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m. .crivaro '"tANCASTER'fWORKS CONFIDENTIAL RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1985 JULY 18 Members Present: L. M. Crivaro, J. M. Guitas, R. E. Jacobson, `D._E;- Kendall, and B. C. Payne Absent: A. P. Biltheiser and J. K. Sellers HAZARD COMMUNICATION STANDARD A. Inspection and survey of work place. The chemical inventory is nearly com plete for Precison Products and the Closure area. B. In-house labeling. We have reviewed our requirements and this information was given to the Pittsburgh Hazardous Materials Committee in order to esti mate quantity and types of labels required for Lancaster. We did not include the materials used in the aluminum finishing operations. C. Employee training. We intend to use the video tapes that are currently being prepared by Pittsburgh! .7 D. Material Safety Data Sheets, We'will need to review all of the available data sheets for accuracy and completeness after all of the information from the work place survey has been collected. SLUDGE LAGOONS UPDATE We reviewed the status of this project. Currently we are preparing informa tion to be submitted to the Penna. DER for their review. We are tentatively considering going with Envirite Corp. of York, Penna. to remove the sludge. NON-HAZARDOUS WASTE MANIFEST (NHWM) Reference Gary Crouth slettet--of 1985 June 03 .__W__dirSctrSsed the necessity of the non-hazardous w^Ce^manifest-fQuns-Jrtvictr^fovide a 'tracking mechanism' of all waste shipment^ We will be using these forms on future waste shipments. PREPAREDNESS, PREVENTION AND CONTINGENCY PLAN We have completed the revisions of this book and it has been distributed with a copy to the Penna. DER. Pittsburgh Environmental Control has received a copy for their review. NOTE: We do need to consider incorporating some type of 'SIGN-UP SHEET' into the book which covers employee training. Randi Jacobson and Lou Crivaro will be handling this requirement. `4, K ALCOA ATC 0023937 sf-446) <cv t-ea) ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1985 JULY 25 PAGE 2 HEALTH MANAGEMENT SYSTEM - LANCASTER WORKS We will be working with this system which will be used to track our hazardous materials and industrial hygiene sampling in the work place. We plan to have all of the materials currently used at Lancaster into our inventory system by September, 1985. OILY WASTE (TRIMSOL) Most of this waste was picked up by a disposal firm; however, ve-.still need to handle those drums which are leaking. John Guitas and Anna' Biltheiser will handle. ASBESTOS During .the installation of air conditioning units in the Word Processing Cen ter, air ducts were required in the roof of Bldg. #2. Asbestos was suspected in the material being removed. This material was analyzed by Lancaster Labs on 1985 May 29 and found to contain no asbestos. TIGHT DUILDING SYNDROME fl A complaint from the Traffic/Invoice office was checked out. It involved 'stale air* being recirculated through the offices and causing some physical discomfort as reported by an employee. We checked Pittsburgh Industrial Hygiene and we followed their recommendations to check out the intake air and carbon dioxide levels. The results were satisfactory and this was communicat ed to the employees in that office.* l There was an F&DA spot inspection of the plant on 1985 June 19. The inspect ors did not tour the plant. They did ask specific questions and then left. A copy of their report is attached. EMPLOYEE TRAINING l are required on an ' annual Randi Jacobson to coordinate The next meeting of the Environmental Steering Committee will be held on 1985 October 10 in the Staff Conference Room at 9:00 A. M. L. M. CRIVARO c/ Attachment ATC 0023938 I ; I ' `r DEPARTMENT OF HEALTH AND HUMAN SERVICES PUBUC HEALTH SERVICE FOOO ANO DRUG ADMINISTRATION 1. DISTRICT AODRESS & PHONE NO. Li. ,S l-L-. Si1"' IV. --i >. t'c\ * C c- ^Vui .>> 2. NAME ANO TITLE OF INDIVIDUAL 3. DATE 4. FIRM NAME TO ALLtmiAiAtYi 6. NUM9E R ANO STREET . )/\C*' tn * "UJ rt. :t . c'r /hii/iii hf/t /.V !s\ //. ev ) 7 / ffync'/ S c 3 O i l: 57 rr^ z / Z7 crD ^(Ji/ /Ttrccf 7- CITY ANO STATE ZIP CODE /- V pjn. S. PHONE # a AREA COOE ______*/*/fC/iS7-rre PA /?er /------------------------------------------------ Notic* of Inspection is hereby given pursuant to Section 704(a)(1) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 374(a)]1 and/or Part F or G, Tide III of the Public Health Service Act (42 U.S.C. 262-26412 - m .TURE (Foodegd Drug Administration EmployeaM) !icti^eut ( - / // yrw- l Applicable pardons at Sscdon 704 end other Ssetions at the Fadani Food, Drag, and Cosmetic Act (21 U.S.C. 374] an quoted below: 10. TYPE OR PRINT NAME ANO TITLE (FDA Employee(s)) __l\ N'... "W.`. .-A\lv.lli<*K. o 2Applicable sections of Parts F and G of Title III Public Health Service Act (42 US C. 262-2641 ate quoted below: ISec. 704. (alii) For purposes of enforcement of this Chapter, officers or employees duly designated by the Secretary, upon presenting approp riate credentials and a written notice to the owner, operator, or agent in charge, an authorized (A) to enter, at reasonable times, any factory, warehouse, or establishment in which food, drugs, devices, or cosmet ics an manufactured, processed, packed, or held, for introduction into interstate commerce or after such introduction, or to enter any vehicle being used to transport or hold such food, drugs, devices, or cosmetics in interstate commerce; and 18) to inspect, at reasonable times and within reasonable limits and in a reasonable manner, such factory, warehouse, . establishment, or vehicle and all pertinent equipment, finished and unfinished materials, containers, and labeling therein. . In the case of any factory, warehouse, establishment, or consulting laboratory In . which prescription drugs or restricted devices are manufactured, processed, packed, or held, the inspection shall extend to all thimp therein (including records. Filet, papers. processes, controls, end facilities) bearing on whether prescription drugs or restricted devices which are adulterated or misbranded within the meaning of this Chapter, or which may not be manufactured, introduced into Interstate