Document VVpGKj1JjGwGmX8naQBJyn04

? CHEMICALS f'-f 7 7^- -> "f yib INTEROFFICE / LAKE CHARLES TO FROM R, J. McCorquodarle Jon C, Shepherd DATE SUBJECT July 1, 1988 Summary of OSHA Compl iance Inspection - 6/21/88 - 6/24/88 Reason for Inspection General Schedule Health Inspection of Chlor/Alkali production facilities (SIC code 2812) to include the Special Emphasis Program's Systems Safety Review screening elements. Compliance Officer Mr. Richie Hofman, CSHO - Baton Rouge Area OSHA Office Opening Conference 6/21/88 at 9:30 A.M. - Human Resources Conference Room Those present were: Richie Hofman, Al Bresley, Bob McCorquodale Ken Savant, Jon Shepherd, Mr. Hofman opened the conference by explaining the reason for his visit. The key elements would include: 1.) Review of OSHA Log 200 (past 5 years) 2.) Review of PPG programs for Hazard Communication, Hearing Conservation, Industrial Hygiene Monitoring, Medical Surveillance, Respiratory Protection, and where applicable, Training records. 3.) Review of Employee Medical Records. 4.) A walk-around inspection (w/Union representative present). 5.) Employee interviews 6.) Completion of the Systems Safety Review screening questionnaire. Mr. Hofman indicated that he did not intend, at that time, to conduct any industrial hygiene sampling. However, he would make a final decision once the walk around and employee interviews were completed. He requested copies of the following information. 1.) 1987 OSHA 200 Log. 2.) Hazard Communication written program. 3.) Hazard Communication Chemicals Inventory 4.) Hazard Communications training records (Note: 2 or 3 rosters, not complete list). 5.) Hearing Conservation Program. 6.) Hearing Conservation training records (see note above), 7.) Randomly selected employee audiograms. 8.) Respiratory Protection written program. 9.) Respiratory Protection training records (see note above). 10.) Any current biological monitoring results (for Mercury) 11.) Any current Asbestos air monitoring results SL 085374 R. J. McCorquodale July 1, 1988 Page 2 12.) Any current Chlorine air monitoring results 13.) Any current Mercury air monitoring results 14.) Any current Noise monitoring results 15.) Any written descriptions of PPG's "Health Program". 16.) A process diagram or schematic for the Chlor/Alkali units. We responded that, with one exception, the scope of the inspection was acceptable and that the records requested wcould be assembled without delay. (This was done and given to him by the end of the second day.) The exception involved access to employee medical records. We explained that PPG has a strong policy regarding the confidentiality of employee medical records and access. We could let him view those files only if each employee involved signed a consent form to allow such access. It was suggested that he could select some representative number of employees, that we would ask each employee to give his/her consent, have a waiver signed, and then proceed. He agreed to this procedure. He asked Ken Savant as the Union representative to select five employees from different areas of the Chlor/ Alkali units, including Maintenance. We also explained that audiometric test results were considered to be medical records and as such could not be copied for him. He agreed and said that he would limit his review to those audiograms contained in the medical records he was given access to. That concluded the opening conference. Bob McCorquodale brought the OSHA 200 log and Recordable 5704s to the Conference Room for review. OSHA Log 200 Review The OSHA Log 200 for 1984 through present, along with supporting 5704s, was provided for Mr, Hofman's review. He found no problems with our Logs. He commented that this was the first time he had reviewed injury records for a company had gone back and updated the logs basis the April 1986 BLS guide lines. He commended us for this. Medical Records Review The employees selected by Ken Savant were: Mike Hazi # 5085 Paul Landry # 678 Maurice Miller # 5356 Ken Savant # 915 Doug Smith # 494 Signed consent forms were obtained for each employee prior to proceeding. The review was conducted in the Manager, Employee Health's office (J. Murry Davis). Ken Savant was present. Mr. Hofman commented that the records were well organized and indicated that all medical surveillance elements were in place and up to date. SL 085375 I I R. J. McCorquodale July 1, 1988 Page 3 Medical Department Tour Mr. Hofman was then shown through the Medical Department. He asked questions regarding our audiometric test procedures and blood sample collection methods. He recommended that our staff begin following the CDC guidelines for veni puncture. He said that he would send us a copy after he returned to Baton Rouge. All other areas were in order. Program Review The balance of the first day of the inspection was spent reviewing the written programs listed above. Mr. Hofman seemed to be very impressed by our Safety Procedures binder. He liked the "Safety Bulletin" concept and indicated the content areas showed a well-organized program in place. He departed the plant at 3:30 P.M. Systems Safety Review Screening The second day (6/22/88) tf the