Document npDE14YVQ9aj7MvoG7gw9vpNG

c U-J rys December 30, 1992 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown Safety Audit - October 5-9, 1992 Attached is our first audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. Our next progress report is due by 3/31/93. All items will be completed by October, 1993. cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMiIlian Carl Stolfo Ron Szmerda Bill Wagner Tom Worrel 1 I (So A\ p PFDRICKTOWN SAFE IY AUDI I OCTOBER 5-9, 1992 1 992 It ems t o _B e _ Co rrect e d SA-1992-1 A management system for the auditing of individual employees with regard to Lockout, Hot Work, Vessel Entry and Forklift Trailer Entry needs to be established. These audits need to be documented. The individual lockout audits are a requirement of OSHA Standard 1910.147 Control of Hazardous Energy (Lockout/Tagout). Plant Response A system for auditing and documenting compliance with the cardinal safetv rules currentlv exists in the Dispersion area. Similar systems are being developed in the Compound and Suspension areas and will be in place bv 2/28/93. The Safety Department will audit each area to insure their svsterns are working. Status Completed X___ In-Progress Incomplete SA-1992-2 In reviewing the Compound Department's mill drill documentation, only 14 were found for 1992. Also weekly check of stopping distance could only be found for these 14. In reviewing the Laboratory's mill drill documentation, all shifts were not conducting monthly drills. BFG GVD Standard SA-113 requires that mill drills be conducted once per month by each shift and a check on stopping distance be conducted weekly on each mill. You need to comply with these requirements, Plant Response Systems and procedures have been revised in both the Com pound and Laboratory areas to assure compliance with GVD Standard _SArJ_1 3_. Status ____X_.._ Completed ______ In-Progress Incomplet e In 1991 we had a potential for a serious accident at the Terre Haute plant when the kneader closure bolt on a Buss Extruder failed and was projected out with great force nearly striking a supervisor. The design of the newer Buss Extruders has been modified to prevent this accident. You need to construct a metal guard to cover this closure bolt or verify that your Buss has the modified design. The design of this guard can be obtained through Mike DeMent of Terre Haute. PI ant Response We contacted Terra Haute and were told that their old Buss machines had the problem with kneader closure bolts. The current Buss design, to which ours is built, has simi1ar bolts but additional wedge brackets on top and bottom for added reinforcement to prevent stress on closure bolts. We will purchase a torque wrench for routine operations and wi 11 consider replacing the bolts on the kneader and the RS screw on a routine PM basis. Will review with Bob Jordan to get additional support/suggestions to prevent anv fail- ures on our machine. Status Completed X In-Progress ________ Incomplete SA-1992-4 In 1981 Avon Lake experienced a lid blowing off a fresh VCM filter when the washers bowed and the hold down ears spread apart. I have sent a copy of this narrative report to Dennis O'Keefe. During the plant safety inspection, three retainers or cotter pins were observed missing on VCM strainers in the Suspension Area and at least 10 retainers were missing on a VCM recovery strainer in the Dispersion Area. These hold down devices in VCM service need to be corrected and a PM program established to prevent a reoccurrence. PI ant Response Maintenance work orders were written to inspect and correct hold down bolts on strainers in VCM service. PM's have been written to inspect and repair these on an annual basis. _____________ Status X_ Compl etcd In-P rogress Incomp 1et e SA-1932-9 A partially filled out Safe Work Permit for a contractor was noted on a Project Engineer's desk. The permit was pre-dated for the following week. I do not have a problem with filling in some of the permit sections, but the signature indicating that hazard communications has been completed at the job site is not to be signed until aft er that communication has been conducted. Plant Response The individual who wrote and ore-signed the hazard commun ication section on the Safe Work Permit has been counseled on the importance of signing the permit after all require ments have been met._________ ________________ _ St at us X Completed ________ In-Progress _________ Incomplete SA-1992-6 In 1992 the GVO/SP&C Divisions have experienced several recordable injuries involving second degree burns. Currently, second degree burns make up 23 percent of our total recordable cases. All plants are being-urged to inspect for hot surfaces (140F) which might cause burns and take preventive measures. You need to audit the plant for hot surfaces and proceed with insulating, guarding or post warning signs. Plant Response A plant audit for hot surfaces will be conducted bv the end of the second quarter. '93. Status Comp 1et ed X In-Progress Incomp 1et e SA 199 ?