Document oDoDLd76yrpYKERX61yRVEbx3

r INTEROFFICE MEMORANDUM Date: From: Dept: Tel No: 23-Mar-1993 10:25am EDT Jan Suhay SUHAY, JAN D/5450 216 447-7690 TO: LAUBACHER, DAVE TO: DESJARDINS, ROBERT LAUBACHERDODPKlOOeMRGATE ) DESJARDINSR@DPK100@MRGATE ) cc: BOB GRAHEK GRAHEK, BOB ) Subject: WHO HAS IT? IS IT YOU OR DO I HAVE IT? YOUR INITIAL RESPONSE TO THE DEER PARK SAFETY AND HEALTH; INDUSTRIAL HYGIENE AUDIT, CONDUCTED ON NOVEMBER 9-12, 1992 SEEMS TO BE MISSING. IF YOU COULD FORWARD A COPY TO HERM WALTEMATE, THAT WOULD BE GREAT. THANKS MUCH, JAN CC: HERM WALTEMATE NGC 13232 Hygiene Items H-1992-5 We have completed monitoring for vinyl CHLORIDE, LEAD, DUST, TIN AND NOISE, OTHER EXPOSURES NEED TO BE MONITORED for. They are: a. Antimony b. Cadmium c. Chromium d. Titanium Dioxide Expected completion of the above monitoring is 4/93. H-1992-6 Establish a Cross Check Procedure for ANALYSIS OF ENVIRONMENTAL MONITORING Samples. Currently working with Lab to SET UP A PROCEDURE - EXPECTED COMPLETION - 6/93. H-1992-7 Develop a Written Program to comply with IH-204, ^Protection of Potable Water Supply"" and implement it. Expected completion - 12/93 F. ASBESTOS MANAGEMENT 1. Other than transite building siding, no known asbestos containing material is in the Deer Park Plant\ G. ADDITIONAL ISSUES 1. Flame retarotvnt work clothing - The majority of the Houston petrochemical industry working with HYDROCARBONS AND FLAMMABLE MATERIALS ARE CURRENTLY SUPPLYING FLAME WrARDANT CLOTHING. SHOULD THE DEER Park Plant elect do so we can expect the cost to be $70,000.00 - $80>000.00. 2. With the current Deer Park expansion project on hold, FUNDING WILL NOW BE REQUIRED TO BRING THE CURRENT VCM RECLAIM TANKS UP TO SA-132\C0MPLIANCE. APPROXIMATE COST $125,000.00. \ NGC 13233 INTEROFFICE MEMORANDUM Date: From: Dept: Tel No: 11--Jun--1993 11:16am EDT Jan Suhay SUHAY, JAN D/5450 216 447-7690 rO: DESJARDINS , ROBERT ( DESJARDINSR@DPK10 0 MRGATE ) CC: BOB GRAHEK ( GRAHEK, BOB ) subject: DRPK - AUDIT FOLLOW-UP BOB: JUST WANTED TO REMIND YOU THAT THE DEER PARK AUDIT FOLLOW-UP RESPONSE IS DUE JUNE 23RD. PLEASE FORWARD YOUR RESPONSE TO BOTH THE SAFETY AND HEALTH PLUS THE INDUSTRIAL HEALTH REPORTS TO HERM WALTEMATE. PLEASE ONLY INDICATE THE STATUS OF ITEMS NOT YET COMPLETE. THANKS MUCH, JAN. cc: Herm Waltemate NGC 13234 l A/oJ (IJGYV[ i*\ XX Items from 1990 IH-1990-1 Raw Materials are not all labeled with hazard information labeled. This is a divisional problem which is being handled now. You will be advised of actions required by your facility. This item will be designated as IH-1992-2. Ill. 1992 Items To Be Corrected IH-1992-1 For Information Only? Product specific MSDS were hot available for each vinyl resin and compound. This is an issue that is being corrected on a divisional level. As you receive Product MSDS you should continue to add them to the MSDS books in addition to updating the books index. IH-1992-2 OSHA 29 cfr 1910.1200 (f) (5), Hazard Communication, requires that each container of Hazardous Material be labeled. The following items must be corrected: a. Harco and Air Products PVA at the Solution Deck need to be Hazard Labeled. b. The Vinyl Reclaim Storage Tank should be-labeled the words "Vinyl Chloride". Please advise your time table for correction of these items. Response ro rf&fj t/v\(QeAT4 TV O Os<* J 0/0/0 4/ 7V/& Status Complete In-progress No Action deg 12/10/92 auditdp.92f/4 IH-1992-3 fV',/ .f Av" * Vv V Although your Respirator Program is very good we found a chlorine escape mask, on the first level,and several half masks, in the Poly Control Room, that need to be properly cleaned or stored. Response Status Complete Xn-progress No Action 1H-1992-4 IH-101 "Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard KST--411M gives engineering and design standards for ventilation equipment. This item could be added to your . maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response deg 12/10/92 audltdp.92f/5 Status Complete In-progress No Action NGC 13236 IH--1992--5 Although you have done, an excellent job of monitoring for^virtyl chXbride, lead^^dust, tin and noise, a number of other exposures need to^be monitored for. They are: a. b. c. \d. Antimony Cadmium Chromium Titanium Dioxide \ \ J / Please^ads^ise your time, thble for completing this item and when itTTras- LreeTT'completed. Response on A/ gi-f /jHC fcC/tf/tC/fL >"9. op/graf Status Complete In-progress No Action IH-1992-6 You need to establish a Cross Check Procedure for analysis of Environmental