Document dazK4ZDQoveqrDgrnN1Jxa6VB
/ iPGoodrich INTER-ORGANIZATION CORRESPONDENCE
TO
Mike Marshall
FROM
Phil Donataccio
SUBJECT
Fiao POINT OR DEPT & BEDC. NO. FIELD POINT OR DEPT. & 8LDG. NO.
Corporate E, H&S Audit Corrective Action Plan (Draft)
DAtl YOUR LETTER
DATE THIS LETTER
11/2/92
Attached is the Henry Plant reply to the 1992 Corrective Audit conducted August 10-14, 1992.
If you or your staff have any questions, please let us know.
Phil Donataccio
MM/PD9284
cc:
G.E. Higby - without attachments* J .D. Krumholz - without attachments* M.E. Guyer - without attachments* R.J. Grahek - without attachments* K.J. Killings - without attachments*
* Attachments not sent due to "Confidentialit.y" requirements-
11/02/92
lO<~
(Z&
Please review and forward your comments to me before Friday, Nov.6. I will then coordinate the "final" response with the plarjJp. Thanks,
Bp.k/-
ek --~-
8FG-4SS6-E M 4 D P/int.ng Co..
Ul. 61S37
200 *39bd
C, T I.IA i
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voopiny: BFGOODRICN Facilixy: henry
-orkshwi
Prmatech Inc. Page: l
Session: 1 06-10-92 Sysxea: 1 MANAGEMENT OF CHANCE
Category: RECOMMENDATIONS
Revision: 0 10-26-92
Dwgi:
QUESTION
vwtp v-NotcH veie was hot aLIBRaTED.
;pj .
REMARKS
; RECOMMENDATIONS ;i. CALIBRATE
J BY J
COMMENTS
1
*----------+ -------------------------------------------------------------------- 4
jwjgji. 11/92: the v-
'NOTCH WEIR IS TO BE
i ;CHECKED IK
; ; accordance with
; ; chapter $ or the
: {EPS'S NPDES
J JCOMPLIANCE { ;INSPECTION MANUAL.
: {THIS WILL BE
: :PERFORMED ON AN
! J ANNUAL BASIS, a
; 5 CALIBRATION CHECK
; {WILL BE PERFORMED
J {MONTHLY on TfiE ; ;secondary measuring
{ {DEVICES AND THE
` '[COMPUTER READOUT TO
* JINSURE RELIABLE
: :data. (sdj.wjc)
: *3.2/1/92.
- THE RADIATION SAFETY OFFICER BAS NOT BEEN TRAINED AND THE PERMIT HAS NOT BEEN UPDATED.
{P ; {
3. environmental project?
>i c{
(IMPACT.) ASSESSMENTSWERE NOT
{;
COMPLETED.
TRaIN OFFICER
3. PROVIDE ASSESSMENTS
0EC{2, 11/92; TRAINING {HAS BEEN SCHEDULED J FOR D.E.CIFPIN THE 1WEEK OP NOV 9TH TO {ATTEND TEE TN tradiation school. ;(DEG) X2/1/92 ^
DME`,3. 11/92: ALL RA'S, ;ar*s, and cpo*s now `.HAVE ENVIRONMENTAL {IMPACT ASSESSMENTS {INCLUDED TO INSURE {THAT ENVIRONMENTAL {CONCERNS ARE {ADDRESSED. COMPLETE {9/1/92
4. SCAFFOLDING Was NOT INSPECTED QUARTERLY.
JC {
4. INSPECT
DECJ 4. A PM MAINTENANCE {WORK ORDER HAS BEEN {GENERATED TO INSPEC {THE SCAFFOLDING
1 {ON A QUARTERLY [ {BASIS. THE PLANT | {PRESENTLY AND IN THE 5 {Past inspects prior ; {to Each use of the
EBB'3DtM
NGC 12549
AUDJT-E'C 1 . i> 1
Worksheet
Cocdp^ny: BFCOODEICH Facility: HEKFY
Session: 1 03-10-92 Syatea: 1 MANAGEMENT OP CHAXr.r
Category: BECOMHEND.'iTTONS
Eovi^ion; 0 10-26-31
Dvg#:
QUESTION
; a; REMARKS
RECOMMENDATIONS {8Y {
Pj-lnattch In'-Page; 2
COMMENTS
{i ;;
' :
Session: 1 0S-10-92 Syeten: 2 RESPONSIBLE CARE
Category: RECOMMENDATIONS
Revision: 0 10-26-32
Dwgft:
{SCaFPOLDINC which is {MORE FREQUENT THAN {QUARTERLY. . T'{ COMPLETE)
{10/30/32. ,
1
QUESTION
{a{ REMARKS
RECOMMENDATIONS
BY {
COMMENTS
{1. THEBE HAS NOT SUFFICIENT `,P{
DOCUMENTATION SUPPORTING STAGEJ {
{VI PROGRESS OF THE RESPONSIBLE; {
'CARE POLLUTION PREVENTION {CODE.
