Document RppBgyMGzVrJ6wMXoXBdb9ZzB

Interoffice Communication To From Oat* Subjact Robert L. Lembke, M.D. Oran D. Steffey January 22, 1975 TRIP TO ABERDEEN CHEMICAL PLANT During the week of January 12, 1975, Andy Longoria, M.T., and I visited the Aberdeen Chemical Plant for the purpose of taking biological samples and checking the installation from the standpoint of OSHA Standards which cover General Environmental Control-Sanitation. The following areas were covered from a general Industrial hygiene standpoint: .Main Offices Color Weigh'Areay# Automatic Bagging Area Old Hose Line Area Line III Lines I and II Plasticizer Building Central Break Room Storeroom Dryer Building V-ll Switch Gear Room D 300-400 Reactor Area Compressor Building Treating Ponds Drum-Material Storage Lupersol Storage Prairie Storage West Warehouse Manual Bagging Area Hog Area New Warehouse Dry Blend Control Room Laboratory Main Change Room Shop V-10 Reactor Building Vinyl Break Area V-ll Reactor Building Steam Generation Plant Dry Chemical Storage Blending Silos Empty Drum Storage Federal Compress Storage VCM Unloading The following comments are made relative to the above areas: Main Offices - This area was found to be in good shape. Discrepancies which were reported as a result of the June 23, 1974, inspection have been corrected. Warehouse-West - The storeroom over the Purchasing and. Accounting offices', is in very poor condition. Floors were dirty and needed cleaning..; Insula-< tion material, which appeared to bej^piiMliH^feasf type insulation,: had been torn from lines and left laying on the floor. Precautions should be taken when removing asbestos type insulation and it should be placed in plastic bags, marked and disposed of immediately. Materials need to be sorted / out and should be stored in an orderly manner. Containers of chemicals X r. SAL 000107731 4 Robert L. Lembke, M.D. January 22, 1975 Page Two were found stored In this area. All chemicals should be In an area used for normal safe storage of such materials. The platform area just out side this storeroom should be cleaned up and materials should be stored in an orderly manner. Railings have been Installed around this area. In the warehouse proper, materials were found to be stacked unsafely. Some containers had been left stacked precariously, some boxed materials were crushed on the side. Contents of some containers were spilled onto floors and onto pallets. All spilled materials should be cleaned up, dust should be vacuumed from all stored materials and floors In general should be kept free of dust and trash. There Is still the very unsanitary condition, which existed during the last inspection of this area, where people walk along the fence and spit tobacco onto the floors and onto the fence. This practice creates a very unsightly and most unsanitary condition. Color Weigh Area - The area next to the color weigh roonr used for storage of materials needs to be cleaned up. . Floors-are^duaSpiisome bag8; are ` broken and materials have'spilled onto the floor and other stored materials. Some of these materials contain lead. This entire storage area, has been in need of better maintenance for some time, especially since materials which contain lead are stored here. The weight room is dusty throughout. The hood exhaust system still appears not to be efficient in remoaringjkis>wi Again the recommendation is made for cleaning of filters and maintenance of this equipment. If this equipment is not found to be efficient due to needed engineering changes, these changes should be made without delay. Manual Bagging Area - This area has been improved, however, dust is*still prevalent to the extent that better attention should be given to use of vacuum cleaning. Automatic Bagging Area -Excessive noiee-is caused in this area from compressors. These units should be sound proofed or moved to an area which would eliminate the noise in the bagging areas. If moving is chosen for alleviating this problem, relocation should be in an area where other persons are not effected by the same problem. The floors need to be cleaned. Dust and various incidental materials have been left laying about the area. Hog Area - This area in general is very discouraging. Much finanadustti covers parts of equipment and floor in thick layers. Water lays about the equipment and especially around electrical switch gear boxes .along^,, the east wall. Poor lighting, which has been an item of'^ast industrial hygiene inspections, has not been improved. With`no more light than is provided in this area and with the poor housekeeping condition now prevalent, this area is very unsafe and unhealthy. .* ,-.v SAL 00010773 Robert L. Lembke, M.D. January 22, 1975 Page Three Old Hose Line Area - This entire area needs to be cleaned up. Materials should be stored In an orderly manner, space should be left between Items to allow for cleaning and sweeping and trash and dust should be kept cleaned from the stored materials and from the area In general. Various odds and ends such as hose spools and other materials are stored In an unorganized manner. Floors are dusty and dirty. New Warehouse - The floors around the shrink-wrap machine should be cleaned and swepfc^Trash and odd '.Items heed to be"plckedi:up and removed !rom this area*..;* The drinking fountain near the south wall next to the office and loading dock doors needs to be replaced. This fountain appears to be plumbed directly to the sanitary waste line. A trap should be placed In the drain1 line between the fountain and the sanitary waste line. Compound Line III - Materials on the floor around, the equipment need to be picked.upeand. the floors should be swept-iandkeptcleaned. ." *' - ' ' .....r - The room adjacent to'And 30* south of Line