Vanderbilt Chemical Corporation - Murray Division - Executive Summary |
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Risk Management Plan Executive Summary Philosophy & Goal We believe we will prosper by being as responsive to our employees, community and the environment as we are to our customers. Accordingly, our goal is to experience zero injuries, accidents and incidents. In order to meet this goal, we will commit any necessary resource and we empower each employee to use those resources. One such resource is our extensive suite of safety procedures. The core of these procedures is a combination of relevant regulations, industry standards, good engineering practices and best management practices. General Information Vanderbilt Chemical Corp. (VCC) is a specialty manufacturer of organic and organo-metallic lubricant additives, rubber accelerators, registered pesticide active ingredients and paint additives. Many of our primary products belong to the dithiocarbamate family. Some of the products are powders or pellets; others are mineral oil based concentrates or aqueous mixtures or slurri es. Co-products include aqueous solutions of sodium hydrosulfide (NaSH), sodium bisulfite (NaHSO3) and sodium sulfate (NaSO4). The primary liquid reactants include amines, diamines, carbon disulfide, mineral oil, hydrogen peroxide, sulfuric acid, nitric acid, sodium hydroxide, alcohol complexes of dithiophosphoric acid, isopropyl and other alcohol's. We store these materials in aboveground storage tanks (AST's), tank trucks, tank cars, totes and drums. The majority of the AST's are located in the A31 Tank Farm in the eastern portion of the site. We receive dry solid reactants in bulk "super sacks", fiber drums and paper sacks and store them primarily in the A72 Warehouse. These materials include, but are not limited to, metal oxides (e.g., antimony, lead, molybdenum, zinc), oxidizers (e.g., ammonium persulfate), and various minor processing aids and additives. Some of these materials are toxic; some are flammable; and some exhibit both toxic and flammable characteristics. Risk Management Program The risk management rule1 (RMP) applies to certain stationary sources that have more than a threshold quantity of a regulated substance present in their process. The list of regulated substance includes 77 toxic and 63 flammable substances. Vanderbilt's Murray, KY facility is one of these sources. The RMP rule describes three categories of sources and establishes different requirements for each category. The rule considers whether the source: 1. has had an accidental release of a regulated substance with off-site consequences within the last five years, 2. could have an accidental release of a regulated substance could cause off-site consequences, 3. falls into a specific type of industry and 4. is subject to the Occupational Safety & Health Administration's (OSHA's) Process Safety Management rule2 (PSM). Vanderbilt handles two regulated (toxic) substances in greater than threshold amounts and otherwise meets conditions 2, 3 and 4, therefore it is subject to Pro gram 3 requirements. Vanderbilt's Murray facility has not had an accidental release of a regulated substance that resulted in off-site consequences within the last five years The RMP rule requires each affected stationary source to report its 5-year accident history and to determine the off-site consequences of a worst case release for each regulated substance that it handles above the threshold amount. For releases of regulated toxic substances, the rule defines "worst case" as a release whose toxic endpoint reaches the greatest distance from the point of the release under standard weather conditions that do little to dissipate the vapor cloud. The RMP rule defines a unique toxic end point for each regulated substance. Worst case naturally occurs when the largest amount of the substance is spilled and the resulting pool has the largest possible surface area. For releases of regulated flammable substances, the rule defines "worst case" as a release that causes: 1. a fire such tha t a thermal radiation of 5 kW/m2 reaches the greatest distance for 40 seconds or 2. a vapor cloud explosion that results in a blast over-pressure of 1 pound per square inch that reaches the greatest distance from the site of the release. In addition to the worst case scenario, the rule requires each affected facility to include at least one alternate scenario for each regulated substance. The following table lists the RMP regulated substances that apply to Vanderbilt: Covered Regulated Substances RMP Substance Carbon disulfide (CS2) CASRN - 75-15-0 Threshold Amount (lbs) - 20,000 Maximum Amount (lbs) - 105,000 Storage Location - Tank Car Piperidine CASRN - 110-89-4 Threshold Amount (lbs) - 15,000 Maximum Amount (lbs) - 93,150 43,000 Storage Location - Tank 31-407-05 or Tank Truck Accident History Between June 1994 and June 1999, there were no accidents involving RMP substances that had off-site consequences. Weather Conditions After the properties of a substance, the amount released and the surface area of the spill are considered, the prevailing weather conditions