Document zk44gMvZKGZYdMxm1J4dQEd3
Inter-Office Correspondence
To- Distribution*
Date
March 21 , 1 984
From
W. B. Graybi 1 !
Location 36 West
Subiect 1984 Accountability Management Document
Attached is a copy of my 1984 MBO Document for your use. Since a large part of these goals involve teamwork with each of you, I am soliciting your inputs, comments, and cooperation towards their achievement.
W.
/yra
Attachmen t
Distribution
T. G. Brown/W. E. Dean C. P. Blahous J. C. Delgado A. P. Leber R. K. Lee C. R. Reiche/R. T. Rogers R. S:r Sacaltew G. C. Strickler/W. J. Peard/F. C. Ludden D. E. Van Cleef
Form 5Q3-A Wev 3 83
PPG INDUSTRIES ACCOUNTABILITY MANAGEMENT
10B4 GOALS
Group: Incumbent:
Ti tle:
Chemicals W. B. Graybi11 Director, Environmentul Affairs
Reports to: Title:
Functional Report:
1. C. K1imas Director of Operations Chemicals J. L. MacMillan, Vice President - APC R. D. Duncan, Vice President - IC
Accountabi1ityl
Occupational Health and Toxicology - Safety,
Provide for a safe working place and safety awareness for the department employees to keep Chemicals at the top of the safety performance list for similar industries. Protect the health of employees by directing the creation and implementation of well designed occupational health, industrial hygiene, and toxicology programs.
Measures
Goals
Safety - Plant Visits
1) Be aware of and practice all safety rules appropriate for plant visits.
Have no AWC.
Safety - E/A Department
2) Promote safety awareness on and off job. Quarterly safety meetings for department - J. C. Delgado, Chairman.
Compliance With New OSHA Hazards Ruling
3) Direct the activities involved in timely dissemination of toxicity and hazards information to Chemical Group
employees to comply with deadlines.
Operation of RHCC Committee
4) Continue emphasis in RHRC policy formation activities to develop current information. Delegate J. C. Delgado and A. P. Leber -
toxicologist.
W. R. Graybi 11 1984 GoaIs Page 2
Accountability 1 continued
5) TSCA 8(e)
6) F_/A GP&Ps 7) Line Lakes Health Study
5) Develop responses to regulatory authorities on a timely basis (TSCA 8(c) and 8(e)) and comments on regulations. Chair the TSCA 8(e) Review Committee.
6) Keep GPSPs current and meaningful through delegation to Delgado, Lee, and Samel son.
7), Keep focus on Barberton Lime Lake residents' health study results.
8} Engineering Standards Involving
1 ndustrTal Hyqi ene
~
a. Contact DEPA or Mr. Indian bimonthly--J. C. Delgado.
8) Insist that engineering design standards take into account health hazards and industrial hygiene awareness and that ACTs address these issues appropriately.
a. Meet with Central Engineering to review.
9) Industrial Hygiene Audits
b. Review all ACTs.
9) Give overall guidance to the industrial hygiene audit procedures and programs at plants.
t? 10) IPELs
a. Improve response and "fix-it" time.
10} Insist on J. C. Delgado and A. P. Leber keeping IPELs current.
a. Review twice per year.
102679
U. B. Graybill 1984 Goals Page 3 Accountabi 1 i ty I continued 11) Sun Ileal th Modul es
1?) Awareness - Industrial Hyqlone
13) Toxicology
to e* ro1
to CP COP
11) Encourage modernization (computer programs, etc.) of health and hygiene programs.
a. Have Sun Health medical module evalua ted.
b. Expand use of Sun audiometries module as necessary.
12-a) Plan for combined health/safety conference - (See VII 2, pg. 15).
12-b). Increase level of awareness by meeti nqs wi th R. D. (luncan, J. L. MacMillan, and Plant Managers.
(1) Issue accountabi 1 i ty document, statement to plant managers via A. G. DeMarco.
