Document RJ3zD9Vkbj3nM8V1NxmzKjpE

CHEMICALS 3 J .-3 's ' INTEROFFICE / LAKE CHARLES TO R. E. Hanna FROM B. W. Walker DATE OF INSPECTION: COMPLIANCE OFFICER: CAUSE OF INSPECTION: UNION REPRESENTATIVE: MANAGEMENT REPRESENTATIVE: DATE June 17, 1974- SUBJECT OSHA Inspection #2 June 12 - 13, 1974 Steven D. Herron Routine - (VCM Process) Mitchell Andrews Bill Andreas Bob Lynch Bryant Walker OPENING CONFERENCE Mr..Steven D. Herron, Industrial Hygienist with the Department of Labor, arrived at the Lake Charles Plant on June 12, 1974. He requested to see a management representative and was referred to Murry Davis, Safety and Security Director. An opening conference was established at Dewey Duncan's office with the Compliance Officer, D. L. Duncan, R. E. Hanna, J. M. Davis and B. W. Walker present at the conference. A questionaire concerning VCM and PVC was given to Mr. Duncan to be filled out by his choice of personnel. Another questionaire was given to R. E. Hanna concerning routine information, i.e., number of employees, names of PPG Officials, address, etc. Mr. Herron asked questions from another questionaire which established whether PPG is covered by the law and other routine questions. Mr. Herron was asked for some identification and he presented his Department Of Labor Credentials^ Mr. Herron stated that his primary purpose was to inspect our VCM process and VCM shipping. He also stated that he would like to inspect our asbestos insulation shop and storage area if he had time. Mr. Herron requested an interview with an employee representative. Mitchell Andrews was called to Mr. Duncan's office for the interview with Mr. Herron. After the interview, Mitchell Andrews stated that Bill Andreas would accompany Mr. Herron on the inspection. Mr. Duncan informed Andrews that the employee representative would not be paid by PPG during the inspection. Mr. Duncan appointed Bob Lynch and Bryant Walker as the employer representatives for the inspection. INSPECTION The inspection began in the Safety Director's office so that Mr. Herron could review our accident records. All recordkeeping was in compliance with OSHA. 0269'] R. E. Hanna OSHA Inspection #2 Page 2 Mr. Herron also reviewed our personnel and area monitoring results of VCM exposure. After inspection of the records, Mr. Herron proceeded to the VCM plant to inspect the facilities and monitor an operator for VCM exposure. John Jordan, VCM Operator, and Bill Andreas were questioned in private by Mr. Herron before the samples were taken. Jordan was asked to collect a VCM sample so that an air sample of his exposure to VCM could be taken. Our lab personnel took air samples at the same time. A picture was taken of Jordan as he attached a sample container to the VCM sample line. Jordan was also monitored as he analyzed the VCM sample in the VCM plant lab. Another picture was taken in the plant lab. Before leaving the VCM plant, John Jordan explained that he had operated the wrong valve on the sampling job which caused VCM to spray out onto his hands. Mr. Herron stated that this will not cause the sample to be invalid due to the probability of this type of incident occuring at any time. Mr. Herron then requested- to be taken to the Shipping Department VCM Tank Car Loading Rack for inspection. After arriving at the loading rack, Mr. Herron determined that monitoring would not be necessary due to new inovations which eliminated exposure. His conclusion was reached after a discussion of the loading procedure with Dean Thibodeaux, Shipping Department Loader, and Charles Burns, Shipping Department Foreman. After leaving the loading rack, Mr. Herron requested to see our asbestos operation in the Cell Repair Area. Mr. Herron inspected the asbestos storage area first and then walked through the Cell Repair Area. The following proposed violations were noted by Mr. Herron on his first inspection of the Cell Repair Area. 1. Failure to post appropriate asbestos hazard warning signs in the asbestos storage and handling areas and on containers which contained asbestos. 