commerce, or sola, or offered for sale by reason of any provision of this Chapter, have been or are being manufactured, processed, pecked, transported, or held in any such place, or otherwise bearing on violation of this Chapter. No inspection authorized by the preceding sentence or by paragraph (3) shall extend to financial data, tales data other than shipment data, pricing data, personnel data (other then dels as fo Quehficsdons of technical end profession*! personnel performing functions subiect to this Act), and research data iother then data, relating to new drugs, antibiotic drugs and devices and. subject to reporting and Inspection under regulations lawfully issued pursuant to taction 5050) or (k). section 507(d) or (g). section 519, or 520(g). and data relating to other drugs or devices which in the case of a new drug would be sub ject to reporting or inspection under lawful regulations issuedpursuant to section 505(e) of the title. A tapereta notice shall be given for each such inspection, but a notice shed not be required for each entry made during the period covered by the inspection. Each such inspection shell be commenced end completed with reasonable promptness. Sac. 704(a) Every parson required under taction 619 or 520(gl to main tain records ana every person who Is in charge or custody of such records shall, upon request of an officer or employee designated by the Secretary, permit such officer or employee at all reasonable times to have access to end to copy and verify, such records. Section 612 (0(1) In the case of any new animal drug for which an approval of an application filed pursuant to subsection (b) is in effect, the applicant shall establish and maintain such records, and make such reports to the Secretary, of data relating to experience and other data or Information, received or otherwise obtained by such applicant with respect to such drug, or with respect to animal feeds bearing or con taining such drug, as the Secretary may by general regulation, or by order with respect to such application, prescribe on the basis of a finding that such records and reports ate necessary in order to enable the Secretary to determine, or facilitate a determination, whether there is or may be ground for invoking subsection le) or subsection (m)(4) of this section. Such regulation or order shall provide, where the Secretary deems it to be appropriate, for the examination, upon request, by the persons to whom such regulation or order is applicable, of similar in formation received or otherwise obtained by the Secretary. (21 Every person required under this subsection to maintain records, end every person in charge or custody thereof, shall, upon request of an officer or employee designated by the Secretary, permit such officer or employee at all reasonable times to have access to and copy and verify such records. , Part F Licensing -- Biological Products and Clinical Laboratories Sec. 351(c) "Any officer, agent, or employee of the Department of Health & Human Services, authorized by the Secretary for the purpose, may during all reasonable hours enter and inspect any establishment for the propagation or manufacture and preparation of any virus, serum, toxin, antitoxin, vaccine, blood, blood component or deriv ative,' allergenic product or other product aforesaid for tale, barter, or exchange in the District of Columbia, or to be sent, carried, or brought from any State or possession into any other State or possession or into . any foreign country, or from any foreign country into any State or possession." PartF-" `Control of Radiation. Sec. 360 Ala) "H the Secretary finds for good cause that the methods, tests, or programs related to electronic product radiation safety In a particular factory, warehouse, or establishment in which electronic products are manufactured or held, may not be adequate or reliable, officers or employees duly designated by the Secretary, upon presenting appropriate credentiab and a written notice to the owner, operator, or agent In charge, are thereafter authorized (1) to enter, at reasonable times any area in such factory, warehouse, or establishment in which the manufacturer's tests (or testing programs) required by section 358 (h) are carried out, and (2) to inspect, at reasonable times and within reasonable limits and in a reasonable manner, the facilities and proce dures within such area which are related to electronic product radiation safety. Each such Inspection shall be commenced end completed with reasonable promptness. In addition to other grounds upon which good cause may be found for purposes of this subsection, good cause will be considered to exist in any case where the manufacturer has introduced into commerce any electronic product which does not comply with an applicable standard prescribed under this tubpart and with respect to which no exemption from the notification requirements has been granted by the Secretary under section 359(a)(2) or 359(e)." (b) "Every manufacturer of electronic products shall establish and maintain such records (including testing records), make such reports, and provide such information, as the Secretary may reasonably require to enable him to determine whether such manufacturer has acted or is acting in compliance with this tubpart and standards prescribed pursu ant to this subpan and shall, upon request ol an officer or employee duly designated by the Secretary, permit such officer or employee to inspect appropriate books, papers, records, and documents relevant to deter mining whether such manufacturer has acted or is acting in compliance with standards prescribed pursuant to section 369(a)." (f) "The Secretary may by regulation (1) require dealers and distributors of electronic products, to which there are applicable stan dards prescribed under this subpart and the retail prices of which is not less than $50. to furnish manufacturers of such products such infor mation as may be necessary to identify end locate, for purposes of section 359, the first purchasers of such products for purposes other than resale, and (2) require manufacturers to preserve such information. FORM FDA 462 (5/65) PREVIOUS EOtTtON IS OBSOLETE (Continued