Monitoring Samples. Please advise when this procedure has been implemented. Response ANA 6*U-CK?Vi ^^6 /*4 C UlA ret yfrt/h 'o //yr/ J-/1& -- AgoJj . C.Nea< deg 12/10/92 auditdp.92f/6 Status Complete In-progress No Action NGC 13237 IH--1992--7 You must develop a Written Program to comply with IH--2 04 r "Protection of Potable Water Supply" and implement it. You have your water sources marked as "Water". The systems should be marked "Non-Potable Water" or "Factory Water" in order to minimize the likelihood of human consumption. Please advise when the program has been written and when it has been implemented. Response ricrt - /rxtvf * Status Complete In-progress No Action IH--1992--8 *W *9 $ A The ventilation in the Lab Hood has been checked and the hood is labeled correctly. The Hood however needs to be detuned to 100 fpm maximum face velocity. Response tz ~ s*v9*+'T/s//9/sCc: ////rsti-C. ___________ deg 12/10/92 auditdp.92 f/7 Status Complete In-progress No Action NGC 13238 ------------ II. Items from 1990 IH Audit; ---------_______ IH-1990-1 Raw Materials are not all labeled with hazard information labeled. This is a divisional problem which is being handled now. You will be advised of actions required by your facility. This item will be designated as IH-1992-2. Ill. 1992 Items To Be Corrected IH--1992-1 For information Only: Product specific MSDS were not available for each vinyl resin and compound. This is an issue that is being corrected on a divisional level. As you receive Product MSDS you should continue to add them to the MSDS books in addition to updating the books index. IH-1992-2 OSHA 29 CFR 1910.1200 (f) (5), Hazard Communication, requires that each container of Hazardous Material be labeled. The following items must be corrected: a. Harco and Air Products PVA at the Solution Deck need to be Hazard Labeled. b. The Vinyl Reclaim Storage Tank should be labeled the words "Vinyl Chloride". Please advise your time table for correction of these items. Response /H/fii!i-t/lf tC /yc'trOJ S~0 tT/^CCir'y ~F& r~v L S is/Q/S C* /j ~ co/n/)t-f/6 A- Status Complete In-progress No Action deg 12/10/92 auditdp.92f/4 NGC 13239 IH--1992--3 Although your Respirator Program is very good we found a chlorine escape mask, on the first level,and several half masks, in the Poly Control Room, that need to be properly cleaned or stored. Response OH - &o//* 6 -- ~ (jif o/y ccf/SLr t_______L seettfitAnroA C**Tj Status Complete In-progress No Action IH--1992--4 IH-101 "Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard "ST-411" gives engineering and design standards for ventilation equipment. This item could be added to your maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response ///a* fd t * lag vcnn^rto sa flm sSifSre-Ai-_____ o/v t/c <L<s/**i:Air l y on T?os>f /? deg 12/10/92 auditdp.92f/5 Status Complete In-progress No Action NGC 13240 IH-1992-5 Although you have done an excellent job of monitoring for vinyl chloride, lead, dust, tin and noise, a number of other exposures need to be monitored for. They are: a. Antimony b. cadmium c. Chromium d. Titanium Dioxide Please advise your time table for completing this item and when it has been completed. Response Mf Jty /?? ~ iSvtfsyu fT& o /y />Ais/a Oj /tesv^rs /s /v&/>&/) . cs? __________ '' Status Complete In-progress No Action IH-1992-6 You need to establish a Cross Check Procedure for analysis of Environmental Monitoring Samples. Please advise when this procedure has been implemented. Response Cosn/0 to /??$ - VC.SYI &is/ L-L 4N0 sn/> t HJTN fT~ fo/} CAAGPS*sSf <2rtCf< /ttfA 4-^Jsi jfis</crs usi xruA/mneTr oN />46\/ioy-i A&oojpXi . yc *}Ut&r p6&UL.rif deg 12/10/92 auditdp.92f/6 Status Complete In-progress No Action IH--1992--7 You must develop a Written Program to comply with IH--204, "Protection of Potable Water supply" and implement it. You have your water sources marked as "Water". The systems should be marked "Non-Potable Water" or "Factory Water" in order to minimize the likelihood of human consumption. Please advise when the program has been written and when it has been implemented. Response *UArA Antd~ AA4> rc/i #\ f rrlra syi/QL&S 7~CA/\j jose s^o c at 7/ ft f ~ ?Q ~ 7 Status Complete In-progress No Action IH--1992-8 The ventilation in the Lab Hood has been checked and the hood is labeled correctly. The Hood however needs to be detuned to 100 fpm maximum face velocity. Response deg 12/10/92 auditdp.92 f/7 Status {/_______ Complete __________ In-progress _____ No Action NGC 13242