{;
{: ;{
'-&r
^
^
^
1. PROVIDE AN
DMEJ1. 11/32: AN UP-TO-
UP-TO-DATE QUALITATIVE
{DATE POLLUTION {PREVENTION CODE
EMISSIONS INVENTORY.
{INVENTORY OF ;emissions^hIs been'
-y
MW*VTHBBH-- {PRIORITIES FOB 5REDUCTION WILL BE {MADE EASED ON ;potential health and jsafety impacts.
{(DHK) 3/1/33.
i_
2. EVALUATE POTENTIAL IMPACT OP RELEASES on the ENVIRONMENT AND THE
DHK`2. 11/32: AN {EVALUATION OP THE {POTENTIAL RELEASE ON {THE ENVIRONMENT AND
'' 2- 'w'?`
HEALTH AND SaPETY OF EMPLOYEES aND THE COMMUNITY.
/U*
{THE SAFETY OF EMPLOYEES AND THE COMMUNITY HAS BEEN {PERFORMED THIS WAS ;PERFORMED IN {CONNECTION WITH THE ;REQUIREMENTS OF THE * ILLINOIS CHEMICAL {SAFETY ACT.
.5. ESTABLISH
priorities taking
INTO CONCERN
DKE:3. 11/32: ONCE THE {PRIORITIES HAVE BEEN {ESTABLISHED,
POTENTIAL HEALTH AND
{MEETINGS WITH PLANT
safety impacts.
{EMPLOYEES AND THE {PUBLIC WILL BE HELD
`TO RECEIVE THEIR {RECOMMENDATIONS. {(DHK, PD) 6/1/93
t-. r? o - --i
NGC 12550
AUDJT-PC 5.hi
Company: BPCOODRICH Facility. HENRV
1 OS-10-92 2 RESPONSIBLE CASE RECaiKENDATIOKS
Worksheet
Revision: 0 10-26-S?
RRHaRES
Dvgt:
RECOMMENDATIONS
:by ;
',4. PROVIDE 1MEASUREMENT OP OS 1 GOING REDUCTION
PROGRESS.
1DME
Session: 1 0S-10-92
Revision: 0 10-26-92
System: 3 SOLID AND HAZARDOUS waste MANAGEMENT
category: RECOMMENDATIONS
Dvg*;
Primatech Inc. Page: 3
COMMENTS
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Page
Session: 1 OE-lO-92
Revision: 0 10-26-22
System: 3 SOLID AND hazardous WaSTE HaKaGBMENT
Category; RECOMMENDATIONS
Dwgc:
QUESTION
A i REMARKS
RECOMMENDATIONS
I BY
COMMENTS
Satellite
accumulation area was not closed with
6. potentially ^
EEUSABLE materials (V VERB STORED IN DRUMS; \
labeled "scrap" and ; waste-' at the FLAMMABLE STORAGE PAD.
J
<P >*S
waste oil was sent to a
FACILITY WHICH WAS NOT AUTHORIZED BY BTC.
7JTHE FACILITY
2- CORRECT
DISPOSED OF WASTE
OIL AT AN OIL
RECYCLING FACILITY
that WaS NOT
INCLUDED ON THE
FACILITY'S LIST OP
APPROVED TREATMENT,
STORAGE AND DISPOSAL
<TSD) FACILITIES.
1 PRODUCTIONS (OPERATIONS. ;(COMPLETE) 9/1/92 5 4) THE BOX IN I QUESTION WAS LABELED (THE SAME DAY AND VaS }SHIPPED S/21/92. ;THERE ARE ;indications that the ;material presently (BEING DISPOSED OF IN (THE CONTAINER is no ; LONGER HAZARDOUS (SINCE THE MATERIAL (WHICH MADE IT (HAZARDOUS IS NOW (SOLD AS OFF-GRADE (PRODUCT. WE ARE IN (TBE PROCESS OF (CHARACTER!ZING THE (WASTE. (DMK, SBJ) 12/1/93.
S) PROCEDURES AND (CHICKS ARE IN PLACE (TO INSURE THAT LIDS (ARE CLOSD AT TIMES (ON SATELLITE (ACCUMULATION DRUMS (EXCEPT WHEN BEING (FILLED, (COMPLETE) (9/1/92.
