Document 7O27ZbM72ke6V8rdpnr1aG898

ch-2 wrv. 7- cnuusanvoi E. I. du Pont de Nemours & Company Wilmington, Delaware 19898 CHEMICALS AND PIGMENTS DEPARTMENT cc: R. J. Blair E. P. Blanchard L. H. Papineau R&D and Research Mgrs, Manufacturing Mgrs. Production Mgrs. SH&E Coordinators L. C. Skaggs, PA December 1, 1981 C&P DIVISION HEADS C&P SITE HEADS SAFETY, HEALTH AND ENVIRONMENTAL REPORT THIRD QUARTER, 1981 Enclosed is the regular report of the C4P Department's performance as well as items of interest in the areas of safety, occupational health, environmental protection and regulation of product hazards. An executive summary of the report is attached to this letter. Comments and questions will be welcomed by any member of the Environmental and Regulatory Affairs Staff. __ FEF/bam Att. F. E. FRENCH DUP 1013619 DU 053722 ,iam-iMiM, i^a^aMi..^MB.aiMamiL SAFETY, HEALTH AND ENVIRONMENTAL REPORT FOR THE THIRD QUARTER, 1981 SUMMARY - SAFETY, HEALTH AND PRODUCT HAZARDS SAFETY MANAGEMENT The C&P plant injury record deteriorated seriously in the third quarter with one fatality, four LWC 's and four RWC's. The injury frequency now slightly exceeds the corporate goal. Off-the-job frequency continued the early year improvement trend; year-to-date is three-fourths of 1980 and slightly below Company goal. S&FP surveys continued to average only "good" and pointed out key deficiencies in completeness of operating instructions and various aspects of safety practices. Medical audits also continue to show the need for improvement with only one "excellent" to date. Auditing of site process hazards management programs has continued. All-day Wilmington management visits have been made to three fourths of the department's sites. Good progress is being maoe, but more work is needed to implement the program fully at all sites. REGULATORY ACTIVITIES A revised Hearing Conservation Amendment went into effect in August; it is more acceptaDle to Du Pont. Other health standards (chromium , formaldehy de , etc.) are being delayed pending redefinition of OSHA's carcinogen policy. State and Local Worker Riqht-to-Know legislation is proliferating and becoming more burdensome. C&P has been participating in testimony in New York. HEALTH AND SAFETY PROGRAMS In connection with the corporate program for identification of asbestos-related medical conditions, abnormalities have been found in about 3* of C&P's employees and 7% of pensioners, but fewer than 20% of these have been found to be symptomatic. A film ''Caring About: Asbestos" has been prepared by C&P to address medical issues ana credibility. Initial employee screening is scheduled for late December. SITE ACTIVITIES Newport health studies have found no evidence of abnormal health problems and no evidence of work-relatedness for cancer rates higher tnan Company average. Communication to employees is planned. DU 053723 DUP 1013620 / v 2 SUMMARY - ENVIRONMENTAL PROTECTION INCIDENTS One major environmental incident occurred, the firs<- in tn? last four quarters: NEWPORT had a release of sulfur chloride fumes wnen a tank overflowed. There were three community complaints. The State was advised and has filed a formal complaint. The plant paid a $1,000 fine. Tne AO serious potential incidents were below last quarter's total of 48"; the reduction appears to be a return to the former downwarc trendline. REGULATIONS There has been little new activity under the Clean Water anc Clean Air Acts. However, in Du Pont, et al. vs. EPA, Du Pont lost its challenge, of the 0.12 ppm ozone amoient air quality standard. The decision is being appealed to tne Supreme Court. Because of the financial cost to industry, which EPA estimates at $4 Billion/vear, it is likely that tne standard will be relaxed either through Clean Air Act amendments or by tne Reagan Administration. Under RCRA, a ban on disposal of containerized hazardous liquids will become effective on Novemoer 19. C4P disposal costs are expectea to increase by aDout $400M/year. Tennessee is reconsidering acceptance of the EPA deepweli permit program. We favor State acceptance because we believe State autnorities are more sympathetic to plant programs. Tne settlement agreement in API, et al. vs. EPA relaxes tne definition of drinking water and eases the criteria of wnat constitutes a source of drinking water. Both are expected to ease the permitting process for future NEW JOHNSONVILLE Wells. PLANT ACTIVITIES In Save-The-Bay (STB) vs. Corps of Engineers, et al., we hav>= responded to STB's questions concerning land use between 1-10 anG tne railroad, but we have not responded to inquiry on plant environmental incidents. We expect this issue and others to be favorably resolved in a hearing as yet to be scheduled. The Regional Water Quality Control Board is suspicious that qrounowater under the ANTIOCH plant has been contaminated by plant operations. They have requested a comprehensive sampling program. A response to this request is under consideration. DU 053724 DUP 1013621 3 REPAUNO experienced a fish kill in the sand ditch as a result of a tank clean out in the "sodium nitrite area. Tne incident d;d not exteno off-plant, but it was observed by N. J. personnel who were on-plant. We oelieve this situation is not subject to State or Federal regulations, and Legal concurs. The plant is formulating corrective; action. The CHAMBERS WORKS "bubble plan11 finally has been approved. It will save the plant approximately $10MM in new investment for control of volatile organics. Recently, the State has proposed to exempt chlorofluorocarbons from air regulations. This change offers further investment savings of J3.5MM. EAST CHICAGO has petitioned for higher SO? limits for its sulfuric acid operations. Degradation of air quality would be preventeo by increasing the stack height. Savings of approximately $250M/yr. are expected. EDGE MOOR has received a new SO? permit emissions limit, per our request. Caustic scrubber ingredient savings should total $300M/yr. NEW JOHNSONVILLE received two Notices of Violation for excess powerhouse stack emissions opacity. Particulates testing has been completed for the stacks, and it is hoped that the low emissions levels will lead to a relaxed opacity limits. BEAUMONT and REPAUNO have been informed that their respective aniline/nitrobenzene wastewaters will be delisted from RCRA control. Thus, total investment savings of $20MM for the worst case scenario have been avoided. At NIAGARA FALLS, the Gill Creek work was completed on November 1 and water flow returned to the Creek bed. DU 053725 DUP 1013622 -jBiai-y,iiiiyiiiiaMt,. SAFETY, HEALTH AND ENVIRONMENTAL REPORT THIRD QUARTER, 1981 SAFETY AND HEALTH* SAFETY PERFORMANCE SAFETY PERFORMANCE FREQUENCY RATES, 1981 (through Sept.) LWC LWC + RWC OFF- THE-JOB Planits Goal Actual .02 .077 .08 .14 .63 .53 Department Actual .079 .14 .54 Du Pont U.S. Goal Actual .03 . 135 .70 .035 .12 .60 Injury performance deteriorated seriousl y in th e second quarter wi th the occurrencei of one fata lity, four LWC ' s and four RWC 1's. The year -to-datei departmental injur y r ate (LWC + RWC) is now higher than the Du Pont U.S. ra te (.14 vs . 