Document gaDXRNXa702De2kY7pKdpmBre

Memorandum Date: 4 August 1977 To: ur. J. K. Roper Unit: From: t . E_ Anderson Unit: Plant Manager - ICD - Philadelphia Subject: r ec eiv ed AU6 0 8 1977 sil ver Attached is a letter which I received from the OSHA Regional Administrator on 8/1/77 relative to our current petition for modification of abatement of our lead-in-air citation. Information is sought in four specifically listed areas. Regarding Item 1, the Philadelphia Plant Respirator Program was mailed to Ms. Eileen Crenshaw on 7/11/77. Regarding Items 2 and 3, the inspector did not request that we submit these data after the closing conference. Item 4 is a repetition of their request for urine porphyrin and blood lead data, which the inspector indicated was their sole basis for denying our petition. OSHA presently has until 8/19/77 to file objection to our petition. TEA/tle CCS Messers: W. E. Blair, D. W. Hurley, J. Jacobs, J. H. Paraskevas <J. Silvet) J. M. Stark, P. Warenski N 27300 NL 000041367 0 July 27, 1977 U.S. DEPARTMENT OF LABOR Oc c u p a t io n a l Sa f e t y a n d He a l t h Ad min is t r a t io n REGIONAL OFFICE --SUITE 2100 3535 MARKET STREET PHILADELPHIA, PA. 19104 t I Mr. Thomas Anderson, Plant Manager NL Industries 2607 E. Cumberland Street Philadelphia, Pa. 19125 Dear Mr. Anderson: Enclosed are the copies you requested of photographs taken 5/19/77 and 7/1/77 during our inspection for evaluation of your 3/22/77 Petition for Modification of Abatements (PMA). We have received the letter of 7/12/77 from your counsel, Jeffrey E. Silver. We understand your impatience with the length and depth of our evaluation. Nevertheless we must continue to pursue all the relevant information in this case. Accordingly, we are once again reiterating our request for the following information: A copy of the latest respirator program for the Philadelphia plant, shown to our Industrial Hygienist on 7/6/77 and promised\ to her by ydu. .2 Raw data for personal and area lead monitoring samples for Building 42, 2, 16 and 18 for June 1976 to date, refused our Industrial Hygienist on 7/6/77. 3. Copies of any written protocol used by your plant physician in determining those procedures to follow in providing medical surveillance and biological monitoring to lead workers, promised out Industrial Hygienist on 7/1/77 if they were found to exist. o J' ^ T 4. Results of urine porphyrin and blood lead measurement for lead workers in Buildings 42, 2, 16 and 28 for June, 1976 to date, again refused our Industrial Hygienist on 7/6/77. We base our right to this information on 29 CFR 1903.14 a(b)(4) which requires an employer requesting a PMA to outline "all available interim steps being taken to safeguard the employees against the cited hazard during-the abatement period." N 27300.01 NL 000041368 In your PMA you list use of respirators, air monitoring and "Compliance with OSHA's administration's published recommended lead control guidelines" as your interim steps. We remind you that our published "Guidelines for Controlling Occupational Exposures to Lead" include requirements for medical surveillance and- biological monitoring. Our intent is to assure that no employee will suffer harm due to our granting of an extention of your abatement date. We enlist your cooperation in achieving this goal. Sincerely yours. tDAVID H. RHONE Regional Administrator for Occupational Safety and Health NL 000041369