4
DMK(2- 11/92: PERMISSXO (WAS RECEIVED PROM (DIVISION (ENVIRONMENTAL PRIOR (TO SHIPPING THE USED (OIL TO SAFETY KLEEN ( ( COMPLETE ).
: iulu >
i"
9PiW ' ^Hrl
NOC 12552
AUDIT'.FC 1.51
Company: BFGOODR.ICH Facility: HENRY
Worksheet
Prinutch Inc. Page: 5
Session: 1 0S-10-92
Rovicion: 0 10-26-92
System: 4 DRINKING WaTRR MANAGEMENT
Category: RECOMMENDATIONS
Dvgs:
QUESTION
; a;
RECOMMENDATIONS
;i- sampling results were not {REPORTED TO THE STATE uITHIN J30 Days.
;p; {; t;
RESOLVE
COMMENTS
MKJ1. 11/92: THE JANaLTTICaL {REQUIREMENTS {required"'under the
JILLINOIS PUBLIC JHEALTH DEPARTMENT ;ARE BEING REVIEWED ;to determine {COMPLIANCE. (DMK) J12/31/92
. THERE IS NO DOCUMENTATION HAT POTABLE RATER SYSTEM IS LEAD TREE".
|P{ `{ \\
3. THERE WAS NO NOTIFICATION {P;
POSTED INFORMING PERSONNEL OP \ J
THE LEAD CONTENT IN THE
{;
drinkinc water.
;:
4. the facility has not DEMONSTRATES THAT THE WATER SYSTEM IS "LEAD FREE".
}p { {
5. NON-POTABLE WATER SYSTEM IS IP
NOT LABELED
!
t- +
. CENERaTE
documentation
DMKS2. 11/92: NO RECORDS ; ARE AVAILABLE TO !DETERMINE IP "LEAD J FREE'* SOLDER AND JPLUX HAS BEEN USED *IK THE POTABLE UaTER J SYSTEM SINCE JUNE ;i9. 1986. a {MONITORING PROCEDURE {WILL BE ESTABLISHED `fOB LEAD IN THE !potable water. ;NOTICE WILL BE {POSTED EOS POSSIBLE `LEAD CONTAMINATION }IN PRINKING WATER. JPROCEDURES WILL BE `.ESTABLISHED TO INSURE THAT "LEAD `.TREE" PIPES, SOLDER `.AND PLUS. ARE USED I {AU FUTURE CHANCES JTO THE DRINKING {Water system. (Smk> {12/31/92.
i. POST NOTITICATIO DKK`,3. SEE ABOVE
A
ADDRESS
` -
DMK{4. SEE ABOVE
S. LABEL
DMKJS. 11/92: A PLOW {DIAGRAM OP THE
NGC 12553
AUDIT-PC 1.51
CotuptLiiy: BFGOODE1CH Facility: HENHT
Session: 1 06-10-92
Worksheet Revision: 0 10-26-92
Primn'Cec.h Inc. Page: 6
AUD1T-PC 1-51
Company: BECOODEICH facility: HENKY
Worksheet
Session: 1 QS-10-92
Revision: 0 10-26-92
Syatea; 6 COMHWITY-RICHT-TO-KNOU
Category: BECOMHENDaTIONS
Dug#:
T'r i-tna t *ch Inc. Page'. 7
\ QUESTION*
Ja; REMARKS
[ RECOMMENDATIONS ; BY [
COMMENTS
[1. THERE IS NO DOCUMENTATION [C[
[THAT SAia 302 NOTIFICATION VaS J [
[SUBMITTED-
[[
1 CENERaTE
documentation
DMKJl. 11/92: A COPY OP [THE SARA 302 [NOTIFICATION LETTER [SUBMITTED TO THE JSERC IS ON FILE IN [THE ENVIRONMENTAL [OFFICE. (COMPLETE) [5/6/87.
Session: 1 OS-10-92 System: ? HAZARD COMMUNICATION
category: RECOMMENDATIONS
Revision: O 10-26-92
Dvgi:
[ QUESTION
j a[ REMARKS
[ recommendations
[BY [
COMMENTS
1. BOXES OF PVC DISPERSION
[P[
STRAININGS RaD TWO CONFLICTING*, [
HAZARD LABELS.
I!