are the next order of importance in calculating the consequences of a release. The RMP rule establishes standard "worst case" weather conditions and requires each source to consider these conditions when modeling its worst case releases. In addition to being "worst case", these standard conditions assure that all sources evaluate their scenarios under the same conditions. Facilities may use weather conditions that are appropriate for their location in their alternate scenarios. We chose to use the average conditions as based on the closest National Weather Service station (i.e., Paducah, KY) for all alternate scenarios. The "worst case" and the average conditions follow: Parameter Worst Case Wind Speed - 1.50 m/sec Average Wind Speed - 3.11 m/sec Wind Direction - 180 degrees Worst Case Humidity - 50% Average Wind Speed - 70% Stability Class - F (very stable - night) Average Stability Clas s - D (neutral - day or night Carbon Disulfide (CS2) Scenarios CS2 is toxic and flammable and has a very high vapor pressure. The RMP rule sets a concentration of 160 mg/m3 in air to establish the toxic end point for CS2. We receive this material in 10,000 gallon tank cars and transfer it to one of two 12,500 gallon AST's. From here, we meter out relatively small amounts to vessels in the various process trains. Nitrogen pressure is used to force the CS2 off the rail cars into our AST's. Once in the AST's, we store it under water until it is combined with other ingredients and we transfer it into the process vessels using water pressure. In addition, both AST's are located under water to ensure that any accidental release from a tank will be protected. We have always used this simple, robust safeguard at Murray because it maximizes safety and eliminates evaporative losses to the air. The Division for Air Quality of the Kentucky Environmental Protection Cabinet requires us t o maintain this water cap at all times. In addition to this safeguard, Vanderbilt takes other precautions when handling and storing CS2: 1. using N2 pressure to unload eliminates mechanical pump seals; 2. rail cars must not have bottom valves; 3. all unloading is "over-the-top"; 4. all unloading connections are bolted (no quick coupled hose connections); 5. special unloading and handling instructions and training. The worst case accident under the RMP rule is a spill of the entire contents of a tank car into the area around the rail siding at "worst case" weather conditions. Such an accident would spill 10,000 gallons (105,000 pounds) of CS2 into an unlined stormwater ditch. The resulting evaporating pool would have a surface area of about 5,600 square feet (i.e., 520 m2). In this scenario, the toxic end point occurs 0.86 miles from the center of the release (see below). Carbon Disulfide Consequence Analysis We used DEGADIS+ to model the following off-site consequences for CS2. DEGADIS+ is suitable for modeling releases that result in dense gas dispersions. For reference, the OSHA short term exposure limit (STEL), RMP toxic endpoint and OSHA immediately dangerous to life (IDLH) of carbon disulfide are 30, 160 and 1580 mg/m3, respectively. The down wind distance to the RMP toxic endpoint and OSHA IDLH are: Scenario - Worst case Description - Largest vessel (10,000 gallon tank car) if released into stormwater ditch (520 m2) under worst case weather conditions as defined by RMP rule. Toxic Endpoint - 0.86 mile IDLH Endpoint - 0.27 mile Alternate #1 Description - Largest vessel (10,000 gallon tank car) if released into stormwater ditch (520 m2) under average weather conditions as recorded at Paducah, KY NWS. Toxic Endpoint - 0.50 mile IDLH Endpoint - 0.10 mile Alternate #2 Description - Largest vessel (10,000 gallon tank car) if released into limited stormwater ditch (250 m2) under average weather conditions as recorded at Paducah, KY NWS. Toxic Endpoint - 0.34 mile IDLH Endpoint - 0.10 mile Alternate #3 Description - 20% of largest vessel (2,000 gallons) if released into stormwater ditch (520 m2) under average weather conditions as recorded at Paducah, KY NWS. Toxic Endpoint - 0.34 mile IDLH Endpoint - 0.10 mile Piperidine Scenarios Piperidine is both toxic and flammable and it has a very high vapor pressure. The RMP rule sets a concentration of 22 mg/m3 in air to establish the toxic end point for this material. We receive this material in 6,000 gallon tank trucks and transfer it to a 12,500 gallon AST. From here, we meter out relatively small amounts to process vessels in the various process trains. Piperidine is unloaded either with mechanical pumps or nitrogen pressure. In addition, Vanderbilt takes special precautions when handling and storing Piperidine. The worst case accident under the RMP rule is a spill of the entire contents of a storage tank into the passive secondary containment around the tank installation at "worst case" weather conditions. Such an accident would spill 13,000 gallons (93,150 pounds) of Piperidine. The resulting evaporating pool would have a surface area of about 2,500 square feet (i.e., 230 m2). In this scenario, the toxic end point occurs 0.77 miles from the center of the release (see below). Piperidine