On Reversal NOTICE OF INSPECTION . ATC 0023939 Any regulation establishing a requirement pursuant to dame It) of the preceding sentence shall (A) authorize such dealers and distributors to elect. In lieu of immediately furnishing such Information to the manu facturer to hold and preserve such Information until advised by the manufacturer or Secretary that such Information is needed by the manufacturer for purposes of taction 369, and IB) provide that the dealer or distributor shall, upon making such election, give prompt notice of such election /together with information identifying the noti/ier and the product) to the manufacturer and shall, when advised by the manufacturer or Secretary, of tha need therefor for the purposes of Section 359, Immediately furnish the manufacturer with the required information. If a dealer or distributor discontinues the dealing in or distribution of electronic products, he shall turn tha information over to the manufacturer. Any manufacturer receiving Information pursuant to this subsection concerning first purchasers of products for purposes other than resale shall treat it as confidential and may use it only if necessary for the purpose of notifying persons pursuant to section 359(e)." Sac. 360 B.(a) It shall be unlawfulill (2) (31 -for any person to fail or to refuse to establish or maintain records required by this subpart or to permit access by the Secretary or any of his duly authorized representatives to, or the copying of, such records, or to permit entry or inspection, as required or pursuant to section 360A." ** Part G -- Quarantine and Inspection See. 361 (a) "The Surgeon General, with the approval of the Secretary is authorized to make and enforce such regulations at In hit judgement are necessary to prevent the introduction, transmission, or spread of communicable diseases from foreign countries into the States or pos sessions, or from one State or possession into any other State or pos session. -For purposes of carrying out and enforcing such regulations, tha Surgeon Genarai may provide for such inspection, fumigation, disinfection, sanitation, pest extermination, destruction of animals or articles found to be so Infected or contaminated as to be sources of dangerous infection to human beings, and .other measures, as in his judgement may be necessary." ATC 0023940 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1985 JULY 25 DISTRIBUTION; A. P. Biltheiser, Lancaster Works J. M. Guitas, Lancaster Works R. E. Jacobson, Lancaster WCrks D. E. Kendall, R.N., Lancaster Works B. C. Payne, Lancaster Works J. K. Sellers, Lancaster Works P. R.~Atkins, Pittsburgh Office-7 " ' Joe Daraiano, Pittsburgh Office-6AB R. M. James, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 Info cc: R. S. Howell, Lancaster Works T. J. Leveque/J. Ciccarelli, Lancaster Works w. w. Kopetz, Lancaster Works J. R. Scifers/R. L. Dodson/R. Langoski, Lancaster Works ATC 0023941 FROM L* M* CRIVARC CONFIDENTIAL received to AFK 1 ^ 1984 PATRICK R. ATKINS MEMORANDUM 1984 APRIL 10 RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1984 APRIL 05 Members Present: Anna Biltheiser, L. M. Crivaro, R. H. Eckstein, J. M. Guitas F. D. Hereda and B. C, Payne Absent: D. E. Kendall and J. K. Sellers ANNUAL RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) TRAINING The sessions will be approximately one hour. They will include Unit Supervi sors; Operators from the Finishing Department, Mixing Room and Store Room; Truckers; and the Joint Safety Committee. The training will cover RCRA; Pre paredness, Prevention, and Contingency Plan (PPCP); Substantial Risk Plan? and Ground Hater Monitoring. HAZARDOUS MTERIALS CONTROL COMMITTEE He have received a memo dated 1984/02/21 regarding the establishment of this committee. This committee was dissolved during the OVA process; however, it was agreed that this committee's functions were necessary and, therefore, a formal committee has been re-established. OSHA CHEMICAL HAZARDOUS COMMUNICATION PROGRAM He acknowledge receipt of Mr. E. Rumberger's memo of 1984 February 24 caption ed, "OSHA Chemical Hazard Communication Standard." In view of the recent ypassage of OSHA regulations, concerning "Hazardous Communication," we need to emphasize proper control of hazardous materials through (1) chemical inven tory, (2) material safety data sheets (MSDS), and (3) written programs. Frank Hereda and Lou Crivaro will audit the plant to determine what areas need information where hazardous materials are used. Randi Eckstein has agreed to check other plants to see if there, are programs being used which we can eval uate. > INDUSTRIAL HYGIENE BULLETIN CONCERNING HEXAVALENT CHROMIUM & STAINLESS STEEL WELDING FUMES , There have been a number of references warning of the presence of hexavalent chromium fumes produced during the welding of stainless steels. In order to determine whether or not this possibility exists, John Guitas will conduct an inventory of the welding rods used. ASBESTOS NOTIFICATION FORMS Referencing Barry Clark's letter dated 1984 February 10, this form is to be used when notification is required during any demolition or renovation involv ing asbestos. He do not see any use for this form at this time with the type of renovation that is currently being done at Lancaster Works. ATC 0023942 0 ALCOA s.'