Document rp0E7yXynYQXbKv5Vam8Dzn5J

To: Mr. Jeff Silver Fro(K O- W. Harley Subject Internal' Memorandum Date: x jun 1977 Unit: ICO - New York Unit. Plant Manager -- Philadelphia. - '------ Jeffs Attached ate documents we discussed in our telephone conversation of 6/1/77 which relate to the OSSA inspection of flay 19 and 25, 1977. To date we have not had a closing conference. Docusants attached* a) Original' citation dated December 22, 1975. f hi Extension #1 dated 3/22/7T for 9 deaths. c) Notification that citation is due to be answered. d) Extension request for #2 - dated 3/14/77. s) Receipt of extension from OSH& dated 3/28/77. f!, Secretary's Motion for an Enlargement of Tine - 4/4/77. g} Secretary's Motion for an Enlargement of Tina - 5/16/77. / h> Request from Area Director for specific infcreation - dated 5/26/77. DKH/tie cc: ST, ., Anderson A. Snitfa R. oath / N 27315 ML 000041420 .- ...s ~ > . J. u US. OEPAaTOESITOF LABOR QCOfbATKiJiAi-SAFETY AND HEALTH AOMrtWSTftATtQM OMjKWKMI This form is pfowdsd foe the assistants of any complainam and is not intended tn ccmstitots tits sxdusiv* means by which a complaint may be registered with the U.S, Department of Labor. Sec. 8(8(11 of the ViUfiami-Steigar Occupational Safety and Health Act. 23 UJS.C. 6St. provides as follows: Any employees or representative of employees who believe that a violation of a safety or health standard exists that threatens physical harm, or that an imminent danger exists, may su*st an inspection by giving notice to tire Secretary or his authorised representativeof such violation or danger- Any such notice shall b* reduced to writing, shall set forth with reasonable particularity tire grounds for she notice, and shall be signed by the employees or representative of employees, and a copy shall be provided the employer or his agent no later than st the time of inspection, except that, upon request of the person giving such notice, his name and the names of SndrvMuaJ empioyMs referred to therein shaili not appear in such copy or on any record published, released, or made available pursuant to subsection fgl of this section. If upon receipt of such notification tn* Secretary determines there are reasonable grounds to believe th3t such violation or danger exists, be dal! make a special inspection in accordance with tile provisions of tills section as soon as practicable, to datanrine if such violation or dangler exists. If the Secretary determines there are no reasonable grounds to believe that a vitiation or danger exists he shall notify the employees or representative of the employees inwriting of such determination. ~'!OTE: Section 11 {c} of the Act provides explicit protection for employees exercising their rights, including making safety ard health complaints.' The undardsgied IfcAasSr er*l D Employee IS Representative of employees n Other fawer'fy/; baileys* that a violation at the foficrwiog pla of employment of an occupational safety or health standard exists which is a job safety or health hazard. Employer's flam*KI. Industries___________________________________________ ____________________________ Address itw Cumberland' Street:Telephone. 423-0600 i. (CityEltiladalrhia .......... State PA ________________ ZipCode JLS125 1. VTinri nf I--Jr'w. piroductioa of lead cospaunds 2. Specify the particular building or worksitewhere the alleged violation is located, including address._________________________ abpya locati-oa_____ .________ ;_____________________________________ _______________________________________ 3. Specify the name end phone number of employer's agentfs) in charge. X Describe briefly the hazard which exists there including the approximatenumber of employees exposed to or threatened by such h3tard. 9 Employees are overexposed to lead due to poor housekeeping. and faulty respirator usage._,,__________________________________;____________________________________ N 27315.01 NL 000041421 (Continue on revets? side if t&ces. 5. Utt by number and/or name the particular standard (or standi/ds) issued by the Departmentof Lehor which you tfaim ha bom violated, 3 known. 