Document O1j2anpnGmw6ZG2MZErYMVnqL

FILE NAME: Drywall Spackling Compounds (DWSC) DATE: 1974 Oct 23 DOC#: DWSC009 DOCUMENT DESCRIPTION: Memo RE National Gypsum Co. - Surprise Inspection - from State of Illinois EPA iifiLif Lj1 /ip / ;/ STATE OF It'LNOIS ENVIRONMENTAL PROTECTION AGENCY INTER - OFFICE CORRESPONDENCE OATE: October 23, 197** f/.EMO TO: Hi les A. Zamco, Surveillance Manager, DAPC r-EO.Vi; R, E l i e d den, Rgion fl-, DAPC NATIONAL GYPSUM CO. - UNANNOUNCED FOLLOW-UP Gold Bond Building Products Division 21800 Maple Stre at Matteson/Cook (6q V s3) INSPECTION, 10/7/74 (1:^7 - 2:50 P.M.) I. D. Mo. 031 180 AAQ Company Contact: Bruno Mini sea1g o ' "Titiec Plant Manager INTRODUCTION The primary purpose of the investigation was to update the enforcement referral I developed dated 2/5/73- The thrust of that referral was the apparent viola tion of numerous asbestos regulations.and the company's lack of an operating permt. The plant manager had. previously stated the company was trying to eliminate asbestos from all their products by September, 1373 (refer to page seven of the enforcement referral), and this was also going to be pursued,. Converst ion with Plant Manager On 10/7/74 I was received by Mr. Mini sea Ic q 'and we had a brief discussion before touring the plant. The following lists the main points of our conver sation. -Asbestos is sfil1 being used at the plant in some products. Asbestos has been eliminated from the formula of all the textured coatings. Most of these products were applied by spraying by the user, -Total asbestos use has been reduced by one-half. -Asbestos has been eliminated from all joint compound mixes sold in ' retail stores for home use. -'`High-bulking clays" have been substituted for the asbestos fiber. effort to smooth, i , u i ! :*m: : 1 1 EVERY IN T E R -O F F IC E L E T T E R SHOULD HAVE ONLY ONE SUBJECT. A L L L E T T E R S T O BE SIGNED . . . NO S A L U T A T IO N OR COM PLIM EN TARY CLOSING NECESSARY. E PA-30-7/71 October 23, 197^ Na t cma Gyps uni Co ,, Pace Two -The company's major'compettrs are U,, 5. Gypsum and Georgia Pacific. PI-AMT -TOUR 5 ea ^Vf i1'''x Joint Compound s ' The inspection began with the charge area where the'dry materials are placed in the nixer. Numerous broken bags were observed. There was also evidence that waste material was being swept instead of being vacuumed. When Mi11sealco was-asked about this, he responded that there was. too much dust to vacuum-- he-said It would take too long' .I asked one of the employees what he did with the empty bags: he responded-that they put- them In plastic .bags, carry, them to the other end of the plant, and throw, them out an opening into a refuse container outside. I asked whether.they .put any labels on the bags; after same hesitation, he said, "Oh yea," and proceeded to look for them, He was unsuccessful in his search. Dry Mix Joint Compounds and Textured Coatings En this area/ail the dry powder products are manufactured and packaged. As mentioned above, none of the textured coatings contain asbestos, but most of the dry joint compounds still do. During my Inspection, an asbestos containing product called "Triple T Compound" was being packaged. There were significant accumulations of waste material on the floor around the bagging machine. Particulate matter was observed suspended in the air and also being exhausted through wall mounted fans. There was evidence In both the charging and bagging area' that the floors are swept instead of being vacuumed: several ..brooms ware observed and sweep marks could be seen on the floor" in some areas. Mini seal co said the bagging machine operator is not supplied with a change of clothes as are the mixer chargemen. Waste Di sposa 1 An inspection of the company's v/aste container revealed blatant disregard for Rule 621 (,d) concerning disposal of asbestos containing wastes. Some empty pa:>er asbestos bags were in plastic bags, but none of those, bags contained warning labels. Other bags were observed simply dumped in the refuse container loose. Still other bags containing asbestos had apparently fallen o"f the overflowing container to the ground. (Mote: After completing the plant, tour -and before I left the site, I drove to the area where the refuse container is kept and took the attached pictures.) A At the conclusion of the tour we returned to Mini sealco's office where 1 reviewed each of the apparent violations observed. 1 also asked him the nature of the course of instruction given employees relative to asbestos October 13, 197*1 Oat Iona1! Gypsum Co, Page Three' hazards, He was somewhat vague in his response, but said various pamphlets had been given to the employees. I told him 1 would make a request for an exact description .of the course and the. materials used in a follovj-up letter, Hinisealco said he.was not aware an operating permit was required, in addition to an asbestos permit, for the manufacturing processes. CONCLUSI3MS i,, The company is not operating in compliance with the following asbestos ` rule:;: .621(a), 6 2 1(c), 6 2 1(d), 651 , 652. 2. The company may not .be operating in compliance with Rule 621(b). 