.s.J l"'v ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1984 APRIL 10 PAGE 2 UPDATE ON FDA (FOOD & DRUG ADMINISTRATION) STATUS - POP This update concerns recently published information regarding the plasticizer, di (2 - Ethylhexyl) phthalate (DOP). Because there is evidence establishing a carcinogenic risk in using DOP, there is a concern that the FDA will continue to approve DOP's use as an approved food additive. Jack Sellers ha3 stated that DOP is the plasticizer used in PVC-111 and also in PVC-115. This status report lends added importance to the approval of A-307 liner material. INDUSTRIAL WATER USE SURVEY We have received a request from the Department of Environmental Resources (DER) to complete an industrial water use survey. The information being re quested in the survey includes water that we use in our plant operations as well as the quantity of water that we discharge into the stream and the Lan caster sanitary sewage system. INDUSTRIAL HYGIENE The Joint Safety Committee had requested industrial hygiene data regarding all of the personal monitor tests for substances that were tested at Lancaster Works. Test results were requested and have been received from the Alcoa Laboratories on all tests that were run within the last two years. Randi Eckstein has submitted these data to the Joint Safety Committee. Any ques tions regarding the data will be convered in their next meeting to be held during the last week of April. GROUND VATER MONITORING (GWM) A request for authorization covering the assessment program was approved on 84/02/06. Three additional wells have been installed and that work was com pleted on 1984 March 15. The ground water monitor sampling for first quarter, 1984, was completed on 1984 March 20. ENVIRONMENTAL CONCERN - ASBESTOS Insulation of piping.in the Boiler- House, Building 3, has been completed. The insulated steam pipes in Building 2 extending to the Closure lunch area have been covered with aluminum sheet. This work is continuing over the Closure lunch area extending north approximately 200 ft. to the Closure office. The remaining work .on this project is the piping located in the Finishing Depart ment. WASTE TREATMENT The flow meter required by the DER in order to receive a "Permit by Rule" status has been received. The Leeds and Northrup representative has been con tacted and the expected completion date on this project is 1984 April 30. ATC 0023943 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1984 APRIL 10 PAGE 3 WASTE OIL We still need to remind those supervisors and operators who are responsible for handling waste oil that all waste oil should be pumped into the storage tank^rahfi-vthan into 55 gallon drums. The only exception at this time is thre TrjcmSpl Waste. An engineering project for a storage dike specifically for Trim Sol waste is currently being designed. SOLVENT-WCSTE TANK Barry Payne has reported that the waste solvent storage tank located outside t the Mixing Room has been removed from the site. The next meeting of the Environmental Health Steering Committee will be held on Thursday, 1984 July 5, at 9 a.m. in the Staff Conference Room. L. M. CRIVARO c/ ATC 0023944 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1984 APRIL 10 DISTRIBUTION: Dr. T. C. Amend/D. Kendall, R.N., Lancaster Hocks A. P. Biltheiser, Lancaster Hocks R. H. Eckstein, Lancaster Borks J. M. Guitas, Lancaster Works F. D. Hereda, Lancaster Works B. C. Payne, Lancaster Works J. K. Sellers, Lancaster Works 1 P* R. Atkins, Pittsburgh Office-7 R. M. James, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 Info cc: R. S. Howell, Lancaster Works T. J. Leveque/J. Ciccarelli, Lancaster Works J. W. Martin, Lancaster Works J. R. Scifers/R. L. Dodson/R. Langoski, Lancaster Works ATC 0023945 FROM L. M. CRIVARO CONFIDENTIAL Kn.Cc.IV tL> jt'iv l 1984 PATRICK R. ATV',M~ TO MEMORANDUM 1984 JANUARY 10 RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1984 JANUARY 05 Members Present: Anna Biltheiser, L. M. Crivaro, R. H. Eckstein, J. M. Guitas D. E. Kendall and B. C. Payne Absent: F. D. Hereda and J. K. Sellers MEDICAL There were no medical problems reported in the last quarter of 1983. INDUSTRIAL HYGIENE PROGRAM We discusspd"the prografifand it was agreed that tighter controls aren^eded in the area of material identification and material safety data sheets. JPe still lack the to screen all materials --use--in Llie plant. One suggestion was made to determine if a computerized list could be developed, which would check all purchase orders for any new materials being ordered. Lou Crivaro to check with Gary Kallmeyer. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) - ANNUAL TRAINING Randi Eckstein has agreed to receive and review the material which will in clude RCRA, Industrial Hygiene and Environmental concerns. TOXIC SUBSTANCES AND CONTROL ACT (TSCA) - FINAL RULE 8(c) Reference memos dated 1983 December 08 and 15. The Act gives all employees the responsibility of reporting certain information pertaining to the manufac ture or use of chemical substances. The reporting of substantial risk infor mation is mandatory. Randi Eckstein to handle. The notice will be posted. ENVIRONMENTAL EVENTS & PROCEDURE REPORT We acknowledge receipt of Mr. R. F. Kohm's memo dated 83/12/19 regarding Environmental Events and Procedures Report. This system will basically be used to track and report environmental events and administrative procedures. Among the events which will be tracked include those which have the potential to result in fines, civil penalties, litigation or signifcant environmental damage. GROUND WATER MONITORING John Guitas reviewed the status of our Assessment and Abatement Program. request for authorization has been submitted to Pittsburgh. The total estimated to implement this program is $105,000. The cost ATC 0023946 0 ALCOA <ev M-ee) environmental health steering committee meeting 1984 JANUARY 10 PAGE 2 ENVIRONMENTAL 1. We have received notice from the DER that they have issued our NPDES Permit. It will be finalized after publication in the Pennsylvania Bulletin. 2. Hie DER has" conducted a preliminary review of our Part B Permit application. A technical review of the application will begin after we have submitted a waste analysis plan. They will report status of the application after the technical review is completed. O /V 3 In considering the possibility of removing the waste from the older sludge lagoon, we contracted on a trial basis the Envirite Carp, of York, Pennsyl vania to remove approximately 25,000 lbs. of the waste sludge in November, 1983. 