Document VGnnMd6kLVGwNr1YGkJEoqMrp

Recived auG30W82 UNION CARBIDE CORPORATION oldriogeburyroad.danbu^.^t.QSPR LAW DEPARTMENT E2281 (203)794-6379 CERTIFIED MAIL NO. 0627787 RETURN RECEIPT REQUESTED August 24, 1982 Mr.' Gerald Baty Area Director United States Department of Labor Occupational Safety & Health Administration 2320 LaBranch - Room 2118 Houston, Texas 77004 RE: C-4523 Union Carbide Corporation Solvents & Intermediates Division Texas City, Texas Dear Mr. Baty: Your letter of August 11, 1982 has been referred to me for review and response. My client. Union Carbide Corporation, oper ates a chemicals facility in Texas City, Texas. Part of this facility is a noncontiguous offsite disposal area covering approx imately 435 acres and utilized for waste water treatment and organic recovery. There are six (6) waste water lagoons, of which only three (3) are active, one (1) non-active landfill and two (2) or ganic recovery pits. Sporatic samples, both personal and area, have been taken at the offsite disposal area for certain air con taminants in the past. At no time has any such concentration read ing exceeded the Occupational-, Safety and Health Administration Airborne Contaminate Standards' In addition, the number of Union Carbide employees who enter into this area are few and the period of time spent-in the area under normal circumstances is approxi mately an hour per shift. Most periods of time will not exceed 15 minutes at any specific lagoon or pit in the area. As a result, it is Union Carbide Corporation's belief that employee exposure to chemical vapors is either below OSHA limits or does not exist. Union Carbide Corporation will periodically monitor for exposure and if such sampling discloses concentrations in excess 1/ 29 CFR 1910.100 eq seq. UCTC 21203 ilr. Gerald Baty U. S. Department of Labor August 24, 1982 Page Two of the Occupational Safety and Health exposure limits referred to above, respiratory equipment will be used to protect our employees. Please also be advised that Mr. Walker Horn does not hold the job title of Supervisor, but rather is employed as an Engineer. His current primary supervisory experience has been with contractor workers. As a result, there is a serious question as to whether the individuals whose complaints resulted in C-4523 are Union Carbide Corporation employees at all. If you have any further questions, or if I can be of any further assistance, please feel free to contact me directly at 203-794-6379. I am BLW: jhb cc: W. Conrad J. Leverton M. Tapp / P. Yalcinkaya K. Martin C. Dudnick J. Knight R.- Cope V UCTC 21204