13-a} Oversee and direct the toxicology program to enhance its effective ness and usefulness.
(1) Attend CUT annual review.
(2) Keep Business Units appraised of developments as they occur.
13-b) Further integrate with BTC contract toxicology programs.
(1) Have Dr. Leber attend BTC MBOs.
(2) Consider cross-fertilization.
13-c) Give priority to existing or new products and intermediates that have widest exposure potential--tests.
W. 13. Graybi11 1984 Goals Page 4
Arcnuntabi1ity II
Etonronnental Programs
Minimize the adverse effect of Group activities on the environment by initiating and executing studies and implementing and directing control programs to assure that we achieve or exceed Corporate and regulatory compliance with environmental standards in a prudent manner.
Measures
Goal s
Comments
1} I1PDES Compliance
1-a) Review routinely and help solve NPDES non-compliance situations and re-negotiations at plants.
t (1) Lake Charles, Barberton, and Natrium emphasis.
1-b) Review Lake Charles south plant situation.
2) Communications
2) Improve on effectiveness of coinmunicatons between G.O. and plants.
a. Environmental workshop Lake Charles - October, 1984.
b. Weekly telephone contacts.
3) Notify legal and accounting of any change in environmental related
lawsuits or threats of suits due to incidents.
a. Issue quarterly SEC update questionnaire for all plants.
4) Procedures/Protocol s
4-a) Direct preparation of Environmental Procedures/Protocols {existing and new).
W. R. Graybill 1984 Goals Page 9 Accountabi1ity continued
5) Audi t.s
6) Envi ronmental Programs
4-b) Review at plants with R. J. Samel son.
4- c) Complete balance in 1984.
5- a) Follow-up to properly close all 1981 audits with emphasis on Beauharnois.
(1) Review with plants, legal, Corporate F/A.
5-b) Follow 1184 audits of Beaumont, . Kalium, Lake Charles Plant A, Natrium, and flichigan Oil/Gas.
fl) Confer with Corporate E/A and plants.
(2) Attend at least one plant session.
(3) Direct timely response and closing of audits via R. J. Samel son.
6} Seek ways to modernize the environ mental program area; computer ization, etc. for better productivity.
a. Use solid waste outside site review company to comment on all of our sites as needed.
b. Evaluate Surteco--three modules at Lake Charles.
7) Assure solid waste is disposed of properly.
W. B. Graybill 1904 Goals Page 6
Accountahi1ity II continued
Environmental Programs cont'd
a. R. J. Samelson/J. W. Osheka to inspect biannually.
b. Use contracted site inspection firm. (See 6a, page 5)
8) Try to improve relations with all agencies.
a. Personal contact at EPA offices.
9) Closures, Decommissioning
9-a) Complete RCRA rlnsure of Caribe (close by duly 1).
9-b) Complete Corpus < Insure in 1984.
9-c) Resol ve directive letter on Jersey City chrome lots issue.
9-d)
Provide oversight to Beaumont and Barberton deemimissioning and decontamination.
Id) Underground Water tC
in) Further develop understanding and mitigation plans for underground watt si tuations it ill pi >nt.s and Jersey City, rollow Beaumont and Barberton decommission with groundwater studies as needed.
11) Review and sign-off on all ACTS.
ee90T
12) Re-direct emphasis towards reduced use of landfilling and more on-site
incineration.
a. Lake Charles incinerator
project reactivated towards ACT-1984.
W. B. Graybill 19R4 Goals Pane 7
Accojmtabi'lity II continued
131 Lime Lakes Reclamation
111 Ell SCO - _E 1_ Dorado, Ark (Lake Charles ChioroTi y dr(Tc a rb on Ifes tru c t T o n)
IS} OEPA Consent Order "[TarTTertan"
tfl C* vot*o
& CP je
16) Trade Associations
13-u)
Continue Hiving oversight direction for line lake reclanation program Bar her t on. R. ,1. Sane! son to di red.