1. CORRECT
SEGIl. THE CEON
dL*
$
[Varerouse will be [audited for [NONCOMPLIANCE AND
[THE PACKAGING [Labeling will be
(wec5 ^
dL\
12/31/92.,
------->^*s-^--------4--+----------------------------A~ffr~
Session: l 08-10-92
Revision: 0 10-26-92
System: S INDUSTRIAL HYGIENE MANAGEMENT
Category: RECOMMENDATIONS
Dvg4:
[ QUESTION
[ RECOMMENDATIONS [BY [
COMMENTS
1. APPROXIMATELY FIVE (5)
[c
PERCENT QF^EEPOSURE MONITORING;
RESULTS POR VINYL CBICRIDE EXCEEDED THE Plll0}/p
; [
2. PROCEDURE rOR "YELLOW LIGHT" ALARM DOES NOT ENSURE EXPOSURES WILL BE LESS THAN THE PEL.
1. MAINTAIN FOLLOWUP DEC[1. PLANT CURRENTLY
PROGRAM
[CONDUCTS BOARD OF
[INQUIRES WHENEVER aN
[INDIVIDUAL EXCEEDS A
[PEL WITHOUT
iRESPIRATORY
IPMENT- ACTION [ ITEH^ARE GENERATED
2- CORRECT
[AND fOLLOWED UP [OCCURS AS PaRT OF [OUR BOI PROGRAM. [(CONTINUING A
[COMPLETE ) i
DEC [ ?.. ALTERNATIVES ABE [BEING [INVESTIGATED TO [INSURE THAT
NGC 12555
R(?|A ^CNH,-J
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\UDTT-PC 1..51
Vorkslioet
Coapajiy: BFCOODKICH facility: henry
Session: l OS-10-92
Revision: Q 10-26-92
Systes: S INDUSTBlAl HYGIENE MANAGEMENT
Category: RECOMMENDATIONS
Dwg<:
QUESTION
BEmaRES
RECOMMENDATIONS
c
3. THESE IS HOT A PORrtAL HEAT STRESS PROGRAM.
4. DOCUMENTATION POE INVESTIGATING STS'S WAS DISORGANIZED aND INCOMPLETE
. ADDRESS
SEVERAL EXIT SIGNS WERE NOT ILLUMINATED.
7
^COMPLETE EXIT SICN PROGRAM
prinatcch Ir.n.
Pag*: S
COMMENTS
.PERSONNEL ;are not exposured to \ greater THAN the pel :WITHOUT USE OF A ; respirator while *performing wore
V;JUNDER A YELLOW LIQBT. (WEC/RDM) <3/1/93. 7
DEG{3. a PLANT SAFETY *, POLICY WILL BE {ISSUED IDENTITYINC {THE CURRENT TRAINING ;program plus ;additional {ADMINISTRATIVE AND {EQUIPMENT CONTROLS.
?-;`{DZG) 6/1/33.
DEGi4. A PLANT PROCEDURE {WILL BE ISSUED 1IDENTIFYING THE iADMINISTRATION OF SSTS'S AND HEARING :becobdability. THE 1PROCEDURE WILL }INCLUDE THE {DOCUMENTATION JREQUIREMENTS. (DEG) 12/31/92/:------ 1---------- --
THE PRESENT 'PROGRAM TO REPLACE ;EXISTING EXIT SIGNS {THAT DO NOT MEET TH !ILLUMINATION {REQUIREMENTS WILL {COMPLETED ALONG WIT {THE AUDITING OP EXI {SIGNS THAT ARE {LOCATED ON THE {DOORS- SIGNS THaT Jam NOT VISIBLE WHEN {THE DOOR IS OPEN {WILL BE RELOCATED.
ry(DEC> 12/31/32.
0 10' ^Sbrl
c; I i.idn -1
NGC 12556
T tT : PI T PC. 1
r>nw
A.UDIT-PC 1.S1
Worksbeex
Prlaatech Inc.
Company: BPGCODKICH Eaeility: HENRY
Page: S
Session: 1 08-10-92
Revision: 0 10-26-92
System: S INDUSTRIAL HYGIENE MANAGEMENT
Category: RECOMMENDATIONS
Dwg#:
QUESTION
: a; REMAKES
RECOHMENDaTIONS
Pallets in pvc sack area SOWED.
ADDRESS
; by :
COMMENTS
ECTHE WOODEN '^PALLETS THAT WERE
JBOWINC IN THIS lAPPLICATION HAVE
;been taken oot or
SERVICE. IN ADDITION the super sacks are 'BEING STACKED IN A J MANNER SO THAT iINDIVIDUALS are not ;PHYSICALLY EXPOSED '.TO A SECOND LEVEL OP 4iBAGS COMPLETE)"}
;S/L4/92r^7
EYEUaSH STATIONS were 1CLEAN.
Each production WILL BE
;RESPONSIBLE POR THE CLEANING OF ISYEBATHS until THE :porcrlein EYEBaTHS ;can be changed out ;UITH MORE MODERN !NON-BOWL DESIGNS. (MEC/IDK) 12/31/32.
110* 30t)d
NGC 12557
BI UOMJ
2t?:0I 26.
n on