inspection was devoted entirely to answering/ discussing the screening questionnaire for Systems Safety Review Special Emphasis Program (OSHA CPL 2-2). A complete copy is attached to this summary. Plant personnel who participated in the discussions at various times were: Al Bresley - Emergency Response Bob McCorquodale - Safety Programs/Emergency Planning Jim Meadows - Maintenance Practices & CHAR/PHAR reviews. Andy Plauche' - Spill Response Roy Sanders - Loss Prevention & Inspection Programs Jon Shepherd - Chemical Inventories Wilton Wallace - Operations Practices/Information & CHAR/PHAR reviews. Jim Wyche - Environmental Issues The discussions were tape recorded, however, the sound quality is such that transcription is impractical. The tapes will be maintained in the event that a future need demonstrates that the effort is warranted. See below "Closing Conference" for a discussion of Mr, Hofman's overall impression of the Chlor/Alkali facility (question # 19 of attached listing). Walk Around Inspection The third day of the inspection (6/23/88) was devoted to a walk around inspection of Chlor/Alkali Operations and support areas. Ken Savant, Union OSHA Coordinator, accompanied us for the entire day. The Company representa tives were myself and Dan Grieneisen in Plant C or Howard Duhon in Plant A. Unit representatives are given below. SL 085376 R, J. McCorquodale July 1, 1988 Page 4 Process schematics for each unit (copies attached) were given to Mr. Hofman prior to commencing the inspection. 1. Chlorine "C" (Steve Gaudet and Garland Garrett) We began in the Control Room. The process flow was explained using the control panel schematic. The outside tour started at the Raw Brine Storage Tanks and followed the process flow through each stage of treatment to the polished brine storage tanks. We then proceeded to the cell circuits. Steve explained the flow of brine into the cells and described how each component coming off of the cell (C^, , & Cell Liquor) was handled. The group followed the flow of CI2 through the coolers and blowers; examined the Neutralization system; the Acid Towers (Drying); and the compressor area. We walked through the H,, compression/handling area. The final area inspected was the Glanor Repair Shop. Each stage of the renewal process was explained. The asbestos processing room was inspected (NOTE: No asbestos handling was going on). 2. Caustic "C" (Terry Smith) As before, we began in the Control Room. The process was explained using the control panel schematic. The outside tour started at the Cell Liquor Tanks and followed the flow through the evaporators to the coolers and filtration area. 3. "C" Welding Shop The group made an unscheduled visit to the ' C" Welding Shop. All employees were at a safety meeting, so no work was in progress. We made a brief walk-through and looked at the element repair area at the east end of the shop. 4. Main Lab Building (Jim Wyche) We made a second unscheduled stop at the Main Lab to look at the C/A Quality Control Area and the Environmental/Industrial Hygiene labs. Most employees were at lunch so no work was observed. The group stopped for lunch. 5. Mercury Cells (Tom Narbit) Due to time constraints and sandblasting going on in the Brine and Mercury treatment areas, the inspection was limited to the Mercury Cell circuits only. We started where the brine enters on the north side. We walked through the lower level as Tom explained the process flow and mercury containment systems. We next walked through the circuit room. Cell potentials, electrical safety procedures and the decomposers were explained. We finished in the Control Room where cell control methods were briefly discussed. SL 085377 R. J. McCorquodale July 1, 1988 Page 5 6. Electrolyzers Mr. Hofman decided that because of time constraints we would limit the Electrolyzers inspection to a brief walk-through. As such, he did not feel that an Operations representative was needed. We checked in through the Control Room and proceeded to Circuit #16. We did not enter the circuit area proper, but rather observed from the west end. We next walked through the K-303 Maintenance Shop, From there we walked along the back (north) side of the Renewal Shop and entered the northwest door to the shop. Two employees were engaged in depositing a diaphragm. Mr. Hofman decided to just look in the door window of the processing and storage rooms. We walked out past the manual and automatic wash houses and looked briefly at the west end of the Circuit # 15. 7. Liquefaction (Bob Kovatich) We started the inspection at the south end of the area at the chlorine compressors. Bob reviewed for us how the various process flows entered and exited the area passing through compression and refrigeration. We walked through the scale tank areas and north to the Tail Gas Recovery Unit. Bob explained in detail how the Sulphur chloride process works including the final sulphur chloride condensation steps prior to discharging the vents. 