13-1)} Onnrterly review with Barberton Engineering, Snell, R. J. Samel son, and Management.
13- c) Get Pilot Plant ACT approved by f April 1--S870M.
14- a ) Complete close-out of EHSCO issue per contract, August, 101(4.
14-b) Have site inspected at least twice in 1984.
IS) Resolve Barberton particulates
consent decree issue - past noncoinpl iance fines.
a. Further discussions with OEPA along with J. MacNealy, Legal , etc.
b. Resolve boiler shutdown dates by April 1.
16-a)
Support activities and evaluate
effectiveness of CIBO and its goals. Represent Chen Group on CIBO.
W. B. Graybi 11 1994 Goals Pago 9
Acconntabi1itv II continued
16-h) Evaluate SMC11A ior our continued support.
(1) lie ITG's reprosontati ve.
(?) Attend appropriate meetings.
(3) Communicate with Hew York Sales Office.
t (4) Review dues history.
16-c) Evaluate PC!C associate member ship during ]904.
{1) Attend annual meeting.
17) Conrdinat' outside interest in Horton mine arid bring to attention nf manauei'ient.
co
o (J\ CP
to c* vo-t1o
CP
W. R. Graybill 19!34 Goals Page 9
Accountability III
Product Safety
Implement and direct the Corporate and Group Product Safety Policies by developing and directing an organization and program to accomplish the objectives of the policy and all regulatory roguirements.
Measures
Goal s
Coninents
1) Product Safety
1) Policy revision oversight to R. K. Lee for updating Chemical Product Safety Policy by second
quarter 19134.
a. Assure imp!emeutation of this with Field Sales inputs.
2) Improve on early involvement of product safety function with Business Unit plans for now products, i.e., Ag. Chemicals and SPU emphasis.
a. Conduct discussions with I. Zinninger, d. P. Luvisi, etc.
3) Lend all necessary assistance to successful introduction of PAC.
b. Stress use of A. 4. Tolmsoff by G. .1. Lazarchik.
4} Make comments as necessary to legislative/regulatory bodies in product safety area that assure good legislation.
a. Work through Gary Wilson, P. M. King.
W. R. Graybi 11
10R4 Goals Pago in
Acoountabi 1 ity IV
Legislation - Regulations* 1 2
Ensure that Corporate, government, and industry environmental arid industrial health standards are met and that the Company's image is enhanced as an environmentally responsible Corporate citizen through the application of the best available expertise, by maintaining a high level of knowledge of the state-of-the-art, and coordinating the input and efforts of the various Group and Corporate functions involved. Improve the working relationship and overall effectiveness of programs involving the joint responsibilities of Environ
mental Affairs and Employee Relations.
Measures
Goal s
Comm'-nts
1) Legislation - RAT, Superfund, Etc. ~~
1). Provide oversight and direction to * inputs to oood environmental legislation:
a. Water - 1ISIA; WPCF; NEDA; Clean Water Act, review of proposed changes.
b. Air Programs - S0CI1A, APCA, NCSA, Clean Air Act, review of proposed changes. (Gary Wilson, P. M. King, R. . Samel son)
c. Solid Waste - Chlorine Institute. (R. J. Sarnelson)
d. Toxicological - CUT, HCSA. (A. P. Leber, Z. G. Bel 1)
2) Comment as necessary on all substantive regulations proposed by EPA affecting chemicals.
a. Work closely with Gary Wilson and C. P. Blahous.
8 9 t0 t
VI. R. Crayhi 11 1DR4 Coals Pago 1 1 Accountjhi1ity IV continued
3) Zero Discharge^
b. (lrqmics ''AT proposals monitor timing for ACTs.
c. 30R questionnaires to plants. Completion on time.
d. Follow new solid waste rules.
e. Follow Superfund rules-- follow re-issuance.
* f. Follow new asbestos rules as it affects chior-alkali.