III, needs.to be cleaned up. Materials stored In the south east corner of this room should be stored in an orderly manner, dust should be vacuumed from Items and broken bags of materials should be cleaned up. In the Line III compound mixer area, the floors are dusty, materials need to be stored more orderly, dust should be vacuumed from floors and stored materials. It was observed that a compressed air hose was being used to remove dry blend mix from equipment. Blowing of materials by an air hose should be prohibited. Various materials were stacked around the door exit near the master batch blender. All exits should remain clear at all times. The master blender is very dusty. It is recommended that engineering attention be given to provide for a more efficient and less dusty operation. Dry Blend Control Room - The drinking fountain drain line appears to be plumbed directly to the sanitary waste line. A trap should be Installed between the fountain and the sanitary line. It was observed that fresh air masks were notbeing kept clean. These were being taken into dirty areas for use and left hanging or laying around to collect dust and dirt in these areas. Compound Lines I and II - These lines were not in operation at the time of this inspection. Most of the area was in good condition, however, dust needed to be cleaned from the equipment and from the floors around the equipment. Laboratory Area - The ladles restroom needed.j:o be .eiggnori -,^-Mgfrg-r-tni .. #. and various items were stored haphazardly on the floor and on a small " shelf. All items should be kept stored neatly on this shelf andUnothing should be left on the floor. The floor needed to be cleaned and especially around the toilet stool and at the junction of floor and wall. Tiles should V ! 'V ^>3-: ...M SAL 000107733 Robert L. Lembke, M.D. January 22, 1975 Page Four be cleaned and the lavatory needed to be cleaned. The drain from the drinking fountain In the main part of the laboratory appeared to be connected directly to the sanitary waste line. This drain should have a trap installed between the fountain and the waste line. Storage shelving in the storage area in the southeast part of the labor atory should have protective lips installed on those being used'for bottles axui glass containers of chemicals and samples. The aisle in this storage ` area was cluttered with boxes and dolly carts. `laboratory benches along the north wall of the development laboratory need to be cleared of stored materials. All benches should be kept clean and free from storage items. Plasticizer Building - The ground level floors need to.be swept and. cleaned. Drums containing Formica Add are corrodedalongsides&amLsome have sides near the bottom ends crushed in. These should be tested for soundness and . those not - safe should hav^thtu^contents transferred to a new `drum. On the second floor,yP-Tolj>snsBulfoniicAcijcU^which is contained in drums, ia-being heated by steam strap heaters and the material is being transferred to the reactors by use of a bucket. A safer method and one less likely to cause exposure should be devised for handling this chemical. Floors need to be cleaned, especially around the reactors. ln~the storage area, workers were at work re-baggn&*Xsophthallc.Acid* without the use of dust masksor'gldvesTFlborsin this area need to be cleaned ancUdtrstshould be vacuumed from floors and stored materials. Bisphenol bagged materials need to be re-stacked and re-bagged since some stacks are tilted and some bags are split open. TrimetalUc Anhydride-bags are broken and contents should be re-bagged. Powdered Activated Carbon bags are broken and materials need to be re-bagged. This storage area in general needs to be cleaned, materials re-bagged, and all items re-stacked in an orderly manner. Change Room - For the most part this area was found to be in good shape. if. Central Break Area - Lunch pails are being left on the tables and in window sills. All lunch palls should be stored on shelves which have been provided, thus making it easier for those doing janitorial work to clean and maintain the rooms. Used paper cups and refuse had been left on tables, this should be placed' in receptacles provided. Trash and dirt has been allowed to accumulate under and behind vending machines. This same condition existed during the last inspection. These machines should be moved out from the walls at least once a month and the floors cleaned in order for sanitary conditions to exist. Wlth>the* conditions aatthey are * there was evidence of cockroaches and one does not,need to look very far to see the reason for the presence of such disease bearing insects.*. These same vending machines were found to^be dirty and needed cleaning. Some of these were out of order and appeared to not be of much use. If these Robert L. Lembke, M.D. January 22, 1975 Page Five are to remain In this room, they should be serviced and maintained in workable condition or they should be removed so as not to contribute to catching of dust and trash and to prevent problems for those charged with cleaning the room. The microwave oven is still sitting on an inverted metal trash can. This same condition has existed during past Inspections. The inside of this oven is dirty and needs to be cleaned. A table should be provided without any more delay. A wood panel below one of the windows in the west wall has a hole ln it and needs to be , replaced with a new painted panel. The drinking fountain.,needed to be cleaned and should be checked to be sure it has a trap in the drain pipe. Floors in this lunch room need to be scrubbed, mopped and cleaned, especially around the edges at the floor-waH'sjuncture and in the corners. The windows are dirty and need to be cleaned. . Water was running^and dripping from.the roof over the east entrance and water w** grand! this area in the approach4tothe laboratory-warehouse area. The drainage should be-'improved to eliminateiit^iastanding^water4and the source*of^the dripping watersshcruld be eliminated. Shops.