8. Pels (Roy Coniglio) Mr, Hofman decided to skip the "A" Caustic walk through (we later drove past on the road east of K-306) and proceed to the Pels unit. We entered at the shipping end of the building and walked through to the Control Room. There we met Roy and Bob Green. Roy explained the process and we went outside to the evaporator/furnace area. From there we walked east to the Prill tower and past to the Pels bagging/drumming area. After walking through the bagging room we returned to the Control Room and departed. 9. Garage Paint Shop/Carpenter's Shop (Lionel Mestayer) After returning to our vehicles we headed toward the north dock areas. As we passed the Garage, Mr. Hofman decided that he would like to briefly visit the Garage Paint Shop. We stopped, located Lionel, and walked briefly through the area. There we spoke with a painter working in the area. We walked through the Carpenter Shop, looked at parts of the dust collection system and left. 10. Complex Paint Shop/Sand Blast Yard From the Garage we drove through the Sandblast Yard (no work going on) and stopped in the Painting Yard. We got out and walked through the area. While there Mr. Hofman examined drums and containers for labeling, etc. He requested Material Safety Data Sheets for the following: - PPG Aquapon Polyamide Epoxy - Component A - PPG Epoxy Thinner (#97-725) - PPG Leptyne Thinner - Thompson Water Sealer (NOTE: These were provided to him the next day.) We walked to the shop and spoke with several painters there. Mr. Hofman looked at blasting hoods and paint storage lockers. SL 085378 R. J. McCorquodale July 1, 1988 Page 6 11. North Docks We completed the day by driving south past the Tank Farm to the North Docks area. We paused at the Chlorine Barge Loading Dock while Mr. Hofman asked some questions regarding loading practices, etc. From there we returned to the Human Resources Building. Mr, Hofman departed the plant at approximately 4:30 P.M. 12. General Comments: Throughout the inspection Mr. Hofman looked at or asked questions regarding: - Respiratory Protection - including usage, storage & inspections - Hearing Protection - including use and signs - Emergency Procedures - Hazard Communication - Maintenance Procedures Employee Interviews Mr. Hofman conducted employee interviews during the last day of his visit (6/24/88). Four employees were selected by the Union OSHA Coordinator - Ken Savant. These were in accordance with areas/jobs Mr. Hofman indicated. The employees selected were: T. J. DeVilbiss # 331 - "C" Chlorine Brine Treatment Operator Warren Vidrine # 5205 - "C" Welding Shop Welder Mark "Tony" Sonnier # 5962 - Mercury Cell Utilities Operator Curtis Ceasar # 148 - Electrolyzers Renewal Man While Mr. Hofman invited a PPG representative to be present during the interviews, Bob McCorquodale declined. It was felt that to do so might seem like pressure from the Company for the employees not to be open and candid. Ken Savant was present during each private interview. Closing Conference 6/24/88 at 11:45 A.M. - Human Resources Conference Room Present were: Richie Hofman, Bob McCorquodale, Al Bresley, Jon Shepherd, and Ken Savant. Mr. Hofman opened the meeting by stating that he appreciated the openness and professionalism of PPG staff and Union representatives. He discussed briefly eight items which he felt required some attention on our part, but did not warrent citations. (The Safety Department has the list and has either closed or is working on resolving each item.) We asked if he wanted any follow-up communications from us. He said that it was not necessary - that he would get in touch with Ken Savant to check that action has been taken. SL 085379 R. J. McCorquodale July 1, 1988 Page 7 He then summarized his findings on the various program areas. 1, Hazard Communication - Good written program and an excellent MSDS delivery method. He stated that the microfiche system was the best method of providing access to MSDSs that he had seen. 2, Respiratory Protection - Good program - all elements seem to be present and functioning well. 3, Hearing Conservation - Good use of hearing protection where needed. Audiograms, etc., in order. U-. Medical Surveillance - Good, thorough program. 5. Monitoring (Air) Results a. Noise - No problems. b. Asbestos - Some high results, but engineering controls were good. (He commended us on the cleanliness of the Plant C Renewal Shop.) c. Chlorine - No problems. d. Mercury - No problems. 6. Safety/Health Program in General - Overall a good program. He was very complimentary with regard to our Safety Procedures Manual. The last point which he covered was his intended response to question #19 on the Systems Safety Review questionnaire: It is apparent that PPG's management has the employee's interest at heart. All of the interviews conducted indicated that PPG has consistantly worked towards improving conditions. The appearance of the two plant areas was very good considering the corrosive nature of a Chlor/ALkali facility. The "GEM" preventative maintenance painting program seems quite effective. There was no visible or detectable evidence of leaks or spills. The Liquefaction area was impressive due to the absence of any chlorine odor The general maintenance and housekeeping of the facility is above average. There was no detectable evidence of hazardous chemicals being vented to the atmosphere. Mr. Hofman concluded the closing conference by stating that we appear to have an excellent working relationship with the Union, and that we are to be commended for our over-all Safety and Health Program. Bob McCorquodale expressed our appreciation for the professional manner in which the inspection was conducted, and that if there were any additional questions, we would be happy to respond to them. Mr. Hofman departed the plant. 