Document R766g73D9NEeD8eMgrKvKb3n

~V- 7k'&A ACIDS TECHNICAL DIVISION VICTORIA PLANT cc: D. G. Jentsch - 570 W. P. Ledet - 570 W. L. Walton - 570 R. J. Sonnier - 570 G. J. Hilkert - 570 W. A. Schurtz -- 570 M. C. Estep - 570 J. H. Reitberger - 570 Acids File 502.100 November 14, 1980 TO: W. R. STEVENS - 570 FROM: R. D. OAKLEY INDUSTRIAL HYGIENE COMPLIANCE PLANS Summary During our last technical seminar on I/H, we discussed what needed a compliance plan; what a compliance plan should be; who should prepare it; who should carry it out; what timing is required; and how the progress should be reviewed. The memorandum summarizes the proposals made during this meeting and suggests documentation procedures; so, the superintendents can review, revise, and issue guidelines for the Acids area compliance plans. Need for Compliance Plans Company policy and government regulations allow routine use of personal protective equipment to prevent a known exposure only until engineering changes are complete or if engineering changes are not feasible. C. E. Bunn's reply to the S&F Industrial Hygiene Audit and I/H Procedure No. 5 require that we have compliance plans for those cases. Use of personal protective equipment is accepted practice as a precaution against the unexpected or emergency conditions and compliance plans are not required or practical. Elements of a Compliance Plan The attached compliance plan form shows what steps need to be taken and provides space for assigning responsibility and timing for each step. - DUP 0814290 DU 009766 2- - Responsibility for Issuing and Updating Plan I/H Procedure No. 5 requires the area supervision to issue a compliance plan whenever respirators are used to meet safe exposure limits and that they must be reviewed yearly. This should be followed for all other types of compliance plans. Responsibility for Preparing and Carrying Out Plan While the area supervisor will initiate and issue the plan, he must have PMT input and commitment for the plan to have meaning. The steps in the compliance plan need to appear on individual engineer's or chemist's objectives with the appropriate priority and timing. Timing The timing needs to be set to show we are diligently attempting to eliminate the use of personal protective equipment where we know exposure would occur. The overall needs of the unit need to be taken into account and obviously not every I/H problem can be solved immediately. However, once we set a reasonable timetable, then we must stick to it. Followup The timing and priority to complete the compliance plan will have a tendency to slip because there is no immediate urgency to complete them.. So, followup by the ADS's and Superintendents is very important. I would suggest a review by the ADS's quarterly and by the Superintendents every six months. Documentation Good records will be needed to support the Compliance Plans. A subsection of the acids I/H file 507 should be reserved for the compliance plan and supporting work. General correspondence on compliance plans like this memorandum should be in 507.100 and specific compliance plans should be given numbers in the .100 series. For instance, 507.101 for the Op. 15 Crude Filter Inspection. The individual compliance files should have copies of all COD's, schedules, reviews, and other correspondence on that problem. The feasibility decision especially needs to be recorded in this file. DU 009767 DUP 0814291 3 The area supervisor should take primary responsibility to see that the appropriate documents get filed. However, the PMT ADS's and the area I/H coordinator must help followup to see the documents are filed. RDO: kd Attachments DU 009768 DUP 0814292 ITEMS THAT REQUIRE A COMPLIANCE PLAN Items that need compliance plans are: Crude filter inspection in Op. 15 V205 loading in Op. 15 V205 loading in Op. 2 ADBA fuming in Op. 3 VCH drum & truck loading in Op. 12 MgO dumping in water treatment Noise control all areas Depending on how our remonitoring orr routine sampling in Op. 1 & 1A turns out, we may need a plan for it Attached for an example is a suggested compliance plan for the crude filter in Op. 15. The PMT ADS's need to review and bless it. DU 009769 DUP 0814293 Acids File 507.101 Date: COMPLIANCE PLAN OP. 15 CRUDE FILTER INSPECTION I/H EQUIPMENT USED ,________ Air Line Respirator PERSON RESPONSIBLE COLLECT BASIC DATA F. L. Salinas GOAL DATE 9/80 Corap. SCOPE SOLUTION ESTIMATE COST JUDGE FEASIBILITIES DOCUMENT DECISION F. L. Salinas 10/80 Comp. F. L. Salinas 12/80 PMT ADS, I/H Coord., Area Supv., F. L. Salinas, Area Supv. 1/81 1/81 INSTALL FACILITIES TEST-RESULTS F. L. Salinas 4Q/81 Area Mechanical Eng. F. L. Salinas I/H Analyst 1/82 DUP 0814294 DU 009770 Acids Pile 507._1 Date: COMPLIANCE PLANS I/H EQUIPMENT USED COLLECT BASIC DATA SCOPE SOLUTION ESTIMATE COST JUDGE FEASIBILITIES DOCUMENT DECISION INSTALL FACILITIES TEST RESULTS PERSON RESPONSIBLE GOAL DATE DUP 0814295 DU 009771