6. (a) To your knowledge he* Ibli Violation been considered previously by any Governmentagency?. (b) If so, please statu the nameof the agency (cl and, this appropriate date it was cnnsidvred. 7. U) Is this complaint;. ora complaintaUtfginy a similar violation, being fi!d with any other Government agency? (0) It so, give the nasne and address of each. 8. (s) To yowr knowledge, has dutwobtion been die subject of any union/managemvnr grievance or have yoo (ot-anyone yen know) otherwise tailed it to theattention of, or discussed itwith, the employer or any representative thereof?__________ _______ (b! if so, please give the resultsthereof, including any efforts by managemtnt to comet the violation. 9. Please indicate yosw desire: i do not want my name revealed to the employer. 3SX My name may be revealed to the employer. COMPLAINANT'S NAME MOTE: IT IS UNLAWFUL 70 MAKE ANY FALSE STATEMENT, REPRESENTATION OR CERTIFICATION IN ANY OQCUMEN FILED PURSUANT TO THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970. VIOLATIONS CAN EE PUNiSH&t BY A FINE OF NOT MORS THAN StAOOO. OS BY IMPRISONMENT OF NOT MORE THAN SIX MONTHS. OR BY BQTf {Section 17{gll Signature________________________ ________ Typed or Printed Name George Salrgo Address (Street___________ _____________ { {City___________________________ If you are an authorisedrcprcsinaaVs of Hi'S itgitic gi yvut w>a'SnieoH'yts itu yyut mu*. Date. _____________________Telephone_______ ______________ JizanZip Code' _______________________________ ..J. NL 000041422 CITATUM*1 nr Harry S. Saehkar, Area Director WiHiaia J. Green Federal Building 600 Arch Street -- Suite 4256 Philadelphia, Pennsylvania 15106 {2151 597-4555/6/7 6549 ;TO:2. { ?n, INDUS Tp.TFS | 2607 Currierland Street j PhiladeIphia, Pennsylvania 19125 3. fc-- 4. 1 ftf S.. 6. TYPE OF A1XGED VIOLATTONCS}: REPEATED 7i * ' H7S a intpcr-tifvn wms made an9/29.30 & 10/7.4 IS 75 of * place of etnptafjrnent located at: & 2607 Cumberland'Sfc.> Phila., PAandfagibri m fallow 9- lead chemical producer On die basis of the inspection it is alleged that you have violated the Occupational Safety and Health Act of 1970, 29 UJ5.C. 651 el seq., in the following respects: i Item Stan&tn}, regulukw* or section of the Act uik&dSy wohted 12. DcmiplWBoftflapd rioiHWK ,3- Dtobrwbi4> afhgtri nobtKMB Bartbceonectei 29 OFF 1910.1000 formerly 29 CPR 1910.93 rrployees, in the following locations, were exposed to materials listed in fables Z-2 of this section, and their exposures were not limited in accordance with the requirerents of 25 CFP 1910.1000(b). Samples were obtained at the breathing rone of the em ployees s a) Oxide Department -- millman b) Building 9 -- Packer *13 and Blender #3 .c) Building 2 -- Plash Drier Packer #5 Subrdssior O* a de tailed pi? for long term abat* r.ent to b< subrsi tted to the Art Director ; the above address b; January 2 1976 d) Building 2 .-- Packer fl _ e) Building 2 -- continuous Drier Operator Complete batcm.cut. .Tune 22,1 f) Building 18 -- Blender f2 g) Building 18 -- Packer #12 Employees at the preceding locations, a thru g, were exposed to lead in excess of eighthour tiiae-weighted averages. The employer was previously cited for -an alleged violation in Item. Number 1 of the fiUHm WinKnw....l august 28.1973. for this standard. .'