'SHA^Notiee CPL 2-2 S"n 9q iqq7 Directorate of Field Operations Appendix B SCREENING ELEMENTS A written summary of answers to the following questions must appear in the case file. Not all questions will be applicable to every workplace. Conversely, any additional information which bears on process safety but which is not addressed here should also be put in the case file. 1. How many of the chemicals listed in Appendix A are involved in the operation? Produced, used, stored or handled? 2. How many of the chemicals listed in Appendix A are used in quantities equal or greater than the amounts listed? 3. what is the size of the facility (i.e., number of employees)? Number of square feet under the roof and acres in the plant? What is number of process s that involve Appendix A chemicals? 4. What is the age of the machinery or units used where Appendix A chemicals are involved? 5. What is the relevant history of the facility? Releases or spills of toxic chemicals? Any EPA reportable releases or spills? Previous or current inspection violations? Explosions or fires? 6. Are there comprehensive management programs including loss prevention, hazard evaluation, reactive materials, inspection and maintenance, plant modification, training, and emergency response? 7. Does the loss prevention program include safety and health self-audits? Frequency? Corporate, local, or contracted? 8. Is there a viable Labor/Management Safety and Health Committee? Are there regular and frequent meetings and walkthrough inspections? Are there prompt resolution of detected hazards? OSHA Notice CPL 2-2 D.iSreEcPto2ra8te..o. Field Operations 9. Are incidents (spills, leaks) investigated and are corrective actions taken? Are records made of incident investigations and subsequent corrective recommendations/actions? 10. Is there an environmental monitoring program? Scheduled or continuous monitoring with alarms for highly toxic chemicals? 11. Are there scheduled shutdowns for comprehensive maintenance? Is maintenance preventive and programmed, or reactive to breakdowns? Is there a testing and calibration schedule for critical equipment? Is there any indication that previously installed pressure relief devices have been removed, plugged, or blinded? Are there permit systems for confined space, lock-out, line breaking, hot work? 12. Is material compatibility, flammability, and reactivity considered in all aspects of design? Is there a nondestructive testing program? 13. Are the programs administered by, or is there access to, qualified safety and health professionals? Are these personnel educated, certified, licensed, and/or experienced? 14. Is there formal and periodic training conducted in operating procedures, process hazards, emergency programs, permit systems, release mitigation, PPE, and HAZCOM? Are there written PPE and respirator programs? Hands-on training and appropriate equipment available? 15. Are there exothermic chemical reactions which can "run away" if not controlled? Do the processes use catalysts, inhibitors, or initiators? Are any processes operated near auto-ignition, explosive, or flammable ranges? Are these processes purged and inerted? Are there extremely high or low temperature/pressure reactions? Are there pressurized vessels which contain highly toxic chemicals? 16. Are there environmental controls (i.e., scrubbers, flares, incinerators, destruct systems, etc.) in place to prevent toxic chemical releases? Are there redundancies incorporated in these controls? B-2 SL 085382 W2WL 2'2 Directorate of Field operations 17. Are there utility systems that are critical to maintenance of safe operation (i.e., cooling water, electric, heating)? Do they have back-up systems incorporated in them? Are back-up systems provided for computer generated controls or other equipment which may be considered essential? Has any analytical evaluation of fail-safe been conducted (i.e., Fault Tree Analysis, HAZAN, FMEA, etc,)? 18. Are there written emergency/evacuation procedures? Are they coordinated with local authorities? Are emergency control center(s) established? Are there re-entry and clean-up procedures? 19. What is the CSHO's overall impression of the facility in regard to its potential for catastrophic release? Included in factors contributing to this impression may be those such as: 0 Results of employee and management interviews. 0 Evidence of equipment or structural corrosion. 0 Evidence of leaking equipment or chemical spills. 0 General maintenance, clean and orderly plant conditions. 