4. Barry Payne reported that the solvent storage tank stored on-sight will be disposed of by Continental Vanguard, Inc. of Bellmawr, New Jersey. The re moval is scheduled for mid January, 1984. INDUSTRIAL HYGIENE In November, 1983, in the snack area of the Metal Decorating area of the Clo sure Department, small particles of insulating material from overhead steam pipes fell onto the lunch table when the heat was turned on. An hourly em ployee complained that the material could be a health hazard. The Maintenance Department corrected the problem temporarily to prevent additional material from falling. A permanent solution is to wrap the pipes with aluminum sheet. This will begin in approximately three weeks and will take three months to complete. The next meeting of the Environmental Health Steering Committee will be held on Thursday, 1984 April 05 at 9:00 A. M. in the Staff Conference Room. / L. M. CRIVARO c/ ATC 0023947 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1984 JANUARY 10 DISTRIBUTION: Dr. T. C. Amend/D. Kendall, R.N., Lancaster Works A. P. Biltheiser, Lancaster Works R. H. Eckstein, Lancaster Works J. M. Guitas, Lancaster Works F.D. Hereda, Lancaster Works B. C. Payne, Lancaster Works J. K. Sellers, Lancaster Works VP. R. .Atkins, Pittsburgh Office--7 R. M. Janes, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 E, E,, Rumberger/T. B. Bonney, Pittsburgh Office-7 info cc: R. S. Howell, Lancaster Works T. J. Leveque/J. Ciccarelli, Lancaster Works J. W. Martin, Lancaster Works J. R. Scifers/R. L. Dodson/R. Langoski, Lancaster Works ATC 0023948 FROM L. M. CRIVARO CONFIDENTIAL RECEIVED OCT 2 4 1983 TO PATRICK R. ATKINS MEMORANDUM ^ ~f/? 0^/XA- 1983/OCTOBER 2 received OCT 251983 RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1983 OCTOBER 13 _Arr & Solid Waste Members Present: Anna Biltheiser, L. M. Cvlvaro, R. H. Eckstein, J. M. Guitas F. D. Hereda, B. C. Payirfe Absent: J. K. Sellers INDUSTRIAL HYGIENE PROGRAM: The Committee has been assigned to/review the revised program. The policy and objective statement has been approved by the Staff and the Committee and will be posted. Proposals to communicating this program to all Lancaster employees were discussed and it was agreed to use the Joint Safety Oommittee, Depart mental Meetings, or Department Safety Meetings. Randy Eckstein recommended/That the Plant Nurse, Ms. Kendall, be included in the Committee. She now cxmducts dosimeter and noise level studies and her in put is important. The Committee agreed and we request that Ms. Kendall attend future meeting Lu^14\ :ed on September 30 by the DER and several areas of concern were uncovered. We were working with Pittsburgh Environmental to obtain a final determination of the Clarifier skim waste with respect to hazardous waste. An analysis of a composite sample will be made and a resolu tion in getting the waste off site to meet the 90 day storage rule will be made if the waste is deemed hazardous. The solvent storage tank, which con tains a thick sludge, must be cleaned out because we are on record with the DER that this tank is no longer used to store solvent waste. Barry Payne is working on this item. We need to insure that weekly inspection reports of the outside area, the concrete storage pad, and the drum storage area cure submit ted. NOTE: All "waste oil" must not be stored in 55 gallon drums. All waste oil is to be pumped into the appropriate storage tanks available. We also note that deposit drums have been used to store various waste. Because these drums are returned to the vendor, they are not to be reused. All deposit drums must be placed in the designated area. All trucks moving deposit drums outside are to be so instructed. Finally, caustic and acid waste do not need a hazardous waste label. Because this waste is covered under a Module I by the DER, it is not required to use the hazardous waste labels. Anna Biltheiser will check into the DOT requirements in hauling the waste to the landfill site. REGARDING EMPLOYEE'S NOTIFICATION OF PERSONAL TEST RESULTS: We have drafted a form letter to be used when they have been notified, This form will be filed in the employee's personnel file. ATC 0023949 ALCOA SF-49 (REV ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1983 October 21 Page 2 POLYCHLORINATED BIPHENYLS (BCP'S): The ongoing effort to dispose of four drums of hydraulic fluid contaminated with PCB's, two drums of water collected during the cleanout of the furnace, and two drums of rags, paper, etc. has failed to locate a contractor to dis pose of the waste. We are currently working with two contractors in order to meet the 1983 December 31 deadline. OBSOLETE MATERIAL: There are drums of various material which are no longer being used in the plant and in storage. Barry Payne is working to have this material returned to the vendor, where possible. ASBESTOS CONCERN: Because of recent complaints regarding the presence of insulated material con taining asbestos, which falls from the heating pipes in the ceiling, the Engi neering Department is requesting a quote to cover the insulating pipes with aluminum in the Closure and Finishing (Ransohoff Dryer) areas. HEARING CONSERVATION: John Guitas has ordered a video cassette from the Aluminum Association. This has been recommended by the Pittsburgh Industrial Hygiene Department. The program will satisfy OSHA requirements for hearing conservation training and will be used in 1984. WASTE TREATMENT: A flow meter for the rinse acid line going into the lift station is on order with an expected delivery of 12 to 14 weeks. This flow meter is required by the DER. A new flow meter for outfall 005, polishing lagoon, is on order and delivery is expected within 6 to 8 weeks. ASBESTOS DISPOSAL PROBLEM: It was learned that the Lancaster Area Landfill Authority does not take asbes tos material waste. In the future, all asbestos waste will be placed in plas tic bags, then placed in steel drums and identified with the proper labels. This material will then be shipped to the Lanchester Landfill, an approved disposal site. The asbestos removal procedure will be revised to include this new practice. A shipping manifest is required and the landfill site will be supplying these to us. * \ ATC 0023950 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1983 October 21 Page 3 SLUDGE LAGOON: We are currently working with two contractors to get rid of the sludge in the sludge lagoon. The old sludge lagoon has been sampled by one of the contract ors for analysis to see if they can handle the waste. GROUND WATER QUALITY ASSESSMENT PROGRAM: We have received an assessment program from our contractor, Wright Associates, dated 1983 October 