vista Chemical Company on April 11, 1989, proposing amendments to the identities of your alkylate and specialty alkylate products originally reported by CONOCO Inc. for inclusion in the Toxic Substances Control Act (TSCA) Initial Inventory. The Agency has reviewed the information you have provided in your letters. In your letters, you stated that CONOCO identifies the process feedstock 'paraffin feed* as a blended mixture of individual homolog paraffins, each identified by its own CAS Registry Number. The Agency does not believe that it is appropriate for the manufacturer to characterize the paraffin feed as individual Class l substances. The feedstocks, distillates, alkylate products and specialty alkylate products will require the following descriptions for inclusion in the TSCA Inventory: (I) 'Sorption Extracted Normal Paraffins C10-C16 -(2) Alkanes, CIO-13 (3) Alkanes, CIO-14 (4) Alkanes, C12-14 (5) Alkanes, C14-16 (6) Benzene, mono C10-13 alkyl (7) Benzene, mono CIO-14 alkyl (8) Benzene, mono C12-14 alkyl (9) Benzene, mono C14-16 alkyl (10) Benzene, mono CIO-13 aklyl, fractionation bottoms (II) Benzene, mono CIO-14 alkyl, fractionation bottoms (12) Benzene, mono C12-14 alkyl, fractionation bottoms (13) Benzene, mono C14-16 alkyl, fractionation bottoms vvv 0000129H (14) (15) (16) > (17) (18) (19) (20) (21) Benzene, ends Benzene, ends Benzene, ends Benzene, ends Benzene, ends Benzene, ends Benzene, ends Benzene, ends mono CIO-13 alkyl, mono CIO-14 alkyl, mono C12-14 alkyl, mono C14-16 alkyl, mono C10-13 alkyl, mono CIO-14 alkyl, mono C12-14 alkyl, mono C14-16 alkyl, fractionation bottoms, light fractionation bottoms, light fractionation bottoms, light fractionation bottoms, light f ractionation bottoms, heavy fractionation bottoms, heavy fractionation bottoms, heavy fractionation bottoms, heavy The Agency believes that the above descriptions are consistent with Inventory listing policy for describing complex mixtures or '`process streams'* of alkylate products. If you still wish to submit corrections on these substances, please describe your substances on the enclosed, blank TSCA Inventory Report Forms C using these twenty one process stream/alkyl range descriptions, and submit them to the Agency. Once we .receive the completed forms we will include the identities of your substance in the unpublished, non-confidential TSCA Inventory. In completing the forms, please note that you are not permitted to assert claims of confidentiality for information that was not claimed as such on your original forms. For future correspondence regarding this matte, please reference Inventory Correspondence Number IC-Z557 and address your letter to: OTS Document Control Officer- (TS-790) U.S. Environmental Protection Agency Office of Toxic Substances 401 M street, S.W. Washington, D.C. 20460 ATTN: Chemical Inventory Section r-r. ^Ti0^Al <&a les' Chemical Inventory section vvv 000012918