Document MMJRrx3yVVrR4EG8JqYvYEaVj

?rtCHEMICALS xcu INTEROFFICE / LAKE CHARLES TO FROM c.w. Banks Jordan DATE SUBJECT November 19, 1985 1985 Hazardous Materials Audit - Lake Charles Lake Charles Management is pleased that you rated the overall audit findings very good. Following are responses to the exceptions noted in your report. 2. caustic Tank Car Loading a. Derails were not in place on outbound ends of the loading track. A blue flag was positioned on one of the two trucks. Answer: The track with blue flag only had a padlocked switch. As a result of your audit comments, both incoming switches will be padlocked with the key controlled by loading personnel on the caustic loading rack. We understand this arrangement meets all requirements. b. Loaded caustic tank cars were inspected for proper closures, placards, tags, etc. Tank car PPGX 3350 was noted with a broken chain on the bottom outlet valve plug. This is a DOT violation. All other cars inspected were in proper condition. Answer: Chain has been replaced and all loading personnel reminded of requirement. 3. PELS(R) a. The West Coast PELS(R) drum is silk screened only with the PPG Emergency Response number and DOT corrosive label. The drum is later product labeled with a removable vinyl label. Since this drum will be reused by the customer a PPG Emergency Response number will remain on the drum, and PPG could be associated with any incident involving the customer's product. The PPG Emergency Response number should not be silk screened on this drum, but should appear on the vinyl label only. Answer: Drums ordered week of December 2 will be correct. Vinyl labels will have Emergency Response number. SL 089795 b. The PELS(R) drum SD-30 is being silk screened with an out dated label. The correct label LC20C-1D1-484D should be silk screened on this drum. If this presents a problem, please contact me. Answer: Will be corrected week of December 2. 4. Organics a. Drums for Perchloroethylene, Trichloroethylene and 111 TriEthane were noted with outdated (1982) labels on them. A new label content has been issued and should appear on any new drum purchase. Drums containing the old label can be used if supply is exhausted in a reasonable time. Some of these drums had a poor appearance due to exterior rusting. Answer: The drums for Per, Tri, and Triethane with outdated labels are being used as rapidly as possible. Hew shipments of drums have updated labels. This transition is occurring slowly due to minimal drum shipments. No drums showing exterior rusting are used for shipments to customers. These drums are kept for delivery of solvents for in-plant usage, b. The PPG Ethyl Chloride trailer was missing front and right side placards. The trailer was loaded and was missing a Transportation Safety Data Tag on the valve outlet. Answer: PPG's Ethyl Chloride trailer has had the placards replaced. All loading personnel have been reminded to renew the Transportation Safety Data Tags when the trailers are loaded. Supervision will check loadud trailers to assure compliance. c. The Matlack Ethyl chloride trailer PP2224 needed remarking of the required ETHYL CHLORIDE stencil on each side of the trailer. Answer: The trailer has been re-stenciled as required. d. The PPG Switch List used by the Organics area (copy attached) does not contain the information required by 49CFR 174.25(b) or (c) for the switching of full or empty hazardous material cars. This form needs to be revised. Contact me if I can be of assistance. Answer: The List in question is used only for inplant place ment of full or empty cars. The appropriate paperwork is currently being used for both outbound and inbound movements. The revisions to the internal switch form will be made as you recommend. SL 089796 5. Lab Samples - lab samples looked good. One hazard description ORM-A NOS should be used only for air shipments. Answer: Have complied. 6. Wastes a. DOT 17H drums containing waste were noted with an improper closure. DOT specifications require a nut on the bolt of the ring closure on the drum. Answer: All drums were in compliance by 11/1/85. Periodic follow up inspections will be made. b. Waste manifests were inspected for proper DOT information and looked good. Only one exception was noted. On Waste Flammable Liquid NOS manifests used for a waste material containing EDO, the letters RQ must be inserted before the word WASTE or after the identification number as follows: RQ Waste Flammable Liquid NOS, Flammable Liquid, UN1993 Waste Flammable Liquid NOS, Flammable Liquid, UN1993 RQ Answer: To the best of our knowledge all incorrect waste manifests have been revised as instructed. 7. Bills Of Lading a. B/L's for HC1 tank trucks do not indicate the DOT specifica tion of the truck or retest date. This is contrary to plant policy: The DOT has made it very clear that this inspection is a shipper requirement. Answer: Now complying with plant policy. b. A number of caustic tank truck B/L's were not signed with the full signature, but were initialed in the capital letters F.D.B. One B/L was improperly signed "Terry". Answer: Reminded all loading personnel that full signatures are required on Bills of Ladings. c. Some B/L's for caustic tank trucks (signed by M.L. Smith) did not contain tank MC specification type or test dates. Answer: In compliance. d. Empty returned tank cars must be described on the B/L in the manner previously noted in item 4c. Answer: To the best of our knowledge, our return Bills of Lading are made up properly. SL 089797 8. The Cargo Information Card for caustic soda barges is not weather proofed or laminated in clear plastic as required by 46CFR 151.45-2(e) (3). Answer: See attached letter from the Coast Guard indicating that a weatherproof information card is optional. HMAUDITGKJ cc: A.G. DeMarco T.G. Brown H.C. Hank J.E. Fike H.J. Hoenes SL 089798 w ^: V\ US Department ontansponotto IObTJW^jQ4SVQ It-f Coast Guard V ^. I Supervisor Marine Safety Detadment U.S. OQAST GUARD 150 Jterine St. Lake Charles, IA 70601-5612 (318) 433-3765 Mr. B. J. Wilson, Marine Engineer PPG Industries Industrial Chemicals Division P.O. Box 1000 lake Charle 16711/4 24 OCT. 1985 Dear Mr. Wl Please excuse this tartly response to your 6 Sept, letter. The regulation as stated in 46CFR 151.45-2 (E) (3) is not specific regarding the requirement for a weatherproof cargo information card being in the wheelhouse. It is our polity to accept either-type of card as having met the intent of the regulation. I would expect also that ather type of card would be acceptable to other officers as well. If you require additional information or if I can be of assistance in the future please do not'hesitate to contact me. ELeutenant Ccrtmander U.S. Coast Guard iipervisor SL 089799