- 7 A management tracking system which assures implementation and closure of all safety concerns needs to be established. This tracking system should include issues identified in such areas as: PI ant Response PHA (HAZOP's) Hazard Research. Inc., Inspections IR1 Inspections New Jersey Fire Marshal Inspections Corporate/Division Safety Audits Various tracking systems currently exist for the many types of inspections, audits, consent agreements, and internally generated corrective action plans. We have no plans to consolidate all of these into a single management tracking system. We will continue to evaluate and fine tune these systems to insure that all identified safety issues are brought to closure . ______ ______ Status X Completed ________ In-Progress ________ Incomplete SA-1992-8 OSHA recently issued a Directive covering Management of Highly Hazardous Chemicals, comments on the potential hazards such as of impact. 1910.119 The directive pipework in risk I would suggest a review be made of all your piperacks crossing plant roadways. This should include the support st ructure. Plant Response A review of all piperacks crossing roadways will be com pleted by 3/31/93.__________ ___ ________ St atu_s ___ Comp 1 et ed In-Progress _____X___ Incomplete NOO 12743 With some of the recent rnajot fires and explosions, the importance of a safe exit from the workplace is brought out. All of your exits need to be properly identified and illumination provided as required by QSHA Standard 1910.37(q)(6). Each of your fenceline gates need to be marked as an exit, emergency exit, not an exit or be identified with its actual character (function). The fenceline emergency exits need to be unimpeded and be identified in you plant evacuation procedure. PI ant Response A plan to comply with this item is being developed and will be completed by 1/31/93. Status Completed X In-Progress Incomplet e SA-1992-10 Lockout clips have become available for locking out 110/120 volt circuit breakers. You should obtain these lockout clips from the manufacturer of your electrical panels and require individual circuits be locked out when work is to be performed on them. Plant Response Our maintenance electrical engineer has been requested to spec and purchase lockout clips for the various types of 110/120 volt circuit breakers in the Diant-. Once clips are available, our lookout procedure wi 11 be modified to reauire their use. To be completed bv 3/31/93. S tjLt_u s Complet ed X In-Progress Incomp 1et e SA-1992-11 During the plant inspection tour a maintenance employee observed cleaning a control valve with air at line pressure. Compressed air used for cleaning needs to be reduced to 30 p.s.i., provided with chip guarding and require personal protective equipment. was PI ant Response An OSHA approved air nozzle was installed at this air cleaning station and the employee involved was counseled. Status X Completed ________ In-Progress ________ Incomplete SA-1992-12 The Pedricktown Community Fire Department is beginning to get involved in training their personnel in HAZMAT training. 1 would suggest that consideration be given to providing them with a computer program which gives hazardous chemical information and chemical spill dispersion modeling such as CAMEO. You may also wish to help set it up and provide training in the proper use. PI ant Response We discussed this subject with the chief of the Pedricktown fire company and he expressed interest in having a computer program like CAMEO available for use by the township. We wi 11 proceed with this recommendation. Complet e bv 6/30/93 Status Completed X __ In-Progres Incomplete fi'ir-i iv\ J'S *t March 31, 1993 To : te ^ C1 eve I and From: Bill Fultz Pedricktown Subject: Pedricktown Safety Audit - October 5-9, 1992 Attached is our second audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. Our next progress report is due by 6/30/93. All items will be completed by October, 1993. & LU cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel Al Matyger Ed McKinley Art McMiIlian Dennis 0*Keefe Carl Stolfo Bill Wagner Tom Worre11 -y Q /n ( 2- D PEDRICKTOWN SAFETY AUDIT OCTOBER 5-9, 1992 1_9 9 2 Items to B e Cor r ected SA-1992'1 A management