Consequence Analysis We used DEGADIS+ to model the following off-site consequences for piperidine. DEGADIS+ is suitable for modeling releases that result in dense gas dispersions. For reference, the OSHA short term exposure limit (STEL), RMP toxic endpoint and OSHA immediately dangerous to life (IDLH) of carbon disulfide are 6.5, 22 and 325 mg/m3, respectively. The down wind distance to the RMP toxic endpoint and OSHA IDLH are: Scenario - Worst case Description - Largest vessel (13,000 gallon tank) if released into dike (230 m2) under worst case weather conditions as defined by RMP rule. Toxic Endpoint - 0.77 mile IDLH Endpoint - 0.13 mile Alternate #1 Descriptio n - Largest vessel (13,000 gallon tank) if released into dike (230 m2) under average weather conditions as recorded at Paducah, KY NWS. Toxic Endpoint - 0.29 mile IDLH Endpoint - 0.08 mile Alternate #3 Description - 20% of largest vessel (2,600 gallons) if released into dike (230 m2) under average weather conditions as recorded at Paducah, KY NWS. Toxic Endpoint - 0.29 mile IDLH Endpoint - 0.08 mile Risk Minimization Measures Process Safety Management (PSM) The Safety and Health Manager is responsible for drafting and maintaining the PSM procedures, for identifying processes that are subject to the PSM rule, for leading hazard assessments of these processes and for ensuring that covered processes are in compliance with the requirements of 29 CFR 1910.119. Some of the individual procedures that relate to PSM are: 1. Process Hazard Analysis 2. Operating Procedures 3. Training 4. Contractor Safety 5. Pre-startup Safety Review 6. Mechanical Integrity (defining the requirement) 7. Ho t Work Permitting 8. Management of Change 9. Incident Investigation 10. Emergency Planning & Response Related Safety and Health Procedures 1. Line Breaking 2. Lock, Tag and Try 3. Permit Required Confined Space Entry Major Hazards At a minimum, the following hazards are considered during a process hazards analysis (PHA): Major Hazard - Description & Discussion Corrosion - Corrosion could lead to equipment failure or failure of structural components that support equipment. Earthquake - Earthquake could cause stress that exceeds normal levels thus resulting in equipment failures. Equipment Failure - Equipment failure could result in releases. Explosion - Explosion could result in the vapor space of vessels thus damaging the affected vessel or surrounding equipment. This could result in a release. Fire - Releases from equipment failure could result in fire. Loss of Utilities - Loss of utilities such as cooling water pumps or draft fans on vessels during an electrical power outage. Over Pressurization - NA Overfilling - Overfilling a vessel could result in a release. Pull-away - Pull-away of connected transportation equipment could result in equipment failure and a release Runaway Reaction - Internal temperature and pressures could exceed safe limits resulting in equipment damage, releases in the work place, fire or explosion Tornadoes - Severe weather could damage equipment and result in a release. Toxic Release - Releases could involve toxic or flammable substances Process Controls in Place - Description & Discussion Alarms - Instruments for critical parameters activate alarms when parameters go out of range Automatic Shutoffs - Critical valves that fail-safe during loss of power. Check Valves - Limit flow to one direction in critical systems Grounding and Bonding - Equipment, including transportation equipment, is grounded and bonded to equalize electrical charges thus preventing electrical discharges (e.g., sparks, arcs, etc.) Interlocks - Critical valves are interlocked to prevent materials from being charged to unexpected locations. Hose stations are used at critical junctures to limit material flow to desired locations. Manual Shutoffs - Manual shutoff valves and double block-and-bleed arrangements are installed to isolate some vessels. Procedures - Written procedures, including Management of Change Procedures, are used to communicate desired actions, normal and extreme operating parameters and cautions to operations personnel. Purge System - Equipment that could have unwanted atmospheres in the vapor space is purged to scrubbers to eliminate associated hazards. Relief Valves - Relief valves and rupture disks are provided on process vessels to relieve excessive pressure. Scrubbers - Air scrubbers are used to control releases of toxic and flammable vapors from critical process and storage vessels. Vents - Vents are provided on critical process and storage vessels to limit and equalize excessive pressure. Mitigation Systems - Descr iption & Discussion Deluge System - Process areas are protected by deluge fire protection systems. Enclosure - All process systems are located inside curbed areas. These containment structures are designed to limit releases to soil and surface water. Fire walls - Process buildings are constructed with fire walls designed to provide protection to personnel and nearby equipment during fires. Neutralization - The pH of certain substances can be neutralized after a release to minimize the affects of pH extremes Secondary