0 Number and type of hazardous chemicals which are vented to the atmosphere. B-3 \ Si 8s383 I s&mw2-2 Directorate of Field Operations Appendix A List of Extremely Harzardous Substances List 1 Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Acetone cyanohydrin Acetone thiosemicarbazide Acrolein Acrytamide Acrylonitrile Acrytyi chloride Adiponrtrile Aldicarb Aidrin Ally! alcohol AJIylamme Aluminum phosphide Aminoptenin Amitron Amitron oxalate Ammonia Ammonium chloroplatinate Amphetamine Aniline Aniline, 2,4,6-trimethyiAntimony pentaflouride Antimycin A Antu Arsenic pentoxide Arsenous oxide Arsenous trichloride Arsine Azinphoa-ethyl Azinphos-methyi 75-86-5 1752-30-3 107-02-0 79026 107-13-1 814-68-6 111-69-3 116-06-3 30900-2 107-18-6 107-11-9 20859-73-8 54-62-6 78-53-5 3734-97-2 766441-7 1691966-7* 30962-9 62-53-3 8605-1 7783-792 1397-940 86-864 130928-2 1327-593 778434-1 778442-1 2642-71-9 86-590 1.000 1,000 500 1,000 10,000 500 1,000 100* 500 1,000 500 5004 500 500 100 500 10000 1,000 1,000 500 500 1,000* 500 100 500 500 100 100 2 Bacitracin Senzal chloride Benzenamine, 9(trifluoromethyi)- Benzana, l-(chloromethyl>4-NitroBenzenearsonic acid Benzenesuitoniy chloride Benzotrichloride Benzyl chloride Benzyl cyanide Bicydo(2.2.1]heptane-2-cartxjnitrile, 5-chlon>6-((((methylamino)Cartnyl)oxy)im Bix(chloromethyi) ketone Bitoscanate Boron trichloride Boron trifluoride Boron trifluoride compound with methyl ether (1:1) Bromadioicne Bromine Butadiene Butyl isovalerate Butyl vinyl ether 1405-874<a)5 9667-3 99166 109141 96095 9609-9* 9607-7 109447 149294 1527141-7 534076 4044699 10294345 7637-07-2 359424 28772-597 7729996 109990* 109-193* 111-342* 10,000 500 500 500 2 10,000 100 500 1,000 500 2 500 500 500 1,000 100 500 10,000 10,000 10,000 SL 085384 A-1 OSHA Notice CPL 2-2 n.SEP 2 fi 1987, . Directorate of Field Operations Appendix A List of Extremely Harzardous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) C.l. basic green i Cadnfium oxide Cadmium stearate Calcium arsenate Camphechtor Canthandin Carbachol chlonde Cartoamic acid, methyl-,0-(((2,4-Dimethyt-l, 3-Dithiolarv2-yl)Methylene)Amino)- Carbofuran Carbon disulfide Carbophenothion Carvone Chlordane Chlorfenvinfos Chlorine Chlormephos Chlormequat chloride Chloroacetaldehyde Chioracetic acid Chloroethanot Chloroethyl chloroformate Chloroform Chloromethyl ether Chloromethyl methyl ether Chlorophacinone Chloroxuron Chlorthiophos Chromic chloride Cobalt Cobalt carbonyl Cobalt, (^^l^-ethanediylbis (nitrilomethylidyne))bis(6-fluorophenolato)K2) Colchicine Coumafuryl Coumaphos Coumatetralyl Cresol,oCrimidine Crotonaldehyde Crotonaldehyde, (E)Cyanogen bromide Cyanogen iodide Cyanophos Cyanuric fluoride Cycloheximide Cyclohexylamine Cyclopentane Decaborane (14) Demeton Demeton-s-methyl DiaMos SL 085365 633-03-45 1306-19-0 2223-93-0 7778-44-1 8001-35-2 56-25-7 51-63-2 26419-73-9 1563-66-2 75-15-10 788186 2244-16-8* 57-74-9 470-90-5 7782-50-5 24934-91-6 999-81-5 107-20-05 79-11-8 107-07-3 627-11-2 67-88-3 542-88-1 107-30-2 3691-35-8 1982-47-4 21923-23-9 10025-73-7 7440-484* 10210-681 62207-785 64888 117-52-2* 5872-4 583829-3 95-487 535-887 4170-30-3 123-73-9 OUvwv 508785 2638282 67814-9 6881-9 10891-8 287-92-3* 17702-41-9 8065-483 918888 10311-84-9 10,000 100 1000* 500 500 100 500 100 2 10000 500 10000 1000 500 100 500 1000 10000 100 500 1,000 10000 1,000 100* 100 500 1000 2 10,000 100 100 100 10,000 100 500 1000 100 1000 1000 500 1,000 1000 100 100 10,000 10,000 500 500 500 100 1 t A*2 OSHA Notice CEL 2-2 SEP 2 8 1987 Directorate of Field Operations Appendix A List of Extremely Harzardous Substances List 1--Continued Chemical Abstract Service Number Threshold Quantity (Pounds) Oiborane Dibutyl phthalate Dichlorobenzaltonium chloride Dichloroethyl ether Dichloromethylphenylsilane Dichlorvos Dicrotophos Diepoxybutane Diethyl chlorophosphate Diethyl-p-phenylenediamine Diethyicarbamazine citrate Digitoxin Diglycidyl ether Digoxin Dimefox Dimethoate Dimethyl phosphorochloridothioate Dimethyl phthalate Dimethyl sulfate Dimethyl sulfide Dimethyl-p-phenylenediamine Dimethyldichlorosilane Dimethyldrazine Dimetilan Dinitrocresol Dinoseb Dinoterb Diotyl phthalate Dioxathion Dioxolane Diphacinone Diphosphcramide. octamethyl* Disulfoton Dithiazanine iodide Dithiobiuret Emetine, dihydrochloride Endosulfan Endothion Endrin Epichlorohydrin EPN Ergocalciferol Ergotamine tartrate Ethanesulfonyl chloride, 2-chloroEthanol, 1,2-dichloro-, acetate Ethion Ethoprophos Ethyl thiocyanate Ethylbis(2-chloroethyl)amine Ethylene fluorohydhn 19207-45-7 84-74*2* 8023-53-8* 111-44-4 149-74-6 62-73-7 141-66-2 1464-53-5 814-49-3 93-05-0* 1642-54-2 71-63-6 2238-07-5 20830-75-5 115-264 60-51-5 2524-03-0 131-11-3* 77-78-1 75-18-3 99-98-9 75-78-5 57-14-7 644-64-4 534-52-1 88-85-7 142007-1 117-64-0* 78-34-2 646-060* 82-66-6 152-169 298-044 514-73-8 541-53-7 31642-7 115-29-7 277604-3 72-20-8 106868 2104-64-5 50-14-6 376763 1622-32-8 10140-67-1 563-12-2 1319448-4 542-90-5 53607-6 371-62-0 100 10,000 10,000 10,000 1,000 1,000 100 500 1,000 10,000 100 10O3 1000 100 500 500 500 10000 500 100 2 10,000 1,000 500 2 100 500 10,000 500 10,000 2 100 500 500 100 1,000 2 500 500 1,000 100 1.0003 500 500 1,000 1,000 1,000 10,000 10,000 23 A-3 SL 085386 0WsW2'2 Directorate of Field Operations Appendix A List of Extremely Hazardous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Ethylene