3) Participate, guide, and review the Lake Charles Zero Discharge RES progress--!!. J. Samel son to take lead role to attend Lake Charles review meetings.
a. Attend at last one plant review meeting.
o va ff'
CP CP
W. B. Grnybi11 1984 Goals Page 12
Accountahi1ity V
Communications; Permi ts
Develop a good communicating and working relationship with the staff of the Corporate Environment, Health and Safety Department to assure close support and agreement of Group and Corporate policies in matters of environment, health, and safety. Develop communicating relationships with appropriate federal and state regulatory and legislative staff groups, provide constructive comment on their environmental activities, and coordinate the receipt of necessary permits and variances. Ensure the clean and sufficient, communication
with the Business Units, Legal, Engineering, Manufacturing, and Research & Development and Sales Distribu tion departments to secure their understanding of Corporate, Group, and regulatory compliance needs.
Measures
Goals
Comments
1) Permits
1)' Continue to work with Central
Engineering and Business Units to help ensure timely involvement in permitting reguirements.
2) Direct permitting of U.S. Potash test facility and commercial plant on timely basis.
a. Oversee Steurns-Rogers, fenixScisson - R. . Samel son.
b. Meet, with Michigan DNR as reguired.
3) Same for new Lake Charles power unit and PAC.
in C
a. Work with ,1. Antil,
R. J. Samel son to submit
application first quarter of
1984.
689^0 t
b. Obtain PAC PTI, PTO by 4/1/84.
W. B. Graybi 11 l'JB'l GoaiIs
Pago n
Arconn tabi1ity V continued
5) Communications - Corporate
R) Comm ini cations - Groun
4) Coordinate the environnontal permitting effort with plants. Law, and Business Units by
involving appropriate contractors (complex situations) and effluent inventories.
5) Participate in Technical and Production Subcommittee meetings and programs and Corporate
f Lnvionment, Health, and Safety meetings to enhance communications
with C. P. Blahous1 function.
6) Continue to input into Corporate
policy formulation in light of Chemical Group policies and practices. Work closely with Corpora to frivi ronnen t. Heal th, and Safety.
7) Issue cony of lf!R4 E/A Goals document to C. P. Rlahous.
B-a) Attend earli APC/IC staff meeting to report on E/A issues.
8-b)
Insist and facilitate good communi cation between departments and Mfg Bus. Units, Law, R/D, Central Engr etc. to maximize effectiveness of E/A.
W. R. Graybill 1984 Goals Pago 14
Accountahi1ity VI
Subordinate - Managers Performs nee--Produe ti vi ty
Maximize the performance and productivity of the maiimpM's addressing environmental, heal Hi, and product
safety programs throughout the Department. Provide effective functional guidance and overs ght to the activities of all principal environmental and industrial hygiene positions at manufacturing plants and terminals.
Measures
Goal s
Common ts
1) Subordinate Development
1) Encourage sharpening of skills by each manager by in-house or outside
, training sessions - develop IDPs.
*
a. Assign IDP action steps to proper MHO.
2) Issue copies of my goal document to E/A staff.
3) Improve on E/A internal communica tions.
a. Optimize new building office effectiveness.
b. Hold two staff meetings per month.
4) Plant Environmental Contacts
eo1 vi) e1
4} Cultivate good working relationship and functional direction with each plant location environmental staff and industrial health/hygiene staff
a. Weekly telephone contacts.
VI. B. Graybi 1 1 1984 Goals
Pago IS
Ar.countahi1 ity VI1
Iriago
Enhance and project the company image as an environmentally aware, technically sound and responsible Corporate citizen.
lie a SCI r es
Goals
Comments
1} Employee Relations Interface
1) Establish and maintain qood coordination and interaction with Employee Relations' safety and health area. Providing oversight, for:
i a.
Reproductive Hazards Policy Development. (RIICC) J. C. Delgado.
b. Health Hazards Assessment J. C. Delgado.
c. Employee Overexposure Hotificntion--Inplomentation J. C. Delgado.
d. Health Area Practice Audits J. C. Delgado.
e. Noise - .1. C. Delgado.
