Document JJmodQaQLOB634jX3woJJ9gm6

Environmental Audit. (11-871 1. Complete 2. Complete 3. Complete 4. Complete 5. Complete 6. Complete 7. The numerous empty bags generated In the compound and dry blend area are troubling. Even though disposal of these bags Is not regulated, some of these bags contain hazardous residues such as lead. Political pressure is building over trash. It Is directionally correct to minimize solid waste such as bags and move toward bulk or returnable containers. Is there any reasonable reduction projects? At the present tine, we have no reasonable reduction projects to minimize the number of empty bags we dispose of. Ve are actively evaluating methods to reduce this type of waste. Response 11/1/88; Lead, antimony, and arsenic containing bags are all disposed of at a hazardous waste landfill. We are working with our lead suppliers on ways to reduce employee, lead dust exposure (e.g. pelletized lead, lead spills, and semi-bulk systems). In addition to lower exposures, all of these methods directionally reduce the amount of lead that leaves the plant in the empty containers. The semi bulk systems reuse the containers, and eliminate lead contaminated bags. Response 3/89: Engineering work continues. In February, a team was sent to our primary lead supplier to see a semi-bulk in operation. This system worked well, and there was no evidence of fugitive lead sources when transfers were made. Response 5/89: An AFE for a trial semi-bulk system for Line III will be submitted in the 4th Quarter of FY1989. Samples of compound made with pelletized lead were produced and are waiting for customer trials. Response 5/90: Construction of the semi-bulk system is scheduled to be completed by 10/90. VAB.0001001440 1- - Environmental Audit. 2/90 - Continued 5. Done. 6. Done. 7. Done. 8. Done. 9. Done. 10. Done. 11. Done. 12. Done. 13. Done. 14. Done. 15. Done. 16. Done. 17. Done. A VAB.0001001441 3- - nflMMTTTO ACTIOM FUI TM rooms OTTAT.TTY OWCAHTgATTflH 1. Done. 2. Done. 3. Done. 4. Done. 5. Add procedure for annual review of the Quality Manual and a log to document all changes nade. ?/9Ai Review of the Quality Manual is accomplished annually via the internal audit. Me will develop a log to document changes and will number all pages of the Quality Manual to facilitate control of revisions. XJA In progress - manual is being revised to include change control/ numbering of pages (about 20% com plete - estimated completion 3/92). Statos 12/91: Sane. COWTtlW. mtliCTnTCTTM 6. Done. 7. Done. 8. Done. STATISTICAL PROCESS COHTROL 9. Done. > VAB.0001001442 Prestollte Audit Page 3 14. Prestolite Co--ent - Develop procedures for the identification and quarantine of equipment found to be out of ca Document steps taken to re-certify repaired equipment Procedure for identification of equlpnent out of calibration is addressed by the calibration schedule in the Vista Maintenance System (VMS). A procedure for the re-certificatloci of repaired equipment vill be added to the Measurement and Gauge Control section of our Quality Manual. m. Status 9/91: Will be part of the Quality Manual revision (3/1/92). Status 12/91: Same 6/92 target. 15. Done. TNSPTCTTQW Aim TVSTTWO - Provide rework Instruction for all employees performing rework and re-inspection on all part numbers. Status 5/91; We will develop rework and reinspection Instructions for all formulas supplied to Prestolite. JEN/JME bv 7/1/91. Status 9/91: Mew target date 3/1/92. Status 12/91: Same. 17. Done. CORRECTIVE ACTION 18. Done. A q VAB.0001001443 Frestollte Audit Page 5 25. Done 26. Done 27. Done 28. Done 29. Done 30. Done A DCS dlsc/Updated 1-92/rah VAB.0001001444 mRBKCTTVg ACTXOH PT^W Page 2 In progress - estimated completion 3/1/92. Status 12/91: Same. 3. Need written procedures for performance of statistical process capability analysis followed by ongoing process control. Status 2/91: We will write quality plans for product areas that will Include the extent and timing of SPC analysis. (TJA, SCH, JDO by 6/1/91) In progress. Status 9/91: In progress. Status 12/91; In progress. Target as 90% complete in FY92 D. Statistical Process Control 1. All personnel must be trained in use of S.P.C. Approximately 90% of our employees have received S.P.C. training. Our goals for FY91 include the development of an SPC chart use and interpretation course. Our goal also targets teaching this course to forty employees during the fiscal year. (TJA by 9/30/91) - Status 5/91: Same. Status 9/91: SPC training is planned for the