--This area has Improved.in housekeeping but.much/isuyetrjtp- be desired. Floors beneath and~hehind workbenches need to be cleaned and ltr:general the entire area requires a constant effort to maintain cleanliness and for the storage of materials in an orderly fashion. Storeroom - Personnel are trying hard to maintain good housekeeping in this- area. Space is at a premium. Aisles are cluttered with , materials and by necessity items must be stacked outside needed storage: shelving. An electrical line leading from an outlet on the south wall into the office in the west side of the storeroom should be replaced with a permanent line. The panels on the main electrical duct work have been left open and electrical lines, some of which are bare and possibly live, have been left dangling in the open and unprotected from being touched. The roof above this office and where electrical switch gear boxes are installed leaks. This condition should be corrected as soon as possible. V-10 Reactor Building - This building is being cleaned and straightened. Even though this building is no longer a production area, it should be maintained in an orderly and clean condition. All drums and containers being stored in this building should be properly labeled as to correct contents. Dryer Building - Fresh air masks are stored in a mask cabinet which is blocked by steeLcabinets. Masks have also been stored dirty;andidusty. A new drinking fountain appears to be plumbed directly to the*sanitary waste-pipe. A trap- should be installed in the.drain pipe betweemgthe fountain and the sanitary line. The dryer building was found to be in good shape throughout its entirety. ** Vinyl Break Area - The refrigerator needed to be cleaned, especially the freezing compartment. The Inside of the microwave oven needa. to be cleaned. The.; drinking fountain should be checked ..for: installation of a,trapin the ^ M* jVri i?rm+1 f SAL 000J0773S b Robert L. Lembke, M.D. January 22, 1975 Page Six drain pipe between the fountain and the sanitary waste line. The rest room was much improved, however, the floors should be cleaned and scrubbed in the corners and at the juncture of floor and wall. Wall tiles need to be scrubbed and cleaned. V-ll Switch Gear Room - Some of the control boxes^were open. These should be kept closed*,*? One control was tagged to' indicate work,being done on a .unit controlledaby this box. A lock out should be used under these conditions teauBsure.that the system is not actuated. V-ll Reactor Building - This building is not being used. It-vas found.,to ...... `be cleanandln^gbod condition. * */.*. #: i D 300-400 Reactor* Area - The small refrigerator;needa^toetbe*defro8ed and , cleaned.^tte-drflwera in the metal cabinet:hehind^theconso^andwhich is . -4 being'uBM^^il^conjunction with^food-preparation^ and^lunhhesteneedfto be ` ^ cleaned. 'Theseadrawera ar*,;Cl!ttered with trashy they; are dirtysanda.should be maintained, in'-as clean, sjfmtary condition. Theccontrol room in general.. wasafound to be ingpod shape. vf . ' Steam Generation Plant - This area has been improved, however^ much needs, to bedone ltrfrthe way of>;sorting'vand;;''Storlng'10f^iSiia^Ala.^^em^i4ored in shelving and.on benches should be cleaned up and stored in an orderly manner. Preformed insulation materials are stored.on the metal walk way along the east wall of the building. Some of this has been broken. This should be cleaned up and a check should be made to .assure that there is no asbestos type of Insulation stored here. Materials above the office and storage should be sorted and stored orderly. Shelving being used, in the office or test room, for storage of chemicals should have protective lips installed. The drinking fountain appears to be connected directly to the sanitary waste line. This should have a trap installed in the drain line between the fountain and the sanitary line. There is some question as to whether untested well water used for boiler feed is being used through this drinking fountain. The water being supplied to this fountain should be city water only. Compressor Building - Water was covering part of the floor in the west part ; of this building^ Drain channels should be cut into the floor leading to the floor drains in order to alleviate this condition. Covers to electrical ducts located in the northwest part of this building were open and electrical wires were exposedaand draping out. These wires should be tucked inside the ducts and the^covers should be closed and secured. The cooling water-reservoir beneath the floor.of , this. buildingadoeewnot| i. appear to have sufficient overflow relief which- could result' in.flooding of the entire building floor surface. If this happens a very dangerous condition would exist since banks of switch gear boxes are installed along the south side of the room in a recessed portion of the floor. i ,i.' } - ' iifS" : - <4 l 1* ' SAL 000107736 Robert L. Lembke, M.D. January 22, 1975 Page Seven A sufficient overflow relief should be provided In order to prevent such condition. Trash should be cleaned from behind the moat southwest located bank of switch gear boxes. Dry Chemical Storage - The enclosed part of this area should be cleaned, floors should be swept and all materials should be stored in an orderly manner. Treating Ponds - Sulfuric Acid is used in this area to adjust the pH of the water in the ponds. This requires the presence of a safety shower which has been installed but it has been located in a very poor