% oto co vD to
3) Image - Media
2) Work closely with Don Van Cleef on planning June, 1984 combined Health Safety Conference Pittsburgh (See I 12a., p. 3).
3) Provide direction to response to media and citzens' inquiry on en vironmental issues; work closely with Public Relations.
W. B. Graybill 1984 Goals Page 16 Accountability VII continued
Image - Media cont'd
5) Image - Agencies
a. IJ. S. Pot-ash pormi tti ng.
b. Barberton mercaptan.
c. Lake Charles VCM SRV lawsuit.
d. Lake Charles underground water issues.
4} Anticipate the level of awareness ( needed by the public and provide direction towards development of Public Relations plans.
5-a)
Provide oversight to all responses
to agency directives and citations by involving legal and the plants.
5-b)
Improve relationships with all agencies wherever possible by direct involvement in meetings.
6 9 ^ oX
to e4
LpJ
U. B. Gra/bi11 1934 Goals Page 17
Accountahi1ity V111 Personal Growth and Deve 1 opinent
Continue personal growth and development for managerial effectiveness in all account, ibi 1 i involvement in appropriate on-joh and off-job activities and development opportunities.
Measures
Goal s
1) Trade Associations
1) Maintain active representation, participation and evaluation in appropriate associations and
committee activities: CIIT, CMA, SOCMA, Cl, GIRO, US I A, HCSA, AIHC, ' PCIC, etc.
2 ) Skills Improvernent
?) Attend appropriate management skills development course in 1934.
a. Review with T. C. Harter by March 15, 19R4.
'!) Read "Inside EPA", Wall Street Journal , Chemical Week, Chemecology,
CMA Hews, Business Week, Chemical Marketing Reporter, and Pesticide Mews, as often as possible.
4) Attend Environmental Regulation Update course, Washington, DC,
May, 1984.
areas through Comments
W. B. Graybill 1984 Goals Page 18
Accountability IX
Comp 1 iance-Equal Employment Opportufii ty Po 1 i cy
Support anfl comply with PPG Industries' Equal Employment Opportunity Policy program and implementation.
Measures
Go a 1 s
Comments
1) EEO
1} Require each manager's awareness and compliance of the EEO policy.
21 Comply with EEO policy and con
tribute to accomplishment of , Group's goals.
3) Mo citations.
v(3SvP' O'
PPG INDUSTRIES, INC. ACCOUNTABILITY MANAGEMENT
4WE GOALS
Group: Incumbent: Title:
Chemicals R. J. Samel son Manager, Environmental Programs
Reports to: W. B. Graybill
Title:
Director,
Environmental Affairs
Accountability I
Promote safety on and off the job, including safe driving, recognition of unsafe conditions and adherence to plant safety rules.
Measures
Goal s
Comments
1. Time lost as a result of job connected accidents.
1. No lost time due to accidents.
2. Safety as a topic of review with staff.
2. At least monthly meetings to emphasize some aspect of safety.
t1
a Ov'f*>
i$m Goals R. J. Samelson Page Two
Accountability II
Assure maximum attention to the solution of problems by maintaining open communicat ions , both internal and external.
Measures
Goals
Comments
1. Proper persons informed of developing problems and situations.
la. No requests for additional copies of memo's from those needing to know.
lb. Staff meetings held on a monthly basis with subordinates.
lc. Environmental workshop held at Barberton in late October.
2. Management kept informed of progress.
2a. Comprehensive monthly reports issued in a timely fashion.
2b. Update reports prepared as required.
2c. BAR prepared for management review in fal1.
2d. All significant nonrompliance situations brought to management attention.
3. Changes to regulations brought to the attention of plants and management.
3a. Rules of significance summarized for plants and management as issued.
3b. Hold monthly meetings with
< Corporate Environmental Affairs
to review status of regulation
and legislative issues.