12) . Current statistics ana long -term trend dat a both point to the need for stro nger emphasis on injury preve ntion. C&P is cons ult ing with a major c orpo rate task fore e which is studying wa ys to im prove perfo rmance. De partmental off- the-joD injury performance was marginally petter tha n Du Pont u.s. goal (. 54 vs . 70). CHEMICALS AND PIGMENTS DEPT. INJURY EXPERIENCE DUP 1013623 The section on TOXICITY AND PRODUCT HAZARD ACTIVITIES begins on page 14 and the ENVIRONMENTAL PROTECTION section begins on page 16. DU 053726 C&P INJURY STATISTICS, 1980 AND 1981-YTD Site Chambers Works Cleveland Deer Rsrk De Lisle East Chicaao Edge Moor Florida Grasselli Johnsonville Memphis Newark Newport Niagara Falls Repauno Wurtland Unit Plants Plant Total Injuries (LW!C-RWC)/Rate 1900 1981-VTD 4^0 .11 O-l .34 0-1 .58 0-1 .18 0-2 .59 0-0 0 0-1 .34 0-0 0 0-2 .24 1-0 .10 0-0 0 0-0 0 0-0 0 0-1 .20 0-0 0 cyo 0 $7 TIT 0-1 .04 0-0 0 0-0 0 1-2 .24 0-0 0 0-0 0 0-0 0 0-0 0 0-0 0 liO .13 0-0 0 0-0 0 k1 .30 2-1 .84 0-0 0 1-0 1.25 in Off Job Injuries/Rate 1980 1981-YTD 421 .61 4 .71 3 1.06 7 .69 6 .94 9 .65 2 .35 2 .33 11 .67 15 .79 2 .23 5 .43 11 .63 5 .53 1 .44 6 , 2.92 T3f-jS3 28 .58 4 .98 1 .45 5 .63 3 .70 5 .60 2 .52 3 .67 6 .48 2 .14 3 .50 3 .35 8 .61 2 .29 00 1.92 78 .53 Medical Trcm-me-.*- 1950 1961-ytd 134 65 54 86 21 8 55 17 5 72 2% 34 25 15 7 52 75 11 14 66 31 82 288 160 " Jackson Lab 0-0 0 Exp. Stn. Lab 0-0 0 Chestnut Run Lab 0-0 Adm. & Mktng. run 0 0 C&P Total .11 0-0 0 0-0 0 1-0 1.13 0-0 0 7?5 .14 Antioch Beaumont Colorquim PPQ 0-2 .47 0-1 .07 2-0 .49 0-0 0 0-2 .65 2-0 .18 0-0 0 0-0 0 Includes 6 MTCs frcm C&P operations. Includes 1 MTC from C&P operations. Includes 1 OTJ from C&P operations 5 .48 4 1.38 00 22 , 1.36 1621 .68 4 .55 2 .98 00 8 .69 92 .54 6 .72 5*** .20 6 .89 4 .41 . 6 5 3 10 1.00 .26 .57 1.31 9 .4 1 1 303 26* 14 12 3 2 3 0 0 165 20** 12 5 1 LWC AND RWC DESCRIPTIONS Chambers Repauno Repauno Niagara Repauno Niagara DeLisle James River DeLisle July 15, 1981 July 22, 1981 July 22, 1981 Aug 4, 1981 Aug 17, 1981 Sept. 19 , 1981 Sept. 23 , 1981 Sept. 25 , 1981 Sept. 28 , 1981 RWC Fatality LWC LWC RWC RWC RWC LWC LWC Finger laceration Thermal Burns Thermal Burns Thermal Burns Finger laceration Thermal Burns Broken ankle Thermal burns Eye abrasion w c TJ Oi 2 DU 053727 SAFETY SURVEYS Complete surveys were made at Fort Hill (Fair), Fortville (Good) and Pineville (Good) and at Antioch (Excellent) and Colorquim (Gooa). A special emphasis survey of employee work practices (Gooo) and emergency preparedness (Excellent) was conducted at DeLisle. Principle survey findings are summarized below arranged by categories common to the S&FPD survey system. The most recent survey ratings for ail plants are summarized on a separate chart. Safety Administration criticisms centered on the need for improved safety communications to contractors. Process Hazards Management programs were found to need more thorough documentation of training and equipment inspections, especially relief valves and safety interlock testing. Process hazards reviews should be more comprehensive with more complete documentation of evaluations. For Training and Job' Cvcle Checks, there is a need to document "as found." Off shift audits were recommended as well as more emphasis on auditing high risk jobs. Safety in the Work Environment and Employee Work Practices were rated gooo as regards use of protective equipment but in some instances sites were delinquent in observation of safety rules. Improved observation by supervision was recommended. Maintenance work needs more careful safety planning. Emergency Control was judged ineffective with regards to contractor communications. This is needed especially to insure tnat maintenance employees are aware of appropriate actions for the area in which tney are working. Also, emergency action plans need to be reviewed more effectively with employees. Aiso cited was the need for better documentation of the testing of emergency equipment that is checked less frequently than daily or weekly. PROCESS HAZARDS MANAGEMENT (PHM) The PHM audit program included one-day visits by a Production Manager and a member of E&RA Staff to Cleveland, Niagara, Newark, Houston, East Chicago and Toledo. Fourth quarter audits are scheduled at Repauno, Chambers, Healing Springs, Grasselli, Newport, Deer Park and Memphis. Schedule and accomplishment data are shown on two following paqes for both forecasted and unforecasted Process Hazards Reviews at major plants. O 3 DU 053728 ,UP 1013625 c > o> e> co> ec> > ro_c--aoeu>cao>c>oSoeuc>a>cS>c>cigc>gG>gccuc>* CcScScSoSScOCffiC SSSS\S\S\SN'>.iNi` -^c\iACM0\'C-<r\r\'Cfs;Or> _J E ow> u> 8^ .5 -D c `-CM3 uoeB&u8u8uxjuxuxj8u oi':'O*. U" ^S8&r*88S. Xx 'S_v_ sSo. SQS3.Sfvx'vSScs>SCSDS(SLN. KV.SsrvNUSJvbV..' SWv S8 ?n n n.< r- w ^ - r*. S > 'l > ^ M| I 6_ u8 >s 73 o. u cT? 7o3 o.'Oo'C'Ooo-7gu-~`-*c0*o0 CWx WXOUOUxUOUCUCUXUC.UXwWliC.eOe o oD'oC U TO3 7O3 (J 7o3 X 0 O XOOXO U*UO W C U O uax o7oo u*ooCuT533 * *< fa 6 u! 3lesssssssss:a| 88?8S83 i x> B o SNS\ > O tf\ K7 S DtJuTDrtr " 11 "i g 1 ".1 "-"i g "i 8 u- Po go --<c 0o o3 0o 0 0* UUOUUOUlUkUUOUUU o O U. OOUOuJ NN -T-* oT cs --i c*-xs-(N cm Wj Wvi in u i tiMn & * v$iuuuuw$' SsSiS5s-oiAo\sSoSs5-C.i\-eiSca-D--Ci _ \0 CD K\x *n N 'C-*CNW\T\ CSC ' uou_oW Iv , " I iQ I 8\8 CN r- -O' 8> si* (H -- > -SifiiSSStS* sf?;..:2-"ScS&cu ulGsS2S=s*iSii -H 4J ^ > D Si=?5=o ^ vi > * trt > a t sts-sis-s 73 73 T? u8 ux uW-o8o KwW gst Jn, I Ju, U1 v. x. NS-SS f.. oc- wv wWcr f5 c_o ooc -- NU OW S*j u <c O >-- to y > -w y> M C C 4rt ert Q. O UJ --* O O' C wj:- C2 xSuIiS5< CN K\ ir CO V> II t> ^ ^ l> a o t_ &o uI VWS -4- DU 053729 DUP 1013626 PROCESS HAZAROS REVIEWS MAJOR PLANTS; EXCL, CHAMBERS WORKS LZ9CV0V XV) o Q *-- <OHOOHONO^H H NHOOl VO E >- I CN O CJ tr> P uu cc a* 3 4J P'iO^HOOOOCs' OO-HOrHOOOl X X CJ <x Q_ E 3 -o X G 4-> V) CO *D <J a. g 4--> 1-4 O CO 4- 4-' c CO o -- > CHhONOONh^1h-1 NWHOOII K<-\t X t~. t-i t- 3 -*-) oo^oooocvi-hO'H'-h^hoooI r* G CJ O' X E 3 X o *-- PVOlAHNOCMN^-ftO-9NH^| r- *o a; TO >- 4--> 3 c (-1 (-< arH 3 J-> OOlftHNQNO<IOOONHHH 0\ a O (3 E (/) G CJ t a: X (-4 H K\l<Vlf\HOOOOrtCO(MN'ON^ri| o 5-1 r-i I <0 a_ <u *o X) <D T) E X f-i u <D 3 CJ 3 4-' or.Hoooo'04HonHOH| r\ 4-> X to CJ o CM (fl CD a o| a: 1--1 I--(Cvir-'CNK\r^--(iry<j| H >1 o u. D CD 0> 3 rH H I 4-J 4-J u u fTr-O4 4-> a v* 3 cj 4-> ar to H w IAHO H O CM CM *--< <--< -M O O -H CMI O 04 U <D X E * "O 3 <u o| i--| >1 Xx uu tao 3 O O C'4P'lT\^H<3-^-l-HINO'aOCM-3-K\CSa3<I| <-t CM I HlAI<VHOHa(MM-7SOOH<N| Ov rKNV o 0) o *D JC CD O Pi H H H in c P H O ^ > O 4- TO TO (L X O CD C (/> 4-> CD oc.ce rH X <-H UZD fli 0`H Jtf U P C (0 CJ o _i x *- a; v) v) wr m G CD 3 -h o e o c > In *-< 4J G Pt tn c CL TO a. o C0 *j --t 3 - 03 GJ 0) _1 </> o. O (0 X E S CD Q. U aJ CO *-H .--GO) TO TJ *-H t4 o a> cj C> *H IOC# Q. O O o UJ UJ U. a o z 2 X X o: 3s r cq 5 DU 053730 vo o o CO CO CM / o OO OO OO CoO --001 lA IA NA CO O o o oo 00 NO CO CO*-* On till VcOo vcoocvoD NO5 NO VO ^ Q " - 1-1 CO ^ 55 CO O' CHAMBERS WORKS 1981 FROCESS HAZARDS REYIFHS DU 053731 > 2 t l * is El i8o I2 Q .s *tun3 iooj 5JJ 1" .an G. C3O ? g 8 U3 (S 5J Jo-f aXOJ 5i XVoI 3 g 6 eo 5 e2 i s cs 35 o 3 ts fi 3- DUP 1013628 EeoP au rt MlMtoi aMmaum mats: lriH'lu:BfiiW8,^-T,aE-g5aW^!:^|||j|ga| / TERP INCIDENTS The 19 TERP incidents in the third quarter were higher than the 14 in the second but the trend of both total and non -accident related incidents continued at less than 50* of the 1980 rate. Accident (and other carrier caused incidents) Non-Accident Related Incidents Other 3rd Qtr. 1981 11 8 0 Previous Qtr. 5 6 3 Same Qtr. Last Year 17 12 9 YTD 1981 Annualized Total 1980 40 80 25 60 5 28 TOTAL 19 14 38 70 168 RHYTHM INSPECTIONS During the 3rd Quarter seven plant sites were inspected: Grasselli anc Wurtland were rated "Excellent;" Newark, James River, New Johnsonviile ana Toledo, "Good;" and Fort Hill, "Fair."