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 'IT- PC 1.51 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 r~ C* r? HI A^e/ y4 e7*/*> A / a/t 7 ^ l-va <uJ >'.ZA rO iJrrrt NGC 12551 AUDIT-PC 1.51 Vorks.hee'; Primatecfi Inc- Company: BFGOODRIch Facillxy: HENRY 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 r: i i i n vi j \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