1984 Goals R. J. Samel son Page Three
Accountability II {continued)
Measures
Goal s
4. Procedures and protocols pre pared for internal plant use.
4a. Complete the revision of existing procedures by July 1.
4b. Complete the writing of new procedures as required by each plant by Dec. 31.
5. Obtain agreement on environ mental priorities.
5a. Participate in environmental priorities review at Lake Charles.
5b. Participate in Beauharnois environmental reviews and give guidance to programs on at least a quarterly basis.
6. Participate in external seminars. 6a. Participate in DNR/LSU hazardous waste seminar if approved by Law Department.
Comments
69^0X
to c*
CO
1984 Goals R. J. Samel son Paqe Four
Accountability III
Assure that operations are able to and do comply with federal, state and local laws and company policies.
Measures
Goals
Comments
1. Number of noncompliance incidents la. Insist on plant performance so
reported to agencies.
that noncompliance with water
permits is maintained at 99" on
a daily basis and 95% on a
monthly basis.
lb. No unreported noncompliance incidents of air pollution control equipment.
lc. No unresolved hazardous waste management incidents.
ld. No PCB noncompliance incidents.
2. Compliance tracking systems installed and operating.
2a. SUNECO system at Lake Charles with four operational modules Permits, NPDES, Events, EIQ.
2b. Evaluate SUNECO performance by end of third quarter.
2c. SUNECO system installed at Natrium tn with three modules by year end. C
3. Responsible NPDES permits issued 3a. Give guidance to the negotiation
for interim BAT/BCT discharges.
of Natrium permit.
69^X
3b. Give guidance to the negotiation of the Lake Charles permit.
3c. Give guidance to the negotiation of the Barberton permit.
SL 102700
1984 Goals R. J. Samelson Page Five
Accountability III (continued) Measures
4. Responsible new facility permits. 4a
4b
4c
5. Responsible 'Part B' permits issued for hazardous waste T-S-D.
6. Responsible closure plans adopted for discontinued RCRA facilities.
7. RCRA noncompliance identified and corrected.
5a 5b 6a
6b 7a
Goal s
Give guidance and direction to Michigan potash test facility permits.
Give guidance and direction to commercial potash facility permitting including EIS preparation.
Participate in permitting of new power facilities at Lake Charles.
Participate in reviewing Lake Charles part B application.
Complete resolution of hazardous waste permit issues at Beaumont.
Give guidance and direction to completion and closure plan negotiation at Puerto Rico by July 1.
Review and guide closure plan for south plant at Lake Charles
Assessment/mitigation programs developed for Lake Charles, Natrium, and Beaumont (groundwater) .
Comments
1984 Goals R. J. Samelson Page Six
Accountability III (continued) Measures
8. Follow-up on audits.
9. PCB Compliance
Goal s
8a Follow close out and response to 1984 Corporate audits.
8b Provide oversight to plants to complete closure of open items as of December 31, 1983.
9a Give guidance to the development of PCB exemption data.
Comments
cn
tolzot
1984 Goals R. J. Samel son Page Seven
Accountability IV
Assure that nonregulated environmental practices meet company policy requirements.
Measures
Goal s
1. Hazardous waste disposal with outside contractors continues to emphasize "least risk".
la. Continue inspections and biannual listing of approved sites. Annual PPG inspections for most used facilities, supplement with contracted inspection reports.
lb. All listed and approved sites inspected by PPG personnel at least every two years, supple ment with contracted inspection reports.
2. Jersey City cleanup satisfac torily negotiated and completed.
2a. Optimum cost/benefit cleanup situation defined.
2b. Agreement reached with Hew Jersey officials and property owners on cleanup scope.
2c. Cleanup contracts awarded and implemented.
3. Puerto Rico cleanup completed. co C
3a. Continue oversight on cleanup activities at Puerto Rico, giving signoff to final nonRCRA closure by July 1.
4. Corpus Christi cleanup completed. 4a. Continue oversight on cleanup activities at Corpus Christi, giving signoff to final closure
by December 31.