- The Export-Sales Order Center activity was also inspected and received a "Good" rating. CORPORATE AND DEPARTMENTAL PROGRAMS AND STUDIES Chlorine Handling - All of the sixteen C&P sites handling chlorine have analyzed the Survey Report, designated coordinators with responsibility for liaison with a Wilmington Ad Hoc Committee member and commenced implementation programs. Those sites handling chlorine in bulk quantities (vessels larger than ton containers) generally have organized their program efforts under the direction of a plant committee headed by a member of production management. The Survey Report has been well received and we strongly commend the responsive and dedicated programs being carried out by plant personnel'. The attached chart documents by program element for each plant, except Altamira, the status of accomplishment to date and the committed schedule for completion of all programs. - 7- o c a CO 05 r<o0 DU 053732 ttaammuii Jzmim ixiiMml^ml ^iifi^Siii^jjKll HI II r> w k* *SSt ft! * ~---- 3 O O 4> -- a-*Is -4c*1 W u a1. Q. * < S U-- U o 2S2 S3 easst ^N*rt4irt i*^ ip ji cd a!i a'rt 6ao 3cC 83" u . i 6--' cc rt a C uu - O J Iu. w (j * ; - u> > *o- c4j o: --e ^4) Vc -* 4> *-j 5c *V u u **)iP/) i 3ii Sit 1U.UJUOO ~u+i <uSi *u*t ui uAi uT6 o I o <rt Ca u41 p* S'?1 uIU uUJ -- c ai a v) DO ss S 515 aU. QaM..o--0:) C CC 553 I IX -*I I ICM*\ UJ u w IS II 3 ^ o. f" t*m' O3 ?3 c StiS if ft cccc :: s s m * ---- 8 DU 053733 DUP 1013630 PERS - Personal Environment Record System - All 13 major plants are reporting data to the Corporate system on a routine basis. Twelve report on 100* of wage roll. A procedure for unit plants has been set up and tested which should be fully operable by year end. Data collection for this system is practically routine. Newport Health and Mortality Studies - A program is being set up to communicate the results of the studies to employees in late November or early December. (No evidence of work-relatedness has been found for any health problems.) Timing depends on receipt of final reports from Medical. Newark - Chromate Pigment Epidemiology Study - No questions have resulted from the employee communication of the results of the study, nor has it been raised as a union issue. Dr. Louria's paper describing the study will appear in the Archives of Environmental Health in six months to a year. Repauno - Benzene Epidemiology Study- Tabershaw, the original contractor for this study, was terminated by the CMA management committee because of his staffing problems. Arrangements are being made for a successor. Formaldehyde Epidemiology Studies - Two studies are involved. The Du Pont-only study is in the data collection stage. The National Cancer Institute - WESTAT industry wide study, in which Du Pont is participating, includes Toledo-C&P and Parlin and Rochester-Photo Products. Representatives of NCI/WESTAT/Du Pont met in October to cover available Du Pont records. Asbestos Program - Data submitted by the plants in answer to the Corporate Medical Division request have been forwarded for Medical's review. Asbestos-related abnormalities have been found in about 3* of C4P employees and 7* of the pensioners examined but fewer than 20* of these cases have been symptomatic. One malignancy was found in an employee and six in pensioners. The C&P film, "Caring About: Asbestos" has been viewed and Wilmington area plant observers feel it is exceptionally well done. It will be available for distribution to the sites in January when accompanying training materials are printed. Forklift Truck Training Film - The videotape training film has been completed and was presented at the C&P Safety Supervisors' Meeting in DeLisle on November 18. Protective Clothing - A survey of available acid and alkali resistant clothing is being carried out and additional testing is being undertaken by C&P. Results should be available by year end. DUP 1013631 -9- DU 053734 ,i(, .'aagi-.-itbi...m.ij. li'-^'^iiiSiiiii iiiiiiillBiiiiiii mmi IBHiniiiniitiiriil LITIGATION During the third quarter, ten actions involving claims for injuries or damages arising from manufacturing or transportation incidents were added and eight were settled at a cost of $68,988. There were 98 actions outstanding at the end of the quarter, up from 81 at the beginning of 1981. Some of the more significant of these are tabulated on the next pages; claims for asbestos-related disease figure prominently. In the Hartman action, nine married couples alleged that Du Pont manufactured "Alpha-naphthylamine and Beta-naphthylamine, and other cancer producing chemicals" and sold such products to American Cyanamid, the employer of the nine plaintiff-husbands. The case was closed when Du Pont agreed to pay each of the nine claimants $6222 (total of $55,998). In Lenher, plaintiffs alleged that the husband's colon cancer developed from or was aggrevated by exposure to unspecified chemicals produced by four named defendants and others. The exposure occurred between November 1959 and June 1967 while he was employed by West Jersey Paper Manufacturing Co. at Camden. Lenher was closed when Du Pont contributed $2,500 toward a $45,000 settlement. The case of Howard Jones, a truck driver for Matlack Corporation, who allegeo that he suffered thermal burns of the left arm and left side of his body when he was splashed with phthalic anhydride during unloading operations at the Newport plant was closed when Du Pont agreed to pay $4,000. Johnson, one of ten Beaumont leukemia actions, was dismissed as to Du Pont. REGULATORY ACTIVITIES OSHA Inspections Tennessee OSHA completed its investigation into the Memphis cyanide related fatality and found no cause for issuance of a citation. Niagara Falls was visited in August by OSHA in August in response to an employee complaint alleging failure to install "feasible" engineering controls to reduce sodium shop chlorine levels to below the OSHA 1 ppm ceiling limit. OSHA returned in the fourth quarter to do sampling and although the chlorine levels exceed the ceiling, no citation will be issued because employees are protected by personal protective equipment. Newport had an OSHA general site health inspection in October prompted by an employee complaint regarding lunchrooms. The inspection is continuing, with no significant findings to date. 10 DU 053735 DUP 1013632 lit:gat:on Litigants CLAIMS FOR INJURIES OR DAMAGES ARISI*C FROM MANUFACTURING OR TRANSPORTATION INCIDENTS Damages Sougnt Description Status Personal Injury - Ou Pont Emoloyee Rafferty vs. Du Pont et al (4 Defendants) S4MW Death resulting from still explosion at cnamoers works Ou Pont has Oeen dismisses oased on workers1 Como. One defendant nas crass claim against Ou Pant, out has delayed Bringing to trial. Millison et *1 vs Ou Pont et al. 6 plaintiffs, 18 