. .See. Attachment for .Abatement Peoui remants The law requires that a copy of this citation shall be prominently posted in a conspicuous place at or near each place that an alleged violation referred to In the citation occurred. The citation must remain posted until all alleged violations cited therein are corrected, or for 3 working days*, whichever period is longer. RIGHTS OF EMPLOYEES ': Ajnv employee ta narufcsutn of employm vto believe, that any pariod of time Bard in this citation for the correction of a vioUhon is unreasonable hju the lipf to contest such time for correction by submitting * letter to the UJ>. Department of Labor at the address shown above witnut in working days* oz tee issuance ai tins citation. "No person shall dtzebarge or in any manner dissimulate egainct any employee because such employ,e has filed any tirrmplein or instituted or caused to he instituted any proceeding under or related to this Act or has testified or is about to testify in cud proceeding oc because or the citrate by such employee on behalf of himself or others of any right afforded by this Act." See Ilf (1) of the Occupational Safely and Health Act of 1970. 29 UJS.C. SSI, B60(c)'ll N 27315.02 NL 000041423 Tije issuance o a ciistsoa does net constitute a finding that* violation of the Act has occurred iinlaw these it aiitan? So contest as pfOTfefed for la the Act 'or, if contested, unless the citation is affirmed fey the Occupations*. fety and Heaito Besfew Conunfeskau : ~~ -- TYPES. OF VtOLAHOMS ' iSSESIOGS vioMsoa is one which is not a serious wslafem within the meaning of the Act but which has a (fixed immediate refetoashto to ogcgpational safety and health. RfOCS vioiaEtoa,. ncwrfing to the Act,. "shell be deemed to ezfrfc in a place of employment if there is a suhstan1 probability that death ce scribes physical! term could result from a condition which exists, cat from one ormate ic&ceSt items, methods, cpsatjans, t| processes -winch haws -been adopted- or axe in use, m such place of employ es tMess the employee did not, and t o u M not -with toe exsms* (treasonable diiigence. Mow of t'ae presence the violation.1* LLrU! violation exists under the Act where the evidence shows (1) that the employer committed an intentional i Imaging violation of too Ad #nd the employer is conscious of the fed that what fee is doing constitutes & violoa eff tos Act, or (2J esedtooisft the effipfossr Was ndfc coasdoudy violating toe Act, h& was Mt that a hasIsui canditiott existed sad jsadfrjw reasonable effort to eliminate the condition. 2SAT2D noJaSaa exists tfmnt the employer has sbated an eadiar violation, fcr which, a citato* was issued, and sa Ir.'.cr iaepadfoa, i> found, to have eommittsdlba same violation. asgonclanca, cr other tones cf coafrnatteaaoa, relators to tola. cBaiba saosdd be directed to toe office shown! the top of front pigs of Sim fona. la corrpondeace, pleasa refer to the OSHA-1 Ho. which appears in the uppt intend co&a: of page of tofr citation. ML 000041424 U.S. DEPARTMENT OF LABOR OCCUPATKJNAI. SAFETY S HEAITH ADMINISTRATION William J* Greene* Jr.* Federal Building Spltef 4^56 - 600 Arch Street Philadelphia, Fenrcsyl-u-ani.e 19106 DATEi December 22, 1975 TO: Mr, Daniel Hurley, Plant Manager KL INDUSTRIES. 2607' Cumberland Street Philadelphia, Pennsylvania 19125 SUBJECT: Attachment to Citation issued December 22, 19751 CSItO #K9638 OSHA-1 Report No- 63 ABATEMENT REQUIREMENT Detailed Plan(s) this detailed plan for the long term program is to in clude feasible engineering and/or administrative controls and a time schedule of pro posed action for each cited item. This plan is to be implemented in accordance with their provisions. .the date by which feasible engineering and/or administra tive controls must be im plemented to reduce the em ployees* exposure to the cited air contaminant to a level not to exceed the respective eight-hour time-weighted averages listed in Table 6-3 or to the employees* exposure