system for the auditing of individual employees with regard to Lockout, Hot Work, Vessel Entry and Forklift Trailer Entry needs to be established. These audits need to be documented. The individual lockout audits are a requirement of OSHA Standard 1910.147 Control of Hazardous Energy (Lockout/Tagout). P1 ant Response A system for auditing and documenting compliance with the cardinal safety rules currently exists in all three manufacturinc areas. The Safetv Department wi11 audit each area to insure their systems are working. St omp1e ted In-Progress Incomplete SA-1992-2 In reviewing the Compound Department's mill drill documentation, only 14 were found for 1992. Also weekly check of stopping distance could only be found for these 14. In reviewing the Laboratory's mill drill documentation, all shifts were not conducting monthly drills. BFG GVD Standard SA-113 requires that mill drills be conducted once per month by each shift and a check on stopping distance be conducted weekly on each mill. You need to comply with these requirements. Plant Response Systems and procedures have been revised in both the Com pound and Laboratory areas to assure compliance with GVD Standard SA-i 1_3_._ _ / Status Comp 1e t ed In-Progress ncomp1ete SA-1992-3 In 1991 wc had a potential for a ser i o u s a c e i dent at the Terre Haute plant when the kne ade r c I osure bo 1 t on a Bus s Extruder failed and was pro jec ted out with gr eat f orce nearly striking a superviso r . Th e de sign of the n ewer B u s s Extruders has been modified to pr even t L 11 i s a ccide n t . You need to construct a met a 1 gua id t o cover this c 1 osur e bolt or verify that your Bu ss has t he modifie d des ign . The design of this guard can be ob t a i ned t hrough Mike DeMent of Terre Haute. Plant Response We contacted Terra Haute and were told that their old Buss machines had the problem with kneader closure bolts. The current Buss design, to which ours is built, has similar bolts but additional wedge brackets on top and bottom for added reinforcement to prevent stress on closure bolts. We will purchase a torque wrench for routine operations and will consider replacing the bolts on the kneader and the RS screw on a routine PM basis. Will review with Bob Jordan to get additional support/suggest ions to prevent anv fail- ures on our machine. To be completed bv 4/30/93 4 Status ___ Completed In-Progress Incomplete SA-1992-4 In 1981 Avon Lake experienced a lid blowing off a fresh VCM filter when the washers bowed and the hold down ears spread apart. I have sent a copy of this narrative report to Dennis O'Keefe, During the plant safety inspection, three retainers or cotter pins were observed missing on VCM strainers in the Suspension Area and at least 10 retainers were missing on a VCM recovery strainer in the Dispersion Area. These hold down devices in VCM service need to be corrected and a PM program established to prevent a reoccurrence. Plant Response Maintenance work orders were written to inspect and correct hold down bolts on strainers in VCM service. PM's have been written t_o inspect and rep a i r these on an annual basis.__________________________________ ____ _______________________________________________ Completed I n-Progress Incomp1e t e SA-1992-5 A partial Ly filled out Safe Work Permit for a contractor was noted on a Project Engineer's desk. The permit was pre-dated for the following week. I do not have a problem with filling in some of the permit sections, but the signature indicating that hazard communications has been completed at the job site is not to be signed until after that communication has been conducted. Plant Response The individual who wrote and pre-signed ication section on the Safe Work Permit on the importance of signing the permit ments have been met.___________________ the hazard commun has been counseled after all require In-Progress ___________ Incomplete SA-1992-6 In 1992 the GVD/SP&C Divisions have experienced several recordable injuries involving second degree burns. Currently, second degree burns make up 23 percent of our total recordable cases. All plants are being urged to inspect for hot surfaces (140F) which might cause burns and take preventive measures. You need to audit the plant for hot surfaces and proceed with insulating, guarding or post warning signs. Plant Response A plant audit for hot surface/ will be of the second quarter inducted by the end Status _______ Comp 1e ted X___ In-Progress Nor 12749 SA-1992-7 A management tracking system which assures implementation and closure of all safety concerns needs to be established. This tracking system