location. It is somewhat hidden behind buildings and associated equipment, it is not well marked, it is some distance from wherethe acid is being added to the ponds and it was not in working order due to being frozen on the day it was inspected. This shower should be relocated to an area which would make it more accessible, It should be marked and painted a bright contrasting color, and it should be kept in usable condition in any kind of weather. The acid druma-Should be kept stored together in an orderly manner. These were scattered over the general area and not stacked together very neatly. Blending Silos - These silos continue to be a^vary*dusty area** Resin was found to be laying about the area in very thick layers. This material should be kept cleaned up and the general area should be kept clear of all products. The area along the east side of the building and just to the north of these silos was stacked with all sorts of trash and various materials. This should be cleaned up and the entire area along the building should be kept clear of materials. This area has been one which has indicated a problem during every inspection which has been made. Drum-Material Storage - The fenced storage area located at the southeast corner of the new warehouse needs to be cleaned up. Drums should be stacked with more care. Some of these are stored so that they overhang pallets and present a dangerous unbalanced condition. Room needs to be left between rows of stacked drums so that access can safely be gained and so that housekeeping can be done. It was noticed that a fire extinguisher located at the southwest corner of the fence of this area was completly blocked by material which had been left stored around it. Empty Drum Storage - This area located just,south of the plasticizer building is greatly improved. Drums are 8tlU being stored haphazardly near the southeast corner of this building. Pallets have been left laying around in disarray. These should be stacked in an orderly manner and out of the way in order to give safe passage through the area. Various products are allowed to run from the supposedly empty drums stored here. * Sft*-. 00010'?737 4 Robert L. Lembke, M.D. January 22, 1975 Page Eight This causes a very undesirable condition not only on the cement pad along the building but along the entire graveled area along the south of this cement pad. Some method should be devised to safely drain pro ducts left in the drums and maintain a clean sanitary condition in this area. This condition has been reported before. Lupersol Storage - A new storage area has been constructed for lupersol. This was^found to be In good condition. ' * ' - *: " 1 " v'f if *>, ... ..... .;-! - .. . ; Federal Compress Storage - For themost part this area was found;.to be > y. in good shape. -Bags of 'FVC resin should be stacked vith greater^pare. :f"' Some of'these were stacked*with questionable.stableness. A? nallBoblie - trailer, which affords, andean lunch area and,which has restroomifacilities has, been provided for. those working in the area. Prairie Storage^Warehousea Jbeing.fcusedfox%storge were found_ta.be in goodshana.in mo8t^respec^^y^e restrQOonw<ml<L8tillSbe-conaldereda ; make-bift. It was not cjDplfc. An electric heater was being:usedto reduce^the.chill in^he toilet area and this required plugging in.the heater to a wall outlet outside the toilet and draping the electric cord across the entrance way. The facility consists of walls constructed around a stool and lavatory with no roof or celling provided. Lighting is still quite inadequate throughout these warehouses. VCM Rail Unloading - This area was found to be in good shape. A periodic inspection needs to be made to assure that all grounding lines are in good shape throughout their full lengths. In addition to the above discrepancies found in the specific areas listed, the following comments are made relative to other areas: The area just south of the shops and west of the Central Break Room needs to be cleaned up. All materials which are placed in this area should be stored in an orderly manner and the area should be maintained clean and neat. > Near the southwest outside corner of the shop and storeroom, sulfuric acid is being used at a treating pit. No safety shower was in evidence. A safety shower and eyewash fountain should be provided for this area. They should be locatedso that easy access will be assured, they should be painted a bright contrasting color and be marked with proper signs. All drinking fountains throughout the plant should be checked,for installation of drain line traps between the vfountain>and sanitarywast& ^ , lines. These should also be checked to assure that city water is provided at the fountain. A clear answer did not appear available as to frequency of sampling of breathing air provided by the compressor unit near the west property line. .-5 . V- W,, -. jJ ' SAL 000107738 Robert L. Lembke, M.D. January 22, 1975 Page Nine Concern for this was shown during the last Inspection. The OSHA regulations concerning breathing air was pointed out In specific terms in the last industrial hygiene trip report. A program for sampling this air should be instituted which would give unquestionable information as to the quality as specified for breathing air. Indications were quite obvious that much improvement is being made at this plant. A greater effort is being made to clean up most areas. Much is to be done but with a progressive effort to attain a clean, safe plant and with the institution of a program which would maintain good, clean hygienic conditions once these are attained will give desired qualities to working conditions in the plant. Management is to be commended for this effort shown. Industrial Hygienist rla * SAL 000107739