defendants Nutt et al vs Du Pont et al. 3 Plaintiffs, 13 Defendants $2*W each Injuries resulting from exposure to asoestos at Repauno and Champers works S2.25MM Injuries resulting from exposure to asoestos at Newport Oeoositions of onysiaians underway. Summary judge ment is sougnt oy Ou Pont. No decision from aooeal to Dei. Supreme Court oarrinc suit. Plaintiff seeding to add 3 plaintiffs; suspenoed as to Ou Pont. Sneathen 4 Sneatnen vs Pacor et al. 13 Defendants S10M Rickards vs A.C. 4 S. Co. unsoec- et al. ified Injuries resulting from exposure to asoestos at Repauno and Clampers worxs Exposure to assesses at Esgemoor Ou Pont asserts defense oases on workers' Comp. oar. Awaiting aooeal in Nutt et al. Plainti'f seeding ts aoc anptrvsr employee and :'e. Oiscovery uncaray. Taylor et al. vs Ou Pont, unspec- 41 Plaintiffs ified Exposure to asoestos at Repauno and Clampers works Dismissal sougnt oases on worxers' come. oar. Awaiting decision in Millison, et al. wolfson vs Ou Pont, 20 defendants >$10M Exposure to asoestos at Repauno Oismissal sougnt oased on worxers' comp. oar. Personal Injury - Carrier's Employee Brunson vs Ou Pont S600M Dillon vs Ou Pont 4 teaman Tank Lines S3W _ Sanitate vs Ou Pont unspec ified Cnronic exoosure to formaloenyoe, metnanol, MjOg and DMS snipped from Grasselli. Interrogations answered. Medical reports increase condition due to enemies! exposure. Exposure to tma wnile unloading at Mempnis Deposition Dy uenpr.is ooerators state plaintiff failed to ooen valve. Trial m 11/81. Sorayed witn "Hylene* wnile Oiscovery proceeoing. loading trucx DUP 1013633 11 DU 053736 Litigants Oanaqes S3 JCnt Desc Status Personal - C7`,'tr"rto 7 ' S 2 / ? Crielly vs Du Pont S250M Alleges injuries at Niagara Plant during dismantlement. Plaintiff as<ed for SoM. Settlement underway. Dyer vs Du Pont S500M injured when oeam fell Depositions underway. during DeLisle construction, Hosxlns 4 towery vs Du Pont, 2 actions Jenkins vs Du Pont Jones 4 Jones vs Du Pont 4 Henkels 4 McCoy, 4 actions Lockwood 4 Lockwood vs Ou Pont S5<X eacn S100M Slot S200M Injured wnen acid fell while working at Mempnis Exoosure to CI2 at Oecisle Deatn and injuries from exoosure to energired power line at Newport Injured wnile cleaning Ti02 slurry car at Edge Moor. Settlement discussions underlay. Defense strategy oeing developed. Taking depositions. Discovery continues. It is alleged tnat use of goggles rarely enforced. Sylvester vs Du Pont SlNW Williams, et al vs Du Pont >$5.75mm Injured in fail at DeLisle Discovery underway. Oeatn oy suffocation in Harron and Jones cases to oe vessel at Deer Park (Syngas) consoiicated in Texas State Court, seeking Oismissai of National Distillers, Inc. anc omitting S4P from litigation. Perstnti 0:**r fldkinson, e: al vs BFI, et al S20W Como. Class action alleging SIQfW Pun. negligence in spreaoing CN~ wastes on roaas. BFI has agreed to accept Ou Pont's defense. Seek to move case to Harris County (Houston). OuSose, et al vs 8TI, et al Fleming vs International Container Services et al, 6 Defencants S20fW Como. Class action alleging $10+1 Pun. negliqence in spreaoing CN- wastes on roacs. S750M Exposure to ye fumes as encioyee of snipping company Brl nas agreed to accsot Ou Pont's defense. Seek to move case to arris County (Houston). Du Pont answereo inter rogatory. Ou Pont's taking of depositions cuasnad; plaintiff in jaii. LaPoint vs Hooker, Du Pont, et al, 9 Defendants KLiliiner 4 Mulliner vs Browning nrris et al Slsm S875M Exoosure to toxic cnemlcais from Love Canal Exoosure to s8 fumes Curing fire training in Beaumont Amended complaint filed. Du Pont denied resdcnsioility. BFI is defending fcr Du Pont. Plaintif retained additional counsel. no trial soon. Beaumont Leukemia Cases 9 Plaintiffs 4 9 actions ijltiole defendants ^rooerty 03nags S75>+* Exposure to oenzene and otner agents caused leukemia Discovery is underway. Trial scneouieo fcr 1/32. 01 in vs Soutnern Pacific, et al S629M VY-CAL Plastics vs Du Pont S15CM Du Pont loaoed contaminated Local counsel retained. T/C itn CNT *nicn caused Du Pont not orime target. reactors to plug. Eauioment damages from contaminated Ti02. Counsel retained. \ 1 DU 053737 12 DUP 1013634 OSHA - Hearing Conservation Amendment - On August 22, a revised OSHA Hearing Conservation Amendment went into effect. The Amendment incorporated many of the substantive changes requested by Du Pont. The Amendment is more closely in line with Du Pont's hearing conservation program and thus poses far less impact than an earlier version. All C&P plants have received a compliance package to assist in implementing the Amendment. C&P has assisted in Legal's comments on the Amendment.' Further proposals by OSHA on unresolved matters such as significant threshold shift are expected by early 1982. A revised Du Pont guideline to physicians and engineering standard covering hearing conservation are expected to issue in early 1982. Sites should review their medical practices. Other OSHA Health Standards The reopeninq of the carcinoqen requlations' is expected shortly. The proposal to "stay" the promulgation of the priority list is expected shortly. OSHA is expected to review its "control requirements" lead standard. The OSHA labeling proposal is anticipated to be published in December. Considerable simplification from early proposals is expected. Access to Medical Recoros is still being worked on by OSHA. The 5th Circuit Court of Appeals recently unanimously held that OSHA's Access to Medical Records Rule is a regulation and not an administrative "standard." The effect of this ruling is to expand potential lawsuit jurisdiction from the D.C. Court of Appeals to any Federal District Court. Chrome and nickel continue on OSHA's priority list for regulation, and considerable political pressure is being placed on OSHA to regulate formaldehyde, ethylene oxide, and ethylene dibromide. However, since regulation of all of these is dependent on establishment of a final carcinogen policy and there is no clear evidence of significant hazard, requests for Emergency Temporary Standards have been rejected and rulemaking is not expected until well into 1982. State "Right-to-Knowu Legislation In the absence of strong federal "labeling" regulations, state and local right to know activities are proliferating. At least 13 states are involved. New York's legislation exemplifies these. MSDS type information on NlOSH substances must be made available to employees in writing on request. The employer is responsible to obtain information but the manufacturer must provide it if he ships, sells or transports in the state. A training program is required. OSHA air contaminants handled by employees must be listed and records held for 40 years. C&P is working with Legal to eliminate the more onerous regulations being formulated by the Department of Health to implement this legislation. .. DU 053738 13 DUP 1013635 TOXICITY AND PRODUCT HAZARDS CORPORATE MATERIAL SAFETY DATA SHEET PROGRAM Continuation of this program has been suspended until certain key issues on scope and content are resolved. The program was originally conceived to insure that pertinent safety, health protection and toxicological information on chemicals used by more than one department at several sites was consistent. Since