Document a4Ynr5aR99kNRa2e4Jo9mrqKy

INTER-ORGANIZATION m TO: ATTENTION: ASHTABULA Robert Laundrie/Harlan Jewett FROM: James Arv i n DATE: June 1, 1981 "* SUBJECT: ASHTABULA PLANT VINYL CHLORIDE LEVELS It appears the overall averages of vinyl chloride levels at Ashtabula are falling. However, there are still some 8-hour averages from 33-* to 60.9 ppm indicated by the Bendix sampling units. I feel the high levels are primarily due to operators not following standard practices and not responding to high levels Indicated by*the Bendix machine. For example, on May 27, 1981 I was in the plant at 6 a.m. and the blue light indicating levels above 15 ppm was on. It had been on for almost the entire shift. No one requested a leak detection inspection from Quality Control to find the problem. Nothing was done until I requested an inspection at 10:30 a.m. The Quality Control men found two leaks - one upstairs where the slurry transfer lines had not been capped according to standard procedure. Lines were capped and levels went down. The other leak was a hammer blind on reactor 312. This was repaired on the afternoon shift after the reactor was brought down. There is lack of enforcement in requiring the wearing of respirators for levels over 5 and 15 ppm. On May 27, 1981 when the blue light was on I observed operators and laborers not wearing the in-line respirators or 10 ppm masks as required in the reactor building. Housekeeping could help keep the levels down. High levels (15 ppm) were found at the slurry transfer lines and some resin had been spilled on the floor. I requested a laborer to work the slurry down and the levels dropped. V Education to follow the standard procedures, such as capping the slurry transfer lines, tightening down gaskets and seals, etc., is needed. In Feburary, 1980 Ashtabula was cited by OSHA for employes not wearing respirators and high levels of vinyl chloride in the reactor while cleaning and to exposure above the time-weighted average in the polymer building. We recently requested an extension of items 1-A and 1-B. Therefore employes must wear respirators, as required, until levels are brought down...not only to protect them from exposures, but to prevent a repeat citation. xd Attachment cc: R. Garber tot*. FORM t BONO bcc: D. Jeffrey James Arvin 6ENC 003169 BETTER Service Is Our Business OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION -- f ..i\ CITATION and NOTIFICA >N OF PENALTY Cleveland Area Office 1240 East Ninth Street, Room 847 Cleveland, Ohio 44199 216/522-3319 ' ISSUANC 4/8/80 > REGION 5 TE < OSHA NUftHER P4561 oo.r AREA * PAGE 1680 . .1 0F Z___ t TYPE OF VIOLATION ISfY;, INSPECTION DATE: * Other ' ? 1 2/8-V3/80 INSPECTION SITE: Middle Road, P. 0. Box 08 TO: General Tire & Rubber Company Middle Road, P. 0. Box 68 Ashtabula, Ohio 44004 Ashtabula, Ohio 44004 THE LAW REQUIRES that a copy of this Citation ba pottad immediately in a promi nent place at or near the location ol the vto* lation(j) cited below. The Citation must remain potted until the violation! cited be- k low have been corrected, or for 3 working days (excluding weekendt and Federal holi days) whichever is longer. This citation describes violations of the Occupational Safety and Health Act of 1970. The penalty(ies) listed below are based on these violations. You must correct the violations referred to in this citation by the dates listed below and pay the penalties proposed, unless within IS working days (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U.S. Department of Labor Area Office at the address shown above. (See the enclosed booklet which outlines your responsibilities and courses of action and should be read in conjunction with this form.) i ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION ' DATE BY WHICH VIOLATION MUST BECORRECTED PENALTIES ARE DUE WITHIN IS DAYS OF RECEIPT OF THIS NOTIFICATION UNLESS CONTESTED (See enclosed Booklet) This Section Me1 Be Detached Before Posting 10 PENALTY the Bendix system indicated a concentration of 5ppn in the area. i' 6ENC 003170 AREA DIRECTOR L -U>SLIiJ W. HICIM: J.. PH.D- ,.^ JSQ- NOTICE TO EMPLOYEES -- The law gives an employee or his lepresentative the opportunity to object to any abatement date it for a violation if he believes the date to be unreasonable. ie contest must be mailed to the U.S. Department of Labor EMPLOYER DISCRIMINATION UNLAWFUL - The law pro T0TAL PENAL' FOR THIS hibits discrimination by an employe^ against an employee for CITATION filing a complaint or for exercising any rights under this Act. Make check orMoi An employee who believes that he has been discriminated Order Payable T rea Office at the address shown above within 15 working days against may file a complaint no later than 30 days after the "POL OSHA' (excluding weekends and Federal holidays) of the receipt by me employer of this citation and penalty. discrimination with the U.S. Department of Labor Area Office Indicate OSHA h on Remittance at the address shown above. uMPLOYER RESPONSIBILITIES AND COURSES OF ACTION -- The enclosed booklet outlines employer responsibilities and courses of action and should be read in conjunction with this notification. CITATION AN0 NOTIFICATION OF PENALTY DUPLICATE w OSHA-2 REV. 5/76 v- ^r^^^S^fFARTMENt OF LABORS . - I,. OCCUPATIONAL SAFETY AND HEALTH ADMltrt*CTATI<^rV^^>* . >''f ' / `.'