3, The company does not have an operating permit for the manufacturing operations as required by Rule 103(b). 'I h. The 'company has made a substantial reduction in the total ^amount of asbestos used In' their products. . 5, If asbestos-containing joint compounds were prohibited, the company could almost Immediately comply with the requirement. 6. The company's attitude has been lackadaisical when It comas to complying with the asbestos regulations. 7, Asbestos is no longer a critical component of joint compounds-- only lack of acceptance by the trade prevents the compiete elimination of asbestos. ! 8. The Agency has been remiss in their duty to protect people from hazardous materials. An enforcement should have been filed as soon as the apparent violations were detected: it has now been over a year and one-half since the matter was referred to Enforcement Services. RECOMMENDATIONS 1,, The attached letter should be sent to the company. 2. An enforcement should be filed immediately. REHipjw cc: Tom Casper, Manager, Enforcement Services Section Attachments: Letter Photographs Gold Bond Building Products Matteson/Cook ID No, 031 180 AAD Div. Date: Temp: Sky: 10/7/7* Time: 5 3 nF Wind: E, Partly sunny 2:50 PA 10 mob T ?ilSIS LirTtw iiiKriJr.Jti'P kiSpa7b'l'irRW r tt; Figure 1, View looking northeast at the southeast corner of the company5s plant. The Pangborn baghouse shown in the center of the picture serves the Dry Products area. Note the open windows and exhaust fan to the left of the baghouse, , * * .... ........... Figure 2. View showing the disheveled condition of the company's refuse container. Empty bags are tossed from the door shown above the container. Mote the white dust deposits on the wail and windows. The bags on the groun to the left of the container contained loose asbestos fiber. Fibrous residue was observed strewn on the ground around tne refuse container. Dr. Richard H. Briceland, Director October 23, 1974 PLEASE REPLY TO: Div. of Air Pollution Control Naval Armory East Randolph at the lake Chicago, Illinois 60601 National Gypsum Co. Gold Bond Building Products'Division 21800 Maple Street Matteson, Illinois 60443 Attention : Bruno Mini sealco Dear Mr. Iliniscalco: This will confirm the October 7, 1974' visit to your plant by Mr. R. E,, Hedden of this office. The primary purpose of that investigation was to evaluate your present compliance with the asbestos regulations and the con ditions under which your asbestos processing permit was granted. An inspection of your production facilities revealed violations of thefollowing rules; 621(a), 621(c), 621(d), 651(a), 652. It is my understanding that the conditions causing these apparent violations were pointed out to you during the inspection. Further, failure to comply with the conditions attached to your asbestos permit No. A 2 06 002 is grounds for revocation under Rule 103(f). In addition, the Agency has no record of an operating permit, as required by Rule 10.3(b)3 having been granted for your manufacturing operations. (Your present asbestos permit*is required in addition to the operating permit.) In order to evaluate your compliance with Rule 651(b), please describe the exact nature of the course of instruction you have given employees rela-' tive to asbestos hazards. Submit copies of all written materials used for this purpose and a list of all employees receiving this course including the date when the course was given. The condition of your facility during this recent visit, and Mr. Redden's previous visits on 12/4/72 and 1/17/73, indicate a lackadaisical attitude on your part with respect to the hazards of asbestos. The reduction in use of asbestos fiber achieved at your plant in the past year and Gold Bond's plans to completely eliminate asbestos from all products is commendable; however, as long as asbestos-containing products are manufactured at your Matteson Plant, the applicable rules must be followed. National Gypsum Co. Gold Bond Building Products Divkiian October 23,i974 Page Two Upder the enforcement provisions of Section 31 of the Environmental Protection Act, the Agency must consider presentation of this matter to the Pollution-Control Board for hearing. Violation of any regulation- creates a liability for penalty not to exceed $10,000 for each violation and $1,000 for each day the. violation continues. If you'desire, you may submit in writing any facts which you feel indicate the all edged violations are incorrect, or apprise this office of measures which you will be taking to achieve compliance. As the Agency would like to consider your response before taking further action, please respond before November 13, 1974. To facilitate a timely response from your company, I have sent a copy of this letter directly to Mr. W,, A. Schmid at-your Buffalo, New York office. If you have any questions concerning this matter, do not hesitate to contact this office. Very truly yours, C. B. Willard Region II Manager CBW:REH:pjw cc: W. A. Schmidt, Chief Engineer - Environmental Go'1d Bond Building Products 325 Dei aware Avenue Buffalo,' New York 14202 Tern Casper, Manager,-Enforcement Services Section, DAPC