to noise levels in excess of those listed in Table 6-16. Until final abatement is achieved, written progress ports should be submitted to Area Director every two months, hist in each progress report the accomplish ments on each cited item. Samnling results of specific operations should be included. N 27315.03 NL 000041425 v.s. ocnutviKNror un Occwpstwnaf Safety a Harry R. Sachlcar, Area Director Ifillian J. Greert Federal. Bui Mint? 600 reh Street -- Suite 4256 Philadelphia, Pennsylvania 19106 Anew 6540 63t [76 (215) 597-4955/6/7 , TO: ,4.Mr. Daniel Hurley, Plant Manaoer * HI. XHDOSTRTEP ) 2607 CuwhsrJ and Street ' Fhiladelnhia, Pennsylvania 19125 I' t ; { * t * object: CStelionfs) for Alleged Occupational Safety and Health Violation!*) J. a* ! a inspection of a place of employment has revealed conditions which we believe do not comply with the provisions f the Occupational Safety and Ifealth Act of 1970, (29 U.S.C. 651 et *}.). The nature of such alleged violtion(s> described in the enclosed citation!*) with references to applicable standards, rules, regulations and provisions of the dd Act These conditions must be corrected on or before the date shown to the right of each alleged violation icrein. he Act requires that a copy of the enclosed eitation(s) be prominently posted "in a conspicuous place upon receipt" : or near each place a violation referred to in the citation occurred. It must remain posted until ait violations cited ierein ate corrected, or foe 3 working days*, whichever period is longer. A sufficient number of copies of the fachcd citatxm(s) should be prepared to permit posting in accordance with the requirements of the Act. The Act 'ovides for penalties for violation of the posting requirements. ou are hereby notified, or will soon be notified, whether or not penalty(ies) will be proposed as a result of the cited oiationts). Tou have the right to contest any or all parts of either the dtationfsf or the proposed penalty) rest Iwfore ie Occupational Safety and Health Review Commission. The Review Commission is an independent agency with ithority to issue decisions regarding ritation(s) and proposed penaity(ies>. If you do contest, you should submit a Iter to' the Area Director at the address shown above within 15 working days* after receipt of the certified mail stive regarding proposed penaltydes); IF you fail to contest within the 15 working day period, the citation)*) and ie peiwHy(hw) as proposed, shall be deemed to be a final order of the Review Commission and not subject to review y any court or agency- art employer Contests the citation, the abatement period specified therein does not begin to run until the date of re Commission's final order in the case PROVIDED the employer initialed his contest in good faith and rtoe solely >r delay or avoidance of penalties. ou have a right to request e discussion with the Area Director concerning any results of the inspection (abatement ires, citations, penallies, etc.). Heme direct correspondence to, or cad, the Area Director at the address shown at w top of this letter. A request for an informal discussion cannot extend the 15 working day period allowed foa ling a notice of contest. Therefore, a request for an informal discussion should he brought to the attention of the rea Director prior to the end of the 15 working days allowed for filing a notice of contest, preferably as soon as assible. n employee or representative of employees may file a notice (letter) to contest the reasonableness of the time ated in the citation for the abatement of the alleged violation(s). Urged violations that are not contested shall be corrected within the abatement period specified in the citation. A illowup inspection may be made for the purpose of ascertaining that toe employer