oxide Ethyienediamme Ethyieneimine Ethylmercunc phosphate Fenamiphos Fenitrcthion Fensulfothion Flu netil Fluonne Fluoroacetamide Fluoroacetic acid Fluoroacetyt chloride Fluorouracil Fonofus Formaldehyde Formaldehyde cyanohydrin Formetanate Formothion Formparanate Fosthietan Fuberidazoie Furan Gallium trichloride Hexachlorocyclopentadiene Hexachloronaphthalene Hexamethylenediamine, N.N^dibutyl* Hydrazine Hydrocyanic acid Hydrogen chloride Hydrogen fluoride Hydrogen peroxide (concentration greater than 52%) Hydrogen selemde Hydrogen sulfide Hydroquinone Indomethacin Indium tetrachloride Iron, PentacarbonyiIsobenzan Isobutyronitrile Isoncyanic acid, 3,4-dichlorophenyi ester Isodrin Isofluorphate Isophorone diisocyanate Isopropyl chloroformate Isopropyl formate Isopropylmethylpyrazolyl dimethylcarbamate 75-21-8 107-15-3 151-564 2235-25-8* 22224-92-6 122-14-5 115-90-2 4301-50-2 7782-41-4 640-19-7 144-49-0 35906-8 51-21-8 944-22-9 50000 107-16-4 23422-53-9 254002-1 17702-57-7 2154002-3 3878-19-1 110009 13450903 77-47-4 1335-57-1* 4835-114 30201-2 74-908 7647010 7664-39-3 7722-84-1 778307*5 7783064 123-31-9 53-86-1* 10025-97-5* 13463406* 297-78-9 70820 102-36-3 465-706 55-914 409071-9 100230 625-55-8 110380 1,000 10,000 500 10,000 2 500 1000 100 100 2* 2 2s 500 500 500 10(000 100 100 100 500 100 500 500 500 10000 500 1000 100 500 100 1000 5<X 500 10000 10000 100 100 10000 500 100 1003 1003 1000 500 500 Si 085387 wmr 2-2 Directorate of Field Operations Appendix A List of Extremely Harzard ue Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Lactonitnle Leptophos Lewisite Lindane Lithium hydride Maiononitrile Manganese, tricarbonyl methylcyclopentadienyl Mechlorethamine Mephosfolan Mercuric acetate Mercuric chloride Mercuric oxide Mesitylene Methacrdein diacetate Methacrytic anhydride Methacrytonitrile Methacrytoyl chloride Methacrytoytaxyethyi isocyanate Methamidophos Methanesulfonyi fluoride Methidathion Methiocart Methomyl Methoxyethylmercuric acetate Methyl 2-chloroacryiate Methyl bromide Methyl chlorotormate Methyl disulfide Methyl isocyanate Methyl isothiocyanate Methyl mercaptan Methyl phenkapton Methyl phosphoric dichloride Methyl thiocyanate Methyl vinyl ketone Methylhydrazine Methylmercuric dicyanamide Methyitrichlorosilane Metolcarh Mevinphos Mexacarbate Mitomycin C Monocrotophos Muscimol Mustard gas Nickel Nickel carbonyl Nicotine Nicotine sulfate 78*97-7 21609-90-5 541-25-3 58-89-9 7580-67-8 109-77-3 12108-13-3 51-75-2 950-10-7 1600-27-7 7487-94-7 21908-53-2 108-67-85 10476-956 760-93-0 126-98-7 92046-7 30674-80-7 10265-926 658-256 950-376 203265-7 16752-775 151-38-2 8063-7 7463-9 79-22-1 624-926 62463-9 556616 74-93-1 3735-23-7 676-97-1 55664-9 78-944 60-344 502-396 75-796 112941-5 7786-34-7 315-184 5067-7 6923-224 2763-964 50560-2 7440626s 13463-396 54-11-5 65-30-5 1,000 500 23 1000 100(b)4 500 10000 23 500 500 500 500 10000 1000 500 10000 100 500 100 1000 500 500 100 500 500 1000 10000 100 500 5004 500 500 1004 10000 2 500 500 10000 100 500 500 500 2 500 1,000 10,000 Any3 1003 100 A-5 SL 085388 OSHA Notice CPL 2-2 SEP 2 8 1987 Directorate of Field Operations Appendix A List of Extremely Hazardous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Nitnc acid Nitric oxide Nitrobenzene Nitrocyclohexane Nitrogen dioxide Nitrosodimethytamine Norbormide 7697-37*2 10102-43-9 98-95-3 1122-60*7 10102*44-0 62-75-9 991-42-4 1,000 1003 10,000 500 100 500 100 Organorhodium complex (PMN-82-147) Orotic acid Osmium tetroxide Ouabain Oxamyl Oxetane, 3,3-bis(chloromethyl)Oxydisulfoton Ozone 0 65-86-15 20816*12-0* 630-60-4 23135-22-0 78-71-7 2497*07-6 10028-15-6 2 10000 10,000 1003 100 500 1000 100 Paraquat Paraquat methosutfate Parathion Parathion-methyi Paris green Perttaborane Pentachtoroethane Pentachtorophenot Pentadecyiamine Peracetic acid Perchloromethylmercaptan Phenol Phenol, 2,2:thiObis(4r6-dichloroPhenol, 2,2:thiobs{4-chloro-6-methyiPhenol, 3^1-methyiethyi)-, methytcarbamate Phenoxarsine, 1Q,106xydiPhenyt dichioroarsine Phenythydrazine hydrochloride Phenylmercury acetate Phenyisilatrane Phenytthiourea Phorate Phosacetim Phosfolan Phosgene Phosmet Phosphamidon Phosphine Phosphonothioic acid, methyl-,O-ethyl 0-(4-(methytthio)phenyl) ester Phosphonothioic add, methyl*,S-(2-{bis(l-methylethy1)amino)ethyl) O-ethyi ester Phosphonotiolc add, methyt-,0-(4-nrtrophenyt) O-phenyl ester Phosphoric add, dimethyl 4-{methytthio) phenyl ester Phosphorous trichloride Phosphorus 191042-5 2074-50-2 56-38-2 298-00-0 12002-03-8 19624-22-7 7801-7* 8766-5* 2570-26-5 79-21-0 594-42-3 108-95-2 97-18-7 4418660 64006 56366 696266 59661 62-364 2097-196 103665 29602-2 410414-7 94762-4 7644-5 732*116 13171-216 780651-2 2706161 50782669 2666367 3254665 771612-2 7726146 2 2 1003 1003 500 500 10000 10000 100 500 500 500 100 100 500 500 1,000 1000 500 500 100 2 100 100 2* 2 100 500 500 100 500 500 1,000 500* c A-6 SL SS389 WW2'2 Directorate of Field Operations Appendix A List of Extremely Harzardous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Phosphorus oxychloride Phosphorus pentachloride Phosphorus pentoxide Phylloquinone Physostigmlne Physostigmine, salicylate (1:1) Picrotoxin Piperidine Piprotal Pinmifos-ethy) Platinous chloride Platinum tetrachloride Potassium arsenite Potassium cyanide Potassium silver cyanide Promecarb Propargyl bromide Propioiadone, beta- Propionitrile Propionitrile, 3-chloroPropyl chloroformate Propylene glycol, ally! ether Propylene oxide Propyleneimine Prothoate Pseudocumene Pyrene Pyridine, 2-methyl*5-vinylPyridine, 4*amino Pyridine, 4-nitro-, 1-oxide Pyrimmi! 