Document VJqOJY9Dm0wzKpD5qDDg6Dko

To -- From INTEROFFICE memorandum T. L. CABBY J. C. SOVAK ee: J. T- Barr/Valley Forge ^ 1*^ Tnnr*i/Ptj`"*ia*<" A. K. McMillan/Valley Forge E. A. Prlaeau/Esccmbla R. E. Schenck/Valley Forge V. J. Stueben/Escembia Date 2T April 1976 Subject AUDIT OP THE OSKA COMPLIANCE IB THE ESCAMBIA ?VC PLANT____________- VALLEY FORGE (LKttlpn, orgpniuuon, ei OacMnntant) VALLEY FORGE__________________________ " (Location. Organiutlen, or Dpprtmnl) An audit of the Escambia FVC Plant vas performed on 20 21 April 1976 to determine the degree of compliance vith OSHA requirements. The overall appearance of the plant ie excellent. The construction on the north end of the plant distracts from the good impressions however. Isolation Is maintained between the construction area and the operating plant. This isolation is not consistently successful and it requires daily maintenance. The respiratory protection program has been fully implemented. The responsibility of maintaining and issuing respirators vas assigned to the Maintenance Department under F. Scanner. At this time, it is diffi cult to Judge hov effective Fred* s efforts are In implementing the program. W. Stueben vill follow-up and vill assure that the program satisfies legal requirements. The attitude of the employees at the Escambia Plant are similar to those at Calvert City. It requires consistent and continuous supervisory in volvement to enforce the vearing of respirators above the one ppm concen tration. The alarm system for the Escambia FVC Plant consists of a single alarm at 1 ppm. Ihe plant, at this time, has no considerations to expand the alarm system to 5, 100, and 10DO ppa VCM concentrations. Based on my interpre tation as veil as J. T. Barr's, such alarms are needed to comply vith the lav. This has been expressed by J. T. Barr in several of his past communi cations. Ifce Legal Department vill be contacted for an interpretation. The monitoring end recordkeeping requirements are veil implemented. i---------------- -------------- (320) AP00043031 T. L. CAREY 27 April 19t6 PC 2 Subject: AUDIT OP THE OSHA COMPLIANCE IN THE ESCAMBIA FVC PLANT I vill follow-up the shore Items in ay subsequent audits. I vill also obtain a local opinion from R. Sehenek on the necessity of multiple level alazms. *TCN:hec AP00043032