first half of 1992. Status 12/91: Same. 2. Done. 3. Must document reactions to all trends, runs and other out of control situations on control charts. Status 2/91: The course referred to in #D1 will emphasize the need to "dirty-up" control charts. Status 5/91: Same. Status 9/91: Same. Status 12/91: Same. A flflMHECTTVK ACTTOW PTAW Page 4 2. Done. 3. Done. G. Corrective Action 1. ust be identified and documented Identification and documentation of probable causes trill be covered In the comprehensive quality plans discussed In C3. Same. Status 9/91; Same Same Status 12/91: Same 2. Done. 3. Done. H. 1. A written procedure is needed addressing effective method to assure material returned is Inspected and corrective actions implemented. We will develop a method and process flow diagram for handling/inspecting returned material (JME by 6/1/91). Our Customer Needs Response System has been implemented to ensure needed corrective action is identified, communicated and taken to ensure customer satisfaction. Status 5/91; Same. In progress - estimate completion 3/92 Status 12/91: Same. I. "Audit 1. Done. 2. Done. VAB.0001001446 K General 1. Done .2 Investigate requirements and develop program to achieve Lab Self-Certification Status by G.M. or A.A.L.A. We will investigate the requirements for a program to achieve Lab self-certification. (JME by 4/1/91) Status 5/91; Investigation not completed. i Lab self>certlficatlon vill not be pursued at this time. Status 12/91: Same. VAB.0001001447 Copies of the appropriate guide pages are Attachment 3, 4 and 5. ERG 31: ERG 31: ERG 27: ERG 55: ERG 26: ERG 17: Fhthallc Anhydride (101, 108P Plasticiser (Vista ERI sheets made) Synpron 16411 Polyvic, Mark 2945, Hark 4734 Altastab 777, 2-Mercaptoethanol Alfol* 810, Alfol* 610 (Vista ERI sheets made) Vinyl Chloride (Vista ERI sheets made) 9. Preparation of BOL's for hasardous waste shipments: We recommend that for preprinted hasardous waste manifests, the shipping description be checked carefully to make sure all mandatory parts are present. Vista is liable for the information on the manifest. 10. Placard requirements: Two placards should be on the Polyvic totes in the plant. (Only one flammable liquid placard was on a tote in the plant). A DCS disc/1-92/rah VAB.0001001448 Tank Cars: Several tank cars noted were contrary to the DOT Regulations and AAR Interchange Rules for failure to have the load limits and light weights rounded off to the nearest SO KG's. VAB.0001001449 DOT AtfPtT 1. Several Emergency Response Guidebooks have been sent by John Farrier to Don Barclay. Don agreed to distribute the books to appropriate Aberdeen employees. We can assist Don In ordering more, if needed. 2. Preparation of switch list for rail moves: The switch list should contain the proper shipping description, the placard notation* RQ (if appropriate), and the "Residue: Last Contained" statement when returning empties. (According to 174.25 (b)(1), 174.25 (b)(3), 174.24 (b)(4). and 174.25 (c), respectively. The new descriptions for the switch list are outlined on Attachment 1. 3. The emergency response telephone number should be included on the switch list because the list performs the function of the shipping paper. [174.25 (b) and 172.604 (a)(3)]. 4. Preparation of "Empty Return" BOL's: The shipping descriptions for returning purchased hazardous material residue containers should be corrected for future bills of ladings. A list of the correct descriptions is on Attachment 2. 5. The hazardous material descriptions should be listed at the top. as the first entries so that they stand out as hazardous materials, See 172.201 (a)(l)(i), (ii). and (iii). 6. Monitoring Procedures: "Throughout the entire period of unloading and while the car is connected to unloading device, the car must be attended by the unloader." [174.67 Ii)]. 7. Determination of required container specifications: For sample ship ments of hazardous materials, performance-oriented certified packaglngs must be used for air shipments. Ve recommend using performance-oriented certified packaglngs for all hazardous material sample shipments to be consistent and insure package integrity. .8 Emergency Response Guidebook pages shou hazardous materials beina returned. HM "The requirements under 49 CFR 173.29, for empty packaglngs that contain any residue of hazardous material, specify that unless a packaging is cleaned and purged of all residue, ... it must be transported in the same manner as required when it previously contained a greater quantity