.tj,-*..*, t--s ..** CITATION nd NOTIFICA^^N OF PENALTY (OsralMdiiw* offlot 1140 BMt Kinth fitment, 1mm 847 CUtnlmL Ohio 44199 tL(SS*h~&l9 muamT n aWANMMS 4/Wfc a Milos ARIA MU __5______ 1680 1 2 l ).^t t)t '\ I lUN'Si UfAUim M>; INSPECTION DATE: Other V8-VV80 INSPECTION SITE: Middle lead, P. 0. Box 68 to. Qeoersl Time 4 Rubber Peepwiy Middle *m4, F. 0. Box 68 AahtAbuU, flfaio 44004 AabtubaLu, <f-u ^4 THE LAW REQUIRES that a copy of thh Citation ba potted Immediately in a proml- nant placa at or naar tht location of the vk>latlonlt) cited below. Tha Citation mutt remain poatad until tha violation* cltad bolow hava bean corrected, or for 3 working day* (excluding weekend* and Federal holi day*) whichever la longer. Thit citation daacribat violation* of the Occupational Safety and Health Act of 1A70. Tha penaltyOea) llatad below are baaed on the*# violation*. You muat correct the violation* referred to in thi* citation by tha data* Hated below and pay the penaltie* propo*ed, uni*** within 16 working day* (excluding weekend* and Federal holiday*) from your receipt of thl* citation and penalty you maU a node* of contact to tha UA. Department of Labor Area Office at the addree* drown above. (Sea tha endoaed booklet which outline* your rwpondbilltfa* and eouraae of action and diould ba read In conjunction with thl* form.) ______ ______ ITEM NUMBER STANDARD, REGULATION OR SECTION OF THE ACT VIOLATED; DESCRIPTION DATE BY WHICH VIOLATION MUST BE CORRECTED PENALTIES ARE DUE WITHIN II DAYS OF RECEIPT OF THIS N0TIFICATI0 UNLES CONTESTED (Seeeadoiad Bedded Thl* Section M Be Detached Before Potting PENALT Tbo ttalsUoa dmorlbed la this citAtira ra Allagad to bsws ou or oboot the 4sy the inspection su m othortlM lwdicAted within the description given below. U 29 OR 1910.1017(c)(l)i &vloyo*s In the poly*tor building, clewing the reactor Teasels, vara etxps*d to on 8-howr tins vslffatsd mi|s tirtone concentration of viqri ddsrltb 1b eras** of coo put per oillion standard. Tho esflsysn wozklnB Istoldo tho vessel was exposed to vlwyl chloddo asonsar 8*5 tijMO tho standard. The helper woo srpesed to 3*8 tirae tho staadard. 10/8/80 11 29 OR 1910.1017(f)(2)* Qaploywo^i) exposures to vinyl ddorUs were not controlled as provided in paragraphs) (c)(1), (c)(2) or (c)(3) of this section by the utilization of 1--ediato feasible aginerlng controls to reduce the exposun* to the lewalt 10/a/Ao Secooc loor, polymer building, (paragraph (c)(1)). 29 OR 1910.134(4) (2) (ii) 1 Suitable inline air purifying beds and filters were not Installed lo oeoprasssvs to folks breathing air qnslityi Isaediately Iho air supply lines were of such Isgth that tho present sorbent beds and filters wore 1 > In rr--fing particulate frea withia tho 29 OR 1910.134(c) (4) I Frequent . ducted by a qualified individual to properly OQlected, need, cleaned 1 (a) Tho lab technician thats raffpoasiWo for log the reactor was not wearing his fedtlv* _ iwwpiratc 1 <\ 7 -Tanner to intrurs * prepsW fit* (b) The coMpeuBder was not wearing his Single raoplxator as required by -GEHC.003 u AREA DIRECTOR LRSLTB ff. WTCHAELg. WJ, NOTICE TO EMPLOYEES -- Tha law gives an employe* or hi* representative tha opportunity to object to any abatement data sat for a violation if h* believes the date to be unreasonable. Tha contest must be mailed to the U.S. Department of Labor Area Office at the address shown above within 15 working days (excluding weekends end Federal holidays) of the receipt by the employer of this citation and penalty. JtM Xieff F EMPLOYER DISCRIMINATION UNLAWFUL - The law pro TOTAL PENA FOR THIS hibits discrimination by wt amplpytr against an employee for CITATION fHIng a oorrfpiaint or for ixardsfog any rights under this Act. MekecheckorM An employee who behaves that ha has been discriminated Order Payable against may file a complaint no later than 30 days jfter tha "OOL-OFu Indicated "l discrimination with the U.S. Department of Labor Area Office en RamMw.. at the address shown abova. EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION - The enclosed booklet outlines employer responsibilities and courses of action and should ba read in conjunction with this notification. CITATION AND NOTIFICATION OF PENALTY DUPLICATE W OSHA-2 REV. 5/76