the large number of multi-site chemicals involved would have seriously strained resources, the effort was to be restricted to large volume (>1MM lbs/yr) chemicals with significant exposure potential. However, in implementation, the program exceeded this mandate with considerable loss in data quality. C&P has assumed the lead role in revising the corporate MSDS program while the Product Environmental Committee investigates the extension of this program to include tne Company's products. Once the MSDS program is reinitiated, plants will be required to use the corporate sheets as their sole reference for health protection information unless a process chemical has varying compositions, in which case vendors' MSDSs may be used as reference guides. HASKELL TESTING HIGHLIGHTS Dimethyletner. The inhalation teratology study on DME has been completed and a report issued. No teratogenicity was observed up to the test exposure level of h% DME in air. Since minor embryo fetal effects were observed between 2 - 496, Haskell has set the exposure threshold at 1250 pom. This is unlikely to affect the product's ena-use application as an aerosol propellant but further inhalation studies are planned by Petrochemicals. Tetrahydrofuran. The completed inhalation teratology study showed no gross effects. However, final conclusions must await completion of histopathology which is expected by 1Q82. Titanium Dioxide/Titanium Tetrachloride. Rats exposed to Ti02 and TiCl^ atmospheres in a 2-year chronic inhalation study were sacrificed last June and July. No significant gross effects were observed at sacrifice but final conclusions must await completion of histopathology. Goal dates are August 1982 for Ti02 and February 1983 for TiC^. Perfluorooctanoic Acid. The fetal ocular lens abnormalities observed by 3M in its teratology study on ammonium perfluorooctanoate (C-8 acid, FC-143) have now been confirmed as arising from an artifact of the experimental procedure employed in histopathology. Questioning of the effect by Haskell led to a reexamination of the tissue slides by 3M and Du Pont teratologists and a confirmation of their revised opinion by two independent pathologists. A meeting between 3M and Du Pont is scheduled for mid-January 1982 following completion of a rabbit teratology study by 3M. At this time, a final conclusion will be reached and a 14 DU 053739 DUP 1013636 / K fo*low-up to EPA on 3M's earlier Section 8(e) Notification developed. In the absence of any teratogenic effects, the future of Du Pont's candioate fiuorosurfactants to replace FC-143 in ptfe manufacture hinges on their relative nontoxicity as assessed by fiuoriae accumulation in blood. CIIT TESTING PROGRAMS Final reports on the aniline hydrochloride and dinitrotoluene 2-year chronic feeding studies in rats and mice are being prepared. Also the final draft of the report on the 2-year chronic inhalation study on formaldehyde is under internal review. The 6-month sacrifice in the 2-year chronic inhalation study on dimethylamine was completed last month. The study is on schedule and an interim report is expected early next year. The 2-year chronic inhalation study on chlorine in rats and rhesus monkeys is in its startup stages, the test will be contracted out by CIIT. Finally, a protocol for the conduct of a 90-day subchronic inhalation study on nitrobenzene in rats is under preparation. CHEMICAL REGULATION TSCA Inventory revisions for CAP'S Dyes has been accepted c* EPA. Our initial submittal of a detailed review of Colored Pigments listings has shown several discrepancies and detailed review of all CAP'S product line is being considered. A second submittal of revisions is unaer consideration by tne agency. We are attempting to complete this task with a third submittal, which is now almost completed. European Economic Community 6th Amenoment, affecting the marketing of new cnemicals, took effect September 18. Despite many uncertainties, lagging implementation in member states and some doubt by many of those affected, the EEC remains certain that notification requirements for new chemicals will start up in 1982. Nevertheless, certain member nations such as Italy and Ireland have apparently done nothing at all to implement the Amendment, and the law in France (in effect since 1977) differs significantly from the 6th Amendment. On a related matter, the EEC core inventory (ECOIN) is now unofficially available. The official date of publication is still reported to be December 15, 1981, when it is targeted for publication in the Official Journal of the EEC. It is also reported that a computer tape version will oecome available from Chemical Abstracts. CAP will have nine months from the date of official publication to make corrections, additions, etc., to correctly reflect all products sold before the September 15, 1981 deadline. It is also said that an additional three months will be alloweo for late submissions. DUP 1013637 - 15 - DU 053740 ENVIRONMENTAL PROTECTION ENVIRONMENTAL INCIDENTS Plant Antioch Augusta Beaumont Burnside Chambers Works Cleveland De Lisle Deer Park East Chicago Edge Moor Florida Fortville Fort Hill Grasselli Healing Springs James River Memphis New Johnsonville Newark Newport Niagara Falls Pineville Repauno Toledo Wurtland 3ra Q'61 Total 2nd Q'81 1st Q'61 4th Q'80 4th Q'Total Year 1980 Year 1979 Major 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 1 0 0 0 "T 1 11 Serious Potential 1 0 0 2 11 4 2 0 0 0 0 0 1 1 1 0 3 3 2 3 3 0 3 0 0 40 48 41 46 175 220 199 The one major incident was the first in the past year. The forty serious potentials hopefully reflect a return to the former_ deminishing trend line. The following are descriptions of the major incident and others of note involving agency contacts, community complaints or otherwise of concern. q c "D q o> w 00 16 DU 053741 Majors NEWPORT - A major fume release was caused by the overflow of a sulfur chloride storage vessel during a filling step. Three community complaints resulted. Operating errors resulted in an excessive inventory in the system. Procedures have been implemented to prevent a recurrence. Tne incident was reported to the State, which filed a formal complaint and levied a $1,000 fine. Serious Potentials DE LISLE - Fumes from two separate TiCl^ releases carried off-site. The first resulted from a gasket failure, and the second occurred when a plug in a sample line was cleared and the valve could not be closed. There were no adverse health or environmental effects. Both were reported to State authorities. NEW UOHNSONVILLE - A fume release occurred during the washing of No. 1 SR tank. The release had no environmental impact. The authorities were notified and responded as if it were a major chlorine release. BURNSIDE - Over a period of several days, about 250 tons of sulfuric acid leaked into the Mississippi River from a Du Pont barge while it was in the charge of the fleeting operator. There was no apparent environmental damage to the River. A Superfund notification was made, and the incident was reported to the State ana Coast Guard. EAST CHICAGO - A spill of about 4,000 gallons of fluorosulfonic acid occurred in a derailment incident at Bridgman, Michigan. Approximately 2,500 people were evacuated from the path of the dissipating fumes. We reported it to the EPA as a TSCA Section 8(e) emergency incident of environmental contamination. Approximately ten people received precautionary medical treatment. This event is not tabulated in our statistics because it was a totally railroad related TERP incident. HEALING SPRINGS - Approximately 100M lbs. of formaldehyde spilled on the ground as a result of failure of a pressure relief valve to reseat. An estimated 50 gallons ( 500 lbs.) reached an adjacent creek killing a few fish. The incident was reported as a Superfund release, and the State was informed. The authorities were satisfied that there was no significant threat to health or environment. Corrective actions are being taken to prevent a recurrence. MEMPHIS - A release of trimethyl amine occurred during the washing of a process tank. It resulted in a community odor complaint. 