2. Failure to keep a safety shower unobstructed for use. (A floor fan had been placed under the safety shower.) 3. Failure to utilize eye wash fountains in place of hose attached to safety shower. 4. Failure to maintain bench grinder in compliance with standards. a. The tool rest was not adjusted within 1/8" of the wheel. b. The top of the guard opening was greater than 1/4" between the wheel and the guard. 5. Failure to provide a safe walking surface around a wet operation. (Water on floor around cathode dip tanks and around cement mixing operation.) 0000270 ] R. E. Hanna OSHA Inspection #2 Page 3 When Mr. Herron noticed the lead pouring operation, the asbestos fluffing operation, and the solder wiping operation, he decided to return the following day to obtain personnel monitoring samples on each operation. Before leaving he stated that he would conduct a closing conference and would like to review our monitoring records on the above mentioned operations. We proceeded to the Safety Director's office to look at the records and have the closing conference. M. Davis produced the monitoring records as requested and Mr. Herron asked for a copy of each. Copies of the records that were given to Mr. Herron are attached as attachments #1, 2, and 3. The closing conference was conducted and will be discussed in a later paragraph. The following day, June 13, 1974, Mr. Herron obtained personnel monitoring samples from Dennis Clifton and Sydney Clemet on the lead pouring operation; from Peter Carrier on the asbestos fluffing operation; and from Robert Hartman on the solder wiping operation. After Hartman completed the solder wiping operation, Mr. Herron requested an examination of the respirator due to Hartman coughing during the operation. Upon examining the MSA Comfo Respirator, it was found to contain two Mersorb cartridges on it instead of the required GMA organic vapor cartridges. This resulted in another proposed violation and possible citation. 6. Failure to provide proper respiratory protective equipment. CLOSING CONFERENCE A closing conference was conducted on June 12, 1974, with Mr. Herron, Bob Lynch, J. M. Davis, B. W. Walker and Bill Andreas present at the conference. I should point out that it was the employer's prerogative to allow the employee representative to be present at the closing conference. Mr. Herron explained the proposed violations and the employers responsibility in handling any citations resulting from such proposed violations. He also explained that due to a delay in receiving his sample results, it may be six weeks to two months before any information on the sampling would be available. If the results of the samples indicate a violation of the allowable concentrations, we could receive additional proposed violations which could result in citations. In reviewing the proposed violations, it was pointed out to Mr. Herron that the specific standard covering safety showers and eye wash facilities allowed the use of a hose attached to the safety shower. Mr. Herron stated that it was the Area Director's interpretation that "eye wash fountains" must be installed. He remarked that he would check this proposed violation with the Area Director and call us on the decision if it results in a proposed violation. CONCLUSION All violations noted by the Compliance Officer are only proposed violations that may or may not result in a citation. Issuing citations and establishing 000027T7 R. E. Hanna OSHA Inspection #2 Page 4 penalties is the prerogative of the Area Director for the Louisiana Office. If a citation is issued, the violation is considered as alleged until a 15 working day waiting period ends after issuance. During this 15 day period, the employer has an opportunity to contest the proposed violations. If they are not contested, the proposed violations are considered as violations and must be corrected within the prescribed abatement period. Personnel monitoring samples were taken by our lab