Containment - Dikes protect all hazardous substance storage tanks. These containment structures are designed to limit releases to soil and surface water. Sprinkler Systems - See deluge systems Monitoring & Detection Systems - Description & Discussion H2S Perimeter detectors - H2S detectors are located around the perimeter where H2S can be present in the process. Pressure - (see alarms) Temperature - (see alarms) Training Both the Safety and Health Manager and the E nvironmental Manager are responsible for conducting initial and periodic (e.g., annual) training in their respective areas for all employees. This training stresses fundamental safety, hazardous waste regulations, pollution prevention and spill/release response. The Maintenance and Engineering Manager is responsible for: 1. documenting and communicating the proper operation of process equipment, including changes to that equipment; 2. ensuring that maintenance personnel are trained and competent to perform their duties; 3. ensuring that maintenance and construction contractors' personnel are trained and competent to perform their duties and that they are oriented to the facility's safety, health and environmental procedures. Operation's management and line supervision is responsible for: 1. documenting and communicating job specific training to all operations personnel; 2. documenting and communicating changes in standard operating procedures to all operations personnel; 3. design ing, conducting and evaluating job-specific training; 4. initiating all operations related management-of-change documentation; 5. ensuring that all changes in safety, environmental and technical information or requirements are communicated to all operations personnel. Job specific operator training is conducted in progressive steps and each candidate must demonstrate understanding of each step both in writing and through on-the-job performance before he may advance to the next step. To ensure that training is adequately understood, trainees must, at a minimum, take and pass written tests. Competency for more complex subjects (e.g., critical crafts, like welding, and assessments of critical process equipment) is usually demonstrated both in the class room by written or oral tests and on the job by observation and evaluation. Management of Change (MOC) The Safety and Health Manager is responsible for the overall management of change (MOC) procedure, including new chemical approval, changes to process procedures and the like. The Maintenance and Engineering Manager is responsible for a subset of the MOC that deals with equipment, including new equipment, revisions to existing equipment and systems, and maintenance of equipment. The MOC procedure requires that all staff managers (safety, environmental, quality, etc.) and selected operations personnel review and approve all new and revised equipment, procedures or materials, and that all changes be communicated to each affected employees. Equipment Integrity - Design/Construction/Installation The Maintenance and Engineering Manager is responsible for ensuring that the design, construction, installation and integrity of all facility equipment is suitable for the intended function and operating environment. He is further responsible for ensuring that all equipment and its installation meet regulatory and industry standards (e.g., API, NFPA, NEMA, etc.). Only equipment that meets all applicable requirements and i s compatible with the materials to be stored or processed shall be chosen. All storage and process equipment shall be installed inside secondary containment that is adequate to contain all spills (see below). Secondary Containment Requirements Secondary containment means a man made structure whose purpose is to contain spills and releases from storage tanks and process areas. Examples of secondary containment are: 1. curbs, floor trenches in process areas, 2. sumps, if they are reserved exclusively for spill containment, 3. dikes or berms around storage tanks, 4. gates on drainage ditches near remote unloading/loading areas. All secondary containment constructed after the effective date of this plan shall: 1. be made of concrete, 2. sized to hold the volume of the largest vessel (or manifolded vessels) plus enough freeboard to allow for a 24-hour 25-year precipitation event (e.g., 6.5 inches)3, 3. be configured to prevent a release in the event of a catastrophic tank failure (i. e., to prevent slop over), and 4. shall contain a manual valve to drain collected stormwater If two or more tanks can be plumbed together, the total volume of all tanks so connected must be considered instead of the single largest tank. Earthen berms currently serve as secondary containment for groups of one, two or three storage tanks in the Area 31 Tank Farm and for two (of three) fuel oil tanks at the Boiler House. These berms will hold spilled materials long enough (e.g., at least 24 hours) to prevent runoff and to allow for recovery. Concrete dikes currently surround the three tanks adjacent to Process Area 21, one of the three fuel oil tanks, the Hydrogen Peroxide Tank and many of the process tanks in or adjacent