17 DU 053742 DUP 1013639 REGULATORY ACTIVITIES water In Kaiser Aluminum and Cnemical, et al. vs. Costle, EPA expects to publish a proposed pH excursion allowance in October. There has been no comment from EPA as to their acceptance of industry's proposal for minimum daily pH compliance of 8536 and average monthly compliance of 99% as determined by continuous monitoring. Air The Administration issued a statement of principles, rather than proposed amendments to the Clean Air Act. In the absence of definitive proposals, Congress will maintain the lead role. In any event, we expect to see some changes to speed the permitting process and reduce associated costs. However, major changes are not likely because Congress believes that such changes would be perceived by the electorate as a "gutting" of the act. Because of such concerns, congressional action has been slow, and a new or amended Clean Air Act is not likely to emerge before March or April of 1982. In Du Pont, et al. vs. EPA, the court has ruled in favor of EPA, thereby letting stand the 0.12 ppm ozone limit vs. Du Pont's ana industry's request for a relaxation to 0.25 ppm. Tne case may be appealed to the Supreme Court. Because of the annual cost to industry as estimated by EPA (approximately $4 Billion/year), Congressional Clean Air Act amendments or the Reagan Administration action may relax this standard. FLORIDA has developed the additional information requested by EPA for the proposed New Source Performance Standards covering the mining industry. The information includes: cost of equipment maintenance over the period 1977-79, frequency of replacement of components in "affected facilities" and the cost of "affected facilities" in 1981. waste Disposal In an about face, EPA no longer will defer the ban on disposal of containerized hazardous liquids in landfills. EPA is expected to define a liquid as anything containing 1036 or more free liquid. The ban, which becomes effective November 19, will increase C&P disposal costs by about $400M/year reflecting use of alternative techniques such as incineration, addition of absorbents or solidification. EPA has deferred until April 13, 1982, the RCRA financial requirements applicaole to owners and operators of hazardous waste facilities. These requirements provide for liability coverage during the operation of the facility and financial assurance that applicable closure and post-closure requirements will be met. 18 DU 053743 DUP 1013640 EPA has determined that the Tennessee Hazardous Waste Management Program meets applicable statutory and regulatory requirements and has granted Tennessee Phase I interim authorization to operate the RCRA Program. Our plants will be working with the State agency rather than EPA on future hazardous waste matters. Oeepwells The recent Underground Injection Control settlement of API, et al. vs. EPA has liberalized both the definition of groundwater and the criteria for exempting underground sources of drinking water. This should simplify obtaining future NEW JOHNSONVILLE deepwell permits. In June, Tennessee formally declined the ODtion to assume primacy for the Federal underground Injection Control (UIC) program. As a result of recent discussions between Charles Jeter, new EPA Region IV Administrator, and Dr. Mike Brunner, Tennessee Dept, of Public Health, the State has agreed to reconsider its decision. Although current information indicates EPA has developed a preliminary State UIC program, no official actions have been taken by EPA. Comments were submitted by DE LISLE to the State of Mississippi on their proposed Underground Injection Control (UIC) legislation. Our comments would bring the State's program more in line with EPA's. PC B' s Initial quarte rly inspections of PCB transformers were ma de and documented by plant s Der EPA's Interim Measures Program. C &P has 60 such transformers, principally at: Chambers Works 25, John son ville 14, Memphis 5, Newp ort 7, and Niagara Falls 3. Replacement wi th non-PCB units would cost approximately $5MM. (PCB's for tr ans formers are oils containing more than 500 ppm PCB.) Signs of vigorous enforcements by EPA further illustrate the importance of site self audits to insure compliance with storage, marking, recordkeeping and inspection requirements. PLANT ACTIVITIES Self-Audits MEMPHIS, NEW JOHNSONVILLE AND DE LISLE RCRA facilities_anc records were recently audited by E&RA. Deficiencies were minor. 19 DU 053744 W9CV0V a n a Inspections EPA made an "unannounced" PCB compliance inspection of CHAMBERS WORKS. PCB annual reports, storage areas and transformers were checked. A return visit was made two weeks later to inquire into former AAQ production and its PCB content. Also, the inspectors sampled selected heat transfer media. We are responding to EPA's continuing questions. The Mexican Environmental Agency conducted a radiation survey on August 13 of ALTAMIRA's ore storage building, settling ponds and outfall line. Beta and gamma readings ranged from 0.1 to 0.4 mR/hr.; these levels about two times background, pose no health risk. However, we believe the survey results are inaccurate because no alpha radiation was detected, contrary to our experience at our U.S. sites. Two weeks later, the Mexican Nuclear Safety Commission took various samples for evaluation of the types and sources of radiation. Their work, as yet, has not been completed. Litigation Save-The-Bay (STB) vs. Corps of Engineers, et al. A hearing before Judge Cox scheduled for November 5 on STB's motion for discovery has been deferred to a date yet to be specified. We have supplied requested information relative to land use between the railroad track and 1-10, but we have opposed STB's request for detailed information on plant environmental incidents. The hearing among other things will resolve STB's request for such information. Water That part of DE LISLE'S NPDES permit addressing deepwell injection will be modified by the State, per our request, to reflect the Fe, Cr and v content of the ore and the ore consumption rate. These liberalizations are needed to allow the plant to achieve compliance consistently. Public notice is expected in late October. Most of EDGE MOOR'S requests for revised NPDES permits have been agreed to by the State of Delaware with Delaware River Basin Commission concurrence. We have advised the State that the iron limit should be raised from 2 to 3.5 ppm, and that we will not oppose the special six month sampling program designed to establish maximum discharge limits. CHAMBERS WORKS was assessed the minimal $500 fine by the Coast Guard for a May, 1981 oil spill. Although the spill occurred in the powerhouse, it ultimately reached the Delaware River. At NEWARK, the pH neutralization system overflowed causing about 3,000 pounds of colored solids in a wastewater slurry to be deposited on the ground, half within the plant fence line and half without. The overflow was caused by excessive surface drainage being collected in the wastewater system during a heavy rainstorm. Plant procedures are being stressed to avoid future situations. 