should include issues identified in such areas as: Plant Response PHA (HAZOP's) Hazard Research. Inc., Inspections IRI Inspections New Jersey Fire Marshal Inspections Corporate/Division 15afety Audits Various tracking systems currently exist for the many types of inspections, audits, consent agreements, and internally generated corrective action plans. We have no plans to_______ consolidate all of these into a single management tracking system. We will continue to evaluate and fine tune these systems to insure that a_ll identified safety issues are brought to closure. Comp 1et ed 1n-Progress Incomp1et e SA- 1992-8 OSHA recently issued a Directive covering Management of Highly Hazardous Chemicals, comments on the potential hazards such as of impact. 1910.119 The directive pipework in risk I would suggest a review be made of all your piperacks crossing plant roadways. This should include the support structure. Plant Response A review of all piperacks crossing roadways has One bv the maintenance shoo and two bv the tank by guarded by the end of the third quarter. ^-- L- 1 " been farm done will S t a tus Comp 1e t ed In-Progress Incomp1e t e ''JGC 12750 SA-1992-9 With some of the recent, major fires and explosions, the importance of a safe exit from the workplace is brought out. All of your exits need to be properly identified and illumination provided as required by OSHA Standard 1910.37(q)(6). Each of your fenceline gates need to be marked as an exit, emergency exit, not an exit or be identified with its actual character (function). The fenceline emergency exits need to be unimpeded and be identified in you plant evacuation procedure. Plant Response Fenceline gates have been properly identified. Emergency exits are unimpeded and identified in the evacuation orocedure. We are trying to find an acceptable and economical way to identify other exits with Herman's inout. Should have this resolved and implemented by the end of the second quarter. Status Completed In-Progress Incomplete SA-1992-10 Lockout clips have become available for locking out 110/120 volt circuit breakers. You should obtain these lockout clips from the manufacturer of your electrical panels and require individual circuits be locked out when work is to be performed on them. Plant Response Lockout clips have been purchased and our lockout procedure has been modified to require their use effective 5/1/93. In-Progress Incomplete NOC 12751 SA- 1 992-1 1 During the plant inspection tour a maintenance employee observed cleaning a control valve with air at line pressure. Compressed air used for cleaning needs to be reduced to 30 p.s.i., provided with chip guarding and require personal protective equipment. was Plant Response An OSHA approved air nozzle was installed at this air c1eaning station and the employee involved was counseled. S Completed In-Progress Incomplete SA-1992-12 The Pedricktown Community Fire Department is beginning to get involved in training their personnel in HAZMAT training. I would suggest that consideration be given to providing them with a computer program which gives hazardous chemical information and chemical spill dispersion modeling such as CAMEO. You may also wish to help set it up and provide training in the proper use. Plant Response We discussed fire company program like will proceed this subject with the chief of the Pedricktown and he expressed interest in having a comtrut-eJL CAMEO available for use by the township with this recommendation. Complete fry 6/30/93 Status Comp 1e t ed rogres s Incomplete NGC 12752 hfuJ kj<y fH /T) /r^ ZT$ June 30. 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown Safety Audit - October 5-9, 1992 Attached is our third audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. Our next progress report is due by 9/30/93. All items will be completed by October, 1993. cc: Joe B'lackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell PEDRICKTOWN SAFETY AUDIT OCTOBER 5--9, 1992 1992 Items to Be Corrected SA--1992--3 In 1991 we had a potential for a serious accident at the Terre Haute plant when the kneader closure bolt on a Buss Extruder failed and was projected out with great force nearly striking a supervisor. The design of the newer Buss Extruders has been modified to prevent this accident. You need to construct a metal guard to cover this closure bolt or verify that your Buss has the modified design. The design of this guard can be obtained through Mike DeMent of Terre Haute. Plant Response We contacted Terra Haute and were told that their old Buss machines had the problem with kneader closure bolts. The current Buss design, to