to process areas (e.g., process and intermediate tanks immediately adjacent to the Area 10). Concrete floors and either concrete dikes or curbs and floor trenches, or both protect process areas, as well as specific storage tanks in process areas. These engineered st ructures are intended to trap spills, aid in the recovery of spills and to prevent spilled materials from migrating into the environment long enough (e.g., at least 24 hours) to allow recovery. Containment structures of both types trap storm water. This water must be inspected and sampled by a Utility Operator and tested by the on-site Laboratory before it may be discharged. Stormwater release procedures are addressed in the written work instructions of the Utility Operator. Finally, spill control and clean-up supplies (e.g., sorbent clay, pads and booms) are maintained on site to control the types of spills discussed in the Hazard Assessment section. Preventive Maintenance (PM) The Maintenance & Engineering manager is responsible for conducting preventive maintenance and inspection pursuant to 29 CFR 1910.119 (i.e., Process Safety Management). Inspections We practice three levels of inspection. The most common type is a visual observation and is made routinely by operating an d maintenance personnel during the course of carrying out their daily duties. In certain high risk material transfers (e.g., carbon disulfide and hydrazine), we use only bolted fittings when unloading transportation vessels and we pressure check the piping system before each transfer. The second is a simple visual inspection conducted periodically by engineering or other trained personnel. For example, engineering staff might be assigned to visually inspect process equipment for signs of corrosion, cracks, etc. For another example, Environmental Operators observe all major storage and operating equipment, dikes, etc. during a weekly "RCRA" inspection. The third, and highest, degree of inspection is a detailed engineering assessment of tanks, vessels and structures. These assessments are conducted by, or under the supervision, of a competent engineer who is knowledgeable in the field. Such assessments include thickness measurements on storage tanks and the structural components o f tanks and buildings. The results of all assessments conducted on in-service equipment in recent year's leads us to believe that our tanks and structures are sound and fit for their present duty. The Engineering Department is in the process of developing a written program to formalize these procedures. Finally, we conduct tank tightness tests (c. annually) on Carbon Disulfide (CS2) storage tanks because they are not visually accessible as other AST's. At this facility, all RMP regulated substances are raw materials. The raw material suppliers are responsible for selecting carriers who will transport these materials to the facility. In turn, these carriers are responsible for selecting, maintaining and inspecting their equipment according to applicable DOT hazardous materials rules. DOT has an elaborate set of rules that govern all aspects of the transportation of hazardous materials. Attention to these rules ensures that transportation equipment is both suitable for the purpos e and sound. Procedures & Work Instructions Operation's management is responsible for drafting written work instructions and operating procedures to ensure quality, safety, pollution prevention and environmental compliance. Each written procedure includes general spill and release response instructions. All such instructions and procedures, including changes and revisions, are reviewed by staff functions, including Quality, Safety and Health, and Environmental Managers. Special Considerations Employee Involvement We do not have a formal, written employee involvement plan however, we do have a formal safety advisory committee made up of employees from all departments and we involve operations and maintenance employees in all process hazards analysis's, incident investigations, emergency response program reviews, and so on. Emergency Response Team Our in-house emergency response team is trained to the structural fire brigade level4 and to HAZWOPER's hazardous materials technici an level5. Loading/Unloading Procedures Trained and experienced personnel carry out material transfer activities according to detailed written work procedures. These procedures are developed and maintained (1) by experienced operation's management, (2) with oversight by both the Safety and Environmental Managers and (3) take into account the guidance in 49 CFR 177 Subpart B (see Section IV - Attachments). The goals of these procedures are (1) personnel safety, (2) protection of public health and the environment and (3) conservation of valuable resources by the elimination of spills and releases from transfer operations. These procedures are incorporated into this plan by reference only. Most bulk liquids are unloaded from tank cars and tank trucks to aboveground storage tanks via reinforced flexible hoses that are connected between the transport vessels and the facility's piping system. In most of these cases, the hoses are