20 DU 053745 DUP 1013642 aaBaMiai^M-BJMwtWaaigmia. Because the mixture is a RCRA hazardous waste, the overflow was reported under Superfund. A follow-up visit was made by the Coast Guard, which concludea that the matter was not under their jurisdiction because the spill did not enter a waterway. NEWPORT notified County authorities that effluent pH fluctuations were likely to occur as a result of the temporary outage of waste neutralization facilities for annual maintenance. The potential for adverse effects to County facilities was minimal due to the reduced flow conditions during the plant shutdown. A fish kill in the REPAUNO sand ditch, caused by high pH waste from a clean out in the sodium nitrite area, was observed by New Jersey Environmental personnel. There was no fish kill off plant or pH violation at the sand ditch outfall. The N.J. personnel were concerned. Cleanout procedures are being studied to avoid future incidents. However, we do not believe that this situation is subject to State or Federal regulations. Legal concurs. EAST CHICAGO received State approval to use "Bromcide" instead of sodium hypochl orite for mic rob iological contro 1 of the sulfuric acid unit cooling tower wa`ter. FORT HILL wa s advised by the Ohio EPA of its willingness to grant a f ive-year NPDES permit wi thout req uiring a new application. However, tne matt er of pH (5XCU rsi on limits is sti 11 unresolved, and the State has ask ed for p1iant per formance data to characterize pH control o f efflue nt water. The MEMPHIS plant study of sewer caoacity showed that a restriction exists in the City's interceptor sewer. The City is scheduling an inspection of the line. The restriction reduces plant flexibility for handling peak storm water runoff and process upsets. Also, discussions were held with City officials regarding possible higher effluent volumes of ammonium sulfate waste. The ACRN area is evaluating a more efficient catalyst that would result in more ammonia bleed through. Incineration, the current disposal metnod for this waste would be too expensive. Recovery of the ammonium sulfate for fertilizer, with sewering capability as backup, appears to be the most promising alternate. Air The CHAMBERS WORKS "bubble plan" for com ply ing wi th the SIP was approved by EPA and New Jersey on Augu st 27. Al so, Ne w Jers ey is proposing to redefine "volatile organi cs" exe mpt ing ce rtain chlorofluorocarbons. This exemption w ould re due e the total emissions contained in the "bubble" el iminati ng the ne ed for a S3.5MM incinerator. EAST CHICAGO submitted a writ ten proposal to the State to increase SO? emission limits from the present 6.5 pounds per ton of acid to 17 pounds. Degradation of air quality would be prevented by increasing stack height. This is expected to reduce scrubber ingredient costs by approximately $250M/year. 21 DU 053746 DUP 1013643 FORT HILL is pursuing authorization to relax the SC2 emissions limit from 21 to 27 pounds per ton of acid. Both the State and EPA Region V have agreed. Remaining steps include review by the Office of Management and Budget, successful passage through a 30-day public notice period and final authorization by the EPA. This liberalization should result in cost savings of approximately $120M/y ear . JAMES RIVER completed installation of the coalescer demister required under the conditions of a variance order granted by Virginia. Initial performance was unsatisfactory, and coalescer pads of revised design will be installed in November. We expect to meet the December 15 compliance date for the demonstration of satisfactory performance. NIAGARA FALLS air pollution permits associated.with "Teracol" expansion have been favorably received by the State'permit engineers. We expect written confirmation by early November. EDGE MOOR has received a new permit for the Line II- fume absorption stack. Per our request, the permit increases the SO2 emission limit from 2.3 to 137 lbs./hr., thereby reducing scrubbing ingredient costs by $300M/yr. This SO2 increase was offset by reducing SO2 emissions from the Powerhouse and other plant sources. Also, the permit contains a provision for 150 lbs./hr. COS emissions recently determined to be present in the stack plume. NEW JOHNSONVILLE received two State Notices of Violation (NOVs) for excess opacity of powerhouse stack emissions during the first and second quarter, 1981. Information was submitted to the State for consideration in excusing the violations. Also, as part of the opacity dialogue, the powerhouse particulate emission testing was completed in July. Average emissions were 0.11 lbs./MM BTU versus an allowable 0.20 lbs./MM BTU. The test report and powerhouse stack permit renewal package will be submitted to the State by 10/30. It is hoped that these results will lead to relaxation of opacity limits as they pertain to the powerhouse stacks. The NEW JOHNSONVILLE scrub solids kiln operating permit was covered in a public hearing held on September 29. No comments were received at the hearing, and it is expected that the permit will be issued shortly. waste Disposal BEAUMONT ano REPAUNO received notice that EPA intends to grant the respective plant petitions to delist aniline/nitrobenzene wastewaters from RCRA regulatory control. These delistings represent a total investment savings of about $20MM vs. the worst compliance case. 22 DU 053747 DUP 1013644 / k BURNSIDE, at the request of EPA Region VI, submitted a reviseo Part A RCRA permit application. The new application eliminated provision for the storage of solid waste, e.g. a furnace brick and tower packing, Because of such materials, we will be disposed off-site in less than 90 days. The MEMPHIS groundwater monitoring program describing barium contaminated groundwater migration received favorable State reaction. However, they are studying impact on the 500-foot drinking water aquifer. Information on MEMPHIS solid waste disposal practices was suomitted to EPA Region IV as part of a study on hazardous materials handling. The program is the result of recent revelations on abuse of landfills in the Memphis area. At NIAGARA FALLS, excavation, backfilling and stone grading of Gill Creek have been completed and Creek flow resumed as of November 1. We nave been advised by the State that the five former disposal sites listed with the Interagency Task Force have been satisfactorily handled. The sixth site, Necco Park, was placed on the New York Superfund list and then withdrawn. The New York authorities were dissatisfied with the progress to date but they agreed to remove Necco Park from the list if we confirmed, in