The outside operator and chief lead operator immediately discovered that the cause of the noise was from the reactor atmospheric vent valve.

In such situations, the Area Director, in appropriate circumstances and after consulting with the Regional Administrator, may issue citations to both the exposing employer(s) and the controlling employer(s) Moreover, in rare instances, the Area Director, after consulting with the Regional Administrator, may issue citations to the controlling employer in addition to or instead of the exposing employer if in his/her judgment the circumstances in a particu lar case are such that the citations would lead to more effective abatement of the hazard(s). / Thorne G.

The "survey method", as Conoco did, where all monitoring is done over a short period of time, or routine sampling, as is done for VCM and lead.

STACK LAND OFFSITE SECOND TOTAL OFFSITE OFFSITE ANTIMONY 00 BARIUM 00 CAUSTIC DI-N-Octyl Phthalate 0 0 0 0 00 00 0 17* 0 0 863.5(2) 3 (3) 1 (9) 863.5(1) 61(2) 264(6) 2(3) 61(1) 00 6460(4) 72184(5) 326(9) 1731 388 * 0 78970 LEAD 07 00 METHANOL 1-499 0 00 PHTHALIC 00 ANHYDRIDE 00 SODIUM SULFATE 0 0 148,276 0 3018(2) 30(3) 4(9) 0 1932(7) 3018(1) 0 0 00 6070* 0 1932 0 SULFURIC ACID 0 0 VCM(8) 3008* 73,554* 00 0* 0 00 00 0 0 (1) Empty Bags (Sent to Monroe County Landfill) (2) Empty Bags (Sent to Chem.

Any further information or materials related to performance tests lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Further, upon information and belief, Abex discontinued the manufacture and sale of asbestos-containing friction products m 1987 and no longer operates any friction product manufacturing facilities There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the penod Abex manufactured and sold friction products -108-

. % VCM Lead Antimony Total Particulates 96 91.4 10 100.0 10 100.0 9 100.0 9 '8.6 0 '0 00 00 OVEREXPOSURES: Job Class Exposure Source Chief Operator 1.1* ppm, VCM Employee unplugged drain on 702 tank, emission recovery system.

It cannot be over emphasized that the products going to customers must be free from fibrous particles that could lead to any type of complaint.

However, given their understandable interest in completing their project, I have suggested that their effort continue apace, unless and until they receive some other signal from those leading the Risk Characterization effort.

Leading the discussion will be Dr.

Bob Flanagan is chasing down some other leads, but it will be some time before we know if these will prove acceptable.

Determinants of exposure are the factors that relate to the release, dispersal or contact with study chemicals leading to exposure of workers.

The lead operator is responsible for the safe, efficient, and environmentally sound operation of this unit.

The attachments reflect information collected during the meetings which will hopefully clear up some misunderstanding with respect to breathing air use on the rack and' lead to the improved operation of BL-410.

Certain of the data, specifically, those concerned with particulate lead in the ambient atmosphere,have been expressed in the conventional manner.

SAFETY * A lead check was performed on Tank S-42