Document wD3wxvvaZr9rp08g74NoRkZdV

ABDOO122079 Clyde Payne, Area Director Occupational Safety & Health Administration Jackson Area Office 3780 1-55 North, Suite 210 Jackson, Mississippi 39211-6323 Dear Mr. Payne: We have received your letter dated October 24, 1994, and have reviewed the alleged violations. This letter is intended to answer questions related to the alleged violations. As a point of information, Mr. Chris Turner has been reassigned to other responsibilities and I, Paul J. Kober, am the current Plant Manager of the Aberdeen facility. Based on the specific nature of that these alleged violations disgruntled, employee. the alleged violations, are the effects of we believe a former, For the specific case we feel is in question, the employee was treated and/or evaluated by 2 General Practitioners, 1 General Surgeon, and 2 Neuro Surgeons. This exhaustive effort was carried out to satisfy the concerns of the employee and to ensure that the best possible medical care was provided. In all cases of occupational injury, the Vista Chemical Aberdeen Plant takes an active role to ensure the employee receives prompt and appropriate medical treatment. Vista makes every effort to work with the treating physician(s) to ensure the prescribed treatments and restrictions are carried out completely. In cases where restricted work activity is permitted by the physician, Vista accommodates these restrictions while providing productive work for the employee. In the Vista Aberdeen facility, insulating materials have been surveyed to determine where asbestos does and does not exist. Lines insulated with asbestos containing insulation are identified by a yellow stripe painted on the sheathing, or a red / orange tag with an asbestos sticker. All asbestos insulation, including the asbestos insulation in the Pi building, has been encapsulated to prevent the possibility of exposure. Where asbestos removal is required, this work is performed by qualified personnel, under the supervision of a trained and qualified supervisor of asbestos abatement. ABDOO122080 To provide verification that the asbestos insulation does not pose a threat for exposure, we have conducted area air sampling in the P-1 building. Six 8 hr. samples were collected over a three day period. The result of this monitoring are as follows: November 2, November 2, November 3, November 3, November 4, November 4, 1994 1994 1994 1994 1994 1994 P-1 P-1 P-1 P-1 P-1 P-1 Second Floor First Floor Second Floor First Floor Second Floor First Floor <.004 <.004 <.004 <.004 <.004 <.004 fibers/cc fibers/cc fibers/cc fibers/cc fibers/cc fibers/cc A 20% caustic solution is used in the Pi building. This material is transferred into a small day tank (approx. 125 gal.) where it is then piped to reactors as needed. When leaks develop in the piping system, the area operator is responsible for initiating a work order for repair. Repairs of this nature are given priority and personal protective equipment is required. The Pi building is a two story structure and is well ventilated. In the process area, each floor has three ventilation fans to provide air exchange. The second floor has an additional ceiling exhaust fan located directly above the caustic day tank. The first floor contains two catch tanks which are provided with their own powered ventilation system. Photographs of the P-1 area are attached to provide a better understanding of the work environment. These photographs show the typical ventilation fans for the P-1 building, the condition of piping in P-1, the condition of insulating materials in P-1, and the methods of identifying asbestos containing insulation. In summary, we believe that the alleged violations are baseless and untrue. The Vista Chemical Aberdeen facility is committed to the safety and health of all persons working within the facility. Paul J. Kober Plant Manager Vista Chemical - Aberdeen, MS