10025-87-3 10026-13-8 1314-56-3 84-80-0* 57-47-6 57-64-7 124-87-8 110-89-4 5281-13-0 23505-41-1 10025-65-7* 13454-96-1* 124-50-2 151-50-8 506-61-6 2631-37-0 106-96-7 57-57-6 107-12-0 542-76-7 109-61-5 1331-17-5* 75-56-9 75-55-8 2275-18-5 95-63-6* 129-00-0 140-76-1 504-24-5 1124-33-0 53556-25-1 500 5Q04 24 10,000 100 100 500 1,000 100 1,000 10,000 10,000 500 1004 5004 1000 2 500 500 1000 500 10,000 10,000 10000 100 10000 1,00* 500 100 500 1000 Rhodium trichloride 1004907-7* 10000 Salcomine Sarin Selenium oxychloride Selenous acid Semicarbazide hydrochloride Silane, (4-aminobutyl)diethoxyrnethyl- Sodium anthraquinone-1-suHonate Sodium arsenate Sodium arsenite Sodium a2ide (Na(N3)) Sodium cacodyiate Sodium cyanide (Na(CN)) Sodium fluoroacetate Sodium pentacyhlorophenate Sodium selenate Sodium selenite Sodium tellurite 14167-18-1 107-44-8 7791-23-3 7738-096 563-41-7 3037-72-7 128-56-3* 7631-89-2 7784-46-5 26626-22-8 124-65-2 143-33-9 62-74-8 131-52-2 1341901-0 10102-18-6 10102-292 500 2* 500 1000 1000 1000 10000 1000 500 100 100 1004 2 100 100 500 500 A-7 SL 085390 ! OSHA Notice CEL 2-2 SEP 2 B 1987 Directorate of Field Operations Appendix A List of Extremely Hazardous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Strychnine Strychnine, sulfate Suifotep Sollaxide. 3-chloropropyl octyl Sulfur dioxide Sulfur tetrafluoride Sulfur trioxide Sulfuric acid 57-24-9 6041*3 3689-24-5 3569-57-1 7446-09-5 7783-600 7446-11-9 7664-93-9 1003 100 500 500 500 100 10O4 1,000 Tabun Tellurium Tellurium hexafluoride Tepp T rbufbs Tetraethyllead Tetraethyttin Tetramethyi lead Tetranitromethane Thallic oxide Thallium sulfate Thailous carbonate Thailous chloride Thalious malonate Thailous sulfate Thiocarbazide Thiocyanic acid, 2-(benxothiazolythio)methyi ester Thiofanox Thiometon Thionazin Thiophenol Thiosemicarbazide Thiourea, (2-chlorophenyl)Thiourea, (2-methylphenyl)* Titanium tetrachloride Toluene 2,4-diisocyanate Toluene 2.6-diisocyanate Trans-i ,4-dichlorobutene Triamiphos Triazofos TMchtoro(chloromethyl)silane Trichloro(dichlorophenyl)silane Trichioroacetyl chloride Trichloroethyteiiane Trichloronale Trichlorophenylsilane Trichlorophon Triethoxysilane Trimethylchlofosilane Trimethylolpropane phosphite Trimethyttin chloride Triphenyttin chloride 77-81-6 13494-80-9 7783-80-4 107-49-3 13071-79-9 78-00-2 597-64-8 75-74-1 509-14-8 1314-32-5* 10031-59-1 6533-73-9 7791-12-0 2757-18-8 7446-18-6 2231-574 21564-17-0* 39196-184 640-15-3* 297-97-2 108-98-5 79-19-6 5344-82-1 61478-8 7550450 546-849 91-08-7 110576 1031476 24017476 1558-254 27137-855 76-02-8 11521*9 327-98-0 95155 52-656* 995301 75774 82411-3 1065451 635557 2* 500 2 100 500 1003 100* 1003 500 10000 100 1003 1003 1003 100 1000 10,000 100 10000 500 500 100 100 500 100 500 100 500 500 500 100 500 500 10,000 1,000 2 10000 500 1,000 500 500 500 A-8 SL 085391 1 2-2 Directorate of Field Operati ns Appendix A List of Extremely Harzsrdous Substances List 1--Continued Chemical name Chemical Abstract Service Number Threshold Quantity (Pounds) Tris(2-chloroethyl)amine Valinomycin Vanadium pentoxide Vinyl acetate monomer Vinylnortiomene Warfarin Warfarin sodium Xyiylene dichloride Zinc phosphide Zinc, dichloro(4,4-dimethyl-5((((methylamino)cartoonyl)oxy)imino)pentanenitnle) 555-77-1 2001-95-8 1314-62*1 108-05-4 3048-64-45 81-81-2 129-06-6 28347-13-9 1314-84-7 58270-08-9 1,000 1.0003 1004 1,000 10,000 500 1,000 100 500* 100 1 Statutory reportable quantity tor purposes of emergency notification under SARA Motion 304(a)(2). 2indicates mat me reportable quantity is suOtect to cnange wnen the assessment of potential carcinogenicity andtor chrome toxicity a completed. *The calculated threshold quantity changed after technical review as desenbed in the text 4This material is a reactive solid The threshold planning quantity will not Become 10500 pounds tor the non-powder form _______ *Thi$ chemical is proposed tor deletion from list Threshold planning quantity is in me interim assigned to the category kaweM concern. 10500 pounds. The statutory one-pound reportable quantity tor methyl isocyanate under CERCLA section 102(b) may be adjusted in a future rulemaking action A-9 Si 8S392 28 1987 Direccorate of Field Operations Appendix A Additional Hazardous Chemicals List 2 Acetaldehyde Acetyl Peroxide Acetylene Allene Ammonium Azide Ammonium Perchlorate Chemical Name Benzoyl Peroxide 3-Bromcpropyne 1,2-Butadiene Butadiene, Inhibited Butane Mixed 2-Butanone Peroxide Buten-3-Yne 1-Butene 2-Butyne Calcium Carbide Carbon Monoxide Carbonyl Sulfide Cis-2-Butene Collodion Cumene Hydroperoxide Cyanogen Cyclobutane Cyclopropane Cyclotetramethylenetetranitramine Cyclotrimethylenetrinitramine Di-Tert-Butyl Peroxide Diazodinitrophenol Diborane Dichlorosilane Diethyleneglycol Dinitrate i,i-Difluoroethane Difluoromonochloroethane