of hazardous materials. This pnrovislion also apopnlied to conformance with emergency response information requirements." VAB.0001001450 Page 5 J. Documentation Instruction Sheets 1. Current written inspection and/or testing Instructions should be revised to Include: A. Sample size B. Gages or tools to be used C. Standards for approval D. Reaction procedure when non-conforming conditions are encountered E. Identification of department or individuals responsible for performance F. Received, dated and signed by appropriate authority G "Accept Zero Defects", statement on I and T plan Status 2/91; We will reissue I and T instructions to Include all the above Items. (JME by 7/1/91) Stjtnp 5/91; same. Status 9/91: In progress - estimated completion 3/1/92. Status 12/91: Same. 2. All test procedures should include, "Accept Zero Defects" statements. Status 2/91: We will include the "Accept Zero Defects" statement on all test procedures. (JME by 7/1/91) $t#tup S/H; Same. Status 9/91: Estimated completion 3/1/92. Status 12/91: Same, 3. Receiving inspection should verify C.O.A. by actual testing on a specified frequency, as well as current acceptance approval of C.O.A. Status 2/91: Quality Control will review our needs concerning raw material testing and will issue recommendations. (JME by 5/1/91) Status 5/91: Not completed yet. w- Status 9/91: In progress - estimated completion 3/1/92. Status 12/91: Verification of COA's is now part of normal raw material receiving procedures. Some testing of raw materials Is also done. No wide spread scale testing is planned. VAB.0001001451 nrntUKCTTVK ACTION PLAN Page 3 4. Action Plan mat be documented for correction of out of control conditions on Control Charts. fiftrl1r* 2/91 s This will be part of the quality plan referred to in #C3. Status 5/91: Same. 9/21l Same. Status 12/91: An overall plan to Improve the use of SPC is being coordinated by the Manager's Natural Team. This item, as well as other improvements, is the goal of the FY92 effort. 5. Done. 1. Implement program including procedure pertaining to advance quality planning activities on new products, including control plans, quality plan, F.M.E.A. 's and long-term process capability studies. This item will be covered in the quality plans referred to in #C3. Status 5/91; Same. Same. Status 12/91: This is part of overall SPC quality plan. Analysis and Cane Control 1. Enhance documented and effective method for the calibration of gages test equipment to include R&D lab, in-process and final Inspection areas, (computer areas) Status 2/91: In process and final inspection areas are complete. The R&D lab will be completed by 4/1/91. (RDJ) Status S/91: The R&D lab has not yet been added to the VMS PM schedule. Status 9/91: Same. Status 12/91i Same. flfflmKfiTTVK ACTIOH PLAH ynd AtithoritT 1. Done. 2. Done. Purchased 1. Done. 2. Done. 3. Done. 4. Done. In-Process Inspection 1. Operating Procedures Manual must include method of approval, revision history log and procedures dated and signed .by appropriate authority. Status 2/91: The Operating Procedures Manuals will be revised to include method of approval, revision history log and dated signatures for procedures. (DFJ by 6/1/91) Status 5/91: Compound procedure manual was revised. The vinyl manual revisions are in progress. Status 9/91: Revision of the vinyl manual is In progress. Status 12/91; 2. Zero discrepancy policy statement should be noted as part of sampling plan procedure and used as the criteria to determine accept/reject status of material. Status 2/91: Zero discrepancy policy statement will be added to each written procedure controlling in-process inspection. (JME by 3/1/91) Status 5/91: In progress. VAB.0001001453 Prestollte Audit Page 4 Gont Inued 19. Praitollta Comt - Dmlop a policy that defines the responsibilities and the procedures used to notify Prestollte Purchasing and Quality Assurance of suspect Material that nay have been shipped. Statw S/Pi l Ve will establish a procedure for notifying Prestollte In the event Material is shipped. However, we believe our positive release method Is effective at guarding against this happening. JME bv Hew target date 3/1/92. Same. COHTROL 20. Done. 21. Praatollte Content - Institute incoming material test instructions to clearly Identify which are to be performed and at what frequencies. St.tni 5/91: We will d.v.lop instructions depicting which tests are to be done and at what frequencies. JME bv 7791. Status 9/91; We do not plan to Institute testing of incoming materials. We rely on SQC data from suppliers to assure conformance. Same. 22. Done. 23. Done. 24. Done. VAB.0001001454 Prestolite Audit Page 2 RTATTRTTCAT. PROCESS COHTROL - continued 10. Done. 11. Preitollte Co--ant - Implement statistical process control on Identified process characteristics. Status 5/91: We will target our compound SPC effort on measuring the amount of raw materials charged to the blender. Implementation of pro cess measurement is targeted to begin by 7/1/91. MRK. JEW TJA. Status 9/91i Measurement parameters are under consideration. Status 12/91: Charting of one parameter has begun; Compound Process Review Team will recommend additional parameters. 