Document n8rnRORYKxbvKKZDRoJMMNy1

fo >/ ItA fl. 1 February 28, 1984 -rZj4>9' x l*,_ ., . . '^' Attached for your review is a copy of the final EIL risk assessment f.c^-- docjiment prepared by A. D. Little. In light of the delay in getting the material* rpm A. D. Little, the report has been forwarded to the insurance carrier with e caveat that additional minor points may have to be clarified. --1 6-s PMK/mr Attachment cc: L. Carothers V. C. Pelletier --^ Paul M. King 'EIVED I'rtRK 01B64 w. B. GRAYBILL 'but ZJu4 S&yS' ^ t^ jl^hAX. out (ruJz^btO j Q- SL 080105 (2^<J j/-_ /d /tc^-- s-A ffUCA /*HX_ l \/o -- /r>Ct?<7 for each location: 1- Inherent Risks - those associated with physical, chemical and toxicological properties of materials handled at the site along with consideration of physical location of the site. 2- Manageable Risks - these are risks that can be controlled by the way we operate our business. There is little that can be done about category 1. We do deal with Hazardous and toxic materials, i.e. chlorine, caustic, benzene, chlorinated hydrocarbons, phosgene, vinyl chloride, mercury, etc. In considering this aspect of our business, there is little doubt that Lake Charles ranks high. It handles large volumes of toxic materials in relatively close proximity to residential areas. The ranking of Beaumont is based upon past production of organic lead products. I would suspect that this ranking should drop considerably as cleanup efforts are completed and these materials removed from the plant. The limelakes at Barberton and salt and other potential contamination will keep the Barberton relative risk high. Reclamation and management of the limelakes may help some. A review of category 2 shows generally good management with some exceptions: 1. Inspection and monitoring programs related to leaks and fugitive emissions can be tightened. 2. Beauharnois particularly needs additional emphasis on inspection monitoring and also emphasis on SPCC. This was brought out by audits and is being addressed. 3. Spill containment programs implementing physical barriers to spills are not completely implemented at Natrium or Lake Charles.I I have a little trouble with the higher ranking assigned to Lake Charles. Perhaps some subjective weight has been given to the size of the operation. In my view, Beauharnois would have been at the top of the list. rOrm 503 A Rev 3/03 SL 080106