which ours is built, has similar bolts but additional wedae brackets on top and bottom for added reinforcement to prevent stress on closure bolts. A torque wrench has been purchased for routine operations and a PM has been set up to inspect the kneader bolts and re place as required. Since our Buss is built to the newer design, no futher guarding is planned. Status X Completed __________ Xn-Progress __________ Incomplete SA-1992-6 In 1992 the GVD/SP&C Divisions have experienced several recordable injuries involving second degree burns. Currently, second degree burns make up 23 percent of our total recordable cases. All plants are being urged to inspect for hot surfaces (140F) which might cause burns and take preventive measures. You need to audit the plant for hot surfaces and proceed with insulating, guarding or post warning signs. Plant Response A plant audit for hot surfaces will be conducted bv the end of the third quarter, 893. Status Completed X___ In-ProgressIncomplete NGC 12754 SA-1992-8 OSHA recently issued a Directive covering 1910.119 Management of Highly Hazardous Chemicals. The directive comments on the potential hazards such as pipework in risk of -impact. X would suggest a review be made of all your piperacks crossing plant roadways. This should include the support structure. Plant Response A review of all piperacks crossing roadways has been done. One bv the maintenance shop and two by the tank farm will bv guarded bv the end of the third quarter. Status Completed X In-Progress Incomplete SA-1992-9 With some of the recent major fires and explosions, the importance of a safe exit from the workplace is brought out. All of your exits need to be properly identified and illumination provided as required by OSHA Standard 1910.37(g)(6). Each of your fenceline gates need to be marked as an exit, emergency exit, not an exit or be identified with its actual character (function). The fenceline emergency exits need to be unimpeded and be identified in you plant evacuation procedure. Plant Response Fenceline gates have been properly identified. Emergency exits are unimpeded and identified in the evacuation proce dure. We have identified a more economical solution to the labelling of other exits and are awaiting word from the NJ fire inspectors office on their acceptability. To be com plete bv the end of the third quarter. Status Completed _______________X___ In-Progress Incomplete NGC 12755 SA--1992-12 The Pedricktown Community Fire Department is beginning to get involved in training their personnel in HAZMAT training. I would suggest that consideration be given to providing them with a computer program which gives hazardous chemical information and chemical spill dispersion modeling such as CAMEO. You may also wish to help set it up and provide training in the proper use. Plant Response We discussed this subject with the chief of the Pedricktown fire company and he expressed interest in having a computer program like CAMEO available for use bv the township. A new computer has been purchased and the software has been ordered to complete this item. Status Completed X___ In-Progress Incomplete INTEROFFICE MEMORANDUM Date: From: Dept: Tel No: 13-Sep-1993 04:31pm Jan Suhay SUHAY, JAN D/5450 216 447-7690 EDT TO: KASWELL, GREG TO: OKEEFE, DENNIS ( KASWELLG@PED2 6 @MRGATE ) ( OKEEFED@PED26MRGATE ) CC: BOB GRAHEK ( GRAHEK, BOB ) Subject: PEDRICKTOWN AUDIT RESPONSE DUE THIS IS JUST A REMINDER, YOUR FOLLOW-UP AUDIT RESPONSE IS DUE TO HERM WALTEMATE BY SEPTEMBER 30, 1993. THANKS MUCH, JAN CC: HERM WALTEMATE NGC 12757 September 30, 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown, Safetyt^dit - October 5-9, 1992 Attached is our fourth audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. Our next progress report is due by 10/31/93. All items will be completed by then. cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell NGC 12758 PEDRICKTOWN SAFETY AUDIT OCTOBER 5-9, 1992 1992 Items to Be Corrected SA--1992--6 In 1992 the GVD/SP&C Divisions have experienced several recordable injuries involving second degree burns. Currently, second degree burns make up 23 percent of our total recordable cases. All plants are being urged to inspect for hot surfaces (140F) which might cause burns and take preventive measures. You need to audit the plant for hot surfaces and proceed with insulating, guarding or post warning signs. Plant Response The plant audit for hot surfaces will be conducted bv the end of October.___________________________________ ____ Status Completed X In-Progress Incomplete SA-1992--8 OSHA recently issued a Directive covering Management of Highly Hazardous Chemicals. comments on the potential hazards such as of impact. 