equipped with quick couplings, but only bolted hose co nnections are used for normal transfers of extremely hazardous chemicals (e.g., carbon disulfide and hydrazine). Exceptions to the bolted hose rule require approval and oversight by both the Safety and Environmental Managers in conjunction with a senior Operation's Supervisor. Low pressure Nitrogen (N2) is used to transfer low viscosity materials, especially those that present extreme fire hazards, whenever possible. Pumps are used in other cases or when the transportation vessel does not support pressured transfers. Bulk liquid products are loaded in much the same manner. Security The Safety and Health Manager is responsible for establishing the plant's security. He ensures that a Security Guard screens all visitors to the plant during normal business hours. Among other things, the Security Guard ensures that each person entering the facility through his station is equipped with the required personal protective equipment and that he has received the required annual briefing re garding: 1. hazards present at the facility, 2. policies, procedures and work rules, 3. emergency procedures. The Safety and Health Manager also reviews the safety and health programs of each contractor and ensures that they periodically demonstrate adequate insurance coverage. Incident Reporting The incident report system is the core of the facility's safety, health and environmental protection. This system ensures that all incidents, regardless of severity, are reviewed at the highest levels of the organization. All incidents (e.g., accidents, injuries, chemical exposures, fires, explosions, releases, spills, leaks, malfunctions, deviations from normal expected operating parameters and near misses), regardless of severity, must be reported in writing by the affected employee before the end of his shift. In the event of a release that can not be controlled, that threatens safety on-site or that presents an imminent and substantial threat to the community, the Foreman will immedi ately summon help by dialing 911. Afterward he will initiate an evacuation of the site and will notify the emergency management team. Otherwise, in the event of a release of any amount of any chemical anywhere, anytime (including an odor complaint), the Foreman will immediately notify the Duty Supervisor of the incident and then he will attend to the release with the resources available. The Duty Supervisor must then immediately notify the Environmental Manager followed by the General Manager and the rest of the GM's staff. The Environmental Manager must evaluate the incident and, if required, make all necessary agency notifications. This procedure is documented in the facility's Integrated Contingency Plan. Each incident report must be distributed to the staff by the next normal business day. Each report is discussed during the semi-weekly staff meeting. At this time, a suitable corrective action is determined and responsibility for implementing that corrective action is assig ned. After the corrective action is complete, each report must be closed in writing. The Safety and Health Manager or the Environmental Manager, or their designates, alone are authorized to close incidents that involve fire or explosion. The Environmental Manager, or his designate, is authorized to close any incident that involves a release, including odor complaints. The Safety and Health Manager, or his designate, alone is authorized to close all other incidents. All incident reports are posted so that each employee has a chance to learn from the incident. Integrated Contingency Plan (ICP) The facility has prepared a contingency plan to help it report and respond to spills and releases. Such plans are driven by both prevention and response goals and have long been required by specific environmental statutes and regulation: 1. KAR 5:037 - Groundwater Protection 2. KAR 34:040 - Waste Management Standards 3. KRS 224.877 & KRS 224.01-400 - Release Reporting & Cleanup 4. KRS 39.88 0 - Mandatory Release Reporting 5. PL 99-499 - Mandatory Release Reporting 6. 40 CFR 68 - Risk Management Programs (CAAA of 1990), 7. 40 CFR 112 - Spill Prevention, Control and Countermeasures (CWA), 8. 40 CFR 117 - Notification Requirements (CWA), 9. 40 CFR 264 - Hazardous Waste Management (RCRA), 10. 40 CFR 302 - Notification Requirements (CERCLA), 11. 40 CFR 355 - Emergency Release Notifications (SARA, EPCRA), 12. 40 CFR 194 - Facility Response Plans (OPA of 1990). This plan addresses the essential environmental protection elements of the National Response Team's Integrated Contingency Plan guidance6 and incorporates the facility's overall Emergency Response Plan (ERP) and other written safety plans and programs by reference. The Safety Manager is responsible for the ERP. The Environmental Manager is responsible for the ICP. The contingency plan may also be used as a tool to help facilities identifying and reducing risk associated with hazardous substances. Footnotes: 1 40 CFR 68 Subpart B 2 29 CFR 1910.119 3 Dr. Glen Conner (State Climatologist for KY, Western Ky Univ.) 3-31-99 4 29 CFR 1910.156 5 29 CFR 1910.120 6 61 FR 28642 |