Document mMyyX5jbKDgnxQVbBwRM0j7k

SUMMARY OF OSHA/EPA INSPECTION QUESTIONNAIRE The following is a summary of the 26 responses to the OSHA/EPA Inspection Questionnaire: 1. Do you have, for your supervisors and other employees, a written set of guidelines for use when a regulatory agency inspector arrives at the plant gate? Yes 15 No 11 2. Have you had either an OSHA or EPA inspection of your plant in the past 12 months: OSHA 10 EPA 18 None 7 3. If you had an OSHA inspection was it regarding the VCM standard or was it involved with another area? a. VCM standard (five responses) b.. VCM, noise, heat, dust lead c. General - triggered by employee complaint *t. If you had an EPA inspection, was it regarding NESHAPS-VCM or was it about something else? Typical response: a. NESHAPS b. NPDES permit c. Hazardous waste - RCRA d. Permit to burn coal e. Landfill permit f. Incinerator operation g. PCB's h. PVC dust i. Safety relief valve discharges 5. Did you receive any citations or notices of violation? If you wish, could you please describe the nature of the violation? Typical response: a. Notice of violation - improperly labelled PCB tank b. No violation but not satisfied with aqueous effluent sampling procedure c. Two OSHA citations on record keeping - one invalid - the other due to math error in number of injuries reported OCC 3041 Page Two Summary of OSHA/EPA Inspection Questionnaire d. OSHA citations: Inadequate maintenance on area monitoring equipment and working in an area with greater than 5 ppm VCM, not wearing respirator e. OSHA - serious and fine; other and no fine f. OSHA - High VCM levels in reactors during cleaning - no respirator g. Incomplete compliance with VCM opening loss regulations and non-compliance with relief valve emissions even though all emissions were reported correctly and on time. 6. Could you give a brief summary of your recent experience with an OSHA or EPA inspection? Typical reponse: a. OSHA inspection included 3 days of personnel monitoring for VCM and 1 day of PVC dust monitoring and other visits to the plant b. EPA was in the area and noticed black smoke from the incinerator stack and demanded an immediate inspection of the facility. We obliged and corrected the problem also sent a letter to the EPA explaining the problem. 9/18/81 I OCC 3042