05. We are currently reviewing the program and a copy has been sent to Pittsburgh Environmental Engineering. This program essentially covers a sampling program, including new monitor wills, hydraulic testing, an assessment of the contamination and submission to the DER. S'f _ A John Guitas is planning to attend the Industrial Hygiene and Environmental Conference, in Pittsburgh on October 31 to November 03. The next meeting of the Environmental Health Steering Committee will be held on Thursday, 1984 January 5 at 9 a.m. in the Staff Conference Room. L. M. CRIVARO c/ ATC 0023951 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1983 October 21 DISTRIBUTION: Dr. T. C. Amend, Lancaster Works A. P. Biltheiser, Lancaster Works R. H. Eckstein, Lancaster Works J. M. Guitas, Lancaster Works F. D. Hereda, Lancaster Works B. C. Payne, Lancaster Works J. K. Sellers, Lancaster works P. R. Atkins, Pittsburgh Office-7 R. M. James, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 info cc: R. S. Howell, Lancaster Works T. J. Leveque/J. C. Rebert, Lancaster Works J. W. Martin, Lancaster Works J. R. Scifers/R. L. Dodson/R. Langoski, Lancaster Works ATC 0023952 r'RG" L. M. CRIYARO TO MEMORANDUM CONFIDENTIAL 1982 MARCH 11 RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1932 MARCH 04 Members Present: L. M. Crivaro, R. H. Eckstein, F. D. Hereda, 3. C. Payne, S. W. Rudy, J. K. Sellers Members Absent: Dr, T. Amend, J. M. Guitas MEDICAL: 1. There were no medical problems in February. 2. Men's Shower Room - As a result of the last inspection by Randi Eckstein and a member of the Joint Safety Committee, several questions regarding the cleanliness of the men's shower room were discussed. It was agreed to de termine whether any serious unsanitary conditions actually exist. The shower rooms are cleaned regularly on a daily basis. We also agreed that this is sufficient enough to maintain clean shower facilities. When there are complaints associated with dirty walls, closed vents, etc., these can be addressed and handled by the Maintenance Department. We suggested that Randi Eckstein provide feedback on complaints and actions regarding the shower room facilities through the Joint Safety Committee, and to use that Committee to get the facts back to the hourly employees. POLYCHLORINATED BIPHENYLS (PCB's) Latest results from the hydraulic fluid drained from furnace 08 show that the PCD level was at 13 parts/MM. We are reminded that four drums (55 gallons ea.) of BCP contaminated fluid, ML925, are stored at Lancaster pending final disposal. ASBESTOS We acknowledge the receipt of Mr. E. E. Rumberger's memo dated 82/02/16 re garding asbestos replacement material. One area in which we are currently in volved is the thermocouple wire used to survey and calibrate the heat treat furnaces. WASTE TREATMENT POLISHING LAGOON A minor tear in the lirer of the polishing lagoon was repaired on 82/02/25. The tear was detected during the drilling of one of the ground water monitori ng wel 1 s. X-RAY EQLUFMENT Mr. R. Geiger visited Lancaster Works on 82/02/25 to inspect the X-ray equipment in the Dispensary and the X-ray spectrcgraph in the Laboratory. All of the equipment was found to be in satisfactory working condition. ATC 0023953 > `~VU- (TJrr^ su (r.cv i ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1982 MARCH 11 PAGE 2 GROUND HATER MONITORING PROGRAM We are currently waiting for the contractor to complete the drilling of the last of the seven v/ells. LOW SOLVENT EMISSION COATING TRIALS On 82/03/02 the last of three scheduled trials was run in Metal Decorating area using a coating from the Lilly Company. Several problems were encounter ed and samples have been submitted to E. Christopher, Richmond Works, for com ments. The other two suppliers have been notified to resubmit samples with our recommended changes based on previous line trials. ENVIRONMENTAL REVIEW DATA Data submitted with Mr. R. F. Kohm's letter dated 82/02/02 are being reviewed by members of the committee in their specific areas of responsibility. The four areas include air quality, water quality, solid waste, and hazardous waste. After all areas have been covered, questions and/or recommendations will be submitted for review. HEARING CONSERVATION - OOSIMETERS Lancaster is preparing to purchase new equipment for conducting noise surveys. Randi Eckstein has agreed to discuss the possibility with Lebanon of sharing the cost and use of this new equipment. Note: A Lancaster Works noise survey was recently conducted in February. Closure Division - Because no further business in closures for the dairy in dustry is anticipated. Jack Sellers had recommended that we not renew our con tract with Syracuse Research Corp. (SRC). SRC had been providing surveys and conformance testing as required for sanitation compliance of interstate milk shippers regulated by the Department of Health. The next meeting of the Environmental Health Steering Committee will be held on Thursday, 1982 April 01, at 9:00 A. M. in the Staff Conference Room. L. M. CRIVARO c/ ATC 0023954 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1902 MARCH 11 DISTRIBUTION: Dr. T. C. Amend, Lancaster Works R. H. Eckstein, Lancaster Works J. M. Guitas, Lancaster Works F. D. Hereda, Lancaster Works B. C. Payne, Lancaster Works S. W. Rudy, Lancaster Works J. K. Sellers, Lancaster Works P. R. Atkins. Pittsburgh nffiro-l-- R. M. James, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 RECEIVED WimK 15 1S8Z PATRICK R. ATKINS info cc: R. S. Howell, Lancaster Works T. J. Leveque/J. C. Rebert, Lancaster Works J. W. Martin, Lancaster Works J. R. Scifers/R. L. Dodson/S. W. Rudy/E. H. Rund, Lancaster Works ATC 0023955 FROM* P---P Wtttitt ROUTE TO:--R-. II. CMWfLC 7- ft. --r 41. E-.