1910.119 The directive pipework in risk I would suggest a review be made of all your piperacks crossing plant roadways. This should include the support structure. Plant Response A review of all piperacks crossing roadways has been done. One bv the maintenance shop and two bv the tank farm will bv guarded bv the end of October. Status Completed X In-Progress Incomplete NGC 12759 SA--19 9 2 -- 9 With some of the recent major fires and explosions, the importance of a safe exit from the workplace is brought out. All of your exits need to be properly identified and illumination provided as required by OSHA Standard 1910.37(q)(6). Each of your fenceline gates need to be marked as an exit, emergency exit, not an exit or be identified with its actual character (function). The fenceline emergency exits need to be unimpeded and be identified in you plant evacuation procedure. Plant Response Fenceline gates have been properly identified. Emergency exits are unimpeded and identified in the evacuation proce dure. The more economical approach for illuminated exit signs in other plant areas did not meet state and NFPA re quirements. A plan has been developed to reach full com pliance bv the end of 1994. Will concentrate on most critical areas first. Status X Completed __________ In-Progress __________. Incomplete SA--1992--12 The Pedricktown Community Fire Department is beginning to get involved in training their personnel in HAZMAT training. I would suggest that consideration be given to providing them with a computer program which gives hazardous chemical information and chemical spill dispersion modeling such as CAMEO. You may also wish to help set it up and provide training in the proper use. Plant Response Computer and CAMEO program have been presented to the______ Pedricktown fire company. Training underway. Status _____X__ CompletedIn-Progress __________ Incomplete NGC 12760 HERM WALTEMATE BOB GRAHEK TTTtrT' MAR^TTATiT, JAN SUHAY November 1, 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown SafetyAudit October 5-9, 1992 Attached is our fifth audit progress report. It gives the status of the items that you identified during the October as requiring attention. Our final progress report will be submitted when the last remaining item is completed. audit 2 cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel Al Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell PEDRICKTOWN SAFETY AUDIT OCTOBER 5-9, 1992 1992 Items to Be Corrected SA--1992-6 In 1992 the GVD/SP&C Divisions have experienced several recordable injuries involving second degree burns. Currently, second degree burns make up 23 percent of our total recordable cases. All plants are being urged to inspect for hot surfaces (140F) which might cause burns and take preventive measures. You need to audit the plant for hot surfaces and proceed with insulating, guarding or post warning signs. Plant Response The plant audit for hot surfaces was conducted. Results have been forwarded to each area for corrective action. Status X Completed __________ In-Progress __________ Incomplete SA-1992-8 OSHA recently issued a Directive covering Management of Highly Hazardous Chemicals. comments on the potential hazards such as of impact. 1910.119 The directive pipework in risk I would suggest a review be made of all your piperacks crossing plant roadways. This should include the support structure. Plant Response A piperack guard has been installed bv the maintenance______ shop. A purchase order has been written and the contract is being let to install two guards at the tank farm piperack. Should be done bv the end of November. Status Completed X In-Progress Incomplete NGC 12762 December 30, 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown Safety Audit - October 5-9, 1992 Attached is our final audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. All items have been completed. cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell NGC 12763 PEDRICKTOWN SAFETY AUDIT OCTOBER 5-9, 1992 1992 Items to Be Corrected SA--1992-8 OSHA recently issued a Directive covering Management of Highly Hazardous Chemicals. comments on the potential hazards such as of impact. 1910.119 The directive pipework in risk I would suggest a review be made of all your piperacks crossing plant roadways. This should include the support structure. Plant Response A piperack guard has been installed bv the maintenance shoo. Two ciuards have been installed at the tank farm nine-rack. This item is comolete. Status X Completed In-Progress Incomplete NGC 12764