Document ExKLJ9nyBqa9oaJy1jp9k7NGV

. MaReMONT 1 COP P O o A T Q N INTER-OFFICE CORRESPONDENCE TO; R. C. Rogers LOCATION: A. ?. Staszak Paulding SUBJECT; 0SHA EXPENDITURE - SUPPLEMENT TO REPORT DATED SEPTEMBER 8, 1975 *TE: November 3, 197 5 COPIES TO; ?.. A. Mennelgarn ". X. Knight PLAINTIFF'S EXHIBIT OSHA EXPENDITURES FOR 1976 MAR-451 Dust Control The following is a listinq of machines hv deoartnent where work i required to comply with osha Standard 1910.1901 covering operations using asbestos in their processes. Projected dollar values have been extracted from the 3190,090 proposal submitted on the Annual Business Plan for 1976. Modification of branch ducts and design fabrication and installation of dust pick uos will be required at the following machines. Block Department - Projected Expenditure 639,000 =1639 Saw *2555 Internal grinder *1632 Belt grinder brancer *1629 Belt arinder =1524 Grinder *1613 Drill *1619 Drill *1620 Drill *1621 Drill *163 Drill *1343 packinc station gang saw Disc Department - Projected Expenditure S50,000 Hammond Grinder G-9 grinder bevel grinder packing station b rar.dsr pill machine** - where unprocessed natter is transferred into hopper oresses** * Includes modification of existing collector for improved efficiencv. **340,000 of the 350,000 will be required for desicn, fab rication and installation of an additional bag house to co._2ct cicsb cscsirscsd bbcss l.ocs.^i.or'.s ccs co tr.2 iir'.itoc c2.02ci.bv oz cbs ocssscC co 1 isctor. --<z_r.ir.c ^s'cs.rcr'.sr.b. -- Pro'.acbsd "y.oscdi.b.`crs S^ , 0 0 0 Fzrr. So- UC-TOS3 .Z'i*} R. C. losers November 3, 19; 5 Pace Two f1774 I.D. grinder groover side crincer hard feed saw #1315 1.3. grinder *2553 I.D. grinder O.n. grinder little ford mixers packing station (drill) 1373 belt grinder The remaining S10,000 will be required for additional air make up units to improve efficiency of dust collection systems in all departments. This is necessary because as the collectors exhaust air from the plant, a negative pressure system is developed. V!ith this happening, the proper transport conveying velocity cannot be achieved at the dust pick ups. Alternative Substitute alternate material such as fiberglass for asbestos. Mo standard as comprehensive exists for employee exposure to fiberglass. Of course there is no guarantee that a new standard will not be promulgated,in fact a standard could be enacted which would be as stringent as the asbestos standard. Moise Control To comply with the 05HA Standard 1910.95 of 90 decibels, Aweighted sound level, work will be renuired at the following machines. hearing in mind the $7,500.00 proposal, this could possibly resolve noise problems at 3 machines. Slock Department Block drill (2 hole) saws 1639, rip saw lining Department lining saws side grinder lining grinder 41797 lining grinder 1306 lining grinder = 1793 Alternative Maim until we are ciced and fined bv OSH.-, before taking care of ocher machines "where noise exceeds rhe permissible lever. ?. C. 'ocsrs November 3, 19 7 5 race Three Glare's and Miscellaneous To comely with OS:?A asbestos housekeeping standard 1910.1001 (H) (1) , the following will be necessary. Purchase vacuum units (10-15 required) to service entire operation, bearing in mind that acceptable units range between $1,500 and $5,000 in price, the only avenue open would be to purchase 3-4 units at a figure of around S9,000 and hope that when we are inspected by OS.'IA, that house keeping is satisfactory. This would leave around 54,000 to cover cost of personal proc-active equipment, lunch rooms, fabrication of nachine guards, guard railing and ether safety devices as the needs arise. '"nether this amount will be adequate is questionable. R. C. "ocers Povemher 3, 1975 Page Four 11-3-75 APS OSHA EXPrCiOTTCRF-Q 1977 Although nuch of this work needed to be accomplished in 1976, the following shall represent 1977 requirements. Dust Control Althourk chancre rooms were removed from the proposed budget for 1976, I reiterate my previous conviction that 530,000 will be required to construct same. Since we were cited for violation of this standard on December 14, la73*, and chances beir.c that dust levels will remain unacceptable in certain areas, we could he issued a citation for a repeat or willful violation for failing to construct change rooms. To reduce operator exposure to asbestos, up to 30,090 would be required for improvement of asbestos handling at mixers, Flock and Disc presses. Ductwork with hoods will need to be installed at the Clutch winders at a cost of approximately S5,000. Due to CPA regulations, the wet scrubbers serving the Slock Department and Lining Department will require conversion, modification, or total replacement with dry type ban house collectors. Cost for this work could exceed .5200,000. ^tart late 1077 . Approximately S150,000 will be required to construct an agglomeration svsten to process asbestos waste material (dust) to a form which will not release asbestos fibres into the air. Moise Contro1 Up to 320,000 may be required to comply with the 90 PDA regulate This represents work required to install enclosures, barriers, etc., ac machines left over after 1976 expenditures. Guards and Ciscsllaneous Costs after d run between S20,900 - S30,000, depending or. r.eecs :iusior. of fiscal year 1976 . This would cover: 1 2 a. satety g.assas b. safety shoes R. C. Rogers November 3, 1973 Page 5 11-3-75 APS 4. building alteration (guard rails, etc.) *This sane violation required us to install dust controls at the 3lock presses at a cost of: Sino,000. This work is scheduled to be completed bv November 24, 1975. A. P. Staszak OSKA and "PA Compliance Director APS: llv