personnel each time the Compliance Officer took samples. The results of our sampling are as follows with the TLV indicated for each chemical. ITEM VCM - Process Operator VCM - VCM Lab Lead - Feed Pot Lead - Pourer Lead - Soldering Job RESULTS 5.0 ppm 2.2 ppm 71 ug/m3 34 jjg/m3 169 ^ug/ri^ TLV 50 ppm 50 ppm 200 jjg/m3 200 jjg/m3 200 jig/m3 BWW/bc Attachment (3) cc: A.T. Raetzsch D.L. Duncan R.E. Baker T.G. Taylor J.M. Davi s L. Krause J.H. Morgan R.P. Lynch R.E. Eakin J.C. Lafleur H.J. Hoenes C.A. Burns E.L. Cook H.C. Underwood R.E. Sourwine 1_BB 0000272 | lead-in-air data SINCE I969 Monitored Personnel or Area Fo Pot Operator Solder Pot Operator Solder Pot Operator Fd Pot Operator Solder Pot Operator Solder Pot Operator Fo Pot Area Solder Wiping Area Fb Pot Area Solder Wiping Area Fb Pot Area Solder Wiping Area Solder Wiping Area Fb Pot Area Fd Pot Area Fo Pot Area Fb Pot Area Solder wiping area Solder Wiping Area Fb Pot Area Solder Wiping Area Fo Pot Area Solder Wiping Area Date Comments Fb Ms;thod Cone., mg, 4- 2-69 4-2p-69 5- 2-69 10- 7-69 10- 7-69 10- 7-69 2- 4-71 2- 4-71 3-15-71 5-15-71 11- 8-71 11- 8-71 11- 3-71 11-10-71 >14-72 3-11-72 5-14-72 - '5-14-72 3-11-72 11-10-72 11-10-72 6-21-73 6-21-73 * Sampled ONLY while wiping bus bars with molten solder. A A A A A A B < 0.05 0.20 0.15 0.05 4> o. o 0.10 < 0.05 B < 0.05 B < 0.05 B < 0.05 B < 0.05 B < 0.05 Sampled ONLY while wiping bars -B Sampled ONLY while pouring lead. B Sampled while removing slag from Pot Sampled while pouring lead. B zo'B<r; Sampled while pouring lead. B "-B Sampled while wiping bars. B Sampled while pouring Fb. B Sampled while wiping bars. B Sampled while pouring lead. B Sampled while wiping bars. B 0.05 0.10 0.05 <0.05 < 0.05 < 0.05 < 0.05 < 0.05 0.05 < 0.05 < 0.05 Method A: MSA Personnel Monitor, 12 to 48 min samplings. Method B: MSA Universal Fo Test Kit, approximately 2 min sample near personnel. 1 BB 0300273 | To: From: Dr* H. B. Lovejo. Tommy R. Vizena employee DATE OF SAMPLE VOL. LITERS Alton Thomas Murlin Fontenot Emmanuel Guillory Robert Hartman John McNabb Charles DcJean Clifton Dennis Fetor Carrier Jos. Guidry Raymond Landry Wickley Boullard Simon Woods 4/17/74 4/26/74 4/17/74 4/17/74 4/26/74 4/19/74 5/15/74 4/26/74 4/19/74 4/22/74 4/16/74 4/26/74 5/15/74 0.68 0.64 0.56 0.60 1.60 0.86 0.44 0.58 2.88 0.48 0.74 0.34 1.74 SP. GR 1.024 1 *l8 1.021 1.017 1,011 1.002 1.030 1.029 1.007 1.026 1.025 1.020 1.012 UNCOR. 0.038 0.033 0.057 0.035 0.021 0.027 0.145 0.041 0.034 0.035 0.027 0.033 0.024 Date: June 3, 1974 Subject: Houston Chemical's results on blood & urine lead. URINE itig/L COR.(1.024) 0.038 0.044 0.065 0.049 0.047 0.324 BLOOD mg/100 gm 0.033 0.062 0.053 ii i^ I AJ (I OO Io iiJ O aj I 03 *f 0.050 0.030 0.100 0.116 0.034 0.120 0.032 0.026 0.040 0.045 0.041 0.060 0.050 0.051 0.048 V- Date 3-06-7*43-06-7^ 3-08-74 3-08-74 3-13-74 3-13-74 3-13-74 3-14-74 3-14-J4 ^-15-74 3-15-74 3-15-74 Tyre Personnel Personnel Personnel Personnel Personnel Personnel Area Personnel Area Personnel Area Personnel AIR SAMPLED POP iSTAL FUMES A1ID DUSTS Fa, Sn, Cu, Zn Dura.tion Joh or Area Concentration, Ug/M3 5 Hours 5 Hours 4 Hours 4 Hours Anode Pouring Solder Wiping Anode Pouring Solder Wiping' (Dejean) (Guillory) (Clifton) (Clement) 880 580 170 1,030 Pb Fo Fb Fo 3 Hours 3 Hours Anode Pouring Solder Wiping (Dejean) (Guillory) 340 (310 (280 Pb Pb Sn 3 Hours Lunch Table 3 Hours Lead Pot Addition (McNabb) 3 Hours East Wall on Temperature Recorder 3 Hours* Maintenance Welder-Copper (Hayes) 6.'3 Hours Between Fb Pots 2.5 Hours Cathode Hand Tinning (Hartman) 7T Pb 500 Fb 25 Pb 450 Cu 69 Fb ( 35 Fd ( 14 Zn ((29 as ZnCl2) Threshold Li'Tn-i t Values for Above Metal Fumes and Pasts (from OSHA Tables") Fb (Lead, inorganic) 200 pg/M3 Sn (Tin, inorganic) 2.000 pg/M3 Cu (Copper, funs) 100 pg/M3 Cu (Copper, dusts and mists) 1.000 pg/M3 Zn (Zinc chloride fume) 1,000 pg/M3 I BB 0000275 | 3 hours continuous cutting of copper -with copper rod. This type of work done approximately once in two weeks (3 hours).