Document z0jko9OY5794GoJMJNnN43ZB

File Notes: Grinnell EPA Violation ^ (&!cr92rtk) 08-04-92 Received a call from Mark Romano. Apparently, when EPA Region 7 visited this past June 24th, they noticed a potential violation of EPCRA with respect to our failure to report BF Goodrich resin. They plant did not receive notice of said violation until now. 08-05-92 Called Doug Elders, EPA Region 7 (Kansas City) and discussed this with him. Apparently he was impressed with our usage of ChemMaster, and his one any only concern was the apparent failure of CT in not reporting PVC resin, since Goodrich's MSDS indicated there was a hazard associated with this material. I communicated that we were knowledgeable makers and users of PVC and that we opted to exploit our options under 29 CFR 1910.1200(d) and work on our knowledge of the material. Elders advised that we must take our challenge to OSHA and have them rule regarding the hazards of this material. He provided the name of a contact with Iowa Department of Labor. 08-07-92 Writer sent letter to Shashi Patel with Iowa Labor. We articulated our position well and I expect positive movement, while it may take some time. (1) CTL031799 02-16-93 Received a call from Elders. He is pushing. I took the position that we were obviously OK as last we spoke, it was up to Iowa DOL to respond. Elders advised that they had, and that the substance was ruled as hazardous, and that the plant had been so advised and that they had amended several years worth of SARA reports. S/D Called John Oleson, Mark Romano and Diane Smith at plant. They have not received any type of notification from either EPA or IDOL, not have the amended any SARA reports (in fact, working on 3/1 report and this also will not report PVC resin). S/D Called for Patel...out. Spoke with Don Petty (515) 281-3606, the Title III Coordinator, and he advised that Patel had apparently ruled the material was hazardous because we heat it in our process and according to the MSDS, materials are liberated during thermal decomposition. I explained the facts to Petty who responded that Patel will need to get back to us. Petty also advised that the material might liberate VCM and Patel (515-281-5352) was taking the SARA rules liberally. I v ry pointedly educated Petty with regard to the true hazards with PVC and advised that CT would not let this drop. Petty suggested a conference call with he, I, and Patel. Patel nor Petty ever responded back. (2) CTL031800 S/D Spoke with Sherry. REDACTED 03-09-93 11:45a Attempted to reach Patel...line busy 3:00p Attempted to reach Patel...left office, message left to return call. 03-10-93 08:00a Attempted to reach Patel, not in, message left. 03-11-93 08:09a Attempted to reach Patel, no answer 3:57p Attempted to reach Patel, left for day, message left for him to return call. 03-12-93 8:40a Attempted to reach Patel, line busy. 10:05a Attempted to reach Patel, on other line, to return call in next few minutes. 11:26a Called again, still unavailable. i 800given. 03-17-93 1:50P Attempted to reach Patel, line busy. 2:59p Attempted to reach Patel, out of town rest of this week, message left. 03-17-93 Called Sherry. (3) CTL031801 S/D Certified letter sent. 3-24-93 File prepaired for referral out. REDACTED S/D 2:15p Received call from Patel, but I was on the phone and he apparently wouldn't hold. Left message. 2:20p I called back, another individual answered and said Patel's number was different that left (eg: on message 515-281-5797 but representative advised his number was 515-281-5352). I was told that Patel had gone for the day. 2:37p I called again, this time Petty answered and said patel was on the other line, but that he could not allow me to hold for Patel as this was the only availab-Le line for in-coming calls. Left urgent message. 3:27p I again called, advised that Patel had left for the day. I left another urgent message. CTL031802 (4)