Comments
1984 Goals R. J. Samel son Page Eight
Accountability IV (continued) Measures
5. Limelake reclamation meets envi ronmental ob.iecti ves.
6. Groundwater programs continued to provide basis for management response.
%
Goals
5a. Provide oversight and participate in the design of pilot studies and commercial facility and in public relations aspects. Commercial design must be odor free
5b. Motivate marketing aspects of reclamation.
5c. Assure that quarterly reviews are held with management.
6a. Further refine groundwater investigations in limelakes area with emphasis on wells #31 and #32 and the NW quadrant of the study area. Cooperate with GEPA as required.
6b. Define phase III work and implement at Beaumont.
6c. Observe response of withdrawal well at Natrium and define forward program.
6d. Review and give guidance to main plant investigation at Lake Charles. Provide emphasis to keep this program moving.
Comments
^0U 0X
1984 Goals R. J. Samelson Page Nine Accountability IV (continued)
Measures
7. Fugitive mercury emissions controlled at Lake Charles.
8. Mitigaton of unusual incidents.
9. Technical input to PAC program.
10. Establish a beneficial use for the Norton mine.
11. Identify alternate pollution control technology.
Goal s
6e. Follow progress of perchlor cleanup at Lake Charles. Participate in final signoff.
6f. Review and give guidance to groundwater investigation and mitigation programs at Beauharnois.
7a. Phase I mercury game plan taken forward to ACT.
7b. Aquatic life chemical analysis program continued.
8a. Participate in defining azide disposal.
8b. Guide PPG response to external clean-up problems as required.
9a. Provide technical input to PAC to enable a proper marketing and field test effort to be implemented.
10a Provide oversight and participate in examination of potential uses for the mine.
11a Provide guidance to the Lake Charles zero discharge project.
lib Provide emphasis to the completion of incineration studies at Lake Charles..
Comments
1984 Goals R. J. Samel sort Page Ten
Accountability V
Provide technical assistance to the Law Department in support of litigation and regulatory activities.
Measures
Goal s
Comments
Provide assistance as needed on environmental issues.
la. Follow-up inspection to sign-off on hazardous waste disposal at
ENSCO by August 1.
lb. Participate in new litigation as necessary (e.g., BAT regulations).
lc. Participate in final settlement of Barberton SO^ and particulates issues.
Id. Provide input regarding technical issues associated with non-owned hazardous waste sites.
le. Assist in resolving Perchlor spill issues.
If. Assist in the resolution of chrome contamination issues in New Jersey.
SL 102705
1984 Goals R. J. Samelson Page Eleven
Accountability VI
Secure reasonable and responsible regulations through active participation in the regulation development process.
Measures
1. Comment on all substantive regulations proposed by EPA affecting Chemicals.
Goals
la. Comment on organics chemical BAT proposals.
lb. Comment on new solid waste rules.
Comments
lc. Comment on superfund rules.
Id. Comment on new asbestos rules.
le. Continue input into PCB rule development.
% o o
1984 Goals R. J. Samel son Page Twelve
Accountability VII
Contribute to industry positions on regulation, litigation and legislation through participation on trade association committees.
Measures
Goal s
Comments
1. Environmental Programs' personnel participation.
la. Water programs - HSIA, WPCF, NEDA-Clean Water Act.
lb. Participate directly in Chlorine Institute Environ mental Protection Committee.
lc. CMA PCB Panel.
1984 Goals
R. J. Samel son Page Thirteen
Accountabi1ity VIII
Continue personal and professional growth and development.
Measures
Goals
1. Participate in training courses to improve management/professional skills.
Comments
%
vo
_s a CP
1984 Goals R. J. Samel son Page Fourteen
Accountability IX
Apply EEO policy to applicable issues involving staff personnel.
Measures
Goal s
1. Discuss EEO as required with staff and peer groups.
la. No issues involving violation of EEO policy.
Comments