12. Done. GAUGE WiTItOL 13. - State the acceptance criteria for each gauge for performed against known standards. Status 5/91; Acceptance criteria for all quality control gauges will be indexed in the Measurement and Gauge Control section of our Quality Manual. JME bv 8/1/91. Status 9/91; In progress along with overall Quality Manual revision. Revision completion targeted by 3/1/92. Status 12/91: Same. VAB.0001001455 Aberdeen Flint FDA Audit 2/91} 1. Done. 2. Done. 3. EVC will be asked to provide a certificate of analysis for BUS-80. EVC should also be asked whether there are any SARA 313 chemicals in BUS-80. A request was made to EVC for this information. We have received an interim MSDS with SARA 313 in formation. Methyl alcohol is contained in BUS-80 and is on the SARA 313 list. Done. Water and steam additives will be reviewed to assure they are FDA allowed. h R&D are doing this testing. Status 5/91: Conversion to FDA allowed additives is complete. Done. 5. Work will continue to assure that reactor agitator seal oil is FDA allowed or that the chance of leakage of seal oil into the reactors is negligible. A trial is planned In the Old Module after the nextseal failure. D500 is currently undertrial. Status 9/91: As seal maintenance is required, the use of the FDA allowed oil will be phased in. Status 12/91: Two reactors use the new oil. All should be converted in 1992. 6. Done. 7. Done. 8. Done. 9. It was pointed out that Vista is now selling Pacific Westexm PVC from the Pace, FL plant and that some of the resin may be repre sented as FDA allowed. JCL. will contact Rick Smith and advise him of the effort at Aberdeen and ask what Pacific Western is doing. Status 2/91: The Business Area is reviewing. Status 5/91; Same. Status 9/91: Same. Status 12/91: Same. 4- - VAB.0001001456 R^gpfluif ff/yo;. Construction of the semi-bulk system is in progress. Status 11/90: The semi-bulk system will be complete by 2/91. Status 02/91: Completion expected by March 1. Problems with valves identified during startup In March are being resolved. The system will be ready to restart in June. Status 9/91; Modifications were made; we are waiting on manpower to resume trials. A trial on non-lead filler went well. Plans are to start using the system with lead stabilizer in 1QCY92. Environmental Audit. 2/90 1. Done. 2. Done. 3. Done. 4. Incinerator sewer tie-in integrity should be evaluated. No progress. The tie-in will be evaluated during a shutdown this fiscal year. Status 8/90: This is delayed until the next scheduled turnarounds (currently scheduled for the summer of 1991). This is delayed until the next scheduled turnarounds (currently scheduled for the summer of 1991). Status 2/91: Same as 11/90. Status 5/91: Same as 11/90. Status 9/91: The planned summer shutdown was delayed to October. Because of the VCM groundwater source investigation, a video inspection of sewers is being planned. This item will be part of this inspection. r VAB.0001001457 2- - M. S. Thomas /i/o r From: Dale: Subject: D. G. Skokna January 6, 1992 QUARTERLY AUDIT RETORT STATUS ABERDEEN PLAET M41P Title Audit Date Status Environmental Audit 11/87 6/7 Completed Environmental Audit 2/90 16/17 Completed Aberdeen Plant FDA Review 1/91 7/9 Completed U.T.A. Audit 11/90 14/30 Completed Prestollte Audit m DOT Audit 4/90 10/91 22/31 Completed 0/10 Completed BOE Audit 11/91 0/1 Completed The DOT and BOE audita were received very recently and not prepared.our Initial response on plans to correct. D. C. Skokna Plant Superintendent rah attachment cc: RWS VAB.0001001458 E< A H MH OH *4 a "H 4 P d AH 8 fl 41 -H tJ M * o N O *9 C H rf rl HO <M-rl 4i ft *> 3 *H Ol *H O m <h 4J na *5a 43 5 a* *4 >m m 4 (3 H MM 5 H 1 # O 41 S i.O O P .O O P ANHUAL CASH FLOW 1MPRO 4J 0p X * P0$1 8 tf P< 4011 Of CO < uo u CO0oU-*4HoOHl -HCCOwf* ter Qof CD QnQ O VAB.000 001459 <HM IP