-KOHMCR----1-- H. C. BROZANSKI - 7 JJ=^J2LARIi1--7 rj. mb nWtinirr - / i L. S. GEHRKE - 7 P. R. ATKINS - 7 f V ?t *s ATC 0023956 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1980 September 17 Distribution: Dr. T. C. Amend, Lancaster Works J. S. Gill, Lancaster Works (w/attachment) J. M. Guitas, Lancaster Works (w/attachment) F. D. Hereda, Lancaster Works (w/attachment) J. K. Sellers, Lancaster Works (Ifa fa RECEIVED 5 SEP 2 2 1980 PATRICK R. ATKINS P. R. Atkins. Pittsburgh Office-7 (w/attachment) R. M. James, Pittsburgh Office-7 (w/attachment) N. W. Nielsen, Pittsburgh Office-18 (w/attachment) V. W. Rieke, Pittsburgh Office-2 (w/attachment) E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 (w/attachment) info cc: R. L. Burns R. S. Howe11 J. R. Scifers/R. L. Dodson/S. W. Rudy/E. H. Rund R. L. Volkman/J. C. Rebert H. M. Walker ATC 0023957 FROM L. M. CRIVARO TO MEMORANDUM CONFIDENTIAL 1980 SEPTEMBER 17 RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1980 SEPTEMBER 11 Members Present: L. M. Crlvaro, J. S. Gill, F. D. Hereda, B. C. Payne, and Anna Biltheiser (for Scott Rudy). Members Absent: Dr. T. Amend, J. M. Guitas and J. K. Sellers MEDICAL: No medical problems reported. WASTE TREATMENT: A report regarding the annual water quality visit was received from the De partment of Environmental Resources representative, Mr. S. Dale, on 1980 July 07. His report requested that we discuss the permit status and monitoring. Mr. Dale was contacted and he stated that he would be contacting us in the near future to finalize our NPDES permit. POLYCHLORINATED BIPHENYLS (PCB's): The test results for PCB's on the hydraulic fluid used in the continuous fur nace indicated that the material had to be drained. The hydraulic fluid has been drained and the furnace recharged with new fluid. Sampling for PC8's will be conducted within six (6) months. X-RAY MACHINE: The new cassettes have been received and we will try to set up a meeting to review the new exposure times with the radiology representative. RESOURCE CONVERSATION RECOVERY ACT (RCRA): We are currently working on the application for a hazardous waste permit from the EPA. A rough draft will be submitted to Dr. R. Lee Byers, Pittsburgh En vironmental^ for his review. Regarding the status of the certification of haulers of our hazardous waste material. Barry Payne is currently involved In this area^---llU'of our^vendors who is hauling waste solvent from the plant is using aT'S^nlfest form tpet in dicates the final destination to the facility. We will be--os i ng th-rgType of form at the present time. A copy of this form is attached to this report. ALCOA ATC 0023958 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1980 September 17 Page 2 Regarding the status of .the identification of drums containing hazardous waste that are moved to the concrete storage pad. We are currently faced with the problem in handling these drums because of a technicality involving trucker classifications as they exist today. We recommend that, to insure safe and proper handling of these drums, only one (1) trucker classification move these drums. The Checker Truckers, under Mr. J. Gabriel's supervision, should be responsible for moving these drums from the department directly to the storage pad. Mr. Rudy is to follow-up on this. MONITOR WELL ANALYSIS: Test results have been received and a copy has been submitted to Pittsburgh Engineering for comments. INDUSTRIAL HYGIENE ASBESTOS PROGRAM: Messrs. John Guitas and Barry Payne are working on the replacement of thermo couple wires and gaskets for boilers which contain asbestos material. In ad dition, we will be looking into the personal sampling of employees involved in handling this material in the near future. The Alcoa Technical Center - En vironmental Health Labs has been contacted for the equipment needed to conduct these tests. OPERATING PROCEDURE - PUMPING OF WASTE SOLVENT AND SLUDGE: The procedure used to pump out the waste solvent and sludge from the station ary containers should be similar to the procedure "Unloading Bulk Sulfuric Acid and Solvents". In addition to this procedure, the following steps should be maintained: (A) the vendor is required to be in before 3:00 PM. (B) Mr. Jere Gabriel is to be contacted when the vendor will be coming into the plant. (C) If an emergency exists and the vendor must come in after 3:00 PM, then a Unit Supervisor must be contacted. DEPARTMENT OF ENVIRONMENTAL RESOURCES - VOLATILE ORGANIC COMPOUND EMISSIONS (VOC) ______________________: We have re informatio local DER representative. He is requesting The next m on Thursda,. vipefimental Health Steering Committee will be held 2, in the Staff Conference Room at 9:00 AM. L. M. CRIVARO ds Attachment ATC 0023959 FROM: P. R. ATKINS ROUTE TO JUL runiilTliBi 7 H^-Gr-BROZANSW'- Jl, fr- BARNES , 7 M/ MC-TAGQART - 7 P. R. ATKINS - 7 - FILE ATC 0023960 ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1980 May 08 Distribution: Dr. T. C. Amend, lancaster Works J. S. Gill, Lancaster Works J. M. Gultas, lancaster Works F. D. Hereda, Lancaster Works J. K. Sellers, lancaster Works P- ft- Atkins. Pittsburgh Offlce-7 R. M. James, Pittsburgh Office-7 N. W. Nielsen, Pittsburgh Office-18 V. W. Rieke, Pittsburgh Offlce-2 E. E. Rumberger/T. B. Bonney, Pittsburgh Office-7 info cc: R. L. Bums R. S. Howell J. R. Scifers/R. L. Dodson/S. W. Rudy/E. H. Rund R. L. Volkman/J. C. Rebert H. M. Walker ATC 0023961 FROM L. M. CRIVARO CONFIDENTIAL TO MEMORANDUM 1980 MAY 08 RECEIVED MAY 1 2 1980 PATRICK R. ATKINS RE: ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING - 1980 MAY 01 Members Present: Dr. Amend, L. M. Crlvaro, J. S. Gill, J. M. Gultas and J. K. Sellers Members Absent: P. D. Hereda Guests: D. L. Thylor Industrial Hygiene Conference: We reviewed the Industrial Hygiene Conference that L. M. Crlvaro recently at tended at the Alcoa Technical Center from 1980 April 28 to 1980 April 30. At tached to this report is a copy of the logo presented at the conference. It represents an employee who is surrounded by a protective shield. It serves to remind us that all employees have the right to work in a hazard free environ ment. The industrial hygienist must implement a program which will meet this goal. Where hazards do exist, employees have the moral and legal right to be informed of these hazards and protected from them. The conference included workshops which covered specific topics such as: (1) data feedback to em ployees; (2) employee training; (3) joint labor/management safety and health corrmlttees. Other topics covered at the conference were toxicology, workers compensation and the physician's role in