writing, our commitment and schedule for remedial work. That letter has been submitted. Studies of various groundwater treatment methods are in progress and negotiations with CECOS for a right-of-way to install our interceptor pumping facilities are nearing completion. ANTI OCH has been advised by Services that they must apply for Permit. Permitting1 will take abo the Petrochemicals Department The State of Delaware ha s is letter in response to the Bev ill Legal cur rently is preparing a re agreement with the State. Lity jndled by a "no enforcement" exemption. Du Pont EDGE MOOR R&P is attempt ing landfilled sludge to extend the life of the Cherry Island site (a lined landfill). Two routes are promising: incorporate an additional flocculation process step to improve dewatering and/or air dry the sludge. The State has approved further large scale air drying tests outside of the lined area. Peepwells DE LISLE presented testimony at the Oil and Gas Board hearing on August 19 for the #4 deepwell drilling permit. There was no opposition, and a drilling permit was issued on August 20. The NPDES permit application for the well was reviewed by the Bureau of Pollution Control permit board on September 22, and public notice is expected in late October. Drilling will begin early in 1982. 23 DU 053748 DUP 1013645 NEW JOHNSONVILLE returned No. 5 Injection Well to primary service on September 9. The well had been out of service since March, 1980, for the installation of a packer annulus seal system, well receptivity appears to be equivalent to pre-shutdown levels. Ocean Disposal EDGE MOOR's second trimester report covering ferric chloride sales was submitted to the EPA on September 30. Although ferric chloride sales increased 1.5% over the first trimester the percent of saleable FeCl3 inventoried increased 4% reflecting higher Ti02 production. The amount of ferric chloride bid on of contracted for is about 45% higher than the actual sales and increased 6.5% in this trimester. At ALTAMIRA, the acute bioassay of the acidic ferric chloride discharge and the dispersion study of the discharge plume are in progress. The bioassay work has been slowed by lack of indigenous species in the area (due to migration with change in seasons) and will not be completed before the Oecemoer 1 target date. A second dispersion sampling run of the discharge plume is scheduled for late November. Preparation of the final combined report to be suDmitted to the Department of the Navy should be completed by April 1, 1982. Radiation Additional information requested of NEW JOHNSONVILLE by the State Department of Radiological Health (TDRH) in April has been submitted. This information was to provide and/or clarify the status of the plant's rare earth exemption. Since that time, TDRH has requested all of the analytical data used for determining the Th-232 concentration of the pipe scale. This will be submitted as soon as possible. Inspections On July 22, ANTIOCH was visited by two regional air pollution inspectors investigating complaints of a white fallout east of the plant site. This fallout was found to be pollen. To satisfy the residents in the area, authorities set up a high volume samoler to collect this material. BURNSIDE was inspected by Louisiana specialists for both Air Quality and NPDES Compliance. No problems were found by the air. inspector. Two minor criticisms were noted in the NPDES inspection, but we have yet to receive a formal report. NEWPORT'S former Thoriated Nickel operating and disposal facilities were surveyed by a representative of the Nuclear Regulatory Commission. No exceptions were noted, but a plate of Thoriated Nickel was discovered. This plate has been transferred to the Experimental Station for disposal under their existing license. 24 DU 053749 DUP 1013646 REPAUNO was inspected by State officials on behalf of EPA for compliance with RCRA regulations. The inspectors did not appear to be knowledgeable and also refused to give us a copy of the inspection checklist. We do not anticipate any follow-up. Miscellaneous ANTIOCH, at tne request of tne Regional Water Quality Control Board, sampled several wells. Analytical results for a number of organic pollutants paralleled plant effluent composition. As a result, the State is suspicious of groundwater contamination from process spills and seepage and has requested a comprehensive plantwide sampling program. The plant is preparing a reply. FLORIDA submitted its Land Reclamation Conceptual Plan to the State Department of Natural Resources before the October 6 deadline. In preparing the plan, Southeastern Wildlife Services, tortoise, a species of special concern, evaluation preliminary proposals for de for implementing the conceptual plan. ice of the gopher i submitted for our these species and Water Managemen t ' ft. ideepwell at f er. The well would be part of a district-wide network. A mutually satisfactory site has been selected, and we are working through Real Estate to complete a lease agreement. DUP 1013647 25 DU 053750 LOGISTICS, ENVIRONMENTAL & REGULATORY AFFAIRS - QUARTERLY REPORT E. P. BIANCHARD W. R. GALLOWAY, JR. L. H. PAPINEAU L. C. SKAGGS - PA PLANT MANAGERS/SHE COORDINATORS BUSINESS & MANUFACTURING MANAGERS M. E. BAKER J. BLACKWELL J. B. COLEMAN F. S. COOPER C. E. DAILEY, III R. A. FENOGLIO R. T. HARDING T. W. KAISER H. C. MILLER, JR. A. M. ROE R. P. ROGERS^ JR. E. W. STEWART J. R. WESTWOOD 0. YEATON *D. M. MC NAMARA - E. L. HOOPS - *P. C. SANTOS *R. W. PORTER - R. F. GORSKLE *d.'p. dhw*>; *R. A. SHINN D. J. KLINKE - *S. L. SCHENK - D. E. SHIMP *D. L. SETTLE - P. E. MORGENTHALER - *J. S. KLOSS - H. B. SICKLER - *D. V. LUEBKE P. R. JOHNSTON - - *D. F. GILBERT N. R. LIBERMAN - *K. B. PLATT - D. F. REDDISH - *E. J. MANCINI *D. B. SPEED *J. R. GOUGHNOCR - H. W. MO DCWELL - *J. B. RAWLINGS - *R. E. DEVISH - *J. F. KANE - R. R. RUDGE - *D. 0. MILLER - J. R. SCOTT - *R. N. KNOWLES - D. E. CREAGAR *W. H. MORRISON *R. W. KUREK H. W. TURNER - *J. J. SAPP *M. M. DAVIS - *Plt. Mgrs ANTIOCH RESEARCH & LABORATORY MANAGER (S) : ANTIOCH AUGUSTA F. A. VOGELSBERG - EDGE MOOR EEAIMONT F. KNOWLES - JACKSON LAB. BEAUMONT P. L. MEREDITH - EDGE MOOR BWNSBX S. C. DOBERSTEIN - JACKSON LAB. CHAMBERS WORK? N. E. KRAUSS - JACKSON LAB. CHAMBERS WORKS G. E. LYNSKEY JACKSON LAB. CLEVELAND / CLEVELAND DE LISLE DE LISLE DEER PARK 7RS MANAGERS: f\ / / |r(AyB. OARK \J L"DEER FARK / / EAST CHICAGO DIVISION HEADS: - B-13 - B-13 EAST CHICAGO/^ EDGE MOOR S. T. ALLEN B. F. KENNEDY EDGE MOOR FLORIDA J. A. BLUMBERG R. 0. BRAENDLE J. MO CLESKEY C. N. MASTEN (3) FLORIDA J. C. BRECKENRIDGE W. H. REYNOLDS FORT HILL J. P. GIAS H. D. SMITH, II PORTVTLLE L. D. GREENBERG G. C. TUNIS GRASSELLI P. J. GRUNWAID GRASSELLI HEALING SPRINGS PRODUCTION MANAGERS: JAMES RIVER JOHNSONVILLE R. J. MATTSON JCHNSONVILLE A. T. GENTILUOCI MEMPHIS J. C. PIACENTI MEMPHIS J. D. LOJEWSKE NIAGARA NIAGARA MISCELLANEOUS: PINEVILLJE REPAUNO R. R. DETWEILER - AGCHEM P. R. MICHEL REPAUNO W. E. ELTING - C. WORKS C. C. QUARLES TOLEDO WURTIAND R. F. HEDGEPATH - LEGAL D. G. HUNTON - PA R. J. LOMBARDO R. N. SELBY C. H. SMITH J. A. WICK - ERD MEXICAN SITES: 11/26/84 ENRIQUE CASTILLO - PPQ, ALTAMIRA C. M. GONZALEZ - COIORQUIM, LERMA SILVIO O. IAVALLE N. - TEWSA A. VERDEJO - DUPSA, MEXICO CITY DU 053756 U g w 05 ccon