Diisopropyl Peroxydicarbonate Dimethyl Ether Dimethyl Sulfide Dimethylamine, Anhydrous 1>Dinitroglycerine Distearyl Peroxydicarbonate Ethane Ethane/Propane Mix Ethyl Chloride Ethyl Ether Ethyl Mercaptan Ethyl Nitrite Ethytamine Ethylene AA -14A0 Chemical Abstract Service Number 75-070 110-22-5 74-86-2 463-49-0 12164-94-2 7790-98-9 94-36-0 106-96-7 590-19-2 106-19-2 106-97-8 1338-23-4 78-80-8 106-98-9 503-17-3 75-20-7 630060 463-58-1 590-18-1 9004-700 80-15-9 460-19-5 287-230 75-19-4 2691-41-0 121-82-4 11005-4 87-310 19287-45-7 4109-960 693210 75-37-6 7508-3 105040 113100 73133 623070 52326060 74040 73000 60-237 73031 103935 7304-7 74031 853g3 I wr#2-2 Directorate of Field Operations Appendix A Additional Hazardous Chemicals List 2 -- (Continued) Chemical Name Ethylene Glycol Dinitrate Ethylene Oxide Formaldehyde Gas Furan Hydrocarbon Mixture A-24 (R) Hydrocarbon Propellant Hydrocarbon Propellant-Butane Mixture Hydrocarbon Propellant-Propane Mixture Hydrogen Hydrogen Cyanide, Anhydrous, Stabilized Hydrogen Sulfide tsobutane Isobutane-Butane Blend Isobutene Isopentane Isoprene Isopropyl Chloride Isopropylamine Lead Nitroresorcinate Lead Styphanate Lithium Hydride M-Nitrotoiuene Mannitol, Hexanitrate Methane. Compressed Methane. Refrigerated Liquid (Cyrogenic Liquid) Methyl Acetylene Methyl Chloride Methyl Formate Methyl Mercaptan Methyl Nitrate 2-Methyl-1-8utene Methylamine, Anhydrous Methylamine, Anhydrous Methyl Cyclopropane N-Butane N-ButyM, 4-Di<Tert-Butyl Peroxy) Valerate N-Propyt Nitrate Naphtha Neopentane Nictel Nitrogen Triiodide Nitroglycerin Nitrostarch, Dry Nitrostarch, Wet O-Nitrotoluene A-11 Chemical Abstract Service Number 628-96-6 75-21-8 50-00-0 11000-9 Unassigned 1333-74-0 74-90-0 7783-06-4 75-28-5 115-11-7 78-78-4 78-79-5 75-29-6 75-31-0 51317-24-9 15245-44-0 758067-8 99-08-1 15825-70-4 74-82-8 74-82-8 74-99-7 74-87-3 107-31-3 74-93-1 598-58-3 58346-2 74-89-5 74-89-5 594-11-6 106-97-8 995-33-5 627*134 8002-05-9 463-82-1 744002-05 13444654 55-680 9056-38-6 9056366 86-72-2 Si aS3s 4 oswm2;2 Directorate of Field Operations Appendix A Additional Hazardous Chemicals List 2 -- (Continued) Chemical Name 1,3-Pentadiene Pentaerythritol Tetranitrate Pentane Phosphine Phosphorous Propane Propane-Isobutane Blend Propane (15.7%)-lsobutane Blend Propane (43.6%Hsobutane Blend Propane, Refrigerated Liquid (Chryogenic Liquid) Propylene Propylene Oxide Reformate Naphtha Silane Tert-Butyl Hydroperoxide Tert-Butyl Peroxyacetate Tert-Butyl Peroxybenzoate Tert-Butyl Peroxypivalate Tert-Butylamine Tetrafluorethylene Trans-2-Butene Trichlorosilane Trifluorochloroethylene Trimethylamine Trinitrobenzoic Acid, Dry Trinitrobenzoic Acid, Wet Trinttroresoreinol Trinitrotoluene, Wet Vinyl Chloride Vinyl Ethyl Ether Vinyl Fluoride Vinyl Isopropyl Ether Vinyl Methyl Ether Vinytidine Chloride Zirconium Metal, Dry Zirconium Scrap Chemical Abstract Service Number 504-60-9 78-11-5 109-66-0 7803-51-2 7723-14-0 74-98-6 74-98-6 115-07-1 75-56-9 68955-35-1 7803-62-5 75-91-2 107-71-1 614-45-9 927-07-1 75-64-9 116-14-3 624-64-6 10025-78-2 79-38-9 75-50-3 129-66-6 129-66-8 62*71-3 118-96-7 75-01-4 109-92-2 75-02-6 926-65-8 107-25-5 75-35-4 7440-67-7 7440-67-7 I A-12 SL 085395 CHEMICALS INTEROFFICE / LAKE CHARLES TO FROM Tom Brown R. J. McCorquodalg-^P^"'' DATE SUBJECT July 6, 1988 OSHA Compliance Inspection 6/21/88 - 6/24/88 The attached write-up, by Jon Shepherd, of the recent OSHA inspection, summarizes the activities of the four days. Jon did an excellent job with the write-up, plus he did a thoroughly professional job of coordinating the inspection. As Jon stated, two inspections were made. The first, Industrial Hygiene, dealt with our Industrial Hygiene/Medical Programs for Chlor/Alkali, The cooperation and participation of all employees involved contributed to our receiving high praise from the Compliance Officer. He (Compliance Officer) stated that although we had some problems, it was obvious to him that we had a sound program and we were willing to work together (Management & Union) to resolve them. The second, Systems Safety, dealt with our ability to prevent and respond to a Bhopal type incident. Our Management representatives (listed in Jon's write-up) were both knowledgeable and professional in their discussions. This, along with the updated Emergency Procedures Manual, indicated to the Compliance Officer that our efforts were aimed at prevention of a major release, but if one occurred we were ready to respond. The Compliance Officer stated that his written evaluation of our Systems Safety would reflect, in his opinion, that our program was sound. The written evaluation of our Emergency Program (Systems Safety) will be given to the Area Director (OSHA) who will write an evaluation "of his own. Both evaluations will be submitted to the Dallas Office (OSHA) along with all other evaluations (inspections) made from this region. Dallas will then decide which locations to select for a detailed follow-up inspection. Based on comments from the Compliance Officer, we are not likely to be a selected location. RJM/fb cc: Harry Hank John Fike Jim Meadows Fred Rau Chuck Bellon Gerry Jordan Roger Corley SL 085396