the industrial hygiene program. Medical: No medical problems reported at this time. Hearing Conservation and Noise Control (HCNC): The consulting firm is scheduled for a plant visit and audit on 1980 May 15* Closures - Metal Decorating Area: Two (2) employees who were previously affected by coatings and/or lining ma terial which resulted in skin rash problems have been permanently- hi nqnnl ^ fted- from working in this area. ---- X-Ray Equipment: A follow-up on the visit by the representative from the Bureau of Radiological Health has resulted in the acquisition of information and recormendations in resolving the two (2) potential problem areas. _ Mr. W. P. Jefferson, Adminis c trative Director in the Department'/):' RaSiology at Lancaster General Hospital, has provided us with information regarding radiographic exposure factors. His recommendation includes the purchasing of new cassettes and advising Mrs. Kendall, Registered Nurse at Lancaster Works, in the technical factors re quired to reduce patient's exposure. ATC 0023962 ALCOA ENVIRONMENTAL HEALTH STEERING COMMITTEE MEETING 1980 May 08 Page 2 Industrial Hygiene: Results from the personal sampling monitor tests run by Mr. R. M. James' visit have been received. However, after Mr. James' full report has been received, we will notify all the employees of their test results and protective action will be taken, if required. Vapor Degreaser: Dan Taylor reviewed the current problem with the vapor degreaser, specifically the freon TMC emissions. Tests are still being conducted on the new vapor de greaser using the freon TMC solvent. Representatives from DuPont and the Detrex Company will be iri the plant on 1980 May 05 to conduct additional emission tests. Lancaster's position has been and still is that Detrex must correct the machine problem in order to maintain the acceptable TLV estab lished by Alcoa of 270 ppm for methylene chloride. The next meeting of the Ehvironmental Health Steering Committee will be held on Thursday, 1980 June 05 in the Staff Conference Room at 9:00 AM L. M. CRIVARO ds ATC 0023963 !cP <, !7oc> iSCcj&i {^atyvjLy- - &JIju^.x . J-r , ^ fir (d Sj*U-*ySs>-L- - &1K-/. vifAt ,&+1^. OJttrtK- ZlerMwJ' - V. CT.^RU^Q - &sr~>M.Hs^- s)r^$Lsc*JL Jfci^t'.-1'V-P Sz 9 OJc 1-rf /{jr<-^r-/dZ ? xftjZo-t-S- y/i/sZXL. C^e-c f -o*--'' yJ')X 7,,--< '?-,;/ ^;~Z, j t> <^<f1 /': /y&c-x 'its ^ -' . > <^>5 , ^ -jr-TSLcJ, .' I \i tv Ac.".; -A i ' ^, I ---. wl -~7--^-:;- / 'X ', c~- * ~ - >w `ji ATC 0023964 P*- yWjJ. Jj-t P 0P jrr7>\ P&t ^UPPt ^U^ircitP UuJU iix^. HadtJlkpo I &Jbu,^,lU 0l^~ fljtbcAt^. "^Xju*-* DjL ' * ___________________________________ _________ cn\sfi<JL /H&wjJI //~l\'sdi/rh-fr^-u fQ PjM^ru^/ /&JLm~ - Xl-iiJ&i/sClJL. fa, J $U>jU &ctsbi.- &^,PMLb Pa Of " " XmlJaTjl. TfUs-Urk iAc. 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SjJJLsl - -3o 7?w&n &c. -&>rs&- ,/^g_______________ *a^J) jjtsuzJ'' s i - ~2Zo X -^'f Jm LCSirJMA S&*Jl/Csy'yCsi'-&Lf I^Hl/ - '^`-iXstTL^EZ. -^gTTy vT'Z-r-^lw^ /h-^J^fC^O^ st<'Z*C. .A^l. dtsCj U^Ce^tZ^-f i -^/ XV/y *.'K--,h~tJj -^7 / C S UjFt <4 . ^'Xertr-r -- /Cerf<- ^3r-^. SZsi'Ca^C-J sfrn~^uls/ /HQyi^Le^, ^Vj'2-cxl^ j ^3l_CL LC^UiHA,). /&<K. cJc< r^i -.cX-ft / - r-^<-g J>^v .^4y' yO,_ ATC 0023966 4cf Q QjA Ac&'s. '^yTL*'-<3-^-ry^c^/~^t~ ) -- Os) (0 *2 - CO o> *3- () O) <*'%. ja-r bJ D _ 3, C HG/kg A/D Up 3.a Uc/^q sQ-dhu. JLUve-fVr wffi-,'*c. - -i~S sa^JL- y -- cj&xsln. . ^/jlxAU-1/b-d- /fiySr-Q. -- sZJjc&^reMxJ} -firm 4r4sr77^ faA&stdl*. QsrFst *q~S' jtc l^'Jj^jH ' 'io he. cAi _______________ Ja^.`-F<-^*-<l, -- `7hsf~ -dkr/Cj^^LxJ)^xCsffin- . skppit^______________________ ^tj< -- 'to /hOi/j^^rxtxX^ .(/kfj ** yj^sr*Z~J\PC -/_______w S^Ua. 'rff/t~--*j p^gy^'^-- // AAyjl - S^U> X? 4'l'Q<j<. ^?7*% T __ aTC 0023967 rL^^rr^i-^A__a-^e-P a!*. 5or (= sCjti+nsa^ Pus-e soJinK-'- ^Jyjjo^jcc^rP StiuJL sMi> -&J m> s/iyr&s yrfy~ j^suiPcs*Jtit*J} j(&J AaSl/^P /y^Pj x<<z ykA^<fcr OiM--jh*yU) . &*. (lien - dCH) /L1 s^-/Py(-'si+(-* 0, PnaJU^rr-^ '. PPry<jL /S^A ^&2zrrP^Tp%prztX<z> $bJl --zy*j yy^Tlfacd-friuXJ^ ---------/f~ JL ^sTrcP-CjJ\st -t:~tJ-_iL ru~p yC^n^cr(^i. -PAtrc-T -4TULP f %*zJbz. IMIl (U JC'.ooAH saAMi joJ~L.______________________________________________ _______________2fce -Pas-r^ n s)vsZ*- Pr /G-r*j.`7"<rr Ph r .a / // s47ldp4*jy -^VP^n. J&t / ' f- ^o ythj-/ Phia v'}'**/ Xl^r^wPL sCjlsr^ -^C' .cpt^^cpjspyOALipAriP. f> A ' - ' tl L / `aL ffLi'Cjcrtx. sisn^e^^Li_, %tc> PcP ^L^z-^c-ry. _______ y^vO&e, Pn s7HJlc *4Uc^G_ yt-sC Pl-p-^ /tie*. - /CaxJjU/O^'^X**________ sCa-v^-Ae&A- /&^ Pc U^t-ap <*-/" sfcAj5Lt''*J'. V^L___________ n-1 *<~<^^ X>rrJ^7>rjLcS jt/j Oj/jsrijuiTl/^- ______ sO^S' y^h^C*^ iX^Cl.t s<Zs3 so/lAtC,^- n<T-^^S~------------------ rdtidLS' "P\ "_____.__ ^Ur-e JLcrt-cs ATC 0023968 o" F~ ^ SAAstJ- SmJJ&tiJlL ^r\ sCr^JUJ *C-<fc^j_a_ /Cjnr^JLMi^T-zJ&^-T^ -<rV sb'^L ^crr^ s^Las ^A6(^_____ yK^ajL^A^ 'JAl ^*tu<All1**^ a^^ZcZ- ' B X<./>fcuJLJi o*Jj ^cio- ^i^v- j /nut^A *AA_ __ Xg->^ -^y. ^cAAcnT s4si2_ s0-6r-r^. ^A*+J <y&&~a^a^<-A*. Jsr\ t >y2^/ V>y<*A4*tjfk-tsr^. SK-Ao.JLuJLt- ATC 0023969 ATC 0023970 l Larrvj ynCSKeq dr&Tn ' id.J.'&pi.UAJO AA^C/jSTE/? Jb / P. H, Kaot pTA/. OFF. __________ Pk \ OlSHAhJTU AJ c..RFfcKT <?c; G. L, Avdf&soaJ _______________ ATc 1992-64-0$- \. __________ ^C(srr^4J -- dPe. ^Prtrrr^ LS ~ .2 *fyj*(t*>* jh&VK, ___ M/Or^~ j&ddjLed-Zd j$uJtjr*^pJ2*\jdri4jL4$tf3___ .. _J$?itoS-3l.._____ _________________________________________ ZE?~d!tus{ d!djc_0 >K. -ipifrxddi /xtydaffa.dd%&dE^.dc ... . ^u^tr^z. dA^jf&djuJa. d^*^rj<&d~ _. ______Jj^dA... . ... ______________':___________ {hcJUd&U Moci,i)\d*UpJL~-a ~lt~. <^uA^y^ rpk/b f&?r4Usri-<- zid &&<r/c>, ^Lhx sCpctJl _____ ^JlAcjisfixe^JPi s^td>r^eJ Ztirf S?CaCt4ruiJ). d!b**Jr\) Jt*d _.. . . Ed!.SfnCddd /3ddk J?0. _ _ _ _ _ _ _ Jdtu4.sdUk .... . 'odcc*n\ . x*~.dE- rs-e-/** Zb sO. ifdjC-i '"9^ /'-<_ ^dic . ~<-^e-Pc--^d/ . -^'-^`J-^Upt.ct V y: !* d/x A. C 3 \:Vp/}_^adJ! _pk - VER A-'J/j 'd Q/7 D'*Jd!,mjSJ'js'jis Jfefdtedd(4yidl/^-'<dx-A<>'~> -pfd-d' ^ d* S-CA'fd - --A...........- - - - jT^ddddsydfrA' MKlS'-- . /dtiZid ^dctcd^ Z*\ 2^ sftfi/dJvAiJ*- ............... . ATC 0023971 __________ dkjJA*__ 1 1^ ^4. 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