has posted the citation(s) as quired by the Act and corrected the alleged violations. Failure to correct an alleged violation within the abatement iriod may result in further proposed penalties for each day the alleged violation has not been corrected. Timely jrreetkHi of an alleged violation does not affect the initial proposed penalty. direction of alleged violations which have an abatement period of 30 days or less should be resorted in writing to te Area Director promptly upon correction. Reports of corrections should show specific corrective action on each reh alleged violation and the dale of such action, tin alleged violations having an abatement date of more than 30 ivs, a written progress report should be submiUed.each 30 days. The progress report should detail what has been use, what remains to be done, and toe time needed to tolly abate each such violation. When the alleged violation fully abated, the Area Director shank) be so advised. he Act provides that whoever knowingly gives false information is subject to a fine up to $10,000, imprisonment p to 6 months, or botb. you wish additional information, you may direct such request to the undersigned at the address shown above. rider the Occupational Safety and Health Act, the tens "Working Day" means Monday* through Fridays bat does not include SaturSundays; or Fedwsl Holiday*. C$atba|i} Enclosed Quantity Pag<* - ----------- KoitseriotK ._________ i ____ I - 3. j I" " by Area Daector N 27315.04 NL 000041426 Ret Citation K9638 Mo ear Mr. Hurleys After reviewing the information you have thus = far provided concerning employee-exposure to lead in your facility, we are Gtill unsble to adequately evaluate your progress. toward abatement.and the success of your control measures. . Consequently, we are not able'to aVc a rea sonable decision upon your request for extension of abatement. There fore, we request the following information;. Results of blood lead analyses for workers in Buildings 42j 1,16 for the tine period January I, 19?lrco date\, by. Job title onlyi 2. Results of/urine J alyset^coproporpiiyrin measurements,, athj-et4plertee. blood counts for \lNl workers In Buildings 42, 2, 16 and. 18'for the* tine period January 1, 19J6 to date, by Job, title only, , *) V" a Results of personal ini mreaBooMnfiHg saaples (lead) for Buildings 4% 2, 16 and 18 for Jan uary, June and October/1976 and January 1, 1977 through April 1977. r. uif 4. Results of any prophylatic use of jtheiating agents to help reduce blood lead levels its the last two years, with employees' names. ^\~i) 5. A copy of the respirator program for the iPbila delphia plant. ^ ,oL} N 27315.05 NL 000041427 IHiTTHD STATES OF AMERICA occaPKaLoaxL s a f e s t a s d asftiaa r e v ie w c o mmis s io n Sli ISfiOSZSCKS^ 1HC s Mlttoon, : - * : say ma is h a il , s b c e e e a r t o f ia b o r , : liSSXXED STATES DSPASTHEST OF IABOR, OSHRC DOCKET HO. REGION III MOTIOa FOR A FURTHER EHLAHSSMEW? OF TIMS Respondent, Ray Marshall, Secretary of labor. United States Department of Labor, by his attorneys, hereby novas for a, further enlargeaent of tlna withIn Which to file pwslhie objection* to Petitioner** Pstltlonfor Modification of i Abatement sate and aa grounds therefor, represents} 1) On April 4, 1977* Respondent submitted a Motion for Enlargement of Time* requesting a 4$ day extension of the period within which to fils possible objections. 