Document 2JEKKgbY0EVYZR7e2RqVdrxdN

"m. crftand Chminai` Zm_____ 5i . PUT IT IN WRITING Date 26 August 1974 To Mr. A. K. McMillan/Valley Forge Subject nsiTA tm.^pphtton - rat.vt-kt TTTY Frnm J. D. Kramer/Calvert City __________________ -^ ) Take Action ) For Your Comments ) For Your Approval ) As Requested > For Your info } File { > Discuss With Me Note & RHurn jfcpt 1 ' # The plant was visited on 20 August 1974 by Mr, Gene Woods, Com^iance Officer out of the Louisville office of OSHA, Mr. Woods is a chemical engineer and seemed knowledgeable on PVC production. He had b^en-at the B. F. Goodrich plant at Louisville. He was accompanied Cnotvat - our plant) by a maritime compliance officer who visited other -jyicfc facilities in the area, but not ours. He told us at the outset&that his only interest at the present time was compliance with the temporary standard. in vinyl chloride ani&oar .'ter- -aft*' net- Mr. Herbig first reviewed the necessary statistics, address, medical records, etc. We then had a session with Mr. Stermon and mysej^fcon. monitoring methods, record keeping, etc. Then Mr. Speed join and we reviewed the many and costly measures taken in the pla reduce exposure to VCM. He then expressed a desire to meet w Mr. Sanford Beck, Union President, whom we could not locate a time, Mr. Herbig took Mr. Woods to lunch and Mr, Beck was ava upon their return. After spending about an hour in private with Mr. Beck, Mr, woo taken into the plant. He first went to the Emulsion plant air accompanied in a brief tour by* Mr. Beck and Mr. Zorman. Acco^ to Mr. Zorman, the tour was brief and he was interested in yheJ the reactor was entered for cleaning after vinyl chloride bate Mr. Zorman1s answer was ho, that we employed chemical cleanin Since the plant was finishing an A-728 run, he took no sample proceeded to the PVC plant, t ' .Mr. Speedfs report on his visit to the PVC plant is appended-' Exhibit I. He took about 20 minute samples on.six (6) operat two beingsduplicates. Mr; Speed's report also indicates that' Bendix readings were quite low with the exception of`point NO; in the exhaust fan by the reciprocating recovery compressors I discussed with you by telephone, we should have by the time* report is*typed a total of 20 relocated points on two chromato in the polymerization building. We had a "wrap up" session with Mr. Woods with Mr. Beck also in,v attendance after I returned from taking you, Mr. Carey, and yqjfilr;.. party to the airport. As a minor point, Mr. Woods pointed out"?;/, that Mr. O'Daniel, our maintenance leak patrolman, did not have*, a fresh air mask with him at the time. His main concern was^wiih X AP00040526 t i Mr. A. K. McMillan 26 August 1974 Page 2 Subiect: OSHA INSPECTION CALVGRT CITY our personnel monitoring system, and we will probably be cited on three counts in the temporary standard - 1910.93q (c) (1) , (2), (3). A copy of the page from FR 39 No. 67, April 5, 1974, is attached for easy reference as Exhibit II. As to the date of April 5, 1974, we informed Mr. Woods that we had only received the Sipin pumps we felt were required the previous week. Mr. Woods gave us his interpreta tion of the standard with r.espect to frequency and method. He requested that 75* of the people on each shift be tested once per week with at least two (2) samples per person. Sample times are to bo 20-30 minutes. We described a program whereby 75* (9 peopLe) on the day shift would be sampled twice or three times for 20-30.* minutes on Monday, 26 August. The same samples would be repeated on Tuesday for the afternoon shift and on Wednesday for the midnight shift. The rest of the week would be spent analyzing the 54 toJ81 samples taken. This is to be repeated each week for three weeks^and if all samples are below 50 ppm, the frequency can be reduced t^once per month, rather than weekly. He indicated that this would coiiqxly with the temporary standard and requested that we submit a:pro.sj|-ss ^ ' report about 1 September. We agreed to do this. He, of coursey^' pointed out that we would have 15 working days or 3 weeks to-cutest v the probable citation. He told us that unless the results of~;thir samples are above 50 ppm, we will not get the results unless request them. I will request them. JDK*, si cc; A; Rf- Adams/Valley Forge J. I* Barr/Valley Forge Tr Carey/Valley Forge TV* Herbig R. Ef. Jones/Pensacola R. wr McGinnis r:E. Af Primeau/Pensacola J. Sebastianelli/Vallcy Forge G. B; II. Speed E. j. Steck M. H. Stermon Ii. L. Watson/Valley Forge' R. R; Spiegclhalter/Pcnsacola J. D. KRAMER -.a* ,-y>f ->.? -r- rJr. i'Jt-r- aft- : AP00040527