Document zQy3Bykkgm518NjB76YBQLg6g

interoffice Communication TO: Distribution FROM: DATE: SUBJ: T. G. Grumbles June 13, 1991 SAFETY AND HEALTH AUDIT MODULES XF:---- Qgsl ------ Attached are the reworked modules for your review. Please give a detailed review to "your" modules, but also review others for obvious problems. Specifically, I had some questions when I assigned verification codes and final points to the modules, so let me know if you see problems or need changes there. Brent has sent you his system introduction part under separate cover. Please review that draft and provide comments back to him directly. I think we need to have a brief description of what the module covers on the cover page for each module. This would be in addition to the title, and the regulatory or other basis for the module. A sample cover page is attached. Please provide the text for these summaries to me (no disc required) directly. The more I reviewed the individual modules, it seemed that a separate medical surveillance module, versus portions in the substance specific standards, would not work. The substance specific standards all have portions that are different and very specific. At this time, I'm proposing we don't do one. Let me know what you think. I am proposing a conference call to discuss the modules, the introduction portions, and what we do next. At that time we can decide if we need to meet. I'll propose an agenda when we get a call set. PLEASE LET ME KNOW YOUR AVAILABILITY ON THE 20TH OR 21ST FOR THE CONFERENCE CALL. T, G. Grumbles dlj 239 Attachment VVV 000006392 Distribution: Mike Lunsford-Okc, Brent White-Bait, K. L. Fogg-LCCP C\o^e: \ Y\^ ^oCLfrvcx V mV Ul_>VnCi,V 'fc'Vs.VAVC ~\but )a4-** i 1b * VV\ C- <L ^ ) s S' J sVvoouO \oo\t anft a r\ pc*V * Corr> /KLAtoA toA*v\o.4 ^ Ia<L. 40 V'tfi Thomas G. Grumbles ior-Ov \~\ O -OtVe.'-^-- VISTA d" ^^ C,U m WXCX.'I. bo~\ => <rr- V-^ ^ Vci-Vo^ cV VW_ Lei. "fijk e. ^r-s Vj VVV 000006383 Environmental Committee Report for the IjCA Board of Directors Meeting May 24, 1991 I- Air Toxics LCA is finalizing comments on the proposed Louisiana Air Toxics Regulations for the DEQ public hearing on Mav 28. 1991 (1:30 p.m. - DNR Mineral Board Room, Baton Rouge, La.)* Written comments must be submitted to DEQ by Mav 31. 1991. Several problems still exist with the proposed air toxics rules that LCA will comment upon in order to seek further changes. The Mid-Continent Oil & Gas Association held several meetings on May 9, 17 and 22, 1991 with other industry groups (including LCA) concerning proposed legislation affecting the state's air toxics program. Mid-Continent has filed several legislative bills that exempt or suspend part or all of the state air toxics program. Mid-Continent plans to schedule some of their bills soon and will be seeking support from other industry groups for their proposed legislation. At our meeting on May 7th the LCA Environmental Committee voiced concern over supporting legislation that completely exempts a part of the regulated community or that suspends the entire air toxics program. LCA has previously supported efforts to encourage DEQ to adopt rules consistent with corresponding federal standards (i.e. the new Clean Air Act). We have also previously objected to portions of the proposed rules that clearly go beyond the existing state air toxics law. Mid-Continent is also considering drafting or amending legislation to suspend only specific portions of the proposed air toxic? rules rather than suspending the entire program. If properly drafted, such legislation could alleviate some of our major concerns or at least force DEQ to consider making further changes to the proposed rules prior to final adoption. The LCA Board is requested to provide guidance as to LCA's position on the proposed legislation, air toxics regulations and public comments. II. Accident Prevention LCA has formed an Ad-Hoc Committee under the LCA Responsible Care Committee to review and develop comments on proposed DEQ "Accident Prevention" rules. The DEQ Citizens Advisory Committee met on April 29, 1991 and agreed to extensively revise an earlier draft of the proposed "Accident Prevention" rules. Another meeting of the DEQ Citizens Advisory Committee has been scheduled for Thursday, Mav 30. 1991 (9 a.m. - DEQ 6th Floor Conference Room) to further discuss the proposed rules. The revised draft was suggested by several industry representatives and it more closely follows existing OSHA and "Responsible Care" requirements. VVV 000006.384