2) Sue to aa overload of eases, Respondent has detarmined that aa additional thirty f30> daya will ha nacar~y < ? N 27315.06 ML 000041423 Willla* 8. Mt&Bixghltn BnesUn Ssemtazf Occupational Safety and Health Review Coemtssioa 1885 "X* Street, H.W. Washington, D.C. 20005 Bet SI. Industries, me. t . Marshall OSBRC Docket He, _______, Region XII fscg, so. 20531 Deer Mr. Mclasghlim Enclosed please find the original of the Secretary*s Motion for a Further aOsigesent of Use. As ehown on the Certificate of Servlco attached thereto, a copy of the Motion has this day been forwarded to tbfc Peti tioner. Very truly yours, / Marshall. H. Barrie Regional. Solicitor Enclosure - Original of Motion SOI.:RHK:raJ i/ces D. V. Burley, Plant Manager - HI. Industries, Inc. CERTIFIED KMX___________ RETORH RBCEEPf REQUESTED j i i i N 27315.07 NL 000041430 j j U^^AItlKlMTOPUflOfr [C5HONO. OcuitDiiwiid kftfy il H--lfc MWtftiiHitfW* rr. ~r-Harry s. Kachkar, Trca Director- I X9636 1 am.* T-Tiljiart .T, creen Federal Bull cine 600 Arch Street -- Suite 4256 1 6549 Philadelphia, Pennsylvania 19106 e$K*twa . FT PSCG3lO.M 76 3 L_ {215} 12-**r. Daniel Hurley, Plant ^snaoer i !TL TKrmzTRTFS * 2607 CtPnherland Street | Philadelphia, PenneyIvania 19125 u. 597-4955/6/7 < I l -J 3. Pvt Decepher 22, 3 975 THESE 5 NO REQUIREHEKT THAT TWJNOTIRCATtON BE SQSTEJS. NOTIFICATION OF PROPOSED PENALTY This notification and the penaltyU*> proposed fey the Secretary of Labor shall be deemed to fee the final cider of the Occupation^ Safety and HcdtB Review CoooiiSioo (am >drcndewl *cacy with |s i?tv*Wu nrtftcMf citations mdft&pciS+d KwdftW 4 not su^err TO ty aaf emit or |cy witUft 1J o&iej! days frdta tbe 4t of receipt of tins ratification* you sateit a Itttti oftonttsti Tic kffrf ccntttt afetnfd fee naued w edenrixe ddivntd so (M AfttBatwar feelow lt tit address shown at tie top of litis notification. If so notice of contest is filed within tfee 1$ wotkwg day period the proposed proally lies) becomes final sad is iistatdistcly payable* Payment of all penalties sb* Is o fee iatk fer check or money ordtc payable to die oedet cf *<Octajiiood Safety and HetldWaW", Payment of penalties should fee testiued U the Area Director at the address dovn above. Section I7tt> of the Act states: "Citil penalties eered uadcr this Acr shaft fee paid into the Treasury of the Hasted States sad shall acttec tu the United States and xsity fee tecoveicd is a civil actios in die name of the United Stases brought in the United States district conn for the district where the violation is alleged to have occurred or where the tapltytt has its principal office-"* r __ j On the 22** ^ day of F)6CeTnhfif _____ . - 19-2.5* ctaioa(*) was issued to yon in accordance with the pcovisio&s of Section $$a) of the Occupational Safety sod Health Act of 1970 (84 Sen. Iffilt 29 USX. 6H* n fc*q-) fecteiaaftet tefestd to as the Ac t . Ywvt Aw notified cf certain alleged violations of the Act, a* specified in that riuUM^tb Y'O? ARE HEKEHY.KOT1i'lFl> Aw jsnwwt t tit pwriswac ef SecttM 16(*) of the Ati, Or ptwh^jrri set forth below is/ ate feeing proposed, based no the citations). 5- 5A. C-itaHon No. l PKPPATED 5B. item Kb , i VIOLATIONS 50 -------------- P^Mej Penalty $135.00 6. GA, Citation So, 6B, {ten No. VIOLATIONS 6C. Proposed Penalty .{ jj Total Proposed Penalty for [i /tl Vis.U.tlacs N 27315.08 NL 000041431 t 135.00_______ l j ! OeXOPATTOStAlt ****** ft HttW-ftDMWmniDMf-' V5 T ' ' -. V .{ , Py~ . , .Tr-. ? P-' -prY; L p-; 11 <p7-,;j ;j-5 - i. ~i.y .. ':i ppp , - i - >3 July 14, 1976 Mr. tone! H. Hurley, Plant Manager UL Industries, Incorporated industrial Cheat cals Division 2555 Are lingo Avenue Philadelphia, PA 19125 . Re: Citation K9638 Mo. 63, De-csaber 22, 19?5. Dear .Mr. Hurley: As eulhorized_hy 29 CFR Section i9Q3.14a{b}{3}, ynnr .ilwp;nr^r-cfL_ petition. for modification of nbatrent dale. .Hail'd June 22, 1976, for the violation alleged by Itc Mo. 1 of the above captioned Citation has teen approved. The abatersent date has been modified as follows: iten_Rft. Date By Hhich Violation, Must Be Corrected HAS53-S. SACHKAR Area Director /Isa JUL l 5 B?6 Jl U__1* ` - ----- N 27315.09 NL 000041432 order for a proper evaluation to ba Bade of Petitioner'* plane. * 3J A careful evaluation 1* essential to afford Peti tioner* a eaplejem adequate protection under the Act. Respondent's Plant Manager, D. V, Burley, baa been contacted and baa no objection to the requested extension. " WffiHEPCfR, counsel for the Secretary of labor respect fully request* a 30 day enlargement of the time period, until June 19, 1977, within which to file possible objections to accordance with Coassiasion Rule 3%. Post Office Address: Marshall B. Harris Regional Solicitor If. S. Department of labor 14480 a&teway Building: 3535 Market Street Philadelphia, PA 1910% (215) 596-1326 /a/ Carlo Ann clans* CarIn Ann Clauss Solicitor of-Labor /*/ Marshall IE. Barrt* Marshall H. Harris Regional solicitor /*/ Regina H. Rnasak Regina M. Koasek Attomsy IfflITED STATES DEPARTHERT OP LABOR Attorneys for Respondent. 1 N 27315.1 NL 000041433 CERTIFICATE OT SERVICE I, Stephen K. Ernst, hereby certify that I eerved the Secretary's Motion for an Enlargensnt of * b* mailing true copy thereof. In a government envelope* postage prepaid, by certified mall, return receipt requested, to the following! April 4, 1977 D. 9m Hurley, Plant Manager Industrial Chemical* Division lO. industries, Inc. Araningo Avenue Philadelphia, PA 19125 ! M Stephen E. groat Stephen K. Ernst Regional Counsel , { | i N 27315.11 NL 000041434 / uQ UJS.C. 651 et 50?., in the foltowiftgrespects: U. S^niLud,Rg^!ion r >r section <*. t3vs Act E$l*tdty vroSitwl 12. Description of aBsgcd vfofe&tt ^ Dtisb'/vlod) j Kites* fee | 29 CFP. 1910.1000 Employees, in the following .locations, were *Subm-ission formerly exposed to materials listed in Tables S--2 of a de 29 CFR 1910.93 of this section, and their exposures were tailed plat not limited in accordance with the require for long ments of 29 CFR 1910.1000(b). Samples were term abate- obtained at the breathing zone of the em Kent to be ployees : submitted to the Ares a}_ Oxide Department -- millnan Director i the above b} Building 9 -- Packer #13-and Blender #3 address by- January 22 c) Building 2 *- Flash Drier Packer #5 1976 d) Building 2 --> Packer #1 e). Building 2 -- continuous Drier Operator Complete abatenenfc h> June 22,13' i f). Building 18 --r Blender #2 g| Building 18 -- Packer #12 Employees at the preceding locations, a thru g, were exposed to lead in excess of eighthour time-weighted averages. The employer was previously cited for an alleged violation, in Xtem Humber 1 of the Citation Dumber 1 issued Augusfc?28,lS73, for this standard. ft *-+-/! r*for,,o'*v! -rrvr- vrir'^T* tl*? The law req-uires that a copy of this citation shall be prominently posted in a conspicuous place at or nest ch place that an alleged violation referred io in the citation occurred. The citation must remain posted until ell violations citftd therein are corrected, or for 3 ivorkirij; days*, whichever period is longer. 1' " "illGHTS-OF iaiMOYEES A-iy rtnpltfyr^ tfipresajitativ, v* emjshvyses T^frc> rf-i-rvi-. ifcat cny period of tlroe firni - ' cttatloa for the oorr-entlao t> u v.nr.'3ton>w' hax the xM fco confdvi tuch tine ior <x)eciton t*y sabnitHtj 3 Itit-ec td of libor j e 1 | v; tutaeu 10 1 JjAfill J-i- X v- rfeht cjfwdsd i>F fh>* .Act.'* life) | N 27315.12 NL 000041436 CEHTIFICATE OF SESgXCB I, Eeglna X. Eoseefc, hereby certify that i served the Secretary** JSafcion for Purther Biltrgeaent of Tina, by stalling a tree copy thereof. In a goveraaent envelope, postage prepaid, by certified nail, return receipt requested, to the followings B. X, Burley, Plant Manager Industrial Chenieals Division XL Industrlee, Ine. 25^5 Araalngo Avenue Philadelphia, PA 19125 Bated: May 2fi, 1977 // Regina M. fonrt Begins M. Koseek / Attorney ?' j 1 j i! t? / `1 i ;1 N 27315.13 HL 000041437